Energy Conservation Program for Consumer Products: Energy Conservation Standards for Residential Furnace Fans
Federal RegisterOct 25, 2013
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket Number EERE-2010-BT-STD-0011]
RIN 1904-AC22
Energy Conservation Program for Consumer Products: Energy Conservation Standards for Residential Furnace Fans
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking and announcement of public meeting.
SUMMARY:
Pursuant to the Energy Policy and Conservation Act of 1975 (EPCA), as amended, the U.S. Department of Energy (DOE) must prescribe energy conservation standards for various consumer products and certain commercial and industrial equipment, including residential furnace fans. EPCA requires DOE to determine whether such standards would be technologically feasible and economically justified, and would save a significant amount of energy. In this notice, DOE is proposing new energy conservation standards for residential furnace fans. The notice also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
DATES:
Meeting:
DOE will hold a public meeting on Tuesday, December 3, 2013, from 9 a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See section VII, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.
Comments:
DOE will accept comments, data, and information regarding this notice of proposed rulemaking (NOPR) before and after the public meeting, but no later than December 24, 2013. See section VII, “Public Participation,” for details.
ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW., Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586-2945. Please note that foreign nationals visiting DOE Headquarters are subject to advance security screening procedures. Any foreign national wishing to participate in the meeting should advise DOE as soon as possible by contacting Ms. Edwards at the phone number above to initiate the necessary procedures. Please also note that any person wishing to bring a laptop computer into the Forrestal Building will be required to obtain a property pass. Visitors should avoid bringing laptops, or allow an extra 45 minutes. Persons may also attend the public meeting via webinar. For more information, refer to section VII, “Public Participation,” near the end of this notice.
Instructions:
Any comments submitted must identify the NOPR for Energy Conservation Standards for Residential Furnace Fans, and provide docket number EE-2010-BT-STD-0011 and/or regulatory information number (RIN) 1904-AC22. Comments may be submitted using any of the following methods:
1.
Federal eRulemaking Portal:
www.regulations.gov
. Follow the instructions for submitting comments.
2.
Email: FurnFans-2010-STD-0011@ee.doe.gov
. Include the docket number and/or RIN in the subject line of the message. Submit electronic comments in Word Perfect, Microsoft Word, PDF, or ASCII file format, and avoid the use of special characters or any form of encryption.
3.
Postal Mail:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue SW., Washington, DC, 20585-0121. If possible, please submit all items on a compact disc (CD), in which case it is not necessary to include printed copies.
4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. If possible, please submit all items on a CD, in which case it is not necessary to include printed copies.
Written comments regarding the burden-hour estimates or other aspects of the collection-of-information requirements contained in this proposed rule may be submitted to Office of Energy Efficiency and Renewable Energy through the methods listed above and by email to
Chad_S._Whiteman@omb.eop.gov.
No telefacsimilies (faxes) will be accepted. For detailed instructions on submitting comments and additional information on the rulemaking process, see section VII of this document (Public Participation).
Docket:
The docket is available for review at
www.regulations.gov
, including
Federal Register
notices, framework documents, public meeting attendee lists and transcripts, comments, and other supporting documents/materials. All documents in the docket are listed in the
www.regulations.gov
index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.
A link to the docket Web page can be found at:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/41
. This Web page contains a link to the docket for this notice on the
www.regulations.gov
site. The
www.regulations.gov
Web page contains simple instructions on how to access all documents, including public comments, in the docket. See section VII, “Public Participation,” for further information on how to submit comments through
www.regulations.gov
.
For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Mr. Ron Majette, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC, 20585-0121. Telephone: (202) 586-7935. Email:
Ronald.Majette@ee.doe.gov
.
Mr. Eric Stas, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC, 20585-0121. Telephone: (202) 586-9507. Email:
Eric.Stas@hq.doe.gov
.
For information on how to submit or review public comments, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Residential Furnace Fans
III. General Discussion
A. Test Procedure
B. Product Classes and Scope of Coverage
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Life-Cycle Costs
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion
A. Market and Technology Assessment
1. Definition and Scope of Coverage
2. Product Classes
3. Technology Options
a. Fan Housing and Airflow Path Design Improvements
b. Inverter Controls for PSC Motors
c. High-Efficiency Motors
d. Multi-Stage or Modulating Heating Controls
e. Backward-Inclined Impellers
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
a. High-Efficiency Motors
b. Backward-Inclined Impellers
C. Engineering Analysis
1. Efficiency Levels
a. Baseline
b. Percent Reduction in FER
2. Manufacturer Production Cost (MPC)
a. Production Volume Impacts on MPC
b. Inverter-Driven PSC Costs
c. Furnace Fan Motor MPC
d. Motor Control Costs
e. Backward-Inclined Impeller MPC
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Installed Cost
2. Operating Costs
3. Other Inputs
4. Base-Case Efficiency Distribution
5. Rebuttable Presumption Payback Period
G. Shipments Analysis
H. National Impact Analysis
1. National Energy Savings Analysis
2. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model
a. Government Regulatory Impact Model Key Inputs
b. Government Regulatory Impact Model Scenarios
3. Discussion of Comments
a. Testing and Certification Burdens
b. Cumulative Regulatory Burden
c. Compliance Date and Implementation Period
d. Small Businesses
e. Conversion Costs
4. Manufacturer Interviews
a. Testing and Certification Burdens
b. Market Size
c. Cumulative Regulatory Burden
d. Consumer Confusion
e. Motors
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impact on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Product Utility or Performance
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
C. Proposed Standards
1. Benefits and Burdens of Trial Standard Levels Considered for Residential Furnace Fans
2. Summary of Benefits and Costs (Annualized) of the Proposed Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Requests to Speak and Prepared General Statements For Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Summary of the Proposed Rule
Title III, Part B
1
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Public Law 94-163 (42 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, including the residential furnace fans that are the focus of this notice. Pursuant to EPCA, any new or amended energy conservation standard that DOE prescribes for certain products, such as residential furnace fans, shall be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) EPCA specifically provides that DOE must consider and prescribe energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work (products for which DOE has adopted the term “furnace fans” as shorthand) not later than December 31, 2013. (42 U.S.C. 6295(f)(4)(D))
1
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.
