[Federal Register Volume 88, Number 83 (Monday, May 1, 2023)]
[Rules and Regulations]
[Pages 27312-27394]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-08696]
[[Page 27311]]
Vol. 88
Monday,
No. 83
May 1, 2023
Part III
Department of Energy
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10 CFR Parts 429 and 430
Energy Conservation Program: Test Procedure for Fans and Blowers; Final
Rule
Federal Register / Vol. 88, No. 83 / Monday, May 1, 2023 / Rules and
Regulations
[[Page 27312]]
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[EERE-2021-BT-TP-0021]
RIN 1904-AF17
Energy Conservation Program: Test Procedure for Fans and Blowers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
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SUMMARY: The U.S. Department of Energy (``DOE'') establishes a test
procedure for fans and blowers, including air circulating fans, and
incorporates by reference the relevant industry test standards for:
measuring the fan electrical input power and determining the fan energy
index of fans and blowers other than air-circulating fans; and
measuring the fan airflow in cubic feet per minute per watt of electric
power input of air-circulating fans. In this final rule, DOE also
establishes supporting definitions, requirements for alternative
efficiency determination methods, and sampling requirements.
DATES: The effective date of this rule is May 31, 2023. All
representations of energy efficiency and energy use, including those
made on marketing materials and product labels, must be made in
accordance with this test procedure beginning October 30, 2023. To the
extent the test procedure established in this document is required only
for the evaluation and issuance of newly established efficiency
standards, use of the test procedure is not required until the
implementation date of such new standards. The incorporation by
reference of certain materials listed in the rule is approved by the
Director of the Federal Register on May 31, 2023.
ADDRESSES: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at www.regulations.gov.
All documents in the docket are listed in the www.regulations.gov
index. However, not all documents listed in the index may be publicly
available, such as those containing information that is exempt from
public disclosure.
A link to the docket web page can be found at www.regulations.gov/docket/EERE-2021-BT-TP-0021. The docket web page contains instructions
on how to access all documents, including public comments, in the
docket.
For further information on how to review the docket, contact the
Appliance and Equipment Standards Program staff at (202) 287-1445 or by
email: [email protected].
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-2J,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 586-9879. Email: [email protected].
Ms. Amelia Whiting, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC
20585-0121. Telephone: (202) 586-2588. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
DOE incorporates by reference the following industry standards into
10 CFR part 431:
ANSI/AMCA Standard 210-16 (AMCA 210-16), ``Laboratory Methods of
Testing Fans for Certified Aerodynamic Performance Rating,'' August 26,
2016. (Co-published as ASHRAE 51-16).
ANSI/AMCA Standard 214-21 (AMCA 214-21), ``Test Procedure for
Calculating Fan Energy Index for Commercial and Industrial Fans and
Blowers,'' March 1, 2021.
ANSI/AMCA Standard 230-23 (AMCA 230-23), ``Laboratory Methods of
Testing Air Circulating Fans for Rating and Certification,'' February
10, 2023.
ANSI/AMCA Standard 240-15 (AMCA 240-15), ``Laboratory Methods of
Testing Positive Pressure Ventilators for Aerodynamic Performance
Rating,'' May 9, 2015.
Copies of AMCA 210-16, AMCA 214-21, AMCA 230-23, and AMCA 240-15
can be obtained from the Air Movement and Control Association
International (AMCA), 30 West University Drive, Arlington Heights, IL
60004-1893, (847) 394-0150, or by going to www.amca.org.
ISO 5801:2017(E), ``Fans--Performance testing using standardized
airways,'' Third Edition, September 2017.
ISO 80079-36:2016, ``Explosive atmospheres--Part 36: Non-electrical
equipment for explosive atmospheres--Basic method and requirements,''
Edition 1.0, February 2016.
Copies of ISO 5801:2017(E) and ISO 80079-36:2016 can be obtained
from the International Organization for Standardization (ISO), Chemin
de Blandonnet 8, CP 401, 1214 Vernier, Geneva, Switzerland, or by going
to www.iso.org.
UL 705 (UL 705-2022), ``Standard for Safety for Power
Ventilators,'' Edition 7, July 19, 2017 (including revisions through
August 19, 2022).
Copies of UL 705-2022 can be obtained from Underwriters
Laboratories (UL), 333 Pfingsten Road, Northbrook, IL 60062 or
www.shopulstandards.com.
For a further discussion of these standards, see section IV.N of
this document.
Table of Contents
I. Authority and Background
A. Authority
B. Background
II. Synopsis of the Final Rule
III. Discussion
A. General
B. Scope of Applicability
1. Fans and Blowers Inclusions
2. Fans and Blowers Exclusions
3. Embedded Fans and Blowers Exclusions
4. Air Circulating Fans
5. Non-Electric Drivers
6. Replacement Fans and Blowers
7. Material Handling and Heavy Industrial Processing Fans and
Blowers
C. Definitions
1. Fan and Blower Categories
2. Safety Fans
3. Definitions Related to Heat Rejection Equipment
4. Air Circulating Fans
5. Outlet Area
6. Air Curtains
7. Basic Model
D. Industry Standards
E. Adoption and Modification of the Industry Standards
1. Combined Motor and Controller Efficiency Calculation
2. Annex A of AMCA 214-21
3. Annex E of AMCA 214-21
4. Section 6.5 of AMCA 214-21 and Annex F
5. Annex H and Annex I of AMCA 214-21
6. Section 8.3 of AMCA 214-21
7. Measurement of PVR Performance
8. Embedded Fans and Blowers
9. Wire-to-Air Performance for Air Circulating Fans
10. Total Pressure Calculation for Air Circulating Fans
11. Appurtenances
12. Voltage, Phase, and Frequency
13. Test Speeds for Air Circulating Fans
14. Run-In Requirements
15. Determination of Equilibrium and Test Stability
16. Test Figures for Air Circulating Fans
17. Location of External Airflow Measurement
18. Transducer Type Barometer
19. Reference Fan Electric Input Power Calculation for Air
Circulating Fans
20. Rounding
F. Distinguishing Between Fans and Blowers and Air Circulating
Fans
G. Metric
1. Metric for Fans and Blowers Other Than Air Circulating Fans
2. Metric for Air Circulating Fans
H. Control Credit Approach for Fans and Blowers Other Than Air
Circulating Fans
[[Page 27313]]
I. Alternative Energy Determination Method (AEDM)
1. Validation
2. Additional AEDM Requirements
3. AEDM Verification Testing
4. Engineered-to-Order
J. Sampling Plan
K. Enforcement Provisions
L. Effective and Compliance Dates
M. Test Procedure Costs and Impacts
1. Cumulative Costs and Burden
2. Estimated Costs for Building and Testing of Fans and Blowers
Other Than Air Circulating Fans at an In-House Facility
3. Estimated Costs for Building and Testing Air Circulating Fans
at an In-House Facility
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Creation of Testing Facility--General Fans
2. AEDM Creation and Testing Costs--General Fans
3. Creation of Testing Facility--Air Circulating Fans
4. AEDM Creation and Testing Costs--Air Circulating Fans
5. Total Costs
6. Certification Statement
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General Government Appropriations
Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration
Act of 1974
M. Congressional Notification
N. Description of Materials Incorporated by Reference
V. Approval of the Office of the Secretary
I. Authority and Background
On August 19, 2021, DOE published a coverage determination
classifying fans and blowers as covered equipment under 42 U.S.C.
6311(2)(A) and 6312(b). 86 FR 46579 (``August 2021 Final Coverage
Determination''). DOE does not currently have a test procedure or
energy conservation standard for fans and blowers. The following
sections discuss DOE's authority to establish a test procedure for fans
and blowers and relevant background information regarding DOE's
consideration of test procedures for this equipment.
A. Authority
The Energy Policy and Conservation Act, 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 C \2\ of EPCA, added by Public Law 95-619, Title
IV, section 441(a), established the Energy Conservation Program for
Certain Industrial Equipment, which sets forth a variety of provisions
designed to improve energy efficiency. EPCA provides that DOE may
include a type of industrial equipment, including fans and blowers, as
covered equipment if it determines that to do so is necessary to carry
out the purposes of Part A-1. (42 U.S.C. 6311(2)(B)(ii) and (iii); 42
U.S.C. 6312(b)) EPCA specifies the types of equipment that can be
classified as industrial equipment. (42 U.S.C. 6311(2)(B)) The purpose
of Part A-1 is to improve the efficiency of electric motors and pumps
and certain other industrial equipment in order to conserve the energy
resources of the Nation. (42 U.S.C. 6312(a)) As stated, on August 19,
2021, DOE published a final determination in which DOE determined that
fans and blowers meet the three statutory criteria for classifying
industrial equipment as covered (42 U.S.C. 6311(2)(A)), because fans
and blowers are a type of industrial equipment which: (1) in operation
consume, or are designed to consume, energy; (2) are to a significant
extent distributed in commerce for industrial or commercial use; \3\
and (3) are not covered under 42 U.S.C. 6291(a)(2). 86 FR 46579, 46585-
46588. DOE also determined that coverage of fans and blowers is
necessary to carry out the purposes of Part A-1. 86 FR 46579, 46588.
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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 C was redesignated Part A-1 and hereafter referred to as ``Part
A-1.''
\3\ DOE notes that distribution for residential use does not
preclude coverage as covered equipment so long as to a significant
extent the equipment is of a type that is also distributed in
commerce for industrial and commercial use.
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The energy conservation program under EPCA consists essentially of
four parts: (1) testing, (2) labeling, (3) Federal energy conservation
standards, and (4) certification and enforcement procedures. Relevant
provisions of EPCA include definitions (42 U.S.C. 6311), test
procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315),
energy conservation standards (42 U.S.C. 6313), and the authority to
require information and reports from manufacturers (42 U.S.C. 6316; 42
U.S.C. 6296).
The Federal testing requirements consist of test procedures that
manufacturers of covered equipment must use as the basis for: (1)
certifying to DOE that their equipment complies with the applicable
energy conservation standards adopted pursuant to EPCA (42 U.S.C.
6316(a); 42 U.S.C. 6295(s)), and (2) making other representations about
the efficiency of that equipment (42 U.S.C. 6314(d)). Similarly, DOE
must use these test procedures to determine whether the equipment
complies with relevant standards promulgated under EPCA. (42 U.S.C.
6316(a); 42 U.S.C. 6295(s))
Federal energy efficiency requirements for covered equipment
established under EPCA generally supersede State laws and regulations
concerning energy conservation testing, labeling, and standards. (42
U.S.C. 6316(a); 42 U.S.C. 6297). DOE may, however, grant waivers of
Federal preemption for particular State laws or regulations, in
accordance with the procedures and other provisions of EPCA. (42 U.S.C.
6316(b)(2)(D))
Under 42 U.S.C. 6314, EPCA sets forth the criteria and procedures
DOE must follow when prescribing or amending test procedures for
covered equipment. EPCA requires that any test procedures prescribed or
amended under this section must be reasonably designed to produce test
results which reflect energy efficiency, energy use or estimated annual
operating cost of a given type of covered equipment during a
representative average use cycle (as determined by the Secretary) and
requires that test procedures not be unduly burdensome to conduct. (42
U.S.C. 6314(a)(2))
B. Background
As discussed, on August 19, 2021, DOE published in the Federal
Register a final coverage determination classifying fans and blowers as
covered equipment. 86 FR 46579. DOE determined that the term ``blower''
is interchangeable with the term ``fan.'' 86 FR 46579, 46583. DOE
defines a fan (or blower) as a rotary bladed machine used to convert
electrical or mechanical power to air power, with an energy output
limited to 25 kilojoule (``kJ'') per kilogram (``kg'') of air. It
consists of an impeller, a shaft and bearings and/or driver to support
the impeller, as well as a structure or housing. A fan (or blower) may
include a transmission, driver, and/or motor controller. 10 CFR
431.172.
Prior to the August 2021 Final Coverage Determination, DOE
published a notice of intent to establish an Appliance Standards and
Rulemaking Federal Advisory Committee (``ASRAC'') Working Group
(``Working
[[Page 27314]]
Group'') for fans and blowers. 80 FR 17359 (April 1, 2015). The Working
Group \4\ commenced negotiations at an open meeting on May 18, 2015,
and held 16 meetings and three webinars to discuss scope, metrics, test
procedures, and standard levels for fans.\5\ The Working Group
concluded its negotiations on September 3, 2015, and, by consensus
vote,\6\ approved a term sheet containing recommendations for DOE on
the scope of a test procedure, and energy conservation standards for
fans. The term sheet containing the Working Group recommendations
(``term sheet'') is available in the fans energy conservation standard
rulemaking docket. (Docket No. EERE-2013-BT-STD-0006, No. 179) \7\
ASRAC approved the term sheet on September 24, 2015. (Docket No. EERE-
2013-BT-NOC-0005, Public Meeting Transcript, No. 58 at p. 29)
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\4\ The Working Group was comprised of representatives from
AAON, Inc.; AcoustiFLO LLC; AGS Consulting LLC; AMCA; AHRI,
Appliance Standards Awareness Project; Berner International Corp;
Buffalo Air Handling Company; Carnes Company; Daikin/Goodman; ebm-
papst; Greenheck; Morrison Products Inc.; Natural Resources Defense
Council; Newcomb & Boyd; Northwest Energy Efficiency Alliance; CA
IOUs; Regal Beloit Corporation; Rheem Manufacturing Company; Smiley
Engineering LLC representing Ingersoll Rand/Trane; SPX Cooling
Technologies/CTI; The New York Blower Company; Twin City Companies,
Ltd; U.S. Department of Energy; and United Technologies/Carrier.
\5\ Details of the negotiation sessions can be found in the
public meeting transcripts that are posted to the docket for the
energy conservation standard rulemaking at: www.regulations.gov/docket?D=EERE-2013-BT-STD-0006.
\6\ At the beginning of the negotiated rulemaking process, the
Working Group defined that before any vote could occur, the Working
Group must establish a quorum of at least 20 of the 25 members and
defined consensus as an agreement with less than 4 negative votes.
Twenty voting members of the Working Group were present for this
vote. Two members (Air-Conditioning, Heating, and Refrigeration
Institute and Ingersoll Rand/Trane) voted no on the term sheet.
\7\ The references are arranged as follows: (commenter name,
comment docket ID number, page of that document). If one comment was
submitted with multiple attachments, the references are arranged as
follows: (commenter name, comment docket ID number. Attachment
number, page of that document). The attachment number corresponds to
the order in which the attachment appears in the docket. The
parenthetical reference provides a reference for information located
in DOE Docket No. EERE-2021-BT-TP-0021. If the information was
submitted to a different DOE docket, the DOE docket number is
additionally specified in the reference.
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On January 10, 2020, DOE received a notice of petition from the Air
Movement and Control Association (``AMCA''), Air Conditioning
Contractors of America, and Sheet Metal & Air Conditioning Contractors
of America (``the Petitioners'') requesting that DOE establish test
procedures for certain categories of commercial and industrial fans
based on an industry test method in development, AMCA 214. DOE
published a notice of this petition with a request for public comment
on April 23, 2020; \8\ 85 FR 22677 (``April 2020 Notice of Petition'').
As part of the April 2020 Notice of Petition, DOE sought data and
information pertinent to whether amended test procedures would (1)
accurately measure energy efficiency, energy use, or estimated annual
operating cost of fans during a representative average use cycle; and
(2) not be unduly burdensome to conduct. 85 FR 22677, 22679.
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\8\ At the time of the petition, AMCA 214-21 was available as a
draft version (AMCA 214).
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On October 1, 2021, DOE published a request for information
pertaining to potential test procedures for fans and blowers. 86 FR
54412 (``October 2021 RFI''). In the October 2021 RFI, DOE identified a
variety of issues on which it sought input to determine whether, and if
so how, potential test procedures for fans and blowers, including air
circulating fans, would: (1) comply with the requirements in EPCA that
test procedures be reasonably designed to produce test results that
reflect energy use during a representative average use cycle, and (2)
not be unduly burdensome to conduct. Id. In response to requests from
stakeholders,\9\ DOE extended the comment period 14 days to November
15, 2021. 86 FR 59308 (Oct. 27, 2021).
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\9\ AMCA requested a 21-day extension (AMCA, No. 2 at p. 1).
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DOE published a notice of proposed rulemaking (``NOPR'') for the
test procedure on July 25, 2022. 87 FR 44194 (hereafter, the ``July
2022 NOPR''). DOE held a public meeting related to this NOPR on August
2, 2022 (hereafter, the ``NOPR public meeting''). DOE received several
comments \10\ requesting a comment extension ranging from 15 to 60
days, some commenters also requested a second public meeting/workshop.
In particular, the Air-Conditioning, Heating, and Refrigeration
Institute (``AHRI'') commented that the complexity of the commercial
fans rulemaking warrants additional time for stakeholder feedback and
recommended that DOE reconsider the request for an open meeting and
reopen the comment period so that all stakeholders have ample
opportunity for discourse on the implementation of an incredibly
complex rule, adding that the 60-day comment period was not sufficient.
(AHRI, No. 40 at pp. 3-4, 5) DOE determined that the length of the
comment period provided a meaningful opportunity to comment on the NOPR
and did not provide an extension.\11\
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\10\ AMCA and AHRI, No. 19 at p. 1; AHAM, No. 20 at p. 1; CA
IOUs, No. 21 at pp. 1-2; NEEA, No. 22 at p. 1, JCI, No. 23 at p. 1;
AHAM, No. 24 at p. 1.
\11\ DOE posted a copy of the pre-Federal Register publication
of the fans and blowers test procedure NOPR on the DOE website and
notified stakeholder organizations via email on June 24, 2022, which
provided stakeholders approximately 30 days for review of that copy
in addition to the 60-day comment period that was announced in the
notice published in the Federal Register on July 25, 2022. A public
meeting was held on August 2, 2022, and the written comment period
closed on September 23, 2022.
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DOE received comments in response to the July 2022 NOPR from the
interested parties listed in Table I-1.
Table I-1--List of Commenters With Written Submissions in Response to the July 2022 NOPR
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Reference in this final
Commenter(s) rule Comment No. in the docket Commenter type
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Association of Home Appliance AHAM................... 35....................... Trade Association.
Manufacturers.
Air-Conditioning, Heating, and AHRI................... 40....................... Trade Association.
Refrigeration Institute.
Air Movement and Control Association AMCA................... 13, 41................... Trade Association.
International.
Appliance Standards Awareness Efficiency Advocates... 32....................... Efficiency
Project, American Council for an Organizations.
Energy-Efficient Economy, Natural
Resources Defense Council.
California Investor-Owned Utilities: CA IOUs................ 37....................... Utilities.
Pacific Gas and Electric Company,
San Diego Gas and Electric, and
Southern California Edison.
California Energy Commission........ CEC.................... 30....................... Manufacturer.
ebm-papst Inc....................... ebm-papst.............. 31....................... Manufacturer.
Greenheck Group..................... Greenheck.............. 39....................... Manufacturer.
[[Page 27315]]
Johnson Controls.................... JCI.................... 34....................... Manufacturer.
Morrison Products Inc............... Morrison............... 42....................... Manufacturer.
New York Blower..................... New York Blower........ 33....................... Manufacturer.
Northwest Energy Efficiency Alliance NEEA................... 36....................... Efficiency
Organization.
Robinson Fans Holdings.............. Robinson............... 43....................... Manufacturer.
Trane Technologies.................. Trane.................. 38....................... Manufacturer.
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A parenthetical reference at the end of a comment quotation or
paraphrase provides the location of the item in the public record.\12\
To the extent that interested parties have provided written comments
that are substantively consistent with any oral comments provided
during the NOPR public meeting, DOE cites the written comments
throughout this final rule. DOE identified one oral comment from Nidec
Motor Corporation (``Nidec'') regarding stability determination that is
summarized and addressed in section III.E.16.a.; one comment from ASAP
generally supporting the test procedure rulemaking summarized and
addressed in section III.A; one comment from Daikin related to embedded
fans exclusions summarized and addressed in section III.B.3.b; and one
comment from Loren Cook Company (``Loren Cook'') related to test burden
summarized and addressed in section III.E.12 of this document. All
other comments provided during the webinar are substantively addressed
by written comments.
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\12\ The parenthetical reference provides a reference for
information located in the docket of DOE's rulemaking to develop
test procedures for fans and blowers. (Docket No. EERE-2021-BT-TP-
0021, maintained at www.regulations.gov.) The references are
arranged as follows: (commenter name, comment docket ID number, page
of that document).
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In addition, DOE notes that it received several comments \13\ that
were not related to the test procedure and instead relate to potential
energy conservation standards. DOE will address these comments in a
separate rulemaking pertaining to energy conservation standards.
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\13\ See AHRI, No. 40 at pp. 7, 8, 9-10, 12-14; CA IOUs, No. 37
at pp. 1-3.
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On November 21, 2022, AMCA, as well as AMCA members (ebm-papst, Big
Ass Fans, Greenheck, New York Blower, and Twin City Fan), ASAP, and
NEEA met with DOE to discuss several items related to the fan and
blower test procedure during an ex-parte meeting. (AMCA No. 45, at pp.
1-12)
II. Synopsis of the Final Rule
In this final rule, DOE adopts a test procedure for fans and
blowers in subpart J of 10 CFR part 431 and modifies 10 CFR part 429,
as follows:
Establishes the scope of the test procedure for fans and
blowers as to include standalone and embedded fans and blowers (i.e.,
fans and blowers incorporated into other equipment) that are either:
axial inline fans; axial panel fans; centrifugal housed fans;
centrifugal unhoused fans; centrifugal inline fans; radial-housed fans;
power roof/wall ventilators (``PRVs''); or air circulating fans with
input power greater than or equal to 125 W; and excluding some fans
that are embedded in other products or equipment; and excluding radial
housed unshrouded fans with a diameter less than 30 inches or a blade
width of less than 3 inches; safety fans; induced flow fans; jet fans;
cross-flow fans; fans manufactured exclusively to be powered by
internal combustion engines; fans that create a vacuum of 30 inches
water gauge (``in. wg'') or greater; and fans designed and marketed to
operate at or above 482 degrees Fahrenheit (250 degrees Celsius). In
addition, for fans and blowers other than air circulating fans, the
test procedure only applies to duty points with fan shaft input power
equal to or greater than 1 horsepower and fan air power equal to or
less than 150 horsepower.
Defines ``axial inline fan,'' ``axial panel fan,''
``centrifugal housed fan,'' ``centrifugal unhoused fan,'' ``centrifugal
inline fan,'' ``radial-housed fan,'' ``power roof ventilator,''
``cross-flow fan,'' ``induced flow fan,'' ``jet fan,'' ``basic model,''
``safety fan,'' ``air circulating fan,'' and related terms.
Adopts through reference in newly adopted appendix A to
subpart J of 10 CFR part 431 (``appendix A'') certain provisions of
ANSI/AMCA 214-21, ``Test Procedure for Calculating Fan Energy Index for
Commercial and Industrial Fans and Blowers'' (``AMCA 214-21''), with
modifications, as the test procedure for determining FEP and FEI of
fans and blowers other than circulating fans;
Adopts through reference in newly adopted appendix B to
subpart J of 10 CFR part 431 (``appendix B'') certain provisions of
ANSI/AMCA 230-23, ``Laboratory Methods of Testing Air Circulating Fans
for Rating and Certification,'' with modifications, as the test
procedure for determining efficacy in cubic feet per minute (``CFM'')
per watt (``W'') (``CFM/W'');
Adopts through reference certain provisions of the
following industry standards referenced by AMCA 214-21: ANSI/AMCA 210-
16, (``AMCA 210-16'') ``Laboratory Methods of Testing Fans for
Certified Aerodynamic Performance Rating'' and ISO 5801:2017(E), ``Fans
Performance testing using standardized airways'' (ISO 5801:2017).
Establishes fan and blower sampling requirements and
provisions related to determining represented values in 10 CFR 429.69;
Establishes an alternative efficiency determination method
(``AEDM'') for fans and blowers in 10 CFR 429.70; and
The adopted requirements are summarized in Table II-1.
[[Page 27316]]
Table II-1--Summary of Adopted Requirements
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Applicable preamble
Topic Location in CFR Adopted requirements discussion
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Scope.............................. 10 CFR 431.174........ Establish the scope of the Section III.B.
test procedure for fans
and blowers as to include
standalone and embedded
fans and blowers (i.e.,
fans and blowers
incorporated into other
equipment) that are
either: axial inline fans;
axial panel fans;
centrifugal housed fans;
centrifugal unhoused fans;
centrifugal inline fans;
radial-housed fans; power
roof/wall ventilators; or
air circulating fans with
input power greater than
or equal to 125 W; and
excluding some fans that
are embedded in other
products or equipment; and
excluding radial housed
unshrouded fans with
diameter less than 30
inches or a blade width of
less than 3 inches; safety
fans; induced flow fans;
jet fans; cross-flow fans;
fans manufactured
exclusively to be powered
by internal combustion
engines; fans that create
a vacuum of 30 in. wg or
greater; and fans designed
and marketed to operate at
or above 482 degrees
Fahrenheit (250 degrees
Celsius). In addition, for
fans and blowers other
than air circulating fans,
the test procedure is
applicable to duty points
with fan shaft input power
equal to or greater than 1
horsepower and fan air
power equal to or less
than 150 horsepower.
Definitions........................ 10 CFR 431.172........ Define ``axial inline Section III.C.
fan,'' ``axial panel
fan,'' ``centrifugal
housed fan,''
``centrifugal unhoused
fan,'' ``centrifugal
inline fan,'' ``radial-
housed fan,'' ``power roof
ventilator,'' ``cross-flow
fan,'' ``induced flow
fan,'' ``jet fan,''
``basic model,'' ``safety
fan,'' ``air circulating
fan,'' and related terms.
Test Procedure..................... 10 CFR 431.174........ Establish FEI as the metric Sections III.D, III.E,
for fans and blowers other III.F and III.G.
than air circulating fans;
incorporate by reference
AMCA 214-21, AMCA 210-16,
and provide additional
instructions for
determining the FEI (and
other applicable
performance
characteristics) for fans
and blowers other than air
circulating fans.
Establish the efficacy
(CFM/W) as the metric for
air circulating fans;
incorporate by reference
AMCA 230-23 and provide
additional instructions
for determining the
efficacy (and other
applicable performance
characteristics) for air
circulating fans.
Sampling Plan...................... 10 CFR 429.69......... Specify the minimum number Section III.J.
of fans or blowers to be
tested to rate a basic
model and determine
representative values.
AEDM............................... 10 CFR 429.70......... Establish requirements for Section III.I.
applying an alternative
energy use determination
method.
----------------------------------------------------------------------------------------------------------------
DOE's test method for fans and blowers includes measurements of
pressure, flow rate, and fan shaft or electrical input power, all of
which are required to calculate FEP, FEI, and efficacy (CFM/W) as
applicable, as well as other quantities to characterize rated fan and
blower performance (e.g., speed). DOE has determined that the relevant
sections of AMCA 214-21, AMCA 210-16, and AMCA 230-23, in conjunction
with the additional provisions adopted in this test procedure, would
produce test results that reflect the energy efficiency and energy use
of a fan or blower during a representative average use cycle. (42
U.S.C. 6314(a)(2)) Additionally, DOE has determined that the test
procedure, which is based on the relevant industry testing standard,
would not be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2)) DOE's
analysis of the burdens associated with the proposed test procedure is
presented in section III.M of this document.
The effective date for the test procedure adopted in this final
rule is 30 days after publication of this document in the Federal
Register. Representations of energy use or energy efficiency must be
based on testing in accordance with the test procedure beginning 180
days after the publication of this final rule.
III. Discussion
In the following sections, DOE establishes test procedures and
related definitions for fans and blowers in subpart J of part 431,
sampling plans for this equipment, an alternative efficiency
determination method (``AEDM'') for this equipment, and enforcement
provisions for this equipment. In the following sections, DOE provides
relevant background information, discusses and responds to relevant
public comments, and presents the adopted requirements.
A. General
ASAP commented in general support of the July 2022 NOPR. (Public
Meeting transcript, No. 18 at p. 5)
AHRI commented that in the Table of Contents of the NOPR, DOE lists
a section ``C. Deviation from the Process Rule;'' however, no such
section can be found in the NOPR. AHRI noted that according to Section
3(a) of 10 CFR part 430, subpart C, appendix A, DOE may,
[[Page 27317]]
as necessary, deviate from [the Process Rule] to account for specific
circumstances of a particular rulemaking, and interested parties will
receive notice of the deviation and explanation. AHRI recommended that
DOE reopen the comment period to include the missing ``Section C.
Deviation from the Process Rule'' that includes an explanation for the
deviation so that the public can respond and provide meaningful
comments. AHRI stated that DOE has failed to be transparent in the NOPR
in providing no notice or explanation of any deviation from the
applicable guidance of appendix A. (AHRI, No. 40 at pp. 2-3)
AHAM commented that DOE did not provide notice and explanation for
deviations from the Process Rule, although the table of contents
included such section. Nevertheless, AHAM noted that it is clear that
DOE deviated from the Process Rule at least with regard to the comment
period, although DOE did not explain why. AHAM commented that instead
of the process rule's required 75-day comment period for test
procedures, DOE provided only 60 (which has become DOE's common
practice regardless of the particular rulemaking). AHAM stated that DOE
declined several parties' requests to extend that comment period
despite substantive reasons necessitating more time and reasonable
extension requests that would not meaningfully extend DOE's rulemaking
process requested. In addition, AHAM commented that a longer comment
period was required for manufacturers to test products using DOE's
proposed tests. In addition, AHAM noted that AHAM members struggled to
understand whether the proposed test procedure would implicate consumer
fans and/or fans used in home appliances in the allotted time. AHAM
stated that denying reasonable requests for modest comment period
extensions will not ultimately streamline DOE's efforts and will result
in increased resource needs for the Department to respond to
stakeholder meeting requests and supplemental documents, which would
lengthen the rulemaking process. AHAM commented that in the future, DOE
should allow for reasonable extensions to comment periods in order to
increase the quality of responses to its requests for comment and the
overall accuracy of its final rules. (AHAM, No. 35 at pp. 7-8)
AMCA noted that incorporating air circulating fans in the test
procedure NOPR at a time when AMCA 230 was undergoing revisions added
considerable time and efforts in addition to having to review the
expected material and AMCA commented that DOE denied multiple
stakeholder requests for a 30-day extension. AMCA further commented
that an ex-parte meeting after the pre-publication of the NOPR and
before the publication of the NOPR would have benefited stakeholders
and potentially improved the NOPR. (AMCA No. 41 at p. 2)
DOE did not deviate from 10 CFR part 430, subpart C, appendix A
(``appendix A''), applicable to fans and blowers under 10 CFR 431.4,
and did not include such discussion in the July 2022 NOPR. DOE notes
however that a section title for this section was not deleted from the
table of contents and should have been deleted.
In addition, appendix A does not prescribe any mandatory comment
period for test procedure NOPRs. A 60-day period is the typical period
that DOE provides for all NOPRs, which exceeds the 45-day minimum
required by EPCA. (See 42 U.S.C. 6314(b)(2)) As previously noted, the
pre-publication version of the NOPR was publicly available for 30 days
for stakeholders to review prior to publication of the NOPR. As such,
the timing and sequence of this rulemaking has been conducted
consistent with the provisions in appendix A. Additionally, the intent
of the pre-publication version of a document is to provide stakeholders
with additional time to review and prepare comments. Further, DOE
provided opportunity for written comments and subsequent ex-parte
meeting, as previously discussed, and comments from all stakeholders
were considered in finalizing this test procedure pertaining to fans
and blowers as discussed in section III of this document.
AHRI commented that the proposed test procedure will exacerbate
supply chain issues, contradicting Executive Order 14017.\14\ AHRI
commented that supply chain disruptions have been lowering the
competitiveness of the HVAC industry and hindering AHRI manufacturing
capabilities. AHRI commented that trade distortions and the COVID-19
pandemic have resulted in shortages of essential components and led to
delays and costly inflation at every stage of the manufacturing supply
chain. AHRI commented that the immediacy of the implementation of a
test procedure change serves to exacerbate near-term supply chain
disruptions, and that these issues are made worse with ongoing labor
shortages, and added together, disrupt domestic production, and result
in temporary shutdowns, reduced sales, increased consumer costs, and
delayed delivery of critical products.\15\ AHRI further provided a
description of current supply issues experienced by its members and
commented that such regulatory burdens by DOE and others have left
manufacturers in an almost constant state of redesign and testing. AHRI
added that innovation is no longer as important as just modifying
products to meet what AHRI described as new and ever-changing
regulatory burdens. (AHRI, No. 40 at pp. 15-17)
---------------------------------------------------------------------------
\14\ Executive Order on America's Supply Chains, February 24,
2021. Available at: www.whitehouse.gov/briefing-room/presidential-actions/2021/02/24/executive-order-on-americas-supply-chains.
\15\ AHRI referenced appendix A of the Supply Chain Disruptions
Affect Viability of U.S. Manufacturing Sector white paper, published
by AHRI, AHAM, NAFEM, and NEMA. Available at www.nema.org/docs/default-source/advocacy-document-library/joint-association-supply-chain-white-paper.pdf?sfvrsn=1763ed3b_2.
---------------------------------------------------------------------------
DOE has determined that establishing a test procedure will not
impact the availability of current models. The test procedure does not
establish any energy conservation standards and does not result in any
non-compliant fans. Section III.M of this document discusses DOE's
analysis of testing costs and burden as a result of establishing this
test procedure.
Morrison commented that the proposed new metric and testing plans
was inconsistent with 2015 ASRAC WG term sheet agreement and
disregarded the 11 years of work that went into this challenging and
groundbreaking rulemaking effort. (Morrison No. 42 at p.1) As discussed
in section III.G.1 of this document, DOE did not propose a new metric
in the July 2022 NOPR. Further in this final rule, DOE is adopting a
minimum sample size of one unit in line with the term sheet as
discussed in section III.J of this document.
B. Scope of Applicability
This rulemaking applies to fans and blowers. A fan or blower is
defined as a rotary bladed machine that is used to convert electrical
or mechanical power to air power with an energy output limited to 25
kilojoule (``kJ'')/kilogram (``kg'') of air. 10 CFR 431.172. It
consists of an impeller, a shaft and bearings and/or a driver to
support the impeller, as well as a structure or housing. Id. A fan or
blower may include a transmission, driver, and/or motor controller. Id.
As discussed, DOE has classified fans and blowers as covered equipment.
86 FR 46579. ``Covered equipment'' consists of certain industrial
equipment, which is classified by the Secretary according to section
6312(b) and excludes covered
[[Page 27318]]
products, other than industrial equipment that is a component of a
covered product. (42 U.S.C. 6311(1) and (2)(A)(iii)) DOE explained in
the coverage determination that fans and blowers, the subjects of this
rulemaking, do not include ceiling fans and furnace fans, as defined at
10 CFR 430.2. See 86 FR 46579, 46586. DOE also noted that distribution
for residential use does not preclude coverage as covered equipment so
long as to a significant extent the equipment is of a type that is also
distributed in commerce for industrial and commercial use. Id. at fn.
26.
In the August 2021 Final Coverage Determination, DOE did not
establish definitions for specific categories of fans and blowers. DOE
stated that it would consider specific categories of fans and blowers
and the scope of applicability of test procedures and energy
conservation standards in its respective rulemakings. 86 FR 46579,
46585.
This section discusses the fans and blowers that DOE includes in
the scope of applicability of the test procedure, as well as
exemptions.
1. Fans and Blowers Inclusions
This section discusses fans and blowers, other than air circulating
fans, proposed for inclusion in the scope of applicability of the test
procedure. Air circulating fans are discussed in section III.B.4 of
this document.
The Working Group recommended that the test procedure be applicable
to certain classifications of fans and blowers, listed in Table III-8
of this document. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #1 at p. 1) The Working Group did not provide
definitions for the specified classifications of the fans and blowers
identified for inclusion in the scope of a test procedure. AMCA 214-21
provides terms and associated definitions for certain classifications
of fans and blowers that correspond to the Working Group
recommendation. The Working Group further recommended that the test
procedure apply only to the fan operating points (i.e., duty points)
with a fan shaft power equal to or greater than 1 horsepower (``hp'')
and fan air power \16\ equal to or less than 150 hp. The Working Group
recommended that air power be calculated using static pressure for
unducted fans (``static air power'') and total pressure for ducted fans
(``total air power'').\17\ (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #5 at p. 4)
---------------------------------------------------------------------------
\16\ The air power of a fan is the fan's output power. It is
proportional to the product of the fan airflow rate and the fan
pressure.
\17\ The terms ``ducted'' and ``unducted'' refer to the
recommended test configuration used when conducting a fan test.
Appendix C of the term sheet specifies which fan categories are
typically ducted (i.e., tested using a ducted outlet and for which
the FEI is calculated on a total pressure basis): axial cylindrical
housed, centrifugal housed (excluding inline and radial), inline and
mixed flow, radial housed; and which fan types are considered
unducted (i.e., tested with a free outlet and for which the FEI is
calculated on a static pressure basis): panel, centrifugal unhoused
(excluding inline and radial), and power roof ventilators.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE noted that on February 24, 2022, the
California Energy Commission (``CEC'') published a proposed rulemaking
for fans and blowers that includes terms and definitions that
correspond to the Working Group recommendations.\18\ The CEC proposed
to cover the following fan categories: axial inline, axial panel,
centrifugal housed, centrifugal unhoused, centrifugal inline, radial
housed, and power roof/wall ventilators, and to define these terms
largely based on the definitions in AMCA 214-21, with revisions to
indicate a fan's intended application and if a fan's inlet or outlet
can be (optionally, as applicable) ducted. In addition, the CEC
proposal considers fans and blowers that have a rated fan shaft power
greater than or equal to 1 horsepower, or, for fans without a rated
shaft input power, an electrical input power greater than or equal to 1
kW, and a fan output power less than or equal to 150 horsepower.\19\ 87
FR 44194, 44199.
---------------------------------------------------------------------------
\18\ All documents related to this rulemaking can be found in
the rulemaking Docket 22-AAER-01 accessible at: www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-20/appliance-efficiency-proceedings-11.
\19\ See Proposed regulatory language for Commercial and
Industrial Fans and Blowers available in the following Docket: 22-
AAER-01 at: efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE proposed to include all fans and blowers
that are included within the scope of AMCA 210-16 (referenced by AMCA
214-21) and proposed that the test procedure would be applicable to the
following fans and blowers, with exclusions discussed in sections
III.B.2 and III.B.3 of this document: (1) axial inline fan; (2) axial
panel fan; (3) centrifugal housed fan; (4) centrifugal unhoused fan;
(5) centrifugal inline fan; (6) radial-housed fan; and (7) power roof/
wall ventilator (``PRV'').\20\ 87 FR 44194, 44200. (See section III.C.1
of this document for definitions of these terms)
---------------------------------------------------------------------------
\20\ PRVs include: Centrifugal PRV exhaust fans; Centrifugal PRV
supply fans; and Axial PRVs, as defined in AMCA 214-21.
---------------------------------------------------------------------------
AMCA supported the proposed standalone fan inclusions and did not
provide comments regarding embedded fans. (AMCA, No. 41 at p. 5) New
York Blower commented that the fans and blowers proposed for inclusion
in the DOE test procedure are appropriate. (New York Blower, No. 33 at
p. 6)
DOE did not receive any other comments on this issue and includes
all fans and blowers within the scope of AMCA 210-16 (referenced by
AMCA 214-21) in the scope of the DOE test procedure. As such, DOE
specifies that the test procedure is applicable to the following fans
and blowers, with exclusions discussed in sections III.B.2 and III.B.3
of this document: (1) axial inline fan; (2) axial panel fan; (3)
centrifugal housed fan; (4) centrifugal unhoused fan; (5) centrifugal
inline fan; (6) radial-housed fan; and (7) PRV.
In the July 2022 NOPR, DOE proposed that the scope of the test
procedure cover fans and blowers with a fan shaft input power equal to
or greater than 1 horsepower and a fan static or total air power equal
to or less than 150 horsepower. DOE proposed the lower 1 hp limit to
match the technical applicability of the AMCA 214-21 and AMCA 210-16
test procedures. DOE proposed the upper air power limit at this time
because fans that operate above the proposed upper limit are typically
custom orders and are too large to be tested in a laboratory setting.
In addition, DOE noted that these limits are in line with the Working
Group recommendations and the CEC scope. 87 FR 44194, 44200-44201.
In the July 2022 NOPR, DOE tentatively determined that the 1 hp fan
shaft power lower limit may not be a practical unit of measurement for
all fans because some fans are designed such that the measurement of
the shaft input power is not feasible, and the only feasible
measurement is the FEP, which is measured in units of kW. For example,
some fans incorporate the bare shaft and the motor in the same enclosed
housing and do not provide access to the fan shaft (i.e., between the
motor and the fan), where the measurement of the fan shaft power would
be conducted. DOE relied on the motor efficiency equations provided in
section 6.4.2.3 of AMCA 214-21 to convert the fan shaft power into
electrical input power \21\ and has tentatively determined that 0.89 kW
is appropriate to establish a standardized equivalent to the 1 hp fan
shaft input power limit. Additionally, section 6.5.3.1.3 ``Fan
Efficiency Requirements'' of ANSI/ASHRAE/IES 90.1, ``Energy Standard
for Buildings except Low-Rise Residential Buildings (2019)'' (``ASHRAE
90.1-2019'') relies on the value of 0.89 kW as the corresponding
[[Page 27319]]
threshold to a value of 1 hp of shaft input power. Accordingly, DOE
proposed that the test procedure would be applicable to a fan or blower
with duty points \22\ with the following characteristics: (1) a fan
shaft input power equal to or greater than 1 horsepower and a fan
static or total air power equal to or less than 150 horsepower, or (2)
a FEP equal to or greater than 0.89 kW and a fan static or total air
power equal to or less than 150 horsepower. 87 FR 44194, 44200.
---------------------------------------------------------------------------
\21\ The electrical input power is equal to the fan shaft input
power divided by the motor efficiency.
\22\ A duty point is characterized by a given airflow and
pressure and has a corresponding operating speed.
---------------------------------------------------------------------------
In addition, AMCA 214-21 distinguishes between fans that use a
total pressure basis \23\ and fans that use a static pressure
basis.\24\ In the July 2022 NOPR, DOE proposed to establish the 150 hp
upper limit in terms of total air power for fans and blowers that use a
total pressure basis FEI and would be required to be tested with a
ducted outlet according to the proposed provisions adopted through
reference to AMCA 214-21. For fans and blowers that use a static
pressure basis FEI and would be required to be tested using a free
outlet under the provisions of AMCA 214-21, DOE proposed to establish
the air power limit in terms of static air power. 87 FR 44194, 44200-
44201.
---------------------------------------------------------------------------
\23\ This includes: centrifugal housed fans, radial housed fans,
centrifugal inline fans, centrifugal PRVs Supply, and Axial Inline
fans. (See Table 7.1 of AMCA 214-21.)
\24\ This includes: Centrifugal unhoused fans, Centrifugal PRVs
Exhaust, Axial Panel fans, Axial PRVs. (See Table 7.1 of AMCA 214-
21.)
---------------------------------------------------------------------------
Finally, to define total air power, DOE proposed to rely on the
definition of ``fan output power'' in AMCA 210-16. DOE proposed to
define ``total air power'' as the total power delivered to air by the
fan; it is proportional to the product of the fan airflow rate, the fan
total pressure, and the compressibility coefficient and is calculated
in accordance with section 7.8.1 of AMCA 210-16. See the definition of
``fan output power'' in Section 3.1.31 of AMCA 210-16 and calculation
formulas in section 7.8.1 of AMCA 210-16. DOE also proposed to define
``static air power'' as the static power delivered to air by the fan;
it is proportional to the product of the fan airflow rate, the fan
static pressure, and the compressibility coefficient and is calculated
in accordance with section 7.8.1 of AMCA 210-16, using static pressure
instead of total pressure. 87 FR 44194, 44201.
In response to the July 2022 NOPR, AMCA commented in support of the
basis of the proposed power limits based on fan air power, fan shaft
input power and fan electrical input power. In terms of scope, AMCA
added that fans deliver air power, defined generally as pressure
multiplied by volume flow rate. AMCA stated that by limiting the top
end of the scope to air power, as opposed to electrical input power, a
less efficient fan is not allowed to escape regulation by consuming a
larger amount of electrical input power to deliver a similar amount of
air power. Regarding the low side of the scope related to power, for
bare fans, AMCA commented that shaft input power is the appropriate
measure because there is no driver. For fans tested wire-to-air, AMCA
commented that the appropriate measure is electrical input power.
(AMCA, No. 41 at p. 5)
Morrison commented in support of the proposed power limits
(Morrison, No. 42 at p. 2)
New York Blower commented that the proposed power limits were
appropriate. New York Blower commented that the limits are configured
in a manner that captures products at the low end of fan powers and
does not allow less efficient products at the high end to escape
regulation by being less efficient. However, New York Blower noted that
the July 2022 NOPR implies that if a fan is capable of operating within
the scope of regulation, it should be regulated under all possible
operating conditions. New York Blower commented that such approach
would remove the upper limit of scope considering that practically any
fan could be slowed down enough to operate within the proposed scope.
Instead, New York Blower commented that for applications that operate
at the high end of the proposed scope, fan performance is typically
attached to the fan and that these types of fans are not sold as a
distributed product--like a fan in a box--but configured and applied to
the application. Thus, for these fans, New York Blower recommended that
the industry be regulated for fans configured and identified as
operating within scope and for identical products operating outside the
scope, the product not be regulated. (New York Blower, No. 33 at p. 7)
ebm-papst commented that testing of larger fans becomes
exponentially more burdensome and recommended that DOE exempt all fans
that have at least one duty point at an air power above 150 horsepower.
Otherwise, according to ebm-papst, many speed adjustable industrial
fans become subject to this regulation even if just a small portion of
the operating map is below 150 hp or air power. (ebm-papst, No. 31 at
p. 1)
Robinson commented that they are not in favor of the inclusion of
duty points within the power range. Robinson commented that custom fan
equipment is often selected at a duty point well beyond the horsepower
limitation, but included within the operational requirements are
operating duty points that fall within the horsepower range. Robinson
asked if the manufacturer is only required to make a representation
regarding that single duty point. Robinson added that in some
instances, customers cannot obtain a desired duty point through speed
control, and therefore duty points must be attained through damper
control. Inclusion of these appurtenances in testing will significantly
multiply testing requirements to make an assertation regarding FEP,
FEI, etc. and result in over-designed fans. (Robinson, No. 43 at p. 4)
The CA IOUs commented that DOE should rely on the best efficiency
point (``BEP'') \25\ as the criteria for whether a fan falls within the
power input range and air horsepower to determine if a fan is within
the scope of the test procedure. The CA IOUs commented that DOE
proposed that the test procedure applies to a fan or blower with duty
points greater than one horsepower and equal to or less than 150
horsepower. Therefore, fans with a single duty point of less than 150
air horsepower would be within the scope of this rulemaking. The CA
IOUs asserted that fans with variable speed drives, regardless of size,
are bound to have duty points less than 150 horsepower. The CA IOUs
also stated that there are also many small fans, particularly forward-
curved fans, with a few points and shaft input power greater than one
horsepower at the extreme right end of the fan curve. The CA IOUs
recommended that DOE change this exclusion to fans where the BEP is
less than or equal to one horsepower or greater than 150 hp. (CA IOUs,
No. 37 at p. 10)
---------------------------------------------------------------------------
\25\ The BEP represents the flow and pressure values at which
the fan total efficiency (ratio of total air power to fan shaft
input power) is maximized when operating a given speed.
---------------------------------------------------------------------------
As noted, the Working Group recommended that the test procedure be
only applicable to the fan operating points with a fan shaft power
equal to or greater than 1 horsepower (``hp'') and fan air power equal
to or less than 150 hp. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #5 at p. 4) In line with this approach, DOE adopts the
power limits as proposed in the July 2022 NOPR and corresponding
definitions of static air power (``fan static air power'') and total
airpower
[[Page 27320]]
(fan total air power''). DOE further clarifies that the test procedure
is only applicable to the fan or blower duty points with the following
characteristics: (1) a fan shaft input power equal to or greater than 1
horsepower and a fan static or total air power equal to or less than
150 horsepower, or (2) a FEP equal to or greater than 0.89 kW and a fan
static or total air power equal to or less than 150 horsepower. When
determining the duty points of a basic model, to establish whether a
fan includes duty points that meet the scope requirements in terms of
power limit, DOE will refer to published data, marketing literature,
and other publicly available information about the range of operation
(i.e., flow, speed, and pressure) of each basic model. If the
manufacturer only includes 1 single duty point in the fan operating
range, then the manufacturer is only required to make a representation
at that one point. In addition, DOE follows the Working Group
recommendation for establishing the scope power limit as proposed in
the July 2022 NOPR. Finally, the limit recommended by the Working Group
recommendation was set to capture the design points that represent the
majority of the market and therefore corresponds to a limit in terms
design point not BEP. (EERE-2013-BT-STD-0006, Public Meeting
Transcript, No. 161 at pp. 96, 100-101) In line with this Working Group
recommendation, DOE is not relying on BEP to establish the scope of the
test procedure.
Regarding fans that are designed to operate outside of the power
limits but that may include duty points that fall in the scope, DOE
notes that the manufacturer would be required to test such a fan at the
duty points that fall in the scope of the test procedure. Regarding
testing with accessories, DOE addresses this issue in section III.E.12
of this document.
2. Fans and Blowers Exclusions
The Working Group recommended the exclusion of circulating fans
(also known as air circulating fans), induced flow fans, jet fans, and
cross-flow fans. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #2 at pp. 2-3) The Working Group also recommended the
exclusion of safety fans due to low operating hours and specific design
features that impair efficiency (e.g., high tip clearance), and a
subset of radial fans that are used for material handling applications
\26\ (e.g., to move paper dust, sand, etc.).\27\ (Docket No. EERE-2013-
BT-STD-0006, No. 179, Recommendation #2 at pp. 2-3) Table III-1 of this
document presents the exclusions recommended by the Working Group.
---------------------------------------------------------------------------
\26\ Specifically, radial housed unshrouded fans, which means a
radial housed fan for which the impeller blades are attached to a
backplate and hub (i.e., open radial blade), or to a hub only (i.e.,
open paddle wheel), and with an open front at the impeller's inlet.
These are different than radial shrouded fans, for which the
impeller blades are attached to a backplate and to a ring or
``shroud'' at the impeller's inlet.
\27\ The discussions of the Working Group related to these
exclusions can be found in the meeting transcripts, available in the
fan's energy conservation standard rulemaking docket. (Docket No.
EERE-2013-BT-STD-0006, Public Meeting Transcript, No. 161 at pp. 63-
70; Public Meeting Transcript, No. 85 at pp. 60-62).
Table III-1--Fan Categories Recommended for Exclusion by the Working
Group
------------------------------------------------------------------------
Fan category recommended for exclusion
by the working group * Definition in AMCA 214-21
------------------------------------------------------------------------
Radial housed unshrouded fan with Included in the definition
diameter less than 30 inches or a ``radial housed fan'' as noted
blade width of less than 3 inches. in Table III[dash]1.
Safety fan............................. Not defined in AMCA 214-21.
Induced flow fan....................... ``Induced flow fan'' means a
type of laboratory exhaust fan
with a nozzle and windband;
the fan's outlet airflow is
greater than the inlet airflow
due to induced airflow. All
airflow entering the inlet
exits through the nozzle.
Airflow exiting the windband
includes the nozzle airflow
plus the induced airflow.
Jet fan................................ ``Jet fan'' means a fan
designed and marketed
specifically for producing a
high velocity air jet in a
space to increase its air
momentum. Jet fans are rated
using thrust. Inlets and
outlets are not ducted but may
include acoustic silencers.
Cross-flow fan......................... ``Cross-flow fan'' means a fan
with a housing that creates an
airflow path through the
impeller in a direction at
right angles to its axis of
rotation and with airflow both
entering and exiting the
impeller at its periphery.
Inlets and outlets can
optionally be ducted.**
------------------------------------------------------------------------
* Note: The Working Group also recommended the exclusion of circulating
fans (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #2 at
pp. 2-3), which are defined in AMCA 214-21 as a fan that is not a
ceiling fan that is used to move air within a space that has no
provision for connection to ducting or separation of the fan inlet
from its outlet. The fan is designed to be used for the general
circulation of air. Circulating fans are discussed in Section III.B.4
of this document.
** Excluded from AMCA 214-21 and defined in ANSI/AMCA Standard 208,
``Calculation of the Fan Energy Index for calculating FEI'' (``AMCA
208-18'').
The Petitioners requested that the scope of any future DOE test
procedure be consistent with the scope described in the term sheet and
requested the exclusion of fans that cannot be tested per AMCA 210-16
(i.e., the physical test method referenced in AMCA 214-21).\28\ The
Petitioners also requested that the scope of the test procedure be
consistent with ASHRAE 90.1-2019. (Docket No. EERE-2020-BT-PET-0003,
The Petitioners, No. 1, attachment ``AMCA Petition to DOE Cover Letter
and Petition [sic] 2020110'' at pp. 7-8)
---------------------------------------------------------------------------
\28\ For example, circulating fans, ceiling fans, desk fans, jet
tunnel fans, and induced flow fans (e.g., used in laboratory exhaust
systems). This is consistent with the scope of the term sheet.
---------------------------------------------------------------------------
Table III-2 of this document compares the scope exclusions
requested by the Petitioners in accordance with the commercial and
industrial fan and blower requirements in ASHRAE 90.1-2019 and the
scope of exclusions as recommended by the Working Group (other than
embedded fans and blowers). In the July 2022 NOPR, DOE reviewed the fan
and blower exclusions to section 6.5.3.1.3 of ASHRAE 90.1-2019 ``Fan
Efficiency Requirements'' as listed in Table III-2 of this document and
tentatively determined that these exclusions are covered by the
exclusions recommended by the Working Group. 87 FR 44194, 44201-44202.
[[Page 27321]]
Table III-2--Exceptions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 ``Fan
Efficiency Requirements''
[Other than for embedded fans and blowers]
------------------------------------------------------------------------
Exceptions to section 6.5.3.1.3 of Included in the exclusions
ASHRAE 90.1-2019 ``fan efficiency recommended by the working
requirements'' group?
------------------------------------------------------------------------
Fans that are not embedded fans with a Yes.
motor nameplate horsepower of less
than 1.0 hp or with a fan nameplate
electrical input power of less than
0.89 kW.
Ceiling fans........................... Yes (Note: ceiling fans are not
within the scope of the
definition of fans and
blowers).
Fans used for moving gases at Yes (safety fans).
temperatures above 482 degrees
Fahrenheit.
Fans used for operation in explosive Yes (safety fans).
atmospheres.
Reversible fans used for tunnel Yes (jet fans, safety fans).
ventilation.
Fans outside the scope of AMCA 208-18.. Yes (AMCA 208-18 references the
scope of AMCA 210-16).
Fans that are intended to operate only Yes (safety fans).
during emergency conditions.
------------------------------------------------------------------------
In the July 2022 NOPR, DOE noted that in its proposed rulemaking
for commercial and industrial fans and blowers, the CEC proposed to
exclude the following categories of fans: (1) safety fans (see section
III.C.2 of this document for more details on this definition); (2)
ceiling fans as defined in 10 CFR 430.2; (3) circulating fans; (4)
induced flow fans; (5) jet fans; (6) cross-flow fans; (7) embedded fans
as defined in ANSI/AMCA 214-21; \29\ (8) fans mounted in or on motor
vehicles or other mobile equipment; (9) fans that create a vacuum of 30
in. wg or greater; \30\ and (10) air curtain unit.\31\ 87 FR 44194,
44202. See Table III-3 and section III.B.3 for a discussion of embedded
fans and air curtain units and section III.B.5 for a discussion of fans
mounted in or on motor vehicles or other mobile equipment.
---------------------------------------------------------------------------
\29\ As defined in ANSI/AMCA 214-21: ``A fan that is part of a
manufactured assembly where the assembly includes functions other
than air movement.''
\30\ CEC proposed excluding these fans because AMCA 214-21 is
not applicable to this equipment. See CEC's Initial Statement of
Reason, available at efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
\31\ When the NOPR was issued, the CEC defined an air curtain
unit as equipment providing a directionally controlled stream of air
moving across the entire height and width of an opening that reduces
the infiltration or transfer of air from one side of the opening to
the other and/or inhibits the passage of insects, dust, or debris.
87 44194, 44260 fn 25.
Table III-3--Fans Recommended for Exclusion by the Working Group and the
Corresponding CEC Proposed Exclusions
------------------------------------------------------------------------
Corresponding term and
Fans recommended for exclusion by the definition proposed for
working group * exclusion in CEC proposed
regulatory text
------------------------------------------------------------------------
Radial housed unshrouded fan with Not excluded by the CEC
diameter less than 30 inches or a proposed regulatory text.
blade width of less than 3 inches.
Safety fan............................. ``Safety Fan'' See section
III.C.2 of this document.
Induced flow fan....................... ``Induced flow fan'' means a
type of laboratory exhaust fan
with nozzle and windband; the
fan's outlet airflow is
greater than the inlet airflow
due to induced airflow. All
airflow entering the inlet
exits through the nozzle.
Airflow exiting the windband
includes the nozzle airflow as
well as the induced airflow.
Jet fan................................ ``Jet fan'' means a fan
designed and marketed
specifically to produce a high-
velocity air jet in a space to
increase its air momentum. Jet
fans are rated using thrust.
Inlets and outlets are not
ducted but may include
acoustic silencers.
Cross-flow fan......................... ``Cross-flow fan'' means a fan
with a housing that creates an
airflow path through the
impeller, in a direction at
right angles to the axis of
rotation and with airflow both
entering and exiting the
impeller at the periphery.
Inlets and outlets can
optionally be ducted.
------------------------------------------------------------------------
* Note: The Working Group also recommended the exclusion of circulating
fans, which are also excluded from the CEC proposed regulation and
defined as a fan that is not a ceiling fan that is used to move air
within a space, that has no provision for connection to ducting or
separation of the fan inlet from its outlet. The fan is designed to be
used for the general circulation of air. Circulating fans are
discussed in section III.B.4 of this document.
In the July 2022 NOPR, DOE reviewed the exclusions recommended by
the Working Group, the exclusions requested by the Petitioners, the
exclusions provided in the proposed CEC regulations, and comments
received and proposed to exclude from the proposed DOE test procedure
the following fans and blowers: (1) radial housed unshrouded fans with
a diameter less than 30 inches or a blade width of less than 3 inches;
(2) safety fans; (3) induced flow fans; (4) jet fans; and (5) cross-
flow fans. 87 FR 44194, 44202.
AMCA commented in support of the proposed exclusions of (1) radial
housed unshrouded fans with a diameter less than 30 inches or a blade
width of less than 3 inches; (2) safety fans; (3) induced flow fans;
(4) jet fans; and (5) cross-flow fans. AMCA noted that these are
consistent with the ASRAC term sheet. (AMCA, No. 41 at p. 6)
DOE did not receive any other comments on these exclusions and thus
excludes from the DOE test procedure
[[Page 27322]]
the following fans and blowers: (1) radial housed unshrouded fans with
a diameter less than 30 inches or a blade width of less than 3 inches;
(2) safety fans; (3) induced flow fans; (4) jet fans; and (5) cross-
flow fans.
In the July 2022 NOPR, DOE also stated that it was considering
including an exclusion, consistent with the findings of the CEC, for
fans that create a vacuum of 30 in. wg or greater. DOE tentatively
determined that a test using AMCA 210-16 may not result in a
measurement of energy use or energy efficiency during a representative
average use cycle for fans that are exclusively used to create a vacuum
rather than produce airflow. 87 FR 44194, 44203.
In response to the July 2022 NOPR, the CEC recommended excluding
fans that create a vacuum of 30 in. wg or greater because these fans
have different operating conditions (run in stall) and will require a
different way to measure their efficiency. (CEC, No. 30 at p. 2)
The CA IOUs requested that DOE exclude fans that create a vacuum of
30 in. wg or greater from the proposed scope. The CA IOUs explained
that typically, fans that create a high vacuum operate in the unstable
range and must be reinforced with heavy housings and oversized bearings
to handle unstable operating conditions. The CA IOUs stated that DOE
may consider the 30 in. wg. too low and if so, requested DOE find an
appropriate level. (CA IOUs, No. 37 at . 8)
DOE has determined that a test using AMCA 210-16 may not result in
a measurement of energy use or energy efficiency during a
representative average use cycle for fans that are exclusively used to
create a vacuum rather than produce airflow. As noted by the CEC and
the CA IOUs, these fans operate in the stalling region (or unstable
range). Further as noted by the CEC, such fans would require a
different way to measure their efficiency. Therefore, in this final
rule, DOE excludes fans that create a vacuum of 30 in. wg or greater.
Additionally, as discussed in section III.C.2 of this document, DOE
excludes fans that designed and marketed to operate at or above 482
degrees Fahrenheit (250 degrees Celsius).
3. Embedded Fans and Blowers Exclusions
In addition to the specific exclusions discussed in the prior
section, DOE also proposed excluding certain ``embedded'' fans from the
scope of the test procedure. Fans can be distributed in commerce as
standalone equipment or can be distributed in commerce incorporated
into other equipment that requires a fan to operate. 87 FR 44194,
44203.
Section 3.25.3 of AMCA 214-21 defines a ``standalone fan'' as ``a
fan in at least a minimum testable configuration. This includes any
driver, transmission or motor controller if included in the rated fan.
It also includes any appurtenances included in the rated fan, and it
excludes the impact of any surrounding equipment whose purpose exceeds
or is different than that of the fan.'' \32\ Section 3.25.4 of AMCA
214-21 defines the term ``embedded fan'' as ``a fan that is part of a
manufactured assembly where the assembly includes functions other than
air movement.''
---------------------------------------------------------------------------
\32\ Additionally, AMCA 214-21 defines a minimum testable
configuration as ``A fan having at least an impeller; shaft and
bearings and/or driver to support the impeller; and its structure or
its housing.'' See Section 3.53 of AMCA 214-21.
---------------------------------------------------------------------------
The Working Group recommended excluding certain embedded fans. See
Table III-4 of this document. (Docket No. EERE-2013-BT-STD-0006, No.
179, Recommendations #2 and #3 at pp. 2-4)
Table III-4--Embedded Fans Recommended for Exclusion by the Working
Group
------------------------------------------------------------------------
Fans embedded in:
-------------------------------------------------------------------------
Single-phase central air conditioners and heat pumps rated with a
certified cooling capacity less than 65,000 British thermal units per
hour (``Btu/h''), that are subject to DOE's energy conservation
standard at 10 CFR 430.32(c).
Three-phase, air-cooled, small commercial packaged air-conditioning and
heating equipment rated with a certified cooling capacity less than
65,000 Btu/h, that are subject to DOE's energy conservation standard at
10 CFR 431.97(b).
Residential furnaces that are subject to DOE's energy conservation
standard at 10 CFR 430.32(y).
Transport refrigeration (i.e., Trailer refrigeration, Self-powered truck
refrigeration, Vehicle-powered truck refrigeration, Marine/Rail
container refrigerant), and fans exclusively powered by internal
combustion engines.
Vacuum cleaners.*
Heat Rejection Equipment:
Packaged evaporative open circuit cooling towers.
Evaporative field-erected open circuit cooling towers.
Packaged evaporative closed-circuit cooling towers.
Evaporative field-erected closed-circuit cooling towers.
Packaged evaporative condensers.
Field-erected evaporative condensers.
Packaged air-cooled (dry) coolers.
Field-erected air-cooled (dry) coolers.
Air-cooled steam condensers.
Hybrid (water saving) versions of all of the previously
listed equipment that contain both evaporative and air-cooled heat
exchange sections.
