Ceiling Fan Regs

Published on December 2016 | Categories: Documents | Downloads: 50 | Comments: 0 | Views: 340
of 101
Download PDF   Embed   Report

New proposed federal regulations for ceiling fans

Comments

Content

Energy Conservation Standards
Rulemaking Framework Document for
Ceiling Fans and Ceiling Fan Light Kits
RIN: 1904-AC87


U.S. Department of Energy
Office of Energy Efficiency and Renewable Energy
Building Technologies Program


March 8, 2013

TABLE OF CONTENTS

 

1  2 

INTRODUCTION .................................................................................................................. 1 
1.1  2.1 
  History of Ceiling Fan and Ceiling Fan Light Kit Standards and Authority ................... 2


SCOPE OF COVERAGE ....................................................................................................... 3 
Ceiling Fans...................................................................................................................... 3 

  Definitions Related to Ceiling Fans.......................................................................... 5


2.1.1 

2.1.1.1  2.1.1.2  2.1.1.3  2.1.1.4  2.2  3  3.1  3.2  3.3  3.4  4  4.1 

Definition of “Hugger Fan”............................................................................... 6 

  Definition of “Standard Ceiling Fan” and “Multi-Mount Fan” ......................... 7


Definition of “Highly Decorative Fan” ............................................................. 7 
Definition of “Outdoor Fan”.............................................................................. 9 


Ceiling Fan Light Kits...................................................................................................... 9 

  Rulemaking Process and Participation of Interested Parties ............................................ 9


  Overview of the Rulemaking Process ..................................................................................... 9


Preliminary Analysis ...................................................................................................... 11 
Notices of Proposed Rulemaking ................................................................................... 13 
Final Rule ....................................................................................................................... 14 
Test Procedures .............................................................................................................. 14 
Modes of Operation for Ceiling Fans and Ceiling Fan Light Kits ......................... 15 
Preliminary Discussion of Test Procedures ............................................................ 16 

  Ceiling Fans..................................................................................................... 16


TEST PROCEDURES AND REGULATORY METRICS .................................................. 14 
4.1.1  4.1.2 

4.1.2.1  4.1.2.2 

Ceiling Fan Light Kits ..................................................................................... 27 


5  OVERVIEW OF ANALYSES FOR ENERGY CONSERVATION STANDARDS
  RULEMAKING............................................................................................................................ 31

  MARKET AND TECHNOLOGY ASSESSMENT ............................................................. 34


6.1 

Market Assessment ........................................................................................................ 34
 
  Manufacturer Trade Group ..................................................................................... 35
  Manufacturers and Market Shares .......................................................................... 35
  Retailers ........................................................................................................... 36
  Major Manufacturers ....................................................................................... 37
  Historical Shipments........................................................................................ 41


6.1.1  6.1.2 

6.1.2.1  6.1.2.2  6.1.2.3  6.1.2.4  6.1.2.5  6.1.3 

Saturation......................................................................................................... 44 
Product Lifetime .............................................................................................. 46 


Product Classes ....................................................................................................... 46 
i

6.1.3.1  6.1.3.2  6.2  6.2.1 

Ceiling Fans..................................................................................................... 46
  Ceiling Fan Light Kits ..................................................................................... 49 


Technology Assessment ................................................................................................. 50 

  Improving Ceiling Fan Efficiency .......................................................................... 51
  Motors.............................................................................................................. 52


6.2.1.1  6.2.1.2  6.2.1.3  6.2.1.4  6.2.1.5  6.2.1.6  6.2.2  7  8 

Number of Blades ............................................................................................ 54 
Blade Design.................................................................................................... 54 
Blade Span....................................................................................................... 55 

  Occupancy Sensors.......................................................................................... 55


Potential Technology Options for Ceiling Fans .............................................. 56 


Improving Efficiency of Ceiling Fan Light Kits..................................................... 56 


  SCREENING ANALYSIS ................................................................................................... 57
  ENGINEERING ANALYSIS............................................................................................... 58


8.1  8.2  8.3  8.4  8.5  8.6  9  9.1  9.2 

  Overview ........................................................................................................................ 59
  Baseline Models ............................................................................................................. 60
  Efficiency Levels............................................................................................................ 61


Cost-Efficiency Relationship and Analysis.................................................................... 62 

  Proprietary Designs ........................................................................................................ 64
  Other Regulatory Changes Affecting the Engineering Analysis ................................... 64


  MARKUPS ANALYSIS ...................................................................................................... 65


Description of Market Participants and Distribution Channels ..................................... 65 
Markup Estimation Using Financial Statements and Regression Analysis ................... 65 


  10  ENERGY USE ANALYSIS ................................................................................................. 67


11  LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES ......................................... 68
  11.1  11.2  11.3  11.4  11.5  11.6  12.1  12.2  Overview .................................................................................................................... 68
 
  Energy Prices.............................................................................................................. 70
  Discount Rates............................................................................................................ 71
  Installation, Maintenance, and Repair Costs .............................................................. 71


Product Lifetime ......................................................................................................... 72 

  Energy Efficiency in the Base Case ........................................................................... 72
  Base-Case Forecast ..................................................................................................... 73


  12  SHIPMENTS ANALYSIS.................................................................................................... 73


Impacts of Standards on Ceiling Fan and Ceiling Fan Light Kit Shipments ............. 74 


  13  NATIONAL IMPACT ANALYSIS ..................................................................................... 74


ii

13.1  13.2  13.3 

Projected Efficiency Trends ....................................................................................... 74
 
  National Energy Savings ............................................................................................ 75


Net Present Value of Consumer Savings.................................................................... 76 


  14  CONSUMER SUBGROUP ANALYSIS ............................................................................. 77


15  MANUFACTURER IMPACT ANALYSIS......................................................................... 77 
15.1  15.2  15.3  15.4  15.5 
  Sources of Information for the Manufacturer Impact Analysis .................................. 78
  Industry Cash-Flow Analysis ..................................................................................... 79
  Manufacturer Subgroup Analysis............................................................................... 79
  Competitive Impacts Analysis.................................................................................... 80


Cumulative Regulatory Burden .................................................................................. 80 


16  EMISSIONS ANALYSIS..................................................................................................... 81 

17  MONETIZATION OF CO2 AND OTHER EMISSIONS REDUCTIONS.......................... 83 
  18  UTILITY IMPACT ANALYSIS.......................................................................................... 84
  19  EMPLOYMENT IMPACT ANALYSIS .............................................................................. 84
  20  REGULATORY IMPACT ANALYSIS............................................................................... 85
  APPENDIX A – LIST OF ITEMS FOR COMMENT ................................................................. 87


APPENDIX B – DRAFT PRELIMINARY MANUFACTURER IMPACT ANALYSIS
QUESTIONAIRE ......................................................................................................................... 93 


iii

LIST OF TABLES Table 2-1  Table 4-1  Table 6-1   Table 6-2   Table 6-3   Table 6-4   Table 6-5   Table 6-6   Table 6-7  Table 6-8   Table 6-9   Table 6-10   Types of Ceiling Fans ................................................................................................6 
Energy Conservation Standards and Efficiency Metrics for Ceiling Fan
Light Kits ...................................................................................................................27 
Market Shares of Ceiling Fan Retailers in 2011........................................................37 
Market Shares of Ceiling Fan Manufacturers............................................................39 
Sample List of ENERGY STAR Partners Manufacturing Version 3.0
Qualified Ceiling Fans With and Without Light Kits ................................................40
  Historical Shipments and Market Shares of ENERGY STAR-Qualified
Products Only.............................................................................................................42 
Historical Shipments of All Ceiling Fans With and Without Light Kits ...................42 
Comparison of Historical Shipments of Ceiling Fans from Different Data
Sources.......................................................................................................................43 
Market Share by Blade Span......................................................................................44 
Energy Conservation Standards and Efficiency Metrics for Ceiling Fan
Light Kits ...................................................................................................................49 
Potential Technology Options for Ceiling Fans.........................................................56 
Potential Technology Options for Lamp....................................................................57 
LIST OF FIGURES Figure 5-1  Figure 6-1  Figure 6-2  Figure 6-3  Figure 6-4  Figure 6-5  Figure 6-6  Figure 9-1   Figure 9-2  Flow Diagram of Analyses Conducted for an Energy Conservation Standard Rulemaking .................................................................................................33
  Market Shares of Ceiling Fan Manufacturers in 2011 (NPD, 2011) .........................38 
Market Shares of Ceiling Fans by Blade Span in 2011 .............................................43 
Market Shares of Ceiling Fans by Blade Span for 2007–2011 ..................................44 
U.S. Ceiling Fan Ownership by Region and Average Number of Ceiling
Fans Per Household ...................................................................................................45 
U.S. Ceiling Fan Usage by Region ............................................................................45 
Depiction of Ceiling Fan System Components That Can be Improved to
Reduce Energy Consumption ....................................................................................52 
Home Improvement Retailer Distribution Channel for Ceiling Fans and
Ceiling Fan Light Kits ...............................................................................................65 
Electrical Wholesaler (Distributor) Distribution Channel for Ceiling Fans
and Ceiling Fan Light Kits.........................................................................................65 


iv

LIST OF ACRONYMS AC ACEEE AEO ALA ANSI BLS BLDC BOM BT CAIR CFL CFLK CFM CFR CO2 CRS CSL D.C. DOE DOJ EGU EIA EISA 2007 EPA EPACT 2005 EPCA ES F FFC FTC FR GHG GREET GRIM Hg hp HVAC IEC IES ImSET I-O kWh LCC LED alternating current American Council for an Energy-Efficient Economy Annual Energy Outlook American Lighting Association American National Standards Institute Bureau of Labor Statistics brushless direct current (motors) bill of materials Building Technologies Program Clean Air Interstate Rule compact fluorescent lamp ceiling fan light kit cubic feet per minute Code of Federal Regulations carbon dioxide cold-rolled steel candidate standard level District of Columbia U.S. Department of Energy U.S. Department of Justice electricity generating unit Energy Information Administration Energy Independence and Security Act of 2007 U.S. Environmental Protection Agency Energy Policy Act of 2005 Energy Policy and Conservation Act ENERGY STAR® Fahrenheit full-fuel-cycle Federal Trade Commission Federal Register greenhouse gas emissions Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation Government Regulatory Impact Model mercury horsepower heating, ventilation, and air conditioning International Electrotechnical Commission Illuminating Engineering Society Impact of Sector Energy Technologies input-output kilowatt hour life-cycle cost light-emitting diode v

lm/W LMC MDF MIA MPC NAICS NEMS NEMS-BT NES NESHAPs NIA NOPR NOX NPD NPV OIRA OMB PBP PM RECS RIMS II RLEUCS RPM SBA SCC SEC SG&A SO2 TSD TSL U.S.C. W

lumens per watt Lighting Market Characterization medium density fibreboard manufacturer impact analysis manufacturer production cost North American Industry Classification System National Energy Modeling System National Energy Modeling System–Building Technologies national energy savings national emissions standards for hazardous air pollutants national impact analysis notice of proposed rulemaking oxides of nitrogen NPD Group, Inc. net present value Office of Information and Regulatory Affairs U.S. Office of Management and Budget payback period particulate matter Residential Energy Consumption Survey Regional Input-Output Modeling System II Residential Lighting End-Use Consumption Study revolutions per minute Small Business Administration social cost of carbon Securities and Exchange Commission selling, general, and administration costs sulfur dioxide technical support document trial standard level United States Code watt

vi

RULEMAKING FRAMEWORK DOCUMENT FOR CEILING FANS AND CEILING
FAN LIGHT KITS 1 INTRODUCTION

The U.S. Department of Energy (DOE) Appliances and Equipment Standards Program, within the Office of Energy Efficiency and Renewable Energy’s Building Technologies Program (BT), develops and promulgates energy conservation standards and test procedures for certain consumer appliances and commercial and industrial equipment. The process for developing standards involves analysis, public notice and comment, and consultation with interested parties. Interested parties include manufacturers, trade associations, consumers, energy conservation and environmental advocates, State and Federal agencies, and any other groups or individuals having an interest in these standards and test procedures. The DOE Appliance Standards Program Report to Congress,1 initially submitted on January 31, 2006, and updated twice a year since first publication, identifies the numerous rulemakings for a variety of products that DOE has scheduled for completion and explains many of the techniques DOE will apply during the rulemaking process to meet this schedule. The purpose of this Framework Document is to describe the procedural and analytical approaches DOE anticipates using to evaluate potential amended test procedures and energy conservation standards or energy use standards for ceiling fans and ceiling fan light kits (CFLK) (section 1.1 provides a discussion of the statutory authority for this rulemaking). This Framework Document is also intended to inform interested parties of the process DOE will follow for the standards rulemaking for these products and to encourage and facilitate input from interested parties during the rulemaking. This document serves as the starting point for developing amended test procedures and energy conservation standards and is not a definitive statement on any issue to be determined in the rulemaking. This Framework Document is organized in the following manner. Section 3 provides an overview of DOE’s rulemaking process. Section 4 provides a preliminary discussion of test procedures. Sections 5 through 20 discuss analyses DOE intends to conduct to fulfill the statutory requirements for this particular energy conservation standards rulemaking. DOE will analyze potential amended energy conservation standards for ceiling fans and ceiling fan light kits to determine whether such standards are technologically feasible, are economically justified, and would result in significant energy savings. DOE will maintain information about this rulemaking on its website.

U.S. Department of Energy. Energy Conservation Standards Activities; Submitted pursuant to Section 141 of the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, and in response to section 305 of the Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. 110-140; U.S. Department of Energy (August 2012) (Available at: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/2012_aug_report_to_congress.pdf). 1


1

Although DOE invites comment on all aspects of the material presented in this document, specific issues on which DOE seeks comment are set out in comment boxes like this one. DOE uses these comment boxes to highlight issues and ask specific questions on the approaches DOE plans to follow to conduct the analyses required for the energy conservation standards rulemaking. Such requests for feedback are numbered sequentially throughout the document and are compiled in Appendix A. 1.1 History of Ceiling Fan and Ceiling Fan Light Kit Standards and Authority

Title III, Part B2 of the Energy Policy and Conservation Act of 1975 (EPCA), Pub. L. 94­ 163 (42 United States Code (U.S.C.) 6291-6309, as codified), established the Energy Conservation Program for Consumer Products Other Than Automobiles, a program covering most major household appliances and certain industrial and commercial equipment.3 This program authorized DOE to establish technologically feasible, economically justified energy conservation regulations for certain products and equipment that would be likely to result in substantial national energy savings. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) Amendments to Title III of EPCA have given DOE the authority to regulate the energy efficiency of several additional types of products and equipment, including certain ceiling fans and ceiling fan light kits, which are the focus of this document. (42 U.S.C 6295(ff)) The Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, amended EPCA and provided that DOE may establish energy conservation standards for ceiling fans and ceiling fan light kits, as well as requirements for determining whether these standards should be amended. (42 U.S.C. 6295(ff)) Specifically, EPACT 2005 set design standards for ceiling fans and provided that DOE may consider and issue energy efficiency or energy use standards for electricity used by ceiling fans to circulate air in a room. (42 U.S.C. 6295(ff)(1) and (6)) For ceiling fan light kits, EPACT 2005 set energy conservation standards for ceiling fan light kits with medium screw base sockets, as well as pin-based sockets. (42 U.S.C. 6295(ff)(2)-(3)) The statute also directed DOE to consider and issue requirements for other types of ceiling fan light kits (including candelabra screw base sockets) by January 1, 2007, and if DOE failed to issue such standards by the date specified, the statute provided for an alternative set of requirements for ceiling fan light kits manufactured after January 1, 2010. (42 U.S.C. 6295(ff)) After January 1, 2010, DOE may again consider amended energy efficiency standards for ceiling fan light kits, standards that would apply to products manufactured not earlier than two years after the date of publication of the final rule. (42 U.S.C. 6295(ff)(5)) Under this statutory structure, DOE codified energy conservation standards and promulgated test procedures for ceiling fans and ceiling fan light kits, which are set forth in the Code of Federal Regulations (CFR). In a final rule technical amendment published in the Federal Register (FR) on October 18, 2005, DOE codified the statutory design standards for ceiling fans and the performance standards for ceiling fan light kits in the CFR at 10 CFR 430.32(s). 70 FR 60407, 60413. An additional final rule technical amendment published in the
2 3

For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012). 2


Federal Register on January 11, 2007, codified standards for light kits with sockets other than medium-screw base or pin-based fluorescent lamps in the CFR. 72 FR 1270. In a final rule published in the Federal Register on December 8, 2006, DOE adopted test procedures for ceiling fans and ceiling fan light kits at 10 CFR part 430, subpart B, appendix U and appendix V, respectively. 71 FR 71340, 71366-67. 2 SCOPE OF COVERAGE

As noted above, EPACT 2005 included amendments to EPCA that provided for new Federal energy efficiency and water conservation test procedures and related definitions for certain consumer products and commercial and industrial equipment, including ceiling fans and ceiling fan light kits.4 2.1 Ceiling Fans

EPCA defines a “ceiling fan” as "a nonportable device that is suspended from a ceiling for circulating air via the rotation of fan blades." (42 U.S.C. 6291(49)) Pursuant to EPCA, DOE intends to regulate the electrical energy consumption of ceiling fans. (42 U.S.C. 6295(ff)(6)(A)) In addition to giving DOE the discretion to issue electrical energy conservation standards for ceiling fans, EPCA also includes certain statutorily-prescribed design standards (including a requirement for (i) fan speed controls separate from any lighting controls; (ii) adjustable speed controls (either more than one speed or variable speed); and (iii) the capability for reverse action (other than fans sold for industrial or outdoor application or where safety would be an issue)). (42 U.S.C. 6295(ff)(1)(A)) The statutory design standards will remain in place and are not subject to review as part of this rulemaking process. As discussed below, DOE previously interpreted “hugger fans,” i.e., fans that are mounted flush to the ceiling, to fall outside the definition of “ceiling fan”, explaining that such fans are “mounted flush to” rather than “suspended from” the ceiling (71 FR 71340, 71343 (Dec. 8, 2006)). DOE is in this rulemaking reconsidering this distinction. DOE also has never interpreted the statutory language “highly decorative fans for which air movement performance is a secondary feature.” (42 U.S.C. 6295(ff)(6)(B)(ii)) DOE is proposing to define this category of ceiling fans with reference to their revolutions per minute (RPM) and is considering whether to make them a separate, exempt product class. Certain ceiling fans are mounted flush to the ceiling, for example, without a downrod. At the time DOE codified the standards prescribed by EPACT 2005 (including those for ceiling fans), DOE interpreted these “hugger fans” as falling outside the definition of covered ceiling fans, because they were not considered to be “suspended from a ceiling.” 71 FR 71340, 71343 (Dec. 8, 2006). The previous interpretation of this definition exempted hugger fans from standards on the basis that they are “typically understood to be ceiling fans that are not suspended from the ceiling; instead, they are set flush to the ceiling.” Id. DOE interpreted the statutory term “suspended” to mean only “suspended from a downrod,” and concluded that

4

Test procedures for consumer products and certain commercial and industrial equipment: http://www1.eere.energy.gov/buildings/appliance_standards/commercial_equipment_test_procedures.html 3


hugger fans are not suspended, and, therefore, not subject to EPCA requirements (including test procedures) applicable to ceiling fans. Id. Merriam-Webster’s Unabridged Dictionary defines “suspend” as, among other meanings, “to hang so as to be free on all sides except at the point of support.”5 DOE’s prior approach represents one plausible interpretation of this ambiguous statutory term. However, it is equally plausible to determine that a hugger fan is suspended from the ceiling as the motor housing is hung flush to the ceiling only at the point of support. Moreover, the presence or absence of a downrod does not appear dispositive as the basic fan mounting to the ceiling is the same regardless of a downrod. DOE has carefully reconsidered this issue and has tentatively concluded that hugger fans are “ceiling fans” within the scope of the statutory definition, particularly given the functional and mounting similarity of all such fans. This reinterpretation is also in line with the scope of CAN/CSA-C814-10, which includes hugger fans. Given that DOE’s prior interpretation has been in place for a number of years, DOE is proposing its revised interpretation as part of this notice-and-comment rulemaking. Specifically, DOE proposes to reinterpret the definition of “ceiling fan” to incorporate hugger fans. Under this reinterpretation, DOE would consider the following fans to be explicitly covered under the definition of “ceiling fan” in 10 CFR 430.2: 1. Fans that are hung from a downrod or other means of suspension; 2. Multi-mount fans (fans that are sold with the option of being hung with or without a downrod); and 3. Fans that are mounted directly or closely to the ceiling. DOE contends that hugger fans generally are indistinguishable from other types of ceiling fans in that they move air via rotation of fan blades, are intended to improve comfort, and are rated on their ability to move air (as measured in cubic feet per minute). DOE believes the only distinguishing feature of hugger fans is that they are safe to use in rooms that have low ceilings; however, DOE acknowledges that such design may have performance characteristics that impact energy efficiency. Consequently, DOE will, on this basis, consider establishing a separate product class for hugger fans. The second part of DOE's proposed reinterpretation aims to acknowledge the existence of and to address multi-mount fans. Many ceiling fans are sold with multiple options for mounting the fan, including but not limited to flush with the ceiling. DOE is clarifying that any ceiling fan sold with the option of being mounted flush to the ceiling, but that also can be mounted such that it is not appropriate for rooms with low ceilings would be considered a “multi-mount fan,” which would also be included in the “ceiling fan” definition. Additionally, in issuing energy conservation standards for ceiling fans, EPCA directs DOE to consider establishing a separate exempted product class(es) for highly decorative fans
5

Merriam-Webster online (Last accessed March 8, 2013) (Available at: <www.merriam­ webster.com/dictionary/suspended>). 4


for which air movement performance is a secondary feature (42 U.S.C. 6295(ff)(6)(B)(ii)). As such, DOE is planning to define “highly decorative fans” with reference to their maximum rotational speed in revolutions per minute (RPM) and is considering establishing a separate product class for highly decorative fans that is exempt from energy conservation standards. DOE is also aware of the existence of fans that do not have external blades, but create airflow due to a set of internal disks or blades (e.g., a Dyson Air Mulitplier fan). DOE understands that ceiling fans of this type currently have very limited market share, if any. DOE notes that its statutory definition does not hinge on whether a given model has a certain type of blades. Thus, DOE tentatively believes that fans with internal blades that would meet the other criteria set forth in the ceiling fan would be covered by DOE’s regulatory scope. Consequently, DOE requests feedback on whether such ceiling fans should be considered as part of this rulemaking. Item 1 DOE seeks comments on its proposed reinterpretation of the ceiling fan definition. DOE seeks comments on whether ceiling fans without external blades should be included in this rulemaking if they meet the definition of a ceiling fan.

Item 2

2.1.1

Definitions Related to Ceiling Fans

DOE surveyed the market of currently available ceiling fans to better understand the different types and classifications currently being used by manufacturers to describe ceiling fans with different designs. DOE has observed a number of descriptions of ceiling fans in the market (that are not necessarily mutually exclusive), including:           Hugger
Low-profile
Flush-mount
Extended
Standard
Indoor
Outdoor
Damp-rated
Wet-rated
Decorative


DOE believes that all of the ceiling fans described on this list are covered by the statutory definition of a “ceiling fan.” For the purposes of DOE’s regulations, DOE proposes to assign ceiling fans to one of four categories, distinguished by their functionality and physical characteristics. For example, DOE is proposing that a ceiling fan that could be described as either a “hugger” or “low profile” ceiling fan, could fall into the “hugger” DOE ceiling fan type
5


because a fan with either description could be used in a room with a low ceiling. This approach is in contrast to the approach previously taken by DOE. Previously DOE interpreted a “hugger fan” with respect to the mounting method; DOE is now proposing to define a “hugger fan” with respect to the distance between the blades and the ceiling. Two other “special” categories of ceiling fans would be those fans designed for outdoor use and those fans for which air movement performance is not a primary feature. All other ceiling fans would be standard, indoor ceiling fans. Table 2-1 summarizes the various ceiling fan types that DOE is considering as part of this rulemaking, along with a description of their functionalities, and the common market terminology/descriptions. Table 2-1 Types of Ceiling Fans DOE Ceiling Fan Type

Market Description May Include… Suitable for use indoors, Standard, indoor, extended Standard Indoor in rooms without low ceilings Suitable for use in Hugger, low profile Hugger rooms with low ceilings Suitable for use in wet Outdoor, damp-rated, wet-rated Outdoor or damp environments Decorative Decorative only; air Highly movement performance Decorative is not a primary feature Functionality

A key issue in this rulemaking involves the need to provide clear definitions of the various types of ceiling fans. DOE intends to develop definitions that are based on physical characteristics of those types of ceiling fans, thereby providing clarity and specificity for interested parties when determining how a given basic model of ceiling fan falls into DOE’s regulatory structure. The following sections discuss DOE’s initial approach in terms of defining various types of ceiling fans. 2.1.1.1 Definition of “Hugger Fan” There currently is no statutory or regulatory definition specific to ceiling fans designed for installation in spaces with low ceilings. Such models are variably referred to within the industry as “hugger fans,” “low-profile fans,” or “flush-mount fans.” Low-profile fans are mounted close to the ceiling (typically with the use of a base), which allows the motor housing to be slightly removed from the ceiling. In contrast, flush-mount fans typically have the motor housing mounted flush against the ceiling. Industry appears to have begun using the term “hugger fans” as a broad term used to describe fans that can be either low-profile or flush-mount. All three of these terms are used to describe ceiling fans that are to be installed in locations with
6


low ceilings, where other types of fans may be unsafe. The close proximity of the ceiling to the fan blades decreases the fan’s efficiency at circulating air when compared to a suspended fan. DOE reviewed the market of currently available ceiling fans marketed as low-profile, flush-mount, and hugger fans to see if it would be possible to identify physical characteristics differentiating these types of fans from standard indoor fans suitable for non-space constrained environments. DOE found that manufacturers typically include schematics describing the vertical distance between the fan blades and the ceiling as part of the product literature for each model. Based on the variety of observed vertical distances described in the literature being used to describe various ceiling fans offered by different manufacturers, DOE found that there is not a common distance being utilized by industry that determines whether a fan is commonly referred to as low-profile, flush-mount, or hugger. To provide clarity as to how a manufacturer should determine whether its ceiling fan would qualifies as a “hugger fan” for DOE’s regulatory purposes under a new definition, DOE is seeking comment about whether there is a common maximum vertical distance that is used to determine whether a ceiling fan is safe for installation in locations with low ceilings. DOE is considering a definition of “hugger fan” as “a ceiling fan where the average vertical distance between the fan blades and the ceiling is no more than [a specified number of] inches,” where the specific distance will be determined as part of the rulemaking process. DOE would like to base the specific distance on feedback from manufacturers as to how they currently decide which fans can go in vertically space-constrained rooms. 2.1.1.2 Definition of “Standard Ceiling Fan” and “Multi-Mount Fan” Once DOE has determined the physical characteristics that distinguish a hugger ceiling fan from a standard ceiling fan, DOE plans also to propose defining “standard ceiling fan,” which includes all other types of fans that are typically suspended from the ceiling through the use of a downrod. In addition, DOE will also propose a definition of a “multi-mount ceiling fan,” which will apply to those ceiling fans that can be used both in locations with low ceilings and in standard applications with the use of a downrod.