In accordance with these and other statutory provisions discussed in this notice, DOE is proposing new energy conservation standards for residential furnace fans. Table I.1 below presents the proposed standards, which represent the “estimated annual electrical energy consumption” normalized by the estimated total number of annual operating hours (1870) and the airflow in the maximum airflow-control setting to produce a fan energy rating (FER). These proposed standards, if adopted, would apply to all products listed in Table I.1 and manufactured in, or imported into, the United States on or after the date five years from the publication of the final rule.
Table I.1—Proposed Energy Conservation Standards for Residential Furnace Fans
[Compliance Starting Five Years From Final Rule Publication]
Product class
Product class description
Proposed standard:
FER * (W/1000 cfm)
1
Non-Weatherized, Non-Condensing Gas Furnace Fan (NWG-NC)
FER = 0.029 × Q
Max
+ 180.
2
Non-Weatherized, Condensing Gas Furnace Fan (NWG-C)
FER = 0.029 × Q
Max
+ 196.
3
Weatherized Non-Condensing Gas Furnace Fan (WG-NC)
FER = 0.029 × Q
Max
+ 135.
4
Non-Weatherized, Non-Condensing Oil Furnace Fan (NWO-NC)
FER = 0.051 × Q
Max
+ 301.
5
Non-Weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB)
FER = 0.029 × Q
Max
+ 165.
6
Manufactured Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWGNC)
FER = 0.051 × Q
Max
+ 242.
7
Manufactured Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)
FER = 0.051 × Q
Max
+ 262.
8
Manufactured Home Electric Furnace/Modular Blower Fan (MH-EF/MB)
FER = 0.029 × Q
Max
+ 105.
9
Manufactured Home Weatherized Gas Furnace Fan (MH-WG)
Reserved.
10
Manufactured Home Non-Weatherized Oil Furnace Fan (MH-NWO)
Reserved.
* Q
Max
is the airflow, in cfm, at the maximum airflow-control setting measured using the proposed DOE test procedure. 78 FR 19606, 19627 (April 2, 2013).
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the proposed standards on consumers of residential furnace fans, as measured by the average life-cycle cost (LCC) savings and the median payback period (PBP). In overview, the average LCC savings are positive for all product classes.
Table I.2—Impacts of Proposed Standards on Consumers of Residential Furnace Fans
Product class
Average LCC
savings (2012$)
Median payback period (years)
Non-Weatherized, Non-Condensing Gas Furnace Fan (NWG-NC)
474
5.38
Non-Weatherized, Condensing Gas Furnace Fan (NWG-C)
371
5.39
Weatherized Non-Condensing Gas Furnace Fan (WG-NC)
247
6.39
Non-Weatherized, Non-Condensing Oil Furnace Fan (NWO-NC)
40
5.49
Non-Weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB)
185
3.55
Manufactured Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWGNC)
26
3.35
Manufactured Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)
27
2.73
Manufactured Home Electric Furnace/Modular Blower Fan (MH-EF/MB)
78
4.61
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted cash flows to the industry from the base year through the end of the analysis period (2013 to 2048). Using a real discount rate of 7.8 percent, DOE estimates that the INPV for manufacturers of residential furnace fans is $252.2 million in 2012$. Under the proposed standards, DOE expects that manufacturers may lose up to 21.6 percent of their INPV, which is approximately $54.4 million. Total conversion costs incurred by industry prior to the compliance date are expected to reach $3.1 million.
C. National Benefits and Costs
DOE's analyses indicate that the proposed standards would save a significant amount of energy. The cumulative energy savings for residential furnace fan products purchased in the 30-year period that begins in the first full year of compliance with new standards (2019-2048) amount to 4.58 quads.
2
For comparison, the estimated annual energy savings in 2030 (0.074 quads) is equal to 0.3 percent of total projected residential energy use in 2030.
3
2
A quad is equal to 10
15
British thermal units (Btu).
3
Projected residential energy use in 2030 in the
Annual Energy Outlook 2013
is 21.65 quads.
The cumulative net present value (NPV) of total consumer costs and savings for the proposed residential furnace fan standards in 2012$ ranges from $8.51 billion (at a 7-percent discount rate) to $26.16 billion (at a 3-percent discount rate). This NPV expresses the estimated total value of future operating-cost savings minus the estimated increased product costs for residential furnace fans purchased in 2019-2048, discounted to 2013.
In addition, the proposed standards would have significant environmental benefits.
4
The energy savings would result in cumulative emission reductions of 429.8 million metric tons (Mt)
5
of carbon dioxide (CO
2
), 230.9 thousand tons of nitrogen oxides (NO
X
), 313.5 thousand tons of sulfur dioxide (SO
2
), 1.77 tons of mercury (Hg), 913.7 thousand tons of methane (CH
4
), and 5.12 thousand tons of nitrous oxide (N
2
O).
6
4
DOE calculates emissions reductions relative to the
Annual Energy Outlook 2012
(
AEO 2012
) Reference case, which incorporated projected effects of all emissions regulations promulgated as of January 31, 2012.
5
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
are presented in short tons.
6
DOE also estimated CO
2
and, for CH
4
and N
2
O, CO
2
equivalent (CO
2
eq) emissions that occur through 2030. The estimated emissions reductions through 2030 are 40 million metric tons CO
2
, 2.3 million tons CO
2
eq for CH
4
, and 167 thousand tons CO
2
eq for N
2
O.