Air curtains.
Air-cooled commercial package air conditioners and heat pumps (CUAC,
CUHP) with a certified cooling capacity between 5.5 tons (65,000 Btu/h)
and 63.5 tons (760,000 Btu/h) that are subject to DOE's energy
conservation standard at 10 CFR 431.97(b).**
Water-cooled and evaporatively-cooled commercial air conditioners and
water-source commercial heat pumps that are subject to DOE's energy
conservation standard at 10 CFR 431.97(b).**
Single package vertical air conditioners and heat pumps that are subject
to DOE's energy conservation standard at 10 CFR 431.97(d).**
Packaged terminal air conditioners (PTAC) and packaged terminal heat
pumps (PTHP) that are subject to DOE's energy conservation standard at
10 CFR 431.97(c).**
Computer room air conditioners that are subject to DOE's energy
conservation standard at 10 CFR 431.97(e).**
[[Page 27323]]
Variable refrigerant flow multi-split air conditioners and heat pumps
that are subject to DOE's energy conservation standard at 10 CFR
431.97(f).**
------------------------------------------------------------------------
* Although the term sheet specifies ``vacuum,'' the term was intended to
designate vacuum cleaners. (Docket No. EERE-2013-BT-STD-0006; AHRI,
Public Meeting Transcript, No. 166 at p. 11).
** The recommendation only applies to supply and condenser fans embedded
in this equipment.
Stated more generally, the exclusions recommended by the Working
Group would exclude from the scope of the test procedure fans that are
embedded in regulated equipment for which the DOE metric captures the
energy consumption of the fan.\33\
---------------------------------------------------------------------------
\33\ The Working Group created a subgroup to propose potential
embedded fan exclusions, which were subsequently voted on by the
Working Group. The information used by the subgroup to develop the
proposal is available in the fans energy conservation standard
rulemaking docket. (Docket No. EERE-2013-BT-STD-0006, No. 125.2)
---------------------------------------------------------------------------
The Working Group further recommended for fans embedded in non-
regulated equipment, and/or embedded in regulated equipment other than
listed in Appendix B of the term sheet, and/or any fans that are not
supply and condenser fans in regulated equipment listed in Appendix B
of the term sheet, that the first manufacturer of a testable
configuration \34\ would be responsible for certifying the standalone
fan performance to DOE. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #4 at p. 4) \35\
---------------------------------------------------------------------------
\34\ AMCA 214-21 defines the ``minimal testable configuration''
as a fan having at least an impeller; shaft and bearings and/or
driver to support the impeller; and its structure or its housing.
\35\ As part of this recommendation, the Working Group also
recommended that if a manufacturer purchases a standalone fan to
incorporate in a product or in equipment, that manufacturer must
ensure that the design operating range (or design point) of the
embedded fan is within the certified operating range of the
standalone fan and disclose the design operating range (or design
point) of the embedded fan to the end-user. This issue does not
relate to the test procedure and is not discussed in this document.
---------------------------------------------------------------------------
The Petitioners requested that the scope of any DOE test procedure
be consistent with the scope of the term sheet. The Petitioners also
requested the test-procedure scope for commercial fans be consistent
with ASHRAE 90.1-2019, and additionally exclude embedded fans that are
part of equipment listed in section 6.4.1.1 of ASHRAE 90.1-2019. ASHRAE
90.1-2019 (See Table III-6 of this document). (Docket No. EERE-2020-BT-
PET-0003, The Petitioners, No. 1, attachment ``AMCA Petition to DOE
Cover Letter and Petition [sic] 2020110'' at pp. 7-8)
The additional exclusions for embedded fans that are part of
equipment listed in section 6.4.1.1 of ASHRAE 90.1-2019 as requested by
AMCA are included in the fan and blower exclusions to section 6.5.3.1.3
of ASHRAE 90.1-2019, ``Fan Efficiency Requirements,'' and presented in
Table III-5 of this document.
Table III-5--Embedded Fan and Blower Exclusions to Section 6.5.3.1.3 of
ASHRAE 90.1-2019 ``Fan Efficiency Requirements''
------------------------------------------------------------------------
Embedded fan and blower exclusions to Included in the exclusion
section 6.5.3.1.3 of ASHRAE 90.1-2019, recommended by the working
``fan efficiency requirements'' group?
------------------------------------------------------------------------
Embedded fans and fan arrays with a No.
combined motor nameplate horsepower of
5 hp or less or with a fan system
electrical input power of 4.1 kW or
less.
Embedded fans that are part of See Table III[dash]7.
equipment listed under section
6.4.1.1..
Embedded fans included in equipment No.
bearing a third party-certified seal
for air or energy performance of the
equipment package.
------------------------------------------------------------------------
Table III-6--Equipment Listed in Section 6.4.1.1 of ASHRAE 90.1-2019
``Minimum Equipment Efficiencies--Listed Equipment--Standard Rating and
Operating Conditions''
------------------------------------------------------------------------
Included in the embedded fan
Fans embedded in: exclusions recommended by the
working group?
------------------------------------------------------------------------
Electrically Operated Unitary Air Partially. This category
Conditioners. includes equipment above
760,000 Btu/h. The exclusions
in the term sheet apply only
to fans embedded in equipment
above 65,000 Btu/h and below
760,000 Btu/h (equivalent to
5.5 tons and 63.5 tons,
respectively as stated in the
term sheet). In addition, the
term sheet specifies that the
exclusions would apply only to
embedded ``supply and
condenser fans.''
Electrically Operated Air-Cooled Partially. This category
Unitary Heat Pumps. includes equipment above
760,000 Btu/h. The exclusions
in the term sheet apply only
to fans embedded in equipment
below 760,000 Btu/h. In
addition, the term sheet
specifies that the exclusion
would apply only to embedded
``supply and condenser fans.''
Air-, water-, and evaporatively cooled Yes, these fans are below 1 hp.
Condensing Units. In addition, it is specified
in Table 6.8.1-1 of ASHRAE
90.1-2019 that this category
only includes equipment
greater than or equal to
135,000 Btu/h.
Water-Chilling Packages................ No.
Electrically Operated Packaged Terminal Yes. However, the term sheet
Air Conditioners, Packaged Terminal specifies that the exclusion
Heat Pumps, Single-Package Vertical would apply only to embedded
Air Conditioners, and Single-Package ``supply and condenser fans.''
Vertical Heat Pumps.
[[Page 27324]]
Room Air-conditioners and Air- Yes. These fans are below 1 hp.
conditioner Heat pumps.
Warm-Air Furnaces and Combination Warm- No.
Air Furnaces/Air-Conditioning Units,
Warm-Air Duct Furnaces, and Unit
Heaters.
Gas- and Oil-Fired Boilers............. Partially. Some of these fans
are below 1 hp.
Heat-Rejection Equipment............... Yes.
Electrically Operated Variable- Yes. However, the term sheet
Refrigerant-Flow Air Conditioners. specifies that the exclusion
would apply only to embedded
``supply and condenser fans.''
Electrically Operated Variable- Partially. This category
Refrigerant-Flow and Applied Heat includes ground water source
Pumps. and ground source equipment
that is not regulated by DOE
and that was not included in
the term sheet exclusions. In
addition, the term sheet
specifies that the exclusion
would apply only to embedded
``supply and condenser fans.''
Floor-Mounted Air Conditioners and Partially. This category
Condensing Units Serving Computer includes equipment greater
Rooms. than or equal to 760,000 Btu/
h, which are not regulated by
DOE.
Commercial Refrigerators, Commercial Yes. These fans are below 1 hp.
Freezers, and Refrigeration.
Vapor-Compression-Based Indoor Pool Yes. These fans are below 1 hp.
Dehumidifiers.
Electrically Operated direct-expansion No.
dedicated outdoor air system Units,
Single-Package and Remote Condenser,
without Energy Recovery.
Electrically Operated direct-expansion No.
dedicated outdoor air system Units,
Single-Package and Remote Condenser,
with Energy Recovery.
Electrically Operated Water-Source Heat Partially. This category
Pumps. includes ground water source
and ground source equipment
that is not regulated by DOE
and was not included in the
term sheet exclusions. In
addition, the term sheet
specifies that the exclusion
would apply only to embedded
``supply and condenser fans.''
Heat Pump and Heat Recovery Chiller No.
Packages.
Ceiling-Mounted Computer-Room Air Partially. The term sheet only
Conditioners. excludes embedded fans in
computer room air conditioners
that are subject to DOE energy
conservation standards.
Walk-In Cooler and Freezer Display Door Yes. These fans are below 1 hp.
Walk-In Cooler and Freezer Non-Display Yes. These fans are below 1 hp.
Door.
Walk-In Cooler and Freezer Yes. These fans are below 1 hp.
Refrigeration System.
------------------------------------------------------------------------
In the July 2022 NOPR, DOE noted that in its proposed regulation,
the CEC proposed to exclude embedded fans, as defined in AMCA 214-21,
including embedded fans in air curtain units.\36\ In its staff report,
the CEC stated that its proposal would exclude fans embedded in
regulated and non-regulated equipment where the main function is other
than the movement of air, as long as the fan is not sold or offered for
sale as a standalone product.\37\ As reasons for exclusion, the CEC
stated that these fans are either manufactured by an original equipment
manufacturer (OEM), who embeds the fan in a piece of equipment where
the main function is something other than the movement of air, or
because they are manufactured for the purpose of being embedded into an
appliance after market.\38\ The CEC also discussed the potential
complexity of testing embedded fans and the accuracy of the results.
See section III.E.9 of this document for further discussion related to
testing 87 FR 44194, 44206-44207.
---------------------------------------------------------------------------
\36\ See Proposed regulatory language for Commercial and
Industrial Fans and Blowers, Docket No. 22-AAER-01 at
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
Note: Since the publication of the July 2022 NOPR, on September 9,
2022, the CEC has published Express terms with implemented
amendments to the proposed regulation for Commercial and Industrial
Fans and Blowers Efficiency.
\37\ See CEC Commercial and Industrial Fans and Blowers Staff
Report, Docket No. 22-AAER-01, TN #241951 at p. 16.
\38\ Id.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE proposed to exclude fans embedded in
equipment listed in Table III-4 of this document, as long as the fan is
not distributed in commerce as a standalone product, consistent with
the Working Group term sheet scope recommendations related to embedded
fans. (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendations #2
and #3 at pp. 2-4) DOE noted that the equipment listed in Table III-4
of this document includes equipment that is separately regulated by DOE
(``covered equipment'') as well as non-covered equipment (i.e.,
transportation refrigeration equipment, vacuum cleaners, heat rejection
equipment, and air curtains). 87 FR 44194, 44207. The rest of this
section discusses the comments received on each proposed exclusion and
DOE's decision for this final rule.
Greenheck commented that DOE should consider adopting the ASAP/
NRDC/ACEEE proposal to CEC \39\ regarding the issue of embedded fans in
equipment. Greenheck commented that the recommendation includes a two-
phase rulemaking approach allowing for expeditious rulemaking in phase
one for fans, while continuing to provide additional opportunities for
energy savings in phase two for built-up equipment that includes
embedded fans. Greenheck commented that including embedded fans in the
scope adds significant complexity and a two-phase approach would
provide time for additional investigation of all impacts for embedded
fans. In addition, Greenheck noted that equipment incorporating fans
are already tested at a component level, or as an entire system to AHRI
test standards, building energy codes, and in some cases, DOE test
standards (e.g., dedicated outdoor air systems equipment). Further,
[[Page 27325]]
Greenheck commented that it, as well as other manufacturers of
equipment that include a combination of fans, heating, cooling,
filtration, energy recovery, and/or other components, publishes
performance data for embedded fans as installed in the equipment.
Greenheck commented that performance data for the fan in the minimum
testable configuration is typically not available and to comply with
the scope of the DOE NOPR, manufacturers would have to retest embedded
fans in their minimum testable configuration. Greenheck commented that
the testing burden is significant and will force manufacturers to
prioritize their resources on the testing required to comply with this
regulation, rather than improving the overall efficiency of the
equipment. Greenheck asserted that the embedded fans are only a portion
of the overall energy consumption of these products and that regulating
the equipment holistically like AHRI 920 for direct-expansion dedicated
outdoor air systems (``DX-DOASes'') will result in the largest
reduction in energy consumption. (Greenheck, No. 39 at pp. 5-6)
---------------------------------------------------------------------------
\39\ See: efiling.energy.ca.gov/GetDocument.aspx?tn=224830.
---------------------------------------------------------------------------
AHAM opposed the development of test procedures, energy
conservation standards, and/or certification requirements for
categories of commercial and industrial fans and blowers that are
component parts of home appliances and supported a finished-product
approach to energy efficiency regulation. AHAM commented that expanding
the test procedure or coverage to embedded fans used in home appliances
could push finished product manufacturers to more expensive components
and increase the cost of appliances and equipment, while not
necessarily improving the energy performance of the finished product
and potentially impacting the efficacy of products such as range hoods.
AHAM added that it would significantly increase burden on manufacturers
if manufacturers of products that incorporate embedded fans are
suddenly forced to certify compliance with standards for component
parts, including the testing, paperwork, and record-keeping
requirements that accompany certification and the risks associated with
enforcement. AHAM commented that the manufacturer additional burden
would not be outweighed by a corresponding benefit. Further, AHAM
stated a concern that for both for embedded fans and air circulating
fans, the proposed efficiency requirements could drive performance
challenges due to reduced air flow. AHAM commented that given that many
products using fans are used to improve indoor air quality, such as
range hoods/downdraft fans, this is an undesirable result, which could
impact consumer health and safety for the long term. In addition, for
air circulating fans, AHAM commented that this would reduce the
performance of the primary function of the fan. AHAM also commented
that for covered products, there is no benefit to requiring embedded
fans to meet an energy conservation standard or to be tested. AHAM
stated that those products are already regulated by DOE and many
manufacturers turn to more efficient designs that include components,
such as more efficient fans to meet more stringent energy conservation
standards. (AHAM, No. 35 at pp. 6-7)
AHRI commented that DOE is proposing changes to the scope of test
procedures for commercial fans that would include fans destined for
particular applications in finished goods. AHRI stated disagreement
with DOE's plan to expand the existing scope of coverage of commercial
fans to include these products. AHRI commented that embedded fan
testing, and ultimately energy conservation standards, would save
minimal, if any, energy and would create needless testing, paperwork,
and record-keeping requirements that would raise costs for consumers.
In addition, AHRI commented that the foreword of AMCA 214-21 notes,
``AMCA Standard 214 primarily is for fans that are tested alone or with
motors and drives; it does not apply to fans tested embedded inside of
other equipment.'' AHRI commented that there is no normative procedure
for applying a stand-alone fan metric to embedded applications and
therefore recommended to only include stand-alone fans in this
regulation. (AHRI, No. 40 at p. 8) In addition, AHRI commented that
there are a variety of safety standards affected by air flow in
addition to the performance standards. AHRI commented that testing of
all legacy equipment because of a fan change will be cost and resource
prohibitive. AHRI added that if a replacement fan is not compliant
then, in most cases, an engineered-to-fit substitution would be
required, along with requisite reliability, robustness assurance
actions, and safety standard compliance. AHRI commented that costs,
risks, and time required to retest heating, ventilation, air-
conditioning and refrigeration (``HVACR'') and water heating equipment
would all be prohibitive and could be impractical if the HVACR and
water heating equipment are out of production. Further, AHRI commented
that manufacturers would be forced to rebuild an out-of-production unit
solely for the purpose of testing the new fan or risk abandoning a
reasonable repair path for consumers. AHRI further stated that there
may be instances where such part substitution makes sense, but that is
not a reasonable basis for a broad scope to a component's test
procedure. (AHRI, No. 40 at pp. 9-10)
JCI commented that the proposed changes will likely result in
elimination of current fans for those products ``outside the scope'' of
this rulemaking as an unintended consequence as fan manufactures will
seek to standardize designs and eliminate options. Therefore, per the
recommendation of the term sheet, JCI recommends that all embedded fans
be excluded from the scope of this rulemaking. JCI further commented
that there also appears to be a major design limitation as there are
few if any existing outdoor condenser fan designs, which have a FEI >
1.0. JCI stated that this issue by itself presents a major design and
test hurdle as direct drive plenum fans are not designed to be utilized
in a traditional outdoor, condenser exhaust configuration such as a
rooftop unit. (JCI, No. 34 at p. 2)
DOE notes that this final rule does not establish any certification
requirements and energy conservation standards for fans and blowers and
would not require any fan replacements or redesigns and would not
result in any changes in fan performance, or in the elimination of fan
models, or in the need to retest HVARC equipment, or added
certification burden. In addition, as discussed in section III.B.3.b of
this document, DOE is implementing exclusions for fans embedded in
covered equipment where the DOE metric already captures the energy use
of the fans, such as supply and condenser fans embedded in DX-DOASes
subject to any DOE test procedures in appendix B to subpart F of part
431. Finally, as discussed in section III.E.9 of this document, DOE
determined that some fan manufacturers test embedded fans as standalone
fans and therefore DOE has determined that there is value in
establishing a standardized test method for these fans.
AHRI commented that as DOE has indicated in a prior notice of
proposed determination and request for comment on small electric
motors, DOE should maintain consistency in its rulemaking process and
seek to establish regulatory coverage over equipment rather than the
components in such equipment. (AHRI, No. 40 at p. 9)
Trane commented that if changing an embedded fan necessitates the
re-optimization or redesign of Trane's
[[Page 27326]]
products, it will be forced to make trade-offs within the design of the
product itself in order to maintain the most cost-competitive price
point. Trane stated that for products which must already meet an energy
performance metric that captures the fans, including the majority of
fans in large commercial unitary air conditioners and air compressors,
this will mean an energy-neutral change to the overall performance of
the product. As an example, if a Trane large commercial air conditioner
must be redesigned to accommodate a larger supply fan, downgrades to
the compressors and/or heat exchangers would have to be made in order
to control costs. The new product would have a similar Integrated
Energy Efficiency Ratio (IEER)--washing out the energy savings from the
supply fan--but would be larger, more expensive, and sub-optimal.
(Trane, No. 38 at p. 3)
DOE notes that this final rule does not establish any energy
conservation standards for fans and blowers and would not impact the
efficiency and performance of fans embedded in covered equipment or
products. In addition, EPCA provides that no standard prescribed for
small electric motors (i.e., those regulated in 10 CFR part 431,
subpart X) shall apply to any such motor that is a component of a
covered product under EPCA or of covered equipment under EPCA. (42
U.S.C. 6317(b)(3)) EPCA does not establish any such prohibition for
fans and blowers. DOE further notes that EPCA does not establish any
such prohibition for electric motors either. See 42 U.S.C. 6313(b)(1)
(providing that standards for electric motors be applied to electric
motors manufactured ``alone or as a component of another piece of
equipment'').
AHRI commented that requests have been made to lower the power
threshold from less than or equal to 1hp, to less than or equal to
0.25hp, which would include a large swath of fans used in residential
products, including residential central air conditioners and heat
pumps. AHRI stated that in order to regulate ``industrial equipment
articles'' that are component parts of consumer products, DOE must
determine that ``such articles are, to a significant extent,
distributed in commerce other than as component parts for consumer
products.'' (42 U.S.C. 6312(c)(1)) AHRI commented that in general, DOE
regulates products as a whole and not by component. Although DOE has
previously regulated furnace fans and electric motors, AHRI commented
that DOE did so under unique authority provided in the sections of EPCA
specific to those products and equipment.\40\ AHRI commented that under
the general industrial component requirement to show that embedded fans
are distributed in commerce other than as component parts in a consumer
product, DOE does not have the authority to regulate fans that are
embedded in consumer products. (AHRI, No. 40 at pp. 5-6)
---------------------------------------------------------------------------
\40\ AHRI commented that DOE is required by EPCA to consider and
prescribe new energy conservation standards or energy use standards
for electricity used for purposes of circulating air through duct
work. Id. 42 U.S.C. 6295(f)(4)(D); Id. 42 U.S.C. 6313(b)(1)
(covering electric motors ``alone or as a component of another piece
of equipment'').
---------------------------------------------------------------------------
As discussed, on August 19, 2021, DOE published a final
determination classifying certain fans and blowers as covered equipment
and determining that fans and blowers meet the three statutory criteria
for classifying industrial equipment as covered (42 U.S.C. 6311(2)(A)),
including that fans and blowers are to a significant extent distributed
in commerce for industrial or commercial use. See 86 FR 46579, 46586-
46588. Further, ``covered equipment'' consists of certain industrial
equipment, which in turn excludes covered products, other than
industrial equipment that is a component of a covered product. (42
U.S.C. 6311(1) and (2)(A)(iii) DOE also noted, in a footnote, that
distribution for residential use does not preclude coverage as covered
equipment so long as to a significant extent the equipment is of a type
that is also distributed in commerce for industrial and commercial use.
See 86 FR 46579, 46586. As such, DOE disagrees with AHRI's assessment
of DOE's authority. DOE can regulate fans and blowers embedded in a
covered product.
a. Fans and Blowers Embedded in Non-Covered Equipment
Consistent with the Working Group term sheet scope recommendation
(Docket No. EERE-2013-BT-STD-0006-0179, Recommendation #2 at p. 2), DOE
proposed to exclude fans that are exclusively embedded in transport
refrigeration (i.e., trailer refrigeration, self-powered truck
refrigeration, vehicle-powered truck refrigeration, and marine/rail
container refrigeration) from the scope of the test procedure. 87 FR
44194, 44207.
In response to the July 2022 NOPR, the CEC recommended excluding
fans mounted in motor vehicles or other mobile equipment since the fans
are smaller in size and, although they require electricity to operate,
the source of electrical power is generated by the engine of the motor
and not the public electrical grid. The CEC noted that Table III-8 of
the July 2022 NOPR may provide the exclusion for these fans, but that
the wording was unclear (CEC, No. 30 at p. 2)
DOE did not receive any additional comments on this exclusion.
Further, because DOE is not adopting a definition of ``exclusively
embedded fan'' (see section of this III.B.3.c document) in this final
rule, DOE excludes fans that are embedded in transport refrigeration
and removed the term ``exclusively'' as proposed in the July 2022 NOPR.
In addition, DOE discusses the exclusion of fan powered by combustion
engines in section III.B.5 of this document.
In the July 2022 NOPR, consistent with the Working Group term sheet
scope recommendation (Docket No. EERE-2013-BT-STD-0006-0179,
Recommendation #2 at p. 2), DOE proposed to exclude fans exclusively
embedded in vacuum cleaners from the scope of the test procedure. 87 FR
44194, 44207.
In response to the July 2022 NOPR, AHAM agreed that fans embedded
in consumer/residential vacuum cleaners should be exempt from the
scope. (AHAM, No. 35 at p. 5)
AHAM commented that it opposes including fans embedded in consumer
home appliances, whether those products are DOE ``covered products'' or
not, in the scope of the test procedure and/or energy conservation
standards. AHAM noted that fans embedded in most home appliances would
not be implicated by DOE's currently proposed definition of embedded
fans because most are under 1 horsepower. However, AHAM noted that a
lower threshold of 0.25 hp would include fans used in a number of
covered products.\41\ AHAM added that there are a few products that
might use fans that meet DOE's definition and AHAM objects to those
fans being considered commercial and industrial fans. AHAM is concerned
that coverage of such fans could negatively impact the product
performance of products such as range hoods/downdraft fans that are
critical for improving indoor air quality in homes. AHAM commented that
DOE should exclude embedded fans used in residential products such as
range hoods/downdraft fans and hand dryers as well as dryer booster
fans and fans used in commercial clothes dryers.
[[Page 27327]]
Additionally, AHAM is concerned that commercial clothes washers could
be implicated even by the 1 horsepower limitation and requested that
DOE specifically exclude fans used in commercial clothes washers from
the scope of its regulation. (AHAM, No. 35 at pp. 4-5)
---------------------------------------------------------------------------
\41\ These products include but are not limited to: residential
refrigerator/freezers, clothes washers and dryers, dishwashers, room
air conditioners, portable air conditioners, dehumidifiers, and (in
the future) room air cleaners.
---------------------------------------------------------------------------
In this final rule, DOE excludes fans that are embedded in vacuum
cleaners from the scope of the test procedure, as proposed. Further
because DOE is not adopting a definition of ``exclusively embedded
fan'' (see section III.B.3.c of this document), DOE removes the use of
the term ``exclusively'' as proposed in the July 2022 NOPR. DOE notes
that this final rule establishes a test procedure for fans and blowers
and does not adopt any energy conservation standards. This final rule
will not have any impacts on the performance of the fan of the larger
equipment in which the fan is embedded. In addition, as noted in
section III.B of this document, DOE establishes a lower shaft input
power limit of 1 hp (0.89 kW of electrical input power) and that the
lower power limit of 1 horsepower (0.89 kW) excludes most fans used in
regulated and non-regulated consumer products, including range hoods.
Finally, as discussed in section III.B.3.b of this document, DOE is
implementing exclusions for fans embedded in covered equipment where
the DOE metric already captures the energy use of the fans.
In the July 2022 NOPR, consistent with the Working Group term sheet
scope recommendations (Docket No. EERE-2013-BT-STD-0006-0179,
Recommendation #2 at p. 2), DOE also proposed to exclude fans
exclusively embedded in heat rejection equipment from the scope of the
test procedure (See Table III-4 of this document for a list of the heat
rejection equipment). DOE noted that fans used in heat rejection
equipment are primarily fabricated in-house by the heat rejection
equipment manufacturer and that these fans are not sold in a standalone
configuration.\42\ 87 FR 44194, 44207.
---------------------------------------------------------------------------
\42\ In some cases, the heat rejection equipment manufacturer
may purchase the impeller and assemble the fan in a housing which is
tied to the structure of the heat rejection equipment.
---------------------------------------------------------------------------
In response to the July 2022 NOPR, Trane commented that DOE should
align with the CEC proposed regulation in which the definition of
embedded fans includes fans used in heat rejection equipment. Trane
commented that heat rejection fans for HVAC systems are not designed
for specific flow of air, and thus a metric based on air flow is not
valid for heat rejection fans such as condenser fans. Trane noted that
because a heat rejection fan's purpose is to reject heat from a system,
these fans are designed in conjunction with a heat exchanger solely for
optimizing removal of heat from a system. Trane commented that
enforcing fan efficiency requirements on these definite purpose fans
will require re-optimization of the heat rejection system that will not
impact overall system efficiency and building energy consumption. Trane
stated that this would impact manufacturer design cost, manufacturing
cost, and end customer cost with no measurable energy benefit or
payback. (Trane, No. 38 at p. 2)
Trane added that in order to align with CEC and the definitions of
AMCA 214-21, DOE should add to the list of exclusions: (1) Air cooled
chillers; and (2) Unitary package units above 760k btu (whose system
metric is covered in ASHRAE 90.1-2019). (Trane, No. 38 at p. 2)
The CA IOUs recommended that DOE exclude all condenser fans from
the scope of the test procedure. The CA IOUs explained that DOE
proposed to accept the Cooling Tower Institute's recommendation to
exclude heat rejection fans on various unregulated equipment and agreed
with this decision as these fans would be difficult or impossible to
test using the underlying procedures. Furthermore, the CA IOUs stated
that improving the fan's efficiency would not necessarily improve the
system's efficiency because of its embedment in a larger system. The CA
IOUs commented that the same logic would apply to condenser fans in
other types of equipment (e.g., chillers and unregulated commercial
unitary air conditioners). (CA IOUs, No. 37 at p. 10)
Daikin commented that fans used in air-cooled condensers have the
same issues as fans used in cooling towers and other heat rejection
equipment. (Public Meeting, No. 18 at p. 16) DOE notes that the Working
Group did not list chillers and air-cooled condensers, and specifically
limited the exemption to regulated commercial unitary air conditioners
with a certified cooling capacity between 5.5 tons (65,000 Btu/h) and
63.5 tons (760,000 Btu/h). As previously noted, the embedded fan
exclusions recommended by the Working Group would exclude from the
scope of the test procedure fans that are embedded in regulated
equipment for which the DOE metric captures the energy consumption of
the fan. In line with the approach taken by the Working Group, and as
discussed in section III.B.3.b of this document, DOE is implementing
exclusions for fans embedded in covered equipment where the DOE metric
already captures the energy use of the fans. Chillers are currently not
a covered equipment and DOE does not regulate commercial unitary air
conditioners with a certified cooling capacity above 760,000 Btu/h. Air
cooled condensers are also not regulated by DOE. Although fans used in
these equipment may face similar issues than fans used in heat
rejection equipment, both pieces of equipment were not specifically
listed for exemption by the Working Group. Therefore, DOE is not
excluding fans used in these categories of equipment. Further, DOE
excludes other condenser fans in several types of covered equipment, if
the DOE metric captures the energy use of these fans. (See section
III.B.3.b of this document.) In addition, in this final rule, DOE is
not establishing any energy conservation standards and the adoption of
a test procedure will not impose fan efficiency requirements. For these
reasons, DOE is maintaining the exclusion of fans embedded in heat
rejection equipment as proposed in the July 2022 NOPR. Further, because
DOE is not adopting a definition of ``exclusively embedded fan'' (see
section of this III.B.3.c document), DOE removes the use of the term
``exclusively'' as proposed in the July 2022 NOPR.
In addition, in the July 2022 NOPR, DOE proposed that fans embedded
in air curtains be excluded from the scope of the proposed test
procedure. 87 FR 44194, 44207. In response to the July 2022 NOPR, The
CEC commented in support of the proposed exclusion of air curtains.
(CEC, No. 30 at p. 2) DOE did not receive any additional comments on
this issue and is excluding fans in air curtains as proposed.
b. Fans and Blowers Embedded in Covered Equipment
In the July 2022 NOPR, DOE also proposed that the test procedure
would exclude fans in covered equipment in which the fan energy use is
already captured in the equipment specific test procedures. DOE
proposed to adopt an exclusion for fans embedded in equipment listed in
Table III-4,\43\ as long as the fan is not distributed in commerce as a
standalone product. DOE proposed to additionally exclude fans embedded
in DX-DOASes to reflect the DOE proposed test procedure and metric for
DX-DOASes that, if adopted,
[[Page 27328]]
would incorporate fan energy use.\44\ DOE noted that the proposed
exclusions were consistent with the recommendations of the Working
Group. DOE also noted that the proposed approach would avoid regulating
fans for which existing DOE regulations account for their energy use by
excluding such fans from the test procedure if distributed exclusively
embedded in the listed equipment. DOE proposed that to the extent a fan
is distributed in commerce as a stand-alone fan, and therefore is not
limited to use in specific equipment, or embedded in equipment in which
its energy use is not addressed in a DOE test procedure, such a fan
would be subject to the DOE test procedure. 87 FR 44194, 44207. Table
III-7 of this document summarizes the embedded fans proposed for
exclusion from the scope of the test procedure.
---------------------------------------------------------------------------
\43\ DOE notes that while the Working Group recommended to
exclude fans in residential furnaces that are subject to DOE's
energy conservation standard at 10 CFR 430.32(y), furnace fans are
excluded from the definition of ``fan and blower'' and therefore do
not need to be listed as a proposed exclusion.
\44\ See 86 FR 72874, 72889-72890 (December 23, 2021).
Table III-7--Embedded Fans Excluded From the Scope of the Test Procedure
------------------------------------------------------------------------
Fans embedded in:
-------------------------------------------------------------------------
DX-DOASes subject to any DOE test procedures in appendix B to subpart F
of part 431.*
Single-phase central air conditioners and heat pumps rated with a
certified cooling capacity less than 65,000 British thermal units per
hour (``Btu/h''), that are subject to DOE's energy conservation
standard at 10 CFR 430.32(c).
Three-phase, air-cooled, small commercial packaged air-conditioning and
heating equipment rated with a certified cooling capacity less than
65,000 Btu/h, that are subject to DOE's energy conservation standard at
10 CFR 431.97(b).
Transport refrigeration (i.e., Trailer refrigeration, Self-powered truck
refrigeration, Vehicle-powered truck refrigeration, Marine/Rail
container refrigerant), and fans exclusively powered by combustion
engines.
Vacuum cleaners.
Heat Rejection Equipment:
Packaged evaporative open circuit cooling towers.
Evaporative field-erected open circuit cooling towers.
Packaged evaporative closed-circuit cooling towers.
Evaporative field-erected closed-circuit cooling towers.
Packaged evaporative condensers.
Field-erected evaporative condensers.
Packaged air-cooled (dry) coolers.
Field-erected air-cooled (dry) coolers.
Air-cooled steam condensers.
Hybrid (water saving) versions of all of the previously
listed equipment that contain both evaporative and air-cooled heat
exchange sections.
Air curtains.
** Air-cooled commercial package air conditioners and heat pumps (CUAC,
CUHP) with a certified cooling capacity between 5.5 tons (65,000 Btu/h)
and 63.5 tons (760,000 Btu/h) that are subject to DOE's energy
conservation standard at 10 CFR 431.97(b).
** Water-cooled and evaporatively-cooled commercial air conditioners and
water-source commercial heat pumps that are subject to DOE's energy
conservation standard at 10 CFR 431.97(b).
** Single package vertical air conditioners and heat pumps that are
subject to DOE's energy conservation standard at 10 CFR 431.97(d).
** Packaged terminal air conditioners (PTAC) and packaged terminal heat
pumps (PTHP) that are subject to DOE's energy conservation standard at
10 CFR 431.97(c).
** Computer room air conditioners that are subject to DOE's energy
conservation standard at 10 CFR 431.97(e).
** Variable refrigerant flow multi-split air conditioners and heat pumps
that are subject to DOE's energy conservation standard at 10 CFR
431.97(f).
------------------------------------------------------------------------
** DX-DOASes are not currently subject to a DOE test procedure. However,
there is an ongoing rulemaking to establish a test procedure for DX-
DOASes that DOE anticipates will be finalized before the final rule of
the fans and blowers rulemaking. Information about this rulemaking can
be found at www.regulations.gov under Docket No. EERE-2017-BT-TP-0018.
* The exclusion only applies to supply and condenser fans embedded in
this equipment.
NEEA commented in support of DOE's definitions and scope for
inclusion and exemptions of embedded fans, but recommended DOE
establish a consistent approach to ensure fan efficiency is accounted
for in other regulated products. NEEA commented that this would include
a similar methodology for each product, even if the exact conditions
are not the same across all products. Conceptually, NEEA stated that
this could function as a checklist to ensure fans are appropriately
accounted for: (1) the total fan energy use is accounted for in the
``average period of use'' of that product (e.g., economizing fan energy
use for CUAC); (2) the testing conditions represent the operating
conditions of the fan (e.g., representative static pressure for
packaged HVAC); (3) the benefits of variable speed fans and right
sizing of a fan are accounted for (i.e., will these energy saving
measures increase the regulated rating). (NEEA, No. 36 at pp. 7-8)
DOE accounts for fan energy use on a product-by-product basis. Any
consideration of fan energy use in other covered product or equipment
would be addressed in the test procedure rulemakings specific to each
such product or equipment.
AHRI recommended that DOE exclude fans embedded in commercial water
heaters and boilers from the rulemaking. AHRI commented that the metric
for commercial water heaters includes the embedded fan's energy,
meeting the criteria which was the basis for limited exclusions in
regulated products recommended by the Working Group. AHRI commented
that the test procedure and energy conservation standards for
commercial boilers do not capture the fan power. However, AHRI
commented that the actual energy savings potential from applying the
proposed fan regulation to a boiler or water heater fan itself is
likely to be small and the total energy consumption of the equipment
may be increased due to effects on combustion. In addition, AHRI stated
that the complexity of integrating a new fan system into a boiler or
water heater is considerable as fans are integral parts of the
combustion
[[Page 27329]]
systems, raising costs that are ultimately passed on to consumers. AHRI
commented that the appropriate approach is to work through the
commercial boiler test standard's consensus process and find a path to
incorporate the electrical energy used in a boiler system into the test
procedure and the equipment ratings to include electrical power
consumption from the fan is currently being drafted. AHRI added that it
estimates the market of the commercial boiler and water heater
industries is small, with annual shipments of approximately 20,000
boiler units and under 2,000 hot water supply boilers. In addition,
AHRI noted that fans used in commercial storage water heaters are
virtually all under 1 horsepower and only exceed 1 horsepower in
commercial boilers and hot water supply boilers with input rates
exceeding two million Btu/h. For hot water supply boilers, AHRI
commented that approximately 12 percent of models exceed 2 million Btu/
h, or approximately 250 boilers per year nationally.\45\ Based on these
shipments, AHRI estimated that the potential 30-year electricity
savings from commercial boiler fans would be on the order of 0.016
quads nationally and noted a potential that fan changes will result in
increased standby losses and reduction in thermal efficiency that would
result in a net energy loss. AHRI added that given the small degree of
energy savings and the small shipment volume relative to the
significant redesign, testing, and certification costs associated with
incorporating a new fan, it is highly unlikely that there are
significant positive consumer benefits. (AHRI, No. 40 at pp. 11-12)
---------------------------------------------------------------------------
\45\ AHRI cited U.S. Department of Energy, Technical Support
Document: Energy Efficiency Program for Consumer Products and
Commercial and Industrial Equipment: Commercial Water Heating
Equipment, April 18, 2016, Figure 3.10.26, p. 3-29).
---------------------------------------------------------------------------
As noted by AHRI, the metric for commercial water heaters includes
the embedded fan's energy, meeting the proposed criteria to identify
the embedded fan exemption. However, as AHRI noted, fans in this
equipment are below 1 hp shaft power and therefore are already excluded
based on the adopted power limits discussed in section III.B.1 of this
document. Therefore, DOE did not propose and is not adopting to
specifically list this equipment in the list of covered equipment for
which the fan is excluded from the test procedure. For embedded fans in
commercial boilers, as noted by AHRI, only the larger units would
incorporate fans that meet the scope criteria discussed in section
III.B.1 of this document. However, as noted by AHRI, the current DOE
test procedure for commercial boilers does not capture the fan energy
use; therefore, DOE did not propose and is not adopting to list this
equipment as part of the covered equipment for which the fan is
excluded from the test procedure. Instead, DOE is exempting fans
embedded in the equipment listed in Table III-7, as proposed in the
July 2022 NOPR and continues to exclude fans in covered equipment in
which the fan energy use is already captured in the equipment specific
test procedures. Further, because DOE is not adopting a definition of
``exclusively embedded fan'' (see section of this III.B.3.c document),
DOE removes the use of the term ``exclusively'' as proposed in the July
2022 NOPR. In addition, DOE notes that this final rule does not adopt
energy conservation standards or certification requirements and any
impacts from setting potential energy conservation standards (including
equipment redesign and consumer benefits) will be analyzed as part of
any separate energy conservation standard rule.
Daikin commented that it was appropriate to exempt embedded fans in
DOE-regulated products and added that DOE should also exempt fans in
equipment that are regulated by IECC and [ASHRAE] 90.1 (Public Meeting
transcript, No. 18 at p. 15-16)
As noted previously, DOE is exempting fans embedded in the
equipment listed in Table III-7, as proposed in the July 2022 NOPR and
continues to exclude fans in covered equipment in which the fan energy
use is already captured in the equipment specific test procedures. In
addition, DOE is not exempting fans that are in equipment that are
regulated by IECC and ASHRAE 90.1, consistent with the term sheet.
Instead, DOE excludes fans embedded in equipment listed in Table III-7,
consistent with the Working Group term sheet scope recommendations
related to embedded fans.
c. Exclusively Embedded Fans
In the July 2022 NOPR, DOE further clarified that DOE proposed to
exclude embedded fans that are not distributed in commerce as
standalone fans. DOE acknowledged that in a number of instances, a
standalone fan purchased by a manufacturer for incorporation into a
unit of listed equipment may be indistinguishable based on physical
features from a fan that is purchased by a manufacturer for
incorporation into non-listed equipment or from a fan used as a
standalone fan. DOE noted that during the ASRAC negotiations, AHRI
conducted a survey of its members to determine the number of fans
purchased versus manufactured by the equipment manufacturer. (Docket
No. EERE-2013-BT-STD-0006, AHRI, No. 125.3 at p. 1) AHRI estimated that
over 80 percent of all fans that are used as components across all
commercial regulated equipment are manufactured by the equipment
manufacturer. Id. This percentage was higher for commercial air-
conditioning and heat pump equipment and was estimated to be between 94
and 99 percent. 87 FR 44194, 44208.
In order to provide additional specificity as to the fans that
would be subject to the embedded fan exclusion, in the July 2022 NOPR,
DOE proposed to use the term ``exclusively embedded fans'' to designate
the fans covered by the embedded fan exclusion. DOE proposed to define
``exclusively embedded fan'' as: a fan or blower that is manufactured
and incorporated into a product or equipment manufactured by the same
manufacturer and that is exclusively distributed in commerce embedded
in another product or equipment. Based on this information, DOE
tentatively determined that the vast majority of fans used as
components in regulated commercial HVACR equipment would meet the
proposed definition of exclusively embedded fan and would not be
subject to the test procedure as proposed in the July 2022 NOPR. DOE
further provided examples illustrating how the proposed definition of
exclusively embedded fan would impact whether a fan must be tested and
certified to DOE. 87 FR 44194, 44208.
In response to the July 2022 NOPR, ebm-papst commented that it does
not believe it to be common practice that original equipment
manufacturers (``OEMs'') fabricate fans in the literal sense. ebm-papst
added that very few OEMs, if any, in the U.S. fabricate their own
impellers and that in its experience no American OEMs fabricate their
own fan motors or their own electronic fan speed controller. However,
ebm-papst added that it is common practice for OEMs to purchase major
sub-components from independent suppliers, such as ebm-papst. (ebm-
papst, No. 31 at p. 6)
Morrison commented that 95 percent of fans it manufactures are used
in HVAC equipment. (Morrison, No. 42 at p. 3)
As noted in the July 2022 NOPR, DOE relied on data from AHRI to
estimate the share of embedded fans that are manufactured in-house by
OEMs vs. purchased and notes that these
[[Page 27330]]
estimates may not reflect individual manufacturer practices.
In response to the July 2022 NOPR, DOE received several comments
related to the proposed definition of ``exclusively embedded fan''.
AHRI stated support for the AMCA 214-21 definition of an embedded
fan as ``a fan that is part of a manufactured assembly where the
assembly includes functions other than air movement.'' (AHRI, No. 40 at
p. 8)
NEEA commented in support of DOE's proposals related to embedded
fans and supports the definition of exclusively embedded fans, which
adds additional clarity to what is included or excluded from
regulation. (NEEA, No. 36 at p. 7)
The Efficiency Advocates supported DOE's proposal regarding
embedded fans. The Efficiency Advocates commented that generally fans
can be sold as standalone products or they may be embedded within a
piece of equipment that requires the fan to operate. The Efficiency
Advocates commented that in the NOPR, DOE defines ``exclusively
embedded'' fans and excludes various types of exclusively embedded fans
consistent with the Working Group recommendations. The Efficiency
Advocates stated that these exclusions, summarized in Table III-8 of
the July 2022 NOPR, essentially apply only to embedded fans in
regulated equipment for which the DOE metric captures the energy
consumption of the fan. The Efficiency Advocates support this approach
to help ensure that inefficient fans are not embedded into products for
which energy use is not captured by a DOE efficiency metric.
(Efficiency Advocates, No. 32 at p. 2)
Morrison commented that the exclusively embedded fans it
manufactures have a clearly identified label with a unique part number
and are exclusive per the manufacturer, with full traceability through
the sales order process to a ship-to site. Morrison stated a concern
about double regulation for parts that are instrumental to the
equipment's already existing regulation and now an added layer of
regulation that adds to the cost of products but provides no additional
energy savings. (Morrison, No. 42 at p. 4) Morrison added that the fans
it manufactures are built to order for the customer and are
application-specific designs with unique part numbers on the label that
identify the customer and location. Morrison stated that all shipments
have a unique Sales Order that confirms the ship-to location and part
number and would be traceable to the OEM's appliance. Morrison
commented that the fans it manufactures are assembled into an appliance
and nearly all are in the covered product category that has a metric
inclusive of the fan energy. In addition, Morrison pointed out that
this proposed added layer of test for standalone fans before embedding
amounts to duplicate regulation and double counting of the energy
savings, and that these fans are currently tested by the OEMs in the
appliance and would not need the added cost of regulation as a fan.
(Morrison, No. 42 at p. 3)
AHAM commented that embedded fans used in covered products should
be excluded. AHAM commented that it is critical that those fans be
excluded regardless of whether they are imported or sold for inclusion
in a domestically manufactured product or are imported as part of that
product. AHAM requested that should DOE include fans that are embedded
in consumer products, DOE ensure that all embedded fans--whether sold
for incorporation into the product or imported already in the product--
are treated the same. Otherwise, AHAM commented that domestically
manufactured products could be at a disadvantage, which is contrary to
the Administration's goals to increase domestic manufacturing. (AHAM,
No. 35 at p. 5)
AHRI commented that all embedded fans, and replacement fans for
these finished goods, regardless of whether they are domestically
produced or imported as part of the product, should be exempt. Under
DOE's proposal, AHRI commented that finished goods manufactured
overseas would be treated differently from those manufactured
domestically. AHRI stated that, as proposed, a manufacturer would be
able to buy and embed a standalone fan and not be subject to the
regulation if the finished product was imported. However, AHRI added, a
domestic manufacturer buying a fan for manufacture domestically would
be subject to the proposed rule, as written, and DOE has not considered
the burden this places on domestic manufacturers. (AHRI, No. 40 at pp.
7-8)
Morrison commented that the exemption for exclusively embedded fans
would lead to trade-restrictive issues. Morrison commented that using a
scenario of covered equipment with an exempted embedded fan: (1) If the
OEM produces the testable fan configuration, then those fans are exempt
from fan regulation (2) But if an identical fan construction is
delivered as a testable configuration by a supplier to an OEM factory
in the U.S., then the fan is considered a standalone fan and therefore
will be in the scope of the regulation and testing will be required (3)
On the other hand, if the U.S. OEM has a joint venture north or south
of the border, then it can receive and install unregulated fans there
and sell the unit back in the U.S. without any fan regulation (4)
Another scenario is possible with the OEM factory in a foreign country
and under that scenario, the embedded fan is exempt from fan
regulation. Morrison commented that this would appear to promote the
use of offshore production and would not just favor foreign-made
equipment but would encourage more use of imported equipment.
(Morrison, No. 42 at p. 3) Similarly, ebm-papst did not support the
proposed definition of standalone fans in the NOPR and provided the
following scenario: If an OEM fabricates the testable fan configuration
itself, the fans will be exempt from fan regulation. However, ebm-papst
stated, if an identical fan construction is supplied as a testable
configuration by a supplier to an OEM factory in the U.S., then the fan
will become a standalone fan and therefore will be in the scope of the
regulation. ebm-papst added that if the U.S.-based OEM owns a factory
outside of the U.S., then it will be permitted to receive and install
unregulated fans there, and sell the unit in the U.S. ebm-papst further
commented that if the OEM factory is in a foreign country altogether,
then the embedded fan will be exempt from the fan regulation. ebm-papst
commented that the proposed exclusions would be a restraint of domestic
trade, while favoring foreign OEM factories. (ebm-papst, No. 31 at p.2)
ebm-papst requested clarification regarding the proposed approach
to exclude embedded fans if they are fabricated by the OEM, while all
external fabricators would be burdened by the regulation. (ebm-papst,
No. 31 at p. 1) ebm-papst requested that DOE ensure that all embedded
fans--whether sold for incorporation into the product or imported
already in the product--be treated the same. Otherwise, ebm-papst
commented that domestically manufactured products could be at a
disadvantage, which is contrary to the Administration's goals to
increase domestic manufacturing. Further, ebm-papst commented that
there are no unique physical features that could be used to distinguish
a fan that is exclusively designed for use in equipment listed in Table
III 8 of the NOPR. However, ebm-papst opposes the attempt to treat
exclusively embedded fans differently, merely due to potential
differences in the fans' supply chains. (Id. at p. 6)
[[Page 27331]]
As noted previously, the proposed exclusions for certain embedded
fans listed in Table III-8 of the July 2022 NOPR, would only apply to
fans that are manufactured in-house by the manufacturer of the
equipment or to fans that are imported already embedded in equipment
listed in Table III-8 of the July 2022. Fans purchased by OEMs in the
U.S. to be incorporated into equipment listed in Table III-8 of the
July 2022 NOPR would not be excluded, while fans purchased and
incorporated by an OEM outside of the U.S. would be excluded. As noted
by the stakeholders, the proposed definition of exclusively embedded
fans could therefore disadvantage domestic fan suppliers. For this
reason, DOE is not establishing a definition of ``exclusively embedded
fan''. As this time, DOE is not differentiating the embedded fan listed
for exclusion in Table III-7 depending on whether it is exclusively
distributed in commerce embedded in another product or equipment listed
in that table (i.e., depending on whether it is manufactured and
incorporated into a product or equipment manufactured by the same
manufacturer). By removing the proposed ``exclusively embedded fan''
definition, all embedded fans, whether sold for incorporation into the
product or already incorporated in the product, would be exempted if
embedded in equipment listed in Table III-7 of this document. In the
future, DOE may consider an approach to provide additional specificity
as to how to identify fans that would be sold for incorporation in
equipment listed in in Table III-7 of this document.
JCI requested clarifications on how DOE will verify the performance
of a fan or blower in a finished-goods unit in the field. JCI asked if
the fans would have to be removed from equipment and sent to a lab for
testing. (JCI, No. 34 at p. 2)
DOE's regulations apply to the point of manufacture and not to the
equipment as installed in the field. If the fan is embedded in another
equipment, testing would be performed in accordance with the provisions
described in section III.E.9 of the document.
AHAM commented that it does not support an approach that would
require OEMs to certify embedded fans used in their finished products
and that would hold OEMs responsible for certification, testing and
record-keeping for the fans embedded in their products. AHAM commented
that the fan manufacturers should bear this burden given that they have
the expertise and facilities to conduct the testing, etc. (AHAM, No. 35
at p. 7)
DOE notes that the fan manufacturer would be responsible for
testing and certifying the fan. If the OEM is also the fan manufacturer
(and fabricates the fan in-house), then that OEM would be responsible
for testing and certifying the fan if included in the scope of the test
procedure.
4. Air Circulating Fans
In the July 2022 NOPR, DOE noted that AMCA 230-15 (with errata) did
not include any limitation in terms of input power of the air
circulating fans that can be tested in accordance with the test
procedure. DOE further noted that the AMCA committee was considering
limiting the scope of AMCA 230-15 (with errata) to air circulating fans
with input power of 125 W and above to focus on commercial and
industrial fan applications and exclude residential fans, such as tower
fans and bladeless fans. 87 FR 44194, 44210.
In the July 2022 NOPR, DOE tentatively determined that the proposed
test procedure would provide a representative measurement of energy use
or energy efficiency during a representative average use cycle for all
air circulating fans. Therefore, at the time, DOE proposed to include
all categories of air circulating fans in the scope of the proposed
test procedure; i.e., including equipment with input power less than
125 W. DOE noted that should additional information justify excluding
fans with input power less than 125 W from the scope (or any other
power limit that may be justified), DOE may consider applying a power
limit in the final rule as considered by the AMCA committee and
supported by stakeholders. In addition, DOE noted that it may consider
specifying that 125 W corresponds to the air circulating fan's input
power at maximum speed. 87 FR 44194, 44210.
The Efficiency Advocates stated support for including air
circulating fans within the test procedure scope, so that published
efficiency information for these products is based on a standardized
test procedure and to allow DOE to consider future potential energy
conservation standards. (Efficiency Advocates, No. 32 at p. 2)
AMCA commented that the stakeholders of residential circulating
fans are not represented by AMCA and have not previously been involved
in the fans-and-blowers rulemaking. Additionally, AMCA noted that the
demarcation of the scope of the AMCA 230 test standard under revision
will start above 125 W. AMCA questioned if DOE has alerted stakeholders
of residential circulating fans that they are in the process of being
regulated as it would be fair to enable them to weigh in on the
proposed test procedure. (AMCA, No. 41 at p. 5) AMCA recommended the
exclusion of ACFH with less than 125-W nameplate electrical power,
which is the demarcation between the published IEC Standard 60879:2019,
``Comfort fans and regulators for household and similar purpose,'' \46\
and AMCA 230 (next revision). AMCA commented that fans covered by IEC
60879 generally are mass-produced, mass-imported, mass-sales
residential products, which are made by stakeholders that have not been
represented in any U.S. fan-regulation activity to date, such as ASRAC,
California Title 20, or model/state energy codes. (AMCA, No. 41 at pp.
7-8)
---------------------------------------------------------------------------
\46\ IEC 60879:2019 specifies the performance-measuring methods
of comfort fans and regulators for household and similar purposes,
including conventional fans, tower fans, and bladeless fans, their
rated voltage being not more than 250 V for single-phase fans and
480 V for other fans, and their rated power input being less than
125 W.
---------------------------------------------------------------------------
ebm-papst recommended limiting the scope of the circulation fan
test procedure to fans with nameplate power ratings of at least 125 W
in an effort to keep the focus of this rulemaking on commercial and
industrial fans. ebm-papst added that the scope of EU 327/2011 is
limited at 125 W and that lower-power circulation fans are in the scope
of IEC 60879. (ebm-papst, No. 31 at p. 6)
Since the publication of the July 2022 NOPR, AMCA published AMCA
230-23, and this latest version of the industry standard only covers
air circulating fans with input power greater than or equal to 125 W.
Further, to date, stakeholders representative of the market of
circulating fans with input power less than 125 W s have not commented
on this rulemaking. In addition, in the NOPR, DOE did not review IEC
60879:2019, which stakeholders indicated would be the most appropriate
industry test procedure for these fans. For these reasons, at this
time, DOE is limiting the scope of the test procedures to air
circulating fans with input power greater than or equal to 125 W, as
measured by the test procedure at high speed.
AHAM commented that consumer fans such as desk fans, box fans,
pedestal fans, should not be included in the scope of commercial and
industrial fans and blowers. AHAM commented that this would be in
direct contradiction to EPCA, and consumer fans have different average
representative uses than commercial and industrial fans. AHAM urged DOE
[[Page 27332]]
to either specifically exclude consumer air circulating fans from the
scope of coverage and noted that a 125 W limit would be an effective
way to distinguish consumer fans so long as the 125-W threshold applies
to the fan rating alone and not to the entire product or the fan and
motor. AHAM noted this could implicate products like residential fan-
heaters and stated it was unclear whether the relevant definitions in
the applicable AMCA and IEC 60879 standards would take the products out
of scope. As such, AHAM requested that DOE make it clear that all
residential/consumer fans are exempt. AHAM added that it was their
understanding that DOE's proposal did not include bladeless circulation
fans in the scope of air circulating fans based on the proposed
definitions. AHAM agrees that such fans should not be included. AHAM
added that DOE should treat other consumer fans the same way, i.e., no
consumer fan should be included in the scope of the commercial and
industrial fan test procedure or energy conservation standards). (AHAM,
No. 35 at p. 6)
AHAM commented against DOE's proposal to include consumer
(residential) air circulating fans and embedded fans used in consumer
(residential) products in the scope of its commercial and industrial
fans and blowers test procedure. AHAM commented that this would be
contrary to EPCA, DOE's coverage determination, and essential EPCA
public policy. AHAM commented that consumer fans and fans used in
consumer products are, by definition, not commercial/industrial fans or
blowers. AHAM added that Congress's intent was to include only
commercial and industrial fans and blowers under the scope of ``fans''
and ``blowers'' in 42 U.S.C. 6311(2)(B). First, AHAM noted that fans
and blowers are listed as types of industrial equipment, which
indicates an intent to cover commercial and industrial equipment, not
residential/consumer products. Second, AHAM added that in EPCA, fans
and blowers are not included in Part A, which is for Consumer Products
other than Automobiles. Third, AHAM stated that fans and blowers by
definition are industrial equipment, which EPCA defines as equipment
that ``to any significant extent, is distributed in commerce for
industrial or commercial use, without regard to whether such article is
in fact distributed in commerce for industrial or commercial use.'' (42
U.S.C. 6311(2)(A)(ii)) In particular, AHAM commented that residential
air circulating fans by definition are clearly consumer products--they
are not, ``to any significant extent'' distributed in commerce for
industrial or commercial use and are distributed for use in homes. AHAM
commented that fans such as desk fans, box fans, and pedestal fans that
are used in homes are regularly distributed in commerce for personal
use or consumption by individuals. AHAM commented that if particular
SKUs are labeled as consumer fans and, in fact, are primarily marketed
and distributed into the very different commercial/industrial sectors,
then they can be dealt with through compliance and enforcement efforts
rather than by over-incorporation of all consumer fans into test
procedures and standards. AHAM noted that commercial clothes washers
also appear in the same list of ``covered equipment.'' (42 U.S.C.
6311(1)(H)) AHAM commented that despite the fact that commercial and
residential clothes washers share similar construction and are often
both used by individual consumers, EPCA differentiates them. Thus, AHAM
stated it was evident that Congress intended to include only truly
commercial/industrial fans and blowers in the scope of industrial
equipment. AHAM added that DOE's proposal to include embedded fans used
in consumer products and residential/consumer air circulating fans in
the scope of the commercial and industrial fans and blowers rulemaking
is inconsistent with its previous decision for these products. AHAM
commented that DOE's final determination of coverage stated that ``[t]o
qualify as `industrial equipment,' fans and blowers must be, to a
significant extent, distributed in commerce for industrial and
commercial use.'' (42 U.S.C. 6311(2)(A)(ii)) AHAM noted that in
footnote 26 of the final coverage determination, DOE notes that
distribution for residential use does not preclude coverage as covered
equipment so long as to a significant extent the equipment is of a type
that is also distributed in commerce for industrial and commercial use.
However, AHAM commented that is not the case with fans embedded in
consumer products (whether they are DOE covered products or not) or
fans used in homes to circulate air. Thus, AHAM commented that DOE
should not be including either type of fan under the scope of the
commercial and industrial fans and blowers test procedure or energy
conservation standards. AHAM commented that DOE's proposal is not
consistent with its own guidance on the consumer/commercial distinction
in EPCA.\47\ Specifically, AHAM noted that residential/consumer fans
are typically smaller than commercial and industrial fans because they
are meant to circulate air in smaller spaces and have lower wattage,
have different durability requirements, and have different safety
requirements. AHAM commented that UL 507: Standard for Electric Fans
applies to consumer fans and some commercial fans, but that there are
also additional safety requirements for commercial fans (e.g., OSHA
requirements) and UL 507 specifically excludes certain fans. AHAM
further noted that there are industrial technical guidance requirements
such as ISO13348 (``Industrial fans--Tolerances, methods of conversion
and technical data presentation'') \48\ that distinguish household and
industrial fans. Finally, AHAM noted that residential fans as a product
type are primarily used in residential applications. AHAM commented
that the same was true for fans embedded in consumer products. (AHAM,
No. 35 at pp. 1-4)
---------------------------------------------------------------------------
\47\ AHAM referenced the following: www1.eere.energy.gov/buildings/appliance_standards/pdfs/cce_faq.pdf.
\48\ See www.iso.org/standard/45118.html.
---------------------------------------------------------------------------
AMCA commented in support of AHAM's comment regarding the scope of
the [air] circulating fan coverage extending below 125 W. (AMCA, No. 41
at p. 4)
DOE notes that air circulating fans are tested in a configuration
that measures electrical input power to the fan, inclusive of the
motor, and that the existing test procedures (i.e., AMCA 230-23 or IEC
60879:2019) do not allow measuring the mechanical shaft power to the
fan, exclusive of the motor. Therefore, DOE has determined that a limit
in terms of electrical input power (applicable to the fan and motor) is
more appropriate. Regarding DOE's authority to regulate fans and
blowers that are distributed in commerce for residential use, as noted
previously (See section III.B of this document), DOE has determined
that distribution for residential use does not preclude coverage as
covered equipment so long as to a significant extent the equipment is
of a type that is also distributed in commerce for industrial and
commercial use. EPCA defines ``industrial equipment'' as any article of
equipment \49\ ``of a type'' that ``to any
[[Page 27333]]
significant extent, is distributed in commerce for industrial or
commercial use'' and ``is not a covered [consumer] product [ ] without
regard to whether such article is in fact distributed in commerce for
industrial or commercial use.'' 42 U.S.C. 6311(2)(A). Accordingly, any
equipment that meets the definition of air circulating fan, has an
input power greater than or equal to 125 W, as measured by the test
procedure at high speed, and is of a type that, to any significant
extent, is distributed in commerce for industrial or commercial use is
included in the scope of the test procedure, regardless of whether it
is sold for use in commercial, industrial, or residential settings. In
addition, as previously stated, DOE is not setting test procedures for
air circulating fans with input power less than 125 W and DOE believes
this would exclude most fans used in residential applications.
---------------------------------------------------------------------------
\49\ The types of equipment are ``(in addition to electric
motors and pumps, commercial package air conditioning and heating
equipment, commercial refrigerators, freezers, and
refrigerator[hyphen]freezers, automatic commercial ice makers,
commercial clothes washers, packaged terminal
air[hyphen]conditioners, packaged terminal heat pumps, warm air
furnaces, packaged boilers, storage water heaters, instantaneous
water heaters, and unfired hot water storage tanks) as follows: (i)
compressors; (ii) fans; (iii) blowers; (iv) refrigeration equipment;
(v) electric lights and lighting power supply circuits; (vi)
electrolytic equipment; (vii) electric arc equipment; (viii) steam
boilers; (ix) ovens; (x) kilns; (xi) evaporators; (xii) dryers; and
(xiii) other motors.'' 42 U.S.C. 6311(2)(B).
---------------------------------------------------------------------------
Morrison commented that air circulating fans should be covered in a
separate rulemaking as their utility, function, and testing process are
different from other fans and blowers. Morrison added that this should
be done so the appropriate fan manufacturers are engaged in this
process to reduce adding burden and complexity to this rulemaking.
(Morrison, No. 42 at p. 1)
AMCA recommended that air circulating fans that are not ceiling
fans be handled with a separate rulemaking. AMCA commented that this
would provide stakeholders of covered fans less than 125 W an
opportunity to participate and provide separation between residential
and commercial/industrial products. (AMCA, No. 41 at p. 17) In
addition, AMCA commented that such request seemed practical and fair
seem practical and fair, especially for the circulating fan
stakeholders that were not in the scope of the ASRAC process, and which
are in the final stages of revising the AMCA 230 test standard for
circulating fans. AMCA requested DOE to allow that standard committee
to complete its work before issuing the final rule on this test
procedure. Already, with the final rule for the ceiling fan test
procedure causing problems for the AMCA 230 revision, AMCA commented
that it would really hurt the standard to have it out of synch with the
fans and blowers test procedure sections that cover circulating fans.
(AMCA, No. 41 at pp. 3-4
Greenheck commented that the inclusion of air circulating fans in
the fans and blowers test procedure is problematic as they are a
completely different type of equipment and utilize different industry
test standards, procedures, and metrics as defined in AMCA 230-15.
Greenheck commented that the inclusion of air circulating fans makes
the test procedure rulemaking confusing and contradictory. (Greenheck,
No. 39 at p. 8)
DOE notes that although the test procedures for fans and blowers
other than air circulating fans, and air circulating fans are combined
in a single notice, DOE is adopting separate test procedures for each
category of equipment and explicitly indicates the scope of application
of each test procedure. In addition, as noted previously, DOE is not
setting test procedures for air circulating fans with input power less
than 125 W. Therefore, DOE is continuing to include air circulating
fans in the same rulemaking docket as fan and blowers. Although DOE is
including air circulating fans in the same rulemaking as fans and
blowers other than air circulating fans, DOE notes that this final rule
establishes the test procedures for fans and blowers other than air
circulating fans and the test procedures for air circulating fans as
separate appendices. In addition, as previously stated, DOE is not
setting test procedures for air circulating fans with input power less
than 125 W. In addition, as discussed in section III.D of this
document, DOE is incorporating by reference the latest version of AMCA
230-23, which addresses AMCA's concerns about this rulemaking being
completed before AMCA 230-23 published.