Item 3

DOE seeks comments on its proposed approach for developing definitions for the four types of ceiling fans, the vertical distance that is used to characterize whether a fan can safely be used in rooms with low ceiling heights, and any other physical characteristics used to determine the different types of ceiling fans currently on the market.

2.1.1.3 Definition of “Highly Decorative Fan” EPCA requires that if DOE sets energy efficiency standards for ceiling fans, it must consider ''establishing separate exempted product classes for highly decorative fans for which air movement performance is a secondary design feature.'' (42 U.S.C. 6295(ff)(6)(B)(ii)) EPCA
7

does not, however, exempt highly decorative fans from the statutorily-prescribed design standards, instead requiring that all ceiling fans have speed controls separate from lighting controls and include adjustable speed controls; most fans also must have the capability of reversible fan action. (42 U.S.C. 6295(ff)(1)(A)) Because DOE has not established standards for ceiling fans beyond the design standards promulgated by statute, DOE has not yet needed to consider whether highly decorative fans should be a separate regulated or exempted product class. 71 FR 71340, 71343 (Dec. 8, 2006). However, because DOE intends to now consider energy efficiency standards for ceiling fans, it will be necessary to clarify the statutory language “highly decorative fans for which air movement performance is a secondary feature.” The air movement performance of a ceiling fan is determined by the blade geometry and velocity. Therefore, DOE believes that blade speed (in RPM) is a valid way to differentiate fans for which air movement performance is a secondary feature. During the rulemaking to codify the design standards prescribed by EPACT 2005, DOE received comment on decorative fans. At that time, the American Lighting Association (ALA) suggested defining “highly decorative fans” as ceiling fans with less than a 3:1 blade length to width ratio and a maximum 175 RPM at high speed down flow. 71 FR 71340, 71343 (Dec. 8, 2006). The American Council for an Energy Efficient Economy (ACEEE) recommended that DOE develop a more limited definition that includes only “highly” decorative fans, and not fans just outside the normal range of blade length-to-width ratio and RPM. DOE’s analysis suggests that the normal range of blade length-to-width is 3.4 to 4.6, with 3.5 being typical; the normal range of RPM is 140-215 at high speed and 35-80 at low speed. Id. Further, ACEEE recommended that any product deemed exempt on the basis of being highly decorative must be clearly labelled as such, making customers aware that their primary function is for decoration and not air circulation. (EERE-2006-TP-0121-0069)6 DOE is proposing to use a new regulatory term “highly decorative fan” to capture the “highly decorative fans for which air movement performance is a secondary feature” contemplated by EPCA. DOE is proposing that the new term “highly decorative fan” be defined as: "a ceiling fan that circulates air via the rotation of fan blades at a maximum rotational speed of 50 RPM." 50 RPM was chosen as the cut-off point for highly decorative fans because DOE has tentatively concluded that fans for which air movement performance is a secondary feature are unlikely to need to exceed this speed.

Item 4

DOE seeks comments on its proposed definition of “highly decorative ceiling fans.”

6

Available at: http://www.regulations.gov/#!documentDetail;D=EERE-2006-TP-0121-0069. 8

2.1.1.4 Definition of “Outdoor Fan” DOE is considering defining “outdoor ceiling fans” as ceiling fans that have either a damp or wet rating. DOE understands that a manufacturer that wants to be able to advertise its ceiling fan as usable in damp or wet environments will seek to have them be either damp-rated or wetrated by a lab such as Underwriters Laboratory or Intertek. The damp or wet rating is a safety rating, required by building safety codes for installation in certain damp or wet locations, and corresponds to the use of a water-resistant housing for the motor and coating for the fan blades (in the case of damp-rated fans) or water-proof housing for the motor and coating for the blades (in the case of wet-rated fans). DOE seeks comment on the need to define “outdoor fans” separately and on using the damp or wet rating as the distinction. Item 5 DOE seeks comments on its proposed definition of “outdoor ceiling fans”.

2.2

Ceiling Fan Light Kits

EPCA defines a “ceiling fan light kit” as “equipment designed to provide light from a ceiling fan” that can be either integral to the ceiling fan or attachable (i.e., sold with or separate from the ceiling fan). Thus, all lighting equipment that is either built into, or designed to be attachable to, covered ceilings fans, is covered by Federal energy conservation standards. 3 Overview of the Rulemaking Process

This section summarizes DOE's energy conservation standards rulemaking process for ceiling fans and ceiling fan light kits. 3.1 Rulemaking Process and Participation of Interested Parties

EPCA requires that any standard DOE prescribes for consumer products must be designed to “achieve the maximum improvement in energy efficiency . . . which the Secretary [of Energy] determines is technologically feasible and economically justified.” (42 U.S.C. 6295(o)(2)(A)) Moreover, EPCA states that the Secretary may not establish an amended standard if such standard would not result in “significant conservation of energy,” or “is not technologically feasible or economically justified.” (42 U.S.C. 6295(o)(3)(B)) When DOE evaluates any new or amended energy conservation standard for covered products under EPCA, DOE considers to the greatest extent practicable the following seven factors to determine whether a standard is economically justified: (1) The economic impact of the standard on the manufacturers and on the consumers of the products subject to such standard; (2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, or in the initial charges for, or maintenance expenses of the covered products which are likely to result from the standard;
9


(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard; (4) Any lessening of the utility or the performance of the covered products likely to result from the standard; (5) The impact of any lessening of competition, as determined in writing by the U.S. Attorney General, that is likely to result from the standard; (6) The need for national energy and water conservation; and (7) Other factors the Secretary considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) Additional statutory requirements of general applicability for prescribing new or amended standards are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)-(iii), and (3)–(5). The processes for developing energy conservation standards and test procedures involve analysis, public notice and comment, and consultation with interested parties. Interested parties generally include manufacturers, trade associations, consumers, environmental and energyefficiency advocates, State and Federal agencies, and other groups and individuals having an interest in energy conservation standards and test procedures. DOE considers the participation of interested parties to be a vital part of the rulemaking processes for setting new and amended energy conservation standards and test procedures. Accordingly, DOE encourages the participation of all interested parties during the comment periods provided at each stage of the rulemaking. The broad array of interested parties who routinely provide comments promotes a balanced discussion of critical information required to conduct the standards and test procedure rulemakings, beginning with public comments on the Framework Document. In conducting the energy conservation standards and test procedure rulemakings, DOE involves interested parties through various means. As discussed in further detail below, the standards rulemaking process for ceiling fans and ceiling fan light kits will involve three public notices (in addition to the Framework Document), which are published in the Federal Register: (1) the preliminary analysis; (2) the NOPR; and (3) the final rule. After publication of the Framework Document, the preliminary analysis, and the NOPR, DOE will hold public meetings to solicit comment from interested parties in order to enhance the rulemaking process. The following outlines next steps for the ceiling fan and ceiling fan light kit energy conservation standards rulemaking:  Preliminary Analysis (section 3.2). The preliminary analysis is designed to publicly vet the data, models, and tools that DOE intends to use in the rulemaking, and to facilitate public participation before the proposed rule stage. Using these models and tools, DOE performs preliminary analyses to assess candidate standard levels (CSLs), which span the range of efficiencies from baseline products to the most efficient technology.
10


 Notice of Proposed Rulemaking (section 3.3). For this rulemaking, the NOPR will present: (1) a discussion of comments received in response to the preliminary analysis; (2) DOE’s analysis of the impacts of potential standards on consumers, manufacturers, and the Nation; (3) DOE’s weighting of those impacts; and (4) any proposed standard levels for public comment.  Final Rule (section 3.4). The final rule will present: (1) a discussion of and response to comments received on the NOPR; (2) the revised analysis (as appropriate) of the impacts of potential standards; (3) DOE’s weighting of the impacts; and (4) the new or amended standard levels (if any) that DOE is adopting. The final rule also will establish the compliance date for any adopted standards. 3.2 Preliminary Analysis

As part of an energy conservation standards rulemaking, DOE in its preliminary analysis typically identifies product technology options and makes a preliminary determination about whether to retain each option for detailed analysis or to eliminate it from further consideration. This process includes a market and technology assessment (section 6) and a screening analysis (section 7). DOE applies four screening criteria in the screening analysis to determine whether a given technology option should be eliminated from further consideration: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product utility or availability; and (4) adverse impacts on health or safety. Technologies that pass the screening analysis, which thereafter are referred to as design options, are evaluated in the engineering analysis (section 8) as methods of improving the efficiency of the covered products. DOE consults with interested parties and independent technical experts and researches industry literature to identify the key issues and design options or efficiency levels that DOE will consider in the rulemaking. This Framework Document, along with the accompanying public meeting announcement and request for public comment, initiates DOE’s dialogue with interested parties. This dialogue provides an opportunity for input into the structural and analytical approach planned for the subsequent energy conservation standards rulemaking. At the start of the preliminary analysis, DOE considers design options or efficiency levels for each product class. DOE uses these design options or efficiency levels to collect manufacturer cost data, historical shipments data, shipments-weighted average efficiency data, and preliminary manufacturer impact data (e.g., capital conversion costs, marketing costs, and research and development costs). As part of the preliminary analysis, DOE also conducts other principal analyses, many of which are described in this document, including: 1. The engineering analysis (section 8); 2. The consumer life-cycle cost (LCC) and payback period (PBP) analyses (section 11); 3. The national impact analysis, which considers national energy savings (NES) and
national consumer net present value (NPV) (section 13); and
4. A preliminary manufacturer impact analysis (section 15).
11


DOE will present the results of these analyses in the preliminary analysis technical support document (TSD), which will be made available at the time of publication of the preliminary analysis. DOE selects candidate standard levels from the energy efficiency or energy use levels considered in the preliminary analysis. Discussion of various CSLs in the preliminary analysis will facilitate review by interested parties of the spreadsheet models that underpin the analyses. DOE will use comments from interested parties to refine the models for the rulemaking analysis at the NOPR stage, where DOE will propose specific energy conservation standard levels for adoption. Based on the results, DOE selects CSLs from the energy efficiency or energy use levels considered in the preliminary analysis. In addition to the efficiency levels corresponding to the maximum technologically feasible (“max-tech”7) design and the efficiency levels corresponding to the minimum LCC point, DOE generally considers levels or design options that span the full range of technologically achievable efficiencies. DOE typically analyzes the following range of efficiency levels:  The baseline efficiency level (i.e., the minimum level) typically represents products having the lowest energy efficiency currently sold on the market for a given product class. If minimum energy conservation standards already exist for a product, the baseline efficiency level typically is defined by the current energy conservation standard;  The level that offers the minimum LCC or greatest LCC savings;  The highest energy efficiency level or lowest energy consumption level that is
technologically feasible (i.e., the “max-tech” level); and
 Levels that incorporate noteworthy technologies or fill large gaps between other
efficiency levels being considered.
At the preliminary analysis stage, DOE uses analytical models and tools to assess the different product classes at each efficiency or energy use level analyzed. Many of these analytical models and tools are in the form of spreadsheets, some of which DOE uses to conduct the LCC and payback period (PBP) analyses and to determine the NES and NPV of prospective standards. Preliminary results may facilitate discussions among interested parties on potential joint recommendations for standard levels. DOE will make the spreadsheet tools and results of the preliminary analysis available on its website for review.8 When it publishes the preliminary analysis, DOE will also make available a preliminary TSD, which will contain the details of all the analyses performed to date.

The “max-tech” represents the most-efficient design that is commercialized or has been demonstrated in a prototype with materials or technologies available today. “Max-tech” is not constrained by economic justification, and typically is the most expensive efficiency level considered in the engineering analysis. 8 Materials associated with the ceiling fan and ceiling fan light kit rulemakings will be available on DOE’s websites at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/25 and http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/76 12


7

After the preliminary analysis is published, DOE provides a public comment period and holds a public meeting to discuss these analyses. 3.3 Notices of Proposed Rulemaking

In developing the separate NOPRs for the test procedures and energy conservation standards for ceiling fans and ceiling fan light kits, DOE will first review and consider all the comments it receives within the stated comment period following publication of this Framework Document and all comments it receives on the preliminary analysis. DOE will publish a NOPR proposing test procedures for ceiling fans and ceiling fan light kits, which will be followed by a 75-day public comment period that includes one public meeting. The NOPR proposing standards for ceiling fans and ceiling fan light kits will be followed by a 60-day public comment period that includes one public meeting. This process may result in revisions or refinements to the planned methodology for each analysis related to the energy conservation standards rulemaking. DOE is planning to conduct in-depth technical analyses for the energy conservation standards NOPR for ceiling fans and ceiling fan light kits, in the following areas: (1) engineering; (2) markups to determine product price; (3) energy-use characterization; (4) life-cycle cost and payback period; (5) national impacts; (6) manufacturer impacts; (7) utility impacts; (8) environmental impacts; (9) employment impacts; and (10) regulatory impacts. DOE will describe the methodology used and make the results of all the analyses available on its website for review and comment. This part of the analytical process culminates in the selection of proposed standard levels (if any) that DOE will present in the NOPR. DOE selects the proposed standard levels from the trial standard levels (TSLs)9 analyzed prior to publication of the NOPR. The NOPR, published in the Federal Register, will document the evaluation and selection of any proposed standards levels, along with a discussion of other TSLs considered but not selected and the reasons DOE did not select them. Based on comments by interested parties, further revisions to the analysis and proposed standard levels may be undertaken for the final rule stage. For each product class, DOE will identify the max-tech level. Beginning with the maxtech level, DOE will weigh the benefits and burdens of each level to determine whether that level meets the criteria outlined in EPCA discussed above (section 3.1). If DOE proposes a lower level, it will sequentially explain the reasons for eliminating higher levels, beginning with the highest level considered. DOE will present the analytical results in the NOPR, and provide the details of the analysis in an accompanying TSD. DOE considers many factors in selecting proposed standards, as discussed in section 3.1. Those factors, which are enumerated in EPCA, take into consideration the benefits, costs, and other impacts of energy conservation standards. DOE encourages interested parties to develop joint recommendations for standard levels. DOE will consider such recommendations carefully in its decision process.

9

TSLs are assembled from the candidate standard levels analyzed for the individual product classes based on a set of criteria from the analytical results. 13


When DOE publishes the NOPR proposing energy conservation standards for ceiling fans and ceiling fan light kits, it will provide the U.S. Department of Justice (DOJ) with copies of the NOPR and TSD to solicit feedback on the impact of the proposed standard levels on competition in the ceiling fan and ceiling fan light kit industries. DOJ will review these proposed standard levels to help assess any lessening of competition that is likely to result from the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (ii)) DOE will consider DOJ’s determination on the impacts of the proposed standard(s) on competition in preparing a final rule. As noted above, publication of the NOPR for energy conservation standards for ceiling fans and ceiling fan light kits will be followed by a 60-day public comment period that includes one public meeting. 3.4 Final Rule

After the NOPR is published, DOE will consider public comments it receives on the test procedures, proposed standards, and accompanying analyses. For the standards rulemaking, DOE will review the engineering and economic impact analyses and proposed standards based on those comments and consider modifications where necessary. Before the final rule is issued, DOE also will consider DOJ comments on the NOPR relating to the impacts of the proposed standard levels on competition to determine whether changes to the standard levels are needed. DOE will publish the DOJ comments and DOE’s response as part of the final rule. The standards rulemaking will conclude with publication of the final rule. DOE will select the final standard level based on the complete record of the standards rulemaking. The final rule will promulgate the final standard levels, identify the compliance date (or dates), and explain the basis for their selection. The final rule will be accompanied by a final TSD. The test procedure rulemaking will conclude with the publication of a final rule, which considers all of the comments DOE receives on its proposed test procedures. 4 4.1 TEST PROCEDURES AND REGULATORY METRICS Test Procedures

EPCA directs DOE to, where applicable, establish test procedures in conjunction with new or amended energy conservation standards for products including ceiling fans and ceiling fan light kits. (42 U.S.C. 6295(r)) EPCA also requires DOE to review test procedures for all covered products at least once every seven years. (42 U.S.C. 6293(b)(1)(A)) To fulfill those requirements, DOE is simultaneously initiating both a test procedure rulemaking and an energy conservation standards rulemaking for ceiling fans and ceiling fan light kits. DOE intends for each test procedure to include an efficiency descriptor and the methods necessary to adequately measure the performance of the covered products for the purposes of developing amended energy conservation standards. Also relevant to the development of a ceiling fan and ceiling fan light kit test procedure, the Energy Independence and Security Act of 2001 (EISA 2007) amended EPCA to require that any new or amended energy conservation standard adopted after July 1, 2010, address standby mode and off mode energy use pursuant to 42 U.S.C. 6295(o). (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts new or amended standards for certain covered products after July
14


1, 2010, the final rule, if justified by the criteria for adoption of standards in section 325(o) of EPCA, must incorporate standby mode and off mode energy use into a single standard if feasible, or otherwise adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)) EISA 2007 also directs DOE to update its test procedures to account for standby mode and off mode energy consumption, with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor, unless the current test procedure already accounts for standby mode and off mode energy use. (42 U.S.C. 6295(gg)(2)(A)) Furthermore, if an integrated test procedure is technically infeasible, DOE must prescribe a separate standby mode and off mode test procedure for the covered product, if technically feasible. Id. Because the final rules for ceiling fans and ceiling fan light kits are scheduled for issuance after July 1, 2010, DOE plans to address the standby mode and off mode energy use of these products in both the test procedure and standards rulemaking. 4.1.1 Modes of Operation for Ceiling Fans and Ceiling Fan Light Kits

Ceiling fans and ceiling fan light kits have distinct modes of operation, and each mode has a corresponding rate or rates of electrical energy consumption. DOE plans to label those modes as active mode, standby mode, and off mode. DOE is proposing the following definitions related to potential ceiling fan and ceiling fan light kit modes of operation:  Active mode is the mode of operation during which the ceiling fan blades are in motion. Ceiling fans are currently required to have adjustable speed controls (either more than 1 speed or variable speed). Ceiling fans are also required to be able to operate such that the fan blades are rotating in the reverse direction of normal operation (with the exception of fans sold for industrial or outdoor applications or in cases where safety standards would be violated). When the blades rotate in reverse, the ceiling fan can enhance room heating by recirculating warm air trapped near the ceiling throughout the room. This direction usually only has one speed option. For ceiling fan light kits, active mode is the mode of operation during which the light is on. Standby mode is a power consumption mode that cannot be switched off, or influenced, by the user and that may persist for an indefinite time when the ceiling fan and/or ceiling fan light kit is connected to the main electricity supply and used in accordance with the manufacturer’s instructions. Standby mode is a non-operational mode when compared to the ceiling fan or ceiling fan light kit’s primary function -- moving air or providing light. Energy consumed by a motion sensor, remote control receiver, or other standby device that continues to draw power during fan and/or light inactivity, should be included when measuring standby power consumption.  Off mode is defined as the condition when the ceiling fan and/or ceiling fan light kit is connected to the main power source but is not providing any standby mode or active mode function. For ceiling fans and/or ceiling fan light kits, this is the mode of operation during which the product is not powered, since ceiling fans and light kits are hard-wired into a home’s electrical system and draw no power when not in active mode or standby mode.

15


4.1.2

Preliminary Discussion of Test Procedures

The following sections describe DOE’s current test procedures, review existing test procedures, and describe key issues and preliminary proposals for test procedure amendments for ceiling fans and ceiling fan light kits. 4.1.2.1 Ceiling Fans Current DOE Test Procedure for Ceiling Fans EPCA directs DOE to base the test procedure for ceiling fans on the ENERGY STAR® Testing Facility Guidance Manual: Building a Testing Facility and Performing the Solid State Test Method for ENERGY STAR® Qualified Ceiling Fans, Version 1.1, published by the U.S. Environmental Protection Agency (EPA). (42 U.S.C. 6293(b)(16)(A)(i)) Accordingly, on December 8, 2006, DOE published a final rule in the Federal Register, which adopted Version 1.1 of the ENERGY STAR test procedure for ceiling fans in Appendix U to Subpart B of 10 CFR Part 430. 71 FR 71340. Review of Current Test Procedures for Ceiling Fans When establishing or amending test procedures, DOE begins by reviewing existing industry test procedures or testing methods currently used to measure the energy use or energy efficiency of the covered products. DOE’s test procedure review included the current Federal test procedure for ceiling fans, version 1.1 (2002) and 1.2 (2011) of the ENERGY STAR guidance manual, and the testing methods described in the Canadian Standards Association's Energy Performance of Ceiling Fans Standards (CAN/CSA-C814-10). DOE adopted a test procedure for ceiling fans in a final rule published in the Federal Register on December 8, 2006. 71 FR 71340. DOE’s test procedure is based on ENERGY STAR guidance manual version 1.1, which is incorporated by reference into appendix U to subpart B of 10 CFR part 430, along with additional requirements on power measurement, sensors, and sensor software used for performing the airflow test. . When developing product specification and testing criteria in 2002, EPA was unable to adopt an existing industry testing procedure for use in the ENERGY STAR program because there was no standardized test method available within the ceiling fan industry at the time.10 Therefore, EPA partnered with Hunter Fan Company to develop the solid-state test method that allows for the measurement of total cubic feet per minute (CFM) and CFM/watt readings for multiple fan speeds. The resulting test procedure was set out in ENERGY STAR guidance manual version 1.1, which, as described above, formed the basis for DOE’s test procedure in 2006. EPA later revised its test procedure in 2011, creating ENERGY STAR guidance manual version 1.2, which differs from version 1.1 in the key ways set forth below. (Hereinafter, the two guidance manuals will be referred to together as "the ENERGY STAR guidance manuals.") Specifically, version 1.2:
10

http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/ceil_fans/ceiltestfinal.pdf?8360­ 5206 16


1. Provides an updated list of product vendors; 2. Stipulates that velocity sensors be rated for ± 5% accuracy and standard flow ranges of 0.15 to 10 m/s (approximately 30–1969 feet per minute), whereas version 1.1 required all instruments, including velocity sensors, to have tolerances within ± 1%; 3. Relaxes the requirement for the ceiling to be stainless steel or sheet rock, allowing for the possibility of a drop ceiling with full coverage from wall to wall; 4. Requires closing AC vents during testing (as opposed to merely recommending it in version 1.1); 5. Describes methods for using a single arm of sensors or a set-up for four sensors to measure several places at once, updating all corresponding figures to coincide with this expansion; 6. Specifies that no inside seam of the test cylinder be directly aligned with the velocity sensors when measuring airflows; 7. Decreases the required room temperature from 76 °Fahrenheit (F) to 70 °F; 8. Extends the warm-up time for the first test from 15 to 30 minutes, and specifies that the lowest speed be tested first; 9. Repeats the procedure for all possible fan speed settings (as opposed to only the rated speed); 10. Includes instruction to use the RMS sensor to calculate average power consumption; and 11. Removes the requirement for a detailed calibration. DOE also reviewed the test procedures included in the Canadian Standards Association's Energy Performance of Ceiling Fans Standards (CAN/CSA-C814-10), which are broadly in line with DOE's test procedures for ceiling fans, albeit with the following modifications: 1. A test set-up for hugger fans; 2. A sampling plan/requirement, specifically "For each basic model of ceiling fan, a sample of sufficient size shall be tested to ensure that every represented fan efficacy value shall be not less than the greater of (a) the mean of the sample; and (b) the upper 95% confidence limit of the true mean divided by 1.10"; 3. Requirement for standby power to be measured, according to another test procedure (CAN/CSA-C62301); 4. Ceiling fans are run for 15 minutes with sensors on before testing begins, without the additional requirement for any AC equipment to be turned off, and then fans run for an additional 3 minutes before starting data acquisition; 5. Required room temperature is 70 +/- 5°F, as opposed to 76 +/-2°F; 6. Specified test cylinders sizes are slightly different for certain fan sizes. For example, a 42" fan would be tested with a 52” cylinder instead of a 50" cylinder for the DOE test procedure;
17


7. Does not include an internal calibration system between testing facilities. Item 6 DOE seeks comment on the existence and applicability of any other test procedure that DOE could consider for measuring the airflow and electrical energy consumption of ceiling fans. DOE seeks comment as to what types of testing manufacturers currently conduct on ceiling fans and what test set-ups and methods are used. DOE has noticed, for example, that some hugger fans are marketed with a declaration of energy efficiency. DOE is interested in knowing how manufacturers have tested such ceiling fans.