The value of the CO
2
reductions is calculated using a range of values per metric ton of CO
2
(otherwise known as the Social Cost of Carbon, or SCC) developed by an interagency process. For this NOPR, DOE used an updated set of SCC values
7
(the derivation of the
SCC values is discussed in section IV.L). DOE estimates that the present monetary value of the CO
2
emissions reduction is between $2.25 and $35.56 billion, expressed in 2012$ and discounted to 2013. DOE also estimates the net present monetary value of the NO
X
emissions reduction, expressed in 2012$ and discounted to 2013, is $0.109 billion at a 7-percent discount rate and $0.314 billion at a 3-percent discount rate.
8
7
Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866,
Interagency Working Group on Social Cost of Carbon, United States Government (May 2013) (Available at:
http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf
).
8
DOE did not monetize Hg or SO
2
emission reductions for this NOPR because it is currently evaluating appropriate valuation of reduction in these emissions.
Table I.3 summarizes the national economic benefits and costs expected to result from these proposed standards for residential furnace fans.
Table I.3—Summary of National Economic Benefits and Costs of Proposed Residential Furnace Fans Energy Conservation Standards (TSL 4), in Billion 2012$ *
Category
Present value
billion 2012$
Discount rate
(%)
Benefits:
Consumer Operating Cost Savings
11.6
7
32.0
3
CO
2
Reduction Monetized Value ($12.9/t case)**
2.2
5
CO
2
Reduction Monetized Value ($40.8/t case)**
11.5
3
CO
2
Reduction Monetized Value ($62.2/t case)**
18.8
2.5
CO
2
Reduction Monetized Value ($117/t case)**
35.6
3
NO
X
Reduction Monetized Value (at $2,639/ton)
0.1
7
0.3
3
Total Benefits
†
23.2
7
43.8
3
Costs:
Consumer Incremental Installed Costs
3.1
7
5.8
3
Net Benefits:
Including CO
2
and NO
X
Reduction Monetized Value
20.1
7
38.0
3
* This table presents the costs and benefits associated with residential furnace fans shipped in 2019-2048. These results include benefits to consumers which accrue after 2048 from the products purchased in 2019-2048. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.
** The CO
2
values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The value for NO
X
is the average of the low and high values used in DOE's analysis.
†
Total Benefits for both the 3% and 7% cases are derived using the series corresponding to SCC value in 2015 of $40.8/t.
Although combining the values of operating savings and CO
2
emission reductions provides a useful perspective, two issues should be considered. First, the national operating savings are domestic U.S. consumer monetary savings that occur as a result of market transactions, whereas the value of CO
2
reductions is based on a global value. Second, the assessments of operating cost savings and CO
2
savings are performed with different methods that use different time frames for analysis. The national operating cost savings is measured for the lifetime of residential furnace fans shipped in 2019-2048. The SCC values, on the other hand, reflect the present value of some future climate-related impacts resulting from the emission of one ton of carbon dioxide in each year. These impacts continue well beyond 2100.
The benefits and costs of these proposed standards, for products sold in 2019-2048, can also be expressed in terms of annualized values. The annualized monetary values are the sum of: (1) the annualized national economic value of the benefits from consumer operation of products that meet the proposed standards (consisting primarily of operating cost savings from using less energy, minus increases in equipment purchase and installation costs, which is another way of representing consumer NPV); and (2) the annualized monetary value of the benefits of emission reductions, including CO
2
emission reductions.
9
9
DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. First, DOE calculated a present value in 2013, the present year used for discounting the NPV of total consumer costs and savings, for the time-series of costs and benefits using discount rates of three and seven percent for all costs and benefits except for the value of CO
2
reductions. For the latter, DOE used a range of discount rates, as shown in Table I.4. From the present value, DOE then calculated the fixed annual payment over a 30-year period (2019 through 2048) that yields the same present value. The fixed annual payment is the annualized value. Although DOE calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized values were determined is a steady stream of payments.
Estimates of annualized benefits and costs of the proposed standards are shown in Table I.4. The results under the primary estimate are as follows. (All monetary values below are expressed in 2012$.) Using a 7-percent discount rate for benefits and costs other than CO
2
reduction (for which DOE used a 3-percent discount rate along with the SCC series corresponding to a value of $40.8/ton in 2015), the cost of the residential furnace fan standards proposed in this rule is $231 million per year in increased equipment costs, while the benefits are $872 million per year in reduced equipment operating costs, $571 million in CO
2
reductions, and $8.24 million in reduced NO
X
emissions. In this case, the net benefit amounts to $1,220 million per year. Using a 3-percent discount rate for all benefits and costs and the SCC series corresponding to a value of $40.8/ton in 2015, the cost of the residential furnace fans standards proposed in this rule is $290 million per year in increased equipment costs, while the benefits are $1,585 million per year in reduced operating costs, $571 million in CO
2
reductions, and $15.56 million in reduced NO
X
emissions. In this case, the net benefit amounts to $1,882 million per year.
Table I.4—Annualized Benefits and Costs of Proposed Standards for Residential Furnace Fans (TSL 4), in Million 2012$
Discount rate
Primary estimate *
Low net benefits estimate
High net benefits estimate
million 2012$/year
Benefits:
Consumer Operating Cost Savings
7%
872
710
1082.
3%
1585
1264
2011.
CO
2
Reduction Monetized Value ($12.9/t case) **
5%
139
117
171.
CO
2
Reduction Monetized Value ($40.8/t case) **
3%
571
477
702.
CO
2
Reduction Monetized Value ($62.2/t case) **
2.5%
877
732
1079.
CO
2
Reduction Monetized Value ($117/t case) **
3%
1761
1471
2167.
NO
X
Reduction Monetized Value (at $2,639/ton) **
7%
8.24
6.97
9.99.
3%
15.56
13.03
19.09.
Total Benefits
†
7% plus CO
2
range
1,019 to 2,641
834 to 2,188
1,263 to 3,259.
7%
1,451
1,194
1,794.
3% plus CO
2
range
1,740 to 3,362
1,394 to 2,748
2,201 to 4,197.