AHRI commented that DOE expanded the scope of the NOPR to include
fans that were not discussed in the 2015 ASRAC negotiations. In
addition, AHRI commented that the October 2021 RFI was narrowly limited
to one classification of fans, the air circulating fan heads
(``ACFH''). (AHRI, No. 40 at pp. 4-5)
DOE notes that neither the term sheet nor the scope of the RFI
limits DOE's authority to initiate a rulemaking on additional
categories of fans and blowers. DOE proposed a test procedure for air
circulating fans in the July 2022 NOPR and considered comments received
in response to the NOPR in determining the test procedure established
in this final rule.
5. Non-Electric Drivers
Some fans operate with non-electric drivers, such as engines or
generators, and such fans may be used in non-stationary applications or
stationary applications. The Working Group recommended that DOE exclude
fans that are exclusively powered by internal combustion engines from
the test procedure and related energy conservation standards. (Docket
No. EERE-2013-BT-STD-0006, No. 179, Recommendation #2 at p. 2)
AMCA 214-21 does not provide for the testing of fans and blowers
powered by internal combustion engines. In order to measure the energy
efficiency or energy use of non-electric drivers during a
representative average use cycle, separate test methods would be
necessary for each type of driver (e.g., engine, generators). DOE is
not currently aware of a relevant industry test procedure and does not
have information regarding the test set-up required to test fans
powered by internal combustion engines. As such, in the July 2022 NOPR,
DOE did not propose test procedures for fans and blowers powered
exclusively by an internal combustion engine,\50\ regardless of whether
such fan or blower is used in a stationary or non-stationary
application. 87 FR 44194, 44210.
---------------------------------------------------------------------------
\50\ DOE notes that the July 2022 NOPR included a typographical
error in Table III-8 of the NOPR, stating ``fans exclusively powered
by fan combustion engines'' instead of ``fans exclusively powered by
an internal combustion engine.''
---------------------------------------------------------------------------
Certain bare shaft fans can be powered by either electric drivers
(i.e., motors) or non-electric drivers. In the July 2022 NOPR, DOE
tentatively determined that to the extent such a fan can be powered by
an electric driver, the proposed test procedure would provide for
measurement of the energy efficiency or energy use during a
representative average use cycle when powered by an electric driver. As
such, DOE proposed that such a fan would be subject to the test
procedure. 87 FR 44194, 44210-44211.
The CEC commented in support of the exclusion of fans that are
operated by an internal combustion engine that is used for personal
(consumer), commercial, or industrial transportation only. The CEC
recommended defining the term ``fan combustion engines,'' since it is
unclear if the term ``fan combustion engine'' is meant to be that of a
turbo fan engine, a fan driven by an internal combustion engine in any
context, or the fans driven by an internal combustion engine used for
the purpose of personal (consumer), commercial, or industrial
transportation. (CEC, No. 30 at p. 3)
[[Page 27334]]
AMCA stated its support for the exclusion of fans and blowers that
are exclusively powered by internal combustion engines from the scope
of this test procedure because such fans include Positive Pressure
Ventilators (``PPV''), which are portable fans for fire-rescue
operations and excluded from having FEI ratings calculated using AMCA
214-21. (AMCA, No. 41 at p. 8)
AMCA noted that to help distinguish fans powered by combustion
engines, PPVs are portable tube-axial fans and can be powered by
batteries, combustion engines, and hydraulics while having no
provisions for duct installations. AMCA added that PPVs sometimes are
confused with floor-drying fans, which are housed centrifugal fans,
whereas PPVs are not supplied in bare shaft configuration. (AMCA, No.
41 at p. 8)
New York Blower commented that fans with internal combustion
engines are extremely rare and not likely to increase due to regulation
and that exclusion of these fans seems appropriate. New York Blowers
stated that it is possible at lower power ranges that there might be a
significant quantity of products and consequently, units driven by
internal combustion applications that they are not aware of. Aside from
a clutch mechanism to keep the fan disengaged from the motor when
idling, New York Blower commented that it does not know of any
distinguishing feature of the fan that would indicate the fan would be
driven by an internal combustion engine. (New York Blower, No. 33 at p.
9)
Robinson stated a lack of awareness of any physical features of a
fan design that would distinguish those as exclusively powered by
internal combustion engines other than the presence of an internal
combustion engine or potentially a fluid clutch. (Robinson, No. 43 at
p. 6)
Morrison commented that many fans for internal combustion engines
are specific designs intended for direct attachment to the engine and
others have low voltage motors consistent with vehicle electrical
systems. Morrison commented that such fans should be part of the
equipment regulation (autos, buses, trucks, generators, and heavy
equipment) as opposed to being included in this effort as detailed in
the ASRAC term sheet. In addition, Morrison noted that these fans have
low-voltage motors and heavy construction features. (Morrison, No. 42
at p. 4)
DOE notes that the July 2022 NOPR included a typographical error in
Table III-8 of the NOPR, stating ``fans exclusively powered by fan
combustion engines'' instead of ``fans exclusively powered by an
internal combustion engine.'' In this final rule, consistent with the
July 2022 NOPR, and as recommended by stakeholders, DOE excludes fans
and blowers powered exclusively by an internal combustion engine,
regardless of whether such fan or blower is used in a stationary or
non-stationary application from the scope of the test procedure. DOE is
not adopting additional definitions as the reference to internal
combustion engines clearly specifies the fans excluded from the scope
of the test procedure. As noted by stakeholders such fans can be
distinguished based on the presence of a clutch mechanism or designs
intended for direct attachment to the engine.
6. Replacement Fans and Blowers
The Working Group did not address the issue of replacement parts in
the term sheet. (Docket EERE-2013-BT-TP-0055, No. 179, Appendix F at p.
19). In the July 2022 NOPR, DOE proposed to include all fans and
blowers that: (1) meet the criteria for scope of inclusion as described
in section III.A.1 of that document, and (2) are not proposed for
exclusion as listed in section III.A.2 of that document or Table III-8
of the July 2022 NOPR, regardless of whether that fan is a replacement
fan. 87 FR 44194, 44211.
Morrison commented that replacement blowers for HVAC appliances
need to be fully excluded for safety reasons as appliance limit
controls may cause malfunction that could result in loss of life and/or
property. (Morrison, No. 42 at p. 2)
AHAM commented that replacement fans, as well as those that are not
considered covered products, should be excluded from the scope of the
test procedure and applicable standards. (AHAM, No. 35 at p. 5)
AHRI commented that any potential regulation should consider the
impact on replacement fans and added that the consequences of a
replacement fan made non-compliant because of these new regulations
could be catastrophic. AHRI commented that in many cases, such as
supply-air fans with air flow through gas fired heat exchangers, hot-
water, coils or electric resistance units, a variety of safety
standards in addition to performance standards are affected. AHRI
commented that the testing of all legacy equipment because of a fan
change will be cost- and resource-prohibitive, and that if a
replacement fan is not compliant, in most cases, an unsafe, engineered-
to-fit substitution would be required. AHRI asserted that the costs,
risks, and time required to retest the HVACR and water-heating
equipment would all be prohibitive and that testing would also be
impractical if the HVACR and water heating equipment is out of
production. AHRI added that manufacturers would be forced to rebuild an
out-of-production unit solely for the purpose of testing a new fan.
AHRI concluded by stating that there may be instances in which such
part substitution makes sense, but that is not a reasonable basis for a
broad, minimum standard. (AHRI, No. 40 at p. 13)
Trane commented that replacement fans should be exempt if embedded
fans fall under regulation. Trane encouraged DOE to align with the CEC
regulation that provides an exemption for ``embedded fans as defined in
ANSI/AMCA 214-21, including embedded fans sold exclusively for
replacement of another embedded fan.'' Trane commented that fans
embedded in equipment such as residential or commercial HVAC have
downstream or upstream impacts on airflow distribution. Trane commented
that many applications of this equipment have heating coils and/or
natural gas heat exchangers that are developed, tested and certified
for safety. Trane stated that when a fan is changed in the field at the
application point, an exact model should be used for replacement to
comply with safety requirements to ensure that no equipment failure
results that may compromise the safety of the building occupants. Trane
commented that, additionally, fan efficiency challenges the ability to
replace ``like for like'' fans. Trane commented that more-efficient
fans are often larger than less efficient ones and as such, this may
increase associated product size. Trane noted that while a similar
impeller-diameter fan may be available at a higher efficiency, it is
imperative to consider that differing fan types have different non-
impeller fan geometries and constraints, such that the overall fan
footprint increases dramatically. Trane commented that with space
constraints being a constant pressure, new products may be too large to
replace smaller existing ones without significant design changes and
associated costs that would serve to dissuade building owners from
purchasing the more efficient fans contained in new products and
instead repair existing, less efficient products. Trane commented that
retrofit curbs can be used, but they generally come with associated
pressure drop, which negates any efficiency improvement associated with
the more efficient fan. (Trane, No. 38 at p. 3)
DOE includes all fans and blowers that meet the criteria for scope
inclusion
[[Page 27335]]
as described in section III.B.1 of this document and are not listed for
exclusion in section III.B.2 of this document or Table III-7 of this
document, regardless of whether that fan is a replacement fan. At this
time, DOE is not adopting energy conservation standards for fans and
blowers, and the test procedure would not impact the availability of
current models. The test procedure does not set any energy conservation
standards and does not result in any non-compliant fans. DOE will
consider the impacts from setting potential energy conservation
standards on replacement fans (e.g., costs, design, safety, and
availability) as part of any potential energy conservation standards
rulemaking.
7. Material Handling and Heavy Industrial Processing Fans and Blowers
In response to the July 2022 NOPR, Robinson commented that fans
that provide mass transfer or are subjected to significant wear will
not benefit from a switch to highly efficient aerodynamic designs. In
fact, stated Robinson, shorter equipment life was highly likely and end
use customers would bear the additional cost of replacement. For this
reason, Robinson stated it does not support the inclusion of fans that
provide mass transfer or are subjected to wear (whether abrasion or
corrosion). (Robinson, No. 43 at p. 5)
At this time, DOE is not adopting energy conservation standards for
fans and blowers, and the test procedure would not impact the
availability of current models. The test procedure does not set any
energy conservation standards and does not result in any non-compliant
fans. In addition, as noted in the July 2022 NOPR, based on input from
AMCA during the ASRAC negotiations, DOE has determined that radial
housed unshrouded fans with a diameter less than 30 inches or a blade
width of less than 3 inches are designed for materials-handling
applications. These fans have specific design features (e.g., built to
resist the impact and erosive wear from large quantities of various
materials passing through the fan housing) that generally limit the
opportunity for improved efficiency. (Docket No. EERE-2013-BT-STD-0006,
Public Meeting Transcript, No. 85 at p. 60). 87 FR 44194, 44202-44203.
Furthermore, testing these fans based on the test method for clean air
fans would not provide a measurement of energy use or energy efficiency
that is representative of an average use cycle. For these reasons, as
discussed in section III.B.2 of this document, DOE is excluding radial
housed unshrouded fans with a diameter less than 30 inches or a blade
width of less than 3 inches at this time.
Robinson further commented that the proposed rule would create an
extreme challenge for the heavy industrial processing industry (e.g.,
mining, refining, metal making, rock product processing, food
production, chemical processing, and much more) in the United States.
Robinson commented that specialty heavy industrial process fans are
significantly different from fans used in commercial or light
industrial applications as they operate in heavy industrial process
facilities that are constrained by significant regulations as well as
engineering requirements. Robinson stated that this means that the
design of the whole process, which requires each part to play a
specific application, is quite complicated and under multiple reviews.
Robinson commented that the fans, as part of the process, are often
designed to perform at several load points, as the design and then the
actual operation of the plant may experience variability. Robinson also
noted that the fans are placed throughout the heavy industrial process
and, depending upon the role of each specific fan, will be forced to
handle particulate, extreme temperatures, dramatic temperature changes,
moisture, corrosive matter, and other items in the air stream. Robinson
noted that the most efficient fan designs are only able to operate in
clean air applications (i.e., where they draw in outside air and blow
it into a part of the heavy industrial process) and that the number of
clean air fans in any heavy industrial process and the amount of energy
they consume, relative to the rest of the process, is small. Instead,
Robinson commented that fans handling air movement through the more
challenging parts of the process are much more likely to consume more
energy, but also deal with variables that limit the efficiency
improvement of that fan. Robinson added that these fans are connected
to the larger whole of the heavy industrial process in which they
operate and are subject to the conditions as they change through the
entire system. Further, if the end goal is to require fans to all
comply with minimum levels of efficiency, Robinson commented that
entire industrial processes will need to be retrofitted to allow all of
the fans within the process to be clean air handling fans. Robinson
commented that not only would this require the reconstruction of entire
heavy industrial processing facilities, but also require that each fan
be bigger or that there be more fans, which would draw greater energy
and therefore be less efficient. Robinson added that it is necessary
for many heavy industrial plant precipitators and baghouses (Air
Pollution Control--APC devices) to operate in a positive pressure
environment to prevent combustion of pollutants captured and collected
in the cleaning device hoppers. In these applications, stated Robinson,
it is necessary for the fans to be located upstream (or in the dirty
air) of the APC device to minimize the risk of fires that would
significantly damage the internals of the APC device. Robinson
commented that the repair/replacement cost of these devices alone, if
damaged by fire, is in the $5 to $10 million range for each, not
including the plant lost production time. Robinson commented that the
cost of adding additional particulate collection equipment upstream of
the existing heavy industrial process fans and APC devices coupled with
the added pressure drop of this equipment will offset any efficiency
benefits since the existing fans will need to be replaced with larger
horsepower fans. In short, Robinson summarized, it would not be
surprising if this forced all heavy industrial processing out of the
United States. (Robinson, No. 43 at pp. 2-3)
At this time, DOE is not adopting energy conservation standards for
fans and blowers, and the test procedure would not impact the
availability of current models. The test procedure does not set any
energy conservation standards and does not result in any non-compliant
fans or necessary redesigns. Any future energy conservation standard
rulemaking would, as part of the analyses conducted to support the
rulemaking, analyze the markets in which fans and blowers are used,
conduct a technology assessment, and evaluate any potential impacts on
technological feasibility, practicability to manufacture, install or
service, equipment utility or equipment availability, health, and
safety as a result of potential standards. In addition, although DOE is
not specifically excluding material handling fans and heavy industrial
processing fans, DOE notes that the test procedure is limited to fan
design points with air power less than 150 hp. In addition, radial
housed unshrouded fan with diameter less than 30 inches or a blade
width of less than 3 inches, safety fans and fans that designed and
marketed to operate at or above 482 degrees Fahrenheit (250 degrees
Celsius) are excluded from the scope of the test procedure. As such,
DOE notes that any fan that meets the scope criteria
[[Page 27336]]
described in section III.B.1 of this document, and is not listed for
exemption as discussed in section III.B.2 and III.B.3 of this document
would be in the scope of the test procedure.
C. Definitions
This section discusses DOE's adopted definitions for specific terms
used in the test procedure for fans and blowers.
1. Fan and Blower Categories
The classification of fans and blowers recommended by the Working
Group for coverage under a test procedure and the corresponding terms
and definitions in AMCA 214-21 and the proposed CEC regulations \51\
are presented in Table III-8 of this document.
---------------------------------------------------------------------------
\51\ See Proposed regulatory language for Commercial and
Industrial Fans and Blowers available in the following Docket: 22-
AAER-01 at: efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
Table III-8--Scope Recommended by the Working Group, Corresponding Terms and Definitions
----------------------------------------------------------------------------------------------------------------
Corresponding term and definition
Working group scope recommendations in AMCA 214-21 Corresponding CEC definitions
----------------------------------------------------------------------------------------------------------------
Axial cylindrical housed fan.......... ``Axial inline fan'' means a fan ``Axial-inline fan'' means a fan
with an axial impeller and a with an axial impeller and a
cylindrical housing with or cylindrical housing with or
without turning vanes. without turning vanes. Inlets and
outlets can optionally be ducted.
Panel fan............................. ``Axial panel fan'' means an axial ``Axial-panel fan'' means a fan
fan, without cylindrical housing, with an axial impeller mounted in
that is mounted in a panel, an a short housing, non-cylindrical,
orifice plate or ring. that can be a panel, ring, or
orifice plate. The housing is
typically mounted to a wall
separating two spaces, and the
fans are used to increase the
pressure across this wall. Inlets
and outlets are not ducted.
Centrifugal housed fan, excluding ``Centrifugal housed fan'' means a ``Centrifugal housed fan'' means a
inline fan and radial fan. fan with a centrifugal or mixed fan with a centrifugal or mixed
flow impeller in which airflow flow impeller in which airflow
exits into a housing that is exits into a housing that is
generally scroll-shaped to direct generally scroll-shaped to direct
the air through a single fan the air through a single fan
outlet. A centrifugal housed fan outlet. Inlets and outlets can
does not include a radial optionally be ducted. It does not
impeller*. include a radial impeller.
Centrifugal unhoused fan, excluding ``Centrifugal unhoused fan'' means ``Centrifugal unhoused fan'' means
radial fan. a fan with a centrifugal or mixed a fan with a centrifugal or mix-
flow impeller in which airflow flow impeller in which airflow
enters through a panel and enters through a panel and
discharges into free space. Inlets discharges into free space. Inlets
and outlets are not ducted. This and outlets are not ducted. This
fan type also includes fans fan type also includes fans
designed for use in fan arrays designed for use in fan arrays
that have partition walls that have partition walls
separating the fan from other fans separating the fan from other fans
in the array**. in the array.
Inline and mixed-flow fan............. ``Centrifugal inline fan'' means a ``Centrifugal inline fan'' means a
fan with a centrifugal or mixed fan with a centrifugal or mixed-
flow impeller in which airflow flow impeller in which airflow
enters axially at the fan inlet enters axially at the fan inlet
and the housing redirects radial and the housing redirects radial
airflow from the impeller to exit airflow from the impeller to exit
the fan in an axial direction. the fan in an axial direction.
Inlets and outlets can optionally
be ducted.
Radial housed fan..................... ``Radial-housed fan'' means a fan ``Radial-housed fan'' means a fan
with a radial impeller in which with a radial impeller in which
airflow exits into a housing that airflow exits into a housing that
is generally scroll-shaped to is generally scroll-shaped to
direct the air through a single direct the air through a single
fan outlet. Inlets and outlets can fan outlet. Inlets and outlets can
optionally be ducted. optionally be ducted.
Power roof ventilator................. ``Power roof/wall ventilator ``Power roof ventilator (PRV)'' or
(PRV)'' means a fan with an ``power wall ventilator (PWV)''
internal driver and a housing to means a fan with an internal
prevent precipitation from driver and a housing to prevent
entering the building. It has a precipitation from entering the
base designed to fit over a roof building. It has a base designed
or wall opening, usually by means to fit over a roof or wall
of a roof curb. opening, usually by means of a
roof curb.
----------------------------------------------------------------------------------------------------------------
* The inclusion of ``scroll-shaped'' in this definition excludes inline fans.
** Radial fans are housed and therefore not included in this definition.
In the July 2022 NOPR, DOE proposed to utilize the terminology and
definitions specified in AMCA 214-21 to define the categories of fans
and blowers proposed in the scope of applicability of the test
procedure and tested using AMCA 210-16 as follows: (1) axial inline
fan; (2) centrifugal housed fan; (3) centrifugal unhoused fan; (4)
centrifugal inline fan; (5) radial-housed fan; and (6) PRVs. DOE
proposed to modify the definition of ``axial panel fan'' as provided in
AMCA 214-21 to distinguish these fans from air circulating axial panel
fans, as follows: an axial panel fan is an axial fan, without
cylindrical housing, that includes a panel, orifice plate, or ring with
brackets for mounting through a wall, ceiling, or other structure that
separates the fan's inlet from its outlet. 87 FR 44194, 44211-44212.
In the July 2022 NOPR, DOE noted that the CEC definitions are
similar to the AMCA 214-21 definitions. DOE noted that the inclusion of
additional language in the CEC definitions to indicate a fan's intended
application or whether a fan's inlet or outlet is (optionally, as
relevant) ducted was informative, but did not further distinguish the
terms. In addition, for axial panel fans, DOE noted that the CEC
definitions specified that the housing is typically mounted to a wall
separating two spaces, and the fans are used to increase the pressure
across this wall. DOE stated that the CEC description distinguishes
axial panel fans from axial air circulating panel fans, which do not
have provisions for connection to ducting or separation of the fan
inlet from its outlet. However, DOE noted that the CEC distinction was
based on how the fan was installed and not on a physical design feature
of the fan. Therefore, DOE proposed to rely on physical features and to
define axial panel fans instead. 87 FR 44194, 44211-44212.
[[Page 27337]]
In addition, to support the exclusions proposed in the July 2022
NOPR and clarify which fans would fall under the proposed exclusions,
DOE proposed to adopt definitions of the terms ``induced flow fan'' and
``jet fan'' as established in AMCA 214-21 and ``cross-flow fan'' as
defined in AMCA 208-18. Id. at 87 FR 44212.
In response to the July 2022 NOPR, New York Blower commented that
the definitions in AMCA 214-21 are adequate. (New York Blower, No. 33
at p. 10) AMCA commented in support of the DOE-proposed definitions of
axial inline fan, centrifugal housed fan, centrifugal unhoused fan,
centrifugal inline fan, radial-housed fan, and power roof ventilator,
which are consistent with definitions found in AMCA 214-21. However,
AMCA noted that there would be additional alignment with the CEC's
resultant definitions for the Title 20 fan regulation if DOE were to
add, ``inlets and outlets can optionally be ducted'' to the definitions
of axial inline fan, centrifugal housed fan, and centrifugal inline
fan. In addition, AMCA commented in support of the DOE-proposed
definitions of induced flow fan, jet fan, and cross-flow fan, as they
are consistent with definitions found in AMCA 214-21 and AMCA 208-18.
(AMCA, No. 41 at p.9)
As noted previously, DOE did not include the additional language
for the CEC definitions as DOE notes that although it provides
additional description of optional features of the equipment, or of the
equipment installation configuration, the additional language does not
describe the equipment's unique physical characteristics and therefore
does not further distinguish the definitions. Therefore, DOE adopts the
definitions of (1) axial inline fan; (2) centrifugal housed fan; (3)
centrifugal unhoused fan; (4) centrifugal inline fan; (5) radial-housed
fan; (6) PRVs; (7) induced flow fan; (7) jet fan; and (8) cross-flow
fan as proposed.
AMCA noted that DOE may want to consider revising the definition of
axial panel fan to state, ``without cylindrical or box housing,'' as in
the definition of air circulating axial panel fan. (AMCA, No. 41 at p.
9)
DOE agrees with AMCA that adding ``or box housing'' would align the
definitions of axial panel fan and air circulating axial panel fan.
However, DOE notes that this is not specified in the AMCA 214-21
definitions and unlike for air circulating fans heads where AMCA 230-23
includes a separate definition of box fans and distinguishes these fans
from air circulating axial panel fan, AMCA 214-21 does not distinguish
box fans using a separate definition. DOE retains the proposed
definition to continue to align with AMCA 214-21.
2. Safety Fans
In the July 2022 NOPR, DOE proposed a definition of safety fan to
support the exclusion of safety fans from the scope of the test
procedure, as discussed in section III.B.2 of this document. 87 FR
44194, 44213.
In the July 2022 NOPR, DOE reviewed the following definition of
safety fan as proposed by the CEC: (1) a fan that is designed and
marketed to operate only at or above 482 degrees Fahrenheit (250
degrees Celsius); (2) a reversible axial fan in cylindrical housing
that is designed and marketed for use in ducted tunnel ventilation that
will reverse operations under emergency ventilation conditions; (3) a
fan bearing an Underwriter Laboratories (UL) or Electric Testing
Laboratories listing for ``Power Ventilators for Smoke Control
Systems''; (4) an open discharge exhaust fan with integral discharge
nozzles which develop or maintain a minimum discharge velocity of 3,000
feet per minute (``fpm''); (5) a fan constructed in accordance with
AMCA type A or B spark resistant construction as defined in ANSI/AMCA
Standard 99-16 Standards Handbook; (6) a fan designed and marketed for
use in explosive atmospheres and tested and marked according to EN
13463-1:2001 Non-electrical Equipment for Potentially Explosive
Atmospheres; or (7) an electric-motor-driven Positive Pressure
Ventilator as defined in ANSI/AMCA Standard 240-15 Laboratory Methods
of Testing Positive Pressure Ventilators for Aerodynamic Performance
Rating.\52\ In the July 2022 NOPR, based on a review of the existing
industry and regulatory definitions of ``safety fan,'' DOE tentatively
determined that the definition proposed by the CEC (at the time) was
representative of the equipment considered ``safety fans.'' 87 FR
44194, 44214.
---------------------------------------------------------------------------
\52\ See CEC Docket No. 22-AAER-01, TN #241950, Proposed
regulatory language for Commercial and Industrial Fans and Blowers,
at pp. 7-8.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE proposed to adopt a definition in line
with the definition proposed by the CEC with the following edits.
Regarding item (1) of the CEC definition: DOE proposed not to include
the term ``only'' from ``a fan that is designed and marketed to operate
only at or above 482 degrees Fahrenheit (250 degrees Celsius)'' because
DOE tentatively determined that a fan that can operate at or above a
certain temperature can also operate below. Regarding item (4) DOE
tentatively determined that the definition of safety fans is equivalent
to ``laboratory exhaust fans'' as defined in section 3.52 of AMCA 214-
21: fans designed and marketed specifically for exhausting contaminated
air vertically away from a building using a high-velocity discharge.
DOE noted it was considering replacing item (4) with ``laboratory
exhaust fans'' and to define it in accordance with AMCA 214-21. DOE
also reviewed item (6) and noted that the referenced industry standard
is no longer current and has been replaced. In 2008, the International
Electrotechnical Commission System for Certification to Standards
Relating to Equipment for Use in Explosive Atmospheres replaced EN
13463-1 by ISO 80079-36, ``Explosive atmospheres--Part 36: Non-
electrical equipment for explosive atmospheres--Basic method and
requirements.'' \53\ The latest version of ISO 80079-36 is the 2016
edition. Therefore, DOE proposed to reference ISO 80079-36:2016,
instead of EN 13463-1:2001. Id.
---------------------------------------------------------------------------
\53\ See www.intertek.com/blog/2019-03-14-hazloc/.
---------------------------------------------------------------------------
In response to the July 2022 NOPR, the CEC recommended that DOE
incorporate the following definition of safety fan: safety fan means
(1) a reversible axial fan in cylindrical housing that is designed and
marketed for use in ducted tunnel ventilation that will reverse
operations under an emergency ventilation condition; (2) a fan for use
in explosive atmospheres tested and marked according to EN ISO
Standards 80079-36:2016, Explosive atmospheres--Part 36: Non-electrical
equipment for explosive atmospheres--Basic method and requirements; (3)
a Positive Pressure Ventilator; or (4) a fan bearing a listing for
``Power Ventilators for Smoke Control Systems'' in compliance with
ANSI/UL 705 Power Ventilators (dated August 23, 2021). Specifically,
the CEC recommended removing fans that are designed and marketed to
operate only at or above 482 degrees Fahrenheit (250 degrees Celsius)
from the safety fan definition and instead listed together with the
exclusions as proposed in Table III-8 of the July 2022 NOPR. The CEC
commented that fans that are designed and marketed to operate only at
or above 482 degrees Fahrenheit (250 degrees Celsius) can be designed
for uses other than safety and are subject to different performance
requirements, for example fans used for industrial processes that
require operation at higher temperatures. The CEC also
[[Page 27338]]
recommended that laboratory exhaust fans not be included in the
definition for safety fan, nor be included as a separate exclusion from
the proposed scope of applicability of the test procedure. The CEC
noted that although laboratory exhaust fans exhaust possible dangerous
gasses, the fans are used for routine non-emergency lab procedures and
are fully capable of achieving efficient operation without compromising
the purpose for which they are installed. (CEC, No. 30 at pp. 2-3)
In response to the July 2022 NOPR, AMCA provided a comparison of
the CEC safety fan definition as provided in the Title 20 express
terms, noting elements that differed or were consistent with the
proposed safety fan definition. AMCA commented that in Title 20 express
terms,\54\ the CEC removed the high-temperature section from the safety
fan definition and inserted it in the list of fan-type exemptions
instead. AMCA added that the rationale for this is that high-
temperature fans are not always safety-related; they also are specified
for commercial-kitchen exhaust and other demanding applications. (AMCA,
No. 41 at p. 6, 12) AMCA recommended that DOE move item (1) of the DOE
proposed safety fan definition to the list of explicit exemptions.
Regarding item (4) of the DOE proposed definition, AMCA noted that it
submitted comments to the CEC recommending that the CEC should seek to
clean up some of the language because AMCA felt that the 3,000-fpm
criterion could provide a loophole for fans that provide 3,000 fpm but
are not used for safety purposes and was intended to describe a
``laboratory exhaust fan'' without naming it. AMCA commented that the
3,000-fpm discharge velocity with integral discharge nozzles appears to
reference similar verbiage in ANSI/AIHA Z9.5, Laboratory Ventilation,
and recommended exhaust velocities for safely exhausting contaminants
without re-entrainment and added that laboratory exhaust fans would be
considered safety fans regardless of exhaust velocity for the simple
fact they service laboratories requiring numerous safety protocols for
the protection of occupants and the surrounding area. For this reason,
AMCA noted that in its comment to the CEC, AMCA commented that the CEC
proposed regulatory language and supporting information indicated
laboratory exhaust fans should be excluded and proposed using the term
``laboratory exhaust fan.'' AMCA recommended that the CEC add the ANSI/
AMCA Standard 214-21 definition for safety fans: ``Laboratory exhaust
fan means a fan designed and marketed specifically for exhausting
contaminated air vertically away from a building using a high-velocity
discharge.'' AMCA commented that rather than agree to AMCA's attempt to
remove perceived loopholes from the proposed exemption, CEC removed the
exemption altogether. AMCA commented that it would prefer to have this
exemption remain in the DOE test procedure. In addition, AMCA
recommended the removal of item (5) of the DOE proposed definition of
safety fan. As AMCA commented to CEC, while AMCA recognizes the spark-
resistant-construction types defined in ANSI/AMCA Standard 99-16,
Standards Handbook, the definitions are not consistent with industry
standards, and exempting spark resistant fans also is somewhat of a
loophole in that a fan should be able to be designed to different types
of spark-resistant construction with no impact on performance. For
these reasons, AMCA recommended striking this item, and, if there were
no other uses of AMCA 99, striking the citation of ANSI/AMCA Standard
99-16 in the referenced-documents portion of this NOPR. (AMCA, No. 41
at p. 12)
---------------------------------------------------------------------------
\54\ DOE notes that this refers to the CEC Express Terms for
Commercial and Industrial Fans and Blowers document available at:
efiling.energy.ca.gov/GetDocument.aspx?tn=245898&DocumentContentId=80074.
---------------------------------------------------------------------------
New York Blower stated support for the safety fan definition
proposed by AMCA. (New York Blower, No. 33 at p. 10)
Robinson requested clarification regarding why AMCA Class C spark
resistant construction was not included. (Robinson, No. 43 at p. 6)
Regarding fans designed and marketed to operate only at or above
482 degrees Fahrenheit (250 degrees Celsius), DOE's research confirms
CEC's comment that some fans designed and marketed to operate only at
or above 482 degrees Fahrenheit (250 degrees Celsius) can be designed
for uses other than safety (e.g., manufacturing). Therefore, in this
final rule, DOE is removing this category from the definition of safety
fans and listing these fans as a separate exclusion instead. In
addition, DOE is adopting its proposal to remove the term ``only'' from
``a fan that is designed and marketed to operate only at or above 482
degrees Fahrenheit (250 degrees Celsius)'' because DOE has determined
that a fan that can operate at or above a certain temperature can also
operate below.
As discussed in the July 2022 NOPR, DOE tentatively determined that
``open discharge exhaust fans with integral discharge nozzles which
develop or maintain a minimum discharge velocity of 3,000 FPM'' as
listed in the CEC definition of safety fans are equivalent to
``laboratory exhaust fans'' as defined in section 3.52 of AMCA 214-21:
fans designed and marketed specifically for exhausting contaminated air
vertically away from a building using a high-velocity discharge. 87 FR
44194, 44214. Therefore, DOE is using the term ``laboratory exhaust
fans'' and describes these fans in accordance with the AMCA 214-21
definition. In addition, DOE did not propose to include these fans in
the scope of applicability of the test procedure and at this time. See
87 FR 44194, 44214. DOE is keeping these fans in the definition of
safety fans, such that they are excluded from the scope of
applicability. In addition, as noted in the NOPR, this would align with
the recommended definition of safety fan provided in appendix D of the
term sheet,\55\ which includes fans designed for use in toxic, highly
corrosive, or flammable environments [or in environments] with abrasive
substances. 87 FR 44194, 44213 For these reasons, although DOE notes
that such fans may be used for other in non-emergency situations, DOE
is including laboratory exhaust fans as part of safety fans.
---------------------------------------------------------------------------
\55\ The Working Group stated that the definition recommended in
appendix D may be subject to potential edits necessary to accomplish
the same intent.
---------------------------------------------------------------------------
DOE reviewed the definition recommended by the CEC and notes that
it no longer includes fans constructed in accordance with AMCA type A
or B spark resistant construction as defined in the ANSI/AMCA Standard
99-16 Standards Handbook. In addition, as highlighted by CEC, DOE
understands that such designations are no longer consistent with
industry standards. DOE has determined that spark resistant fans used
in explosive atmospheres are already included under fans tested and
marked according to EN ISO Standards 80079-36:2016, Explosive
atmospheres--Part 36: Non-electrical equipment for explosive
atmospheres--Basic method and requirements. Therefore, DOE is removing
this category from the definition of safety fans and is not
incorporating AMCA 99-16 by reference.
In the July 2022 NOPR, DOE proposed to include fans bearing an
Underwriter Laboratories (UL) or Electric Testing Laboratories listing
for ``Power Ventilators for Smoke Control Systems'' in the definition
of safety fans. 87 FR 44194, 44214. As previously noted, the CEC-
recommended safety fan definition
[[Page 27339]]
further specifies referencing ANSI/UL 705 Power Ventilators (dated
August 23, 2021). DOE has determined that this additional specification
included in the CEC definition is necessary to identify fans included
in this description. In addition, DOE notes that a more recent ANSI-
approved version of ANSI/UL 705 Power Ventilators is available (dated
August 19, 2022) and, therefore, DOE is adding this language into the
safety fan definition and incorporating by reference the latest version
of UL 705 available.
In summary, DOE defines safety fan as: (1) a reversible axial fan
with cylindrical housing that is designed and marketed for use in
ducted tunnel ventilation that will reverse operation under an
emergency ventilation condition; (2) a fan for use in explosive
atmospheres tested and marked according to EN ISO Standards 80079-
36:2016, Explosive atmospheres--Part 36: Non-electrical equipment for
explosive atmospheres--Basic method and requirements; (3) an electric-
motor-driven Positive Pressure Ventilator as defined in ANSI/AMCA
Standard 240-15, Laboratory Methods of Testing Positive Pressure
Ventilators for Aerodynamic Performance Rating; (4) a fan bearing a
listing for ``Power Ventilators for Smoke Control Systems'' in
compliance with ANSI/UL 705 Power Ventilators (dated August 19, 2022);
or (5) a laboratory exhaust fan designed and marketed specifically for
exhausting contaminated air vertically away from a building using a
high-velocity discharge.
3. Definitions Related To Heat Rejection Equipment
As stated in the July 2022 NOPR, DOE proposed to exclude from the
scope of the test procedure fans and blowers embedded in heat rejection
equipment, specifically fans and blowers embedded in packaged
evaporative open circuit cooling towers; evaporative field-erected open
circuit cooling towers; packaged evaporative closed-circuit cooling
towers; evaporative field-erected closed-circuit cooling towers;
packaged evaporative condensers; field-erected evaporative condensers;
packaged air-cooled (dry) coolers; field-erected air-cooled (dry)
coolers; air-cooled steam condensers; and hybrid (water saving)
versions of such listed equipment that contain both evaporative and
air-cooled heat exchange sections. In the July 2022 NOPR, DOE proposed
to define each of these equipment types according to the
recommendations of the Working Group. 87 FR 44194, 44217. DOE did not
receive any comments on these definitions and adopts them as proposed.
4. Air Circulating Fans
In the July 2022 NOPR, DOE proposed definitions for air circulating
fans and related terms using the definition being considered by the
AMCA 230 committee at the time. DOE proposed to define air circulating
fans as ``a fan that has no provision for connection to ducting or
separation of the fan inlet from its outlet using a pressure boundary,
operates against zero external static pressure loss, and is not a jet
fan.'' 87 FR 44194, 44215. Further, DOE proposed to define an unhoused
ACFH as follows: ``An air circulating fan without housing, having an
axial impeller with a ratio of fan-blade span (in inches) to maximum
rate of rotation (in revolutions per minute) less than or equal to
0.06. The impeller may or may not be guarded.'' DOE also proposed to
define a housed ACFH as an air circulating fan with an axial or
centrifugal impeller, and a housing. 87 FR 44194, 44216.
DOE further proposed definitions for the four categories of housed
air circulating fans. DOE proposed to adopt the definitions of air
circulating axial panel pan, box fan, cylindrical air circulating fan,
and housed centrifugal air circulator as considered by the AMCA 230
committee, with the following clarifications: (1) replace ``air
circulating fan'' considered by the AMCA 230 committee by ``housed air
circulating fan head'' to explicitly indicate that each of these fans
are housed ACFHs; (2) replace the term ``circulator'' as used by the
AMCA 230 committee with ``circulating fan'' for consistency in
terminology; and (3) remove the examples of additional terms used
commonly by industry. Id.
In response to the July 2022 NOPR, AMCA commented that it submitted
a comment on July 7, 2022, that included definitions of air circulating
fans and related terms that were approved by the AMCA 230 committee,
and that this submission was not included in the July 2022 NOPR. (AMCA,
No. 41 at pp. 12-13) AMCA further commented that the AMCA 230 committee
supported the proposal to use the categories defined in revisions under
way for the AMCA 230 standard, namely housed ACFH, unhoused ACFH, and
ceiling fans. (AMCA, No. 41 at p. 7)
Although AMCA submitted the comment prior to the publication date
of the July 2022 NOPR, DOE notes that the comments were not received
early enough to be incorporated at the time of drafting and were made
on the pre-publication version of the NOPR, which is intended to
provide stakeholders additional time to review and prepare comments
(see discussion related to this comment in section III.A.).\56\
However, DOE reviewed the definitions included in the additional
comments provided by AMCA (AMCA, No. 13 at pp. 6-9) and these match the
definitions considered by the AMCA 230 committee as discussed in the
July 2022 NOPR. In addition, these definitions align with those
published in AMCA 230-23. DOE therefore concludes that the proposed
definitions align with the latest definitions published in AMCA 230-23
and adopts the definitions of air circulating fans and related terms as
proposed.
---------------------------------------------------------------------------
\56\ The comment was submitted on July 6, 2022. See
www.regulations.gov/comment/EERE-2021-BT-TP-0021-0013 and the
October 2021 RFI comment period ended on November 15, 2022, as
discussed in section I.B of this document.
---------------------------------------------------------------------------
5. Outlet Area
In the July 2022 NOPR, DOE noted that section 5.5.4 of AMCA 230-15
(with errata) defined the discharge area of an air circulating fan as
the area of a circle having a diameter equal to the blade tip diameter.
DOE noted that this definition was only applicable to unhoused ACFHs as
the discharge area of a housed ACFH is determined based on the surface
area at the exit of the housing and is not based on the fan blade tip
diameter. DOE proposed a definition for fan outlet area specific to air
circulating fans as (i.e., ``air circulating fan outlet area''): (1)
for unhoused ACFHs, the area of a circle having a diameter equal to the
blade tip diameter; (2) for housed ACFHs, the inside area perpendicular
to the airstream, measured at the plane of the opening through which
the air exits the fan. In the July 2022 NOPR, DOE further noted that
the AMCA 230 committee is considering revising the definition of
discharge area to include housed ACFHs, and to replace the term
``discharge area'' by ``fan outlet area,'' which is a more commonly
used term. 87 FR 44194, 44217.
Generally, DOE further specified that for all definitions related
to air circulating fans, DOE was aware that the revisions being
considered by the AMCA 230 committee are subject to change and could
further be revised in the next version of AMCA 230. DOE added that
should the revised version of AMCA 230 publish prior to the publication
of any DOE test procedure final rule, DOE intended, after considering
stakeholder feedback received in response to the proposals in the July
2022 NOPR, to revise the definitions in line with the latest AMCA 230
standard, provided the updates in
[[Page 27340]]
this standard are consistent with the definitions DOE proposed in the
July 2022 NOPR or the updates are related to topics that DOE has
discussed and for which DOE has solicited comments in the July 2022
NOPR. Id.
AMCA commented that it agreed with DOE's use of outlet area for air
circulating fans where the outlet area is smaller than the discharge
area, as this solves one potential issue with the discharge-area
definition in AMCA 230-15. However, AMCA stated that DOE's proposed use
of air circulating-fan outlet area creates an issue with historical
test data. AMCA commented that the Bioenvironmental and Structural
System (BESS) Laboratory's historical performance data for air
circulating-panel, box, and tube fans is based on area determined using
impeller diameter (not the cross-sectional outlet area of the housing).
As the BESS Lab data is the largest set of publicly available, third-
party air circulating-fan performance data, it is likely DOE based much
of its analysis on this historical performance data. For all potential
future users of the data, the AMCA 230 technical committee proposes the
following definitions, which will be included in the upcoming edition
of AMCA 230: (1) discharge area: area of a circle having a diameter
equal to the blade tip diameter; and (2) fan outlet area: the gross
inside area measured at the plane of the outlet opening. In addition,
AMCA commented that the revised AMCA 230 would specify that the airflow
rate and efficiency calculations for unhoused air circulating fan heads
must use the discharge area, while airflow rate and efficiency
calculations for housed air circulating fan heads must use the lesser
of the values for fan outlet area and discharge area. (AMCA, No. 41 at
pp. 13-14)
DOE reviewed the definitions of discharge area and fan outlet area
provided by AMCA and concluded that the AMCA definition of discharge
area aligns with the proposed definition of outlet area for unhoused
air circulating fans and that the definition of fan outlet area aligns
with the proposed definition of outlet area for housed air circulating
fans. To align with industry terminology, DOE distinguishes between fan
discharge area and fan outlet area as characterized by AMCA. DOE notes
that the distinction is not based on the presence or absence of
housing, but rather in the physical area considered. In addition, to
further distinguish between housed and unhoused air circulating fans,
DOE is adopting the additional instructions in section 8.4 of AMCA 230-
23 to specify that the airflow rate and efficiency calculations for
unhoused air circulating fan heads must use the discharge area while
airflow rate and efficiency calculations for housed air circulating fan
heads must use the lesser of the values for fan outlet area and
discharge area. DOE has determined that including this distinction as
part of the test instructions, rather than in the definitions ensures
alignment with industry terminology and reflects current testing
practices.
For fans and blowers other than air circulating fans, in the July
2022 NOPR, DOE noted that Annex H of AMCA 210-16 includes requirements
for determining where the fan outlet area is measured for different fan
categories and references AMCA 99-16, which includes further diagrams
to aid in the determination of the outlet area. DOE tentatively
determined that for fans and blowers other than air circulating fans,
the current definition in AMCA 214-21 and the existing requirements in
Annex H of AMCA 210-16 were sufficient to determine the outlet area and
did not propose any edits. 87 FR 44194, 44217.
Robinson commented that the definition of outlet area provided by
AMCA 99-16 is the industry standard and that the only time this is
potentially questioned was when there is more than one outlet plane.
Otherwise, Robinson commented that it did not see an issue with the
definition of fan outlet and fan outlet area. (Robinson, No. 43 at p.
7) In this final rule, DOE makes no changes to how the fan outlet area
is determined for fans and blowers other than air circulating fans,
based on Annex H of AMCA 210-16, which references AMCA 99-16. Robinson
noted a potential improvement of the definition may be needed in the
case when there is more than one outlet plane. However, Robinson did
not provide additional details and at this time, DOE is not changing
how the fan outlet area is determined for fans and blowers other than
air circulating fans.
6. Air Curtains
In the July 2022 NOPR, DOE proposed to exclude fans and blowers
embedded in air curtains and noted that the CEC defined an air curtain
unit as equipment providing a directionally controlled stream of air
moving across the entire height and width of an opening that reduces
the infiltration or transfer of air from one side of the opening to the
other and/or inhibits the passage of insects, dust, or debris. However,
DOE did not propose a definition for this equipment. 87 FR 44194,
44207-44208 at fn. 25.
The CEC recommends defining ``air curtain unit'' as follows: Air
curtain unit means equipment that produces a directionally controlled
stream of air with a minimum width-to-depth aspect ratio of 5:1 and a
discharge that is not intended to be connected to unitary ductwork. The
controlled stream of air is designed to span the height and width of an
opening and reduce the infiltration or transfer of air from one side of
the opening to the other and/or inhibit the passage of insects, dust,
or debris. (CEC, No. 30 at p. 2)
DOE did not propose a definition for air curtain. As noted in the
July 2022 NOPR, air curtains are used in entrances to buildings or
openings between two spaces conditioned at different temperatures. Air
curtains include fans packaged with a motor, filter, outlet section (a
nozzle, discharge grille, etc.), and in some cases a mounting plate,
and/or an electric heater or water heater. 87 FR 44194, 44207. DOE did
not find any ambiguity in identifying this equipment and as such, is
not adopting a definition of air curtain at this time.
7. Basic Model
The basic model concept allows manufacturers to group like models
for the purpose of making representations of energy efficiency and/or
energy use, including for the purpose of demonstrating compliance with
DOE's energy conservation standards to the extent DOE has established
such standards. The concept of basic model may allow manufacturers to
reduce the amount of testing they must do to rate the energy use or
efficiency of their products. DOE's current regulations provide
equipment-specific basic model definitions, which typically state that
models within the same basic model group have ``essentially identical''
energy or water use characteristics; as well as a general definition
that provides (with some exceptions noted in the regulatory text) that
a basic model means ``all units of a given type of product (or class
thereof) manufactured by one manufacturer, having the same primary
energy source, and which have essentially identical electrical,
physical, and functional characteristics that affect energy
consumption, energy efficiency, water consumption, or water
efficiency.'' See for example 10 CFR 430.2; 431.62, 431.152, 431.192,
431.202, 431.222, and 431.292.
In the July 2022 NOPR, DOE proposed a definition of a basic model
specific to fans as follows: ``all units of fans and blowers
manufactured by one manufacturer, having the same primary energy
source, and having essentially identical electrical, physical, and
[[Page 27341]]
functional (e.g., aerodynamic) characteristics that affect energy
consumption. In addition: (1) all variations of blade pitches of an
adjustable-pitch axial fan may be considered a single basic model; and
(2) all variations of impeller widths and impeller diameters of a given
full-width impeller and full-diameter impeller centrifugal fan may be
considered a single basic model.'' DOE further proposed to define
``full-width impeller'' and ``full-diameter impeller'' as ``the maximum
impeller width and the maximum impeller diameter with which a given fan
basic model is distributed in commerce.'' 87 FR 44194, 44213.
In general, Morrison commented that the definition of a basic model
is acceptable but noted the considerable number of basic models--in the
thousands in many categories. (Morrison, No. 42 at p. 4) In general,
AMCA stated acceptance of the definition of a basic model, but noted
there will be a very large number of basic models being registered in
the CCMS. AMCA provided an example of one axial-fan product line, for
which 60 basic models resulted from the variety of blade spans, hub
diameters, blade counts, and blade pitches. (AMCA, No. 41 at pp. 9-10)
NEEA commented that in the definition of a basic model, DOE assumes
that a fan experiences similar impeller trimming to a pump. NEEA
commented that in practice, however, fans are rarely if ever trimmed
from the full-impeller diameter so identifying this feature is not
necessary. NEEA noted that by contrast, features like hub diameter are
specific to fans, but do not exist in pumps and DOE should consider
them in defining a basic model for fans. (NEEA, No. 36 at p. 6)
Fan and blower manufacturers may offer for sale the same bare shaft
fan assembled, packaged, or integrated with different motor,
transmission, and control combinations. Based on DOE's proposed basic
model definition, the same bare shaft fan, sold with different
combinations of motor, transmission, and controls (or as a bare shaft
fan) could be grouped under the same basic model. In addition, fan
manufacturers would be able to elect to group similar individual fan
models within the same basic model under the same ratings to reduce
testing burden, provided that all representations regarding the energy
use of fans within that basic model are identical and based on the most
consumptive unit. See 76 FR 12422, 12428-12429 (March 7, 2011).\57\
Manufacturers would have the option to certify separate ratings for
each combination of bare shaft fan, motor, transmission, and/or control
in order to make separate representations of the performance of each
specific combination. In view of the substantial number of fans that
could be subject to an individual certification requirement for each
basic model, DOE notes that the proposed definition of basic model
would allow variations of blade pitches of an adjustable-pitch axial
fan to be considered a single basic model.
---------------------------------------------------------------------------
\57\ These provisions would allow manufacturers to group
individual models with essentially identical, but not exactly the
same, energy performance characteristics into a basic model to
reduce testing burden. Under DOE's certification requirements, all
the individual models within a basic model identified in a
certification report as being the same basic model must have the
same certified efficiency rating and use the same test data
underlying the certified rating. The March 7, 2011, Final Rule also
established that the efficiency rating of a basic model must be
based on the least efficient or most energy consuming individual
model (i.e., all individual models within a basic model must be at
least as energy efficient as the certified rating). 76 FR 12422,
12428-12429.
---------------------------------------------------------------------------
Additionally, DOE proposed that all variations of a given full-size
impeller width and full-size impeller diameter may be considered to be
part of a single basic model represented by the fan with the full-size
impeller width and full-size diameter. 87 FR 44194, 44213. In the July
2022 NOPR, DOE did not propose to group fans with varying hub diameters
and is not opting to add this in the definition of basic model at this
time and adopts the definition of basic model as proposed in the July
2022 NOPR. See id. Further, DOE notes that in comments submitted to the
CEC docket, several stakeholders \58\ have expressed interest in
grouping fans of variations of the same impeller into the same basic
model and continues to believe that identifying the variations of
impeller in the basic model definition is useful.
---------------------------------------------------------------------------
\58\ AMCA and Joint Advocates (ASAP, NEEA, NRDC, ACEEE, and CA
IOUs), Comments to the CEC Draft Staff Report,
efiling.energy.ca.gov/GetDocument.aspx?tn=224829 (p.9).)).
---------------------------------------------------------------------------
The CA IOUs requested that DOE adjust its definition of ``basic
model'' to refer to the nominal diameter and width of impellers in
place of ``full-width'' and ``full-diameter'' impeller since custom
impellers may be adjusted to be larger or smaller than the nominal
size. The CA IOUs explained that unlike pumps, fabricated fan impellers
have adjustable widths and diameters that can increase or decrease and
manufacturers typically make these adjustments to attain precise
airflow and pressure at synchronous speed of an induction motor. (CA
IOUs, No. 37 at pp. 9-10)
As previously stated, DOE proposed to define ``full-width
impeller'' and ``full-diameter impeller'' as ``the maximum impeller
width and the maximum impeller diameter with which a given fan basic
model is distributed in commerce.'' As such, the impeller would only be
adjusted to a smaller size as the larger size would then meet the
definition of the full-impeller. Therefore, DOE is not adopting the
term ``nominal.''
New York Blower commented that the proposed definition of a basic
model for fans, which distinguishes on the basis of energy consumption,
contributes to the volume of testing required. Specifically, New York
Blower commented that not being able to group a fan series of different
sizes and geometric similarity (i.e., ``fan product line'') results in
at least each size having to be considered a basic model. New York
Blower added that ideally a single size fan or a subset of all the
sizes offered to the market could be used to certify an entire fan
series. New York Blower commented that this would result in a
significant reduction in clerical and administrative activity to report
ratings to the DOE to support offering products in the market. New York
Blower added that such an approach was used in the Californian
Commercial Fans and Blower rulemaking where the ratings of sizes within
a product were distinguished as either a tested model or a calculated
model. (New York Blower, No. 33 at pp. 5, 10)
New York Blower added that recertifying fans annually that are
unlikely to change for years creates an overhead burden to keeping the
product on the market, even if a sparse quantity of units are sold into
the market. Specifically, New York Blower noted that the fan market,
and in particular the industrial fan market, is a build-on-demand
market. While there may be some designs that sell a large quantity of
units, New York Blower commented that it is more likely that many
distinct and different units across the broad spectrum of products and
sizes available will be sold and manufactured to the wide variety of
customer demands. New York Blower stated that placing an administrative
burden and consequent cost on a multitude of products that are rarely
sold but needed, valued, and installed efficiently in systems when they
are required, created no value to the consumer and provided no energy
savings considering the units are infrequently sold. Therefore, New
York Blower commented that it would be administratively expedient to be
able to reference certification of geometrically similar products to a
reference, tested
[[Page 27342]]
fan--similar to the CRP-8 [Certified Rating Program] form and process
incorporated in the AMCA CRP program.\59\ New York Blower added that an
example would be for all sizes of a product line larger than 40 inches
in diameter to reference, and be certified by, the 40-inch test results
without an AEDM or administrative burden. (New York Blower, No. 33 at
p. 10)
---------------------------------------------------------------------------
\59\ DOE notes that this form is available at www.amca.org/assets/crpdocument/CRP_8.pdf.
---------------------------------------------------------------------------
Robinson commented that the definition of basic model needs further
explanation from the perspective of an industrial process custom fan
manufacturer, and that the idea of a basic model makes sense for
manufacturers of a standard product line. Robinson commented that it
manufactures a number of fan designs that are modified to suit the
needs of a customer's specific requirements. In other words, Robinson
stated, a given design could operate anywhere between 1 and 150 hp and
well beyond with varying efficiency (FEI). Robinson commented that the
example provided on page 73 of the NOPR states, ``if a manufacturer
offers the same fan model in the following full-impeller sizes: 60, 70,
80 and 90 inches, each full-impeller size would constitute a separate
basic model. However, a fan with an impeller trimmed to 69 inches could
be grouped with the same 70-inch untrimmed fan.'' Robinson commented
that without an AEDM, this sounded like a custom fan manufacturer would
have to more or less test everything that falls within the limitations
as Robinson does not have catalog equipment. (Robinson, No. 43 at p. 6)
DOE notes that different-size fans would not operate at the same
duty points and do not have essentially identical electrical, physical,
and functional characteristics that affect energy consumption and
energy efficiency. Therefore, an approach as described by New York
Blower, where a manufacturer would only certify a subset of sizes
within a product line, is not feasible. DOE notes that however, a
manufacturer could test a subset of sizes within a product line and
apply the fan laws as allowed in Annex E of AMCA 214-21 in order to
calculate the performance data of all fans in the same product line
without the application of an AEDM, thereby reducing manufacturer
burden. With regard to custom fans for which a single made-to-order fan
is manufactured, general sampling requirements for all covered
equipment at 10 CFR 429.11(b), and Sec. 429.11(b)(2) provides
provisions for sampling when only one unit of a basic model is
produced.\60\ In accordance with these provisions, a single made-to-
order product must be tested to ensure it complies with the standard.
To reduce testing burden, DOE is adopting AEDM provisions that would
allow certification of a made-to-order product in lieu of testing. (See
section III.I of this document.) Certification would be based on the
test results of the one unit, or AEDM ratings for the model. In
addition, DOE notes that this test procedure would not result in any
certification requirements.
---------------------------------------------------------------------------
\60\ Section 429.11(b)(2) specifies that if only one unit of the
basic model is produced, that unit must be tested and the test
results must demonstrate that the basic model performs at or better
than the applicable standard(s). If one or more units of the basic
model are manufactured subsequently, compliance with the default
sampling and representations provisions is required.
---------------------------------------------------------------------------
D. Industry Standards
DOE's established practice is to adopt industry standards as DOE
test procedures, unless such methodology would be unduly burdensome to
conduct or would not produce test results that reflect the energy
efficiency, energy use, water use (as specified in EPCA), or estimated
operating costs of that product during a representative average use
cycle. 10 CFR 431.4; 10 CFR part 430, subpart C, appendix A, section
8(c).
The Working Group recommended that the test procedure for fans and
blowers other than air circulating fans:
(1) For standalone (non-embedded) fans, be based on a physical test
performed in accordance with the latest version of AMCA 210 (i.e.,
available at the time of publication of any test procedure final rule)
\61\ (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #7 at
p. 5);
---------------------------------------------------------------------------
\61\ Currently the latest version of AMCA 210 is AMCA 210-16.
---------------------------------------------------------------------------
(2) Establish methods to determine the ``FEP'' either by: the
direct measurement of the electrical input power to the fan, or by the
measurement of the mechanical input power to the fan (i.e., a fan shaft
power test, which captures the performance of the bare shaft fan) \62\
and by applying default values (i.e., calculation algorithms) to
reflect the additional motor, transmission, or motor controller energy
use (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #9 at
pp. 5-6); and
---------------------------------------------------------------------------
\62\ A bare-shaft fan is a fan without a motor or any other
drive.
---------------------------------------------------------------------------
(3) Allow the use of equations (``fan laws'') to determine the
performance of a bare shaft fan at a non-tested speed, based on the
results of a test conducted at a different speed (Docket No. EERE-2013-
BT-STD-0006, No. 179, Recommendation #17 at p. 10).
The Working Group also recommended specific test set-up and minimal
testable configurations to use for each fan category.\63\ (Docket No.
EERE-2013-BT-STD-0006, No. 179, Recommendation #7 at p. 5)
---------------------------------------------------------------------------
\63\ AMCA 214-21 references AMCA 210-2016 as the physical test
method to use for fans and blowers (except ACFHs). AMCA 210-16
describes four fan test set-ups (or ``installation categories'')
designated by a letter, depending on the ducting at the inlet and
outlet of the fan. ``A'': free inlet, free outlet; ``B'': free
inlet, ducted outlet; ``C'': ducted inlet, free outlet; and ``D'':
ducted inlet, ducted outlet.
---------------------------------------------------------------------------
The Working Group further made recommendations on calculation
algorithms and reference values to use to represent the motor,
transmission, and motor controller energy efficiency when testing a fan
based on a fan shaft power test. (Docket No. EERE-2013-BT-STD-0006, No.
179, Recommendations #10 through #15 at pp. 6-9) Additionally, the
Working Group recommended that embedded fans be tested in a standalone
fan configuration (i.e., outside of the piece of equipment in which
they are embedded). Because some components of embedded fans may not be
removable without causing irreversible damage to the equipment, the
Working Group recommended non-impeller components of the fan that are
geometrically similar to the ones used by the fan as embedded in the
larger piece of equipment be used to complete the fan testable
configuration. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #8 at pp. 5-6) The Working Group also recommended
calculating FEP as the ratio of the electrical input power of a
reference fan (in this case, a fan that is exactly compliant with any
future fan energy conservation standards) to the electrical input power
of the actual fan for which the FEP is calculated, both established at
the same duty point.\64\ In addition, the Working Group recommended
using either static or total pressure \65\ to characterize the duty
point of a fan and to calculate the associated reference FEP, depending
on the fan category and the test set-up used.\66\ (Docket No.
[[Page 27343]]
EERE-2013-BT-STD-0006, No. 179, Recommendations #18 and #19 at pp. 10-
11) Finally, the Working Group recommended equations and default values
to use when calculating the reference FEP of a fan at a given duty
point. (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendations #18
through #21 at pp. 10-12)
---------------------------------------------------------------------------
\64\ A duty point is characterized by a given airflow and
pressure and has a corresponding operating speed.
\65\ Fan total pressure is the air pressure that exists by
virtue of the state of the air and the rate of motion of the air. It
is the sum of velocity pressure and static pressure at a point. If
air is at rest, its total pressure will equal the static pressure.
\66\ Depending on the fan category, the fan performance is
represented using a test set-up with a ducted outlet (i.e., using
total pressure) or a free outlet (i.e., using static pressure) to
reflect typical usage conditions. Fans with ducts attached to the
fan's outlet are typically selected based on their performance at a
given airflow and total pressure, because both the static pressure
and fan velocity pressure are available to overcome system
resistance. However, fans with a free outlet are typically selected
based on their performance at a given airflow and static pressure,
because the velocity pressure cannot be used to overcome system
resistance. The Working Group recommended using total pressure for
some categories of fans (i.e., axial cylindrical housed fans,
centrifugal housed fans, inline and mixed flow fans, and radial
housed fans) and static pressure for others (i.e., panel fans,
centrifugal unhoused fans, and PRVs).
---------------------------------------------------------------------------
Since the publication of the term sheet, AMCA has revised and
developed test standards consistent with the recommendations of the
Working Group:
In September 2016, AMCA published AMCA 210-16, which
updated ANSI/AMCA 210-2007, ``Laboratory Methods of Testing Fans for
Certified Aerodynamic Performance Rating,'' to include a wire-to-air
test method, which captures the performance of any motor, transmission,
or motor controller present in the fan, in addition to the performance
of the bare shaft fan (i.e., a measurement of the FEP in kW), in
addition to the previously existing methods for conducting laboratory
tests to determine fan shaft power in hp, airflow in cubic feet per
minute (``CFM''), pressure in in. wg, and at a given speed of rotation
in ``RPM.''
In April 2017, AMCA published ANSI/AMCA Standard 207-2017,
``Fan System Efficiency and Fan System Input Power.'' This publication
provides calculation algorithms representing the performance of
reference motors, transmissions, and motor controllers. These
calculations can be directly applied to the results of a fan shaft
power test in accordance with AMCA 210-16 to obtain the FEP of a fan at
a given duty point.
In January 2018, AMCA published ``AMCA 208-18.'' This
publication defines FEI as the ratio of the electrical input power of a
reference fan to the electrical input power of the actual fan for which
FEI is calculated, both established at the same duty point. It provides
equations to calculate the FEP of a fan as a function of airflow and
pressure (either static or total depending on the fan category
considered).
Building on these test standards, AMCA developed a new AMCA 214-21
test method, which was approved by ANSI on March 1, 2021. AMCA 214-21
combines provisions of AMCA 210-16, AMCA 207-17, and AMCA 208-18, as
well as portions of AMCA 211-13 (R2018), ``Certified Ratings Program
Product Rating Manual for Fan Air Performance'' (``AMCA 211-13'') into
a single standard.\67\ Consistent with the recommendations of the
Working Group, AMCA 214-21 provides methods to establish the FEP either
by: (1) the measurement of the electrical input power to the fan (i.e.,
a ``wire-to-air'' test); or by (2) the measurement of the fan shaft
power and the application of calculation algorithms to reflect
additional motor, transmission, or control energy use. In each case,
the fan power measurements are performed in accordance with AMCA 210-16
or ISO 5801:2017, which is referenced in AMCA 214-21 as an equivalent
test procedure to AMCA 210-16. AMCA 214-21 also references laboratory
test methods for additional categories of fans such as jet fans,
circulating fans, and induced flow fans.\68\ Specifically, AMCA 214-21
references AMCA 230-15 \69\ as the industry test procedure to follow
when conducting performance measurements on air circulating fans. In
addition, AMCA 214-21 adds specific test instructions to ensure test
repeatability and reproducibility. Specifically, AMCA 214-21 defines a
single set of test set-ups that must be used when conducting a test to
ensure comparability of results (See Table III-9). Further, AMCA 214-21
specifies how to select the speed(s) and duty points at which to
conduct the test, as well as which accessories to include in the test
(See Table III-10).