Key Issues for Consideration in Active Mode Test Procedures for Ceiling Fans DOE has identified a number of issues regarding the testing of ceiling fans and will consider the feedback received in response to this Framework Document in developing its proposed test procedures. Active mode is the primary mode measured under current test procedures for both DOE’s regulatory program and the ENERGY STAR program. DOE has identified a number of issues that currently are either not addressed regarding testing ceiling fans in active mode or that may require clarifications or modification of the current test procedures currently being used on which DOE requests feedback from interested parties. The issues (discussed in further detail immediately below) include: 1. Accuracy of velocity sensors; 2. Hugger fans; 3. Multi-mount fans; 4. Fans having non-flat or unusually shaped blades; 5. Fans not exactly 8 inches smaller in diameter than an existing test cylinder; 6. Fans with multiple fan heads; 7. Fans where the airflow is not directed straight downwards; 8. Fans sold with combined heaters; 9. Testing at multiple fan speed settings; and 10. Testing in reverse direction Accuracy of velocity sensors

18


DOE conducted initial testing of five conventional ceiling fans according to the current ENERGY STAR test procedure and observed that, at low speed, the average air velocities varied widely depending on the position of the sensor-arm.11 For each fan, the air speed measured by at least one sensor varied by more than a factor of two between different sensor arm positions. This effect was less pronounced at higher fan speed settings when the average airspeed was greater. Given the symmetry of the test set-up, the variability of the average air velocities suggests that the accuracy of the velocity sensors may need to be reconsidered. Performance variability between ceiling fans within a specific fan model During initial testing of the five ceiling fans, DOE observed that the measured RPM for several fans was inconsistent with the RPM listed in the owner’s manuals or online. DOE is unsure what is contributing to this difference in results between the reported and measured values, but it could ultimately impact the repeatability of the test method. Consequently, DOE is seeking feedback on whether the representations of RPM are based on test procedure values and whether DOE should consider a larger sample size to determine certified ratings of ceiling fans of a given basic model. Hugger Fans DOE is proposing a new definition for “hugger fan”, which would include ceiling fans that are mounted flush with or close to the ceiling. The configuration of hugger fans with their proximity to the ceiling is not accounted for under the current DOE test procedure. Therefore, DOE is considering amending its test procedure to allow for the testing of hugger fans. DOE will investigate methodologies for testing hugger fans, including the use of an artificial ceiling, along the lines described in CAN/CSA-C814-10, “Energy Performance of Ceiling Fans.” DOE requests comments on potential approaches it should consider (including the use of an artificial ceiling) to enable hugger fans to be tested. Multi-Mount Fans Multi-mount fans are fans that can either be mounted flush with or close to the ceiling, or suspended from a downrod. DOE is not aware of any data on how often multi-mount ceiling fans are mounted with or without a downrod. DOE is considering testing multi-mounts as hugger fans, (i.e., mounted flush with or close to the ceiling) to provide for a conservative rating and allowing manufacturers to voluntarily run additional testing if they wish to make representations as a standard fan. DOE requests comments on its approach for multi-mount fans. Fans Having Non-Flat or Unusually Shaped Blades. Some fans on the market are not shaped in a traditional way that incorporates flat blades. The current DOE test procedure refers to fan blades, and the test set-up assumes a reasonably flat

11

A rotating arm positions the sensors at 0, 90, 180, and 270 degrees for a portion of each test.  19


blade design.12 The DOE test procedure specifies that a test cylinder, which measures airflow, be hung below the ceiling fan so that there is a 6-inch vertical gap between the middle of the fan blade tips and the top of the test cylinder. (If not all of the blades are the same height, the average of all of the blade heights is required to be 6 inches.) For fans having non-flat blades or unusual shapes, such as fans with airfoil blade shapes, gyro fans, ribbon fans, or fans that “orbit” by changing the tilt of the entire fan, it may be unclear as to how the “middle of blade tip” measurements should be made, and 6 inches from the tip may not be the correct clearance from the cylinder to set up a congruent test for airflow. DOE is considering investigating appropriate distances and measurement methodologies for ceiling fans that have non-flat and unusually shaped blades, with the aim of clarifying how such fans should be measured. As part of this investigation, DOE will consider the methodology set out in CAN/CSA-C814-10. DOE requests feedback as to whether it is necessary to develop specialized methodologies for testing various blade types and seeks suggestions as to how to clarify the test procedure to account for unusual configurations. Fans That Do Not Meet the 8-Inch Difference in Diameter Requirement with Existing Test Cylinders The current DOE test procedures and the test procedure used for the ENERGY STAR program require that ceiling fans be tested in test cylinders exactly 8 inches larger in diameter than the ceiling fan.12 Therefore, the ability to test a unique fan sizes is limited by the availability of a corresponding test cylinder. Testing ceiling fans that are not exactly 8 inches smaller in diameter than an existing test cylinder currently requires the purchase or construction of a new cylinder. DOE is considering investigating to what degree maintaining the 8-inch requirement affects the accuracy and repeatability of the test results with an aim at reducing testing burden and potentially minimizing the number of test cylinders needed to characterize the variety of ceiling fans currently on the market. If DOE finds that it can obtain accurate and reliable results, DOE is considering either: (1) allowing testing of ceiling fans in cylinders within a specified tolerance of the current 8 inch requirement, or (2) developing a correlation between blade span and test cylinder size to account for the change in airflow. Either approach would limit the number of test cylinders that would need to be purchased to test fans with diameters that do not correspond to an existing test cylinder. DOE requests information on the effects of testing ceiling fans in cylinders having diameters other than 8 inches larger than the blade span of the ceiling fan and seeks comments on these potential modifications. Fans with Multiple Fan Heads The current test procedures for DOE and ENERGY STAR are unclear when it comes to some of the test set-up and conditions needed for testing multiple head fans. The geometry of multi-headed fans could result in: (1) most of the airflow from such fans missing a corresponding test cylinder, or (2) a significant additional cost burden to manufacturers to purchase an

ENERGY STAR® Testing Facility Guidance Manual: Building a Testing Facility and Performing the Solid State Test Method for ENERGY STAR® Qualified Ceiling Fans, Version 1.1 (Available at: http://www.energystar.gov/ia/partners/manuf_res/downloads/ceiltestfinal.pdf) 20


12

unusually large test cylinder to capture all of the airflow. In either case, complicated correction factors would be needed to make the test results comparable to fans with a single head. To measure airflow performance for multi-head fans, DOE is considering testing only one of the ceiling fan heads, with the other fan head motors turned off, and treating the fan head like a standard single-head ceiling fan. The airflow and airflow efficiency could be rated for the individual head. Total airflow for multiple heads could be determined by multiplying airflow from one fan by the number of heads, assuming all are of equal construction and diameter. The power consumption could be determined similarly. DOE requests comments on whether a single fan head can be isolated for testing. If this condition cannot be met, DOE requests comment on alternatives for testing multi-head fans. Fans Where the Airflow is Not Directed Vertically DOE has observed that some ceiling fans on the market can be oriented in various positions that direct the airflow and that sometimes, the fans cannot be pointed straight down. A downward orientation is important because the test cylinders and flow sensors are positioned directly beneath the fan in the current testing procedures. A non-vertical orientation would mean that some of the airflow produced by the fan would be undetected by the flow sensors. For fans that are oriented such that the airflow is not directed vertically, DOE is considering adjusting the fan such that the airflow is vertical prior to testing. DOE is also considering requiring that test labs use an adjustable mount to achieve a vertical orientation. Alternatively, DOE is considering testing in the non-vertical direction as specified in the installation manual and measuring the airflow, which could provide a conservative estimate of airflow for the ceiling fan. Fans Sold with Combined Heaters Consumer survey data for 2007–2011 purchased from the market research firm NPD Group, Inc. suggest that approximately 9 percent of ceiling fans are sold with combined heating elements, although it is unclear how much those heaters may be used. DOE has preliminarily concluded that it is not planning to consider the power consumption by the heater in this rulemaking and is proposing to specify in its test procedure that the heaters be switched off during testing. DOE requests comment on the exclusion of the heater usage as part of the ceiling fan testing procedure. Testing at Multiple Fan Speed Settings Current DOE standards for ceiling fans require that all ceiling fans have the ability to run at more than one speed (see section 2.1). Ceiling fans with multiple speed settings allow the user to change the airflow to meet varying climate control needs during active mode operation. During active mode operation, ceiling fans consume electrical energy at various rates depending on those speed settings. Consequently, ceiling fans have different airflow efficiencies (cubic feet per minute (CFM)/watt (W)) for each speed. The current DOE test procedure allows for measurement of airflow efficiency at any and all available fan speeds. DOE is considering various approaches for characterize the ceiling fan energy use at the various speed options available for each basic model. Specifically, DOE could require testing at a single speed or at multiple speeds. One option that limits test burden that DOE could consider would be to test at
21


the highest fan speed setting. DOE requests feedback on the number of speeds that should be considered for testing which would reflect typical consumer operation. For consideration of multiple speeds or variable speed controls, DOE requests comments on how testing a discrete number of speeds would correspond to the various options offered by manufacturers. For example, if DOE required testing in “high,” “medium,” and “low” speeds, how would that correspond to the manufacturer settings in a 4-speed fan? DOE specifically requests feedback on how to define “high,” “medium,” and “low” speeds on fans with more than three speeds or variable speed controls. Testing in Reverse Direction As noted in section 1.2.1, ceiling fans manufactured after January 1, 2007 must be capable of reversible fan action, with certain limited exceptions. Specifically, this requirement does not apply to 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 direction. DOE has concluded that these statutory exceptions to the reverse action design requirement in 42 U.S.C. 6295(ff)(1)(A)(iii) will continue, even as DOE develops performance standards under 42 U.S.C. 6295(ff)(6). On this point, DOE notes that fans sold for industrial applications are not covered products under EPCA’s definition of “consumer product.” DOE anticipates that fans sold for outdoor applications will be a separate product class (see section 6.1.3.1), and DOE is not aware of any residential ceiling fans for which safety standards would be violated by the use of reverse action. However, as a technical matter, DOE is still considering whether reverse action should be included in the test procedure for ceiling fans. DOE anticipates that for most ceiling fans, time spent in reverse will be marginal compared with the amount of time spent turning in the “forward” direction and that the share of time in both directions will differ greatly by region. DOE expects that most consumers use ceiling fans predominantly for cooling and that energy efficiency in the forward and reverse directions will typically be highly correlated. That is, a ceiling fan that is highly efficient in forward would also likely be highly efficient in reverse. DOE requests comment on the relationship between energy consumption in forward and reverse directions. Item 7 DOE requests comments on the accuracy tolerance of the velocity sensors for either the current DOE or current ENERGY STAR test procedures and potential sources of inaccuracy for low speed airflow measurements DOE requests comments on the potential performance variability between ceiling fans for a specific fan model and the possibility of requiring a sample of ceiling fans to certify a model.

Item 8

22


Item 9

DOE requests comments on its proposal to investigate methodologies (including the use of an artificial ceiling) to enable hugger fans to be tested. DOE welcomes any information on how hugger fans currently are tested. DOE requests comments on its proposal to test multimount fans in hugger fan configuration. DOE is considering investigating appropriate distances and measuring methodologies for ceiling fans having non-flat and unusually shaped blades to clarify how such fans should be measured. DOE requests feedback as to whether developing such methodologies is necessary and helpful. DOE seeks suggestions as to how best to clarify the test procedure to account for those types of configurations. DOE requests information on the effects of testing ceiling fans in cylinders having diameters other than 8 inches wider than the blade span of the ceiling fan and seeks comments on the potential modifications to the test procedure described. DOE requests comments on its proposed approach to testing ceiling fans with multiple fan heads. DOE requests comments on its approach to testing ceiling fans where the airflow is not directed vertically. DOE is proposing to specify in its test procedure that heaters be switched off during testing. DOE requests comments on its proposed approach. DOE seeks comment on the possibility of testing at one, three, or all available fan speeds. Additionally, DOE seeks input on the amount of time spent at each fan speed setting. DOE seeks on how to define “high”, “medium”, and “low” speeds on fans with more than three speeds or variable speed controls.

Item 10

Item 11

Item 12

Item 13

Item 14

Item 15

Item 16

Item 17

23


Item 18

DOE seeks comments and any available data regarding its view that energy consumption in forward and reverse are likely to be highly correlated.

Key Issues for Consideration in Low-Power Mode Test Procedures DOE’s current test procedure for ceiling fans uses the metric CFM/watt and measures performance in active mode only. This approach reflects that fact that many ceiling fans consume energy only in active mode. Some ceiling fans, however, contain technologies such as remote-control and thermostat sensors that consume energy in standby mode. The current test procedure does not account for the energy consumed by such features. The Energy Independence and Security Act of 2007 (EISA 2007) amended EPCA to require DOE to consider standby mode and off mode energy consumption in amendments to both its test procedures and energy conservation standards. Specifically, EISA 2007 amended EPCA by adding the following provisions regarding standby mode and off mode energy use.
(gg) STANDBY MODE ENERGY USE. -(1) DEFINITIONS.— (A) IN GENERAL.—Unless the Secretary determines otherwise pursuant to subparagraph (B), in this subsection: (i) ACTIVE MODE.—The term “active mode” means the condition in which an energy-using product:— (I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main functions. (ii) OFF MODE.—The term “off mode” means the condition in which an energy-using product:— (I) is connected to a main power source; and (II) is not providing any standby or active mode function. (iii) STANDBY MODE.—The term “standby mode” means the condition in which an energy-using product:— (I) is connected to a main power source; and (II) offers 1 or more of the following user-oriented or protective functions: (aa) To facilitate the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer. (bb) Continuous functions, including information or status displays (including clocks) or sensor-based functions. (B) AMENDED DEFINITIONS.—The Secretary may, by rule, amend the definitions under subparagraph (A), taking into consideration the most current versions of Standards 62301 and 62087 of the International Electrotechnical Commission. (2) TEST PROCEDURES.— (A) IN GENERAL.—Test procedures for all covered products shall be amended pursuant to section 323 to include standby mode and off mode energy consumption, taking into consideration the most current versions of Standards 62301 and 62087 of the International Electrotechnical Commission, with such
24


energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless the Secretary determines that:— (i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or (ii) such an integrated test procedure is technically infeasible for a particular covered product, in which case the Secretary shall prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible. * * * * * (3) INCORPORATION INTO STANDARD.— (A) IN GENERAL.—Subject to subparagraph (B), based on the test procedures required under paragraph (2), any final rule establishing or revising a standard for a covered product, adopted after July 1, 2010, shall incorporate standby mode and off mode energy use into a single amended or new standard, pursuant to subsection (o), if feasible. (B) SEPARATE STANDARDS.—If not feasible, the Secretary shall prescribe within the final rule a separate standard for standby mode and off mode energy consumption, if justified under subsection (o).

(42 U.S.C. 6295(gg)(1), (2)(A), and (3)) As provided in the statutory excerpt above, DOE must consider the most current versions of Standards 62301 and 62087 of the International Electrotechnical Commission (IEC). (42 USC 6295(gg)(2)(A)) The most current versions of those test procedures are IEC Standard 62301, Household electrical appliances—measurement of standby power (Second Edition 2011), and IEC Standard 62087, Methods of measurement for the power consumption of audio, video, and related equipment (Third Edition, April 2011). DOE reviewed both of these standards in preparation for this rulemaking. DOE found that IEC 62087 specifies methods of measurement for the power consumption of television receivers, videocassette recorders, set top boxes, audio equipment, and multi-function products for consumer use. IEC Standard 62087 does not, however, include measurement of the power consumption of appliances such as ceiling fans. Accordingly, DOE tentatively has concluded that IEC Standard 62087 is not applicable to ceiling fans and should not be considered further in this rulemaking. DOE found that IEC 62301 specifies methods of measurement for electrical energy consumption in low-power modes for household appliances and products, including ceiling fans. Therefore, DOE believes IEC 62301 is applicable to this rulemaking. Using the EPCA definitions quoted above for active mode, standby mode, and off mode for these products, DOE understands that ceiling fans without remote controls or other sensors have no standby mode or off mode electricity consumption. DOE acknowledges that ceiling fans with brushless DC motors could use standby mode or off mode electricity if a power switch is located between the converter and the motor. Ceiling fans with remote controls do not have a true off mode; when they are not in active mode, they are in standby mode, in which case electrical energy is consumed by the remote control receiver. DOE understands that the vast majority of ceiling fans sold in the U.S. lack remote controls or other sensors. These ceiling fans effectively do not have a standby mode and enter
25


off mode when not in active mode. DOE requests comment on the number of fans that are sold with remote control sensors or other features that consume energy in standby mode. For fans that consume no energy in standby or off mode, a test procedure that measures fan performance in active mode is sufficient because active mode efficiency is the only factor in the ceiling fan’s overall energy efficiency. For the products that are equipped with remote control sensors or other features that consume energy in standby mode, DOE will investigate how much energy is consumed in the standby mode. The Department does not currently know the amount of such energy consumption, or how such energy use compares to energy consumption in the active mode for these fans. DOE requests stakeholder input on how much energy ceiling fans consume in standby mode (for those fans that have a standby mode), and how it compares to energy consumption by these fans in the active mode. Similarly, DOE is proposing to include testing of standby mode power consumption as part of the amended ceiling fan test procedure. If technically feasible, DOE plans to incorporate standby mode power consumption of ceiling fans into an integrated metric for each of those products that addresses overall energy efficiency, as directed by the statutory excerpt above. To create an integrated metric, one possible approach would be to combine the energy consumed in standby mode with the energy consumed in active mode according to the operating hours spent in each mode. The equation below illustrates an example of this approach: ‫ݕ݂݂ܿ݊݁݅ܿ݅ܧ ݕ݃ݎ݁݊ܧ‬஼௘௜௟௜௡௚ ி௔௡ ሺ‫ܯܨܥ‬⁄ܹ ሻ ൌ ൬      CFMA – Airflow in active mode. OHA – Annual operating hours in active mode. OHSb – Annual operating hours in standby mode. WA – Power consumption in active mode. WSb – Power consumption in standby mode. ‫ܯܨܥ‬஺ ൈ ܱ‫ܪ‬஺ ൰ ܹ஺ ൈ ܱ‫ܪ‬஺ ൅ ܹௌ௕ ൈ ܱ‫ܪ‬௕

Note that with this type of equation, the energy efficiency of ceiling fans without any standby mode power consumption would simply reduce to the active mode airflow efficiency. DOE requests feedback on its planned approach to the energy efficiency metric for ceiling fans. To combine standby mode and active mode energy consumption into a single efficiency metric as described in the equation above would require estimates of the amount of time ceiling fans spend in each mode. DOE understands that ceiling fan usage patterns depend greatly on climate and geography (see section 6.1.2.4). It may be difficult to estimate a usage pattern (the number of hours in each mode) that is representative of typical ceiling fan usage if typical fan use could not be determined, if for instance there are wide regional differences or the data do not exist. DOE requests feedback on the feasibility of determining a representative national usage profile.

26


Item 19

DOE requests comments on the amount of energy ceiling fans consume in standby mode and/or off mode and how it compares to energy consumption in active mode. DOE requests feedback on its planned approach to use an integrated energy efficiency metric for ceiling fans. DOE seeks information on the number of ceiling fans that are sold with remote controls or other devices that consume energy in standby mode and/or off mode. DOE seeks input on average ceiling fan usage, including the amount of time spent in each mode, and the feasibility of determining representative national average hours of operation.

Item 20

Item 21

Item 22

4.1.2.2 Ceiling Fan Light Kits Current Test Procedures of Ceiling Fan Light Kits The current DOE standards for ceiling fan light kits (42 U.S.C. 6295 (ff)), which were established by EPACT (see section 1.1), use different test procedures, and in some cases different metrics, for different light kit product classes. The Federal standards for ceiling fan light kits with medium screw-based (class 1) and those with pin-based sockets (class 2) are based on the efficacy of the lamps packaged with the light kits. For class 1 and class 2 light kits, luminous efficacy is the metric (lumens emitted per watts consumed (lm/W)). Lamps used in class 1 light kits must meet the ENERGY STAR Program Requirements for Compact Fluorescent Lamps (CFLs), version 3.0 or have equivalent minimum efficacy. Lamps used in class 2 light kits must meet the combined lamp and ballast efficacy requirements set out in the ENERGY STAR Program Requirements for Residential Light Fixtures, version 4.0. The current DOE test procedure references the following IES test procedures, depending on the specific nature of the lamp: LM-66 (Electrical and Photometric Measurements of Single-Ended Compact Fluorescent Lamps) and LM-9 (Electrical and Photometric Measurements of Fluorescent Lamps). The standard for all other ceiling fan light kits (class 3) is based on maximum operating wattage. To date, DOE has interpreted that standard as a design standard that requires the inclusion of a wattage limiter in class 3 light kits; accordingly, DOE has not established a corresponding test procedure for class 3 ceiling fan light kits. Table 4-1 summarizes the metrics and test procedures required for compliance with DOE’s current standards for ceiling fan light kits. Only those IES test procedures that are relevant to the indicated class of ceiling fan light kits are included in the table. Table 4-1 Kits Energy Conservation Standards and Efficiency Metrics for Ceiling Fan Light

27


Product Class

Primary Requirement of Standard

Class 1: Medium screw base (E26)

Class 2: Pinbased fluorescent

Package with lamps that meet the ENERGY STAR Program Requirements for Compact Fluorescent Lamps, version 3.0, or with lamps having equivalent lm/W performance. The light kit must meet the ENERGY STAR Program Requirements for Residential Light Fixtures, version 4.0: Package with compliant lamps to fill all sockets.

Energy Efficiency Metric [Corresponding Test Procedure] Lamp efficacy (lm/W)

DOE and (Referenced) Test Procedures CFR Appendix V of Subpart B of Part 430 (IES LM-66)

Class 3: All other light kits not included in Class 1 or Class 2

Shall not be capable of operating with lamps that total more than 190 watts.

Lamp efficacy (lm/W) (outdoor fixtures may alternatively comply by including automatic daylight shutoff and motion sensor controls) Wattage

CFR Appendix V of Subpart B of Part 430 (IES LM-9)

None

Review of Current Test Procedures for Ceiling Fan Light Kits The ENERGY STAR program requirements included by referenced in the DOE test procedures for ceiling fan light kits are no longer current. The current ENERGY STAR Program Requirements for CFLs is version 4.3 and it is being replaced by the ENERGY STAR Program Requirements Product Specification for Lamps. The ENERGY STAR Program Requirements for Residential Light Fixtures have been replaced by the ENERGY STAR Program Requirements for Luminaires. Currently the DOE test procedures for class 1 lamps do not include test procedures for LED lamps, which can be used in ceiling fan light kits with medium screw based sockets. DOE is currently developing test procedures for LED lamps. The current program requirements for luminaires now require different test methods for light kits with direction and non-directional lighting. While the former still uses lamp photometry, the latter uses luminaire photometry. Moreover, the IES test procedures referenced in the ENERGY STAR test procedures have been updated. For example, the current version of LM-66 is LM-66-11, whereas the version referenced in current DOE test procedure is LM-66-00.

Preliminary Proposals for Test Procedure Amendments

28


To eliminate the confusion of multiple metrics and test procedures, and to reduce the cost of testing for ceiling fan light kits, DOE is considering adopting a single metric, luminous efficacy, for all ceiling fan light kits. All test lamp test procedures would reference the existing DOE test procedure, if such a test exists for a given lamp type, or would include a separate method of test, where needed. Testing would apply to the models of lamps packaged with, or integrated into, the ceiling fan light kit. Ceiling fan light kit manufacturers would be required to package with lamps that individually or together meet the light kit efficacy requirements set forth by this rulemaking. Ceiling fan light kit manufacturers could rely upon lamp manufacturers for the testing and rating of the bulbs that are to be packaged with the light kits. Applying this proposed approach to all ceiling fan light kits would eliminate the need to include wattage limiters in class 3 light kits. For ceiling fan light kits packaged with consumer replaceable lamps (e.g., screw-based sockets, pin-based fluorescents, replaceable light-emitting diodes (LEDs)), DOE is considering requiring testing based on lamp system photometry, where the lamp system includes the reference ballast or driver, if a ballast or diver is necessary to operate the lamps. Lamps with existing DOE test procedures would be tested according to their DOE test procedure. For the types of lamps currently included in ceiling fan light kits there are currently DOE test procedures of medium screw based incandescent lamps and medium screw based compact fluorescent lamps (CFLs) that are integrally ballasted. DOE test procedures are under development for LED lamps and are being updated for other types of CFLs. For lamps used in ceiling fan light kits for which DOE test procedures do not exist, DOE is considering the latest version of the appropriate IES test procedure for the appropriate type of lamps incorporated into ceiling fan light kits: LM-9: Electrical and Photometric Measurements of Fluorescent Lamps LM-20: Approved Method for Photometric Testing of Reflector-Type Lamps LM-45: Electrical and Photometric Measurements of General Service Incandescent Filament Lamps LM-66: Electrical and Photometric Measurements of Single-Ended Compact Fluorescent Lamps LM-79: Electrical and Photometric Measurements of Solid-State Lighting Products DOE is aware that ceiling fan light kits with LEDs may be designed such that the light source component (i.e. LED package, array, module, or light engine) cannot be easily removed or replaced by the end user, thus requiring replacement of the entire ceiling fan light kit. For these ceiling fan light kits with inseparable LED lighting components, DOE is considering the inseparable solid-state lighting (SSL) luminaire test procedures specified in the latest version of ENERGY STAR Program Requirements for Luminaires. DOE is also considering photometric testing of the LED light engine. DOE is considering two approaches to using the luminous efficacy of the packaged lamps (or integrated light sources) to determine ceiling fan light kit efficacy. The first follows the
29


current approach in which all individual lamps packaged with the ceiling fan light kit (or integrated into the ceiling fan light kit) must meet a minimum standard. The second approach would define ceiling fan light kit efficacy as the total lamp lumens divided by the total input wattage, where this metric would be derived from data reported for lamp certification, requiring that lamps lumens and watts are reported individually. The two approaches to using lamp efficacy in support of a ceiling fan light kit energy conservation standard would yield different results under the following conditions: If the packaged lamps perform better than the minimum required, and if lamps with different efficacies used in the same ceiling fan light kit. The first approach is advantageous for its simplicity. The latter is advantageous in that is offers additional flexibility in meeting the standard in cases where different types of lamps are used in the same ceiling fan light kit. It also provides consumers with a more accurate indication of the actual performance of the ceiling fan light kit as purchased, as opposed to just an indication of its minimum performance requirement.

Item 23

DOE requests comments on its proposal to use luminous efficacy as the efficiency metric for all ceiling fan light kits. DOE requests comment on the proposal to base test procedures to determine ceiling fan light kit efficiency on the following IES lamp photometry test procedures: LM-9, LM-66, LM-45, and LM-79, depending on light source type. DOE requests information on the existing and/or future market availability of ceiling fan light kits with inseparable LED lighting components. DOE requests comment on using guidance provided in the latest version of the upcoming ENERGY STAR Program Requirements for Luminaires for testing ceiling fan light kits with inseparable LED lighting components. DOE requests comment on the advantages or disadvantages of defining ceiling fan light kit efficacy as the total lamp lumens divided by the total input wattage.