3%
2,172
1,754
2,732.
Costs:
Consumer Incremental Installed Costs
7%
231
273
201.
3%
290
346
250.
Net Benefits:
Total
†
7% plus CO
2
range
788 to 2,410
561 to 1,915
1,062 to 3,058.
7%
1,220
921
1,593.
3% plus CO
2
range
1,450 to 3,072
1,047 to 2,402
1,951 to 3,947.
3%
1,882
1,407
2,482.
* This table presents the annualized costs and benefits associated with residential furnace fans shipped in 2019-2048. These results include benefits to consumers which accrue after 2048 from the products purchased in 2019-2048. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices and housing starts from the
AEO 2012
Reference case, Low Estimate, and High Estimate, respectively. Incremental product costs reflect a constant product price trend in the Primary Estimate, an increasing price trend in the Low Benefits Estimate, and a decreasing price trend in the High Benefits Estimate.
** The CO
2
values represent global values of the SCC, in 2012$, in 2015 under several scenarios. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC values increase over time. The value for NO
X
(in 2012$) is the average of the low and high values used in DOE's analysis.
†
Total Benefits for both the 3% and 7% cases are derived using the series corresponding to SCC value of $40.8/t in 2015. In the rows labeled “7% plus CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values.
DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. DOE further notes that products achieving these standard levels are already commercially available for at least some, if not most, product classes covered by this proposal. Based on the analyses described above, DOE has tentatively concluded that the benefits of the proposed standards to the Nation (energy savings, positive NPV of consumer benefits, consumer LCC savings, and emission reductions) would outweigh the burdens (loss of INPV for manufacturers and LCC increases for some consumers).
DOE also considered more-stringent energy efficiency levels as trial standard levels, and is still considering them in this rulemaking. However, DOE has tentatively concluded that the potential burdens of the more-stringent energy efficiency levels would outweigh the projected benefits. Based on consideration of the public comments DOE receives in response to this notice and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy efficiency levels presented in this notice that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority underlying this proposal, as well as some of the relevant historical background related to the establishment of standards for residential furnace fans.
A. Authority
Title III, Part B
10
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Public Law 94-163 (42 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 (collectively referred to as “covered products”).
11
These include products that use electricity for purposes of circulating air through duct work, hereafter referred to as “residential furnace fans” or simply “furnace fans,” the subject of this rulemaking. (42 U.S.C. 6295(f)(4)(D))
10
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.
11
All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act, Public Law 112-210 (enacted December 18, 2012).
Pursuant to EPCA, DOE's energy conservation program for covered products consists essentially of four parts: (1) Testing; (2) labeling; (3) the establishment of Federal energy conservation standards; and (4) certification and enforcement procedures. The Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE implements the remainder of the program. Subject to certain criteria and conditions, DOE is required by EPCA to consider and establish energy conservation standards for residential furnace fans by December 31, 2013. (42 U.S.C. 6295(f)(4)(D)) DOE is also required to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of each covered product prior to the adoption of an energy conservation standard. (42 U.S.C. 6295(o)(3)(A) and (r)) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these test procedures to determine whether the products comply with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) DOE does not currently have a test procedure for furnace fans. Accordingly, to fulfill the statutory requirements, DOE is simultaneously conducting a test procedure rulemaking for residential furnace fans. DOE published a notice of proposed rulemaking (NOPR) in the
Federal Register
for a residential furnace fans test procedure on May 15, 2012. 77 FR 28674. After considering public comments, DOE subsequently published in the
Federal Register
a supplemental notice of proposed rulemaking (SNOPR) on April 2, 2013, which contained a revised test procedure proposal for furnace fans. 78 FR 19606. In accordance with the statutory requirements outlined in EPCA, DOE will establish a test procedure for residential furnace fans at or before the time it prescribes furnace fan energy conservation standards Details on the furnace fan test procedure rulemaking are available at:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/40
.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including residential furnace fans. As indicated above, any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and (3)(B)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not prescribe a standard: (1) For certain products, including residential furnace fans, if no test procedure has been established for the product, or (2) if DOE determines by rule that the proposed standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, after receiving comments on the proposed standard, DOE must determine whether the benefits of the standard exceed its burdens by, to the greatest extent practicable, considering the following seven factors:
(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;
(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States of any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. (
See
42 U.S.C. 6295(o)(2)(B)(iii))
Additionally, under 42 U.S.C. 6295(q)(1), the statute specifies requirements when promulgating an energy conservation standard for a covered product that has two or more subcategories. DOE must specify a different standard level for a type or class of covered product that has the same function or intended use, if DOE determines that products within such group: (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)). In determining whether a performance-related feature justifies a different standard level, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements generally supersede State laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions set forth under 42 U.S.C. 6297(d)).
Finally, pursuant to the amendments contained in the Energy Independence and Security Act of 2007 (EISA 2007), Public Law 110-140, any final rule for new or amended energy conservation standards promulgated after July 1, 2010, is required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C.
6295(o)), incorporate standby mode and off mode energy use into a single standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) The proposed furnace fan energy rating metric would not account for the electrical energy consumption in standby mode and off mode, because energy consumption in those modes is already fully accounted for in the DOE energy conservation standards rulemaking for residential furnaces and residential central air conditioners (CAC) and heat pumps (HP). 76 FR 37408 (June 27, 2011); 76 FR 67037 (Oct. 31, 2011). Manufacturers will be required to use the new metrics and methods adopted in those rulemakings for the purposes of certifying to DOE that their products comply with the applicable energy conservation standards adopted pursuant to EPCA and for making representations about the efficiency of those products. (42 U.S.C. 6293(c); 42 U.S.C. 6295(s))
Background
1. Current Standards
Currently, no Federal energy conservation standards apply to residential furnace fans.