---------------------------------------------------------------------------
\67\ AMCA 211-13 provides instructions on how to apply fan laws
and on how to perform a test when establishing an AMCA-certified
rating. Some of these instructions were revised and integrated in
AMCA 214.
\68\ AMCA 230-15, AMCA 250-12, ``Laboratory Methods of Testing
Jet Tunnel Fans for Performance,'' and AMCA 260-20, ``Laboratory
Methods of Testing Induced Flow Fans for Rating,'' for testing
circulating fans, jet fans, and laboratory exhaust fans with induced
flow.
\69\ AMCA 230-15 provides methods for conducting laboratory
tests to determine the performance characteristics of circulating
fans including the FEP in W, speed in RPM, pressure in inches of
mercury, airflow in CFM, thrust in pound force (lbf), efficacy in
CFM/W, and overall efficiency in lbf/W.
Table III-9--AMCA 214-21 Test Configurations
[Table 7.1 of AMCA 214-21]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Required Optional
Fan configuration Test standard ------------------------------------------------------------------------------------------------
Test configuration * FEI pressure basis ** Test configuration FEI pressure basis
--------------------------------------------------------------------------------------------------------------------------------------------------------
Centrifugal housed............... AMCA 210-16......... B or D................. Total................. A or C................ Static.
Radial housed.................... AMCA 210-16......... B or D................. Total................. A or C................ Static.
Centrifugal inline............... AMCA 210-16......... B or D................. Total................. A or C................ Static.
Centrifugal unhoused............. AMCA 210-16......... A...................... Static................ N/A................... N/A.
Centrifugal PRV exhaust.......... AMCA 210-16......... A or C................. Static................ N/A................... N/A.
Centrifugal PRV supply........... AMCA 210-16......... B...................... Total................. A..................... Static.
Axial inline..................... AMCA 210-16......... D...................... Total................. C..................... Static.
Axial panel...................... AMCA 210-16......... A...................... Static................ N/A................... N/A.
Axial PRV........................ AMCA 210-16......... A or C................. Static................ N/A................... N/A.
Circulating Fans................. AMCA 230-15......... E...................... Total................. N/A................... N/A.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Each letter corresponds to a test set-up described in Section 7.1 of AMCA 214-21. A: free inlet, free outlet; B: free inlet, ducted outlet; C: ducted
inlet, free outlet; D: ducted inlet, ducted outlet.
** This indicates that reference FEP used in the FEI calculation is established using either static or total pressure as indicated in this table and as
determined by the required test configuration.
[[Page 27344]]
Table III-10--AMCA 214-21 Test Options
--------------------------------------------------------------------------------------------------------------------------------------------------------
Test description (section 6 of Motor controller Transmission FEP determination
AMCA 214-21) Driver configuration configuration configuration Test speed(s) method
--------------------------------------------------------------------------------------------------------------------------------------------------------
Wire to air test at all speeds..... Motor................. With or without a With or without All speeds **........ Section 6.1 of AMCA
motor controller. transmission. 214-21.
Wire to air test at selected speeds Motor................. With or without a With or without At least two speeds.. Section 6.2 of AMCA
motor controller. transmission. 214-21.
Fan shaft power test for fans None.................. With or without a Without transmission. At least one speed... Section 6.3 of AMCA
without a motor *. motor controller. 214-21.
Fan shaft power test for fans with Electric motors With a variable Direct drive, V-belt At least one speed... Section 6.4 of AMCA
a regulated motor *. subject to standards frequency drive in drive, flexible 214-21.
at 10 CFR 431.25. accordance with coupling, or
section 6.4.1.4 of synchronous belt
AMCA 214-21 or drive.
without a motor
controller.
Fan shaft power test and motor/ Motor................. With or without a Direct drive, V-belt At least one speed... Section 6.5 of AMCA
motor and controls test *. motor controller. drive, flexible 214-21.
coupling, or
synchronous belt
drive.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* With or without the use of interpolation or fan laws as provided in Annex E.
** All speeds for which FEP values are generated.
In the July 2022 NOPR, DOE proposed to incorporate by reference
AMCA 214-21 as the prescribed test method for evaluating the energy use
of fans and blowers, with modifications discussed in section III.E of
this document. DOE also proposed to incorporate by reference AMCA 210-
16, ISO 5801:2017, and AMCA 230-15 (with errata) (or latest version
available at the time of the any final rule),\70\ which are the
physical test methods referenced in AMCA 214-21 for fans and blowers
and air circulating fans. 87 FR 44194, 44121.
---------------------------------------------------------------------------
\70\ In the July 2022 NOPR, DOE noted that it was aware that
AMCA 230-15 is currently undergoing periodic review and may be
revised in the future. Should a new version become available at the
time of any final rule, DOE would incorporate by reference the
latest available version of AMCA 230.
---------------------------------------------------------------------------
In response to the July 2022 NOPR, AMCA commented that AMCA 214-21
itemizes which method of physical testing applies adequately to which
fan category and that these physical measurements are perfectly
suitable for deriving each of the energy performance ratings considered
by this rulemaking. AMCA commented that each of those methods provides
for the relevant fan types their fan air performance and input power.
AMCA added that AMCA 210 and ISO 5801 were the only appropriate test
methods for fans that generate fan static pressure when applied as
intended. AMCA added that AMCA 230 is the single appropriate test
method for measuring the performance of air circulating fans that
operate at zero fan static pressure with at least 125 W electrical
input power and noted that air circulating fans below 125 W electrical
power are in the scope of IEC 60879, ``Comfort fans and regulators for
household and similar purposes.'' AMCA noted that too few AMCA members
supply low-power air circulating fans and that AMCA was unable to
provide more detailed comments. AMCA added that these industry
standards measure input power (W) and that prediction of energy
consumption (kWh) requires knowledge of operating hours and load, which
are too diverse to develop an average use cycle representing the fan
industry at large. AMCA noted that the energy-conservation metric that
is being defined by DOE references FEI as defined in AMCA 214-21, and
because FEI is calculated for a given duty point, energy consumption is
inversely proportional to FEI during any use cycle. (AMCA, No. 41 at
pp. 14-15)
AMCA further commented that AMCA 210 and AMCA 230 establish uniform
test methods to ensure test procedure repeatability. AMCA added that
requirements within the standards, such as maintaining instrument
accuracy and calibration, contribute to attaining repeatability.
Additionally, to help achieve reproducibility between accredited
laboratories, AMCA's laboratory accreditation program requires that
AMCA audit instrument calibration, compare air-performance test results
from AMCA's laboratory against results obtained in the laboratory under
review, and conduct independent readings of certain parameters during
the test for verification of instrumentation accuracy. AMCA commented
that AMCA 214 specifies calculations based on data from various
relevant laboratory methods of test and that AMCA does not recommend
any changes to these standards in regard to repeatability and
reproducibility. In addition, AMCA noted that: (1) AMCA 210 and ISO
5801 are mature test methods that have been used globally for many
years; and (2) thrust-testing per AMCA 230 is straightforward. In
addition, AMCA already notes that thrust-testing also is used in the
DOE test method for large diameter ceiling fans (LDCFs); and (3) as
part of the AMCA Lab accreditation program, the same fan is tested at
AMCA accredited labs and retested at the AMCA Lab with strict tolerance
limits, similar to what is done in a round robin and AMC added it could
provide test data from multiple labs for the same fan. (AMCA, No. 41 at
pp. 15-16)
AMCA also noted that AMCA 210-16 will be heading into its ANSI-
required review/update cycle later in 2022. AMCA expected this to be a
revision cycle, not an affirmation, as affirmations only comprise
editorial corrections. AMCA commented that this revision would take
some time and recommended that DOE not consider the upcoming revision
update to AMCA 210. AMCA commented that since the last revision, public
comments have accumulated via AMCA's website; however, AMCA does not
recommend any changes with regard to AMCA 214-21 and AMCA 210-16.
(AMCA, No. 41 at p. 16)
AMCA also commented that AMCA 230 is nearing the completion of its
ANSI-required review/update cycle. AMCA commented that it expects this
revision to be completed in the near future. AMCA recommended that DOE
reference the updated version of AMCA 230 and advised DOE that AMCA
230's revision is nearing completion with the draft out for committee
ballot. AMCA stated it expected AMCA 230 to be published as an ANSI/
AMCA standard in late 2022 or early 2023. (AMCA, No. 41 at pp. 16-17)
ebm-papst commented that AMCA 210, ISO 5801, and AMCA 230 (as
applicable) provided representative measurements of fan power
consumption, which were suitable for determining fan efficiency. ebm-
papst recommended adopting AMCA 210-16, AMCA 214-21, and AMCA 230-15
[[Page 27345]]
without any changes. (ebm-papst, No. 31 at pp. 7-8)
New York Blower commented that AMCA 214-21 and the corresponding
FEI metric reasonably estimated energy efficiency and functioned as a
viable measure of changes in energy consumption reflected by
differences in the FEI values. New York Blower commented that the
representative average use issue had been a troubling one to settle due
to the wide variety of applications of fans and an industrial
application can easily be considered to be continuous operation at the
specified operating conditions for 3,000 hours annually (New York
Blower, No. 33 at p. 11)
Trane commented that DOE should reference and adopt AMCA 214-21 as
its principal test procedure for commercial fans and blowers. (Trane,
No. 38 at p. 2)
Greenheck commented that DOE should adopt the test procedures and
standards in AMCA 210,\71\ 211, and 214 in lieu of the proposed test
procedures detailed in the July 2022 NOPR. Greenheck commented that the
proposal by DOE differed from the above AMCA standards in ways that
would create an extreme burden on the entire fan industry and result in
little benefit to the consumer or a reduction in energy consumption.
(Greenheck, No. 39 at pp. 1-2)
---------------------------------------------------------------------------
\71\ DOE notes that Greenheck's comment lists AMCA 210, AMCA
211, and AMCA 214 on page 1 of its comments and seems to include a
typo on page 2 where it lists AMCA 11, AMCA 211, and AMCA 214.
(Greenheck, No. 39 at pp. 1-2)
---------------------------------------------------------------------------
Morrison commented that the AMCA 210 and AMCA 214 test procedures
captured the performance and energy consumption of fans in a clear
manner for the relevant fans other than air circulating fans.
(Morrison, No. 42 at p. 4) Morrison commented that AMCA 210 established
uniform test methods to ensure test-procedure repeatability and that
requirements within the standard, such as maintaining instrument
accuracy and calibration, contributed to attaining repeatability.
Morrison commented that it does not recommend any changes to these
standards in regard to repeatability and reproducibility as AMCA 210
was a mature test method that had been used globally for many years.
(Id. at p. 5)
As noted by stakeholders, AMCA 210-16, AMCA 214-21, and AMCA 230-23
are established test standards used by industry to establish the
performance of fans and blower, including air circulating fans. In
addition, as previously noted, AMCA 214-21, which references AMCA 210-
16 provides test methods that are consistent with the recommendations
of the Working Group for fans and blowers other than air circulating
fans. Therefore, in this final rule, DOE incorporates by reference AMCA
210-16 and AMCA 214-21 as proposed in the July 2022 NOPR. In addition,
as discussed in the July 2022 NOPR, DOE is replacing the reference to
AMCA 230-15 (with errata) with AMCA 230-23.\72\ DOE did not propose to
incorporate AMCA 211-22, ``Certified Ratings Program Product Rating
Manual for Fan Air Performance,'' because it does not specify a test
method but rather certification and rating procedures, and thus DOE is
not adding this standard. In addition, DOE is modifying certain
sections of these industry standards as discussed in section III.E of
this document.
---------------------------------------------------------------------------
\72\ In the July 2022 NOPR, DOE noted that it is aware that AMCA
230-15 was undergoing periodic review and may be revised in the
future. Should a new version become available at the time of any
final rule, DOE would incorporate by reference the latest available
version of AMCA 230. 87 FR 44194, 44221.
---------------------------------------------------------------------------
In addition, due to the comments received on the proposed metric
(see section III.G of this document) and the adoption of an efficacy
metric in CFM/W rather than FEI for air circulating fans, DOE is only
incorporating by reference AMCA 230-23 for air circulating fans instead
of referencing both AMCA 230-15 (with errata) and AMCA 214-21 as
proposed. As noted in the July 2022 NOPR, AMCA 214-21 references AMCA
210-16 and AMCA 230-15 (with errata) as the physical test method, and
further provides provisions for calculating the FEI. 87 FR 44194,
44221. Because DOE is adopting an efficacy metric for air circulating
fans and is not opting to determine the FEI of air circulating fans,
DOE is no longer referencing AMCA 214-21 for air circulating fans.
As stated, in the July 2022 NOPR, AMCA 214-21 provides methods to
establish the FEP of a fan based on fan power measurements which are
performed in accordance with AMCA 210-16 or ISO 5801:2017, which is
referenced in AMCA 214-21 as an equivalent test procedure to AMCA 210-
16. 87 FR 44194, 44218-44219. DOE proposed incorporating by reference
AMCA 214-21, which allows testing fans other than air circulating fans
in accordance with either AMCA 210-16 or ISO 5801:2017 and DOE
requested feedback on whether these test methods produce equivalent
test results.\73\ 87 FR 44194, 44221-44222.
---------------------------------------------------------------------------
\73\ The July 2022 NOPR included a typographical error in the
request for comment on the equivalency of AMCA 210-16 and ISO 5801-
2017, which listed AMCA 214-21 instead of AMCA 210-16.
---------------------------------------------------------------------------
AMCA commented that the test methods prescribed in ISO 5801 and
AMCA 210 produce equivalent results when the appropriate test setup is
used. AMCA commented that the technical content of AMCA 210 and ISO
5801 are in agreement. AMCA added that products in AMCA's Certified
Ratings Program (CRP) are tested in accordance with both ISO 5801 and
AMCA 210, and there is reproducibility between both of these test
methods, as has been observed through the CRP over decades. AMCA added
that one AMCA member conducted comparative testing in its own ISO 5801
lab (inlet chamber) and compared the results with an AMCA 210 test
(inlet chamber/Figure 15) and also with AMCA's labs in Chicago and
Malaysia and agreement was excellent between each of these labs. (AMCA,
No. 41 at p. 15)
New York Blower commented that it relies on the ISO standard and
review process to ensure the purpose of the two standards is to produce
a similar result. In general, considering this is a U.S. domestic test
procedure, New York Blower recommended the use of AMCA 214-21 as the
governing document in the test procedure. (New York Blower, No. 33 at
p. 11)
ebm-papst commented that it has conducted intercompany round-robin
testing to compare AMCA 210 results with ISO 5801 results and concluded
that testing fans by these two standards provides equivalent results.
(ebm-papst, No. 31 at p. 8) Similarly, Morrison commented that testing
conducted with the same setup in either of these standards produced
functionally equivalent results. (Morrison, No. 42 at p. 5)
As noted by AMCA, New York Blower, ebm-papst, and Morrison, AMCA
210-16 and ISO 5801:2017 provide equivalent test results and DOE
continues to incorporate by reference AMCA 214-21, which references
both AMCA 210-16 and ISO 5801:2017 for testing fans and blowers other
than air circulating fans.
In addition, in the July 2022 NOPR, DOE further noted that Section
6.3.1 of AMCA 214-21 provides specific equations to be used for bare
shaft fans that can only accommodate a direct-drive transmission (i.e.,
fans that are directly coupled to the drive) and DOE requested comment
on the physical features that could be identified to differentiate bare
shaft fans that can accommodate only a direct-drive transmission from
other bare shaft fans. 87 FR 44194, 44219, 44222.
AMCA commented that AMCA 99-16, Section 9, can be referenced for
common belt and direct-drive fan-drive
[[Page 27346]]
arrangements, auxiliary bearings, shaft(s), and/or pulley(s) typically
indicate a belt-drive arrangement. (AMCA, No. 41 at p. 17) Similarly,
Morrison commented that common belt and direct-drive fan-drive
arrangements could be found in AMCA 99-16. Additionally, the presence
of auxiliary bearings, shaft(s), and/or pulley(s) typically indicated a
belt-drive arrangement. (Morrison, No. 42 at p. 5)
New York Blower commented that it was possible to convert an
arrangement 1 fan (belt drive) to an arrangement 8 fan (direct drive)
merely by replacing the drive sheave with a coupling and an extended
pedestal to support the motor. New York Blower added that, in reality,
the shaft and bearings for the drive system would be redesigned to
accommodate the different drive system, but to the casual observer, it
would look identical. New York Blower noted that arrangement 4 fans
have the impeller mounted directly to the motor and so, technically, it
would not be a fan without the motor. In summary, New York Blower
commented that it was unable to provide distinguishing physical
features to assist in the distinction requested and did not see it
conceivable to do so. (New York Blower, No. 33 at p. 12)
DOE concludes that the presence of auxiliary bearings, shaft(s),
and/or pulley(s) would indicate a belt drive arrangement and would
constitute physical features that would differentiate fans that can
operate in a belt drive configuration from bare shaft fans that can
only accommodate a direct-drive transmission. Therefore, DOE is not
modifying the provisions in section 6.3.1 of AMCA 214-21 which provides
specific equations to be used for bare shaft fans that can only
accommodate a direct-drive transmission.
E. Adoption and Modification of the Industry Standards
As discussed in section III.D, DOE is adopting through reference
certain provisions of AMCA 214-21 and AMCA 230-23 as the prescribed
test method for measuring the energy use and energy efficiency of fans
and blowers. In the July 2022 NOPR, specifically, for fans and blowers
that are not air circulating fans, DOE proposed that testing be
performed in accordance with AMCA 214-21, with the modifications
discussed in the remainder of this section. For air circulating fans,
DOE proposed that testing be performed in accordance with AMCA 230-15
with errata, with the modifications discussed in the rest of this
section. 87 FR 44194, 44221-44222
For fans other than air circulating fans, the industry test
procedure (AMCA 214-21) provides methods to calculate the FEI and FEP
of a fan at each of its duty points based on: (1) the fan electrical
input measured by a wire-to-air test; or (2) the fan shaft input power
measured by a shaft-to-air test, and the application of calculation
algorithms to represents the performance of the motor or motor and
controller. The industry test procedure (AMCA 214-21) also provides
methods to calculate the FEP or fan shaft input power at untested duty
points, based on the performance of test duty points and interpolation
methods, including the fan laws. For air circulating fans, the industry
test procedure provides methods to calculate the efficacy in CFM/W of a
fan at maximum speed based on the fan electrical input measured by a
wire-to-air test. The following sections discuss key elements of the
test procedure and modifications to AMCA 214-21 and AMCA 230-23.
Regarding AMCA 214-21, AMCA recommended that DOE adopt the speed
and size interpolations standardized in AMCA 214-21. (AMCA, No. 41 at
p. 16) Morrison recommended that DOE adopt the speed and size
interpolations standardized in AMCA 214. Further, Morrison recommended
no changes be made to AMCA 214-21 and AMCA 210-16. (Morrison, No. 42 at
p. 5) New York Blower requested that fan laws be declared a universally
accepted AEDM where no testing would be required to apply these laws to
create ratings. (New York Blower, No. 33 at p. 24)
In regards to AMCA, Morrison, and New York Blowers comments, DOE
references section 8.2.1 of AMCA 214-21, ``Fan laws and other
calculation methods for shaft-to-air testing,'' and section 8.2.3 of
AMCA 214-21, ``Calculation to other speeds and densities for wire-to-
air testing,'' which allow speed and size interpolations as proposed in
the July 2022 NOPR. (See 87 FR 44194, 44222.)
Robinson commented that the July 2022 NOPR stated that when
applying fan laws, the results of a tested fan are used to calculate
the fan shaft power of a non-tested fan at a higher speed or with a
larger diameter than the fan tested. Robinson asked whether DOE
suggested that compressible fan laws can only be applied to fans that
are larger or faster than the tested fan. (Robinson, No. 43 at p. 7)
DOE notes the July 2022 proposed to apply the fan laws as described
in section 8.2.1 of AMCA 214-21, ``Fan laws and other calculation
methods for shaft-to-air testing,'' which relies on the calculation
methods in Annex E of AMCA 214-21.87 FR 44194, 44223. Section E.1.1
specifies the requirements to apply the fan laws including the
requirement that the fan must have a greater diameter than the tested
fan, (See section E.1.1.3 of AMCA 214-21) and must have a fan tip speed
that is greater than or equal to the tested fan tip speed.
Motor Efficiency Calculation
For bare shaft fans and fans with an electric motor subject to
energy conservation standards at 10 CFR 431.25 (``polyphase regulated
motor''), sections 6.3 and 6.4 of AMCA 214-21 specify testing these
fans using a shaft-to-air test (i.e., a test that does not include the
motor performance). When conducting a shaft-to-air test, the mechanical
fan shaft input power is measured and the FEP is then calculated by
using a mathematical model to represent the performance of the motor
(i.e., its part-load efficiency). The FEP is then used to calculate the
FEI of the fan.
AMCA 214-21 provides two different methods to estimate the part-
load efficiency of a polyphase regulated motor. A single equation
presented in section 5.3 and section 6.3.3 of AMCA 214 is used to
calculate the FEP of the reference fan (``FEPref'') and the
actual FEP of bare shaft fans (``FEPact''), while a more
complex model based on several equations described in section 6.4.2.3
of AMCA 214 is used to calculate the actual FEP of fans sold with
polyphase regulated motors without a variable frequency drive
(``VFD''). 87 FR 44194, 44222. DOE proposed to maintain the equation as
provided in section 5.3 (which are identical to the equations provided
in section 6.3.3 of AMCA 214-21) and in section 6.4.2.3 of AMCA 214-21
to estimate the part-load motor efficiency when calculating
FEPref, FEPact of bare shaft fans,\74\ and the
FEPact of fans sold with electric motors regulated at 10 CFR
431.25 (and without VFDs). Id.
---------------------------------------------------------------------------
\74\ The NOPR did not explicitly specify ``of bare shaft fans''
in the preamble; however, the discussion did previously mention that
the equation in Section 6.3.3 of AMCA 214-21 is identical to the
equation in Section 5.3 of AMAC 214-21 and applicable to the
calculation of FEPact for bare shaft fans. See 87 FR
44194, 44222. In addition, the proposed regulatory text specified
testing bare shaft fans per Section 6.3 of AMCA 214-21 (See Table 1
to Appendix A to tSubpart J of Part 431), which includes Section
6.3.3 of AMCA 214-21. See 87 FR 44194, 44257.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE requested comment on the equations
provided in section 5.3 and section 6.4.2.3 of AMCA 214-21.
Specifically, DOE requested comment on whether applying the method
outlined in section 6.4 of AMCA 214-21 and the equations
[[Page 27347]]
provided in section 6.4.2.3 of AMCA 214-21 could result in a higher
value of FEI than the FEI resulting from a wire-to-air test in
accordance with Section 6.1 of AMCA 214-21. Id.
AMCA supports DOE's proposal to maintain the equations as provided
in sections 5.3 and 6.4.2.3 of AMCA 214-21 to estimate the part-load
motor efficiency when calculating FEPref, FEPact,
and the FEPact of fans sold with electric motors regulated
at 10 CFR 431.25 (and without VFDs). AMCA commented that the method
outlined in section 6.4 of AMCA 214-21 will result in slightly higher
or slightly lower value of FEI than the one outlined in section 6.1.
AMCA agrees with DOE that this difference is extremely small and not
significant enough to justify deviating from the established industry
test procedure. In addition, AMCA recommended to additionally reference
Section 6.3 of AMCA 214-21 and add it to the list of acceptable methods
for the case of a bare shaft fan. AMCA stated that because bare shaft
fans eventually will be paired with motors compliant with current
federal regulations, and DOE has concluded the impact on FEI is not
significant, section 6.3 should be mentioned along with section 6.4.
AMCA added that if a bare shaft fan is likely to be paired with a
regulated motor, the method outlined in AMCA 211-21 Section 6.3
provides a convenient and accurate method of calculating FEI when the
specific motor size and type is unknown. (AMCA, No. 41 at pp. 17-18)
Morrison stated its general agreement with AMCA's position that the
entire AMCA 214-21 be adopted including use of sections 6.4.2.3 and 6.3
of AMCA 214-21. (Morrison, No. 42 at p. 5)
In the July 2022 NOPR, DOE proposed to rely on Section 6.3 and
discusses the equation in section 6.3.3 of AMCA 214-21 for determining
the FEP of bare shaft fans. See 87 FR 44194, 44223, 44257.
In this final rule, DOE is maintaining the proposed equation as
provided in section 5.3 and section 6.3.3 of AMCA 214-21 and
maintaining the proposed equations in section 6.4.2.3 of AMCA 214-21 to
estimate the part-load motor efficiency when calculating
FEPref, FEPact of bare shaft fans, and the
FEPact of fans sold with electric motors regulated at 10 CFR
431.25 (and without VFDs).
1. Combined Motor and Controller Efficiency Calculation
For fans with a polyphase regulated motor and a controller, AMCA
214-21 allows testing these fans using a shaft-to-air test (i.e., a
test that does not include the motor and controller performance). When
conducting a shaft-to-air test, the mechanical fan shaft input power is
measured and the FEP is then calculated by using a mathematical model
to represent the performance of the combined motor and controller
(i.e., its part-load efficiency). The FEP is then used to calculate the
FEI of the fan.
Section 6.4.2.4 of AMCA 214-21, which relies on Annex B, ``Motor
Constants if Used With VFD (Normative),'' and Annex C, ``VFD
Performance Constants (Normative),'' provides a method to estimate the
combined motor and controller part-load efficiency for certain electric
motors and controller combinations that meet the requirements in
sections 6.4.1.3 and 6.4.1.4 of AMCA 214-21, which specify that the
motor must be polyphase regulated motor (i.e., an electric motor
subject to energy conservation standards at 10 CFR 431.25).
In the July 2022 NOPR, DOE noted that it had previously developed a
similar model to estimate the combined motor and controller part-load
performance in support of the commercial and industrial pump test
procedure final rule published on January 25, 2016 (``January 2016 Pump
TP''), in the case where the motor is a polyphase regulated motor. See
81 FR 4086, 4128-4130. As noted in the test procedure NOPR pertaining
to commercial and industrial pump published on April 29, 2015 (``April
2015 Pumps NOPR''), the model used in the pump test procedure
represents a conservative estimate of part-load motor losses (and
efficiency).\75\ 80 FR 17585, 17628. As noted in the July 2022 NOPR,
DOE noted that such approach minimizes the possibility that using the
calculation approach to estimate the motor and controller performance
would result in better energy efficiency ratings than when testing the
equipment inclusive of the motor and controller. 87 FR 44194, 44223.
---------------------------------------------------------------------------
\75\ The efficiency (Eff) of a motor at a given load (x) relates
to the motor horsepower (hp) and losses (L) as follows: Eff = (x.
hp)/(x.hp + L).)).
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE compared the motor part-load efficiency
resulting from applying the AMCA 214-21 motor and controller equations
with the combined motor and controller part-load efficiency obtained
when using the equation from the DOE pump test procedure and found that
the AMCA model resulted in combined motor and controller part-load
efficiency values that were generally higher than the DOE model. In
addition, DOE reviewed motor and VFD efficiency data from the AHRI
certified product database \76\ and found existing motor and VFD
combinations that performed at a lower efficiency than predicted by the
AMCA 214 model. DOE also reviewed the reference motor and controller
(``power drive system'') efficiency provided in IEC 61800-9-2:2017
``Adjustable speed electrical power drive systems Part 9-2: Ecodesign
for power drive systems, motor starters, power electronics and their
driven applications--Energy efficiency indicators for power drive
systems and motor starters,'' which also provides equations to
represent the performance of a motor and controller used with fans, and
found that the IEC model predicted values of efficiency that were
significantly lower (more than 10 percent on average) than the model
included in AMCA 214-21. Id.
---------------------------------------------------------------------------
\76\ AHRI Standard 1210, ``Standard for Performance Rating of
Variable Frequency Drives,'' certified data from 2016, 2020, and
202. Available at: www.ahridirectory.org/NewSearch?programId=71&searchTypeId=3.
---------------------------------------------------------------------------
Based on this analysis, DOE stated its concerns that the equations
described in section 6.4.2.4 of AMCA 214-21 may not be appropriately
representative, resulting in fan FEI ratings that would be higher than
FEI ratings obtained using the wire-to-air test method described in
section 6.1 of AMCA 214-21. Therefore, DOE did not propose to allow the
use of section 6.4.2.4 of AMCA 214-21. Instead, DOE proposed that fans
with a motor and controller be tested in accordance with section 6.1 of
AMCA 214-21. DOE indicated that manufacturers would still be able to
rely on a mathematical model (including the same mathematical model as
described in section 6.4.2.4 of AMCA 214-21, as long as the
mathematical model meets the AEDM requirements discussed in Section
III.I of this document) in lieu of testing to determine the FEI of a
fan with a motor and controller. Id.
AMCA commented that, for some manufacturers offering fixed
combinations of fan/motor/controller, the testing approach was
appropriate and encouraged, while for other manufacturers offering
standard fan models that can be paired with any standard, commercially
available, regulated motor and standard, commercially available VFD,
the testing approach of AMCA 214-21 Section 6.1 was not practical and
would inhibit AMCA's ability to offer fan products with high-efficiency
motors (above current regulation). AMCA stated its appreciation that
DOE would consider AMCA 214-21 section 6.4.2.4 an acceptable method to
be used as an AEDM; however, AMCA believed some mistakes were made in
DOE's analysis
[[Page 27348]]
that affected the choice of not directly recognizing the calculation
model from this section as an acceptable alternative to testing. AMCA
commented that these were mistakes also made previously by AMCA that
had not yet been sufficiently publicized to prevent them from
recurring. AMCA provided supporting data and analysis to illustrate the
representativeness of the equations in section 6.4.2.4. (AMCA, No. 41
at pp. 18-21) Specifically, AMCA commented that the DOE model used in
the January 2016 Pump TP represented a conservative estimate of part-
load motor losses (and efficiency). AMCA added that the model in AMCA
214-21, section 6.4.2.4, was not intended to be a conservative estimate
of losses. Instead, according to AMCA, the model was intended to
provide a level playing field between manufacturers that chose to test
wire-to-air and those that chose to test fan shaft power and calculate
wire-to-air losses. AMCA commented that the model used in the pump test
procedure, therefore, should result in higher losses, and AMCA believed
DOE's use of the pump model to assess AMCA 214 for the fan rulemaking
was not valid. (AMCA, No. 41 at p. 18) Regarding AHRI data, AMCA
commented that some motor and efficiency data in the AHRI certified
product database previously included VFD models that performed at a
lower efficiency than most others in the database. When AMCA
interviewed the manufacturer of one of the lower-performing models, the
manufacturer confided that the certified efficiency was much lower than
the actual tested efficiency, but was intentionally rated lower for
unrelated reasons. AMCA analyzed the current AHRI 1210 database and
found that 59 percent of AMCA 214 calculations were within +/-1 percent
of AHRI data and 96 percent were within +/-3 percent and provided
graphical representations comparing the AHRI data to the AMCA 207
model.\77\ (AMCA, No. 41 at pp. 18-19) AMCA added that the reference
PDS model in IEC 61800-9-2:2017 was not typical of currently available
products and that no VFDs nor motors were available at these low
efficiency levels in the United States. AMCA noted that the equations
representative of typical PDS were available in IEC TS 60034-31:2010,
``Rotating electrical machines--Part 31: Selection of energy-efficient
motors including variable speed applications--Application guide.'' AMCA
further provided a graphical comparison of its model against the
equations available in IEC TS 60034-31:2010 as well as in the Motor
Systems Tool published by 4E EMSA and demonstrating alignment between
models. (AMCA, No. 41 at pp. 19-20) AMCA added that the next version of
IEC 61800-9-2 will be expanded to cover VFD frequencies above 60 Hz
which is a common condition for fans. AMCA recommended removing IEC
61800-9-2 from consideration for the CIFB rulemaking until at least
Edition 2 of IEC 61800-9-2 has been published. Finally, testing at the
AMCA lab and at members' labs has always shown excellent agreement with
the AMCA 207 models. Figures 5 and 6 show recent testing on 3 and 10 hp
motors covering a vast range of speeds and torques. Again, the AMCA 207
model \78\ is labeled as the equivalent ISO 12759-2. (AMCA, No. 41 at
p. 21)
---------------------------------------------------------------------------
\77\ The AMCA 207 equations are identical to those found in
Section 6.4.2.4 of AMCA 214-21 (See discussion in section III.D of
this document).).
\78\ The AMCA 207 equations are identical to those found in AMCA
214-21 (See discussion in section III.D of this document).)).
---------------------------------------------------------------------------
New York Blower commented that it supports AMCA's analysis. (New
York Blower, No. 33 at p. 13) Morrison stated its general agreement
with AMCA's position that the entire AMCA 214-21 be adopted, including
use of Section 6.4.2.4 of AMCA 214-21. (Morrison, No. 42 at p. 5)
Greenheck commented in support of including AMCA 214 Section
6.4.2.4 combining motor/controller efficiency. (Greenheck, No. 39 at p.
1) In addition, for embedded fans, Greenheck commented that the
requirement for wire-to-air testing poses a specific challenge.
Greenheck commented that many products are manufactured without motor
controllers/VFDs that are provided by the field. Greenheck commented
that the proposed testing requirements would, in these cases, put the
certification burden on the installing contractor to validate FEI at
that selection as the contractor would be completing the ``fan
assembly'' as defined. Greenheck commented that this is an unrealistic
expectation and would likely be violated regularly. Greenheck commented
that DOE should align the testing procedure with existing AMCA
standards that allow for calculation of efficiency for motor
transmission and controllers. (Greenheck, No. 39 at p. 6)
Robinson commented that in its experience, the issues with making
representative energy efficiency ratings with the presence of VFDs at
reduced frequency is difficult without direct torque measurement.
Robinson added that motor and VFD suppliers repeatedly refused to
provide data to allow for calculation of motor and VFD efficiency and
power factor at reduced frequency. (Robinson, No. 43 at p. 8)
As noted in the April 2015 Pumps NOPR, the model used in the pump
test procedure represents a conservative estimate of part-load motor
losses (and efficiency). 80 FR 17585, 17628. As stated, this approach
is intended to minimize the possibility that using the calculation
approach to estimate the motor and controller performance would result
in better energy efficiency ratings than when testing the equipment
inclusive of the motor and controller. As illustrated in AMCA's
comment, the model in AMCA 214-21 section 6.4.2.4 was not intended to
be a conservative estimate of losses and instead is representative of
typical performance. In line with DOE's findings, the analysis provided
by AMCA shows that there are many AHRI-certified motor and VFD
combinations that have a tested efficiency that is lower than the model
in section 6.4.2.4 of AMCA 214-21. Therefore, DOE continues to have
concerns that applying the model in section 6.4.2.4 of AMCA 214-21 may
result in fan FEI ratings that would be higher than FEI ratings
obtained using the wire-to-air test method described in section 6.1 of
AMCA 214-21. Therefore, DOE is not allowing the use of section 6.4.2.4
of AMCA 214-21. Instead, DOE requires that fans with motor and
controller be tested in accordance with section 6.1 of AMCA 214-21. DOE
notes that manufacturers would still be able to rely on a mathematical
model (including the same mathematical model as described in section
6.4.2.4 of AMCA 214-21, as long as the mathematical model meets the
AEDM requirements discussed in Section III.I of this document) in lieu
of testing to determine the FEI of a fan with a motor and controller.
In addition, DOE notes that the fan manufacturer is responsible for
certifying the equipment as distributed in commerce and a consumer or
installer would not be responsible for additional certification. If a
fan manufacturer sells a fan basic model without a controller, they
would be responsible for certifying that fan basic model without a
controller.
2. Annex A of AMCA 214-21
Annex A provides the reference nominal full-load efficiency values
to use for polyphase regulated motors subject to energy conservation
standards at 10 CFR 431.25 when calculating the motor part load
efficiency in accordance with section 6.4.2.3 of AMCA 214-21. In the
July 2022 NOPR, DOE proposed to replace Annex A of AMCA 214-21
[[Page 27349]]
with a reference to Table 5 of 10 CFR 431.25. The values in Annex A and
Table 5 of 10 CFR 431.25 are identical; however, referencing the Code
of Federal Regulations would ensure that the values of polyphase
regulated motor efficiencies remain up to date with any potential
future updates established by DOE. 87 FR 44194, 44223. DOE did not
receive any comment on this issue and is replacing Annex A of AMCA 214-
21 by referencing Table 5 of 10 CFR 431.25.
3. Annex E of AMCA 214-21
Annex E of AMCA 214-21 allows a reduction in the number of tests
potentially required by allowing the use of fan laws to calculate the
fan shaft power of a non-tested fan using results from a fan shaft
power test of a fan with a smaller impeller diameter. In the July 2022
NOPR, DOE noted that since the publication of AMCA 214-21, AMCA 211-22,
``Certified Ratings Program Product Rating Manual for Fan Air
Performance,'' was published. Annex I of AMCA 211-22 allows the use of
fan laws to additionally interpolate the fan shaft power of a non-
tested fan using results from a fan shaft power test of two fans with a
smaller and larger impeller diameter (i.e., interpolation between two
tested sizes). DOE considered adding a reference to Section I.6 of
Annex I of AMCA 211-22 and allowing manufacturers to additionally
interpolate the fan shaft power of a non-tested fan between two tested
fans sizes. Alternatively, DOE considered referencing Annex I of AMCA
211-22 in place of Annex E of AMCA 214-21. In the July 2022 NOPR, DOE
requested comments on whether it should add a reference to section I.6
of AMCA 211-22 or replace Annex E of AMCA 214-21 by Annex I of AMCA
211-22. 87 FR 44194, 44223-44224.
In response to the July 2022 NOPR, the CEC commented that it
supports the reference of Annex E of AMCA 214-21 only. The CEC
recommended that section I.6 of AMCA 211-22 not be added or referenced
and recommended that Annex I of AMCA-211-22 not replace Annex E of AMCA
214-21. The CEC stated that although section I.6 of AMCA 211-22 and
Annex E of AMCA 214-21 could be used to interpolate and compute the Fan
Energy Index (FEI) of the interpolated fan for different diameter fans,
Annex E of AMCA 214-22 clearly communicated the requirements for the
applicability of the formulas provided in Annex E, including the type
of units to be used and its distinct source. Including section I.6
could lead to incorrect data being generated for certification since it
lacked clear explanations and would require more information to
implement correctly. The CEC added that although Annex I of AMCA 211-22
could replace Annex E of AMCA 214-21, it lacks the detail conditions
for the applicability of the formulas presented. The CEC commented that
Annex I of AMCA 211-22 lacks connectivity to the main body of the test
procedure and does not explain the applicability of the results to
sections 6.3, 6.4, and 6.5 of AMCA 214-21. The CEC added that Annex I
could lead to incorrect data to be generated for certification and
would require more information to implement correctly. For these
reasons, the CEC recommended referencing Annex E of AMCA 214-21 only.
(CEC, No. 30 at pp. 3-4)
AMCA recommended that DOE add a reference to section I.6 of AMCA
211-22. This section covers interpolation between tested fan sizes when
geometric similarity requirements were met and would result in more
accurate ratings for non-tested sizes. (AMCA, No. 41 at p. 22) New York
Blower stated support for AMCA's analysis of the issue. (New York
Blower, No. 33 at p. 13)
As previously stated, DOE is not opting to reference AMCA 214-21
for air circulating fans. DOE reviewed the content of Annex I of AMCA-
211-22 and of Annex E of AMCA 214-21 and notes that both appendices
include identical equations describing the fan laws, interpolations
between tested speeds, and general interpolations between tested fans
when a single geometric feature is varied, with the following
exceptions: (1) Section I.6 of Annex I of AMCA 211-22 allows the use of
fan laws to additionally interpolate the fan shaft power of a non-
tested fan using results from a fan shaft power test of two fans with a
smaller and larger impeller diameter (i.e., interpolation between two
tested sizes), while Section E.3 of Annex E of AMCA 214-21 explicitly
prohibits this and requires the use of fan laws instead; (2) the
equations in Annex I of AMCA 211-22 include the compressibility
coefficients, while the equations in Annex E of AMCA 214-21 assume the
flow is incompressible; and (3) the symbols in Annex I of AMCA 211-22
are not consistent with the symbols used in AMCA 214-21. For these
reasons, at this time to maintain clarity and consistency with the
symbols and terms used through AMCA 214-21, DOE is keeping the
reference to Annex E of AMCA 214-21 as proposed in the July 2022 NOPR.
In addition, DOE is specifying that the equations in Section E.2 of
Annex E of AMCA 214-21 must include the compressibility coefficients as
applicable for compressible flows.
4. Section 6.5 of AMCA 214-21 and Annex F
Section 6.5 and Annex F of AMCA 214-21 provide methods to determine
the FEP of the actual fan by conducting separate tests for the bare
shaft fan and the motor or the combined motor and controller. Annex F
specifies the industry test methods \79\ to use when testing the motor
or the combined motor and controller. As provided in Annex F, the motor
and controller, if included, must be tested at the range of speeds and
loads over which the fan is to be rated. The measurements result in a
map of the input power (kW) versus speed and load and intermediate
values can be determined through interpolation (linear interpolation or
a polynomial curve fit). The methods in section 6.5 and Annex F of AMCA
214-21 are applicable to any electric motor (including non-DOE
regulated motors that meet the definition of electric motor at 10 CFR
431.12) as long as it can be tested per the industry test procedures
included in Annex F.
---------------------------------------------------------------------------
\79\ CSA C747-09 (R2014), ``Energy efficiency test methods for
small motors''; CSA C838-13 (R2018), ``Energy efficiency test
methods for three-phase variable frequency drive systems''; IEEE
112-2017, ``IEEE Standard Test Procedure for Polyphase Induction
Motors and Generators''; and ANSI/ASHRAE Standard 222-2018,
``Standard Method of Test for Electrical Power Drive Systems.''
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE noted that the test procedure for
combined motor and controller in AMCA 214-21 deviates from the methods
proposed in the December 2021 Electric Motors Test Procedure NOPR. 86
FR 71710, 71743 (December 17, 2021).\80\ DOE further noted that for
fans combined with regulated motors, the methods described in section
6.5 and Annex F of AMCA 214-21 would be less burdensome than multiple
wire-to-air tests; however, it would likely be significantly more
burdensome than applying the calculation methods described in section
6.3 of AMCA 24-21, since it would require physical tests of all motors
with which the bare shaft fan could be paired. In addition, with the
option to allow for an AEDM as discussed in Section III.I of this
document, a manufacturer would be able to integrate the methods of
Section 6.5 and Annex F of AMCA 214-21 into a mathematical model as
long as the proposed AEDM requirements were met. 87 FR 44194, 44224.
---------------------------------------------------------------------------
\80\ Since then, DOE notes that the electric motors test
procedure was finalized on October 19, 2022. 87 FR 63588.
---------------------------------------------------------------------------
Therefore, DOE proposed not to include section 6.5 and Annex F of
AMCA 214-21. DOE noted that manufacturers would still be able to rely
[[Page 27350]]
on a mathematical model (including potentially the same model as
described in section 6.5 of AMCA 214-21, as long as the models meet the
AEDM requirements discussed in Section III.I of this document) in lieu
of testing to determine the FEI of a fan with a motor or a motor and
controller, provided that the mathematical model meets all the AEDM
requirements proposed in Section III.I of this document. Id.
Greenheck commented that DOE's proposal to not adopt section
6.4.2.4 of AMCA 214-21 \81\ invalidated a common practice where
manufacturers complete bare shaft testing and combine this data with
separate testing of the power drive system (PDS). Greenheck commented
that the ability to test a PDS separate from the fan significantly
reduced testing burden as a single PDS test could be applied across
multiple validation classes and sizes. Greenheck commented that testing
a PDS separate from the fan would also necessitate that those
manufacturers complete wire-to-air testing for any instances where they
wish to demonstrate the improved performance of special motor/drive
combinations. According to Greenheck, this exclusion penalized
manufacturers for offering a more energy efficient PDS through
increased testing requirements. (Greenheck, No. 39 at p. 2)
---------------------------------------------------------------------------
\81\ DOE believes this is a typographical error in the comment
and should be referencing Section 6.5 of AMCA 214-21 which describes
the separate bare shaft fans and PDS testing approach.
---------------------------------------------------------------------------
As noted, the test procedure for combined motor and controller in
section 6.5 and Annex F of AMCA 214-21 deviates from the methods
finalized by DOE on October 19, 2022. In addition, for fans combined
with regulated motors, the methods described in section 6.5 and Annex F
of AMCA 214-21 would be less burdensome than multiple wire-to-air
tests; however, it would likely be significantly more burdensome than
applying the calculation methods described in section 6.3 of AMCA 24-
21, since it would require physical tests of all motors with which the
bare shaft fan could be paired. In addition, as stated, manufacturers
would still be able to rely on a mathematical model (including
potentially the same model as described in section 6.5 of AMCA 214-21,
as long as the models meet the AEDM requirements discussed in Section
III.I of this document) in lieu of testing to determine the FEI of a
fan with a motor or a motor and controller, provided that the
mathematical model meets all the AEDM requirements proposed in Section
III.I of this document. For these reasons, DOE is not including Section
6.5 and Annex F of AMCA 214-21.
5. Annex H and Annex I of AMCA 214-21
Annex H ``Required Reported Values (Normative)'' of AMCA 214-21
provides reporting requirements. In the July 2022 NOPR, DOE did not
propose to adopt Annex H. DOE stated that it may consider proposals to
establish reporting requirements for fans and blowers under a separate
rulemaking. 87 FR 44194, 44224.
Annex I ``Minimum Data Requirements for Published Ratings
(Informative)'' provides guidance on what performance information to
publish. In the July 2022 NOPR, DOE did not propose to adopt Annex I.
DOE proposed to adopt requirements regarding represented values in
Section III.J of that document. 87 FR 44194, 44224.
The CEC recommended incorporating by reference Annex H of AMCA 214-
21 defining the efficiency boundaries of the fan by maximum airflow,
maximum pressure, and maximum fan speed as these terms are defined in
that section. (CEC, No. 30 at p. 6)
The CA IOUs commented that they were concerned that DOE's test
procedure final rule may preempt aspects of the ongoing Title 20
Appliance Standards rulemaking. Specifically, the CA IOUs noted that
DOE did not propose to adopt Annex H ``Required Reported Values
(Normative)'' of AMCA 214-21 Test Procedure for Calculating FEI for
Commercial and Industrial Fans and Blowers. The CA IOUs commented that
DOE stated that it may consider reporting requirements in a separate
rulemaking. However, the CA IOUs noted that the CEC has proposed
adopting Annex H in its Express Terms to determine Maximum Airflow,
Maximum Pressure, and Maximum Fan Speed at which the fan can achieve an
FEI greater than or equal to 1.0. Therefore, the CA IOUs requested that
DOE adopt appendix H to align with the CEC proposal. (CA IOUs, No. 37
at p. 7)
DOE is not adopting reporting requirements for fans and blowers in
this rulemaking. DOE may consider proposals to establish reporting
requirements for fans and blowers under a separate rulemaking. DOE
notes that 180 days after publication of this final rule, any
representations made with respect to energy use or efficiency of fans
or blowers must be made based on testing in accordance with the test
procedures established in this final rule. Further, in regard to the CA
IOUs comments about preemption, EPCA states that section 6297 applies
with respect to the equipment described in section 6311(1)(L) beginning
on the date on which a final rule establishing an energy conservation
standard is issued, except that any State or local standard prescribed
or enacted for the equipment before the date on which the final rule is
issued shall not be preempted until the energy conservation standard
for the equipment takes effect. (42 U.S.C. 6316(a)(10))
6. Section 8.3 of AMCA 214-21
Section 8.3, ``Appurtenances,'' provides guidance on how to
characterize fan performance in the case of a fan with additional
appurtenances beyond what is required by the test procedure. In the
July 2022 NOPR, DOE did not propose to adopt this section as DOE does
not propose to establish fan performance with additional appurtenances
beyond what is specified in the test procedure.\82\ 87 FR 44194, 44224.
---------------------------------------------------------------------------
\82\ Section III.D.7 of the July 2022 NOPR included an erroneous
reference to Section 7.3 of AMCA 214-21, which DOE did not propose
to adopt at the time. See 87 FR 44194, 44224. This error was noted
in a comment by AMCA (AMCA, No. 41 at p. 23).
---------------------------------------------------------------------------
DOE did not receive any comment on this issue and is not including
section 8.3 of AMCA 214-21, because DOE is not establishing fan
performance with additional appurtenances beyond what is required in
the test procedure. See section III.E.12 of this document.
7. Measurement of PVR Performance
Table 7.1 of AMCA 214-21 requires different test configurations for
PRVs that supply air to a building and PRVs that exhaust air from a
building. Some PRVs can operate both as supply and exhaust fans. In the
July 2022 NOPR, DOE proposed that PRVs that can operate both as supply
and exhaust fans be tested in both configurations. 87 FR 44194, 44224.
In response to the July 2022 NOPR, the Efficiency Advocates
commented that they support DOE's proposal for PRVs requiring that
models capable of operating as both supply and exhaust fans be tested
as both as it would help ensure that PRVs are tested and rated in all
configurations in which they may be installed. (Efficiency Advocates,
No. 32 at p. 3)
AMCA supports testing in both configurations. If a PRV is marketed
as being able to operate both as a supply and an exhaust fan, AMCA
requires it to be tested and rated as both a supply PRV and an exhaust
PRV. (AMCA, No. 41 at p. 22)
New York Blower noted that PRVs that operate both in supply and
exhaust
[[Page 27351]]
modes clearly display a significant difference in performance, and that
it is clearly in the manufacturer's best interest to understand the
different performance values. New York Blower added that an unintended
consequence of deriving an efficiency level that eliminates a
significant portion of a direction of PRV could, as unreasonable as it
seems, imply two fans should be installed--each operating in its most
efficient direction--to accomplish both supply and exhaust. (New York
Blower, No. 33 at p. 13)
DOE requires that PRVs that can operate both as supply and exhaust
fans be tested in both configurations. DOE would consider any issues
related to efficiency levels, including differences in performance for
PRVs that operate both in supply and exhaust modes in its separate
energy conservation standards rulemaking.
8. Embedded Fans and Blowers
As discussed in Section III.B.3 of this document, DOE proposed to
exclude fans that are embedded in equipment as listed in Table III-7 of
this document. DOE explained that other embedded fans were included in
the scope of the test procedure to the extent that they meet the test
procedure scope criteria presented in Section III.B.1 of this document
and do not fall under the exclusions discussed in Section III.B.2 of
this document. 87 FR 44194, 44224.
The Working Group recommended that embedded fans be tested in a
standalone fan configuration (i.e., outside of the piece of equipment
in which they are embedded). (Docket No. EERE-2013-BT-STD-0006, No.
179, Recommendation #8 at p. 5) DOE interprets this recommendation to
apply to embedded fans that are not manufactured in a standalone
configuration because standalone fans that are purchased by an OEM for
incorporation into equipment can be tested prior to being embedded.
Because embedded fans included in larger equipment may share structural
or functional parts with that equipment, the fan may not be removable
without causing irreversible damage to the equipment. To address such
embedded fans, the Working Group recommended testing exclusively
embedded fans using additional fan components, except for the fan
impeller, that are geometrically identical to that of the embedded fan
inside the larger piece of equipment. (Docket No. EERE-2013-BT-STD-
0006, No. 179, Recommendation #8 at p. 5) In addition, the Working
Group recommended that embedded fans be certified over their standalone
operating range. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #4 at p. 4)
In the July 2022 NOPR, DOE stated that fan performance information
indicated that OEMs currently test and collect information on embedded
fan performance and that OEMs understand a fan's typical operating
range in terms of flow and pressure. DOE noted that the AMCA 214-21
foreword states that, ``AMCA Standard 214 primarily is for fans that
are tested alone or with motors and drives; it does not apply to fans
tested embedded inside of other equipment.'' To test exclusively
embedded fans that are not manufactured in a standalone configuration,
consistent with the Working Group recommendations, DOE therefore
proposed that these fans be tested as standalone fans, outside of the
equipment in which they are incorporated. In addition, DOE proposed
that if any fan components are not removable without causing
irreversible damage to the equipment into which the fan is embedded,
the manufacturer must use additional fan components, except for the fan
impeller, that are geometrically identical to that of the fan embedded
inside the larger piece of equipment for testing. This would result in
a range of FEI ratings at every operating point at which the fan is
capable of operating, including at the flow and pressure point
experienced by the fan when embedded inside the equipment. 87 FR 44194,
44425.
ebm-papst commented that its customers almost exclusively embed all
purchased fans into equipment that is currently regulated, slated to be
regulated, or not regulated. ebm-papst commented that all fans that it
supplies in testable configurations are rated based on wire-to-air
tests, either AMCA 210 or ISO 5801. However, ebm-papst commented that
fans are often supplied in configurations that are not testable: (1)
suppliers other than ebm-papst have supplied forward curve impellers
loosely placed in scroll housings, thus initially without bearings/
drivers, before the OEM furnishes the motors and thereby finally
creates the housed centrifugal fan; (2) forward curve impellers
complete with integrated motor supplied without scroll housing, as the
eventual housing shape will be part of the larger HVAC unit; or (3)
axial propellers complete with integrated motors but without panels,
because the OEM has the eventual ``panel'' designed and supplied by the
surrounding HVAC unit. Nevertheless, ebm-papst noted that it is common
practice and the OEMs' expectation that suppliers document fan air
performance. In the case of non-testable configurations, the fans would
be tested with inlets, housings, and mounting. (ebm-papst, No. 31 at p.
3)
ebm-papst added that OEM customers expect fan performance
representations from their suppliers when they purchase incomplete
panel fans and or incomplete plenum fans: (1) motorized propellers are
measured and rated in the form of axial panel fans but sold without
panels; and (2) motorized impellers are measured and rated in the form
of plenum fans but sold without inlet cones/rings and without inlet
plates. (Id. at p. 7) emb-papst further commented that all ebm-papst
fans are rated based on tests in standalone configuration, and that
those supplied to OEMs without panels or inlet rings for embedding are
tested in their laboratories with standardized components in place.
emb-papst commented that the necessary geometries of these necessary
peripheral components are comprehensively described for the customers
and users. ebm-papst added that fans it supplies incomplete to OEMs can
be tested with the missing components, that then are documented. In
addition, emb-papst noted that motorized propellers should be tested
with fan panels/orifices in place and that motorized impellers should
be tested with inlet rings/cones and plates in place. (Id. at p. 10)
AMCA commented that fans purchased in a testable configuration
typically are tested standalone and rated. According to AMCA, in these
cases, a fan supplier can provide performance data of a standalone fan
to an OEM. (AMCA, No. 41 at p. 6)
New York Blower commented that its involvement in HVACR equipment
is limited. Regardless, New York Blower stated that for applications it
had been involved in, New York Blower would consider ventilation and
regularly use AMCA 210-16 to conduct the test in a standalone
configuration. New York Blower stated that therefore, by reference,
AMCA 214-21 would also be applicable. (New York Blower, No. 33 at p. 8)
Morrison commented that embedded fans and replacement fans,
especially for HVAC and applications where safety was a consideration,
should be excluded from the scope. Morrison added that fans tested as
standalone do not have the same performance in the appliance as tested
per this test procedure. Morrison stated that testing of fans per AMCA
210 requires many multiples of diameter clear of the inlet and exit to
ensure proper airflow development and these conditions are never
present in appliances, so optimum performance at the lowest energy may
be different than the best FEI selection. (Morrison, No. 42
[[Page 27352]]
at p. 2) Morrison added that while fans supplied to HVAC equipment
manufacturers may be tested as standalone, many are not as they are
custom designed for the appliance and only tested in the appliance.
Morrison commented that the goal of fans for HVAC equipment is to have
the lowest energy consumed at the desired operating point in the
equipment and that will often not correspond with the AMCA 210 or AMCA
214 tested FEI. In other words, according to Morrison, the standalone
testing is generally of no value in the effort of identifying the fan
with the best efficiency in the appliance. Morrison added that the
benefit of standalone testing is very limited as end users need
performance of the appliance tested as an appliance ready for customer
installation. (Id. at pp. 2-3) Morrison further commented that testing
embedded fans as standalone fans will add cost but provide no value.
Morrison stated that AMCA 210 is a test standard for testing of a fan's
performance with no obstruction within recommended distance of the
inlet and exit to ensure the fundamental operation of the fan is not
changed. Morrison commented this is never the case in embedded fans and
in most cases, the most efficient standalone tested fan is not the fan
that consumes the lowest energy in an application--this has been
presented previously in this rulemaking process and is still a
consideration today. Morrison commented that unit level testing or
better full system level testing provides greater opportunity for
energy savings. (Id. at p. 6)
As noted by ebm-papst, it is common practice for OEMs to expect fan
performance information from their fan suppliers. As mentioned by ebm-
papst and AMCA, fans sold in a testable configuration are tested in a
standalone configuration. As specified by ebm-papst, fans supplied
incomplete to OEMs can be tested with the missing components (i.e., in
a standalone configuration) that then are documented. Such approach
aligns with the proposed approach for testing embedded fans that are
not manufactured in a standalone configuration and is consistent with
common industry practice. Therefore, consistent with the Working Group
recommendations, DOE requires that embedded fans that are not
manufactured in a standalone configuration be tested as standalone
fans, outside of the equipment in which they are incorporated. In
addition, in line with the Working Group recommendations and July 2022
NOPR, DOE requires that if any fan components are not removable without
causing irreversible damage to the equipment into which the fan is
embedded, the manufacturer must use additional fan components, except
for the fan impeller, that are geometrically identical to that of the
fan embedded inside the larger piece of equipment for testing. This
will result in a range of FEI ratings at every operating point at which
the fan is capable of operating, including at the flow and pressure
point experienced by the fan when embedded inside the equipment. DOE
further notes that the July 2022 NOPR omitted the corresponding
provisions in the proposed regulatory text and DOE is adding the
corresponding provisions in the final regulatory text.
The CA IOUs commented that the proposed test procedure would apply
to fans embedded in non-regulated equipment such as air-handlers. The
CA IOUs commented that neither proposed regulatory language nor the
commentary provided guidance to manufacturers on how to provide fan
performance data when the requirements of the NOPR take effect. The CA
IOUs commented that Title 24, ASHRAE 90.1, and IECC 2021 require that
designers meet a maximum fan system power and that the selected fans
meet a minimum FEI. The CA IOUs commented that many manufacturers buy a
fan represented as a bare shaft fan and bundle it with a motor,
transmission, and/or controller. If the fan manufacturer created this
bundle, it would have a different representation than the bare shaft
fan. Moreover, many manufacturers build fan arrays (i.e., fans with
single-speed motors controlled by a single variable frequency drive
controller supplied by the packager). The CA IOUs added that fan arrays
are not in the scope of AMCA 214-21. Specifically, the CA IOUs
requested clarification on the following issues: (1) Can packaged
manufacturers use bare shaft performance data from the fan manufacturer
and then apply an AEDM or one of the permitted modeling methods to
determine the performance of the package with added motors and
controllers? (2) When manufacturers package a fan with a motor,
transmission, or speed controller, are they required to perform the
same testing as a fan manufacturer? If not, can the manufacturer
provide performance data based on testing inside the air handler? (3)
How can fan manufacturers present performance data for fan arrays where
one controller operates many motors? (CA IOUs, No. 37 at p. 8)
Regarding issue (1), DOE clarifies that if a manufacturer assembles
a combined bare shaft fan and motor and controller and chooses to make
representations of FEI for the combined equipment that it distributes
in commerce, then the manufacturer would need to rate the combined
equipment in accordance with DOE test procedures. Regarding items (2)
and (3), DOE notes that the test procedure is applicable to the fan
tested in a standalone fan configuration and does not apply to fan
assemblies.
New York Blower commented that it provides a significant quantity
of applications where the fan could be described as embedded in a
device or system that provides an end service, such as dust collection
and that structural design modifications may be required to install the
fan in the resulting system. New York Blower commented that it tests
the fan by extracting it from the system, creating a mounting interface
to support testing and conduct the test. New York Blower commented that
for more integrated systems, such as HVACR applications, this may pose
significant challenges. (New York Blower, No. 33 at pp. 13-14)
DOE understands that the example described by New York Blower is of
a standalone fan installed in a larger system in the field. Such a fan
would be tested in the standalone configuration.
ebm-papst requested clarification regarding an OEM's obligation for
air performance testing when a fan is incomplete without components
that are part of a surrounding unit. (ebm-papst, No. 31 at p. 1)
As adopted, embedded fans that are not manufactured in a standalone
configuration must be tested as standalone fans, outside of the
equipment in which they are incorporated. As noted, if any fan
components are not removable without causing irreversible damage to the
equipment into which the fan is embedded, the manufacturer must use
additional fan components, except for the fan impeller, that are
geometrically identical to that of the fan embedded inside the larger
piece of equipment for testing.
9. Wire-to-Air Performance for Air Circulating Fans
As discussed in the July 2022 NOPR, DOE did not find any
circulating fans that were distributed in commerce without an electric
motor. However, if an air circulating fan is sold without a motor, it
would still meet the definition of an air circulating fan and would be
included in the scope of the test procedure. Therefore, in the July
2022 NOPR, DOE proposed that air circulating fans distributed in
commerce without an electric motor be tested using an electric motor as
recommended
[[Page 27353]]
in the manufacturer's catalogs or distributed in commerce with the air
circulating fan. If more than one motor is available in a
manufacturer's catalogs or distributed in commerce with the air
circulating fan, DOE proposed requiring that it be tested using the
least efficient motor capable of running the fan at the fan's maximum
allowable speed. 87 FR 44194, 44225.
ebm-papst commented that it is not aware of any ACF sold without a
motor. (ebm-papst, No. 31 at p. 10)
DOE did not receive any other comments on this topic and thus
requires that air circulating fans distributed in commerce without an
electric motor be tested using an electric motor as recommended in the
manufacturer's catalogs or distributed in commerce with the air
circulating fan. If more than one motor is available in manufacturer's
catalogs or distributed in commerce with the air circulating fan, DOE
requires that it be tested using the least efficient motor capable of
running the fan at the fan's maximum allowable speed.
10. Total Pressure Calculation for Air Circulating Fans
In the July 2022 NOPR, DOE noted that AMCA 214-21 specifies that
air circulating fans must rely on a FEI based on total pressure (sum of
the static pressure and velocity pressure). (See Table III-9 of that
document.) However, AMCA 230-15 does not specify the measurement or
calculation of fan total pressure, which is a required input to the FEI
calculation. In the July 2022 NOPR, DOE proposed to add provisions to
specify how to calculate fan total pressure and to apply the equations
in section A.2 of AMCA 208-18 when calculating the fan total pressure
at a given airflow for fans tested per AMCA 230-15. 87 FR 44194, 44225.
ebm-papst commented that complete reports of AMCA 230 tests include
all information necessary to calculate fan total pressure of
circulation fans. (ebm-papst, No. 31 at p. 10)
As noted by ebm-papst, the information included in an AMCA 230 test
report includes all the information needed to calculate the fan total
pressure. Although DOE is not adopting FEI as the metric for air
circulating fans (which required the determination of total pressure),
section 8.7 of AMCA 230-23 includes equations for calculating total
pressure (the same as proposed by DOE), and DOE is retaining these
provisions by referencing section 8.7 of AMCA 230-23.
11. Appurtenances
Section 7.3 of AMCA 214-21 provides instructions on which
appurtenances to include as part of the tested fan. It distinguishes
between appurtenances that improve or reduce performance. For
appurtenances that improve fan performance (including but not limited
to inlet bells, diffusers, stators, or guide vanes), AMCA 214-21
specifies that these appurtenances should be included if always
supplied with the fan when distributed in commerce. For appurtenances
that reduce fan performance, which include, but are not limited to,
safety guards, dampers, filters, or weather hoods, AMCA 214-21 states
that if the appurtenance is always supplied with the fan when
distributed in commerce, then it shall be tested with the fan. If the
appurtenance is not always supplied with the fan when distributed in
commerce, it shall not be tested with the fan.