Item 24

Item 25

Item 26

Item 27

30


Standby Power DOE test procedures for ceiling fan light kits currently do not address standby mode. DOE believes that ceiling fan light kits do not consume power in off mode and should consume power in standby mode only if they are controlled via remote control. If the standby sensor and controller are shared between the ceiling fan and the ceiling fan light kit, DOE plans to account for the energy consumption in standby mode under the ceiling fan efficiency metric and not under the ceiling fan light kit luminous efficacy metric. DOE is not currently aware of any ceiling fan light kits sold with a separate remote or sensor, which operates independently from the ceiling fan controls (that is, for which the control circuits are separate).

Item 28

DOE requests input on whether ceiling fan light kits, or ceiling fan light kit controls, exist that have a standby mode and that operate independent of the ceiling fan. If such devices exist, DOE requests comment what fraction of controllers that are of this type, the power draw in standby mode, and the fraction of time they spend in standby mode. DOE requests feedback on its planned approach to attribute all standby power to the ceiling fan if ceiling fan standby is managed by a controller that is shared between the ceiling fan light kit and its ceiling fan.

Item 29

5

OVERVIEW OF ANALYSES FOR ENERGY CONSERVATION STANDARDS RULEMAKING

DOE performs a range of analyses to ensure that it selects energy conservation standards that achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified and will result in significant energy savings, as required by EPCA. Economic justification includes the consideration of economic impacts on manufacturers and consumers, national benefits (including environmental impacts), issues of consumer utility, and impacts from any lessening of competition. DOE expects the selection of standards to achieve the maximum energy savings that are technologically feasible and economically justified without imposing excessive financial burden on any particular party.

31


Figure 5-1 summarizes the analytical components of DOE's standard-setting process. The analyses are listed in the third column. Each analysis requires a set of key inputs comprising data and information required for the analysis. The identified approaches are the methods that DOE will use to obtain key inputs, which may vary depending on the information in question. For example, some key inputs can be found in public databases. In support of this rulemaking, DOE will collect other information from interested parties or experts having special knowledge, and DOE itself will develop relevant information independently. The results of each analysis are key outputs that feed directly into the rulemaking. Arrows indicate the flow of information among the various analyses. DOE ensures a consistent approach to its analyses throughout the rulemaking by considering each analysis as a part of the overall standard-setting framework.

32


Approaches

Key Inputs
• Identify Firms/Products • Historical Shipments • Market Segmentation • Non-Regulatory Programs

Analyses

Key Outputs

Preliminary Analysis (based on Framework Document)
• Characterize Industry • Analysis of Market Data

Market and Technology Assessment
Product Classes Technology Options

• Product Classes • Technology Options

• Analysis of Product Data • Efficiency-Level Approach • Design Option Approach

• Product Prototypes

Screening Analysis
Design Options

• Design Options

• Manufacturing Cost • Efficiency/Performance

Engineering Analysis
Design Energy • Annual Energy Use (UEC) Retail Prices Energy-Efficiency Levels

• Cost-Efficiency Relationship

• Analysis of Energy Use Data • Define Distribution Channels • Economic Census Data Analysis • Retail Price Collection and Analysis

Energy Use Analysis Markups for Equipment Price Determination
• Energy Prices • Installation Costs • Maintenance & Repair Costs • Energy-Efficiency Levels

Life-Cycle Cost and Payback Period Analysis
Candidate Standard Levels • UEC • Energy Prices • Installation Costs • Maint Costs • Repair Costs

• Life-Cycle Costs • Payback Periods

• Accounting Approach • Backcast and Forecast • Market Saturation

Shipments Analysis
• Energy Price Forecasts • Site-to-Source Factors • Manufacturer Prices • Average Costs

National Impact Analysis Preliminary Manufacturer Impact Analysis

• National Energy Savings • Net Present Values

• Conversion Capital Expenditures • Direct Employment Impacts

Preliminary TSD Preliminary Analysis
• Stakeholder Comments

Revise Preliminary Analyses Consumer Sub-Group Analysis Manufacturer Impact Analysis Utility Impact Analysis Employment Impact Analysis Environmental Assessment Regulatory Impact Analysis

• Trial Standard Levels (TSLs) TSLs • Life-Cycle Costs • Payback Periods • Industry Cash Flow • Sub-Group Cash-Flow • Direct Employment Impacts • Competitive Impacts • Cumulative Regulatory Burden • Direct Employment Impacts • Utility Impacts

• Demographics • Manufacturer Prices • Average Costs • Manufacturer Interviews • GRIM Analysis • NEMS-BT • Manufacturer Financial Data • Utility Load Factors • National Energy Savings • National Energy Savings • National Product Costs • National Operating Costs

• IMSET

• National Employment Impacts

• NEMS-BT

• Emission Rates • National Energy Savings • Non-Regulatory Alternatives

• Emission Estimates • National Energy Savings • Net Present Values

NOPR TSD Final Rule Analysis
• Department of Justice Review • Stakeholder Comments

Revise Analyses

• Revised Results

Final Rule TSD

Figure 5-1

Flow Diagram of Analyses Conducted for an Energy Conservation
Standard Rulemaking

33

6

MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the ceiling fan and ceiling fan light kit industries, and the performance attributes of these products. DOE uses this information throughout the rulemaking. It is important to perform the market and technology assessment at the outset of the rulemaking in order to develop product classes and to identify design options or efficiency levels for each product class of ceiling fan and ceiling fan light kit being considered in this rulemaking. 6.1 Market Assessment

In the market assessment, DOE will characterize qualitatively and quantitatively the structure of the markets for ceiling fans and ceiling fan light kits. DOE will identify and characterize the manufacturers of the products, estimate market shares and trends, address regulatory and non-regulatory initiatives intended to improve the efficiency or reduce the energy consumption of covered products, and explore the potential for technological improvements in the design and manufacturing of such products. The market assessment enables DOE to gather data that will help identify issues important to the rulemaking (e.g., potential small business impacts, competitive disruptions, and other factors that may arise from enacting standards). The market assessment will establish the context for this rulemaking and will serve as a resource to guide the analyses that follow. For example, DOE will use historical product shipments and prices as a starting point for forecasting future shipments and prices. Market structure data will be particularly useful for assessing competitive impacts for the manufacturer impact analysis. The assessment also enables DOE to start updating design options by reviewing product literature, industry publications, and company websites. There may be limited public information on national shipments, manufacturing costs, channels of distribution, product lifetimes, and manufacturer market shares of ceiling fans and ceiling fan light kits. Such data represent an important input for analyses that determine whether energy conservation standards or energy use standards are economically justified and will result in significant energy savings. Therefore, DOE encourages interested parties to submit data that will improve DOE’s understanding of the ceiling fan and ceiling fan light kits markets. These data may be provided under a confidentiality agreement with DOE’s contractor responsible for this part of the rulemaking analysis. In other rulemakings, DOE’s contractors routinely work with confidential data provided by manufacturers and other organizations in preparing aggregated results for DOE’s analyses. These aggregated results do not divulge the sensitive, individual raw data, but enable other interested parties to comment on the aggregated dataset. Alternatively, interested parties may submit confidential data to DOE, indicating in writing, which data should remain confidential. Interested parties must submit confidential information to DOE according to the procedures outlined in 10 CFR 1004.11. Pursuant to 10 CFR 1004.11, any person submitting information that he or she believes to be confidential and exempt by law from public disclosure should submit two copies. One copy of the document must include all the information believed to be confidential, and the other copy must have the

34


information believed to be confidential deleted. DOE will make its own determination about the confidential status of the information and treat it accordingly.13 Item 30 DOE requests information that would contribute to the market assessment for ceiling fans and ceiling fan light kits covered in this rulemaking (e.g., current product features and efficiencies, trends in product features and efficiency, and historical product shipments and prices). DOE welcomes input on estimates of market shares, products, features, and trends for the ceiling fans and ceiling fan light kits covered in this rulemaking.

Item 31

6.1.1 Manufacturer Trade Group DOE recognizes the importance of trade groups in disseminating information and promoting the interests of the industry that they support. DOE identified the ALA as the primary group that supports, and has an interest in, ceiling fans and ceiling fan light kits. The ALA is a trade organization that represents lighting (including ceiling fan light kits) and ceiling fan manufacturers, designers, retail showrooms, and distributors working to promote the sale and proper use of quality residential lighting products. The ALA provides specific information regarding the selection, benefits, and proper use of ceiling fans. The ALA also advocates the interests of the industry regarding Federal and State legislative and regulatory issues. Ceiling fan light kit manufacturers do not manufacture their kits’ light sources, which manufacturers are required to package with their light kits, according to current energy efficiency standards. (42 U.S.C. 6295(ff)) Traditional lighting companies such as General Electric, Philips, and OSRAM SYLVANIA generally produce the light sources (consumer replaceable lamps), which are purchased by the ceiling fan light kit manufacturers. The National Electrical Manufacturers Association represents those traditional light source companies. 6.1.2 Manufacturers and Market Shares This section describes major ceiling fan and ceiling fan light kits retailers and manufacturers and their market shares, historical shipments, saturation levels, and product lifetimes.

Factors that DOE considers when evaluating requests to treat submitted information as confidential include: (1) a description of the items; (2) whether and why such items are customarily treated as confidential within the industry; (3) whether the information is generally known by or available from other public sources; (4) whether the information has previously been made available to others without obligation concerning its confidentiality; (5) an explanation of the competitive injury to the submitting person which would result from public disclosure; (6) a date after which such information might lose its confidential character; and (7) why disclosure of the information would be contrary to the public interest. 35


13

6.1.2.1 Retailers Ceiling fans and ceiling fan light kits generally are available to consumers from so-called brick-and-mortar retailers, Internet sellers, and ceiling fan and lighting showrooms. Brick-and-mortar retailers have a physical retail building that consumers can visit to view products and make purchases. There are several sub-types in this category, including:  Mass market retailers—national chain stores such as home centers, discount stores, and hardware stores;  Regional stores, which may have multiple outlets like the mass market retailers, but are limited to a single region;  Specialty stores, which usually offer a broad range of products in a narrow product category and can be mass market, regional, or independent owners having a single retail outlet; and  Club or warehouse stores, which require a membership fee for customers to gain access to the goods, which usually are sold in bulk. Online sales may be via a division of any of the brick-and-mortar retailers, sometimes called “clicks and bricks,” or via a dedicated online retailer. Ceiling fan and lighting showrooms typically offer direct-to-builder services as well as a front showroom for consumer purchases. Several products will be displayed in the showroom similar to other retailers but consumer options are vastly expanded through the ability to order through manufacturer catalogues. These showrooms may also offer other builder items such as ventilation fans and exit signs. Many of these showrooms also offer sales via the Internet. DOE has considered national data from the NPD Group to describe retailers’ market shares. NPD does not collect point-of-sales data for ceiling fans and ceiling fan light kits. Instead, it surveys a representative sample of consumers who recently purchased a ceiling fan. In describing their techniques, NPD stated that they reach out to “approximately 200,000 panelists each month (equivalent to 100,000 completes) and ask them about their appliance purchasing. Specifically, we ask them the appliance purchased, where purchased at, brand purchased and price paid as well as a number of other purchase drivers (the “why’s”) regarding their purchase. From there, we project this information, using the Census population, to be representative of a total U.S. market size estimate. Additionally, we use actual retail POS [point­ of-sale] data to inform our consumer-driven market size estimates.” (NPD, personal email communication, June 4, 2012.) Three so-called “big-box” retailers (Home Depot, Lowe’s, and Wal-Mart) comprise approximately 80 percent of the market for ceiling fans purchased in the United States in 2011, as shown in Table 6-1.

36


Table 6-1

Market Shares of Ceiling Fan Retailers in 2011 Market Share % 36 32 11 4 2 2 1 1 1 1 9 100

Retailer Home Depot Lowe's Wal-Mart Menards Lighting and Electrical Supply Store Ace Hardware Kmart Sears Target Costco Price Club Others Total
Source: NPD Group, 2011.

6.1.2.2 Major Manufacturers Six brands represented more than half of ceiling fan sales in the United States in 2011: Casablanca, Emerson, Hunter Fans, Hampton Bay, Harbor Breeze, and Westinghouse.14 Of those six brands, three (Hunter Fans, Hampton Bay, and Harbor Breeze) represented more than 45 percent of the market in 2011. Hampton Bay is a Home Depot brand, and Harbor Breeze is a Lowe’s brand. Casablanca is owned by Hunter Fans. A breakdown of ceiling fan brands’ market shares based on NPD data is set out in Figure 6-1.

14

Consumer survey data for 2011 purchased from NPD Group, Inc. 37


Figure 6-1

Market Shares of Ceiling Fan Manufacturers in 2011 (NPD, 2011)

Generally speaking, the companies that manufacture and market ceiling fan light kits are the same companies that produce ceiling fans. According to the ALA, in big-box retail outlets, about 90 percent of ceiling fans sold are pre-packaged with light kits produced by or for the fan manufacturer, and although only about 50 percent of ceiling fans sold in lighting showrooms come pre-packed with light kits, about 95 percent can accommodate them. Also according to ALA, about 50 percent of ceiling fans have built-in (non-detachable) light kits. Given the high percentage of ceiling fans that were sold by big-box retailers in 2011 (as shown in Table 6-1), and the fact that light kits, having no moving parts, should last at least as long as fans and are, therefore, unlikely to be replaced during the lifetime of the fan, the light kit market clearly also is dominated by the big-box retailers, the largest of which produce their own brands. However, light kits are also available for independent purchase, especially online, and most detachable light kits can be used with most fans that accept ceiling fan light kits. Therefore, the light kit market may not be identical to the ceiling fan market (for which more data are available), but it should be similar. Findings from surveys conducted for this rulemaking in four Home Depot stores in California and Massachusetts and from data purchased from NPD substantiate the ALA estimates. Eighty-nine percent of 96 models of ceiling fan sold in the Home Depot stores included light kits. According to NPD (2011) consumer surveys, 88 percent of ceiling fans sold nationally included light kits. Market shares for ceiling fans for years between 2007 and 2011 are listed in Table 6-2.

38


Table 6-2 Rank 1 2 3 4 5 6 7 8 9 10 11 12 13

Market Shares of Ceiling Fan Manufacturers 2007 2008 2009 2010 2011 Brand % % % % % Other Hunter Hampton Bay Harbor Breeze Casablanca Westinghouse Emerson Aloha Breeze Impressions Ace Encon Minka Aire Monte Carlo 43.6 18.6 14.6 11.8 4.8 3.4 1.9 0.0 0.4 0.0 0.3 0.2 0.6 55.0 44.9 46.4 15.5 12.5 11.6 5.1 4.1 1.9 0.9 1.0 0.1 0.2 0.3 0.5 50.6 39.5 43.8 15.9 14.6 11.9 3.7 3.8 2.3 2.1 0.6 0.3 0.2 0.1 0.5 52.2 42.4 41.3 17.3 13.6 13.2 5.1 3.5 2.2 1.9 0.5 0.4 0.4 0.1 0.5 54.9 44.1 41.8 17.7 15.6 11.9 5.0 3.1 2.5 1.1 0.5 0.3 0.2 0.2 0.0 55.7 45.2

Total share of top 6 brands % Total share of top 3 brands %
Source: NPD Group, 2007-2011.

Most ceiling fans available on the U.S. market are manufactured (components and assembly) in Asia by a variety of manufacturers of various sizes, some of which maintain a steady presence in ceiling fan manufacturing and some of which remain only for short periods. Therefore, it is difficult to create a complete and accurate list of ceiling fan manufacturers. Ceiling fan companies undertake design reviews at least annually to select manufacturers for their products. Sometimes more than one factory supplies the same model of ceiling fan, and the same factory may make ceiling fans for multiple brands.15 In 2012, for example, manufacturers of the Home Depot brand (Hampton Bay), included Air Cool Industrial Co., King of Fans, and Hong Kong China Electrical Manufacture Co. Ltd.16 Manufacturers of the Lowe’s brand, Harbor Breeze, included Artisan Industrial Co Ltd., Chien Luen Industries Co. Ltd. Inc., China, Fanimation Inc., Hong Kong China Electrical Manufacture Co. Ltd., Landmark Enterprise, and Litex Industries Inc./Ellington Fans.16

Opinion Dynamics Corporation for The Consortium for Energy Efficiency, Residential Lighting Fixture Market Assessment: Ceiling Fans and Outdoor Lighting (2000), and Vin Mehta, personal communication (August 2012). 16 ENERGY STAR. Fans, Ceiling for Consumers.(2012) (List as of August 16th 2012; last accessed August 30, 2012) (Available at: http://www.energystar.gov/index.cfm?fuseaction=find_a_product.showProductGroup&pgw_code=CF); The California Energy Commission, Appliance Efficiency Database (2012) (Last accessed August 30, 2012) (Available at: http://www.appliances.energy.ca.gov/QuickSearch.aspx). 39


15

In 2012, ceiling fan manufacturers that appeared on product lists for ENERGY STAR and the California Energy Commission16 included: Air Cool Industrial Co., Ltd.; Aloha Worldwide Co.; Artisan Industrial Co Ltd., China; Banvil 2000; Big Ass Fans; Canarm Ltd.; Casablanca Fan Company; Ceiling Fans Direct Inc.; Chien Luen Industries Co. Ltd., Inc.; Concord Fans; Craftmade International Inc., Emerson Electric, Company, Encompass Lighting Group LLC, Epiphany Lighting; Fanimation Inc.; Furn Fan Corporation; Grainger Industrial Supply; Gulf Coast Fans Inc.; HD Supply Facilities Maintenance; Hong Kong China Electrical Manufacture Co. Ltd.; Hunter Fan Company; Kendal Lighting; Kichler Lighting; King of Fans; King One Products Co.; Lamps Plus Corporate; Landmark Enterprise; Light Process Company; Litex Industries, Inc./Ellington Fans; Minka Group; Modern Fan Company; Monte Carlo Fan Company; Nicor Inc.; Orgill Inc.; Palm Coast Imports; Progress Lighting; Project Lighting Company, Inc.; Quorum International; Regency Ceiling Fans; Royal Pacific Ltd.; Savoy House; Sea Gull Lighting Products LLC; Sunset Lighting and Fans; Sunway Fan Company, Inc.; Vaxcel International Trading Co. Ltd.; Volume International Corporation; Westinghouse Lighting Corporation; Westwind Products Inc.; Yellow Energy; and Yu Yuan Industrial Co., Ltd. An August 2012 sample list of ENERGY STAR partners who manufacture ceiling fan products qualified for ENERGY STAR version 3.0 is provided in Table 6-3. Note that this list is updated regularly as new products are certified. Table 6-3 Sample List of ENERGY STAR Partners Manufacturing Version 3.0 Qualified Ceiling Fans With and Without Light Kits ENERGY STAR Partner Air Cool Industrial Co., Ltd. Artisan Industrial Co., Ltd. Banvil 2000 Big-Ass Fans Chien Luen Industries Co. Ltd., Inc. Concord Fans Emerson Electric Company Epiphany Lighting Fanimation Inc. Generation Brands HD Supply Facilities Maintenance Hunter Fan Company Kendal Lighting Kichler Lighting King of Fans Lamps Plus Corporate Litex Industries, Inc./ Ellington Fans Minka Group Ceiling Fan Only X X X X X X X X X X X X X X X X X
40


Ceiling Fan with Light Kit X X

X

X

X X X

X

ENERGY STAR Partner Orgill, Inc. Progress Lighting Quorum International Ralada International Ltd., Regency Ceiling Fans Royal Pacific Ltd. Savoy House Summerwind International Limited Sunway Fan Company, Inc. Volume International Corporation Westwind Products Inc. Yellow Energy Yu Yuan Industrial Co., Ltd.

Ceiling Fan Only X X X X X X X X X X X X X

Ceiling Fan with Light Kit

X

X

Source: EPA, Fans, Ceiling for Consumers (2012) (List updated August 16, 2012; last accessed August 30, 2012) (Available at. http://www.energystar.gov/index.cfm?fuseaction=find_a_product.showProductGroup&pgw_code=CF).

6.1.2.3 Historical Shipments In evaluating overall U.S. shipments, DOE has considered data from three sources: (1) NPD; (2) ENERGY STAR; and (3) Appliance Magazine. DOE collated the data sets for their different time periods and different methodologies based on considering the market from different viewpoints. NPD data were described in section 6.1.2.1. Shipments data from Appliance Magazine were extracted from that source’s annual statistical review of the U.S. appliance industry.17 Appliance Magazine sources may include Appliance Magazine, the Air-Conditioning and Refrigeration Institute; Association of Home Appliance Manufacturers; Consumer Electronics Association; Gartner; Gas Appliance Manufacturers Association; Hearth, Patio & Barbeque Association; International Data Corporation; Outdoor Power Equipment Institute; and the Water Quality Association. The data have not included exports since 1997. ENERGY STAR shipments and market share data are reported for two categories, namely ENERGY STAR-qualified ceiling fans with and without light kits. ENERGY STAR takes partner-reported data to be representative of qualified ceiling fan shipments without adjusting for partners who do not report their shipments. This means that the ENERGY STAR data represent a conservative estimate, although the response rate among ceiling fan manufacturers is typically high, for example, 89 percent in 2010. In order to estimate the market share of ENERGY STAR-qualified ceiling fans, ENERGY STAR estimates U.S. shipments based on modeled and documented data. Ceiling fan
17

Appliance® Statistical Review, Annual Report, Appliance Magazine (2003-2006) 41


industry data are used as a direct input whenever possible and compared to forecast assumptions to ensure data comparability. Industry sources may include ceiling fan manufacturer associations, publications, and commercially-available market research. Market shares for ENERGY STAR-qualified products, as reported by ENERGY STAR, are shown in Table 6-4. Market shares of qualifying ceiling fans sold with light kits are low, because only pin-based fluorescents could qualify under the existing ENERGY STAR requirements. Table 6-4 Historical Shipments and Market Shares of ENERGY STAR-Qualified Products Only Year Ceiling Fans Ceiling Fans Light Kits Manufacturer Reporting Without Light with Light Kits Only Information Kits Total % Total % Total % No. Partners % U.S. ES* U.S. ES U.S. ES Respondents 2,631,000 34 166,000 2 24,900 1 23 91 3,022,565 39 368,355 4 130,276 6 25 100 1,845,052 24 117,289 1 11,952 1 27 93 2,646,934 34 132,100 1 21,120 1 29 97 2,500,309 32 126,769 1 45,436 2 32 100 1,266,000 16 219,000 2 61,000 3 37 100 1,394,000 18 304,000 3 171,000 8 46 89

2004 2005 2006 2007 2008 2009 2010

Source: http://www.energystar.gov/index.cfm?c=partners.unit_shipment_data.
Note: Reported ENERGY STAR units shipped are values reported by manufacturers, and they are not amended for
missing data.
*ES = ENERGY STAR.


Historical NPD shipments data are shown in Table 6-5. Note that the NPD consumer survey did not specifically ask whether the ceiling fan light kit was already integrated with the ceiling fan at the time of purchase or simply purchased at the same time. Table 6-5 Historical Shipments of All Ceiling Fans With and Without Light Kits 2007 14,899,594 2,176,229 3,970,371 21,046,194 2008 15,485,300 2,226,826 3,080,311 20,792,436 2009 16,015,248 2,106,832 3,561,611 21,683,691 2010 14,414,909 2,184,390 2,830,707 19,430,006 2011 14,597,241 2,035,746 2,140,867 18,773,853

Number of Units With Light Without Light Not Specified Total

Source: NPD Group (2007-2011).

Overall shipments based on NPD, ENERGY STAR, and Appliance Magazine data are fairly consistent, as shown in Table 6-6. The ENERGY STAR shipments data for all U.S. ceiling fans included in Table 6-6 have been calculated from the estimates of shipments and market shares of ENERGY STAR-qualified ceiling fans. ENERGY STAR shipments are divided by
42

market share to estimate the total U.S. shipments for ceiling fans both with and without light kits. The total U.S. shipments are the sum of the U.S. shipments for those two categories. Table 6-6 Sources Comparison of Historical Shipments of Ceiling Fans from Different Data
2011 N/A N/A 18,774

Total No. of Units 2003 2004 2005 2006 2007 2008 2009 2010 ’000 ENERGY STAR 16,664 16,038 16,959 19,417 20,995 20,490 18,863 17,878 Appliance Magazine 15,500 16,700 16,800 17,000 N/A N/A N/A N/A NPD N/A N/A N/A N/A 21,046 20,792 21,684 19,430 Sources: NPD (2007-2011); ENERGY STAR (2007-2010); and Appliance Magazine (2003-2006).

DOE also examined the market makeup on the basis of blade span. More than half of ceiling fans sold have blade spans of between 42 and 52 inches. About a quarter have blade spans of between 30 and 40 inches. This trend seems reasonably consistent over time. Figure 6-2 shows market shares of ceiling fans by blade span in 2011.
Not  Specified Don't know 11% 5% 54 in or  larger 9%

2011
30‐40 in 23%

42‐52 in 51%

Source: NPD (2011).

Figure 6-2

Market Shares of Ceiling Fans by Blade Span in 2011

Market shares by blade span between 2007 and 2011 are displayed in Figure 6-3 and Table 6-7.

43


60% 50% Market share 40% 30% 20% 10% 0% 2007 2008 2009 Year Source: NPD (2007–2011). 2010 2011 30‐40 in 42‐52 in 54 in or larger Don't know Not Specified

Figure 6-3 Table 6-7

Market Shares of Ceiling Fans by Blade Span for 2007–2011

Market Share by Blade Span 2007 % 18 51 8 4 19 2008 % 19 53 8 5 15 2009 % 21 51 7 6 17 2010 % 22 51 7 6 15 2011 % 23 51 9 5 11

Ceiling Fan Size 30-40 in. 42-52 in. 54 in. or larger Don't know Not specified

Source: NPD (2007–2011).
Note: Values may not add to 100% due to rounding


6.1.2.4 Saturation According to the 2009 Residential Energy Consumption Survey (RECS),18 73 percent of U.S. homes had ceiling fans in 2009. Ownership varied significantly by region, ranging from 57 percent to 85 percent. Figure 6-4 shows U.S. ceiling fan ownership by region. Figure 6-5 shows usage by region.