2. History of Standards Rulemaking for Residential Furnace Fans
Pursuant to 42 U.S.C. 6295(f)(4)(D), DOE must consider and prescribe new energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work. DOE has interpreted this statutory language to allow regulation of the electricity use of any electrically-powered device applied to residential central heating, ventilation, and air-conditioning (HVAC) systems for the purpose of circulating air through duct work.
DOE initiated the current rulemaking by issuing an analytical Framework Document, “Rulemaking Framework for Furnace Fans” (June 1, 2010). DOE then published the Notice of Public Meeting and Availability of the Framework Document for furnace fans in the
Federal Register
on June 3, 2010. 75 FR 31323. See
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/41.
The Framework Document explained the issues, analyses, and process that DOE anticipated using to develop energy conservation standards for residential furnace fans. DOE held a public meeting on June 18, 2010 to solicit comments from interested parties regarding DOE's analytical approach. DOE originally scheduled the comment period on the Framework Document to close on July 6, 2010, but due to the large number and broad scope of questions and issues raised, DOE subsequently published a notice in the
Federal Register
reopening the comment period from July 15, 2010 until July 27, 2010, to allow additional time for interested parties to submit comments. 75 FR 41102 (July 15, 2010).
As a concurrent effort to the residential furnace fan energy conservation standard rulemaking, DOE also initiated a test procedure rulemaking for residential furnace fans. On May 15, 2012, DOE published a notice of proposed rulemaking for the test procedure in the
Federal Register
. 77 FR 28674. In that NOPR, DOE proposed to establish methods to measure the performance of covered furnace fans and to obtain a value for the proposed metric, referred to as the “fan efficiency rating” (FER).
12
DOE held the test procedure NOPR public meeting on June 15, 2012, and the comment period closed on July 30, 2012. After receiving comments on the NOPR alleging significant manufacturer burden associated with the proposed test procedure, DOE determined that an alternative test method should be developed. DOE published in the
Federal Register
an SNOPR on April 2, 2013, which contained its revised test procedure proposal and an explanation of the changes intended to reduce burden. 78 FR 19606. DOE proposed to adopt a modified version of the alternative test method recommended by the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) and other furnace fan manufacturers to rate the electrical energy consumption of furnace fans. DOE has tentatively concluded that the AHRI-proposed method provides a framework for accurate and repeatable determinations of FER that is comparable to the test method previously proposed by DOE, but at a significantly reduced test burden. As required by EPCA, DOE will complete its final rule for residential furnace fan test procedures in advance of the final rule adopting energy conservation standards for those products. (42 U.S.C. 6295(o)(3)(A) and (r))
12
In the May 15, 2012 NOPR for the test procedure, DOE referred to FER as “fan efficiency rating.” However, in the April 2, 2013 test procedure SNOPR, DOE proposed to rename the metric as “fan energy rating,” thereby keeping the same abbreviation (FER).
To further develop the energy conservation standards for residential furnace fans, DOE gathered additional information and performed a preliminary technical analysis. This process culminated in publication in the
Federal Register
of a Notice of Public Meeting and the Availability of the Preliminary Technical Support Document (TSD) on July 10, 2012. 77 FR 40530. In that document, DOE requested comment on the following matters discussed in the TSD: (1) the selected product classes; (2) the analytical framework, models, and tools that DOE is using to evaluate standards; and (3) the results of the preliminary analyses performed by DOE.
Id.
DOE also invited written comments on these subjects, as well as any other relevant issues, and announced the availability of the TSD on its Web site.
Id.
at 40530-31. A PDF copy of the preliminary TSD is available at
http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0011-0037.
The preliminary TSD provided an overview of the activities DOE undertook in developing potential energy conservation standards for residential furnace fans, and discussed the comments DOE received in response to the Framework Document. It also described the analytical methodology that DOE used and each analysis DOE had performed up to that point. These analyses were as follows:
• A
market and technology assessment
addressed the scope of this rulemaking, identified the potential product classes of residential furnace fans, characterized the markets for these products, and reviewed techniques and approaches for improving their efficiency;
• A
screening analysis
reviewed technology options to improve the efficiency of furnace fans, and weighed these options against DOE's four prescribed screening criteria;
• An
engineering analysis
estimated the increase in manufacturer selling prices (MSPs) associated with more energy-efficient furnace fans;
• An
energy use analysis
estimated the annual energy use of furnace fans at various potential standard levels;
• A
markups analysis
converted estimated MSPs to consumer-installed prices.
• A
life-cycle cost (LCC) analysis
calculated, at the consumer level, the discounted savings in operating costs throughout the estimated average life of the product, compared to any increase in installed costs likely to result directly from the adoption of a given standard;
• A
payback period (PBP) analysis
estimated the amount of time it would take consumers to recover the higher expense of purchasing more-energy-efficient products through lower operating costs;
• A
shipments analysis
estimated shipments of residential furnace fans over the time period examined in the analysis (30 years), which were used in performing the national impact analysis;
• A
national impact analysis
assessed the aggregate impacts at the national level of potential energy conservation standards for residential furnace fans, as measured by the net present value of total consumer economic impacts and national energy savings; and
• A
preliminary manufacturer impact analysis
took the initial steps in evaluating the effects new energy conservation standards may have on furnace fan manufacturers.
The nature and function of the analyses in this rulemaking, including the engineering analysis, energy-use characterization, markups to determine installed prices, LCC and PBP analyses, and national impact analysis, are summarized in the July 2012 notice. 77 FR 40530, 40532-33 (July 10, 2012).
The preliminary analysis public meeting took place on July 27, 2012. At this meeting, DOE presented the methodologies and results of the analyses set forth in the preliminary TSD. The numerous comments received since publication of the July 2012 notice, including those received at the preliminary analysis public meeting, have contributed to DOE's proposed resolution of the issues noted by interested parties.