For circulating fans, in the July 2022 NOPR, DOE noted that the
AMCA 230 committee was considering adding the following provisions as
part of the revised version of AMCA 230: any appurtenances sold with
the fan shall be included in the minimum testable configuration. 87 FR
44194, 44225.
In the July 2022 NOPR, DOE reviewed the provisions related to
accessories in AMCA 214-21 and as considered by the AMCA 230 committee
and tentatively determined that testing using the provisions discussed
by the AMCA 230 committee would provide results that are more
representative of field conditions because consumers are likely to use
the fan with the appurtenances they purchase. Therefore, for fans and
blowers, including air circulating fans, DOE proposed to specify that
any appurtenances sold with the fan must be included during the test.
In the July 2022 NOPR, DOE requested comment on the proposed provisions
related to the consideration of appurtenances when testing fans and
blowers, including air circulating fans.\83\ Id.
---------------------------------------------------------------------------
\83\ As previously stated, Section III.D.7 of the July 2022 NOPR
included an erroneous reference to Section 7.3 of AMCA 214-21, which
DOE did not propose to adopt in the July 2022 NOPR. Instead, as
described in Section III.D.12 of the July 2022 NOPR, and consistent
with the proposed regulatory text, DOE proposed to apply the same
provisions related to appurtenances as considered by the AMCA 230
committee for air circulating fans: any appurtenances sold with the
fan shall be included in the minimum testable configuration.
---------------------------------------------------------------------------
In response to the July 2022 NOPR, for air circulating fans, AMCA
commented that if an air circulating fan is sold or supplied with a
guard or other appurtenances, then it should be tested with the guard
or other appurtenances, and if the fan is sold or supplied without a
guard or appurtenances, then it should be tested without a guard or
appurtenances. AMCA added that each combination of circulating fan and
appurtenances would be a separate basic model or conservative ratings
could be used to combine multiple basic models. AMCA commented that
this was feasible due to the relatively limited number of air
circulating fan models and combinations of guards/appurtenances offered
by manufacturers. (AMCA, No. 41 at p. 23)
For fans and blowers other than air circulating fans, AMCA
recommended that DOE use the provisions in section 7.3 of AMCA 214-21.
AMCA explained that including appurtenances in the scope of testing
would add burden on fan manufacturers. AMCA commented that historical
data, in general, has been developed without appurtenances being tested
with the fan, so that including appurtenances would negate the validity
of all the historical data and the basic models would need to be tested
again with multiple samples as proposed. AMCA added that some
appurtenances are mutually exclusive, and that numerous accessories can
be applied to fans, but it may not be possible, or reasonable, to apply
all available appurtenances to a fan for testing. AMCA added that
appurtenances that negatively impact fan air performance would clearly,
at the margin, reduce the compliant region of the fan-performance map,
i.e., the FEI bubble would shrink. AMCA commented that one option might
be for manufacturers to create different basic models, i.e., model
numbers for those that include certain appurtenances and separate model
numbers for those that do not--a solution that would clearly add
complexity and significant testing and AEDM costs. Finally, AMCA
commented that DOE's analyses to date, such as those in the notice of
data availability,\84\ have been done without accessories and that
changing the basis of analysis to include appurtenances would require
the analyses to be completely redone to reasonably estimate the cost
impacts and energy savings in a subsequent energy standard. Most
importantly, this proposal would alter the definition of minimum
testable configuration in AMCA 214-21, which is a ``fan having at least
an impeller; shaft and bearings and/or driver to support the impeller;
and its structure or its housing.'' AMCA
[[Page 27354]]
recommended that fans be tested in their minimum testable
configuration--with considerations for appurtenances that are
consistent with section 7.3 of AMCA 214-21. (AMCA, No. 41 at pp. 23-24)
---------------------------------------------------------------------------
\84\ On November 1, 2016, DOE published a notice of data
availability that presented an analysis based on the scope and
metric recommendations of the term sheet. 81 FR 75742.
---------------------------------------------------------------------------
New York Blower commented that adding appurtenances to the fan for
the test procedure will increase testing costs. New York Blower added
that not all appurtenances can be applied to a fan simultaneously and
the proposal to include appurtenances would multiply the number of
basic models and result in a high number of fan models offered to the
market with different combinations of appurtenances. New York Blower
noted the challenge represented by the complexity that would be
generated from the multiple product configurations, testing, and
administrative burden to support product certification. New York Blower
added that the fan is the prime mover from an energy conversion
perspective, and that it is unlikely a fan will be redesigned to be
more efficient based on the addition of an appurtenance. In addition,
New York Blower noted that many appurtenances are not manufactured by
fan manufacturers and that it would be an additional burden for a fan
manufacturer to engage in appurtenance redesign for a product it may
not manufacture. New York Blower added that all the market impact
analysis done to date was accomplished using appurtenance-free fan data
and cannot be used to draw conclusions on the performance of
appurtenance-laden fans in the future. Further, New York Blower
commented adding appurtenances adds significant complexity. (New York
Blower, No. 33 at pp. 5-6)
In addition, New York Blower commented that the inclusion of
appurtenances when testing fans and blowers will increase the required
testing to a degree that is unsupportable by the majority of
manufacturers in the fan industry. New York Blower added that the fan
is the prime energy conversion device and that redesigning the fan to
improve efficiency to accommodate appurtenances is unlikely to achieve
acceptable results. New York Blower added that the test should be
limited to the minimum testable configuration as described in AMCA 214-
21 with the appropriate modifications to the fan to represent the fan
operating in a system. One example of such, stated New York Blower,
would be the installation of an inlet bell to represent an inlet duct.
(Id. at p. 14)
JCI stated that it shared AMCA's comments regarding the rejection
of the currently accepted section 6.4.2.4 \85\ of AMCA 214-21 on
handling appurtenances, which invalidates industry's significant volume
of historical testing. (JCI, No. 34 at p. 2)
---------------------------------------------------------------------------
\85\ Although JCI references Section 6.4.2.4 of AMCA 214-21, DOE
notes that the appurtenances are addressed in Section 7.3 of AMCA
214-21.
---------------------------------------------------------------------------
Morrison commented that fans and blowers should be tested in their
minimum testable configuration and consistent with the considerations
for appurtenances that are found in section 7.3 of AMCA 214-21.
(Morrison, No. 42 at p. 6)
Robinson commented that the testing procedure expectation placed on
the manufacturers of heavy industrial process fans and blowers is
burdensome and impracticable. Robinson commented that the challenge is
pronounced for heavy industrial process fan manufacturers when it comes
to testing with appurtenances. Robinson explained that most heavy
industrial processes require several subprocesses, often over the
stretch of significant acreage of an industrial plant facility (i.e.,
paper mill, petroleum refinery, pharmaceutical plant, mining facility,
chemical plant, food production plant, etc.). Robinson commented that
the air movement equipment required to operate these processes and
subprocesses is robust, designed and engineered specifically for each
application and installation, and also connected to and affected by all
of the appurtenances of the plant's system. Robinson commented it is
unknown how a fan manufacturer would test the fan with its
appurtenances at any point before full installation and by that time,
the fan is fully constructed and sold. Robinson stated that the
location and timing of the testing will also be difficult as fans are
often sold as part of a new subprocess in the midst of construction or
as a replacement for a fan currently operating, which when shut down
requires the idling of an entire industrial process. Robinson commented
it is unclear to what extent industrial fan manufacturers will have to
go in order to comply with this part of the rule. Further, Robinson
stated that all historical testing, done over l00 years, has been done
without appurtenances, and this rule would render all of that testing
useless. (Robinson, No. 43 at p. 3) Robinson added that the inclusion
of appurtenances when testing fans and blowers will add exponentially
to the testing required. Robinson pointed out that it is customary to
certify designs or fan performance based off of test block conditions
or with appurtenances in their least restrictive settings. Robinson
commented that information provided by suppliers of appurtenances is
often inadequate to establish losses at conditions other than design,
and for industrial process custom fan manufacturers, this would be a
very significant burden as each unique configuration and basic model
would be either tested or validated. Robinson added that the addition
of appurtenances also brings system effect factors into play, which
create significant complications. Robinson added that the test should
be limited to the fan only (with or without a motor or drive system)
(Id. at p. 9)
Greenheck commented that DOE did not propose to adopt the AMCA 214-
21 Section 7.3 provisions for appurtenances and has provided a
confusing stance on what is to be tested. Greenheck commented that
there are several appurtenances, and combinations of appurtenances,
available on fan products. Greenheck added that many appurtenances are
mutually exclusive and should not or cannot be tested together.
Greenheck further commented that appurtenances are generally intended
to aid the end customer in accommodating building limitations or
overall system design requirements and are not part of the basic fan
performance. As currently written, stated Greenheck, the DOE rulemaking
appears to require two-sample tests for each appurtenance and
appurtenance combination, which represents an additional, significant
testing burden for all manufacturers. Greenheck further provided an
example to illustrate the high number of appurtenances for a single
model, where with the combination of a two-sample test and wire-to-air
testing, appurtenances would lead to 6,336 tests for a fan series with
11 sizes. (Greenheck, No. 39 at pp. 2-3)
NEEA commented that the treatment of appurtenances in the
definition of a basic model is unclear in the current NOPR. In
addition, NEEA noted that in Section III.C.5 of the NOPR, DOE proposed
to adopt section 7.3 of AMCA 214-21. However, NEEA noted that DOE used
language inconsistent with section 7.3 of AMCA 214-21 and in the
proposed regulatory text included in Section VI, DOE provided text that
``replaces the provisions in section 7.3 of AMCA 214-21.'' NEEA
commented that DOE's current language has the potential of dramatically
increasing the number of basic models, as it does not clearly identify
how appurtenances impact a basic model. (NEEA, No. 36 at p. 3)
[[Page 27355]]
Loren Cook Company commented that there is a burden associated to
testing any appurtenances sold on a fan. Loren Cook added that it has
several products each with many sizes and have a dozen or more
accessories that could affect performance and would result in excessive
amount of testing required. (Public Meeting Transcript, No. 18 at pp.
65-66)
For fans and blowers other than air circulating fans, in view of
the substantially high number and combinations of appurtenances as
noted by AMCA, New York Blower, JCI and Greenheck, and to remain
consistent with the definitions of minimum testable configurations as
described in AMCA 214-21 \86\ as noted by AMCA, DOE requires testing in
accordance with section 7.3 of AMCA 214-21, which distinguishes between
appurtenances that improve or reduce performance. As such, DOE is no
longer replacing the provisions in Section 7.3 of AMCA 214-21. For
appurtenances that improve fan performance, which include, but are not
limited to inlet bells, diffusers, stators, or guide vanes, AMCA 214-21
specifies that these appurtenances should be included if always
supplied with the fan when distributed in commerce. For appurtenances
that reduce fan performance, which include, but are not limited to,
safety guards, dampers, filters, or weather hoods, AMCA 214-21 states
that if the appurtenance is always supplied with the fan when
distributed in commerce, then it shall be tested with the fan. If the
appurtenance is not always supplied with the fan when distributed in
commerce, it shall not be tested with the fan. To align with the
adopted definition of ``minimum testable configuration,'' DOE requires
testing in accordance with section 7.3 of AMCA 214-21. In addition, DOE
clarifies that its regulations would apply to the fan as distributed in
commerce and would not account for any potential additional
appurtenances added in the field. As noted by AMCA, such approach would
permit the preservation of historical data and reduces test burdens.
---------------------------------------------------------------------------
\86\ DOE is incorporating by reference AMCA 214-21 and relies on
the definitions included in Sections 3 of AMCA 214-21, including the
definition of minimum testable configuration as proposed in the July
2022 NOPR. See 87 FR 44194, 44257.
---------------------------------------------------------------------------
For air circulating fans, in line with the provisions in Section
6.3 of AMCA 230-23, DOE requires that any appurtenances sold with the
fan shall be included in the minimum testable configuration, as
proposed.
In addition, in the July 2022 NOPR, DOE noted that for air
circulating fans, the AMCA 230 committee was considering additional
provisions to include in the next version of AMCA 230 to describe what
should be considered as part of the test (i.e., the ``minimum testable
configuration''). The committee was considering the following: (1) If
sold with the fan, an on/off switch or speed control device would be
included in the minimum testable configuration. The power consumption
of the on/off switch or speed control device would be included in the
active and standby mode power measurements. (2) If multiple control
devices are sold with the fan, only the standard fan control device
would be used for testing. (3) Optional product features not related to
generating air movement would not be energized for the purpose of
testing. Optional product features not related to generating air
movement include, but are not limited to, misting kits, external
sensors not required to operate the fan, and communication devices not
required to operate the fan. 87 FR 44194, 44225.
For air circulating fans, in the July 2022 NOPR, DOE tentatively
determined that it is unlikely that additional features not related to
air movement would remain in the on-position unless intended by the
consumer. As such, requiring testing in their ``as-shipped''
configuration would not provide a more representative measure of energy
use for air circulating fans. DOE proposed to add clarification that
additional features not related to air movement be installed, but
either powered off or set at the lowest energy-consuming mode during
testing. Further, to avoid confusion as to which controller is used for
testing in the case where multiple advanced controllers are offered,
DOE proposed to add additional clarification to its specifications for
appurtenances. Specifically, DOE proposed to clarify that if the air
circulating fan is offered with a default controller, testing would be
conducted using the default controller. If the air circulating fan is
offered with multiple controllers, testing would be conducted using the
minimally functional controller (i.e., ``standard controller'').
Testing using the minimally functional controller is consistent with
the direction to test with additional features not energized during the
power consumption measurement. Controller functions other than the
minimal functions (i.e., the functions necessary to operate the air
circulating fan blades) are akin to additional features that do not
relate to the air circulating fan's ability to create airflow. This
proposed addition clarifies which controller to select. These proposals
were in line with the additional provisions considered by the AMCA 230
committee at the time. Id. at 87 FR 44225-44226.
DOE did not receive any comments on these specific proposals.
Since then, AMCA 230-23 has incorporated these provisions in
section 6.3. DOE is referencing the provisions in section 6.3 of AMCA
230-23.
12. Voltage, Phase, and Frequency
This section is only applicable to fans with a motor that are
tested wire-to-air, where the electrical power supplied to the fan
needs to be specified.
Regarding frequency, fans and blowers can be rated to operate at 50
or 60 Hz, be supplied by single-phase or multi-phase electricity, and
can operate at a single rated voltage (e.g., 115 V) or within one or
more rated voltage ranges, or a combination of both (e.g., 115/208-230
V). In the July 2022 NOPR, DOE stated that section 7.8 of AMCA 214-21
specifies that for fan electrical power measurement (when conducting a
wire-to-air test), the fan must be operated using a 60 Hz supply unless
that frequency conflicts with nameplate values. The voltage during the
test shall match the highest allowable value that corresponds with the
relevant nameplate. 87 FR 44194, 44226.
In the United States, 60 Hz frequency is the most representative,
and DOE tentatively determined that fans rated for operation with only
60 Hz power supply would be tested with 60 Hz electricity and that fans
capable of operating with 50 Hz and 60 Hz electricity would also be
tested with 60 Hz electricity. DOE tentatively determined that it does
not need to consider fans rated for operation with only 50 Hz power,
since these fans are not relevant in the U.S. market. Id.
Regarding the phase to select for testing, DOE proposed to clarify
which phase to use during the test as follows. DOE proposed to specify
to test fans and blowers, including circulating fans, rated for
operation with only a single- or multi-phase power supply with single-
or multi-phase electricity, respectively. For fans and blowers,
including circulating fans, capable of operating with single- and
multi-phase electricity, DOE proposed that such fans must be tested
using a multi-phase power supply, which is the most common power supply
for industrial and commercial equipment. Id.
Regarding the voltage to select for testing, DOE proposed to
clarify which voltage to use during the test as follows. For fans and
blowers other than air circulating fans, DOE proposed to retain the
provisions in section 7.8 of AMCA
[[Page 27356]]
214-21 to specify testing at the highest rated voltage and align with
existing industry standards. Id. For air circulating fans, DOE reviewed
the provisions related to the supply voltage in the ceiling fan test
procedure, which are also tested based on AMCA 230-15 (with errata).
Section 3.4.3 and 3.4.4 of 10 CFR part 430, appendix U. DOE proposed
the same provisions for air circulating fans that it uses for ceiling
fans, with additional language to distinguish how to select the supply
voltage for fans tested using single-phase and multi-phase electricity.
Specifically, DOE proposed that the supply voltage must be: (1) for air
circulating fans tested with single-phase electricity, the supply
voltage would be (a) 120 V if the air circulating fan's minimum rated
voltage is 120 V or the lowest rated voltage range contains 120 V, (b)
240 V if the air circulating fan's minimum rated voltage is 240 V or
the lowest rated voltage range contains 240 V, or (c) the air
circulating fan's minimum rated voltage (if a voltage range is not
given) or the mean of the lowest rated voltage range, in all other
cases; (2) for air circulating fans tested with multi-phase
electricity, the supply voltage would be (a) 240 V if the air
circulating fan's minimum rated voltage is 240 V or the lowest rated
voltage range contains 240 V, or (b) the air circulating fan's minimum
rated voltage (if a voltage range is not given) or the mean of the
lowest rated voltage range, in all other cases. Id.
ebm-papst stated that the electrical power supply (frequency,
phase, and voltage) are specified by the fan supplier. ebm-papst
commented that any surveillance testing for enforcement of a regulation
should be performed at the supplier-specified electrical conditions.
ebm-papst commented that DOE restrictions on the permitted power supply
would potentially limit the usability of fan performance data for
specific projects due the very diverse nature of the fan industry.
(ebm-papst, No. 31 at p. 10)
For fans supplied for use in the United States, AMCA advised that
the frequency, phase, and voltage be 60 Hz, 1- or 3-phase, and 110 VAC
or 230/460 VAC, respectively. AMCA added that the test procedure should
conform to U.S. standards for fans sold in the United States.
Additionally, AMCA stated that because these are the most prevalent
electrical properties of fans sold in the market, the test procedure
should be based on those properties. Additionally, AMCA stated support
for the adoption of section 7.8 of AMCA 214 and not ``consider[ing]
other options such as specifying a voltage for test similar to that
proposed . . . for air circulating fans.'' AMCA noted that doing
otherwise could negate historical fan data that was tested in
accordance with AMCA 214. (AMCA, No. 41 at p. 24)
New York Blower commented in support of testing at 60 Hz. New York
Blower commented that fans with application motors can be configured
regularly with 1- or 3-phase voltage configurations at a variety of
voltage levels. New York Blower stated that if the fan is rated and
offered for sale at a variety of motors that require different voltages
and phases, then it should be tested as offered. New York Blower added
that bare fans can be driven by a torque meter. (New York Blower, No.
33 at p. 15)
Morrison commented that it supports the use of voltage, phase, and
frequency for U.S.-targeted products be 110 VAC or 230/460 VAC, 60 Hz,
and 1- or 3-phase. (Morrison, No. 42 at p. 6)
Nidec requested clarity on the voltages to consider in the test
procedure. (Public Meeting Transcript, No. 18, at p. 56)
The frequency, voltage, and phase selected for testing can impact
the determination of the input power and in turn the determination of
the FEI or CFM/W metrics. Therefore, DOE specifies how manufacturers
must select the frequency, phase, and voltage when testing in
accordance with the DOE test procedure and cannot permit testing each
fan and at the supplier-specified electrical conditions.
Regarding the frequency, DOE requires that fans rated for operation
with only 60 Hz power supply be tested with 60 Hz electricity and that
fans capable of operating with 50 Hz and 60 Hz electricity also be
tested with 60 Hz electricity. DOE is not adopting provisions for fans
rated for operation with only 50 Hz power supply, as these are not
relevant to the U.S. market.
Regarding the phase to select for testing, DOE clarifies which
phase to use during the test as proposed in the July 2022 NOPR. DOE
requires testing fans and blowers, including circulating fans, rated
for operation with only a single- or multi-phase power supply with
single- or multi-phase electricity, respectively. For fans and blowers,
including circulating fans, capable of operating with single- and
multi-phase electricity, DOE requires testing using multi-phase power
supply, the most common power supply for industrial and commercial
equipment.
Regarding the voltage to select for testing, DOE specifies which
voltage to use during the test as proposed in the July 2022 NOPR. For
fans and blowers other than air circulating fans, DOE retains the
provisions in section 7.8 of AMCA 214-21. For air circulating fans, DOE
adopts the same provisions as proposed in the July 2022 NOPR, to
distinguish how to select the supply voltage for fans using single-
phase and multi-phase electricity. DOE's provisions related to voltage
are similar to those used for ceiling fans and DOE believes these
provide sufficient clarity on how to select the voltage for testing
based on the voltage(s) of the air circulating fan as rated by the
manufacturer.
13. Test Speeds for Air Circulating Fans
In the July 2022 NOPR, for single speed air circulating fans, DOE
proposed to require that testing be conducted at the single available
speed. For multi-speed fans with discrete operating speeds, and for
variable-speed fans with continuously adjustable speeds, while DOE
believed it is preferable to align the DOE test procedure with the
accepted industry test procedures--in this case AMCA 230--as much as
possible, DOE explained that it did not have data to determine the
typical field operating speed(s) of air circulating fans and DOE
tentatively determined that testing at each discrete speed (for multi-
speed fans) or at each of the five speeds currently specified in AMCA
230-15 (with errata), rather than only requiring testing at the maximum
speed, may provide a more holistic representation of an air circulating
fan's performance over a range of service levels, which may in turn
facilitate easier comparisons for consumers. In addition, DOE proposed
to clarify that for variable-speed air circulating fans with a minimum
speed that is greater than 20 percent of the maximum speed, the
performance data would be captured and reported in five speeds evenly
spaced throughout the speed range, including at minimum and maximum
speeds.\87\ 87 FR 44194, 44227.
---------------------------------------------------------------------------
\87\ If the fan's maximum speed is 1000 RPM and the fan's
minimum speed is 400 RPM, then the following speeds should be
reported: 400, 550, 700, 850, and 1000 where each speed is equally
spaced of 150 RPM or (1000-400)/4.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE added that it was considering several
alternative options for specifying the test speeds at which fans with
multiple or variable speeds should be tested, including testing a high
speed only, or testing in accordance with the speed requirements for
large diameter ceiling fans in section 3.5 of 10 CFR part 430, appendix
U, which specifies that testing must be conducted at maximum speed and
at 40-percent speed or the nearest
[[Page 27357]]
speed that is not less than 40-percent speed. DOE noted that regardless
of the proposed tested speeds, performance data at additional speeds
may be captured and reported to better define the shape of the fan
performance curve (for example, additional measurements at 20, 60, and
80 percent of maximum speed). Id.
AMCA commented that AMCA currently does not have usage data for air
circulating fans in the United States. AMCA noted that the AMCA 230
committee recommends rating air circulating fans at only maximum speed.
AMCA commented that some small air circulating fans are supplied with
solid-state controllers (SSC) for fan-speed reduction and recently,
direct-drive air circulating fans with variable-speed EC motors have
entered the market. However, AMCA commented that the current market for
air circulating fans is predominantly single speed fans. AMCA added
that there is no common number of available speeds (2, 3, 4, etc. speed
fans) and the discrete speeds vary greatly (~95 to 60 percent of
maximum speed). AMCA recommended that only the highest speed be used
for the air circulating fan metric because consumers will benefit from
comparing fans at a standardized condition and that using the highest
speed is the only equitable way to do this for air circulating fans.
AMCA stated that rating fans at different non-maximum speeds will cause
consumers to be confused and potentially purchase significantly less
efficient fans. AMCA provided an example comparison of a single speed
fan (Fan 1) and a variable speed model (Fan 2) where both fans are used
in agricultural applications and generate the same amount of airflow at
maximum speed and Fan 1 consumes half the power of Fan 2 at high speed.
AMCA commented that as currently defined in the NOPR, Fan 1 and Fan 2
would have the same proposed ACFEI rating of 1.01. (See Table III-11)
Table III-11--Air Circulating Fan Performance Comparison
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
% Max RPM....................... 36% 52% 68% 84% 100%
Airflow (CFM)................... 2,440 3,145 3,851 4,556 5,262
Fan 1 Power (W)................. .............. .............. .............. .............. 297.6
Fan 2 Power (W)................. 38.8 107.6 220 381.4 595.2
Fan 1 ACFEI (proposed).......... * * * * 1.01
Fan 2 ACFEI (proposed).......... 2.15 1.07 0.74 0.59 0.51
Fan 1 (CFM/W)**................. .............. .............. .............. .............. 17.68
Fan 2 (CFM/W)**................. 62.89 29.23 17.50 11.95 8.84
----------------------------------------------------------------------------------------------------------------
* Note: the AMCA comment included values at different speeds. However, for a single speed fan, only one speed is
applicable.
** DOE added the CFM/W row for additional comparison.
AMCA commented that since air circulating fan heads in agricultural
applications are often purchased to generate relatively high air speeds
to cool large mammals (cows require 200-400+ fpm of air speed for
cooling), the air circulating fans are very likely to run at higher
speeds for the majority of their operating hours. In this instance,
according to AMCA, the efficiency metric would mislead the consumer to
believe that the single speed fan would consume the same amount of
electricity as the highly inefficient variable speed fan. (AMCA, No. 41
at p. 26) AMCA added that similar to high-speed small diameter (HSSD)
ceiling fans, air circulating fan heads are typically either single
speed or do not have common discrete speeds, so speeds other than high
speed may not be well defined. Additionally, stated AMCA, there are no
data available to estimate a distribution of time spent at speeds other
than high speed for use in an efficiency metric. AMCA commented that
the operating speed(s) and time spent at each speed will vary greatly
based on the application and potentially on the local weather
conditions. Finally, commented AMCA, unlike ceiling fans where low
speed operation can be used for destratification, the only utility of
an air circulating fan is generating elevated air speed, which takes
place at higher fan speeds. Therefore, AMCA recommended that similar to
HSSD fans, DOE only rate air circulating fans at maximum speed. (AMCA,
No. 41 at pp. 25-26)
Big Ass Fan commented that an [air circulating] fan with an ACFEI
of 1 at full speed could have a ACFEI of 10 to 20 when the speed is
reduced to the 20 to 30 percent range. Big Ass Fan commented that such
approach would inflate the ACFEI metric such that a fan could have a
ACFEI of 1 at full speed and a weighted average ACFEI of 7. In
addition, Big Ass Fan commented that operating at 20 percent speed does
not provide any utility as these fans are primarily designed to create
air speed to increase the rate of heat loss off the human body, or off
of an animal. As such Big Ass fan stated that the ACFEI metric as
proposed would be rewarding to speeds that provide no utility and would
not represent how the product is used. (Public Meeting Transcript, No.
18 at p. 55)
DOE collected additional speed data on air circulating fan
performance data from the BESS certification database \88\ and observed
that over 80 percent of models are rated at high speed only. While DOE
cannot confirm if these fans are single speed, the data seems to
indicate that the market is predominantly single speed as stated by
AMCA. In addition, as noted by AMCA and Big Ass Fans, a weighted
average metric across different speeds may have unintended
consequences, inflate the ACFEI metric, and disproportionally favor
multi-and variable-speed fans, which would show significantly better
ratings even when performing relatively worse than a similar single
speed fan at the same airflow and maximum speed. In addition, the
latest version of AMCA 230-23 (section 7.2.4.1 of AMCA 230-23) was
revised to require testing at the highest speed only (maximum speed).
Therefore, at this time, DOE is requiring testing at maximum speed
only, which DOE believes is most representative of an average use cycle
and would not be unduly burdensome for manufacturers to conduct. DOE
notes that for multi- and variable-speed air circulating fans, section
7.2.4.1 of AMCA 230-23 provides that performance data at additional
speeds may be captured to better define the shape of the fan
performance curve (for example, additional measurements at 20, 60, and
80 percent of maximum speed). DOE adopts to reference these provisions
and allows optional representations at lower speeds as allowed in AMCA
230-23.
---------------------------------------------------------------------------
\88\ Additional speed data collected in September 2022 included
435 models of air circulating fans with the following information:
Manufacturer, Power Supply, Model Number, Style (i.e., basket, box,
panel, or tube), Size (in) (i.e., impeller diameter), Guard
configuration, Airflow (CFM), efficacy (CFM/W), Thrust (lbf), Input
power (kW), Thrust Efficiency ratio (lbf/kW), 5D Centerline Velocity
(fpm), and Speed (high, med, low, % of max). See bess.illinois.edu.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE noted that AMCA 214-21 has provisions to
[[Page 27358]]
calculate performance data at non-tested speeds based on wire-to-air
test results at different speeds. See section 6.2 of AMCA 214-21,
``Calculated Ratings Based on Wire to Air Testing,'' which references
section 8.2.3, ``Calculation to other speeds and densities for wire-to-
air testing'' and Annex G, ``Wire-to-Air Measurement--Calculation to
Other Speeds and Densities (Normative).'' For air circulating fans, DOE
tentatively determined that these sections do not apply because air
circulating fans have a more limited range of operating speeds and DOE
proposed to test at each speed where performance data is required. In
the July 2022 NOPR, DOE noted that AMCA 214-21 also includes an annex
that only applies to shaft-to-air tests and allows interpolating
performance between tested speeds (Annex E of AMCA 214-21). For air
circulating fans, DOE tentatively determined that these sections do not
apply because air circulating fans are tested wire-to-air. 87 FR 44194,
44227.
In response to the July 2022 NOPR, AMCA commented that for ACF,
only G.2.3 airflow and G.2.5.2 electrical power at zero static pressure
apply. (AMCA, No. 41 at p. 27) AMCA commented that Annex E is not
needed for air circulating fans because air circulating fans are tested
and sold inclusive of motors. Id.
As previously stated, DOE is no longer referencing AMCA 214-21 for
air circulating fans and DOE is not opting to reference sections 6.2 of
AMCA 214-21, which references section 8.2.3 and Annex G; or Annex E of
AMCA 214-21.
14. Run-In Requirements
In the July 2022 NOPR, DOE stated that section 7.4 of AMCA 214-21
specifies that all fans shall be run-in for not less than 15 minutes
prior to the commencement of data collection and that the AMCA 230
committee was considering similar provisions for air circulating fans.
DOE proposed that the minimum run-in requirement of 15 minutes for fans
and blowers be applied to air circulating fans. 87 FR 44194, 44235.
Since then, AMCA 230-23 became available and sections 7.1.3 and 7.3
of AMCA 230-23 include a minimum run-in requirement of 15 minutes.
New York Blower commented that the proposed run-in requirements
seem appropriate and are similar to current procedures and practices.
(New York Blower, No. 33 at p. 17)AMCA and Morrison recommended that
the minimum run-in time for any fan should be at least 15 minutes,
which is consistent with DOE's proposal. (AMCA, No. 41 at pp. 28-30;
Morrison, No. 42 at p. 7)
In this final rule, DOE is requiring that all fans shall be run-in
for no less than 15 minutes prior to the commencement of data
collection.
15. Determination of Equilibrium and Test Stability
As discussed in the July 2022 NOPR, both AMCA 210-16 and AMCA 230-
15 require that steady readings must be obtained prior to the start of
test; however, neither test standard provides specific variables with
associated tolerances within which equilibrium can be quantified. To
ensure repeatable and reproducible results from a test method, it is
necessary to specify consistent requirements for determining when a fan
is and is not at equilibrium before the commencement of testing. It is
also necessary to specify a duration over which equilibrium must be
established. 87 FR 44194, 44227-44228.
a. Fans and Blowers Other Than Air Circulating Fans
As discussed in the July 2022 NOPR, DOE reviewed the test chamber
and test equipment accuracy requirements listed in section 6 of AMCA
210-16 to determine equilibrium requirements for fans and blowers other
than air circulating fans. 87 FR 44194, 44229. DOE proposed that
calculations of ambient air density, and measurements of input power
(as measured by a reaction dynamometer, torque meter, calibrated motor,
or electrical meter), and fan speed would need to fall within the
tolerance window listed in Table III-12 prior to initiating the test.
Id. In DOE's proposal, input power stability would be required on a
single input power device. DOE proposed that fan system equilibrium
would need to be verified over at least 5 minutes, with measurements
for each variable recorded at a maximum of 5 seconds. Id.
Table III-12--Tolerance Requirements for Measured Variables To Establish
Stability for Fans and Blowers That are not Air Circulating Fans as
Proposed in the July 2022 NOPR
------------------------------------------------------------------------
Variable Equilibrium tolerance
------------------------------------------------------------------------
Ambient air density....................... 1 percent of
mean.
Input power by reaction dynamometer....... 4 percent of
mean.
Input power by torque meter............... 4 percent of
mean.
Input power by calibrated motor........... 4 percent of
mean.
Input power by electrical meter........... 2 percent of
mean or 1 W, whichever is
greater.
Fan speed................................. 1 percent of
mean or 1 rpm, whichever is
greater.
------------------------------------------------------------------------
In the July 2022 NOPR, DOE discussed that ISO 5801 includes more
stringent stability tolerance requirements for fan speed; however, DOE
stated that since it was proposing requirements for both fan speed and
input power, it was suggesting a less stringent tolerance on fan speed.
Id. DOE requested comment on its proposal for determining if a fan that
is not an air circulating fan has reached equilibrium prior to
initiating testing, on the minimum duration and maximum interval over
which equilibrium would need to be verified, and on which variables
proposed in Table III-12 that, if not stable prior to test, would have
the greatest impact on measured fan performance. 87 FR 44194, 44229.
During the public meeting associated with the July 2022 NOPR, Nidec
commented that motor test methods require [motor] temperature
stabilization and that the July 2022 NOPR did not discuss temperature
stabilization. (Public Meeting Transcript, No. 18, p. 57) In the July
2022 NOPR, DOE stated that section 7.4 of AMCA 214-21 specifies that
all fans shall be run-in for not less than 15 minutes prior to the
commencement of data collection. 87 FR 44194, 44235. As discussed in
section III.E.15, DOE is requiring that all fans shall be run-in for no
less than 15 minutes prior to the commencement of data collection. The
purpose of this requirement is to ensure the motor tested with the fan
is appropriately warmed up and stable. While DOE has not provided
specific temperature stabilization requirements for the motor, DOE
expects that laboratories will sufficiently run-in the motor to avoid
lengthy testing to demonstrate fan stability. ebm-papst commented that
AMCA 210 and ISO 5801 testing has not caused them concerns about
equilibrium. (ebm-papst, No. 31 at p. 11)
New York Blower commented that the signals being measured for
larger fans have inherent instability. (New York Blower, No. 33 at p.
12) New York Blower also commented that a 5-minute interval between
each test determination seems excessive,
[[Page 27359]]
particularly based on their experience of testing industrial fans;
however, they understand if this is necessary for air circulating fans.
(New York Blower, No. 33 at p. 16) In response, DOE notes that its
intent in the July 2022 NOPR was that a fan would be considered stable
if it met the proposed tolerance requirements over a 5-minute
``stability test'', not that each test would be 5 minutes in duration.
Robinson stated that the equilibrium requirements are reasonable;
however, they added that not all laboratories are temperature
controlled and therefore the density requirement may not be attainable
for the duration of the test. Robinson commented that specifying
equilibrium for density as it applies to centrifugal housed or radial
housed fans would create a need for laboratories to add climate control
systems or increase the sizes of their existing laboratories to
maintain a density equilibrium. If this is only meant as a measure of
starting a test that may be acceptable, but for the duration of a test
a 1 percent change in density is unlikely to be maintained particularly
as testing a fan will take several hours or span over more than one
day. (Robinson, No. 43 at p. 7) Additionally, Robinson commented that
they do not see a need for a tight restriction on speed variation if
the data can be corrected to a common condition. (Robinson, No. 43 at
p. 10) In response, DOE notes that the purpose of setting a tolerance
on fan speed is to ensure stability prior to testing, and prior to
correcting to a common condition.
Of the variables listed in Table III-12, calculated ambient air
density, which is a function of dry bulb temperature, wet bulb
temperature and barometric pressure, impacts the fan's test
environment. It is important to ensure that the lab environment is
stable, while fan stability is being assessed. Calculated air density
for fans and blowers that are not air circulating fans is determined
from the dry bulb temperature at plane 0 (Td0), the wet bulb
temperature at plane 0 (Tw0), and the barometric pressure,
where plane 0 is defined in Table 2 of AMCA 210-16 as the general test
area. Regarding Robinson's comment that it may be difficult to maintain
calculated air density within 1 percent of the mean over
the duration of the test, DOE clarifies that the air density tolerance
proposed in the July 2022 NOPR applies only to the determination of fan
stability and that section 6.2.4.1 of AMCA 210-16 includes temperature
and pressure measurement requirements when environmental conditions are
varying. DOE would not expect temperature, relative humidity, and
barometric pressure to vary outside of the ranges listed above over the
timeframe necessary to determine stability, even in a building without
climate control. However, DOE notes that since air density is used to
determine fan performance, air density must be captured during each
test run.
Greenheck recommended not including additional equilibrium or
stabilization procedures because once the dynamometer or calibrated
motor is initially warmed up, no additional benefit is gained by
waiting to stabilize. (Greenheck, No. 39 at . 6) To substantiate its
position, Greenheck provided example test data for housed centrifugal
fans at a constant rpm that showed no difference in brake horsepower
versus airflow when the test was completed with cold bearings, warmed
bearing or running each duty point for 5 minutes before taking the test
measurement. (Greenheck, No. 39 at p. 7, Figure 2) Greenheck also
provided a plot of energy use as a function of airflow for an axial fan
using a calibrated motor. (Greenheck, No. 39 at p. 8, Figure 3)
Although data values were not provided, Greenheck stated that all power
readings within the usable portion of the fan curve are within 1
percent whether the motor was warmed up and data collected, the motor
was warmed up and data was corrected to 1200 rpm, or the motor was
warmed up and data was taken after running for 5 minutes. (Greenheck,
No. 39 at p. 7, Figure 2)
Section 6.1.2 of AMCA 210-16 states that ``statistically stable
conditions shall be established before each determination'' and that
``trial observations shall be made until steady readings are
obtained.'' This section of AMCA 210-16 provides no provisions for
determining stable readings and provides no requirements for evaluating
if conditions are statistically stable. Comments from AMCA and fan and
blower manufacturers suggest that there are multiple ways a
manufacturer may verify that a fan under test is considered stable
prior to testing. Based on the data provided by Greenheck, ensuring
that the dynamometer or calibrated motor is warmed up may be sufficient
to ensure fan stability during test. However, DOE notes that it is
required to ensure that its test procedures are repeatable--ensuring
repeatability becomes especially important if enforcement testing is
warranted to evaluate compliance with any potential energy efficiency
standards.
AMCA and Morrison stated that there is a need to ensure both
equilibrium prior to testing and stability during testing, and that DOE
did not sufficiently differentiate between the two. (AMCA No. 41 at pp.
28-30; Morrison, No. 42 at p. 7) In the following sections, DOE
discusses the test stability requirements that it is adopting for fans
and blowers that are not air circulating fans. DOE notes that the
purpose of these stability provisions is to clarify section 6 of AMCA
210-16 to improve overall repeatability and reproducibility of the test
procedure. DOE does not expect these requirements to obsolete
historical testing completed by the industry.
In its comments, AMCA recommended using the same approach for
determining stability of air circulating fans and fans and blowers that
are not air circulating fans. Specifically, AMCA stated that all
measured values will fluctuate over time, and recommended averaging
these values over a 120-second duration to ensure test repeatability.
(AMCA, No. 41 at p. 28) AMCA also commented that these fluctuations may
trend upward or downward, or may fluctuate around an average value, and
provided two examples, one where measured power increases with time
over a measurement interval of 300 seconds, and the second where
measured power varies, but does not increase over the same measurement
interval. (AMCA, No. 41 at pp. 28-29) AMCA further recommended that
instrument filtering should be used to minimize measurement
fluctuations and provided examples of how a measurement instrument
could be set up to do this. (AMCA, No. 41 at p. 29) AMCA also suggested
that fan speed stability would be established when the averaged results
from two successive readings differ by no more than 1 percent or 1 rpm,
whichever is greater, and that electrical input power stability would
be established when the averaged results from two successive readings
differ by no more than 1 percent or 1 watt, whichever is greater. Id.
DOE interprets AMCA's comments to suggest that filtered fan speed and
input power or torque measurements should be averaged over 120-second
intervals and that the average over this interval should be compared to
previous 120-second intervals to determine whether these variables meet
the tolerance requirements discussed above. (See AMCA, No. 41 at p. 29,
recommendation 3) But AMCA also stated that fan stability occurs much
more quickly for fans and blowers that are not air circulating fans
since they are tested against pressure and in a duct or in a chamber.
(AMCA, No. 41 at p. 29) Additionally, for fans and blowers that
[[Page 27360]]
are not air circulating fans, AMCA suggested a different time interval
for determining the test measurement value, specifically taking the
average over a 15 second interval, but increasing the averaging
duration to 60 seconds if individual measurements fluctuate by more
than 2 percent of the average over the 15-second interval.
(AMCA, No. 41 at p. 30) For testing, Morrison Products suggested a
similar approach, but with shorter time intervals, specifically, test
measurement values would be determined by averaging over 10 seconds;
however, if individual measurements fluctuate by more than 2 percent of the mean, the duration over which the average should
be taken would increase to 30 seconds. (Morrison Products, No. 47 at p.
7)
DOE agrees with AMCA that determination of fan stability should be
a comparison of averages over successive time durations. However,
because DOE expects that fans and blowers that are not air circulating
fans will reach stability more quickly than air circulating fans, it
believes determining average input power and fan speed over 120-second
intervals may filter the data too much and may unnecessarily increase
the time to confirm equilibrium. Instead, DOE has determined that
ensuring the average fan speed and average input power over successive
60-second data intervals (i.e., average of data points collected at
least every 5 seconds over 60 seconds) are within the tolerances listed
in Table III-12 is appropriate for determining fan speed and input
power equilibrium. The 60-second data interval is consistent with the
interval recommended by AMCA as a secondary option if filtered
measurements fluctuate by more than 2 percent over a 15-
second test interval. (AMCA, No. 41 at p. 30) While AMCA's suggestion
was specific for testing, DOE believes that a consistent data
collection interval for both equilibrium determination and testing
reduces the complexity of the test procedure and reduces test procedure
burden since the last sampling interval for determining equilibrium
interval may be used as a test measurement.
In its comments, AMCA provided a figure showing input power
trending upward over a 300-second measurement interval. (AMCA, No. 41
at p. 29, Figure 7) DOE understands this figure to suggest that
comparing average values between successive data collection intervals
may not capture instances where fan speed or input power are
consistently trending upward or downward over time. Upward or downward
trends in fan speed or input power over successive test intervals
indicate that the fan system has not reached stability and that
stability data must be collected over additional 60-second time
intervals until data within the measured time intervals are no longer
consistently increasing or decreasing. Comparing the slope of the
individual data within each time interval, in addition to ensuring
required tolerances are met, provides information on whether the
measured value is stable, or consistently increasing or decreasing over
time. For example, a positive slope calculated for three consecutive
time intervals indicates a consistent upward trend in the measured
variable suggesting that the fan has not reached stability and
additional intervals must be run until a negative slope is achieved. As
a second example, if a positive, negative, and positive slope are
determined for fan speed and input power over three consecutive
intervals, these variables are likely stable.
As such, DOE has determined to add further specificity to the
stability requirements outlined in section 6.1.2 of AMCA 210-16.
Specifically, stability will be evaluated and confirmed over at least
three 60-second data collection intervals. DOE believes that at least
three data collection intervals are necessary to ensure that slope is
not consistently increasing or decreasing for each successive test
duration. Fan speed and input power shall be monitored at least every 5
seconds over each 60-second data collection interval. The following two
requirements must be met for a fan to be considered stable and for
testing to commence:
(1) The average of fan speed from one data collection interval to
the next must be within 1 percent or 1 rpm, whichever is
greater; and the average input power by reaction dynamometer, torque
meter or calibrated motor must be 4 percent, or the average
input power by electrical meter must be 2 percent of the
mean or 1 watt, whichever is greater. These values are consistent with
those proposed in the July 2022 NOPR; however, the interval over which
average speed and average input power is determined, and the comparison
between these intervals has been further clarified.
(2) The slope of fan speed and the slope of fan input power over 60
seconds from one data collection interval to the next shall not be
trending upward or trending downward. Specifically, if the slope of 3
or more successive data collection intervals are all positive or all
negative, additional data collection intervals must be run until a
negative or positive slope, respectively, is achieved.
For testing (i.e., after equilibrium has been verified), Morrison
recommended sampling and statistically averaging test measurements over
10 seconds and that if filtered measurements fluctuate by more than 2
percent of the average value, the averaging time shall be increased to
30 seconds. (Morrison, No. 42 at p. 7) AMCA, as discussed previously,
recommended statistically averaging test measurements over 15 seconds
and if filtered measurements fluctuate by more than 2 percent of the
average value, the averaging time would be increased to 60 seconds.
(AMCA, No. 41 at p. 29-30)
First, DOE clarifies that the tolerances specified in Table III-12,
excluding the air density tolerance, should be maintained throughout
the test. Second, average values from two successive 60-second sampling
intervals meet the tolerance requirements specified in Table III-12
(excluding air density). DOE expects that maintaining the same data
collection requirements for equilibrium determination and testing
(i.e., 60 seconds) will simplify the test and ultimately reduce test
burden, since the last equilibrium measurement could be used as a valid
test point. However, DOE also recognizes that laboratories may be able
to achieve the specified tolerance on fan speed and input power over a
shorter time interval, as suggested by Morrison. Therefore, in this
final rule, DOE is specifying only that the sampling interval to
determine average test values should not exceed 60 seconds, consistent
with the sampling interval used to determine equilibrium.
Regarding AMCA's comment on data filtering, or damping, DOE
recognizes that data filtering helps reduce noise or measurement
fluctuation. DOE's requirement that data taken every 5 seconds must be
averaged over a 60-second duration effectively filters the data with a
time constant of 5 seconds.
b. Air Circulating Fans
In the July 2022 NOPR, DOE discussed the equilibrium options
considered by the AMCA 230 committee. At the time, the committee was
considering choosing three or four of the following values to determine
equilibrium: fan speed, system input power, barometric pressure, and
load differential. The committee was also considering that these
variables would need to meet a specified tolerance after at least 5
minutes of the fan running, with measurements taken at least every 5
seconds. 87 FR 44194, 44228.
Furthermore, DOE had tentatively determined that the ambient air
density, extraneous airflow (i.e., test room ventilation), system input
voltage,
[[Page 27361]]
system input current, system input power, fan speed, load, and load
differential would impact test results. Id. Therefore, DOE proposed
that measurements of these values would need to fall within a specified
tolerance window listed in Table III-13 prior to initiating a test for
air circulating fans. Id. DOE also proposed that measurements for each
of the variables would be taken at least every 5 seconds over at least
5 minutes, providing a minimum of 60 data points from which equilibrium
can be verified. Id.
Table III-13--Tolerance Requirements for Measured Variables To Establish
Stability for Air Circulating Fans as Proposed in the July 2022 NOPR
------------------------------------------------------------------------
Variable Equilibrium tolerance
------------------------------------------------------------------------
Calculated air density.................... 1 percent of
mean.
System input voltage...................... 2 percent of
mean.
System input current...................... 2 percent of
mean.
System input power........................ 2 percent of
mean or 1 W, whichever is
greater.
Fan speed................................. 1 percent of
mean or 1 rpm, whichever is
greater.
Load...................................... 1 percent of
mean.
Load differential......................... 1 percent of
mean.
------------------------------------------------------------------------
DOE proposed that air density, as determined from dry bulb
temperature, dew point, and barometric pressure measured over at least
5 minutes, would remain within one percent of the mean air density to
establish equilibrium prior to fan testing. Id. The system input
voltage, system input current, system input power, load, and load
differential tolerances for evaluating equilibrium that DOE proposed
were two times the equipment accuracy tolerances specified in AMCA 230-
15 and identical to those discussed by the AMCA 230 committee working
group at the time. Id. Additionally, DOE proposed that fan speed would
be within 1 percent of the mean rpm or 1 rpm, whichever is
highest over at least a 5-minute duration to establish equilibrium
prior to testing. Id.
Furthermore, in the July 2022 NOPR, DOE discussed possibly
prioritizing the variables such that equilibrium must always be
demonstrated for a specific number of the highest priority variables.
Id. Alternately, DOE discussed possibly specifying a subset of the
variables proposed, similar to what had been discussed by the AMCA 230
committee at the time. Id.
DOE requested comment on its proposal for determining that an air
circulating fan has reached equilibrium prior to initiating testing, on
the minimum duration and maximum interval over which equilibrium would
need to be verified, and on the variables it proposed. 87 FR 44194,
44228-44229.
As discussed, AMCA recommended using the same approach for
determining stability of air circulating fans and fans and blowers that
are not air circulating fans and AMCA's comments are summarized in the
previous section. For air circulating fans, AMCA stated that the AMCA
230 committee proposed the following requirements for equilibrium that
will be included in the next edition of AMCA 230: readings shall be
recorded when both speed and electrical power have stabilized; readings
shall be recorded at least 15 minutes after start-up; the averaged
results from two successive readings of electrical input power shall
differ by not more than 1 percent or 1 watt, whichever is greater; and
the averaged results from two successive readings of fan speed shall
differ by not more than 1 percent or 1 rpm, whichever is greater.
(AMCA, No. 41 at p. 28, 30)
Greenheck recommended that DOE adopt the run-in period and
filtering methodology in the latest revision of AMCA 230 and that DOE
handle air circulating fans in a separate rulemaking. (Greenheck, No.
39 at p. 8)
In the July 2022 NOPR, DOE stated that should the revised version
of AMCA 230 publish prior to the publication of any DOE test procedure
final rule, DOE intends to revise its test procedure provisions in line
with the latest AMCA 230 standard, provided the updates to the AMCA 230
standard are related to topics that DOE has discussed and for which DOE
solicited comments. 87 FR 44194, 44228. Sections 7.1 and 7.3 of AMCA
230-23 include provisions for run-in and determination of fan stability
prior to test, specifically:
(1) Run-in shall be conducted for no less than 15 minutes prior to
the commencement of data collection;
(2) Ambient conditions shall be measured prior to startup and
throughout the test, as specified;
(3) Load differential, measured electrical input power and fan
speed measurements shall be averaged for a minimum of 120 seconds;
(4) Measured electrical input power stability is established when
the averaged results from two successive readings differ by not more
than 1 percent or 1 watt, whichever is greater; and
(5) Fan speed stability is established when the averaged results
from two successive readings differ by not more than 1 percent or 1
rpm, whichever is greater.
Based on its review of AMCA 230-23, review of the comments received
to the July 2022 NOPR, and additional evaluation of DOE test data for
air circulating fans, DOE is generally adopting the fan stability
provisions in AMCA 230-23, with additional clarification, as discussed
below.
Regarding the determination of ambient conditions, DOE notes that
AMCA 230-23 does not provide additional specifications for determining
ambient conditions. Of the variables listed in Table III-13, input
voltage and room air density, which is a function of dry bulb
temperature, wet bulb temperature and barometric pressure, impact the
fan's test environment. It is important to ensure that environmental
stability is achieved to minimize changes that impact fan performance,
and that stability is maintained during the test to ensure test
repeatability. DOE proposed in the July 2022 NOPR that calculated air
density must remain within 1 percent of the mean and input
voltage must remain within 2 percent of the mean over a
period of 5 minutes with data collected at least every 5 seconds. 87 FR
44194, 44228. DOE received no comments from stakeholders regarding
stability determination or proposed tolerance criteria for either input
voltage or room air density. Therefore, DOE is adopting the equilibrium
tolerance criteria for input voltage and calculated air density as
proposed in the July 2022 NOPR. However, based on comments received
regarding determining fan stability (i.e., fan speed and load
differential) and the language in AMCA 230-23, DOE is instead requiring
that input voltage and room air density must meet the specified
tolerance requirements over the full duration of a test, including the
time it takes to demonstrate fan stability. While DOE proposed that
determining equilibrium over at least 5 minutes, DOE recognizes that
achieving equilibrium and capturing test data will vary depending on
the fan, and has therefore opted to not specify a minimum time
requirement for data capture. Finally, as discussed for fans and
blowers that are not air circulating fans, since air circulating fans
may be tested in facilities without climate control, ambient condition
data collection may start after the run-in period has been completed,
but before commencement of stability testing. In summary, this final
rule specifies that input voltage shall be captured at least every 5
seconds and shall not vary by more than 2 percent over the
duration of each test (including stability determination) and
calculated air
[[Page 27362]]
density shall not vary by more than 1 percent over the
duration of each test (including stability determination).
AMCA 230-23 specifies that stability must be established for
electrical input power and fan speed; however, DOE notes that section
7.2 of AMCA 230-23 requires reporting of load differential. Since
measurement of load differential is a required value, and used in later
calculations, DOE has determined that stability must also be
demonstrated for load differential, in addition to electrical input
power and fan speed. DOE notes that it proposed a tolerance of 1 percent of the mean for load differential in the July 2022
NOPR. 87 FR 44194, 44228.
While AMCA's comments to the July 2022 NOPR are consistent with the
language in AMCA 230-23, AMCA's comments additionally suggest that
comparing average values between successive data collection intervals
may not capture an upward or downward trend in fan speed, input power,
or load differential. (AMCA, No. 41 at p. 29, Figure 7) A lab may
observe an upward or downward trend in these variables over successive
data collection intervals if the fan has not been run-in for enough
time and/or is not at equilibrium.
To account for continuous upward or downward trends in slope over
multiple 120-second measurement intervals, and to address AMCA's
comment, DOE is adding further specificity to the stability
requirements outlined in section 7.3 of AMCA 230-23. Specifically,
stability will be evaluated and confirmed over at least three 120-
second data collection intervals. The 120-second data collection
interval is consistent with the provisions in section 7.3 of AMCA 230-
23 for determining fan stability. However, AMCA 230-23 and AMCA's
comments to the July 2022 NOPR do not recommend a minimum number of
data collection intervals for determining stability. DOE believes that
at least three data collection intervals are necessary to ensure a mix
of positive and negative slopes calculated for the data collected over
successive 120-second intervals. If the slope for each of three
intervals either all increase or all decrease, the variable being
measured is trending up or trending down, respectively, and the fan is
not at equilibrium (see similar discussion in the previous section for
fans and blowers that are not air circulating fans). While more than a
minimum of three data collection intervals would provide greater
assurance that fan speed, input power, and load are stable, DOE
selected a minimum of three test intervals to minimize test burden,
while still ensuring that a laboratory can validate that slopes are not
consistently positive or negative. Additionally, DOE expects that if a
fan is appropriately run-in prior to testing, laboratories should be
able to demonstrate speed, input power and load stability with the
minimum of three test intervals. Fan speed, input power, and load
differential shall be monitored at least every 5 seconds over each 120-
second data collection interval. The following two requirements must be
met for a fan to be considered stable and for testing to commence:
(1) The average of fan speed from one data collection interval to
the next must be within 1 percent or 1 rpm, whichever is
greater; the average fan input power from one data collection interval
to the next must be 1 percent or 1 watt, whichever is
greater; and the average load differential from one data collection
interval to the next must be 1 percent. The tolerance
requirements for fan speed and load differential are the same as those
proposed in the July 2022 NOPR (see Table III-13); however, DOE has
tightened its tolerance criteria for fan input power from 2
percent of the mean or 1 W, whichever is greater, to 1
percent of the mean or 1 W, whichever is greater, to be consistent with
section 7.3 of AMCA 230-23.
(2) The slope of fan speed, input power, and load differential over
120 seconds from one data collection interval to the next shall not be
monotonic. Specifically, if the slope of 3 or more successive data
collection intervals are all positive or all negative, additional data
collection intervals must be run until a negative or positive slope,
respectively, is achieved.
16. Test Figures for Air Circulating Fans
In the July 2022 NOPR, DOE noted that AMCA 230-15 (with errata)
describes the test set-up that can be used to test various categories
of air circulating fans and specifies that air circulating fan heads
and table fans, which correspond to unhoused ACFHs, must be tested
according to test figures 2A, 2B1, and 2B2. AMCA 230-15 (with errata)
and also specifies that box fans and personnel coolers, which are both
housed ACFHs, must be tested using test figures 3A and 3B. DOE noted
that the AMCA 230 committee reviewed the existing text figures and was
considering revising the allowable test figures to reflect that housed
air circulating fans could also be tested using test figures 2A, 2B1,
and 2B2, and unhoused air circulating fans would be tested using
figures 3A and 3B. 87 FR 44194, 44229.
In the July 2022 NOPR, DOE tentatively determined that test figures
2A, 2B1, 2B2, 3A and 3B are appropriate for all air circulating fans.
As such, DOE proposed to specify that any test figures that are
specified in AMCA 230-15 (with errata) can be used for testing air
circulating fans. Id.
Since then, AMCA 230-23 became available and specifies that test
figures 2A, 2B1, 2B2, 3A and 3B \89\ are appropriate for all air
circulating fan in section 6.1 of AMCA 230-23.
---------------------------------------------------------------------------
\89\ In AMCA 230-23. These figures were re-numbered 10.2A,
20.2B1, 10.2B2, 10.3A and 10.3B
---------------------------------------------------------------------------
AMCA commented that AMCA 230-23 will include slight refinement of
the test figures from the 2015 version. Nevertheless, stated AMCA, each
test figure is applicable to the fans in the scope of AMCA 230, which
means that figures 2A, 2B1, 2B2, 3A, and 3B are applicable to all air
circulating fans. (AMCA, No. 41 at p. 27)
As proposed, DOE specifies that any test figures specified in AMCA
230-23 can be used for testing air circulating fans.
17. Location of External Airflow Measurement
In the July 2022 NOPR, DOE noted that section 8.1.2 of AMCA 230-15
(with errata) specifies that the air velocity in the test room, not
generated by the test air circulating fan, shall not exceed 0.25 m/s
(50 fpm) prior to, during, and after the test. Velocity measurements
shall be taken immediately before and immediately after the test to
ensure that this condition is met. In addition, AMCA 230-15 (with
errata) specifies the location of the extraneous airflow measurement
shall be directly under the center of the fan at an elevation of 1701.8
mm (67 in.) above the floor. DOE noted that this provision is only
applicable to fans tested according to Figure 1 of AMCA 230-15 (with
errata) and that there is no location specified for extraneous airflow
measurement for fans tested according to Figures 2A, 2B1, 2B2, 3A and
3B. 87 FR 44194, 44234-44235.
In the July 2022 NOPR, DOE noted that the AMCA committee was
considering adding the following provisions to specify the location of
the extraneous airflow measurement and to move these provisions from
section 8.1.2 of AMCA 230-15 (with errata) into each of the figures.
For Figure 1 of AMCA 230-15, the location of extraneous airflow
measurement would be directly under the center of the fan at an
elevation of 1.7m (67 in.) above the floor. For figures 2A, 2B1, 2B2,
3A and 3B, the location of extraneous airflow measurement should be at
the center of
[[Page 27363]]
the fan at a distance of 1.5m (5 ft) downstream of the fan impeller.
DOE agreed that these additional specifications were necessary to
ensure test procedure repeatability, and therefore proposed to add
these additional provisions as considered by the AMCA 230 committee. 87
FR 44194, 44235.
AMCA commented that it supports the proposed location, adding that
positions to measure extraneous airflow were added to AMCA 230 toward
its revision. AMCA commented that the positions are the same as noted
in the NOPR. (AMCA, No. 41 at p. 28)
Since publication of the July 2022 NOPR, the test figures of AMCA
230-23 have been updated to specify the positions to measure extraneous
airflow as proposed. In this final rule, DOE is directly referencing
the test figures in AMCA 230-23 which include the location of the
extraneous airflow measurement as proposed.
18. Transducer Type Barometer
In the July 2022 NOPR, DOE noted that section 6.5.2.1 of AMCA 230-
15 (with errata) specifies that transducer type barometers shall be
calibrated for each test. DOE stated that the AMCA 230 committee was
considering removing this requirement from the revised version. DOE
noted that it was also considering not including this requirement as it
may be sufficient to require that the barometer be calibrated against a
mercury column barometer with a calibration that is traceable to
National Institute of Standards and Technology (``NIST'') or other
national physical measures recognized as equivalent by NIST, without
having to repeat calibration before each test. 87 FR 44194, 44235.
AMCA commented that calibration of transducer-type barometers for
each test should be removed. AMCA commented that mercury-column
barometers are discouraged and have often been removed from labs for
safety reasons, but that transducers are very stable and are calibrated
annually. AMCA commented that the AMCA 230 technical committee proposed
the following change to barometer calibration, which will be included
in section 6.5.2.1 ``Calibration'' of the 2022 edition of AMCA 230:
``barometers shall be calibrated and calibration traceable to NIST or
other national physical measures recognized as equivalent by NIST.
Barometers shall be maintained in good condition. All equipment used to
measure psychometric data shall be calibrated with uncertainties by an
ISO 17025 accredited calibration laboratory.'' (AMCA, No. 41 at p. 30)
Robinson commented that it does not recommend adding a requirement
to calibrate transducer-type barometers for each test. (Robinson, No.
43 at p. 10)
Since publication of the July 2022 NOPR, section 5.5.2.1 of AMCA
230-23 removed the requirement for calibration of transducer-type
barometers for each test. As noted by AMCA, it is sufficient to require
that the barometer be calibrated with a calibration that is traceable
to National Institute of Standards and Technology (``NIST'') or other
national physical measures recognized as equivalent by NIST, without
having to repeat calibration before each test. DOE adopts to reference
the provisions in section 5.5.2.1 of AMCA 230-23, and to not require
calibration of transducer-type barometers for each test as recommended
by Robinson.
19. Reference Fan Electric Input Power Calculation for Air Circulating
Fans
In the July 2022 NOPR, DOE proposed to rely on an FEI metric for
air circulating fans. 87 FR 44194, 44237-44238. Section 4 of AMCA 214-
21defines the FEI as the fan electrical input power of a reference fan
(FEPref) divided by the fan electrical input power of the
fan being rated at the same flow and total pressure conditions
(FEPact). Similar to how the FEPref of fans and
blowers other than air circulating fans is calculated, DOE proposed to
calculate the FEPref for air circulating fans based on:
A reference fan shaft input power equation, used to
calculate the reference fan shaft input power at a given duty point.
This equation relies on a flow constant (Q0) and a pressure
constant (P0), which represent how efficiency varies as a
function of flow and pressure and an efficiency target, which was set
to represent a market reference efficiency fan;
A reference fan transmission efficiency equation, which
calculates the reference fan transmission as a function of the
reference shaft input power and represents a typical belt drive. See
section 5.2 of AMCA 214-21; and
A reference motor equation as described in section III.E.1
of this document.
DOE collected air circulating fan performance data from the BESS
certification database \90\ and performed regression analyses to
determine the appropriate flow, pressure, and efficiency target
constants for air circulating fans. DOE proposed to rely on the
following constants: Q0 = 3,210 CFM (rounded to the nearest
10); P0 = 0 in.wg; and an efficiency target of 0.38 (38
percent). 87 FR 44194, 44231-44234.
---------------------------------------------------------------------------
\90\ Data collected on March 22, 2022, included 507 models of
air circulating fans with the following information: Manufacturer,
Power Supply, Model Number, Style (i.e., basket, box, panel, or
tube), Size (in) (i.e., impeller diameter), Guard configuration,
Airflow (CFM), efficacy (CFM/W), Thrust (lbf), Input power (kW),
Thrust Efficiency ratio (lbf/kW), 5D Centerline Velocity (fpm). See
bess.illinois.edu.