18

U.S. Department of Energy–Energy Information Administration, Residential Energy Consumption Survey (RECS), 2009 RECS Survey Data (2011) (Last accessed Sept. 7, 2012) (Available at: http://www.eia.gov/consumption/residential/data/2009/). 44


U.S. Ceiling Fan Ownership by Region and Average  per Household 2009
Pacific Mountain South Mountain North West South Central East South Central South Atlantic West North Central East North Central Middle Atlantic New England 0% 20% 40% 60% 80% 100% Households in Millions U.S. Census Division

3+ 2 1 0

Source: RECS (2009).

Figure 6-4

U.S. Ceiling Fan Ownership by Region and Average Number of Ceiling Fans Per Household
60.0 50.0 40.0 30.0 20.0 10.0 0.0 Used only a few days or nights, when really needed Used quite a bit Used just about all summer Not used at all

Percentage of households with a ceiling fan

2009

Census Division

Source: RECS (2009).

Figure 6-5

U.S. Ceiling Fan Usage by Region

45


6.1.2.5 Product Lifetime DOE has begun to investigate life expectancy of ceiling fans. Data from Appliance Magazine suggest significant variation in the life expectancy of ceiling fans, between 7 and 18 years.19 Estimates represent expert judgment of Appliance Magazine staff. DOE also notes that ceiling fan motors often come with a limited lifetime warranty for the motor, and that a 30-year warranty is required for the motor in order for a ceiling fan to qualify for ENERGY STAR. DOE anticipates that lifetimes of ceiling fans will vary greatly depending on intensity of usage. The variation in usage among regions will be an important factor for DOE to consider. DOE has not found significant data on life expectancy of ceiling fans and is unaware of any data on the relationship between usage and life expectancy. Therefore, DOE seeks comments, input, and data on ceiling fan life expectancy and, in particular, the relationship between ceiling fan usage and ceiling fan life expectancy. DOE has not found independent data on ceiling fan light kit lifetimes. But DOE does not believe that it will need information on ceiling fan light kits lifetimes for this rulemaking, for reasons explained in section 11.5. Item 32 DOE seeks input and data on ceiling fan life expectancy and, in particular, the relationship between ceiling fan usage and ceiling fan life expectancy.

6.1.3

Product Classes

When necessary, DOE divides covered products into classes by: (1) the type of energy used; (2) the capacity of the product; or (3) any other performance-related feature that justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE then conducts its analysis and considers establishing separate standard levels for each product class. The following sections discuss DOE's approach to establishing product classes for ceiling fans and ceiling fan light kits. 6.1.3.1 Ceiling Fans As mentioned previously, DOE defines the term “ceiling fan” to mean “a nonportable device that is suspended from a ceiling for circulating air via the rotation of fan blades.” It defines “ceiling fan light kit” as “equipment designed to provide light from a ceiling fan that can be integral, such that the equipment is attached to the ceiling fan prior to the time of retail sale; or attachable, such that at the time of retail sale the equipment is not physically attached to the ceiling fan, but may be included inside the ceiling fan at the time of sale or sold separately for subsequent attachment to the fan.” 10 CFR 430.2.

19

Appliance Magazine, The 22nd Portrait of the U.S. Appliance Industry (2001). 46


DOE proposes that product classes be determined on the basis of functionality delivered to the consumer. DOE does not plan to differentiate product classes based on the type of energy used, because all ceiling fans and ceiling fan light kits are powered by electricity. Neither does DOE plan to differentiate product classes based on capacity (or blade span, as applied to ceiling fans) of the product, because DOE instead plans to account for blade span by developing a relationship between efficiency and blade span and applying it to the engineering analysis. DOE plans to examine a range of blade sizes to determine if there is a functional relationship between fan efficiency and blade size. In analyzing the cost of efficiency improvements (described in subsequent sections of this document), DOE plans to examine representative ceiling fan blade span sizes as part of the process of developing a continuous specification relating airflow efficiency or energy consumption limits to blade span. For example, ceiling fan standards could be in a form in which the minimum efficiency for a given fan is determined by an equation that takes into account the fan’s blade span. In DOE’s previous rulemaking addressing ceiling fans, DOE did not establish any product classes for ceiling fans. 71 FR 71340 (Dec. 8, 2006). In that rulemaking, DOE did not establish standards for ceiling fans beyond the design standards in section 325(ff) of EPCA, which apply to all ceiling fans. (42 U.S.C. 6295(ff)). DOE also interpreted hugger fans as falling outside the definition of “ceiling fan” and did not define “highly decorative fans for which air movement performance is a secondary design feature.” Thus, the requirement for DOE to consider whether highly decorative fans should be a separate exempted product class did not need to be addressed at that time. 71 FR 71340, 71343 (Dec. 8, 2006). In this rulemaking, DOE proposes to reinterpret the definition of “ceiling fan” to include hugger fans. DOE also must consider establishing “separate, exempted product classes for highly decorative fans for which air movement performance is a secondary design feature.” (42 U.S.C. 6295(ff)(6); see section 2.1) Accordingly, in this rulemaking DOE is considering establishing separate product classes for both hugger fans and highly decorative fans for which air movement performance is a secondary design feature. With regard to hugger fans, DOE contends that they, like other types of ceiling fans, move air via the rotation of fan blades, are intended to improve comfort, and are rated on their ability to move air (as measured in CFM). DOE has tentatively concluded that the only distinguishing feature of hugger fans is that they can be used in rooms with lower ceilings. Using typical ceiling fans (i.e., ones with a downrod) in rooms having lower ceilings can create safety issues, thereby making hugger fans useful in those circumstances. For these reasons, DOE is proposing to establish a separate product class for hugger fans. As noted above, DOE is proposing to define “highly decorative fans for which air movement performance is a secondary feature” as“a nonportable device that is suspended from a ceiling, and that circulates air via the rotation of fan blades at a maximum rotational speed of 50 RPM.” DOE is considering establishing a separate product class for this category if it finds that there are fans that meet this definition. DOE notes that most ceiling fans are sold with a rating that specifies the type of environment in which they can be safely used (e.g., indoor, wet, or damp). Wet-rated or damprated ceiling fans are suitable for use outdoors and in humid environments such as bathrooms.
47


Both types may be classified together as outdoor ceiling fans. As with other ceiling fan types, they move air via rotation of fan blades, are intended to improve comfort, and are rated on their ability to move air (as measured in CFM). Such ceiling fans are designed somewhat differently than indoor ceiling fans in that the blades often are made of different material (or with a different finish), and the motor housing is sealed to prevent damage from water or water vapor. DOE is considering creating a separate product class for outdoor ceiling fans in order to take into account the additional costs associated with these products. DOE seeks comment on whether it would be appropriate to differentiate product classes for ceiling fans based on the type of environment in which they can be used. Most ceiling fans are aimed at conventional indoor use. In order to distinguish these fans from outdoor fans, DOE proposes to create a product class for indoor ceiling fans. DOE is considering creating the following product classes based on functionality delivered to the consumer. At this time DOE knows of no performance-related features that would require establishing additional product classes beyond the following. 1. Indoor ceiling fans. These products represent the bulk of the market. Air movement performance is a primary feature, but these products may not be suitable for use in damp or wet conditions and are not designed to be mounted flush with the ceiling. 2. Hugger fans. These products also have air movement performance as a primary feature, but they can be used in rooms that have low ceilings. DOE is proposing to include multi-mount fans in this product class. 3. Highly decorative ceiling fans. These are products for which aesthetics and ambiance are of primary concern and for which air movement performance is a secondary feature. 4. Outdoor ceiling fans. These products can be used in wet or damp conditions, for instance in bathrooms or on a covered porch. Air movement performance is a primary feature for these fans. DOE seeks comment on its approach for differentiating product classes for ceiling fans and on any other potential methods for establishing product classes that fulfill the requirements of 42 U.S.C. 6295(q). Item 33 DOE welcomes comments on whether it should establish a separate product class for hugger fans.

48


Item 34

DOE welcomes comments on whether it should establish a separate product class for “highly decorative fans for which air movement performance is a secondary feature.” DOE also seeks input on whether such ceiling fans should be subject to or exempted from energy conservation standards. DOE seeks input on whether the differences between the construction of outdoor and indoor ceiling fans warrants establishing a separate product class for outdoor ceiling fans. DOE seeks feedback from interested parties on its general approach to developing product classes.

Item 35

Item 36

6.1.3.2 Ceiling Fan Light Kits As previously discussed, DOE currently divides ceiling fan light kits into three products classes, depending on the type of light socket: (class 1) medium screw based, (class 2) pin-based fluorescent, and (class 3) all other types. Table 6-8 summarizes the primary requirements of the energy conservation standards for the different product classes and the energy efficiency metrics used. Table 6-8 Kits Energy Conservation Standards and Efficiency Metrics for Ceiling Fan Light Primary Requirement of Standard Energy Efficiency Metric [Corresponding Test Procedure] Lamp efficacy (lm/W)

Product Class

Class 1: Medium screw base (E26)

Class 2: Pinbased fluorescent

Class 3: All other light kits not included in Class 1 or Class 2

Package with compact fluorescent lamps (CFLs) that meet the ENERGY STAR requirements for CFLs, version 3, or with lamps having equivalent lm/W performance. The light kit must meet the ENERGY STAR requirements for residential light fixtures, version 4.0 and be packaged with lamps to fill all sockets. Shall not be capable of operating with lamps that total more than 190 watts.

Source CFR 430.32(s)(2); 42 U.S.C. 6295(ff)(2)

Lamp efficacy (lm/W)

CFR 430.32(s)(3); 42 U.S.C 6295(ff)(3)

Wattage limit

CFR 430.32(s)(4); 42 U.S.C 6295(ff)(4)

49


As mentioned in section 4.1.2.2, DOE is considering combining or restructuring ceiling fan light kit products classes from the current three into one or two product classes if the following conditions are met: (1) DOE finds that a common efficiency standard level is technically feasible and economically justified, (2) it does not result in backsliding within any of the original product classes, and (3) and if the products are found to offer the same consumer utility. Separate product classes typically are established when products offer significantly different consumer utility. DOE is not aware of any differences in consumer utility among the three product classes. DOE believes that the current system, in which multiple metrics are utilized for compliance, is atypical and unnecessarily complicated. DOE is considering moving to a single metric (lumens per watt (lm/W)) for all product classes (see section 4.1.2.2). DOE is also aware that there are ceiling fan light kits that are packaged with or have integrated dimming functionality and that these products may offer unique performance characteristics and consumer utility over ceiling fan light kits that are not packaged with dimming functionality, but which may allow for separately packaged dimming functionality. Item 37 DOE requests feedback on the possibility of combining or restructuring product classes for ceiling fan light kits specifically on: (i) significant consumer utility differences among ceiling fan light kits; (ii) which products should be combined; and (iii) what issues should be considered. DOE requests feedback the consumer utility of ceiling fan light kits that are packaged with dimming functionality.

Item 38

6.2

Technology Assessment

The technology assessment centers on understanding how ceiling fans and ceiling fan light kits use energy and on identifying potential technological changes that may improve the efficiency of these products. Measures that improve the energy efficiency of the product are called “technology options,” and they are based on existing technologies, as well as prototype designs and concepts. In consultation with interested parties, DOE will develop a list of technology options for consideration in this rulemaking. Following research into this list of technology options, DOE will consider each one against four screening criteria: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product utility or availability; and (4) adverse impacts on health or safety. The screening analysis is discussed in further detail in section 7. Those technology options that pass the four screening criteria become “design options” and will be considered in the engineering analysis as appropriate ways of improving the efficiency and will assist DOE in determining the “max-tech” design. The following sections discuss potential technology options for ceiling fans and ceiling fan light kits.

50


6.2.1

Improving Ceiling Fan Efficiency

Ceiling fan airflow efficiency is the ratio of the volume of air moved by the fan in a given interval of time to the amount of electricity consumed. This air movement depends on three factors: (1) blade design (including number and shape of blades); (2) motor type and design; and (3) installation location (the distance from the ceiling and from the floor/person being cooled). The three factors can be subdivided into the following seven factors. 1. Blade pitch, which is the angle of the blade relative to the fan. The steeper the blade pitch, the more air the blade will move with each sweep. A steep pitch, however, also increases the amount of energy required to move the fan. Thus, a balance is sought between maximizing blade pitch without overworking the motor. Since the optimal pitch depends on the size, shape, and speed at which a ceiling fan is operating, it is difficult to isolate it as a separate variable, and instead, it will be incorporated into the general analysis of fan blade shape. 2. Blade shape and width. As with pitch, the shape and width of the fan blade will have a large impact on the amount of air the fan can move and the energy needed to move it. A wider blade will move more air, but it will place a greater burden on the motor. 3. Number of blades. Fewer blades increase efficiency and RPM but can also have an impact on air noise due to the increased RPM. 4. Blade span. Longer blades move more air than smaller blades at a given RPM. As with wider blades, longer blades may place a greater burden on the motor, or require a larger motor. 5. RPM, which is the number of blade rotations in a minute and a measure of the ceiling fan speed. There are tradeoffs between greater airflow and increased energy consumption at higher RPMs, as well as safety issues associated with very high RPMs. Ceiling fans sold in the U.S. are required to have adjustable speed controls and typically have 3 or 4 RPM options. Since RPM is directly related to airflow and airflow is addressed through the other factors listed here, DOE does not consider RPM a separate design option. 6. Height from ceiling and floor. Fans that are mounted closer than 9 inches to the ceiling are more likely to wobble and shudder because of resonance effects on the shorter pendulum arm resulting from any imbalance of the blades or electrical forces in the motor. Fans that are mounted close to the ceiling cannot efficiently move as much air, because the proximity of the ceiling limits access to air supply and restricts heat dissipation from the motor, thereby requiring motors that do not produce as much heat. 7. Motor. Different types of ceiling fan motors are capable of different levels of electrical efficiency.

51


In addition to these seven factors that can influence airflow efficiency, occupancy sensors can also have an impact on the overall efficiency of a ceiling fan. Occupancy sensors can save energy by signaling to a ceiling fan to power down if a room is unoccupied. Figure 6-6 shows some of the key elements of a ceiling fan that can be improved to reduce energy consumption.

Electronic Speed Control (for brushless DC motor) Blade Occupancy Sensor

Motor

Switch

Capacitor Speed Control (for AC induction motor)

Source: Sathaye et al. (2012).20 Image Sources
Fan: Aavaas (2011).
Sofa: shutterstock (2011).
Sensor: Schneider Electric (2011).


 

Figure 6-6

Depiction of Ceiling Fan System Components That Can be Improved to
Reduce Energy Consumption


The key design factors that can be modified to affect the efficiency of ceiling fans are motors and fan blades. 6.2.1.1 Motors The electric motor that powers the fan is among the most important factors in determining the energy efficiency of a ceiling fan. The primary component of ceiling fan motors is the rotor that converts electromagnetic force into mechanical rotation to drive the fan blades. The rotor consists of a stack of steel sheets that has slots set at a specific angle and injected with aluminium. The stator contains the main and auxiliary windings that create the magnetic force used to drive the fan rotor. Magnetic force travels along the stationary slots of the stator to the rotor through the air gap between stator and rotor, driving the rotor. Higher quality motors tend to use silicon steel, which reduces loss of power in the rotor compared to cold-rolled steel (CRS) which is often used in cheaper motors.

20

Sathaye, N., Phadke, A., Shah, A., and Letschert, V. (LBNL, EETD), Potential Global Benefits of Improved Ceiling Fan Energy Efficiency (2012). 52


The most common ceiling fan motor is a single-phase induction motor (permanent-split capacitor type) with an external rotor. The efficiency of such motors can be improved by increasing the size of (or the quality of steel used in) the stator and rotor stack, improving the lamination design, increasing the cross section of copper wiring, or operating the fan at reduced speed through capacitor speed control. Most induction motors are mounted to the fan blades directly. This configuration is known as direct-drive and means that the fan and motor rotate at the same speed. In principle, ceiling fans could attach the fan blades to the motor via a geared mechanism that allows the fan blades to rotate at a different speed than the motor (a technology used in many industrial fans). This would enable higher motor speeds for a given fan RPM, which could increase overall efficiency. The most efficient ceiling fans on the market have brushless direct current (BLDC) motors. BLDC motors are permanent magnet synchronous alternating current (AC) motors driven by a converter plus inverter combination control system. In this configuration, the motor displays characteristics of direct current motors; thus, they are called brushless direct current motors. Because there is no electrical current flowing in the rotor of a BLDC motor, there are no rotor energy losses, thereby resulting in greater efficiency. While a typical ceiling fan has an efficiency of about 86 CFM/W, fans that have a BLDC motor are capable of efficiency ratings of more than 300 CFM/W. These fans tend to be higher-end products, and the increase in efficiency is likely attributable not only to the motor type but also to other design features (e.g., the blade shape and number of blades). Another advantage of these motors is that they tend to be smaller and make less noise than those found in traditional ceiling fan motors. One disadvantage of BLDC motors is that the lifetime of the motor may be less than the lifetime of an induction motor due to the electronic controls required to run the BLDC motor. Although BLDC motors are more common in premium fans (in terms of other features such as materials and design), some manufacturers include more-expensive BLDC motors in lower-priced, conventional ceiling fans, which may have been achieved by compromising on other features, such as including a less expensive remote control.21 BLDC motors require additional controls to enable them to function on AC current in a typical home. The additional controls increase the cost of BLDC motors compared to induction motors. Generally, excluding the additional controls which are necessary for it to function in a home, the costs of a BLDC motor are comparable to the costs of some induction motors. DOE seeks input on cost differences between BLDC motors and induction motors. The following are types of motors that can be used in ceiling fans.  Direct-drive single-phase induction motors. This is the most common type of motor used in ceiling fans. Fan blades are mounted directly to the motor, and the motor is made to operate at the same speed as blade rotation.  Geared single-phase induction motors. Most ceiling fan motors are not as efficient as they could be, because they are low-speed direct-drive motors. Induction motors can be
21

See: http://www.hansenwholesale.com/ceilingfans/reviews/ceiling-fans-dc-motors.asp. 53


made more efficient if they are designed for much higher RPM. By including a gear mechanism, higher RPM motors can be used in ceiling fans. DOE is not aware of any ceiling fans currently on the market that use gear driven motors, though such motors are used in industrial fans.  BLDC motors. BLDC motors require less electricity and copper wiring to produce the same amount of power. The rotor magnetic field in BLDC motors is stationary, which reduces rotor losses and makes them significantly more efficient. Typically, ceiling fans that have a BLDC motor are approximately 300 percent more efficient than conventional ceiling fan motors.  Three-phase induction motors. Due to recent developments in the electronics of control systems, single-phase induction motors may be able to be replaced by more efficient three-phase induction motors. Three-phase motors are more efficient due to their simpler motor circuit, which results in lower losses. DOE is not aware of any ceiling fans currently on the market that use three-phase induction motors, although fans with threephase motors are commonly used in industrial and commercial locations. Modern electronics can efficiently transform a single-phase system commonly used in residential locations into a three-phase system for these motors. 6.2.1.2 Number of Blades The number of blades in a ceiling fan affects its efficiency. In general, ceiling fans that have fewer blades are more efficient, because they are subject to less air resistance. However, fans that have fewer blades have also been known to generate more noise during operation because of the additional space between the blades. Unwanted noise is why most residential ceiling fans are sold with five blades. DOE understands that by redesigning the blade shape, it may be possible to reduce the number of blades without increasing the noise level. 6.2.1.3 Blade Design Optimizing fan blade design requires a delicate balance between many, sometimes conflicting, elements. For flat blades, the steeper the blade pitch, the more air that the blade will move with each sweep. Blade pitch, however, also increases the amount of energy required to move the fan. Therefore, it is important to balance maximizing the blade pitch with not overworking the motor. The shape, weight, aerodynamic drag and material of a ceiling fan blade can significantly affect the efficiency of a ceiling fan. Advanced fan blade technologies consist of modified structural configurations of the blade shape to minimize drag and maximize air displacement. Among the possible “styles” of modification that can result in better fan efficiency are: (1) twisted blades, where the blade pitch decreases from where the blade attaches to the motor casing to the blade tip; (2) upswept blade tips or attachable clips that can be added to a fan blade to increase airflow or reduce drag; and (3) airfoil blades that may appear traditionally shaped from below, but which have an aerodynamic shape similar to the wing of an airplane. Blade design can significantly affect efficiency, with reported examples demonstrating more than a
54


doubling of efficiency.22 For safety, edges of residential ceiling fans must be smooth and well rounded, which has the added benefit of reducing drag. The most common materials used for ceiling fan blades are wood and medium-density fibreboard (MDF). Plywood blades with a laminate coating are more resistant to warping than MDF and other cheaper woods. Blades made from MDF (often found on lower-end ceiling fans) are typically heavier than plywood, and the edges cannot be as rounded, which results in lessefficient blades. Blades made from metal (generally steel or aluminium) are less common in residential ceiling fans due to the increased risk of injury and noise. Aluminium blades are more malleable and can be more easily shaped that steel blades. Blades can also be made of injection molded resin, a material that is resistant to warping and weather conditions, and also can be molded into aerodynamically advantageous shapes. 6.2.1.4 Blade Span DOE has found that residential ceiling fans are currently available with a wide range of blade spans. The size of the ceiling fan will depend on the size of the room in which it is to be used, and guidelines for selection of the correct fan size are available.23 Ceiling fans cool the occupants directly beneath them, so larger fans will cool a larger occupied area. Since blade span is typically chosen based on room size, DOE does not intend to consider blade span among its design options for ceiling fans. Instead, as discussed in section 6.1.3.1, DOE plans to develop a continuous specification relating airflow efficiency to blade span. DOE has begun researching the relationship between blade span and energy efficiency and has found that, for all types of ceiling fans, efficiency tends to increase with blade span. To investigate this, DOE considered airflow and power (in watts) separately and has initially found that both of these parameters seem to increase with blade span, but that the rate of increase seems significantly higher for airflow than power. 6.2.1.5 Occupancy Sensors Occupancy sensors use technologies that detect the presence of people through movement and body heat. If used with an occupancy sensor, a ceiling fan could power down if it senses that a room is unoccupied. By limiting the hours of active mode operation to times when people are in the path of the fan, an occupancy sensor could reduce the overall energy consumption of a ceiling fan. Currently, very few ceiling fans, if any, are sold with occupancy sensors. To ensure that all power-saving technologies are properly accounted for, DOE is considering whether or not to include occupancy sensors as a technology option for ceiling fans. If occupancy sensors have a meaningful impact on overall fan energy consumption, then DOE could explore applying a credit to those fans that are equipped and sold with sensors. DOE requests information on the prevalence of occupancy sensors in the ceiling fan market and their effectiveness in terms of reducing energy consumption. .
22

For example: Parker, D., Hua, G. & Hibbs, B., High Efficiency Ceiling Fan, United States Patent, Number 6039541 (2000) (Available at: http://www.haikufan.com/our-fan/sustainability/). 23 See for example: http://www.energystar.gov/index.cfm?c=ceiling_fans.pr_ceiling_fans_basics and http://www.ceiling-fans.biz/products/Ceiling-Fans-Sizing/347.html. 55


6.2.1.6 Potential Technology Options for Ceiling Fans DOE will consider more-efficient blades and motors, and may consider ceiling fan controls, as energy efficiency technology options. These technologies are listed in Table 6-9. Table 6-9
1. 2. 3. 4.

Potential Technology Options for Ceiling Fans
More-Efficient Direct-Drive Single-Phase Induction Motors Geared Single-Phase Induction Motors Brushless DC Motors Three-Phase Induction Motors

More-Efficient Motors

More-Efficient Blades 5. Fans with Fewer Blades
6. Twisted Blades 7. Airfoil Blades 8. Blade Attachments 9. Alternative Blade Materials Ceiling Fan Controls 10. Occupancy Sensors

Item 39

DOE welcomes comments on the preliminary technology options identified in this section (i.e., high-efficiency motors and highefficiency fan blades for ceiling fans) and whether there are other technology options it should consider. In commenting on technology options, please discuss their impacts (if any) on safety, performance, and consumer utility. DOE requests input on whether it should include occupancy sensors as an energy efficiency option for ceiling fans and on how these could be taken into consideration in its rulemaking.

Item 40

6.2.2

Improving Efficiency of Ceiling Fan Light Kits

DOE will consider lamp type as the primary energy efficiency technology option for this rulemaking. At the highest level, lamps are distinguished by both their lighting technology (light source type) and socket type. Light source type has the most direct influence on the overall efficiency of the light kit. The efficacies of light sources commonly used in light kits range from below 15 lm/W, for incandescent sources, to over 60 lm/W for certain CFL and LED technologies. Table 6-10 shows the light source types and socket types currently included in ceiling fan light kits, based on a survey of light kits sold online and based on an in-store survey conducted for this rulemaking in four “big box” retail outlets in California and Massachusetts. In addition, DOE may consider new lamp technologies (e.g., Zhaga-standard LED lamps) that are just entering the market. In some cases, any light source type can be and are used with particular
56


socket technologies (e.g., medium screw base and candelabra base). In other cases, only certain light source types are allowed to be used for certain socket types. For example, the American National Standards Institute (ANSI) standard for GU-24 sockets specifically excludes their use for incandescent lamps.24 Table 6-10 Potential Technology Options for Lamp

Lamp Type Light Sources Standard Incandescent Halogen Incandescent CFL LED Socket Types 2GX13 E-11 Mini Candelabra E-12 Candelabra G10q G9 GU-10 GU-24 E-26 Medium 2GX13

Item 41

DOE welcomes input on the potential technology options for ceiling fan light kits and on other technology options that should be considered.