The submitted comments include a joint comment from the American Council for an Energy-Efficiency Economy (ACEEE), Adjuvant Consulting, on behalf of the Northwest Energy Efficiency Alliance (NEEA), the Appliance Standards Awareness Project (ASAP), the National Consumer Law Center (NCLC), and the Natural Resources Defense Council (NRDC); a comment from the Air-Conditioning, Heating, and Refrigeration Institute (AHRI); a second joint comment from California Investor-Owned Utilities (CA IOUs) including Pacific Gas and Electric Company (PG&E), Southern California Edison (SCE), Southern California Gas Company, and San Diego Gas and Electric (SDGE); a comment from Earthjustice; a comment from ebm-papst Inc. (ebm-papst); a comment from Edison Electric Institute (EEI); and a comment from the Northeast Energy Efficiency Partnership (NEEP). Manufacturers submitting written comments included: First Company, Goodman Global, Inc. (Goodman), Ingersoll Rand, Lennox International, Inc. (Lennox), Morrison Products, Inc. (Morrison), Mortex Product, Inc. (Mortex), National Motor Corporation (NMC), and Rheem Manufacturing Company (Rheem). Comments made during the public meeting by those not already listed include the U.S. Environmental Protection Agency (EPA), the motor manufacturer Regal Beloit, and Unico Incorporated. This NOPR summarizes and responds to the issues raised in these comments. A parenthetical reference at the end of a quotation or paraphrase provides the location of the item in the public record.
III. General Discussion
A. Test Procedure
In the SNOPR for the residential furnace fan test procedure published in the
Federal Register
on April 2, 2013 (78 FR 19606), DOE proposed to adopt a modified version of a test method recommended by AHRI and supported by other furnace fan manufacturers in the written comments on the May 2012 Test Procedure NOPR. (Docket No. EERE-2010-BT-TP-0010, AHRI, No. 16 at p. 3) DOE agrees with AHRI's assessment that its method provides a framework for accurate and repeatable determinations of FER that is comparable to the test method previously proposed by DOE, but at a significantly reduced test burden. In general, the test burden of the AHRI method is reduced relative to the test procedure originally proposed in the NOPR because it: (1) Does not require airflow to be measured directly; (2) avoids the need to make multiple determinations in each airflow-control setting because outlet restrictions to achieve the specified reference system external static pressure (ESP) would be set in the maximum airflow-control setting and maintained for measurements in subsequent airflow-control settings; and (3) can be conducted using the test setup currently required to rate furnace annual fuel utilization efficiency (AFUE) for compliance with residential furnace standards.
In the April 2, 2013 test procedure SNOPR, DOE proposed to incorporate by reference the definitions, test setup and equipment, and procedures for measuring steady-state combustion efficiency provisions of American National Standards Institute (ANSI)/American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) Standard 103-2007,
Method of Testing for Annual Fuel Utilization Efficiency of Residential Central Furnaces and Boilers
(ASHRAE Standard 103). In addition to these provisions, DOE proposed additional provisions for apparatuses and procedures for measuring throughput temperature, external static pressure, and furnace fan electrical input power. DOE also proposed calculations to derive FER based on the results of testing for each basic model. 78 FR 19606, 19608-09 (April 2, 2013).
In the SNOPR, DOE proposed to define “fan energy rating” (FER) as the estimated annual electrical energy consumption of the furnace fan normalized by: (a) the estimated total number of annual fan operating hours (1,870);
13
and (b) the airflow in the maximum airflow-control setting.
Id.
at 19608. The estimated annual electrical energy consumption, as proposed, is a weighted average of the furnace fan electrical input power (in Watts) measured separately for multiple airflow-control settings at different external static pressures (ESPs). These ESPs are determined by a reference system that represents national average duct work system characteristics.
Id.
Table III.1 below includes the proposed reference system ESP values by installation type.
13
Details about the derivation of operating hours used to calculate FER are found in the test procedure NOPR. 77 FR 28674, 28680 (May 15, 2012).
Table III.1—Proposed Reference System ESP Values by Furnace Fan Installation Type
Installation type
Weighted average ESP
(in. w.c.)
Units with an internal evaporator coil
0.50
Units designed to be paired with an evaporator coil
0.65
Units installed in a manufactured homes
14
0.30
The
proposed rated airflow-control settings correspond to operation in cooling mode (which DOE finds is predominantly associated with the maximum airflow-control setting), heating mode, and constant-circulation mode. Table III.2 illustrates the airflow-control settings that would be rated for various product types.
14
Manufactured home external static pressure is much lower than non-manufactured home installations because there is no return air duct work in manufactured homes. Also, the United States Department of Housing and Urban Development (HUD) requirements for manufactured homes stipulate that the duct work for cooling should be set at 0.3 in. w.c.
Table III.2—Proposed Rated Airflow-Control Settings by Product Type
Product type
Rated airflow-control setting 1
Rated airflow-control setting 2
Rated airflow-control setting 3
Single-stage Heating
Default constant-circulation
Default heat
Absolute maximum.
Multi-stage or Modulating Heating
Default constant-circulation
Default low heat
Absolute maximum.
As shown in Table III.2, for products with single-stage heating, the three proposed rated airflow-control settings are the default constant-circulation setting, the default heating setting, and the absolute maximum setting. 78 FR 19606, 19609 (April 2, 2013). For products with multi-stage heating or modulating heating, the proposed rated airflow-control settings are the default constant-circulation setting, the default low heating setting, and the absolute maximum setting. The absolute lowest default airflow-control setting is used to represent constant circulation if a default constant-circulation setting is not specified. DOE proposed to define “default airflow-control settings” as the airflow-control settings specified for installed use by the manufacturer in the product literature shipped with the product in which the furnace fan is integrated.
Id.
Manufacturers typically provide detailed instructions for setting the default heating airflow-control setting to ensure that the product in which the furnace fan is integrated operates safely. Manufacturer installation guides also provide detailed instructions regarding compatible thermostats and how to wire them to achieve the specified default settings.