---------------------------------------------------------------------------
In addition, DOE noted that it was considering using the term ``Air
Circulating Fan FEI'' or ``ACFEI'' to differentiate the proposed FEI
for air circulating fans from the FEI as it applies to fans and blowers
that are not air circulating fans and from the CFEI as it applies to
ceiling fans. 87 FR 44194, 44238
As noted in Section III.G of this document, DOE is not adopting the
FEI or ACFEI as the metric for air circulating fans. Therefore, DOE is
not opting to specify a calculation of FEPref for air
circulating fans. Comments received on the air circulating fan FEI also
relate to the metrics and are discussed in Section III.G of this
document.
20. Rounding
As discussed in the July 2022 NOPR, AMCA 214-21 provides a method
for calculating fan performance using the FEI metric; however, AMCA
214-21 does not provide normative rounding requirements for FEI. 87 FR
44194, 44234. DOE also discussed that it would consider referencing any
rounding requirements in the updated version of AMCA 230, if those
requirements were consistent with the rounding provisions that DOE
proposed and solicited comments on in the July 2022 NOPR.\91\ Id. DOE
received no comments regarding standardization of rounding with the
newest version of AMCA 230. DOE notes that AMCA 230-23 provides
rounding provisions for blade span and tip speed but does not include
rounding provisions in Section 8, calculations. While not discussed in
the July 2022 NOPR, DOE notes that AMCA 230-15
[[Page 27364]]
also does not provide rounding requirements.
---------------------------------------------------------------------------
\91\ There is an error in section III.D.18 (Rounding) in the
July 2022 NOPR. In the following sentence, it should have stated
``reporting'' instead of appurtenances, ``Should the revised version
of AMCA 230 publish prior to the publication of any DOE test
procedure final rule, DOE intends, after considering stakeholder
feedback received in response to the proposals in this document, to
revise the provisions related to appurtenances in line with the
latest AMCA 230 standard, provided the updates in this standard are
consistent with the provisions DOE is proposing in this NOPR, or the
updates are related to topics that DOE has discussed and for which
DOE has solicited comments to in this NOPR. Since the section title
is ``rounding'', DOE has determined that, despite the error, and
given that DOE received no comments the context of this sentence is
clear.
---------------------------------------------------------------------------
FEI is specified to the hundredths place in section 6.5.3.1.3 of
ASHRAE 90.1-2019 (Fan Efficiency). Additionally, the DOE energy
conservation standard for large diameter ceiling fans is the Ceiling
Fan Energy Index (``CFEI''), where the CFEI metric is calculated
according to AMCA 208-18, is specified to the hundredths place (i.e.,
CFEI must be greater than or equal to 1.00 at high speed and 1.31 at 40
percent speed, or the nearest speed that is not less than 40 percent
speed). 10 CFR 430.32.(s)(2)(ii). Additionally, Annex I of AMCA 214-21
(informative) specifies rounding the FEI to the hundredth place.
Therefore, in the July 2022 NOPR, DOE proposed rounding represented
values of FEI to the hundredths place. Id. For consistency, DOE also
proposed that represented values for FEP would be rounded to the
hundredths place. Id.
How inputs to the calculation of FEI are rounded can impact the
represented FEI (or FEP value). DOE reviewed the provisions related to
rounding in the ceiling fans test procedure, which states that all
measurements should be recorded at the resolution of the test
instrumentation and that calculations shall be rounded to the number of
significant digits present at the resolution of the test
instrumentation. Section 3.1.1 of 10 CFR part 430, appendix U; 87 FR
44194, 44234.
In the July 2022 NOPR, DOE tentatively concluded that the rounding
provisions in section 3.1.1 of 10 CFR part 430, appendix U are
reasonable and that recording measurements at the resolution of the
test instrumentation would provide sufficient significant digits for
accurately calculating representative values of FEI and FEP. Id.
Therefore, DOE proposed that all measurements would be recorded at the
resolution of the test instrumentation and that calculations would be
rounded to the number of significant digits present at the resolution
of the test instrumentation. Id.
ebm-papst, New York Blower, AMCA, and Morrison agreed that rounding
FEI to the hundredths place is reasonable. (ebm-papst, No. 31 at p. 11;
New York Blower, No. 33 at p. 17, AMCA, No. 41 at p. 28; Morrison, No.
42 at p. 6). Additionally, New York Blower, AMCA and Morrison supported
DOE's to round FEP to the nearest hundredth of a kW. (New York Blower,
No. 33 at p. 17, AMCA, No. 41 at p. 28; Morrison, No. 42 at p. 6) AMCA
and Morrison did, however, suggest that if the FEP is less than 1 kW,
the value should be rounded to the nearest thousandth of a kW. (AMCA,
No. 41 at p. 28; Morrison, No. 42 at p. 6) DOE received no comment on
measurements being recorded at the resolution of the test instrument
and calculations being rounded to the number of significant digits
present at the resolution of the test instrument.
DOE is adopting the requirement to round the FEI to the nearest
hundredths place. DOE considered stakeholder feedback on the rounding
requirements for FEP and is specifying that FEP should be rounded to
three significant digits. Therefore, if FEP is greater than 1 kW, the
value would be rounded to the nearest hundredth of a kW and if the FEP
is less than 1 kW, the value would be rounded to the nearest thousandth
of a kW. DOE is additionally specifying that all measurements shall be
recorded at the resolution of the test instrument and that calculations
shall be rounded to the number of significant digits present at the
resolution of the test instrument, consistent with its proposal in the
July 2022 NOPR.
As discussed in detail in section III.G of this document, DOE is
adopting an efficacy metric, reported in CFM/W, for air circulating
fans. Although DOE discussed the possibility of adopting a CFM/W metric
for air circulating fans in the July 2022 NOPR (87 FR 44194, 44234),
DOE did not discuss or propose any rounding requirements for this
metric. As such, DOE expects to propose rounding provisions for air
circulating fans in a future certification rule.
F. Distinguishing Between Fans and Blowers and Air Circulating Fans
In the July 2022 NOPR, DOE noted that some manufacturers offer the
same fan model with different mounting configurations. Depending on the
mounting configuration, the same fan could either meet the definition
of a fan tested per AMCA 210-15 or meet the definition of an air
circulating fan and be tested per AMCA 230-15. DOE identified that air
circulating fans with housing (i.e., axial panel air circulating fans
and box fans) can also be distributed in commerce as with brackets for
mounting through a wall, ceiling, or other structure that separates the
fan's inlet from its outlet and marketed as ``exhaust fans.'' In this
case, DOE tentatively concluded these fans would be tested per AMCA
210-16 as they would meet the definition of an axial panel fan. DOE
added that manufacturers who distribute these fans in commerce in both
configurations and market the fans both for air circulation and exhaust
applications typically test the fan using both AMCA 230-15 (with
errata) and AMCA 210-16. DOE proposed that fan models that meet both
the definition of an axial panel fan and the definition of an air
circulating fan depending on the presence or absence of brackets for
mounting through a wall, ceiling, or other structure that separates the
fan's inlet from its outlet be tested according to both the test
procedures for fans and blowers, excluding air circulating fans, and
the test procedure for air circulating fans. 87 FR 44194, 44235.
AMCA commented that fan owners often apply fans differently from
how manufacturers intended them to be used and that fan manufacturers
did not have control over how panel fans are employed. AMCA noted that
the presence or absence of brackets may not deter the use of a fan for
the user's desired application. AMCA recommended that the criterion for
the DOE-relevant test method is the fan nameplate information and
coinciding technical marketing material and installation instructions.
AMCA commented that if a fan is presented both as an air circulating
fan and a fan and blower other than an air circulating fan by the
manufacturer, then it shall be rated both ways, supported by both type
of test reports. AMCA added that if a fan is a circulating panel fan,
it should be required to be tested only as a circulating panel fan; if
it is a panel fan, it should be required to be tested only as a panel
fan; and if the fan can be used as either a circulating panel fan or a
panel fan, it should be tested as both. (AMCA, No. 41 at pp. 30-31)
ebm-papst commented that the NOPR does not provide sufficient
clarification of the distinguishing mounting features. Therefore, ebm-
papst stated that an axial panel fan should be rated at least either as
a ventilation fan or as a circulation fan. ebm-papst commented that
rating of the same fan as per a second category should remain the
choice of the fan suppliers, because they have to serve a diverse
market with many unique fan selection criteria. (ebm-papst, No. 31 at
p. 12)
The Efficiency Advocates commented in support of DOE's proposal
that fans meeting the definition of both axial panel fans and air
circulating fans be tested as both. The Efficiency Advocates commented
that some manufacturers offer the same fan model with different
mounting configurations. For example, stated the Efficiency Advocates,
housed air circulating fans may also be sold with brackets for mounting
through a wall or ceiling for use as an exhaust fan. The Efficiency
Advocates added that this would reduce the potential for a loophole
wherein a less efficient fan could be sold with different mounting
configurations as a means of being
[[Page 27365]]
subject to a less stringent standard. (Efficiency Advocates, No. 32 at
pp. 2-3)
DOE recognizes that manufacturers do not have control over how
users ultimately decide to install their equipment. As a general
matter, DOE's authority applies to products as manufactured and not at
point of installation. (See generally 42 U.S.C. 6302.) DOE considers
whether a fan is distributed in commerce with or without the presence
or absence of brackets for mounting through a wall, ceiling, or other
structure that separates the fan's inlet from its outlet. DOE requires
that a fan that meets the definition of an axial panel fan and is
distributed in commerce with components that enable it to be mounted
through a wall, ceiling, or other structure that separates the fan's
inlet from its outlet be tested in accordance with the test procedure
for fans and blowers, excluding air circulating fans. DOE requires that
a fan that meets the definition of an axial panel air circulating fan
or box fan and is not distributed in commerce with components that
enable it to be mounted through a wall, ceiling, or other structure
that separates the fan's inlet from its outlet, be tested in accordance
with the test procedure for air circulating fans. DOE requires that a
fan that meets the definitions of both an axial panel fan and an air
circulating fan (i.e., axial panel air circulating fans and box fans)
and is distributed in commerce with and without components that enable
it to be mounted through a wall, ceiling, or other structure that
separates the fan's inlet from its outlet be tested according to both
the test procedures for fans and blowers, excluding air circulating
fans, and the test procedure for air circulating fans.
In addition, AMCA commented that the current definitions used for
certain air circulating fans, including axial panel fans, will lead to
market confusion and the potential elimination of a significant number
of products from the marketplace due to the product class assigned by
DOE to the fan. AMCA provided an example of two essentially identical
fans, except for the size of the fan. AMCA stated that per the current
definitions, the first fan would be classified as an axial panel fan/
air circulating axial panel fan and will likely remain available to
consumers. However, AMCA commented that per the current DOE
definitions, the second fan is a belt-driven ceiling fan, which
requires the fan to meet the design requirements, including the
capability of reverse operation and energy conservation standard, for
ceiling fans. AMCA added that as Fan 2 is commonly applied, reversing
the fan provides no benefit and the addition of the capability to
reverse would reduce the efficiency of the fan at an added first cost
to the consumer. In addition, stated AMCA, the second fan (assuming a
common method of test) uses less energy to move the same volume of air,
hence has a higher efficiency than Fan 1. AMCA finds it difficult to
believe that consumers, retailers, and customs officials will be able
to differentiate between DOE's axial panel Fan 1 and ceiling Fan 2.
(AMCA, No. 41, p.31)
DOE notes that the requirement to include the capability of
reversible action is not required for all ceiling fans s manufactured
on or after January 1, 2007, and DOE included three exceptions for fans
sold for industrial applications, fans sold for outdoor applications,
and cases in which safety standards would be violated by the use of the
reversible mode. 42 U.S.C. 6295(ff)(1)(A)(iii)) Further, as previously
stated, the definition of ``fan and blower'' includes air circulating
fans and excludes ceiling fans. Therefore, equipment that meets the
definition of a ceiling fan would be excluded from the scope of
equipment included under ``fan and blower.'' Any fan that is
distributed in commerce with components that enable it to be suspended
from a ceiling, and that meets the ceiling fan definition (see 10 CFR
430.2) in terms of being a non-portable device and for circulating air
via the rotation of fan blades, is a ceiling fan. 87 FR 50396, 50402
(August 16, 2022). DOE will address any comments and concerns regarding
the energy conservation standards for ceiling fans under a separate
ceiling fan rulemaking.\92\
---------------------------------------------------------------------------
\92\ See Docket No. EERE-2021-BT-STD-0011.
---------------------------------------------------------------------------
G. Metric
This section discusses the metrics adopted for fans and blowers
other than air circulating fans and for air circulating fans.
1. Metric for Fans and Blowers Other Than Air Circulating Fans
AMCA 214-21 provides uniform methods to determine the FEP and FEI
of a fan at a given duty point.\93\ As explained, FEP describes the
electrical input power of a fan in kW. AMCA 214-21 defines FEI as the
ratio of the electrical input power of a reference fan to the
electrical input power of the actual fan for which the FEI is
calculated, both established at the same duty point. As stated, FEI is
a dimensionless index for evaluating a fan's performance against a
reference fan. Section 5 of AMCA 214-21 provides the equations to
calculate the reference fan electrical input power as a function of
airflow and pressure.
---------------------------------------------------------------------------
\93\ As previously described, a duty point is characterized by a
given airflow and pressure and has a corresponding operating speed.
The collection of all duty points associated with a given speed is
referred to as a ``fan curve.'' AMCA 214-21 provides methods to
establish the FEP and FEI at any point within the operating range of
the fan.
---------------------------------------------------------------------------
For fans other than circulating fans, the Working Group recommended
using FEP as the primary fan metric and to allow using FEI for
additional representation of energy use. The Working Group also
recommended calculating FEI using the FEP of a fan that is exactly
compliant with any future fan energy conservation standards. (Docket
No. EERE-2013-BT-STD-0006, No. 179, Recommendation #6 at p. 5). The
Working Group further recommended that the metric be evaluated at each
operating point as specified by the manufacturer. (Docket No. EERE-
2013-BT-STD-0006, No. 179, Recommendations #18 and #27 at pp. 10-11,
13-14). DOE explained that under this approach, for each basic model of
fan, a manufacturer would have to determine the FEP of the fan at each
operating point.
In the July 2022 NOPR, DOE also noted another metric called ``Fan
Efficiency Grade'' or FEG, which is a numerical rating that represents
the ratio of air power produced by the fan divided by the fan shaft
power and is defined as a function of fan impeller diameter. FEG
ratings are defined in discrete ``bands'' (e.g., FEG 85, FEG 80, FEG
75, etc.) and are established in accordance with AMCA 205-12, ``Energy
Efficiency Classification for Fans.'' \94\ DOE noted that as defined in
AMCA 205-12, the FEG rating is representative of only the maximum
efficiency of the fan. As a result, depending on the actual operating
conditions, a fan with a higher peak efficiency and FEG rating could
consume more energy in a particular application than a fan with a lower
peak efficiency and FEG rating. In addition, the FEG metric does not
capture the performance of the motor, transmission, or motor
controllers and does not differentiate among fans with motors,
transmissions, and motor controllers with differing efficiency levels.
DOE further noted that in its proposed regulation, the CEC is proposing
to use
[[Page 27366]]
the FEI metric for fans and blowers.\95\ Since the publication of the
term sheet and of AMCA 214-21, a number of incentive programs and model
energy codes and standards used in State energy codes rely on the FEI
metric.\96\ 87 FR 44194, 44237.
---------------------------------------------------------------------------
\94\ See AMCA white paper available at: www.amca.org/assets/resources/public/userfiles/file/Nospreads_FanEfficGrades.pdf.
\95\ See Proposed regulatory language for Commercial and
Industrial Fans and Blowers available in the following Docket: 22-
AAER-01 at: efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
\96\ ANSI/ASHRAE/IES 90.1-2019, Energy Standard for Buildings
Except Low-Rise Residential Buildings; ANSI/ASHRAE/ICC/USGBC/IES
189.1-2020, Standard for the Design of High-Performance; Green
Buildings Except Low-Rise Residential Buildings; 2021 International
Energy Conservation Code; 2021 International Green Construction
Code; 2020 Florida Building Code: Energy Conservation; 2021 Oregon
Energy Efficiency Specialty Code; 2022 California Building Energy
Efficiency Standards (Title 24); incentive programs presently
offered or under development by Seattle City Light, ComEd, and Xcel
Energy See AMCA FEI Advocacy Brief available at: www.amca.org/assets/resources/public/assets/uploads/0621-FEI_Advocacy_Brief_V3-20210715.pdf.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE proposed to apply FEI as the efficiency
metric for fans and blowers. DOE stated that FEI would provide for
evaluation of the efficiency of a fan or blower across a range of
operating conditions, would capture the performance of the motor,
transmission, or motor controllers (if any), and would allow for the
differentiation of fans with motors, transmissions, and motor
controllers with differing efficiency levels. In addition, the use of
FEI would align with the industry test standard (AMCA 214-21) and drive
better fan selections. 87 FR 44194, 44237.
In addition, DOE proposed that fan FEI would be evaluated in
accordance with the DOE proposed test procedure at each of the fan's
operating points within the range of air power and shaft input power
proposed in scope (i.e., at each duty point, as specified by the
manufacturer within the range of air power and shaft input power in
scope, see Section III.B.1 of this document). This approach is
consistent with the term sheet recommendations and would require the
determination of the FEI at each duty point as specified by the
manufacturer. With this approach, the test procedure would not
prescribe particular operating conditions at which the FEI is to be
evaluated in order to calculate the FEI metric; instead, the FEI is
determined at each duty point. Further, if DOE were to establish any
potential energy conservation standards, compliance with that standard
would be required at each duty point specified by the manufacturer
within the range of air power and shaft input power proposed in scope
(i.e., operating range or ``bubble''), and for which the manufacturer
publishes performance data. Manufacturers would not be allowed to
publish performance data at non-compliant operating points. 87 FR
44194, 44237.
DOE further explained that in order to allow manufacturers to
continue to publish performance data at any duty point, DOE also
considered an alternative metric approach where the metric would be
evaluated at set duty point(s) specified in the test procedure instead
of having the FEI metric evaluated at each duty point as proposed. As a
potential consideration, DOE provided an example of three duty points
identified relative to the fan's BEP \97\ at maximum speed and provided
an example of a weighted average FEI metric (``WFEI'') established as
the average FEI across all three duty points (i.e., duty points of 100,
75, and 50 percent flow relative to BEP) and using a reference system
curve in the case of multi- and variable-speed fans. DOE did not
propose use of the WFEI metric in the July 2022 NOPR but requested
comment on this alternative approach. 87 FR 44194, 44237-44238.
---------------------------------------------------------------------------
\97\ The BEP represents the flow and pressure values at which
the fan total efficiency (ratio of total air power to fan shaft
input power) is maximized when operating a given speed. Prior to the
use of FEI, energy codes required selecting a fan with an efficiency
within 10-15 percentage points of the BEP efficiency. See
International Green Construction Code (2012); ANSI/ASHRAE/IES 90.1,
Energy Standard for Buildings Except Low-Rise Residential Buildings
(2013); ANSI/ASHRAE/USGBC/IES 189.1, Standard for the Design of
High-Performance Green Buildings Except Low-Rise Residential
Buildings (2014); International Energy Conservation Code (2015).
---------------------------------------------------------------------------
In response to the July 2022 NOPR, the CA IOUs commented in support
of the proposed publication of the FEI and FEP at each duty point. (CA
IOUs, No. 37 at p. 1)
ebm-papst stated support for the use of FEI for fans in the scope
of this NOPR, other than air circulating fans. (ebm-papst, No. 31 at p.
12)
Greenheck commented that DOE should follow the recommendations of
the term sheet, specifically in terms of the metric. (Greenheck, No. 39
at p. 2) Greenheck further recommended DOE utilize FEI as its
efficiency metric as defined in AMCA 214-21 and required by ASHRAE 90.
(Greenheck, No. 39 at p. 3)
Morrison commented that FEI is an appropriate metric to use in this
proposed regulation for fans (that are not circulating fans). Morrison
noted that ASHRAE and ICC energy codes, and States such as California,
Oregon, and Florida, have adopted FEI in their State energy codes. The
CEC is using FEI in its Title 20 regulation and that FEI is consistent
with the term sheet. (Morrison, No. 42 at p. 7)
AMCA commented that FEI at maximum fan speed is the regulated
metric for fans and blowers. AMCA commented that fan manufacturers and
many other stakeholders have invested in determining and publishing FEI
in lieu of FEG, FMEG,\98\ and other efficiency metrics. (AMCA, No. 41
at p. 16) Further, AMCA commented that FEI is the most appropriate
metric to use for a regulation for fans that are not air circulating
fans. AMCA commented that FEI has been the metric used in ASHRAE and
ICC energy codes since 2019, and States such as California, Oregon, and
Florida have FEI in their State energy codes. AMCA further stated that
the CEC is using FEI in its Title 20 regulation, which underwent
extensive internal and public review--Title 20 is slated to take effect
on Nov. 1, 2023.\99\ AMCA further noted that the 2015 ASRAC term sheet
has FEP as the regulatory metric and allowed for FEI to be used for
marketing and other purposes. AMCA commented that since ASRAC, while
code-change processes for ASHRAE 90.1, IECC, Title 20, and Title 24
were under way, industry and regulators agreed that FEI was a superior
metric for regulating fans; hence these code/regulatory bodies settled
on FEI and the AMCA 214 standard was developed around FEI as the
regulatory metric. AMCA commented that the AMCA Certified Ratings
Program evolved to certify manufacturer selection software ratings for
FEI.\100\ Also, stated AMCA, electric utility incentive programs have
been developed around FEI for fans and blowers other than air
circulating fans. AMCA also noted that for large-diameter ceiling fans,
a derivative of FEI, Ceiling Fan Energy Index (CFEI), was developed to
replace the average CFM/W metric DOE had previously used to regulate
these products. (AMCA, No. 41 at pp. 31-32)
---------------------------------------------------------------------------
\98\ DOE notes that FMEG refers to the Fan Motor Efficiency
Grade metric used in Europe and determined in accordance with ISO
12759:2010, ``Fans--Efficiency classification for fans.''
\99\ DOE notes that the CEC has since finalized its rulemaking.
See www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-20/appliance-efficiency-proceedings-11.
\100\ AMCA noted that a complete list of manufacturers with
AMCA-certified ratings, is available at www.amca.org/find-FEI.
---------------------------------------------------------------------------
NEEA recommended that DOE establish the design point metric FEI as
the regulatory metric for fans and blowers other than air circulating
fans as it is an easy-to-understand rating (the higher the FEI value
is, the better that fan is for a customer's specific application),
accounts for one of the
[[Page 27367]]
major drivers of fan energy use (fan sizing and specification) and will
result in significant energy savings and better-sized fans for the end
user. NEEA added that although FEI is a new metric, the fan market is
ready and willing to adopt this metric for regulation as demonstrated
by the development of an industry standard for FEI (AMCA 214-21), by
manufacturers beginning to rate their fans using FEI, and by energy
codes and utility incentive programs establishing requirements based on
FEI. (NEEA, No. 36 at p. 2)
New York Blower stated support for AMCA's recommendations regarding
the FEI metric. (New York Blower, No. 33 at p. 20) New York Blower
added that FEI, as proposed in AMCA 214-21 provides a variety of
utility, accurately represents efficiency, and provides energy
consumption comparison between fans operating at the same duty point
and that New York Blower is not aware of a better metric that
represents energy consumption or the opportunity for energy savings.
(Id. at p. 18)
In this final rule, DOE is applying FEI as the efficiency metric
for fans and blowers other than air circulating fans. In addition,
consistent with the term sheet recommendations, DOE is requiring that
the FEI be evaluated in accordance with the DOE test procedure at each
of the fan's operating points within the range of air power and shaft
input power with thein scope (i.e., at each duty point, as specified by
the manufacturer within the range of air power and shaft input power in
scope; see Section III.B.1 of this document). This approach requires
the determination of the FEI at each duty point as specified by the
manufacturer.
In response to the July 2022 NOPR, several stakeholders commented
on the consideration of a WFEI metric for fans and blowers other than
air circulating fans. The CA IOUs commented that while they support the
proposed FEI metric, they equally support the concept of an alternate
WFEI metric. However, the CA IOUs recommended revising the recommended
alternative test points for fans without motor controllers because two
of the points would fall in the unstable or stall operating region of
the fan curve and provided illustrative examples (i.e., the 75 percent
and 50 percent of BEP airflow). Instead, the CA IOUS suggested a WFEI
calculation using operating points based on pressure (e.g., 80 and 60
percent of the BEP pressure). In addition, the CA IOUs suggested
refining the definition of ``maximum speed.'' The CA IOUs commented
that maximum speed is ambiguous and could refer to: (1) the maximum
structural speed; (2) the maximum speed for which the manufacturer
provides ratings; (3) the maximum speed the motor can sustain; (4) the
maximum speed at which the motor controller allows the fan to operate;
or (5) the maximum speed at which the fan can operate with a particular
belt-drive transmission. The CA IOUs noted that interpreting maximum
speed according to the last definition could provide an opportunity to
evade any future standard as a manufacturer could certify performance
at the speed resulting from operation with the fixed pulleys, which may
incentivize some manufacturers to use a pulley set that results in a
low speed or an adjustable pulley set to the lowest speed. The CA IOUs
recommended the following framework to create a definition of maximum
speed: (1) for bare shaft fans, the maximum speed shall be the maximum
permitted speed of the fan as published by the manufacturer; (2) for
fans sold with single-speed motors and direct-drive or flexible
coupling transmissions, the certified speed shall be the speed achieved
at each test point; \101\ (3) for fans sold with single-speed motors
and belt-drive transmissions, the fan shall be tested with a
configuration that provides a speed the lesser of (a) the maximum speed
that can be sustained by the motor or (b) the maximum structural speed
published by the manufacturer; (4) for fans sold with a motor, speed
controller, and direct-drive or flexible coupling transmissions, the
tested point shall be the lesser of: (a) the maximum permitted speed of
the fan as published by the manufacturer, (b) the maximum speed that
can be sustained by the motor along the best efficiency curve, or (c)
the maximum speed allowed by the controller and cannot be increased by
a consumer; (5) for fans sold with a motor, speed controller, and belt-
drive transmissions, the tested point shall be the lesser of: (a) the
maximum permitted speed of the fan as published by the manufacturer, or
(b) the maximum speed that can be sustained by the motor at its rated
output along the best efficiency curve, using a transmission
configuration that allows the motor to operate at its rated output. (CA
IOUs, No. 37 at pp. 3-7)
---------------------------------------------------------------------------
\101\ The CA IOUs noted that for many single-speed induction
motor fans, the speed will change along the flow-pressure curve.
---------------------------------------------------------------------------
ebm-papst commented that WFEI has no benefit over any of the other,
much more deeply evaluated, fan efficiency metrics. In addition, ebm-
papst stated opposition to the establishment of a reference system
curve. ebm-papst commented that the fans it manufactures serve vastly
different applications and this prevents usage of one or a few
reference system curves for developing valid kWh predictions. (ebm-
papst, No. 31 at p. 12)
Greenheck commented that the alternative WFEI metric would allow
fan selections that use additional energy compared to a more energy-
efficient fan for a given duty point and provided an illustrative
example. (Greenheck, No. 39 at p. 4)
The CEC commented that a WFEI could result in an invalid
representation of the efficiency range of the fan because it may reside
in an area of operation where the fan stalls and is therefore not
tested by manufacturers nor operated once installed. The CEC commented
that when comparing the WFEI of two fans and assuming all three points
to be used for the analysis reside in an area of operation where the
fan will not stall, the WFEI generated will be heavily dependent on
non-efficient operating conditions. Instead, the CEC recommended
maintaining the FEI metric. (CEC, No. 30 at pp. 4-6)
NEEA commented against the use of WFEI as the regulatory metric as
it does not align with the term sheet recommendation and would be an
abrupt change to the current momentum behind FEI in the fan industry
and energy codes. NEEA further noted some issues with the duty points
considered for calculating the WFEI, which may be in the stall or surge
region of the fan. NEEA also noted a lack of market information on the
expected WFEI rating. NEEA further commented on the similarities
between PEI (Pump Energy Index) and the WFEI metric and commented that
while pump performance curves, which are used to calculate PEI, are
readily available and did not represent an increase in burden for the
industry to provide, fan manufacturers do not commonly publish
performance data in this way, so there would be increased burden to
produce these data, in addition to the testing required for
certification. (NEEA, No. 36 at pp. 4-6)
Morrison commented that a WFEI metric would change the intent of
the discussions and spirit of the ASRAC agreement and noted the
following issues with such a metric: (1) WFEI is another version of
FEG, which the Working Group rejected as a less than ideal metric for
fans; (2) WFEI in most circumstances cannot be calculated using the
points specified in the NOPR because some duty points may fall in the
stall or surge region; (3) the WFEI for fixed-speed fans and variable-
speed fans would have vastly differing values for the same fan and
nothing related to their
[[Page 27368]]
effect on energy use. Morrison further added that a FEG-style rating
was considered by all involved in the ASRAC as inferior to the FEI
rating method. Morrison added that the WFEI is an adjusted FEG and not
at all like the FEI/FEP metrics proposed and agreed to in the term
sheet. (Morrison, No. 42 at pp. 7-8)
Robinson commented on the unlikelihood that using a weighted
average measure will result in the intended energy conservation sought
by the proposed rule. Robinson added that the heavy industrial fan
selection process includes several realities that may not be part of
selection of a commercial fan. Robinson stated that heavy industrial
process fans often operate on several data points and often require
their own permitting process prior to installation. Robinson commented
that heavy industrial process fans are subject to unique challenges in
operation: they may have acid in the air stream; they may have rock
product in the air stream; they may be subjected to high heat, etc.
Robinson commented that the unique challenges of the operation of the
HIP fan often drive fan selection more than the efficiency of the fan.
Robinson commented that the understood, desired end result of
implementing a weighted average measure is to force consumers to
purchase more efficient fans. However, Robinson concluded, because of
the factors described above (and others) it's unlikely that heavy
industrial process operators will choose a specific fan type because of
its efficiency rating alone. (Robinson, No. 43 at p. 4)
AHRI commented that DOE's consideration of an alternative metric,
WFEI to replace Fan Energy Index (FEI)--the metric derived by industry
test procedure AMCA 214-21--could constitute a proposal that is
contradictory to the National Technology Transfer and Advancement Act
of 1995 (NTTA), Public Law 104-113, and the Office of Management and
Budget (OMB) Circular A-119, Federal Participation in the Development
and Use of Voluntary Consensus Standards and in Conformity Assessment
Activities. AHRI commented that both documents direct Federal agencies
to adopt voluntary consensus standards unless they are inconsistent
with applicable law or otherwise impracticable, as noted by DOE. (86 FR
70892, 70910, at fn 15 (Dec. 13, 2021)) AHRI commented that WFEI is a
separate metric with a distinct calculation procedure that has not been
evaluated by either fan manufacturers or their customers. (AHRI, No. 40
at p. 4) AHRI added that DOE has not presented supporting documentation
that WFEI achieves the differentiation sought. (AHRI, No. 40 at p. 4)
AHRI expressed its concern that the introduction of a WFEI metric did
not undergo public comment in the October 2021 RFI. AHRI added that due
to the lengthy history and complexity of commercial and industrial fans
and the introduction of WFEI, stakeholders should be given additional
time to review and ask DOE questions in order to provide meaningful
comments that will assist DOE in this rulemaking process. (AHRI, No. 40
at p. 5) AHRI further commented that the proposed WFEI metric does not
align with the term sheet and is not an appropriate metric. (Id. at p.
6)
AMCA commented that the WFEI was a deviation from the ASRAC term
sheet which required the industry and advocates to expend time and
resources to research and analyze a whole new metric (AMCA, No. 41 at
p.2) AMCA added that there were numerous problems with using a WFEI
metric. First, AMCA noted that the duty points considered in the NOPR
to evaluate the WFEI would fall in regions where many fans would
operate in stall or surge. Therefore, AMCA commented that if a weighted
average value of BEP flow were used, different duty points would need
to be chosen and noted that an optimal selection point for a backward-
inclined fan typically is at 95 percent of peak pressure. In addition,
AMCA commented that the considered WFEI metric would encourage fan
designers to target higher efficiency at lower airflow, which would not
result in energy savings. AMCA commented that fans are more often
selected for operation at airflows greater than the BEP airflow and fan
designers should be encouraged to improve efficiency at these greater
airflows where fans are often applied. AMCA also included an example in
Table 5 to illustrate how WFEI values for different sizes of the same
fan model will remain approximately the same, which would drive fan
selections toward the smaller, less-efficient sizes, which are less
expensive. AMCA further identified additional issues with the potential
consideration of a WFEI metric for fixed-speed fans and variable-speed
fans related to the risk of having the duty points located in the
stall/surge regions, as well as system effects and the noted that air-
system curves are not necessarily quadratic parabolas through the
origin due to filters, coils, and other devices which tend to introduce
a linear component to the system resistance curve. Further, AMCA
commented that it does not believe a WFEI would result in any net
energy savings based on rating calculation. AMCA noted that the WFEI
metric would assume the fan with a VFD will be selected because it has
a higher rating than a fan without a VFD. However, AMCA commented, that
would not guarantee the fan will be operated at varying speeds and if
the fan is run at constant speed, the fan with the VFD will consume
more energy because of additional drive losses in the VFD. Therefore,
AMCA commented that the WFEI approach does not accurately reflect the
presumed energy savings in application. In addition, AMCA commented
that using a WFEI metric would change FEI from a duty-point metric to a
product-based metric similar to FEG. AMCA noted the significant history
revolving around the shortcomings of the FEG metric and how fans of
similar FEG ratings can consume vastly different amounts of energy at
specific duty points while a FEI metric would accommodate and identify
these differences in energy consumption. (AMCA, No. 41 at pp. 32-34)
JCI stated that it shares AMCA's comments regarding the use of a
new metric, weighted average (WFEI), versus the established FEP/FEI
metrics which is also not in alignment with the 2015 term sheet. (JCI,
No. 34 at p. 2)
New York Blower commented that the challenges of applying a
product-based efficiency metric for fans (such as WFEI) because fans
adapt to the system in which it is installed and the same fan can
operate at high efficiency in one system and perform poorly in a
different system. New York Blower commented that the FEI metric was
developed to drive fan selections to peak efficiency and yield the
greatest energy savings. (New York Blower, No. 33 at p. 2) New York
Blower commented that the calculation of the WFEI would select duty
points in the stall region for many fans. New York Blower added that
they examined different ways to select duty points that could be
combined into a WFEI metric and were unable to find an algorithm that
could be employed across all fan categories without forcing selection
of unacceptable duty points. Instead, New York Blower suggests that the
BEP at maximum operating speed should be chosen as a single value to
compute the WFEI. In addition, New York Blower commented that fans with
variable speed drives would have an artificially high WFEI rating even
if that fan is never operated away from a single speed and would allow
less efficient fans marketed with a controller to remain in the market.
New York Blower added that in the industrial market, a majority of
applications are not operated
[[Page 27369]]
at or applied in a variable speed solution. Instead, there have seen an
increase in cyclic activity in fans over the recent years (i.e., the
fans are being turned off when not operated). (New York Blower, No. 33
at p. 3) If DOE's intent is to promote variable speed drive
installation, New York Blower commented that then either a direct
credit to the required FEI performance requirement, or an installation
credit at the time of calculations to overcome the insertion loss of
the variable speed drive is appropriate. (New York Blower, No. 33 at p.
19) Finally, New York Blower commented that a product-based metric
will, ultimately, result in product elimination from the market if
efficiency requirements are raised high enough. Because of the vast
performance range of a fan, New York Blower stated that it is unlikely
the energy savings would be realized in proportion to the products
eliminated from the market. Instead, New York Blower commented
customers would lose utility from the loss of product availability. New
York Blower commented on the complexity of implementing an application-
based metric (such as FEI), acknowledging that a product-based metric
(such as WFEI) is clearly an easier path to declaring an industry
regulated. However, New York Blower recommended that DOE consider the
value of saving energy be balanced with the urgency to complete a
regulatory effort. (New York Blower, No. 33 at p. 4)
In the July 2022 NOPR, DOE did not propose to adopt the WFEI as the
metric for fans and blowers other than air circulating fans. The WFEI
metric was considered in the July 2022 NOPR in order to provide a
potential alternative metric that would allow manufacturers to publish
ratings at operating points with a potentially non-compliant FEI,
should DOE establish energy conversation standards for fans and blowers
other than air circulating fans. 87 FR 44194, 44237-44238. As noted by
the CA IOUs, the CEC, Morrison, New York Blower and AMCA, the
determination of such metric is challenging as some the operating
points used in the calculation of the WFEI could fall in the stalling
operating region of the fan. In addition, as highlighted by NEEA,
Morrison, and AHRI such metric would not align with the term sheet
recommendations. Further as stated by Greenheck, AMCA, New York Blower
and Robinson, a fan with a higher WFEI may not necessarily result in
less energy use. As noted previously, DOE establishes the FEI as the
metric for fans and blowers other than air circulating fans, consistent
with the term sheet recommendations and industry practice. Therefore,
DOE is not adopting a definition of maximum speed and is not adopting
to specify operating points for the calculation of the WFEI.
In response to the July 2022 NOPR, and regarding the ability to
publish performance data for non-compliant duty points, the Efficiency
Advocates commented that they continue to support the development of a
fan efficiency metric and regulatory framework that drives better fan
selections, but they encourage DOE to consider how this goal can be
achieved while accommodating the potential need for manufacturers to
show certain non-compliant operating points. The Efficiency Advocates
commented that the original framework for improving fan selection was
to limit the range of operating points, as shown in manufacturer
literature and selection software, only to compliant operating points.
They added that manufacturers have raised concerns regarding the need
to show certain non-compliant operating points for safety reasons.
Therefore, they encourage DOE to explore options for a regulatory
framework for fans that would drive better fan selections, while
accommodating the potential need for additional published information.
For example, DOE could consider the feasibility of limiting fan
selections returned in manufacturer selection software to those that
are compliant at the specified operating point while allowing
manufacturers to show certain non-compliant operating points (e.g., in
the high pressure, low airflow operating range) for those compliant fan
selections. (Efficiency Advocates, No. 32 at p. 1)
Greenheck commented that it remained neutral on the topic of
showing noncompliant points on the fan curve after a compliant fan is
selected from a list of potential fan options. Greenheck added that
this concept was not part of the proposed rulemaking and was suggested
as an alternative to the flawed WFEI metric. Greenheck commented that
the display of noncompliant points for safety or retrofit applications
is an issue for the Energy Regulators, Advocates and built-up equipment
manufacturers to discuss and determine the impact upon the industry and
the potential value or burden of not showing those values. (Greenheck,
No. 39 at p. 5)
NEEA recommended that DOE works together with stakeholders to
determine the compliance, certification and enforcement approach for
FEI. NEEA stated that NEEA and industry partners are in active
collaboration to address DOE's concerns about compliance, certification
and enforcement and expect to present additional comments with specific
proposals after the comment period has closed. (NEEA, No. 36 at p. 3)
NEEA commented in support of allowing manufacturers to publish non-
compliant fan information stating that manufacturers need to be able to
publish information on non-compliant installations of a fan to inform
sizing. If this information is published, NEEA recommended that DOE
provide direction on how manufacturers should make it clear that non-
compliant fans should not be selected--such as different or grayed-out
coloring for visual representations of fan performance. NEEA added that
DOE could also require that manufacturer's selection software provide
clear warnings and not allow the purchase of fans with FEI less than
1.0. (NEEA, No. 36 at p. 4) NEEA further commented that the process for
compliance will be different for FEI compared to other regulated
metrics. NEEA suggested two options: (1) Software compliance:
Manufacturers could certify compliance of their selection software--the
system a user interacts with when selecting a fan for purchase (NEEA
noted that this recommendation aligned with Recommendation #26 of the
term sheet); and (2) Compliant mapping: For each model, NEEA commented
that DOE could require manufacturers to submit the operating conditions
that resulted in a compliant FEI. These operating conditions could be
organized in a ``compliant window'' or mapping similar to a fan
operating curve; DOE could confirm that this window was correct when
they review the CCMS submission. (NEEA, No. 36 at pp. 3-4)
In this final rule, DOE is not establishing energy conservation
standards for fans and blowers and therefore this final rule would not
result in any complaint window or non-complaint operating points as
noted in Greenheck and NEEA's comments. DOE will consider issues
related to representations and compliance to any potential energy
conservation standard in a separate energy conservation standards
rulemaking.\102\
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\102\ See rulemaking docket: EERE-2022-BT-STD-0002.
---------------------------------------------------------------------------
2. Metric for Air Circulating Fans
In the July 2022 NOPR, DOE proposed to incorporate by reference
AMCA 214-21 for air circulating fans, which relies on the FEP and FEI
metrics (``wire-to-air metrics'') for air circulating fans. DOE also
presented comments from AHRI,
[[Page 27370]]
AMCA, ASAP, ACEEE, NRDC, and the CA IOUs in support of a FEI metric for
air circulating fans.\103\ Specifically, ASAP, ACEEE, NRDC cited
advantages for FEI such as representativeness of energy use,
straightforward interpretation by consumers, ability to account for
efficiency differences between fans of the same diameter that deliver
the same airflow, consistency with other fan metrics \104\ while the CA
IOUS mentioned the ability to account for air
velocity.105 106 87 FR 44194, 44236-44237.
---------------------------------------------------------------------------
\103\ (AHRI, No. 10 at p. 2; AMCA, No. 6 at p. 9; ASAP, ACEEE,
NRDC, No. 7 at p. 2; CA IOUs, No. 9 at p. 2).
\104\ (ASAP, ACEEE, NRDC, No. 7 at p. 2).
\105\ (CA IOUs, No. 9 at p. 2).
\106\ See also (AHRI, No. 10 at p. 2; AMCA, No. 6 at p. 9).
---------------------------------------------------------------------------
In addition, to account for variations in fan speeds, DOE proposed
the following, depending on the air circulating fan's speed capability:
for single speed fans, DOE proposed that the FEI be evaluated at the
single available speed and corresponding duty point. For multi-speed
fans and variable speed fans, in the absence of data to characterize
typical operating speeds, DOE proposed to calculate the FEI based on
the weighted average FEI at each of the tested fan speeds, and that
each speed be apportioned an equal weight. (e.g., if the FEI is
calculated at five speeds, each speed is given 20 percent in the
calculation of the weighted average FEI). DOE tentatively determined
that while DOE has not found data to characterize the field operating
speeds of air circulating fans, a more representative FEI can be
calculated by using a weighted average across multiple speeds and
weighting all those speeds equally (when compared to calculating the
efficiency at only high speed). DOE noted that it would still allow
manufacturers to make representations of performance using CFM/W. 87 FR
44194, 44238.
DOE also stated that AMCA 230-15 provides methods to determine FEP
of air circulating fans as well as efficacy (i.e., amount of flow per
unit of electrical input power produced in CFM/W) and overall
efficiency (i.e., amount of thrust per unit of electrical input power
produced in lbf/W). Id. at 87 FR 44237. In the July 2022 NOPR, DOE
indicated that it was aware that the AMCA 230 committee may consider
specifying which metric to use in the updated version of AMCA 230 when
evaluating the energy performance of air circulating fans. While the
NOPR proposed to rely on FEI, DOE stated it was considering alternative
metrics such as CFM/W, including weighted average CFM/W for multi- and
variable-speed fans, as well as alternative weights for multi- and
variable-speed fans. In addition, DOE discussed potentially using the
abbreviation ``ACFEI'' (air circulating fan FEI) to distinguish this
metric from the FEI specific to fans and blowers other than air
circulating fans. 87 FR 44194, 44238-44239.
Since the publication of the July 2022 NOPR, AMCA 230-23 was
published and section 7.2.4.1 includes revised provisions regarding
test speeds to require testing at maximum speed only, with additional
optional tests at lower speeds.
As discussed in section III.E.20 of this document, for the July
2022 NOPR, DOE collected air circulating fan performance data from the
BESS certification database and performed regression analysis to
determine the appropriate flow, pressure, and efficiency target
constants for air circulating fans needed to calculate the FEI metric.
DOE proposed to rely on the following constants: Q0 = 3,210
CFM (rounded to the nearest 10); P0 = 0 in. wg; and an
efficiency target of 0.38 (38 percent). 87 FR 44194, 44230.
In response to the July 2022 NOPR, the Efficiency Advocates
commented in support of using FEI as the metric for air circulating
fans because it is both representative of energy usage and
straightforward for purchasers to interpret (for example, a FEI of 1.1
represents about a 10 percent reduction in energy usage in comparison
to an FEI of 1). Importantly, the Efficiency Advocates commented that
the FEI accounts for inherent efficiency differences between fans of
the same diameter that deliver different airflows. The Efficiency
Advocates added that using FEI for air circulating fans would provide
consistency with the other non-air circulating fans fan categories
included within the scope of the proposed test procedure. In addition,
the Efficiency Advocates commented in support of testing variable- and
multi-speed air circulating fans at multiple, discrete speeds. They
agree with DOE that testing and rating multi-speed fans at a range of
speeds will better inform purchasers about fan efficiency across a
range of operating speeds. They are also concerned that testing multi-
speed air circulating fans only at high speed could result in lower
ratings relative to single speed fans due to additional control losses.
In other words, while a multi-speed fan may save energy in real-world
applications, a rating only at high speed could make it appear less
efficient than a comparable single speed fan. Thus, the Efficiency
Advocates support DOE's proposal to test variable-/multi-speed fans at
multiple speeds. (Efficiency Advocates, No. 32 at p. 2)
ebm-papst commented that FEI provides no benefit with ACFs.
Instead, ebm-papst supports making CFM/W the regulated metric because
this metric has served users of ACFs well. (ebm-papst, No. 31 at pp.
11, 13)
The CA IOUs commented that BESS Laboratories, an important
certifying body for the agricultural fan market, uses a CFM/W metric.
The CA IOUs commented that DOE used data from BESS Laboratories to
inform its NOPR and similarly, many state utility programs use the BESS
Laboratories data to provide rebates incentivizing farmers to use
energy-efficient circulating fans. Although a FEI-based metric for
circulating fans is likely superior, it would disrupt the market if
CFM/W were not allowed to be used 180 days after the final publication
of this rule. The CA IOUs recommended that DOE allow the publication of
CFM/W and remove it in a future rulemaking (CA IOUs, No. 37 at p. 10)
In addition, the CA IOUs commented that DOE should gather additional
air circulating fan performance data to develop a new FEI-based metric.
The CA IOUs noted that BESS certification database only represents a
portion of the air circulating fan market. Specifically, the CA IOUs
noted that the air circulating fans tested by BESS Laboratories are
among the most efficient in the market and that manufacturers typically
will only send their best-performing fans to qualify for utility
rebates. The CA IOUs commented that the basis for the new equation
should include sampling from the vastly larger air circulating fan
market, including commodity fans sold in the retail market. For this
reason, the CA IOUs recommended that DOE continue gathering information
on the larger market and base the new metric on that data. (CA IOUs,
No. 37 at p. 11)
AHRI commented that DOE did not provide data to characterize the
field operating speeds of air circulating fans. However, DOE proposed
that a more representative FEI can be calculated by using a weighted
average across multiple speeds and weighting all those speeds equally
(when compared to calculating the efficiency at only high speed)
without offering substantiation of this conclusion. Further, AHRI
commented that DOE also stated that CFM/W can continue to be used to
represent performance of air circulating fan heads; however, this is
absent in the proposed regulatory text. (AHRI, No. 40 at p. 4)
AMCA recommended efficacy (in CFM/W) as the regulated efficiency
[[Page 27371]]
metric for air circulating fans because air circulating fans are rated
at only one volumetric flow rate (speed) at zero fan static pressure.
AMCA commented that FEI does not add any advantages over simpler
metrics for air circulating fans. (AMCA, No. 41 at p. 28) However, AMCA
commented that users have for years selected and compared air
circulating fans based on CFM/W ratings. AMCA commented that a change
of the metric would cause confusion among many stakeholders. In
addition, AMCA commented that requiring testing at multiple speeds
would negate nearly all historical test data, provide an efficiency
metric that confuses consumers, and create an inequitable market that
rewards inefficient multiple speed fans that lack consumer utility.
(AMCA, No. 41 at pp. 16-17) AMCA added that all considered air
circulating-fan metrics (efficacy, thrust efficiency, and single-speed
ACFEI) are based on measured fan thrust and fan air density and that
legacy data of fully documented tests permit accommodation of future
fan ratings as efficacy, thrust efficiency, or single-speed ACFEI these
metrics can be calculated from raw test data. AMCA added that there
would be little or no impact to the testing cost itself (only
recalculation of ratings using the same test data are needed). However,
any metric using blended or weighted ratings would invalidate all
existing ACF ratings. Most air circulating fans would require new
laboratory testing. (AMCA, No. 41 at p. 35) AMCA added that fan
manufacturers must accommodate several distinct types of users,
including agricultural markets, which generally do not seem to be well-
considered in the fan rulemaking. For air circulating fans, the use of
the FEI metric may be an issue for agricultural circulating fans
(livestock cooling) because BESS labs has been using CFM/W for its
certified ratings. These ratings also are used in agricultural
electricity-savings incentive programs. However, AMCA commented that a
switch to another metric would not be too difficult if historical test
results could still be used for calculating new ratings. (AMCA, No. 41
at p. 36) Finally, AMCA commented that the upcoming AMCA 230 will not
have an ACFEI metric in the standard. AMCA commented that if DOE
ultimately adopts the ACFEI metric, then AMCA recommends using the
following constants derived from analyses performed by the AMCA 230
committee: Q0 = 0.2454 cubic meters per second (1,500 CFM);
P0 = 0.6719 Pa (0.0027 in. wg); and Fan Efficiency target of
38 percent. However, AMCA noted that there was insufficient analytical
support for this metric at this time and that the current draft of AMCA
230 does not include ACFEI as a ratings metric. Id.
As noted by ebm-papst, the CA IOUs, and AMCA, the fan efficacy in
CFM/W is the industry established metric and DOE has concerns over the
readiness of an ACFEI metric. In addition, as stated by AMCA, there is
insufficient analytical support and DOE acknowledges the uncertainty
regarding the values of Q0 and P0 that should be
used. Therefore, DOE concludes that, at this time, the advantages of
the FEI or ACFEI metric identified in the July 2022 NOPR and discussed
previously (i.e., representativeness of energy use, straightforward
interpretation by consumers, ability to account for efficiency
differences between fans of the same diameter that deliver the same
airflow, consistency with other fan metrics and ability to account for
air velocity) are not significant enough to justify deviating from the
established industry efficacy metric (CFM/W) given that the FEI or
ACFEI metric have not yet been adopted by industry. In addition, the
latest industry test procedure (AMCA 230-23) relies on an efficacy
metric and does not rely on the FEI metric. Therefore, at this time,
DOE is establishing an efficacy metric in CFM/W for air circulating
fans.
In addition, given the uncertainty and lack of data regarding
operation at speeds less than the maximum speed, as discussed in
section III.E.14 of this document, DOE evaluates the efficacy metric at
the highest speed (or ``maximum speed'') only for all air circulating
fans regardless of their speed configuration.
H. Control Credit Approach for Fans and Blowers Other Than Air
Circulating Fans
For fans and blowers other than air circulating fans, the Working
Group recommended that the FEP of a fan with dynamic continuous control
be calculated with an additional credit to offset the losses inherent
to the control. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #16 at p. 9)
As stated in the July 2022 NOPR, DOE analyzed the control credit in
the European Commission Regulation No. EU 327/2011 and observed that
the value of the credit is equivalent to about 5 to 10 percent of the
fan electrical input power for a fan with controls with an electrical
input power less than 5 kW, but that it decreases to 4 percent for fans
at or above 5 kW. Since the term sheet publication, AMCA established
the FEI calculation method in AMCA 214-21. DOE also reviewed the
calculation of FEP for fans with variable speed controls in AMCA 214-
21, which does not provide for any control credit (i.e., motor
controller credit). (See section 6.4.2 of AMCA 214-21.) In its proposed
rulemaking for commercial and industrial fans and blowers, the CEC did
not propose a credit when establishing the FEI of fans with controllers
and did not specify a different minimum FEI level when proposing energy
conservation standards for fans with a controller.\107\ Instead, the
CEC highlighted that fans with a controller will have a larger FEI-
compliant performance capability compared to fans that are single
speed.\108\ 87 FR 44194, 44240.
---------------------------------------------------------------------------
\107\ See Proposed regulatory language for Commercial and
Industrial Fans and Blowers available in the following Docket: 22-
AAER-01 at: efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
\108\ See Staff Report, pp. 36-37 for Commercial and Industrial
Fans and Blowers available in the following Docket: 22-AAER-01 at:
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
---------------------------------------------------------------------------
Consistent with industry practice, DOE proposed to adopt the FEP
and FEI calculation as specified in AMCA 214-21 and did not propose to
develop a control credit for fans with a controller. As stated, EPCA
requires the DOE test procedures be reasonably designed to produce test
results, which reflect energy efficiency and energy use during a
representative average use cycle and not be unduly burdensome to
conduct. (42 U.S.C. 6314(a)(2)) To the extent use of a dynamic
continuous control impacts the energy use characteristics of a fan or
blower, the test procedure should account for such impact and
appropriate consideration of any such impact would be part of the
evaluation of potential energy conservation standards. Id.
AMCA supports DOE's proposal to not include a control credit in the
test procedure. AMCA explained that the majority of AMCA members are
not in the motor/controller business and frequently do not have
influence over the choice of motor control. AMCA commented that should
a credit be applied for motor controllers; it should be done at the
efficiency-requirement level and not within the FEI calculation. (AMCA,
No. 41 at p. 36)
Robinson commented that should DOE not include a credit, as it
would cause differentiation from the European calculations and could
impact the ability of U.S. manufacturers to compete against European or
non-U.S. manufacturers. (Robinson, No. 43 at p. 11)
[[Page 27372]]
Morrison commented that variable frequency drive (``VFD'') control
provides a good method to achieve part load operation dynamically in
order to promote energy savings. Morrison stated that since the FEP
calculation metric penalizes the use of VFDs, providing at a minimum an
equivalent bonus factor is appropriate to gain back the losses in the
calculation. Morrison commented that operating at part load saves
significantly more energy than any other efficiency change. (Morrison,
No. 42 at p. 8)
New York Blower commented against a credit in the FEP and FEI
calculation for fans with a motor controller. However, in the context
of a WFEI metric which overestimates energy savings obtained merely by
selling the fan with a motor controller, New York Blower commented that
a credit to cover an insertion loss of the motor controller would be
more tolerable and representative of system performance than the energy
consumption calculation as currently proposed in the WFEI. While not
supported with much data, New York Blower commented that a 5 percent
credit would be acceptable. New York Blower commented that based on
limited published data, they estimate that motor controllers can
operate at roughly 97 percent efficiency at optimal conditions. New
York Blower further stated that a 5 percent credit would give the motor
controller an additional 2 percent credit above typical insertion
loss--which should be included in the FEI calculation--in the overall
FEI representation. Again, New York Blower commented that they would
accept criticism in their estimates from those more knowledgeable of
the subject matter of motor controllers. New York Blower commented that
they believe this proposal is reasonable in intent and execution
considering the imposition of a WFEI metric. (New York Blower, No. 33
at pp. 20-21)
As stated previously, DOE is not adopting WFEI as the metric for
fans and blowers. Consistent with industry practice, for fans and
blowers other than air circulating fans, DOE is adopting the FEP and
FEI metric as specified in AMCA 214-21 and is not including a control
credit for fans with a motor controller. As stated, EPCA requires the
DOE test procedures be reasonably designed to produce test results,
which reflect energy efficiency and energy use during a representative
average use cycle and not be unduly burdensome to conduct. (42 U.S.C.
6314(a)(2)) As stated by Morrison, the FEP calculation metric penalizes
the use of VFDs, as it incorporates the losses from the VFD and
appropriate consideration of any such impact would be part of the
evaluation of potential energy conservation standards.
I. Alternative Energy Determination Method (AEDM)
For certain covered equipment, DOE permits the use of an AEDM
subject to the requirements at 10 CFR 429.70. An AEDM is a mathematical
model based on the covered equipment design, and mitigates the
potential cost associated with having to physically test units. AEDMs
are permitted in instances in which the model can reasonably predict
the equipment's energy efficiency performance.
Although specific requirements vary by product or equipment, use of
an AEDM entails development of a mathematical model that estimates
energy efficiency or energy consumption characteristics of the basic
model, as would be measured by the applicable DOE test procedure. 10
CFR 429.70(c)(1)(i). The AEDM must be based on engineering or
statistical analysis, computer simulation or modeling, or other
analytic evaluation of performance data. 10 CFR 429.70(c)(1)(ii). A
manufacturer must validate an AEDM by demonstrating that its predicted
efficiency performance of the evaluated equipment agrees with the
performance as measured by actual testing in accordance with the
applicable DOE test procedure. 10 CFR 429.70(c)(1)(iii). The validation
procedure and requirements, including the statistical tolerance, number
of basic models, and number of units tested, vary by product. 10 CFR
429.70.
Once developed, an AEDM may be used for representations of the
performance of untested basic models in lieu of physical testing. The
manufacturer, by using an AEDM, bears the responsibility and risk of
the validity of the ratings, including cases where the manufacturer
receives and relies on performance data for certain components from a
component manufacturer.
AEDMs, when properly developed, can provide a straightforward and
accurate means to predict the energy usage or efficiency
characteristics of a basic model of a given covered product or
equipment and reduce the burden and cost associated with testing. Where
authorized by regulation, AEDMs enable manufacturers to rate and
certify the compliance of their basic models by using the projected
energy use or energy efficiency results derived from these simulation
models in lieu of testing.
The Working Group recommended allowing the use of an AEDM to
generate the represented values of FEP and FEI of a fan basic model.
(Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendations #23 through
#25 at pp. 12-13)
As proposed in the July 2022 NOPR, DOE allows the use of an AEDM in
lieu of testing to determine fan performance, which would mitigate the
potential cost associated with having to physically test units.
Comments received on this issue are discussed in the remainder of this
section. 87 FR 44194, 44241.
1. Validation
Validation is the process by which a manufacturer demonstrates that
an AEDM meets DOE's requirements for use as a certification tool by
physically testing a certain number of basic models and comparing the
test results to the output of the AEDM. Before using an AEDM, a
manufacturer must validate the AEDM's accuracy and reliability as
follows.
A manufacturer must select a minimum number of basic models from
each validation class to which the AEDM applies. To validate an AEDM,
the specified number of basic models from each validation class must be
tested in accordance with the DOE test procedure and sampling plan in
effect at the time those basic models used for validation are
distributed in commerce. Testing may be conducted at a manufacturer's
testing facility or a third-party testing facility. The resulting
rating is directly compared to the result from the AEDM to determine
the AEDM's validity. A manufacturer may develop multiple AEDMs per
equipment category, and each AEDM may span multiple validation classes;
however, the minimum number of basic models must be validated per
equipment category for every AEDM that a manufacturer chooses to
develop. An AEDM may be applied to any basic model within the
applicable equipment category at the manufacturer's discretion. All
documentation of testing, the AEDM results, and subsequent comparisons
to the AEDM would be required to be maintained as part of both the test
data underlying the certified rating and the AEDM validation package
pursuant to 10 CFR 429.71.
The Working Group recommended that the AEDM be validated by the
testing of at least two basic models, compliant with any potential
energy conservation standards for each equipment class.\109\ In
addition, the
[[Page 27373]]
Working Group recommended that if an AEDM was used to simulate a wire-
to-air test method, then the basic models used to validate the AEDM had
to be tested using the wire-to-air test method. (Docket No. EERE-2013-
BT-STD-0006, No. 179, Recommendation #24 at p. 13).
---------------------------------------------------------------------------
\109\ DOE uses validation classes for AEDMs. While validation
classes may not directly align with equipment classes, validation
classes are consistent with equipment classes. DOE would propose
equipment classes in a future energy conservation standards
rulemaking for fans and blowers.
---------------------------------------------------------------------------
In the July 2022 NOPR, DOE proposed to include fan and blower
validation classes at 10 CFR 429.70(k) and to require that two basic
models per validation class be tested using the relevant proposed test
procedure. This number of basic models is consistent with the number of
basic models required for most DOE-regulated equipment that utilize
AEDMs. In addition, DOE proposed that at least one basic model selected
for validation testing would be required to include a motor, or a motor
and controller of each topology (e.g., induction, permanent magnet,
electronically commutated motor) included in the AEDM. DOE also
proposed that if the AEDM is intended to represent the wire-to-air test
method, then the testing of the basic models used to validate the AEDM
must be performed according to the wire-to-air test method. Similarly,
if the AEDM is intended to represent the fan shaft power test method,
DOE proposed that the testing of the basic models used to validate the
AEDM be performed according to the fan shaft power test method. 87 FR
44194, 44241.
Morrison commented that they continue to support the recommendation
24 of the term sheet and support a plan that has manufacturers using
testing results from two units to prove an AEDM but using the sampling
plan per Recommendation #23 of the ASRAC term sheet. The sampling plan
should be removed from the AEDM validation testing requirements.
(Morrison, No. 42 at p. 9)
AMCA commented that they support Working Group Recommendation #24.
However, AMCA commented that Recommendation #24 varies from the NOPR in
that the NOPR calls for the testing to be done compliant with the test
procedure and sampling plan, which currently calls for two units per
basic model. AMCA accepts testing two units to prove an AEDM but using
the sampling plan per Recommendation #23 of the ASRAC term sheet.
(AMCA, No. 41 at p. 37)
New York Blower commented that to require two units to validate an
AEDM seems reasonable, but when the tests must be executed in
accordance with a sampling requirement attached to it, the AEDM
development processed appears overly complicated. (New York Blower, No.
33 at p. 21)
Robinson commented that the AEDM approach for fans and blowers is
an imperative as testing costs will be overwhelming in the absence of
an AEDM. Robinson commented that the requirement for two samples to
validate an AEDM will preclude the term sheet agreement of using
historical testing data which is developed from a single fan.
(Robinson, No. 43 at p. 11)
DOE includes fan and blower validation classes at 10 CFR 429.70(m)
and requires that two basic models per validation class be tested using
the relevant proposed test procedure. As stated, the number of basic
models is consistent with the number of basic models required for most
DOE-regulated equipment that utilize AEDMs. In addition, DOE requires
that at least one basic model selected for validation testing would be
required to include a motor, or a motor and controller of each topology
(e.g., induction, permanent magnet, electronically commutated motor)
included in the AEDM. DOE also requires that if the AEDM is intended to
represent the wire-to-air test method, then the testing of the basic
models used to validate the AEDM must be performed according to the
wire-to-air test method. Similarly, if the AEDM is intended to
represent the fan shaft power test method, DOE requires that the
testing of the basic models used to validate the AEDM be performed
according to the fan shaft power test method. In addition, as discussed
in section III.J of this document, DOE requires testing at least one
unit per basic model in accordance with the sampling plan per
Recommendation #23 of the ASRAC term sheet.
DOE's proposed validation classes for fans and blowers are listed
as follows: (1) centrifugal housed; (2) radial housed; (3) centrifugal
inline; (4) centrifugal unhoused; (5) centrifugal PRV exhaust; (6)
centrifugal PRV supply; (7) axial inline; (8) axial panel; (9) axial
PRV; (10) unhoused ACFH; (11) air circulating axial panel fan; (12) box
fan; (13) cylindrical air circulating fan; and (14) housed centrifugal
air circulating fan. 87 FR 44194, 44241. Per the current draft of the
revised AMCA 230 standard, AMCA recommends replacing the proposed
validation classes (10) through (14) with ``(10) Air circulating fan
heads.'' \110\ Additionally, AMCA recommends an 11th class for
laboratory exhaust fans that are not induced flow fans per its
recommendation for the definition of safety fans and lab exhaust fans
that are not induced flow fans.\111\ (AMCA, No. 41 at p. 37)
---------------------------------------------------------------------------
\110\ In their comments, AMCA uses the acronym ACFH to designate
air circulating fan heads. Air circulating fans includes both housed
and unhoused ACFHs and DOE considers the term ACFH equivalent to air
circulating fan.