7

SCREENING ANALYSIS

The purpose of the screening analysis is to eliminate, or screen out, technology options that DOE will not analyze further in the engineering analysis or downstream analyses because they do not meet four key criteria. DOE will follow the process set forth below to screen out technology options. DOE will develop a list of technology options (through its own research and in consultation with interested parties) for consideration in the engineering analysis (section 8). This initial list of identified candidate technology options will encompass all those technologies that may be technologically feasible. Thereafter, DOE will review each technology option or

24

American National Standard for Electric Lampholders (ANSI_ANSLG C81.62-2009), page 50, tablenote (3). 57


best available technology in light of the following four criteria, as provided in sections 4(a)(4) and 5(b) of the Process Rule25: 1. Technological feasibility. DOE will screen out technologies that are not incorporated in commercially-available products or working prototypes. 2. Practicability to manufacture, install, and service. If DOE determines that mass production and reliable installation and servicing of the technology could not be achieved on the scale necessary to serve the relevant market by the time of the compliance date of the standard, it will not consider that technology further. 3. Adverse impacts on product or equipment utility or availability. If DOE determines that a technology will have a significant adverse impact on the utility of the relevant product for significant consumer subgroups, or will result in the unavailability of any covered product type with performance characteristics (including reliability), features, size, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not consider that technology further. 4. Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider that technology further. DOE will fully document its reasons for eliminating any technology options during the screening analysis and will publish this documentation for interested parties’ review and comment as part of the NOPR. Technology options that are not screened out by the above four criteria will be considered design options in the development of cost-efficiency curves in the engineering analysis. Item 42 DOE welcomes comments on any technologies listed in section 6.2 (or others not identified) that it should not consider based on any of the four screening criteria. If so, which screening criteria apply to the cited technology or technologies? DOE also welcomes comments on how the above four screening criteria might apply to any additional technology option(s) that an interested party recommends to DOE.

8

ENGINEERING ANALYSIS

After conducting the screening analysis described in section 7, DOE will perform an engineering analysis based on the remaining design options that are available to improve ceiling fan and ceiling fan light kit efficiency. The engineering analysis consists of estimating the energy consumption and cost of products at various levels of increased efficiency. Section 8.1
The Process Rule establishes procedures, interpretations, and policies to guide DOE in the consideration and promulgation of new or amended energy conservation standards under EPCA and is found at 10 CFR part 430, subpart C, appendix A. 58

25

provides an overview of the engineering analysis. Section 8.2 discusses baseline models. Section 8.3 discusses efficiency levels. Section 8.4 describes DOE’s planned approach to the costefficiency relationship and analysis. Section 8.5 addresses proprietary designs. Section 8.6 discusses cumulative regulatory burdens that might affect the engineering analysis. 8.1 Overview

The purpose of the engineering analysis is to determine the relationship between manufacturer selling price and efficiency for residential ceiling fans and ceiling fan light kits. In determining the cost-efficiency relationship, DOE estimates the increase in manufacturer selling price associated with design changes that increase efficiency relative to the baseline models (which, in most cases, are the most typical, lowest-efficiency products currently sold on the market). DOE will develop cost estimates for ceiling fans and ceiling fan light kits at a range of efficiency levels based on the technologies incorporated into products at those levels and the associated changes in material, labor, shipping, and overhead costs. This relationship between price and efficiency serves as the basis for cost/benefit calculations to individual consumers in the LCC analysis and to the Nation in the NIA. The engineering analysis will focus on identifying and evaluating commercially-available ceiling fans and ceiling fan light kits that incorporate design options that improve efficiency. The analysis will also identify the highest efficiency that is technologically feasible within each product class (i.e., the “max-tech” model). DOE may determine the max-tech model by investigating the existence of any prototypes with higher efficiency than commercially-available models. For ceiling fans, DOE has proposed developing a number of product classes (see section 6.1.3.1 on product classes). As a preliminary step in this analysis, DOE may determine an appropriate subset of product classes to analyze. DOE would extrapolate the results of this analysis to the remaining product classes. The number of product classes chosen to be representative will depend on whether appropriate relationships between engineering results can be developed between the various product classes. For each representative product class of ceiling fans, DOE may analyze a subset of representative units at selected fan sizes (determined by blade span). Once DOE has identified cost-efficiency relationships at those selected sizes, it is considering scaling the results to cover the full range of blade spans. This will lead towards development of a continuous specification relating efficiency to a ceiling fan’s blade span. Possible methods for developing the relationship between efficiency and blade span include performing selected performance testing of ceiling fans and conducting a statistical analysis of manufacturer catalogs and website information in addition to other publicly-available data sources. Once DOE establishes the representative product classes and representative fan sizes (together, “representative product groups”), it will select a baseline model as a reference point for each representative product group from which to measure changes resulting from the design options. DOE will then develop separate cost-efficiency relationships for each representative product group analyzed.

59


DOE proposes the following two-part method for determining the cost-efficiency relationship for ceiling fans: 1. Developing a detailed bill of materials (BOM) for baseline models in each representative product class and size bin through product teardowns. 2. Calculating the incremental cost of adding specific design options to a baseline model. For ceiling fan light kits, DOE plans to base its analysis primarily on the design option approach. To develop the relationships between efficiency and technology options for both ceiling fans and ceiling fan light kits, DOE intends to utilize publicly-available data, including data from government databases, manufacturer catalogs and websites, where the technology options used can be identified, as well as selected product testing for ceiling fans. DOE encourages interested parties to submit test data or other information that will improve DOE’s understanding of ceiling fan and ceiling fan light kit performance. Using this data, which will allow DOE to determine the incremental costs of changes in material, labor, shipping, and overhead from the baseline, DOE will develop cost estimates for design options (which it will also use in the manufacturer impact analysis, section 15). Item 43 DOE seeks stakeholder comment on these and other potential approaches to determining the cost-efficiency relationship for ceiling fans and ceiling fan light kits.

8.2

Baseline Models

For each product class and representative size bin in the case of ceiling fans, and for each product class in the case of ceiling fan light kits, DOE will identify a baseline model ceiling fan and ceiling fan light kit to serve as a reference point against which DOE can measure changes resulting from potential energy conservation standards. DOE will develop a separate efficiency curve for each baseline model directly analyzed. Should DOE develop a scaling method, as described in more detail in section 8.4 a separate curve for each baseline model and product class may not be necessary. Selection of the baseline model is a critical aspect of DOE’s analytical approach. The baseline model should represent the characteristics of a typical ceiling fan or ceiling fan light kit in a given representative product group. Normally, the baseline model is a model that just meets current energy conservation standards. However, because performance-based energy conservation standards for ceiling fans do not currently exist, DOE will select baseline models typical of the least-efficient residential ceiling fan models offered for sale in the market in a given product class and representative size bin. Selection of the baseline model for each representative size bin will involve consideration of ceiling fan features and performance characteristics, such as motor type, blade shape and span, and fan efficiency.
60


As previously indicated, when amending standards, the baseline efficiency for products classes is typically set at their existing standard. Given the proposal to use luminous efficacy as the efficiency metric for all ceiling fan light kits, the baseline for class 1 (medium screw base) and class 2 (pin-based fluorescent) light kits would, therefore, be determined by their current efficacy-based standards. For class 3 products (all other light kits), which are currently based on a fixed wattage limit, DOE will need to determine an equivalent efficacy standard. To determine the equivalent lm/W baseline, DOE is considering identifying baseline models for current class 3 products that just comply with the standard, and dividing their lumen output by the watts consumed. If DOE combines either two or all three existing product classes for ceiling fan light kits into a single product class, DOE would set the baseline at the highest of the existing standards for the product classes to be combined. This approach would guarantee that the energy use of any individual light kit sold could not drop below the existing standard set for the current product classes (ensuring no back-sliding on a product class-by-class basis). Item 44 DOE welcomes comments on its proposed approach and on the selection and appropriate features and performance characteristics of baseline models for each representative product group for ceiling fans.

8.3

Efficiency Levels

To establish the efficiency levels DOE intends to consider, DOE will identify the highest efficiency that is technologically feasible within each product class (i.e., the max-tech model) and analyze the design options and costs associated with improving ceiling fan and ceiling fan light kit efficiency from the baseline through the max-tech models. DOE intends to collect efficiency data from various sources including manufacturer catalogs and websites to establish the range of efficiencies currently available on the market. DOE will also use these data to categorize relationships between efficiency and technological options, where the technological options used can be identified. DOE notes that the maximum efficiency levels available in current ceiling fan and ceiling fan light kits may not necessarily correspond to the max-tech levels. It is possible that some of the design options that have met the screening criteria (i.e., passed the screening analysis) may be working prototypes that are not yet commercially available and, therefore, would not be found in today’s available maximum-efficiency products. DOE seeks stakeholder input to determine appropriate max-tech efficiency levels.

Item 45

DOE seeks input from stakeholders regarding the range of efficiency levels that should be examined as part of its analysis for ceiling fans and ceiling fan light kits. DOE seeks input from interested parties on a methodology that would be appropriate for determining the max-tech models for each ceiling fan and ceiling fan light kit analyzed.
61


Item 46

8.4

Cost-Efficiency Relationship and Analysis

The engineering analysis primarily involves estimating the energy consumption and cost of products at various levels of efficiency. Those estimates are then used to identify the costefficiency relationship for the products. DOE typically structures its estimation of the costefficiency relationship around one of three methodologies: (1) the design-option approach, which calculates the incremental cost of adding specific design options to the baseline model; (2) the efficiency-level approach, which calculates the incremental costs of achieving increases in energy efficiency, without regard to the particular design options used to achieve such increases; and (3) the reverse-engineering cost-assessment approach, which involves a “bottom-up” manufacturing cost assessment based on a detailed bill of materials being analyzed. Which methodology to use for the engineering analysis depends on the product, the technologies under study, and any historical data DOE can utilize. DOE plans to use separate approaches for ceiling fans and ceiling fan light kits, as explained below. For ceiling fans, DOE tentatively has decided to use the design option approach to identify incremental improvements in efficiency for each product and the reverse-engineering approach to develop a cost assessment for each baseline model. If a relationship between various product classes or representative size bins can be quantified, DOE may select a representative product class or size bin to analyze and develop a scaling method to derive results for the other product classes or representative size bins. If not, DOE could conduct a separate analysis for each product class and representative size bin. DOE anticipates, for example, that there may be a scaling between the incremental cost of hugger fans and that of indoor ceiling fans for a given efficiency improvement at a given size. If that is the case, DOE will consider using a scaling factor between those two product classes. Also, certain components of indoor and outdoor ceiling fans may be similar. For example, the motors in different baseline models may be the same, but the housing and the blade materials may be different. If that is the case, DOE will be able to use the same cost estimates for certain elements (i.e., the motors) across the two product classes while developing different costs for other elements, such as the housing and blade finish. Before performing the engineering analysis, DOE plans to test a number of ceiling fans according to the DOE test procedure being developed. The testing would enable DOE to gather measured data on ceiling fan efficiency to support the engineering analysis. DOE plans to disassemble and inventory the ceiling fan components for selected fan models and to identify manufacturing processes required to fabricate them. This approach will allow DOE to derive the material and labor costs and generate BOMs for baseline ceiling fans in each product class and representative size bin. The BOMs describe the products in detail, including manufacturing steps required to make and/or assemble each part. DOE will then develop a cost model to convert the BOMs for baseline models and the cost of the design options associated with different efficiency levels into manufacturer production costs (MPCs). By applying derived manufacturer markups to the MPCs, DOE will calculate the manufacturer selling prices and construct industry cost-efficiency curves. As a compliment to this work, DOE may also evaluate retail prices to estimate manufacturer selling prices, as well as review data collected from manufacturers about prices, efficiencies, and other features of various models of

62


ceiling fans, and interview manufacturers about the techniques and associated costs used to improve efficiency. In order to determine the cost-efficiency relationship for ceiling fan light kits, DOE plans to determine the energy efficiency by lamp efficacy alone, and only the costs of the lamps and their associated sockets (not the light kits themselves) will be included in the cost analysis. DOE believes this approach is appropriate because changing the lamp type will incur no additional costs in the light kits, assuming that all of the socket types are already represented. Given that the analysis plans to consider all socket types in use in light kits, the latter is guaranteed. Given that ceiling fan light kit manufacturers generally purchase rather than manufacture the lamps and associated sockets used in their light kits, DOE will use bulk retail purchase prices of these products in its analysis, corrected for manufacturer discounts. DOE is considering obtaining its efficacy data from DOE’s Compliance Certification Database26 if available and adequate and from DOE’s LED Lighting Facts database of verified products27 for LED lamps, supplemented by other government sources, manufacturer catalogues, and manufacturer interviews, as necessary. Efficiency levels will be based on population data for lamps having the same lumen output ranges and source types as those currently used in light kits. DOE recognizes that ceiling fans and ceiling fan light kits can have both a functional use and decorative features. Costs associated with a product's basic functionality may be independent of costs associated with style or aesthetics. In the cost-efficiency analysis, DOE will attempt to isolate costs associated with functionality. Wherever possible, products that are stylistically similar will be used to determine cost variations related to functional components. The proposed baseline model for ceiling fan light kits, for example, would have standard decorative features, as determined by the features of products that have the largest sales volumes. Manufacturer interviews are also expected to help isolate costs associated with functionality from those associated with aesthetics. Item 47 DOE seeks comments on its proposed methods for determining costs associated with incremental efficiency improvements in both ceiling fans and ceiling fan light kits. DOE welcomes comments on how ceiling fan efficiency varies with airflow capacity, motor type, motor rated horsepower, blade span, number and design of blades, or any other ceiling fan parameter. DOE also seeks comments on how ceiling fan light kit efficiency varies with bulb type, number of bulbs, or any other ceiling fan light kit parameter. DOE welcomes comments on the proposed method for isolating costs associated with decorative features from costs associated with functional features in ceiling fans and ceiling fan light kits

Item 48

Item 49

26 27

See: http://www.regulations.doe.gov/certification-data/. See: http://www.lightingfacts.com/products. 63

8.5

Proprietary Designs

In its engineering and economic analyses, DOE will consider all design options that are commercially available or present in a working prototype, including proprietary designs that meet the screening criteria discussed in section 7. DOE will consider a proprietary design in the subsequent analyses, however, only if it does not represent a unique path to a given efficiency level. If the proprietary design is the only approach available to achieve a given efficiency level, then DOE will eliminate that efficiency level from further analysis. DOE will reject a standard level that can only be met with a single proprietary technology because it could result in an anticompetitive market, a principle consistently applied in past DOE rulemakings as economically unjustifiable. However, if a given energy efficiency level can be achieved by a number of design approaches, including a proprietary design, DOE will continue to examine the given efficiency level, despite the proprietary nature of that one design. DOE is sensitive to manufacturer concerns about proprietary designs and will take steps to maintain the confidentiality of any proprietary data provided by manufacturers. This information will provide input to the competitive impacts assessment and other economic analyses. Item 50 DOE seeks information on proprietary designs of which it should be aware for both the ceiling fans and ceiling fan light kits under consideration in this rulemaking. If such proprietary designs exist, DOE would like to acquire the cost data necessary for evaluating those designs.

8.6

Other Regulatory Changes Affecting the Engineering Analysis

In conducting an engineering analysis, DOE considers the effects of the full complement of regulatory burdens (including those outside DOE’s statutory standards rulemaking process) that can affect manufacturers of covered products. Some regulatory requirements potentially could affect the energy efficiency or energy consumption of the ceiling fans and ceiling fan light kits covered under this rulemaking. DOE will attempt to identify all regulatory requirements that could affect the engineering analysis. Evaluating such requirements is closely related to the cumulative regulatory burden assessment that DOE will conduct as part of the manufacturer impact analysis. Based on consideration of the comments received on the engineering analysis, DOE will make any necessary changes to its analysis. Those changes will be reflected in the NOPR. Item 51 DOE welcomes comments on regulatory burdens and changes that should be considered in the engineering analysis of ceiling fans and ceiling fan light kits. DOE welcomes comments on other engineering issues that could affect the engineering analysis.

Item 52

64


9

MARKUPS ANALYSIS

Because DOE uses retail (consumer) price data in its LCC, PBP, and national impact analyses, DOE typically uses manufacturer-to-consumer markups to convert estimates of the manufacturer selling price derived from the engineering analysis (section 8) to consumer prices. The manufacturer-to-consumer markups are in addition to the markups on production costs that DOE uses in estimating manufacturer selling price in the engineering analysis. To validate those markups, DOE will collect data on current market prices. 9.1 Description of Market Participants and Distribution Channels

In generating end-user price inputs for the LCC analysis and NIA, DOE must identify distribution channels (i.e., how the products are distributed from the manufacturer to the consumer), and estimate relative sales volumes through each channel. DOE is considering two main distribution channels for ceiling fans and ceiling fan light kits: (1) home improvement retailer and (2) electrical wholesaler (distributor). Figure 9-1 shows how DOE plans to characterize the home improvement retailer distribution channel for ceiling fans and ceiling fan light kits: Distribution Channel 1:

Figure 9-1

Home Improvement Retailer Distribution Channel for Ceiling Fans and Ceiling Fan Light Kits

Figure 9-2 shows how DOE plans to characterize the electrical wholesaler (distributor) distribution channel for ceiling fans and ceiling fan light kits:

Distribution Channel 2:

Figure 9-2

Electrical Wholesaler (Distributor) Distribution Channel for Ceiling Fans and Ceiling Fan Light Kits

9.2

Markup Estimation Using Financial Statements and Regression Analysis

To estimate distribution channel markups, DOE will rely on economic data from public sources and industry input to determine the extent to which products are marked up from the
65


manufacturer to the consumer. Publicly-owned companies are required to disclose financial information on a regular basis by filing various forms with the U.S. Securities and Exchange Commission (SEC). Filed annually, SEC Form 10-K provides a comprehensive overview of the company’s business and financial conditions. To estimate retailer and wholesaler markups, DOE will analyze both economic Census data from the U.S. Census Bureau28 and financial data from available 10-K reports for publicly-owned home improvement retailers and electrical wholesalers.29 In addition to developing manufacturer and retailer markups, DOE will also develop and include sales taxes to calculate appliance retail prices. DOE will use an Internet source, the Sales Tax Clearinghouse, to calculate applicable sales taxes.30 DOE will also use collected retail price data to validate the overall manufacturer-to­ consumer markup. DOE has purchased ceiling fan consumer survey data for 2007–2011 from NPD Group, Inc. (NPD), which provides an estimate of sales-weighted retail price data. In addition to purchasing consumer survey data, DOE has conducted in-store site visits, and may also consult retailers’ Internet sites. This analysis will generate end-user prices for each potential efficiency level, assuming that each level represents a new minimum efficiency standard. DOE will make this assumption to capture the effect on retail prices that may be produced by manufacturers’ higher production volumes of more-efficient products as required by the standard. Because DOE expects to develop a range of price estimates, it may describe new retail prices within a range of uncertainty. If the results of DOE’s analysis show a large range of retail prices for each product, DOE will develop probability distributions of retail price to use as inputs to the LCC and PBP analysis in order to determine the impact of uncertainty on the economic feasibility of amended energy conservation standards. Item 53 DOE welcomes suggestions and comments concerning its proposed approach for estimating end-user prices for ceiling fans and ceiling fan light kits. DOE welcomes suggestions and comments concerning its assumed distribution channels for ceiling fans and ceiling fan light kits, and data and/or estimates regarding relative sales volumes through each channel. DOE welcomes comments on typical manufacturer, retailer, wholesaler, and contractor markups associated with ceiling fans and ceiling fan light kits.

Item 54

Item 55

28 29

Economic census data from the U.S. Census Bureau are available at: http://www.census.gov/econ/census/#.
10-K reports are filed with the U.S. Securities and Exchange Commission and are available at
www.sec.gov/index.htm.
30 See http://www.thestc.com/.
66

10 ENERGY USE ANALYSIS
The purpose of the energy use analysis is to estimate the annual energy usage of the baseline and higher-efficiency ceiling fans and ceiling fan light kits considered in this rulemaking, as described in the engineering analysis for representative U.S. homes, and to assess the energy-savings potential of increased product efficiencies. This analysis, which is meant to represent typical energy usage in the field, is an input to both the LCC and PBP analysis and the NIA. The energy use analysis enables DOE to determine the LCC and the PBP of more-efficient products in relation to the baseline product and to establish the savings in consumer operating costs at various product efficiency levels. For ceiling fans and ceiling fan light kits, energy use is derived by multiplying the product input power rating by the annual operating hours. Input power ratings for representative baseline and higher-efficiency products are developed in the engineering analysis (section 8). For most ceiling fans, this energy use will just correspond to the energy use in active mode. For those ceiling fans and ceiling fan light kits which consume power in standby mode, the energy use in standby mode will be derived by multiplying the power consumed in standby mode by the annual operating hours in standby mode. The energy use in standby mode will then be added to the energy use in active mode. To estimate annual energy use for ceiling fans, DOE plans to research available ceiling fan and heating, ventilation, and air-conditioning (HVAC) usage studies, as well as regional residential utility monitoring studies. Because energy use by ceiling fans varies greatly based on consumer usage patterns, DOE will conduct further research to establish a range of energy use for ceiling fans. The Energy Information Administration (EIA)’s Residential Energy Consumption Survey31 is one source for defining the range of energy use for ceiling fans. DOE will also consider ceiling fan sales data collected as part of its market and technology assessment (section 6), which will help characterize the prevalence of ceiling fan use by geographic region. Since usage varies significantly between regions, and DOE considers that usage and ownership levels are likely correlated (i.e., regions with more ceiling fans are likely to use ceiling fans more), national averages may give a distorted picture of regional impacts and make a distribution analysis impossible. DOE plans to estimate a regional distribution of operating hours that accounts for geographic location, climate and season, market penetration, and ceiling fan usage patterns. To estimate annual energy use for ceiling fan light kits, DOE plans to consider data from a number of sources including DOE’s Residential Lighting End-Use Consumption Study (RLEUCS), anticipated 2013,32 2010 U.S. Lighting Market Characterization (LMC)33 and the EIA’s 2009 RECS to estimate a distribution of operating hours. RLEUCS leverages several
U.S. Energy Information Administration, Residential Energy Consumption Survey, 2009 RECS Survey Data.
(2009) (Last accessed August 14, 2012) (Available at: www.eia.gov/consumption/residential/data/2009/).
32 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Residential Lighting End-Use
Consumption Study: Estimation Framework and Baseline Estimates (2013) (Available at:
http://www1.eere.energy.gov/buildings/ssl/m/tech_reports.html). 33 U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy, Final Report: 2010 U.S. Lighting Market Characterization (2012) (Available at: http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf). 67

31

recent national and regional datasets, linking lamp usage from end-use metering studies with household characteristics and lighting inventory profiles to estimate residential lighting energy usage. The LMC, which is based on thousands of building audits and surveys, indicates the occurrence of certain room types within a given building type and the operating hour characteristics in these rooms. LMC data can be associated with RECS data, which provide information on the distribution of U.S. buildings by building type and Census Division. For the NOPR stage of this rulemaking, DOE may conduct a sensitivity analysis to determine how high and low estimates of energy use might affect the economic feasibility of any potential energy conservation standards. Item 56 DOE welcomes comments on its proposed methodology to determine annual operating hours and energy use for covered ceiling fans and ceiling fan light kits, and how operating hours may vary (e.g., by product type and application, geographical location, season).

11 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES This section describes the life-cycle cost and payback period analysis that DOE will perform for ceiling fans and ceiling fan light kits, including how DOE develops the inputs to the calculations. The LCC analysis establishes the total cost of an appliance over its lifetime (including purchase price, installation cost, and operating costs). The PBP analysis calculates the amount of time required for energy cost savings to pay back any increased cost of a higherefficiency product. 11.1 Overview The effects of energy conservation standards on consumers of a product include a change in operating cost (usually decreased) and a change in purchase price (usually increased). DOE analyzes the net effect of amended standards on consumers by evaluating changes in the LCC of owning and operating the product, as well as the PBP of higher-efficiency products. The LCC of a product is the cost a product incurs over its lifetime, taking into account both purchase price and operating expenses. The PBP represents the time it takes to recover the additional installed cost of the more-efficient device through annual operating cost savings. DOE analyzes the net effect on consumers by calculating the LCC and PBP using the engineering performance data (section 8), the energy-use and end-use load characterization data (section 10), and the markups (section 9). Inputs to the LCC calculation include the total installed cost to the consumer (purchase price plus any installation cost), operating costs (energy expenses, and, if applicable, repair costs and maintenance costs), the lifetime of the product or other defined period of analysis, and a discount rate. Additional inputs to the payback period calculation include the installed cost to the consumer and first-year operating costs. DOE considers both LCC and PBP to determine the impacts of potential energy conservation standards on consumers of the covered products. However, because calculation of
68


LCC uses a discount rate (that depends on consumers’ cost of financing) and takes into account changing energy prices over time, it is considered by DOE to be a better indicator of the economic impacts of standards on consumers. DOE plans to perform the LCC and PBP analyses using a spreadsheet model combined with a commercially-available software add-on program used to conduct stochastic analysis using Monte Carlo simulation and probability distributions to account for uncertainty and variability among the input variables. Each Monte Carlo simulation will consist of 10,000 LCC and PBP calculations. The model will perform each calculation using input values that are either sampled from probability distributions and household samples or characterized with single point values. The analytical results are a distribution of 10,000 data points showing the range of LCC savings and PBPs for a given efficiency level relative to the base-case efficiency forecast. For any sensitivity analyses it conducts, DOE will account for correlations that may exist between inputs. Since ceiling fan usage varies significantly between regions, and DOE considers that usage and ownership levels are likely correlated (i.e., regions with more ceiling fans are likely to use ceiling fans more), national averages may give a distorted picture of regional impacts and make a distribution analysis impossible. DOE, therefore, proposes to undertake its LCC and PBP analysis on a regional basis. DOE will also determine as part of the LCC and PBP analyses whether there may be a rebound (or “take back”) effect associated with more-efficient ceiling fans and/or ceiling fan light kits. The “take-back” in energy consumption associated with the rebound effect typically involves greater use that can result from increases in energy efficiency and the associated reduction in operating costs. The rebound effect assumes that consumers will increase their overall annual usage of a more-efficient product, thereby decreasing their overall annual savings. The following sections discuss the methodologies DOE plans to use to develop several of the inputs to the LCC and PBP analysis, including: (1) energy prices; (2) discount rates; (3) maintenance, repair, and installation costs; and (4) product lifetime. The other inputs to the LCC and PBP analysis—namely, manufacturer costs, annual energy consumption, and markups for the determination of consumer retail prices—have been discussed previously. DOE is also required to perform a PBP analysis to determine whether the rebuttable presumption of economic justification applies (where the higher installed cost of more-efficient equipment is less than three times the value of the lowered operating costs in the first year of the energy conservation standard). (42 U.S.C. 6295(o)(2)(B)(iii)) To determine the rebuttable presumption PBP, DOE will determine the value of the first year’s energy savings by calculating the quantity of those savings in accordance with DOE’s test procedure. Although DOE will examine the rebuttable-presumption criteria, DOE determines whether potential standards are economically justified through an analysis of the economic impacts of increased efficiency pursuant to section 325(o)(2)(B)(i) of EPCA. (42 U.S.C. 6295(o)(2)(B)(i)) The results of this analysis serve as the basis for DOE to definitively evaluate the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification).
69


In preparing the NOPR, DOE carefully reviews all the comments it receives on the preliminary analysis LCC analysis, makes any necessary revisions to the analysis, and if necessary, evaluates additional parameters not included in the preliminary analysis. Item 57 DOE welcomes comments from interested parties as to whether a more-efficient ceiling fan or ceiling fan light kit would be expected to be used more and whether such a rebound effect should be considered separately for this product.

11.2 Energy Prices DOE plans to derive average monthly electricity prices for the 27 geographic areas used in RECS 2009 by using the latest data from EIA and monthly energy price factors. DOE will develop the 27 regional energy prices based on the household population in each region. DOE will assign an appropriate price to each household in the RECS sample, depending on its location.
To calculate electricity prices for residential consumers in each of the above geographic areas, DOE will use information provided by electric utilities as summarized in the most recent EIA Form 861 data.34 These data, which cover the residential, commercial, and industrial sectors for every utility serving final customers, are published annually and include annual electricity sales in kWh, revenues from electricity sales, and number of customers. DOE’s calculation of an average residential electricity price proceeds in two steps: (1) for each utility, estimate an average residential price by dividing residential revenues by residential sales; and (2) calculate a regional average price, weighting each utility that has customers in a region by the number of residential customers served in that region.

In its LCC analysis, DOE will use projections of national average electricity prices to residential consumers to estimate future energy prices. DOE will use the most recent available edition of EIA’s Annual Energy Outlook (AEO) as the source of projections for future energy prices. Item 58 DOE seeks stakeholder input on the planned approach for estimating current and forecasted energy prices.

EIA’s 2008 Form 861 data and EIA’s Form 826 (Available at: http://www.eia.doe.gov/cneaf/electricity/epm/table5_3.html). 70

34

11.3 Discount Rates The calculation of LCC requires use of an appropriate discount rate to determine the present value of a product’s lifetime operating expenses. The discount rate used in the LCC analysis represents the rate from an individual consumer’s perspective.35 For consumers of ceiling fans and ceiling fan light kits, DOE plans derive the discount rates from estimates of the “finance cost” to purchase residential products. The finance cost can be interpreted as: (1) the financial cost of any debt incurred to purchase products (principally interest charges on debt), or (2) the opportunity cost of any equity used to purchase products (principally interest earnings on household equity). Much of the data DOE uses to determine the cost of debt and equity comes from the Federal Reserve Board’s triennial Survey of Consumer Finances.36 Item 59 DOE welcomes input on the planned approaches for estimating discount rates for consumers of ceiling fans and ceiling fan light kits.

11.4 Installation, Maintenance, and Repair Costs DOE does not currently plan to consider installation costs for ceiling fans and ceiling fan light kits because DOE does not believe that the installation cost will be affected by changes in product efficiency. DOE will evaluate how any maintenance and repair costs may change with increased efficiency for ceiling fans and ceiling fan light kits. Often, small incremental changes in product efficiency incur little or no change in maintenance and repair costs over baseline products. For products with significant energy-efficiency improvements over the baseline, there may be increased maintenance and repair costs, because such products are more likely to incorporate technologies that are not widely available or used. DOE will estimate maintenance and repair costs at each considered efficiency level using a variety of sources, including RS Means,37 manufacturer literature, and information from expert consultants. DOE will account for regional differences in labor costs by using RS Means data. Item 60 DOE welcomes comments on appropriate maintenance and repair costs for ceiling fans and ceiling fan light kits.

The consumer discount rate differs from the discount rates used in the national impact analysis, which are
intended to represent the rate of return on capital in the U.S. economy, as well as the societal rate of return on
private consumption. Refer to section 13.3for additional information.
36 Available at http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html.
37 RS Means Company, Inc., RS Means Residential Cost Data (31st Annual Edition ed. 2012) (Available at:
http://rsmeans.reedconstructiondata.com/).
71

35

11.5 Product Lifetime Product lifetime is the age at which a product is retired from service. DOE plans to use information from various literature sources and industry experts and input from manufacturers and other interested parties to determine a range for the lifetime of ceiling fans. DOE has begun to investigate life expectancy of ceiling fans. Data from Appliance Magazine suggests significant variation in the life expectancy of ceiling fans ranging between 7 and 18 years (Appliance Magazine, 2001).38 Estimates represent expert judgment from Appliance Magazine staff. DOE anticipates that there will be significant differences in lifetimes of ceiling fans depending on usage. Since usage varies significantly between regions, this will be an important factor for DOE to consider. DOE has not found significant data on life expectancy of ceiling fans and is unaware of any data on the relationship between usage and life expectancy of ceiling fans. Therefore, DOE seeks comments, input, and data on ceiling fan life expectancy and, in particular, on the relationship between ceiling fan usage and ceiling fan life expectancy. Assuming that DOE adopts ceiling fan light kit standards based on lamp efficacy and a packaging requirement (see section 4.1.2.2), the relevant lifetime depends on the nature of the light kit and the packaged lamps. For the purpose of calculating energy savings, the relevant lifetime is the lifetime of the packaged lamp (or light engine for light kits with integrated lighting) unless it exceeds the ceiling fan lifetime, in which case the relevant lifetime is the ceiling fan lifetime. The ceiling fan lifetime rather than the ceiling fan light kit lifetime is used because the fan, having moving parts, is likely to have a shorter life, and the available data suggest that when the fans ceases to function, its light kit is also retired. (Light kits are generally purchased packaged with or built into fans, in the major big-box markets, and they are generally purchased at the same time as fans in showrooms.) Item 61 DOE welcomes comments on appropriate lifetimes for both ceiling fans and ceiling fan light kits covered in this rulemaking. DOE is particularly interested in regional lifetime data and data on the relationship between ceiling fan usage and ceiling fan life expectancy.

11.6 Energy Efficiency in the Base Case To estimate the share of consumers that would be affected by a standard at a particular efficiency level, DOE’s LCC and PBP analysis will consider the projected distribution (i.e., market shares) of product efficiencies that consumers will purchase in the first compliance year under the base case (i.e., the case without amended energy conservation standards). Projected market shares will use available data on recent market trends in ceiling fan and ceiling fan light kit efficiency and will take into account the potential impacts of the ENERGY STAR program and other programs or policies that may affect the demand for more-efficient ceiling fans and
38

Appliance Magazine, The 22nd Portrait of the US Appliance Industry (2001). 72


ceiling fan light kits (such as consumer rebate programs or State tax credits to consumers that encourage the purchase of more-efficient products). DOE will consider how the trends in ceiling fan and ceiling fan light kit efficiency are likely to influence the distribution of more-efficient products. Item 62 DOE seeks comments on the appropriate distribution of energy efficiencies for both ceiling fans and ceiling fan light kits in the absence of amended energy conservation standards.

12 SHIPMENTS ANALYSIS DOE typically develops shipment forecasts of products to calculate the national impacts of potential energy conservation standards on energy consumption, net present value (NPV), and future manufacturer cash flows. DOE is considering developing shipments forecasts (from the assumed compliance date of a new standard to 30 years after compliance is required) based on an analysis of key market drivers for ceiling fans and ceiling fan light kits. In order to develop forecasts using this methodology, DOE must rely on the lifetime function of the product. DOE has begun to investigate life expectancy of ceiling fans and anticipates that there will be significant differences in lifetimes of ceiling fans dependent on usage. Since usage varies significantly between regions, the lifetime factor in itself (when combined with shipments data) may not result in a reliable projection of future stock. As discussed in section 11.5, DOE assumes that light kits are retired at the end of the fan’s lifetime. However, unlike in section 11.5, for the shipments calculations for light kits, the relevant lifetime is not the lamp lifetime but the fan lifetime, at which point the light kit is retired. In order to avoid over-reliance on lifetime data, DOE is considering an alternative approach in which it projects future stock levels for ceiling fans directly using current values and forecasts of national and regional ownership levels, regionally differentiated usage patterns, and regional population projections. DOE is considering using available stock and shipments data (such as from EIA’s RECS and the shipments sources discussed in section 6.1.2.3) to estimate lifetimes. In this situation where lifetimes are highly uncertain, DOE considers this method likely to provide more robust results. Item 63 DOE welcomes comments on the approach described to forecast shipments of ceiling fans and ceiling fan light kits.

12.1 Base-Case Forecast To evaluate the impacts of potential energy conservation standards, DOE will develop a base-case shipments or stock forecast against which to compare forecasts for higher efficiency levels. (The latter are also referred to as standards-case forecasts.) DOE designs the base-case forecast to depict what it anticipates would happen to energy consumption and costs over time if DOE does not adopt new energy conservation standards for the products covered under this
73


rulemaking. When it develops base-case shipments forecasts, DOE plans to calibrate its shipments or stock model against historical shipments or stock levels. With regard to historical product saturation rates, EIA’s RECS and the shipments sources discussed in section 6.1.2.3 provide relevant data. DOE plans to use these sources to establish product saturation rates. To determine replacement shipments, DOE will use the same product lifetimes and retirement functions that it generates for the LCC and PBP analysis. In addition, DOE will consider other market segments as appropriate, such as households that may purchase additional units. Item 64 DOE seeks input on historical shipments and stock data for ceiling fans and ceiling fan light kits, including the distribution of shipments by efficiency.

12.2 Impacts of Standards on Ceiling Fan and Ceiling Fan Light Kit Shipments DOE intends to evaluate whether standards that require more-efficient ceiling fans and/or ceiling fan light kits would have an impact on the number of fans and/or light kits shipped. DOE will consider application of elasticity parameters that relate changes in shipment quantities to changes in the installed cost of products with ceiling fans. Item 65 DOE welcomes comments on whether energy conservation standards might affect shipments of ceiling fans and ceiling fan light kits, as well as the anticipated extent of such impacts, if any.

13 NATIONAL IMPACT ANALYSIS In the national impact analysis, DOE estimates national energy savings from new or amended energy conservation standards and the net present value of total consumer benefits. The NIA considers: (1) NES attributable to each potential standard; (2) monetary value of the NES to purchasers of the considered equipment; (3) increased total installed cost of the equipment because of standards; and (4) NPV of the difference between the operating cost savings and increased total installed cost. DOE performs all NIA calculations using a computer spreadsheet model.39 The spreadsheets combine the calculations for determining the NES and NPV for each considered product class with input from the shipments model. 13.1 Projected Efficiency Trends A key component of DOE’s NIA analysis, namely DOE’s estimate of NES and NPV, is the product energy efficiencies forecasted over time for the base case (without new standards) and each standards case. Forecasted efficiencies represent the shipment-weighted energy efficiency
39

Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at: http://www.eere.energy.gov/buildings/appliance_standards/. 74


of the covered ceiling fans and ceiling fan light kits during the forecast period (i.e., from the assumed compliance date of a new or amended standard to 30 years after compliance is required). Section 12 describes how DOE plans to develop a base-case energy efficiency distribution (which yields a shipment or stock-weighted average efficiency) for each of the ceiling fan and ceiling fan light kit product classes for the first year of the forecast period. To forecast base-case efficiencies over the entire 30-year forecast period, DOE intends to extrapolate from the historical trends to the extent that is possible and reasonable. The market-share efficiency data will enable DOE to estimate the effect that new or amended standards may have in the year manufacturers must begin to comply with them. DOE has used “roll-up” and/or “shift” scenarios in its standards rulemakings. Under the “roll-up” scenario, DOE assumes: (1) product efficiencies in the base case that do not meet the standard level under consideration would “roll-up” to meet the new standard level; and (2) product efficiencies above the standard level under consideration would not be affected. Under the “shift” scenario, DOE retains the pattern of the base-case efficiency distribution but re-orients the distribution at and above the new minimum energy conservation standard. DOE will evaluate whether one of these approaches is more reasonable for ceiling fans and ceiling fan light kits. After DOE establishes average efficiency for the assumed compliance date of a standard, it estimates future efficiency by using an appropriate rate of forecasted efficiency growth as for the base-case efficiency trend. Item 66 DOE seeks comments on the appropriate assumptions to use regarding long-run changes in ceiling fan and ceiling fan light kit energy efficiency independent of amended energy conservation standards. DOE seeks comments on the use of the “roll-up” and “shift” efficiency scenarios to characterize the impact that potential standards would have on the product efficiency distributions.

Item 67

13.2 National Energy Savings DOE will calculate annual national energy savings for each standards case analyzed. The energy savings are measured over the entire lifetime of products purchased in the 30-year shipments projection period.40 To estimate the primary energy savings resulting from electricity savings at building sites, DOE will develop annual conversion factors based on the version of the National Energy Modeling System (NEMS) that corresponds to the latest version of AEO. For electricity, the
In the past, DOE presented energy savings results for only the 30-year period that begins in the year of compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of national energy savings to be consistent with the approach used for its national economic analysis. 75

40

conversion factors change over time in response to projected changes in generation sources (i.e., the types of power plant projected to provide electricity). DOE intends to determine whether there may be a rebound effect associated with moreefficient ceiling fans and/or ceiling fan light kits. If data indicate that there may be a rebound affect and allow for the quantification of this effect for ceiling fans and/or ceiling fan light kits, DOE will account for the rebound effect in its calculation of NES. DOE has historically presented NES in terms of primary energy savings. On August 18, 2011, DOE published a Federal Register notice announcing its intention to use full-fuel-cycle (FFC) measures of energy use and greenhouse gas and other emissions in the national impact analyses and emissions analyses included in future energy conservation standards rulemakings. 76 FR 51281. While DOE stated in that notice that it intended to use the Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model to conduct the analysis, it also said it would review alternative methods, including the use of NEMS. After evaluating both models and the approaches discussed in the August 18, 2011 notice, DOE has determined NEMS is a more appropriate tool for this purpose. 77 FR 49701 (Aug. 17, 2012). Therefore, DOE intends to use the NEMS model to conduct FFC analyses. The method used to derive the FFC multipliers will be described in the preliminary TSD. 13.3 Net Present Value of Consumer Savings The inputs for determining NPV of the total costs and benefits experienced by consumers of the considered appliances are: (1) total annual installed cost; (2) total annual savings in operating costs; (3) a discount factor; (4) present value of costs; and (5) present value of savings. DOE calculates net savings each year as the difference between the base case and each standards case in terms of the total savings in operating costs and total increases in installed costs. DOE calculates savings over the life of each product. DOE calculates NPV as the difference between the present value of operating cost savings and the present value of total installed costs. DOE calculates increases in total installed costs as the difference in total installed cost between the base case and a standards case. DOE expresses savings in operating costs as decreases associated with the lower energy consumption of products bought in the standards case compared to the base case. Total savings in operating costs are the product of savings per unit and the number of units of each vintage that survive in a given year. DOE also incorporates the impact of “price learning” into its analysis, to capture the reduction in product prices with cumulative production. Based on U.S. Office of Management and Budget (OMB) guidelines for Federal agencies, DOE will conduct two NPV calculations, one using a real discount rate of 3 percent and another using a real discount rate of 7 percent (OMB, Circular A-4: Regulatory Analysis (2003)). The discount rates for the determination of NPV are in contrast to the discount rates used in the LCC analysis, which are designed to reflect a consumer’s perspective. The 7-percent real value is an estimate of the average before-tax rate of return to private capital in the U.S. economy. The 3-percent real value represents the “societal rate of time preference,” which is the rate at which society discounts future consumption flows to their present value.

76


14 CONSUMER SUBGROUP ANALYSIS
At the NOPR stage of this rulemaking, DOE will conduct a consumer subgroup analysis. In this analysis, DOE assesses consumer impacts of any new or amended standards by dividing consumers into subgroups and accounting for variations in key inputs to the LCC analysis. A consumer subgroup comprises a subset of the population likely, for one reason or another, to be affected disproportionately by new or amended energy conservation standards (e.g., low-income consumers, seniors). The purpose of a subgroup analysis is to determine the extent of any such disproportional impact. DOE will work with industry and other interested parties early in the rulemaking process to identify any consumer subgroups for consideration. In comparing potential effects on different consumer subgroups, DOE will evaluate variations in energy prices, energy use profiles, and purchase prices that might affect the LCC of a new or amended energy conservation standard for identified consumer subgroups. Item 68 DOE welcomes input from interested parties regarding which, if any, consumer subgroups should be considered when developing potential energy conservation standards for ceiling fans and ceiling fan light kits.

15 MANUFACTURER IMPACT ANALYSIS DOE conducts its manufacturer impact analysis (MIA) consistent with the Report to Congress, “Energy Conservation Standards Activities” (Jan. 31, 2006) (required report under Section 141 of the Energy Policy Act of 2005) (Standards Activities), available at http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.p df. Prior to 2006, DOE did not report any MIA results during the preliminary analysis phase; however, under the format established by the “Energy Conservation Standards Activities,” DOE now collects, evaluates, and reports preliminary information and data in the preliminary analysis. (See Standards Activities, p. 48) Such preliminary information includes the anticipated conversion costs by efficiency level and the corresponding anticipated impacts on direct employment. DOE solicits further information during the preliminary analysis phase through the manufacturer interviews conducted as part of that phase’s engineering analysis. A draft set of questions to be used for those interviews is contained in Appendix B. DOE intends the MIA to help assess the potential impacts of amended energy conservation standards on manufacturers of ceiling fans and ceiling fan light kits. In addition to financial impacts, a wide range of quantitative and qualitative effects may occur following adoption of an amended standard that may require changes to the manufacturing practices for these products. DOE identifies these potential effects through interviews with manufacturers, as well as other stakeholders and experts. For the NOPR, DOE supplements the results of the preliminary MIA with more-detailed analyses, as described in sections 15.1 through 15.5. Specifically, DOE carries out an industry­
77


wide cash flow analysis using the Government Regulatory Impact Model (GRIM), identifies and analyzes subgroups of manufacturers whose businesses vary significantly from the industry as a whole, performs a competitive impacts assessment, and reviews the cumulative regulatory burden for the industry. 15.1 Sources of Information for the Manufacturer Impact Analysis Many of the analyses described earlier provide important information that DOE uses as inputs for the MIA. Such information includes financial parameters developed in the market assessment (section 6), manufacturing costs and prices from the engineering analysis (section 8), retail price forecasts (section 9), and shipments forecasts (section 12). DOE supplements this information with information gathered during manufacturer interviews, as discussed below. During the preliminary analysis phase, DOE conducts detailed interviews with manufacturers to gain insight into the range of possible impacts from potential amended energy conservation standards. These interviews will coincide with preliminary technical interviews for the engineering analysis. During the NOPR phase, DOE will conduct more detailed MIA interviews with manufacturers. The interview process plays a key role in the MIA by providing an opportunity for directly affected parties to express their views on important issues. During the interviews, DOE solicits information on the possible impacts of potential amended standards on manufacturing costs, product prices, sales, direct employment, capital assets, and industry competitiveness. Both qualitative and quantitative information are valuable in terms of this analysis. DOE schedules interviews well in advance to provide every opportunity for key individuals to be available to participate. In addition, DOE provides manufacturers with the questionnaire before the interviews to facilitate the gathering of the appropriate information. Although a written response to its questionnaire is acceptable, DOE prefers an interactive interview process, because it helps clarify manufacturer responses and provides the opportunity to identify additional issues. DOE asks interview participants to identify all confidential information provided in writing or orally, and DOE determines whether the information submitted is entitled to confidential treatment. DOE will protect confidential information from disclosure, consistent with applicable law. It considers information gathered, as appropriate, in the energy conservation standards decision-making process. However, DOE does not make confidential information available in the public record. DOE also asks participants to identify all information that they wish to have included in the public record but that they do not want to have associated with their interview (thereby identifying that particular manufacturer). DOE incorporates such information into the public record, but reports it without attribution. DOE collates the completed interview questionnaire results and prepares a summary of the major issues and outcomes. This summary becomes part of the TSD produced in a rulemaking.

78


15.2 Industry Cash-Flow Analysis The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of new or amended energy conservation standards on the industries that produce the products covered by the standard. The GRIM analysis uses a number of inputs—annual expected revenues; manufacturer costs such as costs of goods sold; selling, general, and administrative (SG&A) costs; taxes; and capital expenditures (both ordinary capital expenditures and those related to standards)—to determine a series of annual cash flows beginning from the announcement of the new or amended standards and continuing throughout the analysis period. DOE compares the results against base-case projections that involve no amended standards. The financial impact of new or amended standards is the difference between the two sets of discounted annual cash flows. Other performance metrics, such as return on invested capital, also are available from the GRIM. DOE gathers the inputs needed for the GRIM from two primary sources: (1) the analyses conducted to this point; and (2) interviews with manufacturers and other stakeholders. Information gathered from previous analyses includes financial parameters, manufacturing costs, price forecasts, and shipments forecasts. Interviews with manufacturers and other stakeholders are essential in supplementing this information. 15.3 Manufacturer Subgroup Analysis It is possible that the use of average industry cost values may not adequately assess differential impacts among subgroups of manufacturers. DOE recognizes that smaller manufacturers, niche players, and manufacturers exhibiting a cost structure that differs significantly from the industry average may be affected differently by new or amended standards. Ideally, DOE would consider the impact on every firm individually. In highly concentrated industries, this may be possible. In industries having numerous participants, however, DOE uses the results of the market and technology assessment to group manufacturers into subgroups, as appropriate. Small businesses, as defined by the Small Business Administration (SBA) for ceiling fan and ceiling fan light kit manufacturers, are enterprises with 750 employees or fewer. Small business size standards are listed by North American Industry Classification System (NAICS) code and industry description. Ceiling fan and ceiling fan light kit manufacturing is classified under NAICS 335210, “Small Electrical Appliance Manufacturing.”41 A search of small businesses of this NAICS code listed in the U.S. Small Business Association website42 indicates that there may be up to 10 small businesses that manufacture ceiling fans and/or ceiling fan light kits that could potentially be covered by this rulemaking. However, as this NAICS code covers all small electrical appliance manufacturing, it is not clear how many of these manufacturers produce ceiling fans and ceiling fan light kits. As part of its subgroup analysis, DOE would identify small businesses that manufacture these products and interview small businesses affected by the rulemaking to determine if there are differential impacts on these companies that
41 42

http://www.naics.com/free-code-search/naicsdescription.php?code=335210. http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm. 79


may result from amended energy conservation standards. DOE examines publicly-available data and contacts manufacturers, when needed, to determine if they meet the SBA’s definition of a small manufacturing facility and if their manufacturing facilities are located within the United States. The detailed manufacturer subgroup impact analysis entails calculating cash flows separately for each defined class of manufacturer. For ceiling fans and ceiling fan light kits, DOE is interested in feedback about potential subgroups, including small businesses. DOE will conduct a Regulatory Flexibility Act analysis to determine the impacts of any amended standards on small businesses. Item 69 DOE seeks comment on the appropriate manufacturer subgroups, if any, for ceiling fans and ceiling fan light kits that DOE should consider in a manufacturer subgroup analysis.

15.4 Competitive Impacts Analysis EPCA directs DOE to consider any lessening of competition that is likely to result from an imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and 6316(a)) It further directs the Attorney General to determine in writing the impacts, if any, of any lessening of competition likely to result from standards. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE makes a determined effort to gather and report firm-specific information regarding financial and other impacts associated with amended energy conservation standards, and it will then report the anticipated aggregated impact of the amended standard on manufacturers. A key aspect of the competitive impacts analysis focuses on assessing the impacts on smaller manufacturers. DOE bases this assessment on manufacturing cost data and on information collected from interviews with manufacturers. These manufacturer interviews focus on gathering information that will help in assessing asymmetrical cost increases to some manufacturers, increased proportion of fixed costs potentially increasing business risks, and potential barriers to market entry (e.g., proprietary technologies). DOE provides the Attorney General with a copy of the NOPR and the TSD for consideration in the evaluation of the impact of amended standards in terms of the lessening of competition. DOE publishes the Attorney­ General’s letter and addresses any related comments in the final rule. 15.5 Cumulative Regulatory Burden Other regulations (Federal, State, local, or international) may apply to manufacturers of ceiling fans and ceiling fan light kits covered under this rulemaking, as well as to other products made by the same manufacturers. Multiple regulations may result in a significant, cumulative regulatory burden on these manufacturers. Accordingly, DOE carefully considers the overlapping effects of amended DOE standards and other regulatory actions on manufacturers of ceiling fans and ceiling fan light kits.

80


Item 70

DOE welcomes comments on what other existing regulations or pending regulations it should consider in its examination of cumulative regulatory burden.