\111\ DOE notes that AMCA also noted that their recommended
changes would alter the regulatory text as follows: (i) Select basic
models. For each fan or blower validation class listed as follows:
centrifugal housed fan; radial housed fan; centrifugal inline fan;
centrifugal unhoused fan; centrifugal power roof ventilator exhaust
fan; centrifugal power roof ventilator supply fan; axial inline fan;
axial panel fan; axial centrifugal power roof ventilator fan;
unhoused ACFH; air circulating axial panel fan; housed air
circulating fan head; lab exhaust fan to which the AEDM is applied.
(AMCA, No. 41 at p. 37) DOE notes that the draft regulatory text
provided by AMCA and the comment do not align. In their comments,
AMCA recommends replacing the proposed validation classes (10)
through (14) with ``(10) Air circulating fan heads'' while in the
regulatory text they recommend replacing the proposed validation
classes (12) through (14) with ``(10) Air circulating fan heads.''
(AMCA, No. 41 at p. 37) DOE interprets that comment as taking
precedent over the draft regulatory text provided as the validation
classes listed by AMCA in the draft regulatory text provided do not
match the comment otherwise.
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DOE did not receive any comments related to the proposed validation
classes (1) through (9) and is adopting them as proposed. Regarding
laboratory exhaust fans, as stated previously (see section III.C.2 of
this document), DOE is not including laboratory exhaust fans in the
scope of the test procedure and therefore is not adding a validation
class for this equipment. Regarding validation classes for air
circulating fans, AMCA recommended using unique validation classes for
all categories of air circulating fans. DOE has concerns that such an
approach, keeping with the 2 basic models per validation class, would
not allow development of a model that is sufficiently representative of
impeller designs and housing configurations. In addition, AMCA did not
provide supporting information other than stating consistency with AMCA
230-23 (which does not include AEDM requirements). Therefore, at this
time, DOE is reducing the number of validation classes for air
circulating fans by grouping all housed ACFHs with axial impellers
(i.e., air circulating axial panel fans, box fans, and cylindrical air
circulating fans) under the same validation class (``axial housed
ACFH'') and to establish the following validation classes: unhoused
ACFH, axial housed ACFH, and housed centrifugal air circulating fan.
New York Blower estimated that three fans would need to be tested
to support ratings for 12 sizes and that the performance of the
remaining sizes could be estimated using an AEDM. New York Blower
commented that once the AEDM inventory in the industry is created,
maintenance would be
[[Page 27374]]
lessened, but to get started would clearly take extensively longer than
any compliance period currently proposed. New York Blower commented
that having to document AEDMs and certify every size, on an annual
basis, would be an incredible burden to the fan industry and result in
added cost paid by consumers. (New York Blower, No. 33 at p. 5)
DOE is not establishing any certification requirements in this
final rule; however, DOE notes that beginning 180 days after
publication of this final rule, any voluntary representations of FEI
for fans that are not air circulating fans or CFM/W for air circulating
fans that are within the scope of this test procedure would be required
to be based on the DOE test procedure. This requirement is further
discussed in section III.L.
The Working Group recommended adding a tolerance of 5 percent to
the results of the AEDM for the basic models used for validation of the
AEDM. The Working Group recommended that the predicted FEP using the
AEDM may not be more than five percent less than the FEP determined
from the test according to the DOE test procedure for the basic models
used to validate an AEDM. (Docket No. EERE-2013-BT-STD-0006, No. 179,
Recommendation #25 at p. 13).
The Working Group recommendation would require that the FEP
calculated by an AEDM must be greater than or equal to 95 percent of
the FEP determined testing the basic models used to validate the AEDM.
This is equivalent to requiring that the FEI determined using the FEP
calculated by an AEDM must be less than or equal to 100/0.95 percent or
approximately 105 percent of the FEI calculated using the FEP
determined from testing the basic models used to validate the
AEDM.\112\
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\112\ The FEI is equal to the reference FEP (FEPref)
divided by the FEP of the actual fan. Therefore, if the FEP
calculated using the AEDM (FEP-AEDM) is greater than or equal to 95
percent of the FEP (FEP-test) determined through testing, the
FEPref/FEP-AEDM is less than or equal to \1/0\.95 *
FEPref/FEP-test.
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In the July 2022 NOPR, DOE proposed to apply the 5 percent
tolerance to the FEI because FEI is the proposed metric. DOE proposed
that the FEI calculated by an AEDM must be less than or equal to 105
percent of the FEI determined from the test of the basic models used to
validate the AEDM. 87 FR 44194, 44241.
In response to the July 2022 NOPR, Robinson requested clarification
on whether there is a positive margin on the AEDM for predicted FEP.
(Robinson, No. 43 at p. 11) DOE notes that there is a positive margin,
as stated in the previous paragraph.
DOE did not receive any additional comments on this proposal and
therefore is requiring that the FEI calculated by an AEDM must be less
than or equal to 105 percent of the FEI determined from the test of the
basic models used to validate the AEDM. For air circulating fans, DOE
is applying a 5 percent tolerance as proposed, but to the adopted
efficacy metric in CFM/W.
2. Additional AEDM Requirements
In the July 2022 NOPR, consistent with provisions for other
commercial and industrial equipment, DOE proposed to require that, if
requested by DOE, a manufacturer must perform at least one of the
following activities: (1) conduct a simulation before a DOE
representative to predict the performance of particular basic models of
the equipment to which the AEDM was applied; (2) provide analysis of
previous simulations conducted by the manufacturer; or (3) conduct
certification testing of basic model(s) selected by DOE. 87 FR 44194,
44241-44242.
In addition, DOE proposed that when making representations of
values other than FEI (e.g., FEP, fan shaft power) for a basic model
that relies on an AEDM, all other representations would be required to
be based on the same AEDM results used to generate the represented
value of FEI. Id. at 87 FR 44242.
In response to the July 2022 NOPR, Robinson commented that it
objects to the requirement of providing copies of AEDM calculations
because the Robinson companies are privately held. (Robinson, No. 43 at
p.11) DOE notes that manufacturers initially must certify whether basic
model performance was determined with an AEDM or not. If DOE has
questions on the AEDM used for a given basic model, DOE contacts the
manufacturer for this information. DOE considers all AEDM data provided
by manufacturers to be confidential. These data would not be publicly
available. Additionally, DOE notes that use of an AEDM and AEDM
representations are voluntary.
DOE did not receive any additional comments on these issues and
requires that when making representations of values other than FEI
(e.g., FEP, fan shaft power) or efficacy (as applicable) for a basic
model that relies on an AEDM, all other representations would be
required to be based on the same AEDM results used to generate the
represented value of FEI or efficacy.
3. AEDM Verification Testing
In the July 2022 NOPR, consistent with the provisions for certain
commercial and industrial equipment, DOE proposed to include provisions
related to AEDM verification testing for fans and blowers in 10 CFR
429.70(k), including: (1) selection of units from retail if available,
or otherwise from a manufacturer, (2) independent, third-party testing
if available, or otherwise at a manufacturer's facility, (3) testing
performed without manufacturer representatives on site, (4) testing in
accordance with the DOE test procedure, any active test procedures, any
guidance issued by DOE, and lab communication with the manufacturer
only if DOE organizes it, (5) notification of manufacturer if a model
tests worse than its certified rating by an amount exceeding a 5
percent tolerance with opportunity for the manufacturer to respond, (6)
potential finding of the rating for the model to be invalid, and (7)
specifications regarding when a manufacturer's use of an AEDM may be
restricted due to prior invalid represented values and how a
manufacturer could regain the privilege of using an AEDM for rating. 87
FR 44194, 44242. DOE did not receive any comments related to these
proposals and DOE is adopting these provisions as proposed.
4. Engineered-To-Order
In response to the July 2022 NOPR, New York Blower requested
clarification regarding engineered-to-order products. Specifically, New
York Blower requested clarification regarding what defines a product as
an engineered-to-order product and whether that would impact sampling
and AEDM requirements. New York Blower commented that engineered-to-
order better describes custom fans which contain a design, but no
distinct sizes. New York Blower commented that the sizes are
dynamically created when the customer provides the specification and
the fan is then designed and built once, for a single use. New York
Blower requested clarification on whether this type of product is
required to follow the sampling and testing requirements. New York
Blower recommended that custom fan designs be certified at a single
size and that at the time of order, the data from the tested size would
be rescaled through an AEDM, built, and shipped. New York Blower
further recommended that the certification of the original tested fan
would be carried to the designed fan and no further sampling or testing
would be required. New York Blower commented that this is how
[[Page 27375]]
custom fans have been designed for as long as the affinity laws have
been understood. New York Blower noted that such approach would
conflict with the definition of the basic model as each instance of the
custom fan design is likely to consume a significantly different amount
of energy from the tested fan and therefore would need to be considered
a different basic model. In summary, New York Blower requested that DOE
allow custom fan designs to be certified through a single certification
for each design. (New York Blower, No. 33 at pp. 23-24)
As stated in section III.E of this document, DOE references section
8.2.1 of AMCA 214-21, ``Fan laws and other calculation methods for
shaft-to-air testing,'' and section 8.2.3 of AMCA 214-21, ``Calculation
to other speeds and densities for wire-to-air testing,'' as proposed in
the July 2022 NOPR. (See 87 FR 44194, 44222.) Section 8.2.3 of AMCA
214-21 includes provisions which allow speed and size interpolations.
In addition, as discussed in this section, DOE allows the use of AEDM
in lieu of testing. For engineered-to-order equipment, manufacturers
would have the option to determine the FEI of the engineered-to-order
basic model through physical testing, application of the fan laws (in
accordance with the test procedure), or application of an AEDM.
Manufacturers would be required to certify the basic model.
As discussed in section III.C.7 of this document, with regards to
custom fans for which a single made-to-order fan is manufactured,
general sampling requirements for all covered equipment at 10 CFR
429.11(b), and Sec. 429.11(b)(2) provides provisions for sampling when
only one unit of a basic model is produced.\113\ In accordance with
these provisions, a single engineered-to-order product must be tested
to ensure it complies with the standard. To reduce testing burden, DOE
is adopting AEDM provisions that would allow certification using such
AEDM, in lieu of testing (i.e., physical testing or application of the
fan laws as in accordance with the test procedure) and would apply to
any basic model, including made-to-order products. Certification would
be based on the test results of the one unit, or the AEDM ratings for
the model.
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\113\ Section 429.11(b)(2) specifies that if only one unit of
the basic model is produced, that unit must be tested, and the test
results must demonstrate that the basic model performs at or better
than the applicable standard(s). If one or more units of the basic
model are manufactured subsequently, compliance with the default
sampling and representations provisions is required.
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J. Sampling Plan
DOE provides sampling provisions for determining represented values
of energy use or energy efficiency of a covered product or equipment.
See generally, 10 CFR part 429. These sampling provisions provide
uniform statistical methods that require testing a sample of units that
is large enough to account for reasonable manufacturing variability
among individual units of a basic model, or variability in the test
methodology, such that the test results for the overall sample will be
reasonably representative of the efficiency of that basic model.
The general sampling requirement currently applicable to all
covered products and equipment provides that a sample of sufficient
size must be randomly selected and tested and that, unless otherwise
specified, a minimum of two units must be tested to certify a basic
model. 10 CFR 429.11. This minimum is implicit in the requirement to
calculate a mean--an average--which requires at least two values.
Manufacturers can increase their sample size to narrow the margin of
error. The design of the sampling plan is intended to determine an
accurate assessment of product or equipment performance, within
specified confidence limits, without imposing an undue testing or
economic burden on manufacturers. Different samples from the same
population will generate different values for the sample average. An
interval estimate quantifies this uncertainty in the sample estimate by
computing lower and upper confidence limits (``LCL'' and ``UCL'') of an
interval (centered on the average of the sample) which will, with a
given level of confidence, contain the population average. Instead of a
single estimate for the average of the population (i.e., the average of
the sample), a confidence interval generates a lower and upper limit
for the average of the population. The interval estimate gives an
indication of how much uncertainty there is in the estimate of the
average of the population.\114\ Confidence limits are expressed in
terms of a confidence coefficient. For covered equipment and products,
the confidence coefficient typically ranges from 90 to 99 percent.\115\
The confidence coefficient 97.5 percent, for example, means that if an
infinite number of samples are collected, and the confidence interval
computed, 97.5 percent of these intervals would contain the average of
the population: i.e., although the average of the entire population is
not known, there is a high probability (97.5 percent confidence level)
that it is greater than or equal to the LCL and less than or equal to
the UCL.
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\114\ NIST/SEMATECH e-Handbook of Statistical Methods,
www.itl.nist.gov/div898/handbook/eda/section3/eda352.htm.
\115\ Part 429 in 10 CFR outlines sampling plans for
certification testing for product or equipment covered by EPCA.
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To ensure that the represented value of efficiency is no greater
than the population average, the sampling plans for determination of
the represented value typically consist of testing a representative
sample to ensure that . . . (ii) Any represented value of energy
efficiency \116\ . . . shall be no greater than the lower of (A) the
average of the sample () or (B) the lower XX confidence limit of the
true mean divided by K, where the values for XX and K vary with product
or equipment type. XX, the confidence limit, typically ranges from 90
to 99 percent, while K, an adjustment factor, typically ranges from 0.9
to 0.99. The specific values for XX and K for a particular product or
equipment are selected based on an expected level of variability in
product performance and measurement uncertainty. 10 CFR 429.14 through
10 CFR 429.66. Requiring that the represented value be less than or
equal to the LCL would ensure that the represented value of efficiency
is no greater than the population average. DOE divides the LCL by K to
provide additional tolerance to account for variability in product
performance and measurement uncertainty.\117\ The comparison with the
average of the sample further ensures that if LCL divided by K is
greater than , the represented value is established using the average
of the sample. In addition, DOE relies on a one-sided confidence limit
to provide the option for manufacturers to rate more conservatively.
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\116\ Or any other metric for which the consumer will favor a
higher value, such as FEI.
\117\ For example, if DOE expects that the variability for
measured performance is within a margin of 3 percent, DOE will use a
K value of 0.97. See for example 79 FR 32019, 32037 (June 3, 2014).
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The Working Group recommended that a represented value of FEP of a
basic model be based on a minimum of one test, where the represented
value of FEP must be less than or equal to any energy conservation
standard level, and greater than or equal to the tested value of
FEP.\118\ The Working Group did not
[[Page 27376]]
provide recommendations to address a situation in which a manufacturer
chooses to increase their test sample size. (Docket No. EERE-2013-BT-
STD-0006, No. 179, Recommendation #23 at p. 12) The Petitioners also
requested that manufacturers be allowed to establish FEP and FEI
ratings of a fan basic model based on testing of a single unit. (Docket
No. EERE-2020-BT-PET-0003, The Petitioners, No. 1.3 at p. 8)
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\118\ DOE notes that this requirement can be converted into the
FEI metric as follows: the represented value of FEI of the basic
model must be based on a minimum of one test, where the represented
value of FEI must be greater than or equal to any energy
conservation standard and less than or equal to the tested value of
FEI.
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In the July 2022 NOPR, DOE proposed that a minimum sample size of
two units would be used when making representations of FEP, FEI, and
fan shaft power, as applicable. This proposal is consistent with the
statistical sampling requirements in place for other commercial and
industrial equipment regulated by DOE.\119\ 87 FR 44194, 44243. In
addition, DOE proposed that the FEI be rounded to the nearest
hundredth. Id. at 87 FR 44243.
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\119\ The general sampling requirement currently applicable to
all covered products and equipment provides that a sample of
sufficient size must be randomly selected and tested to ensure
compliance and that, unless otherwise specified, a minimum of two
units must be tested to certify a basic model as compliant. See 10
CFR 429.11.
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AMCA commented that a 2-sample test was a deviation from the ASRAC
term sheet, which required the industry and advocates to expend time
and resources to research and analyze the implication of losing the
historical record of fan tests. (AMCA, No. 41 at p. 2) AMCA commented
that sample sizes of one unit must be allowed, as stipulated in
Recommendation #23 of the term sheet. AMCA further cited the example of
commercial packaged boilers as a covered product for which DOE allows a
single unit sample (10 CFR 429.60). AMCA commented that, if DOE does
not allow a single unit sample, much of the historical data for the fan
industry would be eliminated. AMCA added that the industry does not
have the financial or logistical resources to retest all products with
two-sample tests. In addition, AMCA commented that AMCA 214-21 defines
how to calculate the FEP and FEI at a single duty point or point of
operation which consists of values of flow rate, pressure, power, and
density. AMCA noted that the proposed statistics included in the NOPR
imply FEP and FEI values can be averaged over multiple tests. However,
AMCA commented that when considering multiple samples, the tests would
have to have an identical number of sampled duty points and each duty
point would have to be at the same flow, pressure, and density.\120\
AMCA commented that while tests can be corrected to have all data
points represented at the same density, it is highly unlikely each
collected data point will be at the same flow and pressure. AMCA
commented that there is no known methodology to combine multiple sets
of test data to compute an expected mean value of performance \121\ and
commented that DOE would need to provide some methodology. AMCA added
that the proposed statistics would function accurately under the
following conditions: (1) A single value of performance (metric) was
derived from the test (for example, the WFEI); or (2) The value from
the test was captured at some specific operating condition that is
repeatable across tests (for example at BEP). AMCA commented that the
proposed test procedure is such that historical data would not pass the
current test-procedure requirements and requiring two units to be
tested will double the expense for manufacturers and lead to excessive
testing burden. AMCA commented that units that are built for test
cannot be placed back into stock and sold as new or offered for sale
and all tested units would be an unrecoverable expense. AMCA commented
that in addition to the costs, the time required to test two units of
every basic model would span well beyond the compliance time period and
could exceed 10 years. Instead, AMCA recommended to follow the
guidelines of AMCA 214 and allow a single test where the FEP and FEI is
calculated at each duty point (corrected to uniform speed and density
as appropriate), and this data becomes the basis for the efficiency
values presented in the market. (AMCA, No. 41 at pp. 38-40)
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\120\ At a given density, each duty point is defined as a value
of pressure and flow at a given speed, and the test procedure
provides methods to determine the electrical or FEP at that duty
point.
\121\ AMCA commented that AMCA 211 provides a method of
comparing fan-performance data to a reference rating and an
interpolation method for estimating performance between two sets of
performance data but does not provide a method of combining more
than one set of test data to provide average prediction of
performance. (AMCA, No. 41 at p. 39)
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JCI and Morrison commented in support of AMCA's comments regarding
the proposed sampling plan. (JCI, No. 34 at p. 2; Morrison, No. 42 at
pp. 9-12)
NEEA recommends DOE work with AMCA to understand the burden
associated with testing two units to certify a basic model and clarify
DOE's stance on allowing the use of historic testing to be used in
certifying fans. (NEEA, No. 36 at p. 3)
New York Blower commented that the sampling and statistics built
into 10 CFR parts 429 and 431 will function as expected for a product-
based metric. However, New York Blower added that the FEI metric is
designed to be applicable to an entire fan performance envelope (flow,
pressure, density, and power) and that there is no agreed upon
methodology that allows for the combining of two or more fan curves
into a representation of performance for a population. (New York
Blower, No. 33 at p. 3) New York Blower added that requiring two-sample
testing will double the costs of testing compared to creating ratings
for a series of sizes within a product line from a single test. (New
York Blower, No. 33 at p. 5)
New York Blower further commented that for a product-based metric
where statistical representation of a population is required, a two
sample minimum is appropriate. New York Blower added that a two-sample
minimum could impose significant restrictions on the manufacturer, by
amplifying any deviation between samples to predict population
performance. New York Blower commented that a Weighted Average FEI
value could be calculated from a single test. Presuming this would
represent minimum energy consumption or maximum efficiency of the
population of products would require the manufacturer to estimate any
deviations from future samples and incorporate it in the ratings
calculation. While not statistically supportable, it would be a method
to create ratings and certify products from a single test. (New York
Blower, No. 33 at p. 22)
Robinson commented that the two-sample minimum causes great concern
for heavy industrial processing fans. Robinson commented that heavy
industrial processing fans are uniquely designed and engineered for
each installation and application. The material and parts are ordered
specific to the job and only after the engineering and drawing of the
individual product are complete. The NOPR indicates that the DOE would
attempt to require two of each fan to be built to test its efficiency.
Considering the number of heavy industrial processing fans and blowers
sold in a year, Robinson commented that this will add a significant
time and financial burden even if it were possible to design an AEDM.
In the case of custom engineered equipment, Robinson stated that an
accurate AEDM will be difficult and expensive to develop, requiring
significant engineering expertise. (Robinson, No. 43 at pp. 3-4)
In addition, Robinson requested clarifications regarding the
sampling process and noted that it is not unusual for a custom fan
manufacturer to not
[[Page 27377]]
make a particular size for years depending on the needs of the market.
Robinson commented it was their understanding that one test would be
required to certify a design as custom fan manufacturers would have
historical design data available regarding the original design.
Robinson commented that the definition of basic models and varying full
width size classes suggests that an extraordinary amount of testing
would need to be conducted to certify basic models. (Robinson, No. 43
at p. 12)
Greenheck commented that the proposed two-test requirement is
disruptive and an extreme burden to the industry. Greenheck commented
that the fan test procedure and certified ratings program (``CRP''),
developed by AMCA and utilized by the fan industry, requires a single-
sample precertification test and recurring surveillance audits.
Greenheck commented that a two-sample requirement will not focus the
industry on development of higher efficiency products and support
energy savings. Instead, it will eliminate currently available fan
performance data and shackle manufacturers with years of
recertification of existing products. Greenheck commented that the
improved accuracy of two-sample testing provides no value or energy
savings for products already following the AMCA CRP program. Greenheck
recommended that DOE accept AMCA CRP historical data and allow single
unit performance data following AMCA 210 and AMCA 211 moving forward.
(Greenheck, No. 39 at pp. 2-3)
AHRI commented that the Working Group explicitly recommended that a
represented value of a basic model be based on a minimum of one test,
where the tested value must be less than the represented value. AHRI
commented that this was deemed appropriate by the Working Group after
lengthy discussion about the substantial burden retesting on the
industry. AHRI commented that the ratings and sampling methods embodied
in AMCA Publication 211, ``Certified Ratings Program Product Rating
Manual for Fan Air Performance,'' have long been used and have been
offered for regulatory purposes. AHRI does not support DOE's proposal
that a minimum sample size of two units would be used when making
representations of FEP, FEI, and BHP, as applicable, be required when
that was explicitly recommended against by the cognizant Working Group.
AHRI added that DOE has offered no data or analysis that the agreed
upon methodology would be insufficient or deviate substantially from
current practices. (AHRI, No. 40 at p. 7)
ebm-papst commented that they were unable to see through the
complexities and important nuances of the AEDM and the statistical
procedures that the NOPR proposed to implement. Instead, ebm-papst
recommended adoption of AMCA 211 certification program into this fan
rulemaking. (ebm-papst, No. 31 at p. 13)
Rheem commented that having multiple samples can be beneficial
(Public Meeting Transcript, No 42 at pp. 85-86)
For fans and blowers other than air circulating fans, DOE is
following the recommendation of the Working Group (Docket No. EERE-
2013-BT-STD-0006, No. 179, Recommendation #23 at p. 12) and providing
the option to test a minimum of one unit, where the tested value must
be less than the represented value. If, however, a fan manufacturer
chooses to certify compliance of a basic model based on the test result
of a single unit, DOE notes that it may consider using a minimum sample
size of one unit for enforcement testing, and if a single unit of this
fan basic model does not meet the applicable Federal energy
conservation standard, the fan basic model will be considered non-
compliant. If a manufacturer chooses to certify compliance of a basic
model based on the test result of a sample of more than one unit, DOE
may consider performing enforcement testing based on a sample of more
than one unit. As discussed in section III.K, DOE is not adopting
enforcement provisions in this document and will address enforcement
provisions in a future energy conservations standards rulemaking.
As stated, the Working Group did not provide recommendations to
address a situation in which a manufacturer chooses to increase their
test sample size, specifically in terms of the methodology to use when
averaging the FEI of two or more duty points, which may not be exactly
at the same flow and pressure due to testing variations. To address the
situation where a manufacturer may choose to increase the test sample,
DOE adds provisions to clarify how to perform the average FEI
calculation: for each speed and flow value for which the manufacturer
chooses to make a representation, the average FEI is the average of the
FEI determined by each test and the duty point is defined as the value
of speed, flow, and average of the pressures determined by each test.
DOE notes that AMCA 214-22 provides methods to convert performance data
from one speed to another speed (see Annex G and Annex H of AMCA 214-22
as well as section 7.9.1 of AMCA 210-216), as well as interpolation
methods to determine the performance along the fan curve (i.e., at any
flow value) at a given speed.\122\ Therefore, separate test results can
be converted to the same flow and speed. The remaining pressure value
would then be averaged to provide the average duty point pressure.
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\122\ Sections 7.13.1 and 7.13.2 of AMCA 214-22 state: ``If
needed, duty points between laboratory tested points
(determinations), are obtained by fitting a cubic polynomial based
on the four closest determinations.''
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Regarding the use of historical test data, DOE understands that
manufacturers of fans and blowers likely have historical test data
which were developed with methods consistent with the DOE test
procedure being adopted in this final rule. DOE does not expect
manufacturers to regenerate all of the historical test data unless the
rating resulting from the historical methods, which is based on the
same methodology being adopted in this final rule, would no longer be
valid.
Regarding the use of AMCA 211-22, DOE develops its own
certification, compliance, and enforcement provisions and will consider
the provisions in AMCA 211-22 to the extent possible in a separate
certification-focused rulemaking.
AHAM commented that deviation from an agreed-upon term sheet
diminished the value of participating in ASRAC negotiations and could
result in reduced interest in participating in such negotiations in the
future. AHAM stated that stakeholders from all perspectives (e.g.,
manufacturers, efficiency advocates, States, and utilities) and DOE
alike see value in that process. AHAM commented that they are a strong
supporter of negotiated standards--both through the ASRAC process and
through ``private'' negotiations among stakeholders with various points
of view. (AHAM, No. 35 at p. 9)
AMCA commented that, DOE always reserves and retains the right to
diverge from the ASRAC consensus, but in the interest of encouraging
future participation in a process generally acknowledged to be a
classic example of good regulatory policy and practice, DOE last-minute
divergence in fundamental ways from the ASRAC consensus (especially
where that consensus has been used as a guide for the more rapidly
developed related regulation in California) will only serve as a
disincentive for future parties to participate in ASRAC negotiations.
(AMCA No. 41 at p. 3)
DOE notes that the adopted provisions to allow a sample of at least
one unit aligns with the term sheet. As noted throughout the notice,
DOE aligned with the recommendations of
[[Page 27378]]
the term sheet except on the metric (FEI vs. FEP), where DOE aligned
with the latest industry standard. See section III.G.1 of this
document. DOE established the ASRAC in an effort to further improve
DOE's process of establishing energy efficiency standards for certain
appliances and commercial equipment. ASRAC allows DOE to use negotiated
rulemaking as a means to engage all interested parties, gather data,
and attempt to reach consensus on establishing energy-efficiency
standards.
For air circulating fans, DOE did not receive any comments specific
to the sampling plan. For air circulating fans, the metric is evaluated
at a single operating point (i.e., maximum speed, See Section III.G.2
of this document) and each basic model's performance is represented by
a single rating. This metric approach is different from the one used
for fans blowers other than air circulating fans where the metric is
evaluated at each of the fan's operating points within the range of air
power and shaft input power in scope (i.e., at each duty point, as
specified by the manufacturer within the range of air power and shaft
input power in scope; see Section III.B.1 of this document) and
requires the determination of the FEI at each duty point as specified
by the manufacturer, resulting in multiple FEI ratings for the same
basic model. For this reason, DOE believe it is appropriate to allow a
minimum of one unit for fans and blowers other than air circulating
fans, and to require a minimum of two units for air circulating fans.
Thus, DOE is requiring a minimum of two units, as proposed in the July
2022 NOPR. As noted, a minimum of two units is consistent with the
statistical sampling requirements in place for other commercial and
industrial equipment regulated by DOE.\123\
---------------------------------------------------------------------------
\123\ The general sampling requirement currently applicable to
all covered products and equipment provides that a sample of
sufficient size must be randomly selected and tested to ensure
compliance and that, unless otherwise specified, a minimum of two
units must be tested to certify a basic model as compliant. See 10
CFR 429.11.
---------------------------------------------------------------------------
K. Enforcement Provisions
In the July 2022 NOPR, DOE proposed to add specific enforcement
testing provisions for fans and blowers at 10 CFR 429.110 and proposed
that DOE would use an initial sample size of not more than four units
and would determine compliance based on the arithmetic mean of the
sample. This is similar to existing enforcement testing provisions for
pumps and HVACR equipment. DOE also proposed to add product-specific
enforcement provisions for fans and blowers other than air circulating
fans to specify that: (1) geometric similarity of two or more fans will
be verified by requiring that the manufacturer provides all fan design
dimensions as described in Annex K of AMCA 214-21; and (2) DOE will
test each fan basic model according to the test method (specified by
the manufacturer in any certification report (i.e., based on section
6.1, 6.2, 6.3, or 6.4 of AMCA 214-21). 87 FR 44194, 44243.
DOE did not receive any comments specific to this issue. In this
final rule, DOE is not adopting enforcement provisions as proposed in
the July 2022 NOPR. At this time, DOE has not established any energy
conservation standards for fans and blowers and will consider
establishing enforcement provisions as part of any future energy
conservation standards rulemaking.
L. Effective and Compliance Dates
The effective date for the adopted test procedure will be 30 days
after publication of this final rule in the Federal Register. EPCA
prescribes that all representations of energy efficiency and energy
use, including those made on marketing materials and product labels,
for certain equipment, including fans and blowers, must be made in
accordance with an amended test procedure, beginning 180 days after
publication of the final rule in the Federal Register. (42 U.S.C.
6314(d)(1)) EPCA provides an allowance for individual manufacturers to
petition DOE for an extension of the 180-day period if the manufacturer
may experience undue hardship in meeting the deadline. (42 U.S.C.
6314(d)(2)) To receive such an extension, petitions must be filed with
DOE no later than 60 days before the end of the 180-day period and must
detail how the manufacturer will experience undue hardship. (Id.)
AMCA commented that if DOE's test procedure results in a
comprehensive need for industry testing, there would not be sufficient
throughput to meet, for example, a 180-calendar-day deadline. In
actuality, it would likely take years for industry to retest
everything. (AMCA No. 41, at p. 40)
JCI stated that it shares AMCA's comments regarding the 180-day
compliance window between rule finalization and the effective date
which is not possible for a product sector being regulated for the
first time under the proposed NOPR requirements; either the proposed
test procedures need to be revised or the time period needs to be
extended to 6 years. (JCI, No. 34 at p. 2)
DOE understands that manufacturers of fans and blowers likely have
historical test data which were developed with methods consistent with
the DOE test procedure being adopted in this final rule. DOE notes that
it does not expect manufacturers to regenerate all of the historical
test data, unless the rating resulting from the historical methods,
which is based on the same methodology being adopted in this final
rule, would no longer be valid. EPCA provides a 180-day timeline for
all representations regarding energy consumption or the cost of energy
consumed by fans and blowers to be made according to the DOE test
procedure. (42 U.S.C. 6314(d)(1)) This is a statutory requirement and
not a timeline chosen by DOE.
AHRI commented that once the test procedure is finalized, fan
manufacturers will have 180 days to comply with the new procedure. AHRI
commented that this is an unrealistic timeline. AHRI commented that
component fans that were once available for a product's full operating
range may no longer be available and OEMs will not have the information
about market availability of new component fans until well after the
motor has been tested and certified. AHRI added that after assessing
the availability on the market, OEMs may have to redesign equipment to
accommodate for a different motor size, which could also negatively
impact performance and efficiency. AHRI stated that redesign and
testing take years to complete, and the information required for this
equipment assessment will not be available until after fan
manufacturers are actually complying with the test procedure. (AHRI,
No. 40 at p. 9) AHRI added detailed descriptions and estimates of the
costs to incorporate a redesigned fan into an OEM equipment. (AHRI, No.
40 at pp. 9-10)
As discussed previously, EPCA prescribes that all representations
for fans and blowers must be made in accordance with an amended test
procedure, beginning 180 days after publication of the final rule in
the Federal Register. (42 U.S.C. 6314(d)(1)) At this time, DOE is not
adopting energy conservation standards for fans and blowers, and the
test procedure would not impact the availability of current models. The
test procedure does not set any energy conservation standards and does
not result in any non-compliant fans.
M. Test Procedure Costs and Impacts
As previously discussed, DOE is establishing a test procedure for
fans and blowers at 10 CFR part 431, subpart J and a new appendix A and
appendix
[[Page 27379]]
B. Additionally, DOE is (1) adopting through reference the test methods
in AMCA 214-21 and AMCA 230-23, with certain modifications; (2)
adopting through reference certain test procedure provisions in AMCA
210-16; and (3) specifying FEP and FEI, based on AMCA 214-21, and CFM/
W, based on AMCA 230-23, as the relevant metrics. DOE is also adding
section 69 to 10 CFR part 429, which adds fan and blower sampling
requirements and provisions related to determining represented values,
and is adding paragraph (n) to 10 CFR 429.70, which specifies
alternative efficiency determination method requirements. DOE has
determined that the test procedure would impact testing costs as
discussed in the following paragraphs.
By adopting industry standards, DOE has determined that the test
procedure in this final rule would be reasonably designed to produce
test results that reflect energy efficiency and energy use of fans and
blowers during a representative average use cycle and that would not be
unduly burdensome for manufacturers to conduct. In the July 2022 NOPR,
DOE presented costs associated with performing testing according to the
proposed test procedure at third-party testing facilities (i.e.,
facilities that are not operated by the manufacturer whose product is
being tested). 87 FR 44194, 44243.
In the July 2022 NOPR, DOE assumed that both AMCA and non-AMCA
members could test products at the AMCA testing facilities, with non-
AMCA member costs being double the cost of AMCA members. 87 FR 44194,
44243. DOE has since learned that it is uncommon for the AMCA testing
facility to test non-AMCA member products. In the July 2022 NOPR, DOE
had estimated that 40 percent of fan manufacturers are not AMCA
members. Id.
In the July 2022 NOPR, DOE had expected that manufacturers could
have substantial initial capital costs if they established a test
laboratory capable of testing to the proposed test procedure; however,
DOE had anticipated that the cost to perform a test would be less for
in-house testing than for third-party testing. Id. In other words, DOE
had expected that over the lifetime of a new test laboratory, the
initial capital costs would be less than the total cost of third-party
testing.
In the July 2022 NOPR, DOE provided estimated costs for testing
fans at third-party laboratories; however, based on stakeholder
comments, DOE anticipates that the cost to perform a test would be less
for in-house testing than for third-party testing. Id. DOE requested
feedback on its assumption that it would cost an average of $4,200 to
test one fan for both general fans and air circulating fans. DOE also
requested feedback on the method described for estimating manufacturer
per-model testing costs of general fans and air circulating fans.
Additionally, DOE requested feedback and data on the total testing
costs per basic model for testing at third-party facilities and on
third-party laboratory testing costs (other than AMCA). Id.
AMCA commented that testing for air circulating fans per AMCA 230
would cost $1,420 per fan with an added cost of $350 per fan speed.
(AMCA, No. 41 at p. 35) Additionally, AMCA provided an estimated cost
of $6,300 to test a general fan. (AMCA, No. 41 at p. 40) New York
Blower commented that the third-party testing costs were reasonable.
(New York Blower, No. 33 at p. 22). AMCA, New York Blower, and Morrison
commented that DOE did not consider the cost to ship fans to third-
party facilities in its estimated test costs. (AMCA, No. 41 at p. 40;
New York Blower, No. 33 at p. 22; Morrison, No. 42 at p. 12).
AMCA also commented that BESS Labs traditionally tests circulating
fans; however, AMCA's policy is not to report on other organizations'
pricing, so it did not provide details on BESS Labs and its testing
programs. (AMCA, No. 41 at p. 40). JCI commented that there are limited
laboratory facilities available for testing. (JCI, No. 34 at p. 1) DOE
recognizes that third-party testing is currently not widely available
and is not aware of any third-party testing facilities that can
accommodate both general fans and air circulating fans aside from
AMCA's testing facilities; therefore, DOE has updated its cost
estimates to recognize that some fan manufacturers may need to build a
test lab to test and certify fans according to the DOE test procedure.
Based on DOE's additional evaluation, and from stakeholder
comments, in this final rule, DOE presents costs for building an in-
house test facility to obtain representative efficiency values for fans
and blowers according to the test procedure. As such, DOE has assumed
that the in-house facilities would be connected to or within reasonable
distance to the manufacturer production facility to eliminate the need
to ship fans to the test lab. DOE has worked to minimize testing burden
while maintaining the rigor of the test procedure is this final rule
by: (1) requiring a minimal certification sample size of one unit per
basic model, reduced from a minimum of two proposed in the July 2022
NOPR (87 FR 44194, 44243); (2) requirements for testing with
appurtenances is now consistent with AMCA 210-16 and AMCA 230-23, which
allows manufacturers to use historical data; (3) clarifying the
definition of a basic model that was proposed in the July 2022 NOPR (87
FR 44194, 44213); and (4) allowing the use of AEDMs in lieu of testing.
DOE addresses cumulative costs and burden and discusses its estimated
test costs in detail in the following sections. Ultimately, DOE has
determined that the costs to conduct the test procedure in this final
rule do not outweigh the benefits and that the text procedure is not
unduly burdensome for manufacturers to conduct.
1. Cumulative Costs and Burden
In response to the July 2022 NOPR, stakeholders commented that
cumulative testing costs and burden would be significant based on the
proposed test procedure.
Morrison commented that they estimate testing to take from 3 to 5
years and would require expanding lab operation and personnel.
(Morrison, No. 42 at p. 12) Morrison additionally stated that they
would need to test each of their thousands of basic models two times.
Id. Additionally, Morrison stated that by dedicating more time to
testing, they would not be able to dedicate as much time to customer
development or research and design. Id. AMCA commented that it would
take longer than 180 days, and most likely years, for the industry to
retest all fans, either at a third-party lab or at an in-house
laboratory. (AMCA, No. 41 at pp. 40-41) AMCA also stated that the
amount of time required to test fans is dependent on the number of
basic models. Id. JCI stated that they expect the cumulative test cost
to be in the tens of millions of dollars and to take 6 years to
complete. (JCI, No. 34 at p.1) AHRI commented that it would likely take
fan manufacturers longer than 180 days after the test procedure is
finalized to begin certifying fans. (AHRI, No. 40 at pp. 9-11) New York
Blower commented that the cumulative testing burden would be
significant when the number of basic models, samples, and appurtenances
are considered. (New York Blower, No. 33 at p. 4)
New York Blower additionally commented that the proposed test
procedure would not allow manufacturers to use historical test data and
that manufacturers need to use historical test data to comply with
standards in time. (New York Blower, No. 33 at p. 4)
DOE understands the comments from stakeholders to be in response to
DOE's
[[Page 27380]]
proposal in the July 2022 NOPR to require a minimum of two samples to
rate a basic model. 87 FR 44194, 44243. Additionally, DOE recognizes
that the concerns over test costs and burden may be in response to
DOE's proposals for testing with appurtenances (87 FR 44194, 44226),
testing air circulating fans at multiple speeds (87 FR 44194, 44227),
and DOE's consideration of a WFEI metric for fans and blowers that are
not air circulating fans (87 FR 44194, 44237-44238) in the July 2022
NOPR.
In response to stakeholder concerns regarding cumulative test costs
and burden, DOE is providing the option to test a minimum of one unit,
rather than two units, for rating and certification (see Section
III.J). As discussed in section III.E.12, DOE is aligning the
provisions for testing with appurtenances with industry test standards
AMCA 214-21 and AMCA 230-23. Finally, DOE is requiring that air
circulating fans be tested at a single speed, as discussed in section
III.E.14 of this document. As a result, DOE expects that manufacturers
may use historical test results and the cumulative test cost and the
time required to test products will be substantially decreased.
Furthermore, DOE notes that the deadline for manufacturers to
comply with the test procedure 180 days after it is published is for
voluntary representations, which is further discussed in section III.L
of this document. If DOE were to set standards for general fans and air
circulating fans, certification based on the sampling plan discussed in
section III.J would be required on the compliance date of the standard,
which could be between 3 and 5 years after the publication date of the
energy conservation standards final rule.
JCI commented that the cost of testing was underestimated and that
DOE did not consider the cost of building prototypes for test. (JCI,
No. 34 at p. 1) Robinson stated that DOE did not consider the cost of
building a custom fan in duplicate to test (Robinson, No. 43 at p. 12).
The test procedure that DOE is adopting is non-destructive, meaning
that test does not alter the operation and performance of the fan;
therefore, DOE does not see a reason for that a prototype or duplicate
fan needs to be produced solely for testing DOE is not including the
cost of the fan in its updated test procedure cost estimates.
2. Estimated Costs for Building and Testing of Fans and Blowers Other
Than Air Circulating Fans at an In-House Facility
a. Capital Costs
In the maximum-burden case where a fan manufacturer would be
required to construct a test lab from scratch, manufacturers would be
required to make capital outlays to acquire or build a testing facility
and purchase test equipment. DOE has estimated costs for fans based on
the AMCA 210-16 industry standard that DOE is referencing in this final
test procedure. DOE estimated minimum and maximum costs, then used
these two values to determine an average cost.
To estimate the costs to build an in-house testing facility, DOE
assumed a single-story building built in the U.S. using 2022 costs. DOE
estimated test facility square footage by using information from
manufacturers and by evaluating outlet duct setups in AMCA 210-16, with
length and width buffers applied. DOE estimated an average floor area
of 3,450 square feet.\124\ Using this average square footage value, DOE
estimated a one-time building cost for warehouse and storage to be
$321,000.\125\
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\124\ DOE used the AMCA 2012 general fans database to estimate
the maximum diameter of a general fan. DOE then used the maximum
diameter to determine the floor area necessary to build a main
chamber and ductwork in accordance with the test set-ups in AMCA
210-16 with a buffer of 5 times the estimated area. DOE calculated
the average floor area to be 6,500 square feet, which DOE then used
as the maximum square footage value. DOE used 400 square feet as the
minimum floor area, which DOE determined from communication with
manufacturers. DOE calculated the average of these two values to
estimate an average floor area of 3,450 square feet ((6,500 + 400) /
2 = 3,450).
\125\ DOE estimated the building cost for warehouse and storage
based on the RSMeans Facilities Construction Cost Data (2011). DOE
then used the Federal Reserve Economic Data's ``Producer Price Index
by Industry: Fan, Blower, Air Purification Equipment Manufacturing''
to account for inflation to 2022 prices. (https://fred.stlouisfed.org/series/PCU333413333413)
---------------------------------------------------------------------------
DOE has identified that the test structure to test in accordance
with AMCA 210-16 would consist of a traverse pitot duct and a main
chamber. DOE has estimated that the average one-time cost for the
traverse pitot duct and the main chamber would be $1,800.
The test procedure for fans and blowers other than air circulating
fans, which aligns with AMCA 210-16, requires pressure, flow, power,
and air density to be measured or calculated by equipment with specific
calibrations and accuracies. The cost of this test equipment is
considered as a one-time cost. The pressure measurement requires a
manometer and a pitot-static tube. DOE has estimated the average cost
of a manometer to be $590 and the average cost of a pitot-static tube
to be $290. Flow can also be measured with the pitot-static tube.
According to AMCA 210-16, power can be determined indirectly or
directly. The indirect determination of power requires force or torque
measurements by either a reaction dynamometer or torque meter,
respectively, and power is calculated using equations in AMCA 210-16.
The direct measurement of power requires either a calibrated motor or
an electric meter. DOE has assumed that a testing facility would have
all equipment necessary to determine power either directly or
indirectly (i.e., a reaction dynamometer, torque meter, calibrated
motor and electric meter) to provide testing flexibility. This
assumption is also the most conservative. DOE has estimated the average
costs of a reaction dynamometer to be $5,700, a torque meter to be
$1,600, a calibrated motor to be $1,700, and an electric meter to be
$9,700. The air density is calculated using measurements of air
temperature with a thermometer and pressure with a barometer. DOE has
estimated the average costs of a thermometer to be $600 and a barometer
to be $330. In sum, DOE has estimated that the cost to acquire all of
the necessary test equipment to perform the general fans test procedure
is, on average, $20,500.
In total, DOE has estimated the average capital cost of building an
in-house testing facility for fans as $343,300. DOE notes that some fan
manufacturers have indicated they already have existing facilities and
equipment to test general fans according to AMCA 210-16, which DOE
references in this final test procedure.
b. Annual Costs
DOE has estimated annual costs for operating a testing facility,
which include utilities and equipment calibration. DOE has estimated
that the annual utilities costs would be $8,000,\126\ based on the
average floor area discussed in the previous section. Equipment would
need to be calibrated
[[Page 27381]]
each year, which DOE has estimated to be $21,500 \127\ based on 2016
calibration price lists from the National Institute of Standards and
Technology (``NIST'').
---------------------------------------------------------------------------
\126\ DOE estimated the commercial utility costs to be $0.1122/
kWh using data from EIA's ``2021 Average Monthly Bill'' and
commercial utility use to be 20.70 kWh/square foot using EIA's
``2018 Commercial Buildings Energy Consumption Survey''
(www.eia.gov/electricity/sales_revenue_price/pdf/table5_b.pdf;
https://www.eia.gov/consumption/commercial/data/2018/pdf/CBECS%202018%20CE%20Release%202%20Flipbook.pdf). DOE then calculated
total average commercial utility costs to be $8,000 ($0.1122/kWh x
20.70 kWh/square foot x 3,450 square feet = $8,013).
\127\ DOE estimated the NIST calibration fee from www.nist.gov/system/files/documents/2016/10/31/FeeSchedule-2016.pdf. However,
this catalog does not list calibration prices for the following
equipment: manometer, pitot-static tube, and barometer; therefore,
DOE used similar thermodynamic and mechanical type instruments that
measure velocity of airflow and pressure from NIST.
---------------------------------------------------------------------------
In total, DOE has estimated the annual cost of operating an in-
house testing facility for general fans as approximately $29,500.
c. Testing Costs
This final rule includes requirements regarding the sampling plan
and representations for covered fans at subpart B of 10 CFR part 429.
The sampling plan requirements require a minimum sample size of one
unit per general fan basic model be tested when determining
representative values of FEI, as well as other fan performance metrics.
Fan test costs include the cost of labor to set-up, test, and
disassemble the fan. DOE estimated that it would take an average of 4
hours to set-up and disassemble a general fan and 2 hours to test a
general fan, resulting in a total of 6 hours of labor per test. DOE has
also assumed that a mechanical engineering technician would set-up and
perform the testing. Based on wage and salary data from the Bureau of
Labor Statistics (``BLS''), DOE has estimated a fully burdened hourly
mechanical engineering technician wage of $43.\128\ DOE has calculated
the total cost of labor for testing a general fan to be approximately
$260 per basic model, assuming one fan is tested per basic model.
---------------------------------------------------------------------------
\128\ DOE estimated the hourly wage using data from BLS's
``Occupational Employment and Wages, May 2021'' publication. DOE
used the ``Mechanical Engineering Technologies and Technicians''
mean hourly wage of $30.47 to estimate the hourly wage rate
(www.bls.gov/oes/current/oes173027.htm). Last accessed on April 3,
2023. DOE then used BLS's ``Employer Costs for Employee
Compensation--December 2022'' to estimate that wages and salary
account for approximately 70.5 of employer labor costs for private
industry workers. (www.bls.gov/news.release/pdf/ecec.pdf). Last
accessed on April 3, 2023. Therefore, DOE estimated a fully-burdened
labor rate of $43 ($30.47 / 0.705 = $43.21).
---------------------------------------------------------------------------
d. AEDM Costs
As previously discussed, an AEDM is a mathematical model developed
by a manufacturer that estimates the energy efficiency or energy
consumption characteristics of a basic model as measured by the
applicable DOE test procedure. Before using an AEDM, a fan manufacturer
must validate the AEDM's accuracy and reliability by physically testing
two basic models and comparing the test results to the output of the
AEDM (see discussion in III.I.3 of this document).
In the July 2022 NOPR, DOE assumed a mechanical engineer would
develop and validate a new AEDM. 87 FR 44194, 44243. DOE estimated that
it would take 24 labor hours per validation class for an engineer to
develop and validate an AEDM using existing simulation tools. Id. 87 FR
at 44243-44244. DOE assumed a mechanical technician would implement an
AEDM once it is developed. Id. DOE estimated that it would take a
mechanical technician 1 hour to determine the representative values
necessary to certify a basic model using an AEDM. Id.
In response to the July 2022 NOPR, several stakeholders commented
that DOE underestimated the time it would take to develop an AEDM and
to develop certified ratings from that AEDM. AMCA provided a list of
steps required to validate an AEDM and estimated that it would take 56
working hours to develop an AEDM and 24 working hours to develop
certified ratings. (AMCA, No. 41 at . 42) New York Blower commented
that it would take between 100 and 200 working hours to develop an AEDM
and 3 hours to develop certified ratings because using computational
fluid dynamics to estimate fan performance is complex. (New York
Blower, No. 33 at p. 23) Robinson suggested that it would take on the
order of several days to weeks to develop an AEDM (Robinson, No. 43 at
p. 12) Morrison commented that it would take at least 80 working hours
to develop an AEDM. (Morrison, No. 42 at p. 13) Additionally, the same
stakeholders commented that the development of certified ratings from
an AEDM would need to be done by a mechanical engineer, not a
mechanical technician. (AMCA, No. 41 at . 42; New York Blower, No. 33
at p. 23; Robinson, No. 43 at p. 12; Morrison, No. 42 at p. 12)
After considering stakeholder comments, DOE has updated the costs
to develop, validate, and implement an AEDM. DOE used the values
provided in stakeholder comments to estimate the labor hours required
to develop, validate, and implement an AEDM. Additionally, DOE has
updated its estimates to reflect stakeholder comments that a mechanical
engineer would be required to complete all stages of the AEDM.
For this final rule, DOE assumes a mechanical engineer would
develop, validate, and implement a new AEDM. Based on wage and salary
data from the BLS, DOE estimated the fully burdened hourly mechanical
engineering wage to be approximately $66.\129\ Considering the values
provided in stakeholder comments, DOE estimates an average of 128 labor
hours per validation class for an engineer to develop and validate an
AEDM for general fans using existing simulation tools. Therefore, DOE
estimates the cost of a fully burdened mechanical engineer as
approximately $8,500 per validation class. As discussed in section
III.J.1, testing of two basic models is required to validate an AEDM
for a specific validation class while one unit must be tested per basic
model in order to validate an AEDM. Therefore, two physical tests on
two different basic models are required for validation of a AEDM for
general fans. As discussed previously, DOE estimates the labor cost per
test to be $260. Therefore, the total estimated manufacturer labor cost
to develop and validate an AEDM for a single validation class is
estimated to be $9,020 which is the cost to perform one test on two
basic models ($520) plus the fully burdened cost of a mechanical
engineer's time to develop and validate the AEDM ($8,500).
---------------------------------------------------------------------------
\129\ DOE estimated the hourly wage using data from BLS's
``Occupational Employment and Wages, May 2021'' publication. DOE
used the ``Mechanical Engineers'' mean hourly wage of $46.64 to
estimate the hourly wage rate (www.bls.gov/oes/current/oes172141.htm). Last accessed on April 3, 2023. DOE then used BLS's
``Employer Costs for Employee Compensation--December 2022'' to
estimate that wages and salary account for approximately 70.5
percent of employer labor costs for private industry workers.
(www.bls.gov/news.release/pdf/ecec.pdf). Last accessed on April 3,
2023. Therefore, DOE estimated a fully-burdened labor rate of $66
($46.64 / 0.705 = $66.16).
---------------------------------------------------------------------------
DOE also assumes a mechanical engineer will implement an AEDM once
it is developed. Using the values provided in stakeholder comments, DOE
estimates that it would take a mechanical engineer an average of 14
labor hours to determine the representative values necessary to certify
a basic model using an AEDM. Therefore, the estimated cost to implement
an AEDM to develop certified ratings is $950 per basic model.
In response to the July 2022 NOPR, AMCA and Robinson commented that
not all manufacturers have the simulation tools necessary to validate
and implement an AEDM. (AMCA, No. 41 at . 42; Robinson, No. 43 at pp.
11-12) DOE acknowledges that computational fluid dynamics (``CFD'')
software is necessary to validate and implement an AEDM for fans and
blowers and has concluded that the cost to purchase the software should
be included as an AEDM one-time cost.
[[Page 27382]]
Robinson estimated that the investment in hardware and software would
be on the order of $125,000. (Robinson, No. 43 at p. 11)DOE reviewed
CFD prices online and found a CFD free of cost,\130\ so used $0 as its
minimum CFD cost and the estimate from Robinson as the maximum cost for
CFD software. DOE averaged these two values to determine an average CFD
software cost of $62,500. DOE estimated the cost of a workstation with
the necessary system requirements to run CFD software to be $3,000,
with a minimum of $1,000 and a maximum of $5,000; however, DOE notes
that many CFD software packages are cloud-and license-based. DOE has
estimated the average cost of CFD software and compatible hardware to
be $65,500 (62,500 + 3,000 = 65,500).
---------------------------------------------------------------------------
\130\ openfoam.org/
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3. Estimated Costs for Building and Testing Air Circulating Fans at an
In-House Facility
In response to the July 2022 NOPR, DOE only received comment from
AMCA containing cost estimates for testing air circulating fans at a
third-party laboratory. To estimate the costs for testing air
circulating fans, DOE used the comment received, its own testing
experience with these fans, information provided by manufacturers
during interviews, and in some cases made assumptions relative to the
values estimated for general fans.
a. Capital Costs
In the maximum-burden case where ACF manufacturers would have to
construct a test lab from scratch, manufacturers would be required to
make capital outlays to acquire or construct a test facility and
purchase test equipment. DOE has estimated its test costs for ACFs
based on the AMCA 230-23 industry standard that DOE is referencing in
this final rule. DOE estimated a minimum and maximum costs, then used
these two values to determine an average cost.
To estimate building costs of an in-house testing facility, DOE
assumed a single-story building in the U.S. using 2022 costs. DOE
estimated test facility square footage by using information from
manufacturers and by evaluating standard setups in AMCA 230-23, with
length and width buffers applied. DOE estimated an average floor area
315 square feet.\131\ Using this average square footage value, DOE has
estimated one-time building cost for warehouse and storage to be
$29,300.
---------------------------------------------------------------------------
\131\ DOE used its air circulating fan database to estimate the
average and maximum diameter of an ACF to be 40 inches and 61
inches, respectively. DOE then used these diameters to determine the
floor area necessary to build a test structure for each fan in
accordance with the test set-ups in AMCA 230-23 with a buffer of
1.2. DOE calculated the average floor area to be 180 square feet and
the maximum floor area to be 430 square feet. DOE then took the
average of these two values to estimate that the average floor area
would be 315 square feet ((180 + 430) / 2 = 315).
---------------------------------------------------------------------------
DOE has identified that the test structure to test in accordance
with AMCA 230-23 would consist of a lever arm and a test station. DOE
has estimated that the average one-time cost for the lever arm and the
test station would be $400.
The test procedure for ACFs, which aligns with AMCA 230-23,
requires thrust, power, and air density to be measured or calculated by
equipment with specific calibrations and accuracies. The cost of this
test equipment is considered as a one-time cost. According to the test
procedure, thrust can be measured with a load cell or standard weights.
DOE has assumed that a testing facility should be equipped with both
equipment types to accommodate various testing configurations and to
take a conservative approach. DOE has estimated the cost of a load cell
to be $1,500 and a set of standard weights to be $1,300. The power
measurement is taken directly from an electric meter, which DOE has
estimated to cost $9,700. The air density is calculated using
measurements of air temperature with a thermometer and pressure with a
barometer. DOE has estimated the costs of a thermometer to be $600 and
a barometer to be $330. In sum, DOE has estimated that the cost to
acquire all the necessary test equipment to perform the ACF test
procedure is, on average, $13,430.
In total, DOE has estimated the capital cost of building an in-
house testing facility for ACFs, on average, as $43,130. DOE notes that
some fan manufacturers have indicated they already have existing
facilities and equipment to test ACFs according to AMCA 230-23, which
DOE references in this final test procedure.
b. Annual Costs
DOE has estimated annual costs for operating a testing facility,
which include utilities and equipment calibration. DOE has estimated
that the annual utilities costs would be $730,\132\ based on the
average floor area discussed in the previous section. Equipment would
need to be calibrated each year, which DOE has estimated to be $16,600
based on 2016 calibration price lists from NIST.\133\
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\132\ DOE estimated the commercial utility costs to be $0.11/kWh
using data from EIA's ``2021 Average Monthly Bill'' and commercial
utility use to be 20.70 kWh/square foot using EIA's ``2018
Commercial Buildings Energy Consumption Survey'' (www.eia.gov/electricity/sales_revenue_price/pdf/table5_b.pdf; www.eia.gov/consumption/commercial/data/2018/ppt/CBECS%202018%20C&E%20Flipbook.ppt). DOE then calculated total
average commercial utility costs to be $730 ($0.1122/kWh x 20.70
kWh/square foot x 315 square feet = $731).
\133\ DOE estimated the NIST calibration fee from www.nist.gov/system/files/documents/2016/10/31/FeeSchedule-2016.pdf. However,
this catalog does not list calibration prices for barometers;
therefore, DOE used pricing for similar thermodynamic instruments.
---------------------------------------------------------------------------
In total, DOE has estimated the annual cost of operating an in-
house testing facility for ACFs as approximately $17,330.
c. Testing Costs
This final rule includes requirements regarding the sampling plan
and representations for covered air circulating fans at subpart B of 10
CFR part 429. The sampling plan requires a minimum sample size of one
unit per ACF basic model be tested when determining representative
values of CFM/W, as well as other general fan performance metrics. Test
costs include the cost of labor to set-up, test, and disassemble the
fan. DOE estimated that it would take an average of 4 hours to set-up
and disassemble a fan and 2 hours to test a fan, resulting in a total
of 6 hours of labor per test. DOE has also assumed that a mechanical
engineering technician would set-up and perform the testing. Based on
wage and salary data from the BLS, DOE has estimated a fully burdened
mechanical engineering technician wage of $44 per hour.\134\ DOE has
calculated the total cost of labor for testing an ACF to be
approximately $260 per basic model.
---------------------------------------------------------------------------
\134\ DOE estimated the hourly wage using data from BLS's
``Occupational Employment and Wages, May 2021'' publication. DOE
used the ``Mechanical Engineering Technologies and Technicians''
mean hourly wage of $30.47 to estimate the hourly wage rate
(www.bls.gov/oes/current/oes173027.htm). Last accessed on April 3,
2023. DOE then used BLS's ``Employer Costs for Employee
Compensation--December 2022'' to estimate that wages and salary
account for approximately 70.5 percent of employer labor costs for
private industry workers. (www.bls.gov/news.release/pdf/ecec.pdf).
Last accessed on April 3, 2023. Therefore, DOE estimated a fully-
burdened labor rate of $43 ($30.47 / 0.705 = $43.21).
---------------------------------------------------------------------------
d. AEDM Costs
As discussed previously in section III.M.2.d of this document, DOE
assumes that a mechanical engineer would develop, validate, and
implement a new AEDM. Based on wage and salary data from the BLS, DOE
estimated the fully burdened mechanical engineering wage to be
approximately $66 per
[[Page 27383]]
hour.\135\ Since product lines for air circulating fans are less
complex than those for general fans, DOE also estimates that it would
take roughly half the time to develop an AEDM for ACFs than it would to
develop an AEDM for general fans; therefore, DOE assumed 62 labor hours
per validation class for an engineer to develop and validate an AEDM
for ACFs fans using existing simulation tools. Therefore, DOE estimates
the cost of a fully burdened mechanical engineer as approximately
$4,100 per validation class. As discussed in section III.I.1, testing
of two basic models is required to validate an AEDM for a specific
validation class. One unit must be tested per basic model in order to
validate an AEDM. Therefore, two physical tests on two different basic
models are required for validation of an ACF AEDM. As discussed in the
previous section, DOE estimates the labor cost per test to be $260.
Therefore, the total estimated manufacturer labor cost to develop and
validate an AEDM for a single validation class is estimated to be
$4,620, which is the cost to perform one test on two basic models
($520) plus the fully burdened cost of a mechanical engineer's time to
develop and validate the AEDM ($4,100).
---------------------------------------------------------------------------
\135\ DOE estimated the hourly wage using data from BLS's
``Occupational Employment and Wages, May 2021'' publication. DOE
used the ``Mechanical Engineers'' mean hourly wage of $46.64 to
estimate the hourly wage rate (www.bls.gov/oes/current/oes172141.htm). DOE then used BLS's ``Employer Costs for Employee
Compensation--June 2022'' to estimate that wages and salary account
for approximately 70.5 percent of employer labor costs for private
industry workers. (www.bls.gov/news.release/pdf/ecec.pdf). Last
accessed on April 3, 2023. Therefore, DOE estimated a fully-burdened
labor rate of $66 ($46.64 / 0.705 = $66.16).
---------------------------------------------------------------------------
DOE also assumes a mechanical engineer would implement an AEDM once
it is developed. DOE estimates that it would take a mechanical engineer
7 labor hours to determine the representative values necessary to
certify a basic model using an AEDM. Therefore, the estimated cost to
implement an AEDM to develop certified ratings for ACFs is $460 per
basic model.
Additionally, DOE acknowledges that computational fluid dynamics
software is necessary to validate and implement an AEDM and has
concluded that the cost to purchase the software should be included as
a one-time cost to use AEDMs. Software and hardware requirements and
estimated cost are expected to be similar to that estimated for general
fans (i.e., $63,000).
e. Voluntary Representations
Manufacturers of fans included within the scope of the test
procedure adopted in this final rule would not be required to test fans
and blowers in accordance with the DOE test procedure until the
compliance date of a final rule adopting new energy conservation
standards for fans and blowers. If manufacturers are currently
reporting FEI for fans and blowers that are not air circulating fans or
CFM/W for air circulating fans, they would need to ensure that the
product is tested using the DOE test procedure and any representations
in their marketing materials disclose the results of such test.\136\
Although DOE is not requiring manufacturers to report FEI for fans and
blowers that are not air circulating fans or CFM/W for air circulating
fans prior to the compliance date of any new efficiency standards, DOE
is assuming that manufactures may incur additional costs to remove or
add FEI or CFM/W to their marketing materials to effect voluntary
representations prior to the compliance date and independent of any new
efficiency standards.
---------------------------------------------------------------------------
\136\ If manufacturers voluntarily make representations
regarding the FEI of fans and blowers that are not air circulating
fans or CFM/W of air circulating fans, they would be required to
test according to the DOE test procedure. See 42 U.S.C 6314(d)(1)
---------------------------------------------------------------------------
DOE anticipates that manufacturers currently making voluntary
representations would update their online selection software, online
catalogs, and product labels to remove or update efficiency
representations in accordance with the DOE test procedure. DOE assumes
that manufacturers would only need to update future print marketing
materials, rather than create new materials as a result of the test
procedure. DOE estimates that this effort would consist of no more than
an hour of time for a graphic designer, along with two hours of time
for a web developer, and one hour for a mechanical engineering
technician--for a cost of approximately $195.01--per manufacturer.\137\
If manufacturers decide to voluntarily test their products to provide
an updated representation, manufacturers would incur the previously
estimated testing costs along with this marketing materials related
cost.