16 EMISSIONS ANALYSIS In the emissions analysis, DOE will estimate the reduction in power sector emissions of carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2), and mercury (Hg) from potential amended energy conservation standards for ceiling fans and ceiling fan light kits. In addition, DOE will estimate emissions impacts in production activities (extracting, processing, and transporting fuels) that provide the energy inputs to power plants. These are referred to as “upstream” emissions. Together, these emissions account for the full-fuel-cycle. In accordance with DOE’s FFC Statement of Policy (76 FR 51281 (Aug. 18, 2011)), the FFC analysis also includes impacts of standards on emissions of methane and nitrous oxide, both of which are recognized as greenhouse gases. DOE will conduct the emissions analysis using emissions factors derived from data in the latest available version of EIA’s Annual Energy Outlook(AEO), supplemented by data from other sources. EIA prepares the Annual Energy Outlook using NEMS. Each annual version of NEMS incorporates the projected impacts of existing air quality regulations on emissions. Sulfur dioxide (SO2) emissions from affected electric generating units (EGUs) are subject to nationwide and regional emissions cap-and-trade programs. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous States and the District of Columbia (D.C.). SO2 emissions from 28 eastern States and D.C. were also limited under the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), which created an allowancebased trading program that operates along with the Title IV program. CAIR was remanded to the U.S. Environmental Protection Agency (EPA) by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) (see North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008)), but it remained in effect. On July 6, 2011, EPA issued a replacement for CAIR, the Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). The AEO 2012 NEMS assumes the implementation of the CSAPR.43 The attainment of emissions caps is typically flexible among EGUs and is enforced through the use of emissions allowances and tradable permits. Under existing EPA regulations, any excess SO2 emissions allowances resulting from the lower electricity demand caused by the adoption of an energy conservation standard could be used to permit offsetting increases in SO2 emissions by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about the effects of efficiency standards on SO2 emissions covered by the existing
On December 30, 2011, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and told EPA to continue administering CAIR. See EME Homer City Generation, LP v. EPA, Order, No. 11-1302, Slip Op. at *2 (D.C. Cir. Dec. 30, 2011). On August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME Homer City Generation, LP v. EPA, No. 11-1302, 2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 2012). The court again ordered EPA to continue administering CAIR. AEO 2012 had been finalized prior to both these decisions; however. DOE understands that CAIR and CSAPR are similar with respect to their effect on emissions impacts of energy conservation standards. 81

43

cap-and-trade system, but it concluded that negligible reductions in power sector SO2 emissions would occur as a result of standards. Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury and Air Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 2011. 77 FR 9304 (Feb. 16, 2012).44 In the final MATS rule, EPA established a standard for hydrogen chloride as a surrogate for acid gas hazardous air pollutants (HAP), and also established a standard for SO2 (a non-HAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP. The same controls are used to reduce HAP and non-HAP acid gas; thus, SO2 emissions will be reduced as a result of the control technologies installed on coal-fired power plants to comply with the MATS requirements for acid gas. AEO 2012 assumes that, in order to continue operating, coal plants must have either flue gas desulfurization or dry sorbent injection systems installed by 2015. Both technologies, which are used to reduce acid gas emissions, also reduce SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 emissions when electricity demand decreases (e.g., as a result of energy efficiency standards). Emissions will be far below the cap that would be established by CSAPR, so it is unlikely that excess SO2 emissions allowances resulting from the lower electricity demand would be needed or used to permit offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE believes that efficiency standards will reduce SO2 emissions in 2015 and beyond. CSAPR established a cap on NOX emissions in 28 eastern States and the District of Columbia. Energy conservation standards are expected to have little effect on NOX emissions in those States covered by CSAPR because excess NOX emissions allowances resulting from the lower electricity demand could be used to permit offsetting increases in NOX emissions. However, standards would be expected to reduce NOX emissions in the States not affected by CSAPR, so DOE estimates NOX emissions reductions from potential standards in the States where emissions are not capped. The MATS limit mercury emissions from power plants, but they do not include emissions caps, and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. For this rulemaking, DOE will estimate mercury emissions reduction using emissions factors based on the latest version of AEO, which incorporates the MATS. Power plants may emit particulates from the smoke stack, which are known as direct particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power plants. DOE is investigating the possibility of using other methods to estimate reduction in PM emissions due to standards. The great majority of ambient PM associated with power plants is in the form of secondary sulfates and nitrates, which are produced at a significant distance from power plants by complex atmospheric chemical reactions that often involve the gaseous emissions of power plants, mainly SO2 and NOx. The monetary benefits that DOE estimates for reductions in SO2 and NOx emissions resulting from standards are in fact primarily related to the health benefits of reduced ambient PM.

On July 20, 2012, EPA announced a partial stay, for a limited duration, of the effectiveness of national new source emission standards for hazardous air pollutants from coal-fired and oil-fired electric utility steam generating units. See: http://www.epa.gov/airquality/powerplanttoxics/pdfs/20120727staynotice.pdf. 82


44

Item 71

DOE seeks input on its approach to conduct the emissions analysis for the products covered by this rulemaking.

17 MONETIZATION OF CO2 AND OTHER EMISSIONS REDUCTIONS DOE plans to consider the estimated monetary benefits likely to result from the reduced emissions of CO2 and NOX that are expected to result from each of the amended energy conservation standard levels considered. In order to estimate the monetary value of benefits resulting from reduced emissions of CO2, DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed to by an interagency process. The SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, net agricultural productivity loss, human health effects, property damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to monetize the harms associated with climate change will raise serious questions of science, economics, and ethics. But with full regard for the limits of both quantification and monetization, the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions. At the time of this notice, the most recent interagency estimates of the potential global benefits resulting from reduced CO2 emissions in 2015, expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton avoided. For emissions reductions that occur in later years, these values grow in real terms over time. Additionally, the interagency group determined that a range of values from 7 percent to 23 percent should be used to adjust the global SCC to calculate domestic effects, although DOE will give preference to consideration of the global benefits of reducing CO2 emissions. To calculate a present value of the stream of monetary values, DOE will discount the values in each of the four cases using the discount rates that had been used to obtain the SCC values in each case. DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to the contribution of CO2 and other GHG to changes in the future global climate and the potential resulting damages to the world economy. Thus, these values are subject to change. DOE also estimates the potential monetary benefit of reduced NOX emissions resulting from the standard levels it considers. For NOx emissions, available estimates suggest a very wide range of monetary values, ranging from $460 to $4,722 per ton in 2011$).45 In accordance with OMB guidance, DOE conducts two calculations of the monetary benefits derived using each of the economic values used for NOx, one using a real discount rate of 3 percent and another using a real discount rate of 7 percent.46

For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory
Affairs (OIRA), 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates
on State, Local, and Tribal Entities.
46 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
83


45

DOE is investigating the appropriate valuation of Hg emissions. It currently does not plan to monetize estimates of reduced Hg emissions in this rulemaking. Item 72 DOE requests comments on the approach it plans to use for estimating monetary values associated with emissions reductions.

18 UTILITY IMPACT ANALYSIS In the utility impact analysis, DOE analyzes the changes in electric installed capacity and generation that result for each trial standard level. The utility impact analysis uses a variant of the DOE/EIA’s National Energy Modeling System.47 NEMS is a public domain, multi-sectored, partial equilibrium model of the U.S. energy sector. Each year, DOE/EIA uses NEMS to produce an energy forecast for the United States, the Annual Energy Outlook. DOE uses a variant of this model, referred to as NEMS-BT,48 to account for selected utility impacts of new or amended energy conservation standards. DOE’s analysis consists of a comparison between model results for the most recent AEO Reference Case and for cases in which energy use is decremented to reflect the impact of potential standards. For the analysis of standards on ceiling fans and ceiling fan light kits, DOE will use the version of NEMS based on the latest available AEO. Item 73 DOE welcomes input from stakeholders on its proposed approach to conduct the utility impact analysis.

19 EMPLOYMENT IMPACT ANALYSIS Employment impacts include direct and indirect impacts in the domestic workforce resulting from new or amended energy conservation standards. Direct employment impacts are any changes in the number of employees of manufacturers of the product subject to standards. The MIA addresses impacts in the number of employees working for the manufacturers. Indirect employment impacts from standards consist of the net jobs created or eliminated in the national economy, other than in the manufacturing sector being regulated, caused by: (1) reduced spending by end users on energy; (2) reduced spending on new energy supply by the utility industry; (3) increased spending on new products to which the new standards apply; and (4) the effects of those three factors throughout the economy. One method for assessing the possible effects on the demand for labor of such shifts in economic activity is to compare sector employment statistics developed by the Labor Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of the number of jobs per million dollars of economic activity in different sectors of the economy, as
For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration documentation. A useful summary is National Energy Modeling System: An Overview 2003, DOE/EIA-0581 (March 2003). 48 DOE/EIA approves use of the name NEMS to describe only an official version of the model without any modification to code or data. Because this analysis entails some minor code modifications and the model is run under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it by the name NEMS­ BT. (BT is DOE’s Building Technologies Program, under whose aegis this work has been performed.) 84

47

well as the jobs created elsewhere in the economy by this same economic activity. Data from BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and indirectly) than expenditures in other sectors of the economy.49 There are many reasons for these differences, including wage differences and the fact that the utility sector is more capitalintensive and less labor-intensive than other sectors. Energy conservation standards have the effect of reducing consumer utility bills. Because reduced consumer expenditures for energy likely lead to increased expenditures in other sectors of the economy, the general effect of efficiency standards is to shift economic activity from a less labor-intensive sector (i.e., the utility sector) to more labor-intensive sectors (e.g., the retail and service sectors). In the NOPR stage of this rulemaking, DOE plans to estimate indirect national employment impacts using an input/output model of the U.S. economy called Impact of Sector Energy Technologies version 3.1.1 (ImSET).50 ImSET is a special-purpose version of the “U.S. Benchmark National Input-Output” (I–O) model, which was designed to estimate the national employment and income effects of energy-saving technologies. The ImSET software includes a computer-based I–O model having structural coefficients that characterize economic flows among 187 sectors most relevant to industrial, commercial, and residential building energy use. DOE notes that ImSET is not a general equilibrium forecasting model and understands the uncertainties involved in projecting employment impacts, especially changes in the later years of the analysis. Because ImSET does not incorporate price changes, the employment effects predicted by ImSET may over-estimate actual job impacts over the long run. DOE may consider the use of other modeling approaches for examining long-run employment impacts. Item 74 DOE welcomes feedback on its proposed approach to assessing national employment impacts.

20 REGULATORY IMPACT ANALYSIS In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis that will address the potential for non-regulatory approaches to supplant or augment energy conservation standards to improve the efficiency of ceiling fans and ceiling fan light kits on the market. DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, and other interested parties can result in substantial efficiency improvements. DOE intends to analyze the likely effects of non-regulatory initiatives and compare such effects with those projected to result from amended energy conservation standards. DOE will attempt to base its assessment on the actual impacts of any such initiatives to date, but will also consider information presented regarding the impacts that any existing initiative might have in the future. DOE intends to analyze policies such as consumer rebates, consumer tax credits, manufacturer
See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input-Output
Modeling System (RIMS II), U.S. Department of Commerce (1992) (Available at:
http://www.bea.gov/scb/pdf/regional/perinc/meth/rims2.pdf).
50 J. M. Roop, M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies, PNNL-18412,
Pacific Northwest National Laboratory (2009) (Available at:
www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf ).
85

49

tax credits, voluntary energy efficiency targets (e.g., the ENERGY STAR program), early replacement, and bulk government purchasing. If DOE proposes energy conservation standards for ceiling fans and ceiling fan light kits and the NOPR constitutes a significant regulatory action, DOE would prepare and submit to OMB for review the assessment of costs and benefits required under section 6(a)(3) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993). Item 75 DOE requests any available data or reports that would contribute to the Regulatory Impact Analysis for ceiling fans and ceiling fan light kits covered in this rulemaking. In particular, DOE seeks information on the effectiveness of existing or past programs for these products that are similar to the policies noted above.

86


APPENDIX A – LIST OF ITEMS FOR COMMENT This appendix lists all the items for comment contained in this Framework Document and the page numbers on which those items can be found. Item 1  Item 2  DOE seeks comments on its proposed reinterpretation of the ceiling fan definition. ...................................................................................................................5  DOE seeks comments on whether ceiling fans without external blades should be included in this rulemaking if they meet the definition of a ceiling fan...................................................................................................................5  DOE seeks comments on its proposed approach for developing definitions for the four types of ceiling fans, the vertical distance that is used to characterize whether a fan can safely be used in rooms with low ceiling heights, and any other physical characteristics used to determine the different types of ceiling fans currently on the market. .............................................7  DOE seeks comments on its proposed definition of “highly decorative ceiling fans.” ..............................................................................................................8  DOE seeks comments on its proposed definition of “outdoor ceiling fans”. ............9  DOE seeks comment on the existence and applicability of any other test procedure that DOE could consider for measuring the airflow and electrical energy consumption of ceiling fans. DOE seeks comment as to what types of testing manufacturers currently conduct on ceiling fans and what test set-ups and methods are used. DOE has noticed, for example, that some hugger fans are marketed with a declaration of energy efficiency. DOE is interested in knowing how manufacturers have tested such ceiling fans.........................................................................................................18  DOE requests comments on the accuracy tolerance of the velocity sensors for either the current DOE or current ENERGY STAR test procedures and potential sources of inaccuracy for low speed airflow measurements.......................22  DOE requests comments on the potential performance variability between ceiling fans for a specific fan model and the possibility of requiring a sample of ceiling fans to certify a model. ..................................................................22  DOE requests comments on its proposal to investigate methodologies (including the use of an artificial ceiling) to enable hugger fans to be tested. DOE welcomes any information on how hugger fans currently are tested. .........................................................................................................................23  DOE requests comments on its proposal to test multi-mount fans in hugger fan configuration. .......................................................................................................23  DOE is considering investigating appropriate distances and measuring methodologies for ceiling fans having non-flat and unusually shaped blades to clarify how such fans should be measured. DOE requests feedback as to whether developing such methodologies is necessary and helpful. DOE seeks suggestions as to how best to clarify the test procedure to account for those types of configurations. ............................................23  DOE requests information on the effects of testing ceiling fans in cylinders having diameters other than 8 inches wider than the blade span
87


Item 3 

Item 4  Item 5  Item 6 

Item 7 

Item 8 

Item 9 

Item 10  Item 11 

Item 12 

Item 13  Item 14  Item 15  Item 16 

Item 17  Item 18 

Item 19 

Item 20  Item 21 

Item 22 

Item 23  Item 24 

Item 25  Item 26 

Item 27 

Item 28 

of the ceiling fan and seeks comments on the potential modifications to the test procedure described.............................................................................................23
  DOE requests comments on its proposed approach to testing ceiling fans
with multiple fan heads..............................................................................................23 
DOE requests comments on its approach to testing ceiling fans where the
airflow is not directed vertically. ...............................................................................23
  DOE is proposing to specify in its test procedure that heaters be switched
off during testing. DOE requests comments on its proposed approach. ...................23
  DOE seeks comment on the possibility of testing at one, three, or all
available fan speeds. Additionally, DOE seeks input on the amount of time spent at each fan speed setting...........................................................................23 
DOE seeks on how to define “high”, “medium”, and “low” speeds on fans
with more than three speeds or variable speed controls. ...........................................23
  DOE seeks comments and any available data regarding its view that
energy consumption in forward and reverse are likely to be highly correlated....................................................................................................................24 
DOE requests comments on the amount of energy ceiling fans consume in
standby mode and/or off mode and how it compares to energy consumption in active mode. .....................................................................................27 
DOE requests feedback on its planned approach to use an integrated
energy efficiency metric for ceiling fans. ..................................................................27 
DOE seeks information on the number of ceiling fans that are sold with
remote controls or other devices that consume energy in standby mode and/or off mode..........................................................................................................27 
DOE seeks input on average ceiling fan usage, including the amount of
time spent in each mode, and the feasibility of determining representative national average hours of operation...........................................................................27 
DOE requests comments on its proposal to use luminous efficacy as the
efficiency metric for all ceiling fan light kits.............................................................30 
DOE requests comment on the proposal to base test procedures to
determine ceiling fan light kit efficiency on the following IES lamp photometry test procedures: LM-9, LM-66, LM-45, and LM-79,
depending on light source type. .................................................................................30 
DOE requests information on the existing and/or future market availability
of ceiling fan light kits with inseparable LED lighting components. ........................30 
DOE requests comment on using guidance provided in the latest version
of the upcoming ENERGY STAR Program Requirements for Luminaires for testing ceiling fan light kits with inseparable LED lighting components. ...............................................................................................................30
  DOE requests comment on the advantages or disadvantages of defining
ceiling fan light kit efficacy as the total lamp lumens divided by the total input wattage..............................................................................................................30 
DOE requests input on whether ceiling fan light kits, or ceiling fan light
kit controls, exist that have a standby mode and that operate independent of the ceiling fan. If such devices exist, DOE requests comment what

88


Item 29 

Item 30 

Item 31 

Item 32  Item 33  Item 34 

Item 35 

Item 36  Item 37 

Item 38  Item 39 

Item 40 

Item 41  Item 42 

fraction of controllers that are of this type, the power draw in standby mode, and the fraction of time they spend in standby mode. ....................................31 
DOE requests feedback on its planned approach to attribute all standby
power to the ceiling fan if ceiling fan standby is managed by a controller that is shared between the ceiling fan light kit and its ceiling fan. ............................31
  DOE requests information that would contribute to the market assessment
for ceiling fans and ceiling fan light kits covered in this rulemaking (e.g., current product features and efficiencies, trends in product features and efficiency, and historical product shipments and prices). ..........................................35 
DOE welcomes input on estimates of market shares, products, features,
and trends for the ceiling fans and ceiling fan light kits covered in this rulemaking. ................................................................................................................35 
DOE seeks input and data on ceiling fan life expectancy and, in particular,
the relationship between ceiling fan usage and ceiling fan life expectancy. .............46 
DOE welcomes comments on whether it should establish a separate
product class for hugger fans. ....................................................................................48 
DOE welcomes comments on whether it should establish a separate
product class for “highly decorative fans for which air movement performance is a secondary feature.” DOE also seeks input on whether such ceiling fans should be subject to or exempted from energy conservation standards. ..............................................................................................49
  DOE seeks input on whether the differences between the construction of
outdoor and indoor ceiling fans warrants establishing a separate product class for outdoor ceiling fans. ....................................................................................49 
DOE seeks feedback from interested parties on its general approach to
developing product classes. .......................................................................................49 
DOE requests feedback on the possibility of combining or restructuring
product classes for ceiling fan light kits specifically on: (i) significant consumer utility differences among ceiling fan light kits; (ii) which   products should be combined; and (iii) what issues should be considered................50
DOE requests feedback the consumer utility of ceiling fan light kits that
  are packaged with dimming functionality..................................................................50
DOE welcomes comments on the preliminary technology options
identified in this section (i.e., high-efficiency motors and high-efficiency fan blades for ceiling fans) and whether there are other technology options it should consider. In commenting on technology options, please discuss   their impacts (if any) on safety, performance, and consumer utility. ........................56
DOE requests input on whether it should include occupancy sensors as an
energy efficiency option for ceiling fans and on how these could be taken into consideration in its rulemaking. ..........................................................................56 
DOE welcomes input on the potential technology options for ceiling fan
light kits and on other technology options that should be considered. ......................57
  DOE welcomes comments on any technologies listed in section 6.2 (or
others not identified) that it should not consider based on any of the four screening criteria. If so, which screening criteria apply to the cited technology or technologies? DOE also welcomes comments on how the
89


Item 43 

Item 44 

Item 45 

Item 46 

Item 47 

Item 48 

Item 49 

Item 50 

Item 51 

Item 52  Item 53 

Item 54 

Item 55 

Item 56 

above four screening criteria might apply to any additional technology option(s) that an interested party recommends to DOE. ............................................58  DOE seeks stakeholder comment on these and other potential approaches to determining the cost-efficiency relationship for ceiling fans and ceiling fan light kits. ..............................................................................................................60  DOE welcomes comments on its proposed approach and on the selection and appropriate features and performance characteristics of baseline models for each representative product group for ceiling fans..................................61  DOE seeks input from stakeholders regarding the range of efficiency levels that should be examined as part of its analysis for ceiling fans and ceiling fan light kits. ..................................................................................................61  DOE seeks input from interested parties on a methodology that would be appropriate for determining the max-tech models for each ceiling fan and ceiling fan light kit analyzed. .....................................................................................61  DOE seeks comments on its proposed methods for determining costs associated with incremental efficiency improvements in both ceiling fans and ceiling fan light kits. ............................................................................................63  DOE welcomes comments on how ceiling fan efficiency varies with airflow capacity, motor type, motor rated horsepower, blade span, number and design of blades, or any other ceiling fan parameter. DOE also seeks comments on how ceiling fan light kit efficiency varies with bulb type, number of bulbs, or any other ceiling fan light kit parameter. ..................................63  DOE welcomes comments on the proposed method for isolating costs associated with decorative features from costs associated with functional features in ceiling fans and ceiling fan light kits .......................................................63  DOE seeks information on proprietary designs of which it should be aware for both the ceiling fans and ceiling fan light kits under consideration in this rulemaking. If such proprietary designs exist, DOE would like to acquire the cost data necessary for evaluating those designs. ...................................64  DOE welcomes comments on regulatory burdens and changes that should be considered in the engineering analysis of ceiling fans and ceiling fan light kits. ....................................................................................................................64  DOE welcomes comments on other engineering issues that could affect the engineering analysis. ............................................................................................64  DOE welcomes suggestions and comments concerning its proposed approach for estimating end-user prices for ceiling fans and ceiling fan light kits. ....................................................................................................................66  DOE welcomes suggestions and comments concerning its assumed distribution channels for ceiling fans and ceiling fan light kits, and data and/or estimates regarding relative sales volumes through each channel..................66  DOE welcomes comments on typical manufacturer, retailer, wholesaler, and contractor markups associated with ceiling fans and ceiling fan light kits. .............................................................................................................................66  DOE welcomes comments on its proposed methodology to determine annual operating hours and energy use for covered ceiling fans and ceiling

90


Item 57 

Item 58  Item 59  Item 60  Item 61 

Item 62 

Item 63  Item 64 

Item 65 

Item 66 

Item 67 

Item 68 

Item 69 

Item 70 

Item 71  Item 72 

fan light kits, and how operating hours may vary (e.g., by product type and application, geographical location, season). ..............................................................68
  DOE welcomes comments from interested parties as to whether a more-
efficient ceiling fan or ceiling fan light kit would be expected to be used more and whether such a rebound effect should be considered separately for this product...........................................................................................................70 
DOE seeks stakeholder input on the planned approach for estimating
current and forecasted energy prices..........................................................................70 
DOE welcomes input on the planned approaches for estimating discount
rates for consumers of ceiling fans and ceiling fan light kits. ...................................71
  DOE welcomes comments on appropriate maintenance and repair costs for
ceiling fans and ceiling fan light kits. ........................................................................71
  DOE welcomes comments on appropriate lifetimes for both ceiling fans
and ceiling fan light kits covered in this rulemaking. DOE is particularly interested in regional lifetime data and data on the relationship between ceiling fan usage and ceiling fan life expectancy. .....................................................72 
DOE seeks comments on the appropriate distribution of energy
efficiencies for both ceiling fans and ceiling fan light kits in the absence of amended energy conservation standards. ...................................................................73 
DOE welcomes comments on the approach described to forecast
shipments of ceiling fans and ceiling fan light kits....................................................73
  DOE seeks input on historical shipments and stock data for ceiling fans
and ceiling fan light kits, including the distribution of shipments by efficiency....................................................................................................................74 
DOE welcomes comments on whether energy conservation standards
might affect shipments of ceiling fans and ceiling fan light kits, as well as the anticipated extent of such impacts, if any. ...........................................................74 
DOE seeks comments on the appropriate assumptions to use regarding
long-run changes in ceiling fan and ceiling fan light kit energy efficiency independent of amended energy conservation standards. ..........................................75
  DOE seeks comments on the use of the “roll-up” and “shift” efficiency
scenarios to characterize the impact that potential standards would have on the product efficiency distributions. ..........................................................................75 
DOE welcomes input from interested parties regarding which, if any,
consumer subgroups should be considered when developing potential energy conservation standards for ceiling fans and ceiling fan light kits. .................77
  DOE seeks comment on the appropriate manufacturer subgroups, if any,
for ceiling fans and ceiling fan light kits that DOE should consider in a manufacturer subgroup analysis. ...............................................................................80
  DOE welcomes comments on what other existing regulations or pending
regulations it should consider in its examination of cumulative regulatory burden. .......................................................................................................................81 
DOE seeks input on its approach to conduct the emissions analysis for the
products covered by this rulemaking. ........................................................................83 
DOE requests comments on the approach it plans to use for estimating
monetary values associated with emissions reductions. ............................................84 

91


Item 73  Item 74  Item 75 

DOE welcomes input from stakeholders on its proposed approach to conduct the utility impact analysis. ............................................................................84  DOE welcomes feedback on its proposed approach to assessing national employment impacts. .................................................................................................85  DOE requests any available data or reports that would contribute to the Regulatory Impact Analysis for ceiling fans and ceiling fan light kits covered in this rulemaking. In particular, DOE seeks information on the effectiveness of existing or past programs for these products that are similar to the policies noted above.............................................................................86 

92


APPENDIX B – DRAFT PRELIMINARY MANUFACTURER IMPACT ANALYSIS
QUESTIONAIRE
1 Issues 1.1 What are the key issues for your company regarding a possible future product rulemaking? 2 Shipment Projections 2.1 What is your company’s approximate market share? 2.2 Would you expect your market share to change once standards become effective? Does your outlook change with higher efficiency levels? 2.3 How would you expect shipments to change for the industry as a whole as a function of standards and why? 2.4 Looking at price/cost effects only, how would you expect shipments to change for a 5 percent, 10 percent, 25 percent, or 50 percent manufacturer price/cost increase? 3 Conversion Costs 3.1 What level of capital expenditure and product conversion costs would you anticipate to make at higher standard levels? Please describe what they are and provide your best estimate of their respective magnitudes. 3.2 How would the adoption of amended energy conservation standards affect capacity utilization and manufacturing assets at your domestic production facilities? Would an amended standard result in stranded capital assets? Would any facilities be closed or downsized? Added or upgraded? 3.3 How might an amended standard impact product innovation? 4 Product Mix and Profitability 4.1 How would your company’s product mix and marketing strategy change with changes in the efficiency standard? 4.2 What distribution channels are used from the manufacturer to the retail outlet? What is the share of product going through each distribution channel? 4.3 Generally, how would new product standards affect your customer mix, distribution channels, and corresponding profit margins?

93


4.4 How might a new standard affect the ENERGY STAR program, and consequently your firm? 5 Market Shares and Industry Consolidation 5.1 In the absence of amended standards, do you expect any industry consolidation? 5.2 How would amended standards affect your ability to compete? 5.3 Could amended standards disproportionately advance or harm the competitive positions of some firms? 5.4 Are there concerns over intellectual property? 5.5 Could amended standards result in disproportionate economic or performance penalties for particular consumer/user subgroups? 5.6 Beyond price and energy efficiency, could amended standards result in products that will be more or less desirable to consumers due to changes in product functionality, utility, or other features? 6 Cumulative Regulatory Burden 6.1 Are there recent or impending regulations on your specific product or other products that impose a cumulative burden on the industry? 6.2 If so, what is the total expected impact of those other regulations?

94


Sponsor Documents

Or use your account on DocShare.tips

Hide

Forgot your password?

Or register your new account on DocShare.tips

Hide

Lost your password? Please enter your email address. You will receive a link to create a new password.

Back to log-in

Close