---------------------------------------------------------------------------
\137\ Graphic designer salary of $28.83 per hour, web developer
salary of $39.09 per hour, and mechanical technician salary of
$29.07 per hour. Wages account for 70.5 percent of employer labor
costs. DOE estimated the hourly wage using data from BLS's
``Occupational Employment and Wages, May 2021'' publication for each
occupation (www.bls.gov/oes/current/oes172141.htm). Last accessed on
April 3, 2023. DOE then used BLS's ``Employer Costs for Employee
Compensation--December 2022'' to estimate that wages and salary
account for approximately 70.5 percent of employer labor costs for
private industry workers. (www.bls.gov/news.release/pdf/ecec.pdf).
Last accessed on April 3, 2023. ($28.83 + $39.09 * 2 + $30.47)/0.705
= $195.01.
---------------------------------------------------------------------------
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Executive Order (``E.O.'')12866, ``Regulatory Planning and
Review,'' as supplemented and reaffirmed by E.O. 13563, ``Improving
Regulation and Regulatory Review, 76 FR 3821 (Jan. 21, 2011) and E.O.
14094, ``Modernizing Regulatory Review,'' 88 FR 21879 (April 11, 2023),
requires agencies, to the extent permitted by law, to (1) propose or
adopt a regulation only upon a reasoned determination that its benefits
justify its costs (recognizing that some benefits and costs are
difficult to quantify); (2) tailor regulations to impose the least
burden on society, consistent with obtaining regulatory objectives,
taking into account, among other things, and to the extent practicable,
the costs of cumulative regulations; (3) select, in choosing among
alternative regulatory approaches, those approaches that maximize net
benefits (including potential economic, environmental, public health
and safety, and other advantages; distributive impacts; and equity);
(4) to the extent feasible, specify performance objectives, rather than
specifying the behavior or manner of compliance that regulated entities
must adopt; and (5) identify and assess available alternatives to
direct regulation, including providing economic incentives to encourage
the desired behavior, such as user fees or marketable permits, or
providing information upon which choices can be made by the public. DOE
emphasizes as well that E.O. 13563 requires agencies to use the best
available techniques to quantify anticipated present and future
benefits and costs as accurately as possible. In its guidance, the
Office of Information and Regulatory Affairs (``OIRA'') in the Office
of Management and Budget (``OMB'') has emphasized that such techniques
may include identifying changing future compliance costs that might
result from technological innovation or anticipated behavioral changes.
For the reasons stated in the preamble, this final regulatory action is
consistent with these principles.
Section 6(a) of E.O. 12866 also requires agencies to submit
``significant regulatory actions'' to OIRA for review. OIRA has
determined that this final
[[Page 27384]]
regulatory action does not constitute a ``significant regulatory
action'' under section 3(f) of E.O. 12866. Accordingly, this action was
not submitted to OIRA for review under E.O. 12866.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of a final regulatory flexibility analysis (FRFA) for any
final rule where the agency was first required by law to publish a
proposed rule for public comment, unless the agency certifies that the
rule, if promulgated, will not have a significant economic impact on a
substantial number of small entities. As required by Executive Order
13272, ``Proper Consideration of Small Entities in Agency Rulemaking,''
67 FR 53461 (August 16, 2002), DOE published procedures and policies on
February 19, 2003, to ensure that the potential impacts of its rules on
small entities are properly considered during the DOE rulemaking
process. 68 FR 7990. DOE has made its procedures and policies available
on the Office of the General Counsel's website: www.energy.gov/gc/office-general-counsel. DOE reviewed this final rule under the
provisions of the Regulatory Flexibility Act and the procedures and
policies published on February 19, 2003.
DOE has determined that the only non-voluntary costs imposed by
this test procedure would be changes to marketing materials for
companies currently making efficiency representations--constituting
$195.01 per manufacturer as estimated previously. This cost is not
expected to differ between small and large manufacturers. The testing
costs estimated previously would either be imposed following possible
new energy conservation standards on covered fans and blowers or
voluntarily undertaken by manufacturers. As such, DOE has concluded
that there would not be significant economic impact on small entities
as a result of this test procedure. Still, although such is not
currently required, DOE has recently conducted a focused inquiry into
small business manufacturers of the fans and blowers covered by this
rulemaking in relation to the test procedure related costs that would
be imposed as a result of possible future energy conservation
standards.
DOE used the Small Business Administration (SBA) size standards to
determine whether any small entities would be subject to the
requirements of the proposed rule. The small business size standards
are listed by North American Industry Classification System (``NAICS'')
code as well as by industry description and are available at
www.sba.gov/document/support--table-size-standards. Manufacturing
commercial and industrial fans and blowers is classified under NAICS
333413, ``Industrial and Commercial Fan and Blower and Air Purification
Equipment Manufacturing.'' The SBA sets a threshold of 500 employees or
fewer for an entity to be considered as a small business for this
category. DOE used a combination of publicly available information and
a private stakeholder database to create a list of potential
manufacturers. DOE additionally referenced manufacturer lists for
similar products derived from Compliance Certification Database.\138\
Once DOE created a list of potential manufacturers, DOE used market
research tools to determine whether any met the SBA's definition of a
small entity, based on the total number of employees for each company
including parent, subsidiary, and sister entities.
---------------------------------------------------------------------------
\138\ U.S. Department of Energy Compliance Certification
Database, available at www.regulations.doe.gov/certification-data/products.html.
---------------------------------------------------------------------------
Based on DOE's analysis, over 200 companies potentially selling
commercial and industrial fans and blowers covered by this proposed
test procedure were identified. DOE screened out companies that do not
meet the small entity definition and additionally screened out
companies that are largely or entirely foreign owned and operated. Of
the identified companies, 51 were further identified as a potential
small business manufacturing commercial and industrial fans and
blowers. Through a review of each business' respective website DOE
established that 20 of the 51 businesses were distinct OEMs directly
producing covered equipment. Below is a discussion of the various
potential testing costs associated with these small manufacturers and
potential future energy conservation standards for fans and blowers.
1. Creation of Testing Facility--General Fans
DOE does not expect costs for a test facility to differ between
large and small businesses. As outlined in section III.M of this
document, DOE estimated the capital investment for a new general fan
testing facility and equipment to be $343,300 along with approximately
$8,000 in yearly utility costs and $21,500 in yearly calibration costs.
2. AEDM Creation and Testing Costs--General Fans
DOE likewise does not expect that general fan per model in-house
testing costs or AEDM creation costs would differ between large and
small manufacturers. As outlined in section III.M, DOE estimated the
average total labor cost of testing a covered general fan to be $260
per model (Which will need to be done for two basic models per
validation class) and approximately $8,700 to develop the AEDM for a
validation class--for a total of $9,220.
Due to the lack of a model database and the large number of
potential small businesses, DOE reviewed the websites and, where
available, the product catalogs of each of the small businesses
manufacturers. While detailed product information was not availiable
for three of the sampled small businesses, DOE identified, maximally,
2,709 models of commercial and industrial fans and blowers that are
covered by the proposed test procedure across the remaining 17 small
businesses. The number of models identified ranged from 7 to 636 across
the applicable manufacturers, for an average of 159 and a median of 40
models per manufacturer. Across all 20 small business manufacuters, DOE
estimates that 65 AEDMs would be required--with manufacturers offering
between one and six of the general fans categories covered by this
rulemaking, for a median value of two. Accordingly, DOE has estimated
that total unit testing and AEDM creation costs would be $599,300 for
all small businesses.
3. Creation of Testing Facility--Air Circulating Fans
DOE does not expect costs for a test facility for air circulating
fans to differ between large and small businesses. As outlined in
section III.M of this document, DOE estimated the capital investment
for a new air circulating fans testing facility and equipment to be
$43,130 on average, along with approximately $730 in yearly utility
costs and $16,660 in yearly calibration costs.
4. AEDM Creation and Testing Costs--Air Circulating Fans
DOE likewise does not expect that air circulating fans per model
in-house testing costs or AEDM creation costs would differ between
large and small manufacturers. As outlined in section III.M of this
document, DOE estimated the average total labor cost of testing a
covered general fan to be $260 per model (Which will need to be done
for two basic models per validation class) and approximately $4,100 to
develop the AEDM for a validation class--for a total of $4,620.
Out of the 20 small business manufacturers identified, four produce
[[Page 27385]]
covered air circulating fans in addition to general fans. The number of
models offered range from four to 30 and each of these small businesses
only offers one validation category of air circulating fan.
Accordingly, all four small businesses would incur an aggregate
additional $18,480 in testing and AEDM creation costs.
5. Total Costs
Total potential costs to the identified small businesses would be
approximately $7,244,000 and the average cost would be approximately
$381,260. 16 of the small businesses would also incur an average of
$8,000 in yearly utility costs and $21,500 in yearly calibration costs
and four of small businesses would incur around $8,730 in yearly
utility costs and $38,160 in yearly calibration costs. DOE was able to
find annual revenue estimates for 19 of the small businesses. Estimated
one-time testing costs as a pecentage of estimated annual revenue range
widely--from less than one 0.4 percent to 44.6 percent--for an average
of approximately 7.7 percent. Additionally, Manufacturers would not be
required to test their products according to the DOE test procedure
unless and until possible new energy conservation standards are
established. Manufacturers would need to test their products according
to the DOE test procedure if they wish to make representations about
efficiency in their marketing material--as mentioned previously,
updating marketing materials is expected to cost $195.01.
6. Certification Statement
As noted previously, almost no non-voluntary costs are anticipated
as a result of this rulemaking--since testing would not be required
unless and until new energy conservation standards are established for
covered fans and blowers. Based on the de minimis cost impacts, DOE
certifies that this final rule does not have a ``significant economic
impact on a substantial number of small entities,'' and determined that
the preparation of a FRFA is not warranted. DOE will transmit a
certification and supporting statement of factual basis to the Chief
Counsel for Advocacy of the Small Business Administration for review
under 5 U.S.C. 605(b).
C. Review Under the Paperwork Reduction Act of 1995
Although no energy conservation standards have been established for
fans and blowers as of the publication of this final rule,
manufacturers of fans and blowers would need to certify to DOE that
their products comply with any potential future applicable energy
conservation standards. To certify compliance, manufacturers must first
obtain test data for their equipment according to the DOE test
procedures, including any amendments adopted for those test procedures.
DOE has established regulations for the certification and recordkeeping
requirements for all covered consumer products and commercial
equipment, including fans and blowers. (See generally 10 CFR part 429.)
The collection-of-information requirement for the certification and
recordkeeping is subject to review and approval by OMB under the
Paperwork Reduction Act (``PRA''). This requirement has been approved
by OMB under OMB control number 1910-1400. Public reporting burden for
the certification is estimated to average 35 hours per response,
including the time for reviewing instructions, searching existing data
sources, gathering and maintaining the data needed, and completing and
reviewing the collection of information.
Certification data will be required for fans and blowers; however,
DOE is not establishing certification or reporting requirements for
fans and blowers in this final rule. Instead, DOE may consider
proposals to establish certification requirements and reporting for
fans and blowers under a separate rulemaking regarding appliance and
equipment certification. DOE will address changes to OMB Control Number
1910-1400 at that time, as necessary.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
In this final rule, DOE establishes test procedure amendments that
it expects will be used to develop and implement future energy
conservation standards for fans and blowers. DOE has determined that
this rule falls into a class of actions that are categorically excluded
from review under the National Environmental Policy Act of 1969 (42
U.S.C. 4321 et seq.) and DOE's implementing regulations at 10 CFR part
1021. Specifically, DOE has determined that adopting test procedures
for measuring energy efficiency of consumer products and industrial
equipment is consistent with activities identified in 10 CFR part 1021,
appendix A to subpart D, A5 and A6. Accordingly, neither an
environmental assessment nor an environmental impact statement is
required.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4,
1999), imposes certain requirements on agencies formulating and
implementing policies or regulations that preempt State law or that
have federalism implications. The Executive order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the States and
to carefully assess the necessity for such actions. The Executive order
also requires agencies to have an accountable process to ensure
meaningful and timely input by State and local officials in the
development of regulatory policies that have federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations. 65 FR 13735. DOE examined this final
rule and determined that it will not have a substantial direct effect
on the States, on the relationship between the national government and
the States, or on the distribution of power and responsibilities among
the various levels of government. EPCA governs and prescribes Federal
preemption of State regulations as to energy conservation for the
products that are the subject of this final rule. States can petition
DOE for exemption from such preemption to the extent, and based on
criteria, set forth in EPCA. (42 U.S.C. 6297(d)) No further action is
required by Executive Order 13132.
F. Review Under Executive Order 12988
Regarding the review of existing regulations and the promulgation
of new regulations, section 3(a) of Executive Order 12988, ``Civil
Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), imposes on Federal
agencies the general duty to adhere to the following requirements: (1)
eliminate drafting errors and ambiguity; (2) write regulations to
minimize litigation; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. Section 3(b) of Executive Order 12988
specifically requires that Executive agencies make every reasonable
effort to ensure that the regulation (1) clearly specifies the
preemptive effect, if any; (2) clearly specifies any effect on existing
Federal law or regulation; (3) provides a clear legal standard for
affected conduct
[[Page 27386]]
while promoting simplification and burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately defines key terms; and (6)
addresses other important issues affecting clarity and general
draftsmanship under any guidelines issued by the Attorney General.
Section 3(c) of Executive Order 12988 requires Executive agencies to
review regulations in light of applicable standards in sections 3(a)
and 3(b) to determine whether they are met or it is unreasonable to
meet one or more of them. DOE has completed the required review and
determined that, to the extent permitted by law, this final rule meets
the relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (``UMRA'')
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a regulatory action resulting in a rule that may cause the
expenditure by State, local, and Tribal governments, in the aggregate,
or by the private sector of $100 million or more in any one year
(adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820; also available
at www.energy.gov/gc/office-general-counsel. DOE examined this final
rule according to UMRA and its statement of policy and determined that
the rule contains neither an intergovernmental mandate, nor a mandate
that may result in the expenditure of $100 million or more in any year,
so these requirements do not apply.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This final rule will not have any impact on the autonomy or integrity
of the family as an institution. Accordingly, DOE has concluded that it
is not necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (March 18, 1988), that this regulation will not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
J. Review Under Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for agencies to review most
disseminations of information to the public under guidelines
established by each agency pursuant to general guidelines issued by
OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22, 2002), and
DOE's guidelines were published at 67 FR 62446 (Oct. 7, 2002). Pursuant
to OMB Memorandum M-19-15, Improving Implementation of the Information
Quality Act (April 24, 2019), DOE published updated guidelines which
are available at www.energy.gov/sites/prod/files/2019/12/f70/DOE%20Final%20Updated%20IQA%20Guidelines%20Dec%202019.pdf. DOE has
reviewed this final rule under the OMB and DOE guidelines and has
concluded that it is consistent with applicable policies in those
guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OMB,
a Statement of Energy Effects for any significant energy action. A
``significant energy action'' is defined as any action by an agency
that promulgated or is expected to lead to promulgation of a final
rule, and that (1) is a significant regulatory action under Executive
Order 12866, or any successor order; and (2) is likely to have a
significant adverse effect on the supply, distribution, or use of
energy; or (3) is designated by the Administrator of OIRA as a
significant energy action. For any significant energy action, the
agency must give a detailed statement of any adverse effects on energy
supply, distribution, or use if the regulation is implemented, and of
reasonable alternatives to the action and their expected benefits on
energy supply, distribution, and use.
This regulatory action is not a significant regulatory action under
Executive Order 12866. Moreover, it would not have a significant
adverse effect on the supply, distribution, or use of energy, nor has
it been designated as a significant energy action by the Administrator
of OIRA. Therefore, it is not a significant energy action, and,
accordingly, DOE has not prepared a Statement of Energy Effects.
L. Review Under Section 32 of the Federal Energy Administration Act of
1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91; 42 U.S.C. 7101), DOE must comply with section 32 of the
Federal Energy Administration Act of 1974, as amended by the Federal
Energy Administration Authorization Act of 1977. (15 U.S.C. 788;
``FEAA'') Section 32 essentially provides in relevant part that, where
a proposed rule authorizes or requires use of commercial standards, the
notice of proposed rulemaking must inform the public of the use and
background of such standards. In addition, section 32(c) requires DOE
to consult with the Attorney General and the Chairman of the Federal
Trade Commission (``FTC'') concerning the impact of the commercial or
industry standards on competition.
The modifications to the test procedure for fans and blowers
adopted in this final rule incorporates testing methods contained in
certain sections of the following commercial standards: AMCA 214-21,
AMCA 210-16, AMCA 230-23, AMCA 240-15, ISO 5801:2017, ISO 80079-
36:2016, and UL 705. DOE has evaluated these standards and is unable to
conclude whether it fully complies with the requirements of section
32(b) of the FEAA (i.e., whether it was developed in a manner that
fully provides for public participation, comment, and review.) DOE has
consulted with both the Attorney General and the Chairman of the FTC
about the impact on competition of using the methods contained in these
standards and has received no comments objecting to their use.
[[Page 27387]]
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of this rule before its effective date. The report will
state that it has been determined that the rule is not a ``major rule''
as defined by 5 U.S.C. 804(2).
N. Description of Materials Incorporated by Reference
In this final rule, DOE incorporates by reference the following
test standards:
AMCA 214-21 is an industry-accepted test procedure that provides
methods to determine fan electrical shaft power and/or electrical
power, flow, and pressure and calculate the fan energy index (FEI) and
is applicable to product sold in North America. AMCA 214-21 specifies
testing conducted in accordance with other industry-accepted test
procedures (also proposed for incorporation by reference). The test
procedure established by this final rule references various sections of
AMCA 214-21 that address test setup, test conduct, and calculation of
the FEI for fans and blowers other than air circulating fans.
AMCA 210-16 and AMCA 230-23 are industry-accepted test procedures
that provides methods of tests for fans and blowers other than air
circulating fans, and air circulating fans, respectively, in the United
States. These methods are referenced in AMCA 214-21.
AMCA 240-15 is an industry-accepted test procedure that provides
definitions and methods of tests for positive pressure ventilator.
Copies of AMCA 214-21, AMCA 210-16, AMCA 230-23, and AMCA 240-15,
may be purchased from AMCA International at 30 West University Drive,
Arlington Heights, IL 60004-1893, or by going to www.amca.org.
ISO 5801:2017 is the industry-accepted test procedure that provides
methods of tests for fans and blowers that are not air circulating
fans, internationally.
ISO 80079-36:2016, specifies the method and requirements for
design, construction, testing and marking of non-electrical equipment
intended for use in potentially explosive atmospheres.
Copies of ISO 5801:2017 and ISO 80079-36:2016 may be purchased from
International Organization for Standardization, Chemin de Blandonnet 8,
CP 401, 1214 Vernier, Geneva, Switzerland, or by going to www.iso.org.
UL 705-22 provides safety requirements for power ventilators.
Copies of UL 705-2022 can be obtained from UL, 333 Pfingsten Road,
Northbrook, IL, 60062 or www.shopulstandards.com.
V. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this final
rule.
List of Subjects
10 CFR Part 429
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Intergovernmental relations, Reporting and recordkeeping requirements,
Small businesses.
10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation test procedures, Incorporation by
reference, and Reporting and recordkeeping requirements.
Signing Authority
This document of the Department of Energy was signed on April 20,
2023, by Francisco Alejandro Moreno, Acting Assistant Secretary for
Energy Efficiency and Renewable Energy, pursuant to delegated authority
from the Secretary of Energy. That document with the original signature
and date is maintained by DOE. For administrative purposes only, and in
compliance with requirements of the Office of the Federal Register, the
undersigned DOE Federal Register Liaison Officer has been authorized to
sign and submit the document in electronic format for publication, as
an official document of the Department of Energy. This administrative
process in no way alters the legal effect of this document upon
publication in the Federal Register.
Signed in Washington, DC, on April 20, 2023.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
For the reasons stated in the preamble, DOE amends parts 429 and
431 of Chapter II of Title 10, Code of Federal Regulations as set forth
below:
PART 429--CERTIFICATION, COMPLIANCE, AND ENFORCEMENT FOR CONSUMER
PRODUCTS AND COMMERCIAL AND INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 429 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C. 2461 note.
Sec. 429.11 [Amended]
0
2. Section 429.11 is amended in paragraphs (a) and (b)(1) by removing
``429.68'' and adding in its place ``429.69''.
0
3. Add Sec. 429.69 to subpart B to read as follows:
Sec. 429.69 Fans and blowers.
(a) Determination of represented values of fans and blowers other
than air circulating fans. A manufacturer must determine the
represented values for each basic model, either by testing in
conjunction with the applicable sampling provisions or by applying an
AEDM as set forth in this section and in Sec. 429.70(n). Manufacturers
must update represented values to account for any change in the
applicable motor standards in Table 5 of Sec. 431.25 of this chapter
and certify amended values as of the next annual certification (as
applicable).
(1) Testing. (i) If the represented values for a given basic model
are determined through testing, a sample of at least one unit must be
selected and the requirements of Sec. 429.11 apply.
(ii) If only one unit is tested, at each duty point characterized
by a flow and speed value, any represented value of fan electrical
input power (``FEP''), fan shaft input power, or other measure of
energy consumption of a basic model for which consumers would favor
lower values shall be greater than or equal to the tested value.
Represented values must be rounded to the nearest hundredth.
(iii) If only one unit is tested, at each duty point characterized
by a flow and speed value, any represented value of fan electrical
input power (``FEI''), or other measure of energy consumption of a
basic model for which consumers would favor higher values shall be less
than or equal to the tested value. Represented values must be rounded
to the nearest hundredth.
(iv) If more than one unit is tested, at each duty point
characterized by a flow and speed value, any represented value of fan
electrical input power (``FEP''), fan shaft input power, or other
measure of energy consumption of a basic model for which consumers
would favor lower values shall be greater than or equal to the higher
of:
(A) The mean of the sample, where
[GRAPHIC] [TIFF OMITTED] TR01MY23.374
Where is x the sample mean; n is the number of samples, and xi is
the i\th\ sample. Or,
(B) The upper 95 percent confidence limit (UCL) of the true mean
divided by 1.05, where:
[[Page 27388]]
[GRAPHIC] [TIFF OMITTED] TR01MY23.375
and x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.95 is the t statistic for a 95
percent one-tailed confidence interval with n-1 degrees of freedom
(from appendix A of subpart B of this part). Represented values must be
rounded to the nearest hundredth.
(v) If more than one unit is tested, any represented value of the
fan energy index (``FEI''), or other measure of energy consumption of a
basic model for which consumers would favor higher values shall be less
than or equal to the lower of:
(A) The mean of the sample, where
[GRAPHIC] [TIFF OMITTED] TR01MY23.376
Where x is the sample mean; n is the number of samples, and xi is
the i\th\ sample. Or,
(B) The lower 95 percent confidence limit (LCL) of the true mean
divided by 0.95, where:
[GRAPHIC] [TIFF OMITTED] TR01MY23.377
and x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.95 is the t statistic for a 95
percent one-tailed confidence interval with n-1 degrees of freedom
(from appendix A of subpart B of this part). Represented values must be
rounded to the nearest hundredth.
(vi) At each duty point characterized by a flow and speed value,
the representative value of static or total pressure of a basic model
of must be the mean of the tested static or total pressure for each
tested unit. If only one unit is tested, the representative value of
static or total pressure at the duty point of a basic model is the
tested value.
(2) Alternative efficiency determination methods. In lieu of
testing, the represented values for a basic model must be determined
through the application of an AEDM pursuant to the requirements of
Sec. 429.70(n) and the provisions of this section, where: the
represented values of any basic model used to validate an AEDM must be
calculated under paragraph (b)(1) of this section.
(b) Determination of represented values for air circulating fans. A
manufacturer must determine the represented values for each basic
model, either by testing in conjunction with the applicable sampling
provisions or by applying an AEDM as set forth in this section and in
Sec. 429.70(n).
(1) Testing. (i) If the represented values for a given basic model
are determined through testing, the requirements of Sec. 429.11 apply.
(ii) Any represented value of fan electrical input power
(``WE''), or other measure of energy consumption of a basic
model for which consumers would favor lower values shall be greater
than or equal to the higher of:
(A) The mean of the sample, where
[GRAPHIC] [TIFF OMITTED] TR01MY23.378
Where x is the sample mean; n is the number of samples, and xi is
the i\th\ sample. Or,
(B) The upper 95 percent confidence limit (UCL) of the true mean
divided by 1.05, where:
[GRAPHIC] [TIFF OMITTED] TR01MY23.379
and x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.95 is the t statistic for a 95
percent one-tailed confidence interval with n-1 degrees of freedom
(from appendix A of subpart B of this part). Represented values must be
rounded to the nearest hundredth.
(iii) Any represented value of efficacy (Effcirc) or
other measure of energy consumption of a basic model for which
consumers would favor higher values shall be less than or equal to the
lower of:
(A) The mean of the sample, where
[GRAPHIC] [TIFF OMITTED] TR01MY23.380
Where x is the sample mean; n is the number of samples, and xi is
the i\th\ sample. Or,
(B) The lower 95 percent confidence limit (LCL) of the true mean
divided by 0.95, where:
[GRAPHIC] [TIFF OMITTED] TR01MY23.381
and x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.95 is the t statistic for a 95
percent one-tailed confidence interval with n-1 degrees of freedom
(from appendix A of subpart B of this part). Represented values must be
rounded to the nearest hundredth.
(2) Alternative efficiency determination methods. In lieu of
testing, the represented values for a basic model must be determined
through the application of an AEDM pursuant to the requirements of
Sec. 429.70(n) and the provisions of this section, where: the
represented values of any basic model used to validate an AEDM must be
calculated under paragraph (b)(1) of this section.
0
4. Amend Sec. 429.70 is amended by:
0
a. In paragraph (a), removing ``429.65'' and, adding its place,
``429.69''; and
0
b. Adding paragraph (n).
The additions reads as follows:
Sec. 429.70 Alternative methods for determining energy efficiency or
energy use.
* * * * *
(n) Alternative efficiency determination method (AEDM) for fans and
blowers. (1) Criteria an AEDM must satisfy. A manufacturer is not
permitted to apply an AEDM to a basic model of fan or blower to
determine represented values pursuant to this section unless:
(i) The AEDM is derived from a mathematical model that estimates
the energy use characteristics of the basic model as measured by the
applicable DOE test procedure and accurately represents the performance
characteristics of that basic model;
(ii) The AEDM is based on engineering or statistical analysis,
computer simulation or modeling, or other analytic evaluation of actual
performance data; and
(iii) The manufacturer has validated the AEDM in accordance with
paragraph (n)(2) of this section.
(2) Validation of an AEDM. Before using an AEDM, the manufacturer
must validate the AEDM's accuracy and reliability by comparing the
simulated FEI, or simulated efficacy, as applicable, to the tested FEI
or tested efficacy, as applicable (determined by testing), as follows.
(i) Select basic models. For each fan or blower validation class
listed as follows: centrifugal housed fan; radial housed fan;
centrifugal inline fan; centrifugal unhoused fan; centrifugal power
roof ventilator exhaust fan; centrifugal power roof ventilator supply
fan; axial inline fan; axial panel fan; axial centrifugal power roof
ventilator fan; unhoused ACFH; axial housed ACFH; and housed
centrifugal air circulating fan to which the AEDM is applied, a
manufacturer must select at least two basic models compliant with any
energy conservation standards in subpart J of part 431 of this chapter.
In addition, at least one basic model selected for validation testing
should include a motor, or a motor and controller if the AEDM is
applied to a basic model with a motor or to a basic model with a motor
and controller.
(ii) Apply the AEDM to the selected basic models. Using the AEDM,
[[Page 27389]]
calculate the simulated FEI, or efficacy, as applicable, for each of
the selected basic models.
(iii) Testing. Test a sample of units of each of the selected basic
models in accordance with 10 CFR 431.174 and determine the FEI or
efficacy, as applicable, in accordance with Sec. 429.69(a)(1) and
(b)(1) as applicable.
(iv) Compare. The simulated FEI or simulated efficacy, as
applicable, for each basic model must be less than or equal to 105
percent of the FEI or efficacy, as applicable, determined in paragraph
(n)(2)(iii) of this section through testing.
(v) Additional AEDM requirements. When making representations of
values other than FEI (e.g., FEP, fan shaft power) or efficacy (as
applicable) for a basic model that relies on an AEDM, all other
representations are required to be based on the same AEDM results used
to generate the represented value of FEI or efficacy.
(3) Verification of an AEDM--(i) Periodic reviews. Each
manufacturer must periodically select basic models representative of
those to which it has applied an AEDM. The manufacturer must select a
sufficient number of basic models to ensure the AEDM maintains its
accuracy and reliability. For each basic model selected for
verification: subject at least one unit to testing in accordance with
10 CFR 431.174. The provisions in paragraph (n)(2)(iv) of this section
must be met.
(ii) Inspection records. Each manufacturer that has used an AEDM
under this section must have available for inspection by the Department
of Energy records showing:
(A) The method or methods used to develop the AEDM;
(B) The mathematical model, the engineering or statistical
analysis, computer simulation or modeling, and other analytic
evaluation of performance data on which the AEDM is based;
(C) Complete test data, equipment information, and related
information that the manufacturer has generated or acquired pursuant to
paragraphs (n)(2) and (3) of this section; and
(D) The calculations used to determine the simulated FEI or
simulated weighted-average FEI, as applicable, of each basic model to
which the AEDM was applied.
(iii) Simulations. If requested by the Department, the manufacturer
must:
(A) Conduct simulations to predict the performance of particular
basic models of electric motors specified by the Department;
(B) Provide analyses of previous simulations conducted by the
manufacturer; and/or
(C) Conduct testing of basic models selected by the Department.
PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
5. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C. 2461 note.
0
6. Section 431.172 is revised to read as follows:
Sec. 431.172 Definitions.
Air circulating axial panel fan means an axial housed air
circulating fan head without a cylindrical housing or box housing that
is mounted on a panel, orifice plate or ring.
Air circulating fan means a fan that has no provision for
connection to ducting or separation of the fan inlet from its outlet
using a pressure boundary, operates against zero external static
pressure loss, and is not a jet fan.
Air circulating fan discharge area: area of a circle having a
diameter equal to the blade tip diameter.
Air circulating fan outlet area means the gross inside area
measured at the plane of the outlet opening.
Air-cooled steam condenser means a device for rejecting heat to the
atmosphere through the indirect condensing of steam inside air-cooled
finned tubes.
Axial inline fan means a fan with an axial impeller and a
cylindrical housing with or without turning vanes.
Axial panel fans means an axial fan, without cylindrical housing,
that includes a panel, orifice plate, or ring with brackets for
mounting through a wall, ceiling, or other structure that separates the
fan's inlet from its outlet.
Basic model, with respect to fans and blowers, means all units of
fans and blowers manufactured by one manufacturer, having the same
primary energy source, and having essentially identical electrical,
physical, and functional (e.g., aerodynamic) characteristics that
affect energy consumption. In addition:
(1) All variations of blade pitches of an adjustable-pitch axial
fan may be considered a single basic model; and
(2) All variations of impeller widths and impeller diameters of a
given full-width impeller and full-diameter impeller centrifugal fan
may be considered a single basic model.
Box fan means an axial housed air circulating fan head without a
cylindrical housing that is mounted on a panel, orifice plate or ring
and is mounted in a box housing.
Centrifugal housed fan means a fan with a centrifugal or mixed flow
impeller in which airflow exits into a housing that is generally
scroll-shaped to direct the air through a single fan outlet. A
centrifugal housed fan does not include a radial impeller.
Centrifugal inline fan means a fan with a centrifugal or mixed flow
impeller in which airflow enters axially at the fan inlet and the
housing redirects radial airflow from the impeller to exit the fan in
an axial direction.
Centrifugal unhoused fan means a fan with a centrifugal or mixed
flow impeller in which airflow enters through a panel and discharges
into free space. Inlets and outlets are not ducted. This fan type also
includes fans designed for use in fan arrays that have partition walls
separating the fan from other fans in the array.
Cross-flow fan means a fan or blower with a housing that creates an
airflow path through the impeller in a direction at right angles to its
axis of rotation and with airflow both entering and exiting the
impeller at its periphery. Inlets and outlets can optionally be ducted.
Cylindrical air circulating fan means an axial housed air
circulating fan head with a cylindrical housing that is not a Positive
Pressure Ventilator as defined in AMCA 240-15 (incorporated by
reference, see Sec. 431.173).
Evaporative field erected closed-circuit cooling tower means a
structure which rejects heat to the atmosphere through the indirect
cooling of a process fluid stream to a lower temperature by partial
evaporation of an external recirculating water flow.
Evaporative field erected open-circuit cooling tower means a
structure which rejects heat to the atmosphere through the direct
cooling of a water stream to a lower temperature by partial
evaporation.
Fan or blower means a rotary bladed machine used to convert
electrical or mechanical power to air power, with an energy output
limited to 25 kilojoule (kJ)/kilogram (kg) of air. It consists of an
impeller, a shaft and bearings and/or driver to support the impeller,
as well as a structure or housing. A fan or blower may include a
transmission, driver, and/or motor controller.
Fan static air power means the static power delivered to air by the
fan or blower; it is proportional to the product of the fan airflow
rate, the fan static pressure and the compressibility coefficient and
is calculated in accordance with section 7.8.1 of AMCA 210-16
(incorporated by reference, see Sec. 431.173), using static pressure
instead of total pressure.
[[Page 27390]]
Fan total air power means the total power delivered to air by the
fan or blower; it is proportional to the product of the fan airflow
rate, the fan total pressure and the compressibility coefficient and is
calculated in accordance with section 7.8.1 of AMCA 210-16
(incorporated by reference, see Sec. 431.173).
Field erected air-cooled (dry) cooler means a structure which
rejects heat to the atmosphere from a fluid, either liquid, gas or a
mixture thereof, flowing through an air-cooled internal coil.
Field erected evaporative condenser means a structure which rejects
heat to the atmosphere through the indirect condensing of a refrigerant
in an internal coil by partial evaporation of an external recirculating
water flow.
Full-diameter impeller means maximum impeller diameter with which a
given fan or blower basic model is distributed in commerce.
Full-width impeller means the maximum impeller width with which a
given fan or blower basic model is distributed in commerce.
Housed air circulating fan head means an air circulating fan with
an axial or centrifugal impeller, and a housing.
Housed centrifugal air circulating fan means a housed air
circulating fan head with a centrifugal or radial impeller in which
airflow exits into a housing that is generally scroll shaped to direct
the air through a single, narrow fan outlet.
Induced flow fan means a type of laboratory exhaust fan with a
nozzle and windband; the fan's outlet airflow is greater than the inlet
airflow due to induced airflow. All airflow entering the inlet exits
through the nozzle. Airflow exiting the windband includes the nozzle
airflow plus the induced airflow.
Jet fan means a fan designed and marketed specifically for
producing a high velocity air jet in a space to increase its air
momentum. Jet fans are rated using thrust. Inlets and outlets are not
ducted but may include acoustic silencers.
Packaged air-cooled (dry) cooler means a device which rejects heat
to the atmosphere from a fluid, either liquid, gas or a mixture
thereof, flowing through an air-cooled internal coil.
Packaged evaporative closed-circuit cooling tower means a device
which rejects heat to the atmosphere through the indirect cooling of a
process fluid stream in an internal coil to a lower temperature by
partial evaporation of an external recirculating water flow.
Packaged evaporative condenser means a device which rejects heat to
the atmosphere through the indirect condensing of a refrigerant in an
internal coil by partial evaporation of an external recirculating water
flow.
Packaged evaporative open-circuit cooling tower means a device
which rejects heat to the atmosphere through the direct cooling of a
water stream to a lower temperature by partial evaporation.
Power roof ventilator means a fan with an internal driver and a
housing to prevent precipitation from entering the building. It has a
base designed to fit over a roof or wall opening, usually by means of a
roof curb.
Radial-housed fan means a fan with a radial impeller in which
airflow exits into a housing that is generally scroll-shaped to direct
the air through a single fan outlet. Inlets and outlets can optionally
be ducted.
Safety Fan means:
(1) A reversible axial fan in cylindrical housing that is designed
and marketed for use in ducted tunnel ventilation that will reverse
operation under emergency ventilation conditions;
(2) A fan for use in explosive atmospheres tested and marked
according to the English version of ISO 80079-36:2016 (incorporated by
reference, see Sec. 431.173);
(3) An electric-motor-driven-Positive Pressure Ventilator as
defined in AMCA 240-15 (incorporated by reference, see Sec. 431.173);
(4) A fan bearing a listing for ``Power Ventilators for Smoke
Control Systems'' in compliance with UL 705 (incorporated by reference,
see Sec. 431.173); or
(5) A laboratory exhaust fan designed and marketed specifically for
exhausting contaminated air vertically away from a building using a
high-velocity discharge.
Unhoused air circulating fan head means an air circulating fan
without a housing, having an axial impeller with a ratio of fan-blade
span (in inches) to maximum rate of rotation (in revolutions per
minute) less than or equal to 0.06. The impeller may or may not be
guarded.
0
7. Section 431.173 is added to read as follows:
Sec. 431.173 Materials incorporated by reference.
(a) Certain material is incorporated by reference into this subpart
with the approval of the Director of the Federal Register in accordance
with 5 U.S.C. 552(a) and 1 CFR part 51. To enforce any edition other
than that specified in this section, DOE must publish a document in the
Federal Register and the material must be available to the public. All
approved incorporation by reference (IBR) material is available for
inspection at DOE, and at the National Archives and Records
Administration (NARA). Contact DOE at: the U.S. Department of Energy,
Office of Energy Efficiency and Renewable Energy, Building Technologies
Program, 1000 Independence Ave. SW, EE-5B, Washington, DC 20585, (202)
586-9127, [email protected], https://www.energy.gov/eere/buildings/building-technologies-office. For information on the availability of
this material at NARA, visit www.archives.gov/federal-register/cfr/ibr-locations.html or email: [email protected]. The material may be
obtained from the sources in the following paragraphs of this section.
(b) AMCA. Air Movement and Control Association International, Inc.,
30 West University Drive, Arlington Heights, IL 60004-1893; (847) 394-
0150; www.amca.org.
(1) ANSI/AMCA Standard 21016 (``AMCA 210-16''), Laboratory Methods
of Testing Fans for Certified Aerodynamic Performance Rating, ANSI-
approved August 26, 2016; IBR approved for Sec. 431.172; appendix A to
this subpart. (Co-published as ASHRAE 51-16).
(2) ANSI/AMCA Standard 214-21 (``AMCA 214-21''), Test Procedure for
Calculating Fan Energy Index (FEI) for Commercial and Industrial Fans
and Blowers, ANSI-approved March 1, 2021; IBR approved for Sec.
431.174; appendix A to this subpart.
(3) ANSI/AMCA Standard 230-23 (``AMCA 230-23''), Laboratory Methods
of Testing Air Circulating Fans for Rating and Certification, ANSI-
approved February 10, 2023. IBR approved for appendix B to this
subpart.
(4) ANSI/AMCA Standard 240-15 (``AMCA 240-15''), Laboratory Methods
of Testing Positive Pressure Ventilators for Aerodynamic Performance
Rating, ANSI-approved May 9, 2015; IBR approved for Sec. 431.172.
(c) ISO. International Organization for Standardization, Chemin de
Blandonnet 8, CP 401, 1214 Vernier, Geneva, Switzerland; www.iso.org.
(1) ISO 5801:2017(E) (``ISO 5801:2017''), Fans--Performance testing
using standardized airways, Third Edition, approved September 2017; IBR
approved for appendix A to this subpart.
(2) ISO 80079-36:2016, Explosive atmospheres--Part 36: Non-
electrical equipment for explosive atmospheres--Basic method and
requirements, Edition 1.0, February 2016; IBR approved for Sec.
431.172.
(d) UL. Underwriters Laboratories, 333 Pfingsten Road, Northbrook,
[[Page 27391]]
Illinois, 60062; www.shopulstandards.com.
(1) UL 705, Standard for Safety for Power Ventilators, Edition 7,
July 19, 2017 (including revisions through August 19, 2022); IBR
approved for Sec. 431.172.
(2) [Reserved].
0
8. Section 431.174 is added to read as follows:
Sec. 431.174 Test Procedure for fans or blowers.
(a) Scope for fans and blowers other than air circulating fans. A
fan or blower, other than an air circulating fan is subject to the test
procedure in this section if it meets the following criteria:
(1) Is a centrifugal housed fan; radial housed fan; centrifugal
inline fan; centrifugal unhoused fan; centrifugal power roof ventilator
exhaust fan; centrifugal power roof ventilator supply fan; axial inline
fan; axial panel fan; or axial centrifugal power roof ventilator fan;
(2) Is not:
(i) A radial housed unshrouded fan with blade diameter at tip less
than 30 inches or a blade width of less than 3 inches;
(ii) A safety fan;
(iii) An induced flow fan;
(iv) A jet fan;
(v) A cross-flow fan;
(vi) A fan manufactured exclusively to be powered by internal
combustion engines;
(vii) A fan that create a vacuum of 30 inches water gauge or
greater;
(viii) A fan that is designed and marketed to operate at or above
482 degrees Fahrenheit (250 degrees Celsius); or
(ix) A fan and blower embedded in the equipment listed in paragraph
(a)(3) of this section;
(3) Is not an embedded fan subject to the following exclusions:
(i) The test procedure in this section does not apply to fans or
blowers that are embedded in:
(A) Single phase central air conditioners and heat pumps rated with
a certified cooling capacity less than 65,000 British thermal units per
hour (``Btu/h'') cooling capacity, that are subject to DOE's energy
conservation standard at 10 CFR 430.32(c);
(B) Three phase, air-cooled, small commercial packaged air-
conditioning and heating equipment rated with a certified cooling
capacity less than 65,000 Btu/h cooling capacity, that are subject to
DOE's energy conservation standard at Sec. 431.97(b);
(C) Transport refrigeration (i.e., Trailer refrigeration, Self-
powered truck refrigeration, Vehicle-powered truck refrigeration,
Marine/Rail container refrigerant);
(D) Vacuum cleaners;
(E) Heat Rejection Equipment: Packaged evaporative open-circuit
cooling towers; Evaporative field-erected open-circuit cooling towers;
Packaged evaporative closed-circuit cooling towers; Evaporative field-
erected closed-circuit cooling towers; Packaged evaporative condensers;
Field-erected evaporative condensers; Packaged air-cooled (dry)
coolers; Field-erected air-cooled (dry) cooler; Air-cooled steam
condensers; Hybrid (water saving) versions of all of the previously
listed equipment that contain both evaporative and air-cooled heat
exchange sections;
(F) Air curtains; and
(G) Direct expansion-dedicated outdoor air system that are subject
to any of DOE's test procedures in appendix B to subpart F of this
part.
(ii) The test procedure in this section does not apply to supply or
condenser fans or blowers that are embedded in:
(A) Air-cooled commercial package air conditioners and heat pumps
(``CUAC,'' ``CUHP'') with a certified cooling capacity between 5.5 ton
(65,000 Btu/h) and 63.5 ton (760,000 Btu/h) that are subject to DOE's
energy conservation standard at Sec. 431.97(b);
(B) Water-cooled and evaporatively-cooled commercial air
conditioners that are subject to DOE's energy conservation standard at
Sec. 431.97(b);
(C) Water-source heat pumps that are subject to DOE's energy
conservation standard at Sec. 431.97(b);
(D) Single package vertical air conditioners and heat pumps that
are subject to DOE's energy conservation standard at Sec. 431.97(d);
(E) Packaged terminal air conditioners (``PTAC'') and packaged
terminal heat pumps (PTHP) that are subject to DOE's energy
conservation standard at Sec. 431.97(c);
(F) Computer room air conditioners that are subject to DOE's energy
conservation standard at Sec. 431.97(e); and
(G) Variable refrigerant flow multi-split air conditioners and heat
pumps that are subject to DOE's energy conservation standard at Sec.
431.97(f); and
(4) In addition, the test procedure is only applicable to fan or
blower duty points with the following characteristics, measured or
calculated in accordance with the test procedure set forth in appendix
A of this subpart:
(i)(A) Fan shaft input power equal to or greater than 1 horsepower;
or
(B) Fan electrical input power equal to or greater than 0.89 kW;
and
(ii)(A) Fan static air power equal to or less than 150 horsepower
for fans using a static pressure basis fan energy index (``FEI'') in
accordance with the required test configuration listed in table 7.1 of
AMCA 214-21 (incorporated by reference, see Sec. 431.173); or
(B) Fan total air power equal to or less than 150 horsepower for
fans using a total pressure basis FEI in accordance with the required
test configuration listed in table 7.1 of AMCA 214-21;
(b) Scope for air circulating fans. The test procedure in this
section applies to all air circulating fans with input power greater
than or equal to 125W at maximum speed.
(c) Testing and calculations for fans and blowers other than air
circulating fans. Determine the FEI, the fan electrical input power
(``FEP''), and fan shaft power (as applicable) at each duty point, as
specified by the manufacturer, using the test procedure set forth in
appendix A of this subpart.
(d) Testing and calculations for air circulating fan. Determine the
FEI and the fan electrical input power (``FEP'') or the weighted-
average FEI and weighted-average FEP as applicable, using the test
procedure set forth in appendix B of this subpart.
0
9. Add appendix A to subpart J of part 431 to read as follows:
Appendix A to Subpart J of Part 431--Uniform Test Method for the
Measurement of Energy Consumption of Fans and Blowers Other Than Air
Circulating Fans
After October 30, 2023, any representations made with respect to
energy use or efficiency of fans and blowers subject to testing
pursuant to Sec. 431.174 must be made in accordance with this
appendix. Any optional representations of fan energy index in the
optional test configuration listed in table 7.1 of AMCA 214-21
(FEIoptional) must be accompanied by a representation of
fan energy index in the required test configuration listed in table
7.1 of AMCA 214-21 (FEI).
0. Incorporation by Reference
In Sec. 431.173, DOE incorporated by reference the entire
standard for AMCA 210-16, AMCA 214-21, and ISO 5801:2017; however,
only enumerated provisions of those documents are applicable as
follows. In cases where there is a conflict, the language of this
appendix takes precedence over those documents.
0.1 AMCA 210-16:
(a) Section 3, ``Definitions/Units of Measure/Symbols'';
(b) Section 4, ``Instruments and Methods of Measurement'' ;
(c) Section 5, ``Test Setups and Equipment'';
(d) Section 6, ``Observation and Conduct of Test'';
(e) Section 7, ``Calculations'' excluding Section 7.9.2,
``Conversion to other rotational speeds and air densities with
compressible
[[Page 27392]]
flow'' and Section 7.9.3, ``Conversion formulae for new densities
and new rotational speeds'';
0.2. AMCA 214-21:
(a) Section 2, ``References (Normative),'' as referenced in
section 2.2 of this appendix;
(b) Section 3, ``Definitions,'' as referenced in section 1 of
this appendix;
(c) Section 4, ``Calculation of the FEI for a Single Duty
Point,'' as referenced in section 2.6 of this appendix;
(d) Section 5, ``Reference Fan Electrical Power
(FEPref),'' as referenced in section 2.6 of this
appendix;
(e) Section 6.1, ``Wire-to-Air Testing at the Required Duty
Point,'' as referenced in section 2.2 of this appendix;
(f) Section 6.2, ``Calculated Ratings Based on Wire-to-Air
Testing,'' as referenced in section 2.2 of this appendix;
(g) Section 6.3, ``Bare Shaft Fans,'' as referenced in section
2.2 of this appendix;
(h) Section 6.4, ``Fans with Polyphase Regulated Motor'',
excluding Section 6.4.1.4, ``Requirements for the VFD, if included''
and Section 6.4.2.4, ``Combined motor-VFD efficiency'' as referenced
in section 2.2 of this appendix;
(i) Section 7, ``Testing,'' as referenced in sections 2.2 and
2.3 of this appendix;
(j) Section 8, ``Rating Development'', excluding Section 8.2.2,
``Separate Fan and Motor Tests'' and Section 8.3, ``Appurtenances''
as referenced in section 2.2 of this appendix;
(k) Annex D, ``Motor Performance Constants (Normative),'' as
referenced in section 2.2 of this appendix;
(l) Annex E, ``Calculation Methods for Fans Tested Shaft-to-
Air,'' as referenced in section 2.2 of this appendix;
(m) Annex G, ``Wire-to-Air Measurement--Calculation to Other
Speeds and Densities (Normative),'' as referenced in section 2.2 of
this appendix;
(n) Annex J, ``Other data and calculations to be retained,'' as
referenced in section 2.2 of this appendix; and
(o) Annex K, ``Proportionality and Dimensional Requirements
(Normative),'' as referenced in section 2.2 of this appendix.
0.3. ISO 5801:2017:
(a) Section 3, ``Terms and Definitions'';
(b) Section 4, ``Symbols, Abbreviated Terms and Subscripts'';
(c) Section 5, ``General'';
(d) Section 6, ``Test Configurations'';
(e) Section 7, ``Carrying out the Test'';
(f) Section 8, ``Airways for Duct Configuration'';
(g) Section 9, ``Standardized Test Chambers'';
(h) Section 10, ``Various Component Parts for a Laboratory
Setup'';
(i) Section 11, ``Standard Test Configurations'';
(j) Section 12, ``Measurements'';
(k) Section 13, ``Reference Conditions'';
(l) Section 15, ``Calculations'';
(m) Section 16, ``Fan Characteristic Curves''; and
(n) Section 17, ``Uncertainty Analysis''.
1. Definitions
The definitions applicable to this appendix are defined in Sec.
431.172 and in section 3, ``Definitions,'' of AMCA 214-21. In cases
where there is a conflict, the definitions in Sec. 431.172 take
precedence over AMCA 214-21.
2. Test Procedure for Fans and Blowers Other Than Air Circulating
Fans
2.1. General.
This section describes the test procedure for fans and blowers
other than air circulating fans. In cases where there is a conflict,
the provisions in this appendix take precedence over AMCA 214-21.
Where AMCA 214-21 refers to Annex A, ``Polyphase Regulated Motor
Efficiencies (Normative),'' of AMCA 214-21, Table 5 of Sec. 431.25
must be used instead.
2.2. Testing
2.2.1. General.
The fan electrical input power (FEPact) in kilowatts
must be determined at every duty point specified by the manufacturer
in accordance with one of the test methods listed in Table 1, and
the following sections of AMCA 214-21: Section 2, ``References
(Normative)''; Section 7, ``Testing,'' including the referenced
provisions to AMCA 210-16 and ISO 5801:2017 as listed in sections
2.2.2 and 2.2.3 of this appendix; Section 8.1, ``Laboratory
Measurement Only'' (as applicable); and Annex J, ``Other data and
calculations to be retained.''
Table 1 to Appendix A to Subpart J of Part 431
----------------------------------------------------------------------------------------------------------------
Motor controller Transmission Applicable section(s)
Driver present? configuration? Test method of AMCA 214-21
----------------------------------------------------------------------------------------------------------------
Electric motor................. Yes or No........ Any.............. Wire-to-air...... 6.1 ``Wire-to-Air
Testing at the
Required Duty
Point''.
Electric motor................. Yes or No........ Any.............. Calculation based 6.2 ``Calculated
on Wire-to-air Ratings Based on Wire
testing. to Air Testing''
(references Section
8.2.3, ``Calculation
to other speeds and
densities for wire-to-
air testing,'' and
Annex G, ''Wire-to-
Air Measurement--
Calculation to Other
Speeds and Densities
(Normative)'').
Regulated polyphase motor...... No............... Direct drive, V- Shaft-to-air..... 6.4 ``Fans with
belt drive, Polyphase Regulated
flexible Motors,'' (references
coupling or Annex D, ``Motor
synchronous belt Performance Constants
drive. (Normative)'') *.
None or non-electric........... No............... None............. Shaft-to-air..... Section 6.3, ``Bare
Shaft Fans''.
Regulated polyphase motor...... No............... Direct drive, V- Calculation based Section 8.2.1, ``Fan
belt drive, on Shaft-to-air laws and other
flexible testing. calculation methods
coupling or for shaft-to-air
synchronous belt testing'' (references
drive. Annex D, ``Motor
Performance Constants
(Normative),'' Annex
E, ``Calculation
Methods for Fans
Tested Shaft-to-
Air,'' and Annex K,
``Proportionality and
Dimensional
Requirements
(Normative)'').
None or non-electric........... No............... None............. Calculation based Section 8.2.1, ``Fan
on Shaft-to-air laws and other
testing. calculation methods
for shaft-to-air
testing'' (references
Annex E,
``Calculation Methods
for Fans Tested Shaft-
to-Air,'' and Annex
K, ``Proportionality
and Dimensional
Requirements
(Normative)'').
----------------------------------------------------------------------------------------------------------------
* Excluding Section 6.4.1.4, ``Requirements for the VFD, if included'' and Section 6.4.2.4, ``Combined motor-VFD
efficiency.''
Testing must be performed in accordance with the required test
configuration listed in table 7.1 of AMCA 214-21. The following
values must be determined in accordance with this appendix at each
duty point specified by the manufacturer: fan airflow in cubic feet
per minute; fan air density; fan total pressure in inches of water
gauge for fans using a total pressure basis FEI in accordance with
Table 7.1 of AMCA 214-21; fan static pressure in inches of water
gauge for fans using a static pressure basis FEI in atcordance with
table 7.1 of AMCA 214-21; fan speed in revolutions per minute; and
fan shaft input power in horsepower for fans tested in accordance
with sections 6.3, 6.4 or 6.5 of AMCA 214-21.
In addition, if applying the equations in Section E.2 of Annex E
of AMCA 214-21 for compressible flows, the compressibility
coefficients must be included in the equations as applicable.
All measurements must be recorded at the resolution of the test
instrumentation and calculations must be rounded to the number of
significant digits present at the resolution of the test
instrumentation.
In cases where there is a conflict, the provisions in AMCA 214-
21 take precedence over AMCA 210-16 and ISO 5801:2017. In addition,
the provisions in this appendix apply.
2.2.2 Power Roof Ventilators
[[Page 27393]]
Centrifugal Power Roof Ventilators that are both supply and
exhaust must be tested in both supply and exhaust configurations as
listed in table 7.1 of AMCA 214-21.
2.2.3 Embedded Fans
Embedded fans that are not manufactured in a standalone
configuration must be tested in a standalone configuration. If some
components of the bare shaft fan are not removable without causing
irreversible damage to the equipment into which the fan is embedded,
testing must be performed using additional fan components, except
for the fan impeller, that are geometrically identical to that of
the fan embedded inside the larger piece of equipment for testing.
2.3. Power Supply
Any wire-to-air testing must be conducted at the supply
frequency, phase, and voltages specified in this section. The
frequency and voltage must be selected in accordance with section
7.8. of AMCA 214-21. Fans and blowers rated for operation for
single- or multi-phase power supply must be tested with single- or
multi-phase electricity, respectively. Fans and blowers, capable of
operating with single- and multi-phase power supply, must be tested
using multi-phase electricity.
2.4. Stability Conditions.
The following conditions must be met to establish system
stability prior to collecting test data:
(a) Barometric pressure, dry bulb temperature and wet bulb
temperature in the general test area must be captured at least every
five seconds after the run-in period is completed and the ambient
air density calculated from these values shall not vary by more than
1 percent during verification of fan speed and fan input
power stability.
(b) After the fan has been run-in, record the fan speed in rpm
and the input power (in pound-force, pound-force-in, or watts) at
least every 5 seconds for at least three 60-second intervals.
Readings shall be made simultaneously. Repeat these measurements
over 60-second intervals until:
(1) The average fan speed from the last 60-second interval
varies by less than the absolute value of 1 percent or 1 rpm,
whichever is greater, when compared to the average fan speed
measured during the previous 60-second test interval;
(2) The average input power from the last 60-second interval
varies by less than the absolute value of 1 percent, whichever is
greater, compared to the average input power measured during the
previous 60-second test interval; and
(3) The slopes calculated from the individual data collected for
fan speed and input power during at least three 60-second sampling
intervals include both positive and negative values (e.g., two
positive and one negative slope value or one positive and two
negative slope values). If three positive or three negative slopes
are determined in succession, additional sampling intervals are
required until slopes from three successive sampling intervals
include both positive and negative values.
2.5. Sampling Intervals for Testing.
A test measurement must meet the following conditions:
(a) The sampling interval over which average test values are
determined shall not exceed 60 seconds;
(b) The average fan speed from the most recent 60-second
interval varies by less than the absolute value of 1 percent or 1
rpm, whichever is greater, when compared to the average fan speed
measured during the previous 60-second test interval; and
(c) the average input power from the last 60-second interval by
reaction dynamometer, torque meter or calibrated motor must be
4 percent, or the average input power by electrical
meter must be 2 percent of the mean or 1 watt, whichever
is greater, compared to the average input power measured during the
previous 60-second test interval.
2.6. FEI calculation
The FEI must be determined at every duty point in accordance
with Section 4, ``Calculation of the FEI for a single duty point,''
and Section 5, ``Reference Fan Electrical Power
(FEPref)'' of AMCA 214-21. In addition, the FEI must be
rounded to the nearest hundredths place; FEP must be rounded to
three significant figures; and all measurements must be recorded at
the resolution of the test instrument.
0
10. Add appendix B to subpart J of part 431 to read as follows:
Appendix B to Subpart J of Part 431--Uniform Test Method for the
Measurement of Energy Consumption of Air Circulating Fans
After October 30, 2023, any representations made with respect to
energy use or efficiency of air circulating fans subject to testing
pursuant to Sec. 431.174 must be made in accordance with this
appendix. Any optional representations of air circulating fan
efficacy at speeds less than the air circulating fan's maximum speed
must be accompanied by a representation of the air circulating fan
efficacy at maximum speed.
0. Incorporation by Reference
In Sec. 431.173, DOE incorporated by reference the entire
standard for AMCA 230-23; however, only enumerated provisions of
those documents are applicable as follows. In cases where there is a
conflict, the language of this appendix takes precedence over those
documents.
0.1 AMCA 230-23:
(a) Section 4, ``Definitions/Units of Measurement/Symbols,'' as
referenced in section 1 and 2.2.2 of this appendix;
(b) Section 5, ``Instruments and Methods of Measurement,'' as
referenced in section 2.2.2 of this appendix;
(c) Section 6, ``Equipment and Setup,'' as referenced in section
2.2.2 of this appendix;
(d) Section 7, ``Observations and Conduct of Test,'' as
referenced in section 2.2.2 of this appendix;
(e) Section 8, ``Calculations,'' as referenced in section 2.2.2
of this appendix; and
(f) Section 9, ``Report and Results of Test,'' as referenced in
section 2.2.2 of this appendix.
1. Definitions
The definitions applicable to this appendix are defined in Sec.
431.172 and in Section 4, ``Definitions/Units of Measurement/
Symbols,'' of AMCA 230-23. In cases where there is a conflict, the
definitions in Sec. 431.172 take precedence over AMCA 230-23.
2. Test Procedure for Air Circulating Fans
2.1. General
This section describes the test procedure for air circulating
fans.
2.2. Testing
2.2.1. General
The air circulating fan efficacy (E[fnof][fnof]circ) in cubic
feet per minute (``CFM'') per watt (``W'') (``CFM/W'') at maximum
speed must be determined in accordance with the applicable sections
of AMCA 230-23 as listed in section 2.2.2 of this appendix. In
addition, testing must be conducted in accordance with the
provisions in sections 2.3 through 2.5 of this appendix. Optional
testing speeds lower than maximum speed is permitted. Speeds less
than maximum speeds must be expressed at a percentage of maximum
speed (e.g., 50 percent) and the air circulating fan efficacy at
lower speed must include the speed percentage in its subscript
(e.g., E[fnof][fnof]circ,50).
All measurements must be recorded at the resolution of the test
instrumentation and calculations must be rounded to the number of
significant digits of the resolution of the test instrumentation.
2.2.2. AMCA 230-23, Applicable Sections.
The following sections of AMCA 230-23 are applicable: Section 4,
``Definitions/Unit of Measurement/Symbols''; Section 5,
``Instruments and Methods of Measurement''; Section 6, ``Instruments
and Methods of Measurement''; Section 7, ``Observations and Conduct
of Test''; Section 8, ``Calculations''; and Section 9, ``Report and
Results of Test.''
2.3. Air circulating fans without motors
Air circulating fans distributed in commerce without an electric
motor must be tested using an electric motor as recommended in the
manufacturer's catalogs or distributed in commerce with the air
circulating fan. If more than one motor is available in
manufacturer's catalogs or distributed in commerce with the air
circulating fan, testing must be conducted using the least efficient
motor capable of running the fan at the fan's maximum allowable
speed.
2.4. Power Supply.
The test must be conducted at the frequency, phase, and voltages
specified in this section.
2.4.1. Frequency.
Air circulating fans rated for operation with only 60 Hz power
supply must be tested with 60 Hz electricity. Air circulating fans
capable of operating with 50 Hz and 60 Hz electricity must be tested
with 60 Hz electricity.
2.4.2. Phase.
Air circulating fans rated for operation for single- or multi-
phase power supply must be tested with single- or multi-phase power
electricity, respectively. Air circulating fans, capable of
operating with single- and multi-phase power supply, must be tested
using multi-phase electricity.
2.4.3. Voltage.
Select the supply voltage as follows:
[[Page 27394]]
(a) For air circulating fans tested with single-phase
electricity, the supply voltage must be:
(1) 120 V if the air circulating fan's minimum rated voltage is
120 V or the lowest rated voltage range contains 120 V,
(2) 240 V if the air circulating fan's minimum rated voltage is
240 V or the lowest rated voltage range contains 240 V, or
(3) The air circulating fan's minimum rated voltage (if a
voltage range is not given) or the mean of the lowest rated voltage
range, in all other cases.
(b) For air circulating fans tested with multi-phase
electricity, the supply voltage must be
(1) 240 V if the air circulating fan's minimum rated voltage is
240 V or the lowest rated voltage range contains 240 V, or
(2) The air circulating fan's minimum rated voltage (if a
voltage range is not given) or the mean of the lowest rated voltage
range, in all other cases.
2.5. Stability Conditions.
In addition to the test requirements specified in sections 7.1
and 7.3 of AMCA 230-23, the following conditions must be met to
establish system stability prior to collecting test data:
(a) Test voltage shall be captured at least every five seconds
and shall not vary by more than +/-1 percent during each test.
Barometric pressure, dry bulb temperature and wet bulb temperature
in the general test area for calculation of air density must be
captured at least every five seconds and the calculated ambient air
density shall not vary by more than +/-1 percent during each test.
(b) After a run-in time of at least 15 minutes, record the fan
speed in rpm, the input power in watts, and load differential in
pound-force for at least 3 120-second intervals. Repeat these
measurements over additional 120-second intervals until:
(1) The average fan speed of the last 120-second interval varies
by less than the absolute value of 1 percent or 1 rpm, whichever is
greater, when compared to the average fan speed measured during the
previous 120-second test interval;
(2) The average input power of the last 120-second interval
varies by less than the absolute value of 1 percent or 1 watt,
whichever is greater, compared to the average input power measured
during the previous 120-second test interval;
(3) The average load differential of the last 120-second
interval varies by less than the absolute value of 1 percent,
whichever is greater, compared to the average load differential
during the previous 120-second test interval; and
(4) The slopes calculated from the individual data collected for
fan speed, input power, and load differential during at least three
120-second intervals include both positive and negative values
(e.g., two positive and one negative value or one positive and two
negative values). If three positive or three negative slopes are
determined in succession, additional sampling intervals are required
until slopes from three successive intervals include both positive
and negative values.
[FR Doc. 2023-08696 Filed 4-28-23; 8:45 am]
BILLING CODE 6450-01-P