In the SNOPR, DOE proposed to weight the Watt measurements using designated annual operating hours for each function (
i.e.,
cooling, heating, and constant circulation) that are intended to represent national average operation. Table III.3 shows the proposed estimated national average operating hours for each function to be used to calculate FER.
Table III.3—Estimated National Average Operating Hour Values for Calculating FER
Operating mode
Variable
Single-stage
(hours)
Multi-stage or
modulating
(hours)
Heating
HH (heating hours)
830
830/HCR (heat capacity ratio).
Cooling
CH (cooling hours)
640
640.
Constant Circulation
CCH (constant-circulation hours)
400
400.
Total
1,870
(830/HCR) + 1,040.
The specified operating hours for the heating mode for multi-stage heating or modulating heating products are divided by the heat capacity ratio (HCR) to account for variation in time spent in this mode associated with turndown of heating output. The HCR is the ratio of the reduced heat output capacity to maximum heat output capacity. The proposed FER equation is:
EP25OC13.000
Where:
CH = annual furnace fan cooling operating hours;
E
Max
= furnace fan electrical consumption at maximum airflow-control setting operating point;
HH = annual furnace fan heating operating hours;
E
Heat
= furnace fan electrical consumption at the default heating airflow-control setting operating point for units with single-stage heating or the default low-heating airflow control setting operating point for units with multi-stage heating;
CHH = annual furnace fan constant circulation hours;
E
Circ
= furnace fan electrical consumption at the default constant-circulation airflow-control setting operating point (or minimum airflow-control setting operating point if a default constant-circulation airflow-control setting is not specified);
Q
Max
= airflow at maximum airflow-control setting operating point; and
1000 = constant to put metric in terms of watts/1000cfm, which is consistent with industry practice.
The public meeting for the energy conservation standards preliminary analysis occurred only two months after the public meeting for the test procedure NOPR. At the time of the preliminary analysis meeting, the comment period for the test procedure NOPR was still open. Consequently, many of the written comments and oral comments made during the preliminary analysis public meeting focused on test procedure issues and echoed comments in the test procedure rulemaking proceeding. While these test procedure issues are germane to the regulation of residential furnace fans more broadly, they are beyond the scope of the present energy conservation standards rulemaking. Accordingly, DOE addressed these test procedure-related comments, with detailed responses, in the April 2, 2013 test procedure SNOPR. Any additional comments made during the preliminary analysis relating to the test procedure that were not discussed in the test procedure SNOPR (
i.e.,
did not result in changes to DOE's proposed test procedure) will be addressed in the test procedure final rule.
B. Product Classes and Scope of Coverage
Although the title of 42 U.S.C. 6295(f) refers to “furnaces and boilers,” DOE notes that 42 U.S.C. 6295(f)(4)(D) was written using notably broader language than the other provisions within the
same section. Specifically, that statutory provision directs DOE to “consider and prescribe energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work.” Such language could be interpreted as encompassing electrically-powered devices used in any residential HVAC product to circulate air through duct work, not just furnaces, and DOE has received numerous comments on both sides of this issue. At the present time, however, DOE is only proposing to cover those circulation fans that are used in furnaces and modular blowers. DOE is using the term “modular blower” to refer to HVAC products powered by single-phase electricity that comprise an encased circulation blower that is intended to be the principal air-circulation source for the living space of a residence. A modular blower is not contained within the same cabinet as a residential furnace, CAC, or heat pump. Instead, modular blowers are designed to be paired with separate residential HVAC products that provide heating and cooling, typically a separate CAC/HP coil-only unit. DOE finds that modular blowers and electric furnaces are very similar in design. In many cases, the only difference between a modular blower and electric furnace is the presence of an electric resistance heating kit. DOE is aware that some modular blower manufacturers offer electric resistance heating kits to be installed in their modular blower models so that the modular blowers can be converted to stand-alone electric furnaces. In addition, FER values for modular blowers can be easily calculated using the proposed test procedure. DOE proposes to address the furnace fans used in modular blowers in this rulemaking for these reasons. As a result of the extent of the current rulemaking, DOE is not addressing public comments that pertain to fans in other types of HVAC products.
When evaluating and establishing energy conservation standards, DOE divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justify a different standard. In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) For this rulemaking, DOE proposes to differentiate between product classes based on internal structure and application-specific design differences that impact furnace fan energy consumption. Details regarding how internal structure and application-specific design differences that impact furnace fan energy consumption are included in chapter 3 of the NOPR technical support document (TSD). DOE proposes the following product classes for this rulemaking.
• Non-Weatherized, Non-Condensing Gas Furnace Fan (NWG-NC)
• Non-Weatherized, Condensing Gas Furnace Fan (NWG-C)
• Weatherized Non-Condensing Gas Furnace Fan (WG-NC)
• Non-Weatherized, Non-Condensing Oil Furnace Fan (NWO-NC)
• Non-Weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB)
• Manufactured Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC)
• Manufactured Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)
• Manufactured Home Electric Furnace/Modular Blower Fan (MH-EF/MB)
• Manufactured Home Weatherized Gas Furnace Fan (MH-WG)
• Manufactured Home Non-Weatherized Oil Furnace Fan (MH-NWO).
Each product class title includes descriptors that indicate the application-specific design and internal structure of its included products. “Weatherized” and “non-weatherized” are descriptors that indicate whether the HVAC product is installed outdoors or indoors, respectively. Weatherized products also include an internal evaporator coil, while non-weatherized products are not shipped with an evaporator coil but may be designed to be paired with one. “Condensing” refers to the presence of a secondary, condensing heat exchanger in addition to the primary combustion heat exchanger in certain furnaces. The presence of an evaporator coil or secondary heat exchanger significantly impacts the internal structure of an HVAC product, and in turn, the energy performance of the furnace fan integrated in that HVAC product. “Manufactured home” products meet certain design requirements that allow them to be installed in manufactured homes (
e.g.,
a more compact cabinet size). Descriptors for “gas,” “oil,” or “electric” indicate the type of fuel that the HVAC product uses to produce heat, which determines the type and geometry of the primary heat exchanger used in the HVAC product.
C. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially-available products or in working prototypes to be technologically feasible. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i).
After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) Practicability to manufacture, install, and service; (2) adverse impacts on product utility or availability; and (3) adverse impacts on health or safety. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)-(iv). Additionally, it is DOE policy not to include in its analysis any proprietary technology that is a unique pathway to achieving a certain efficiency level. Section IV.B of this notice discusses the results of the screening analysis for residential furnace fans, particularly the designs DOE considered, those it screened out, and those that are the basis for the trial standard levels (TSLs) in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a new standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for residential furnace fans, using the design parameters for the most-efficient products available on the market or in working prototypes. The max-tech levels that DOE determined for this rulemaking are described in
section IV.C of this proposed rule and in chapter 5 of the NOPR TSD.
D. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that are the subject of this rulemaking purchased in the 30-year period that begins in the anticipated year of compliance with new standards (2019-2048). These savings are measured over the entire lifetime of products purchased in the 30-year analysis period.
15
DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the base case. The base case represents a projection of energy consumption in the absence of mandatory energy conservation standards, and it considers market forces and policies that affect demand for more-efficient products.
15
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.
DOE used its national impact analysis (NIA) spreadsheet model to estimate energy savings from potential standards for the products that are the subject of this rulemaking. The NIA spreadsheet model (described in section IV.H of this notice) calculates energy savings in site energy, which is the energy directly consumed by products at the locations where they are used. DOE reports national energy savings on an annual basis in terms of the primary (source) energy savings, which is the savings in the energy that is used to generate and transmit the site energy. To convert site energy to primary energy, DOE derived annual conversion factors from the model used to prepare the Energy Information Administration's (EIA's)
Annual Energy Outlook 2012
(
AEO 2012
).
DOE has begun to also estimate energy savings using full-fuel-cycle metrics. 76 FR 51282 (Aug. 18, 2011), as amended at 77 FR 49701 (August 17, 2012). The full-fuel-cycle (FFC) metric includes the energy consumed in extracting, processing, and transporting primary fuels (i.e., coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of efficiency standards. DOE's approach is based on calculation of an FFC multiplier for each of the primary fuels used by covered products and equipment. For more information on FFC energy savings, see section IV.H.1.
2. Significance of Savings
As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting a standard for a covered product unless such standard would result in “significant” energy savings. Although the term “significant” is not defined in the Act, the U.S. Court of Appeals for the District of Columbia Circuit, in
Natural Resources Defense Council
v.
Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), opined that Congress intended “significant” energy savings in this context to be savings that were not “genuinely trivial.” The energy savings for all of the TSLs considered in this rulemaking are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.
E. Economic Justification
1. Specific Criteria
As discussed above, EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential new or amended standard on manufacturers, DOE conducts a manufacturer impact analysis (MIA), as discussed in section IV.J. DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include: (1) Industry net present value (INPV), which values the industry on the basis of expected future cash flows; (2) cash flows by year; (3) changes in revenue and income; and (4) other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment, as discussed in section IV.N. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the changes in life-cycle cost (LCC) and payback period (PBP) associated with new or amended standards. The LCC, which is specified separately in EPCA as one of the seven factors to be considered in determining the economic justification for a new or amended standard, 42 U.S.C. 6295(o)(2)(B)(i)(II), is discussed in the following section. For consumers in the aggregate, DOE also calculates the national net present value of the economic impacts applicable to a particular rulemaking.
b. Life-Cycle Costs
The LCC is the sum of the purchase price of a product (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. The LCC savings for the considered efficiency levels are calculated relative to a base case that reflects projected market trends in the absence of standards. The LCC analysis requires a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and consumer discount rates. For its analysis, DOE assumes that consumers will purchase the considered products in the first year of compliance with new standards.
To account for uncertainty and variability in specific inputs, such as product lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value. DOE identifies the percentage of consumers estimated to receive LCC savings or experience an LCC increase, in addition to the average LCC savings associated with a particular standard level. DOE also evaluates the LCC impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a national standard. DOE's LCC analysis is discussed in further detail in section IV.F.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section IV.H, DOE uses
the NIA spreadsheet to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing classes of products, and in evaluating design options and the impact of potential standard levels, DOE evaluates potential standards that would not lessen the utility or performance of the considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) The standards proposed in this notice will not reduce the utility or performance of the products under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider any lessening of competition that is likely to result from standards. It also directs the Attorney General of the United States (Attorney General) to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (ii)) DOE will transmit a copy of this proposed rule to the Attorney General with a request that the Department of Justice (DOJ) provide its determination on this issue. DOE will publish and respond to the Attorney General's determination in the final rule.
f. Need for National Energy Conservation
In evaluating the need for national energy conservation, DOE notes that the energy savings from the proposed standards are likely to provide improvements to the security and reliability of the nation's energy system. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the nation's needed power generation capacity, as discussed in section IV.M.
The proposed standards also are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases associated with energy production. DOE reports the emissions impacts from each TSL it considered in section IV.K of this notice. DOE also reports estimates of the economic value of emissions reductions resulting from the considered TSLs, as discussed in section IV.L.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a standard is economically justified, to consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent interested parties submit any relevant information regarding economic justification that does not fit into the other categories described above, DOE could consider such information under “other factors.”
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analysis generates values used to determine which of the considered standard levels meet the three-year payback period contemplated under the rebuttable presumption test. The rebuttable presumption payback calculation is discussed in section V.B.1 of this notice. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the Nation, and the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification).
IV. Methodology and Discussion
This section addresses the analyses DOE has performed for this rulemaking with regard to residential furnace fans. After a brief discussion of the spreadsheet tools and models used, separate subsections will address each component of DOE's analysis.
DOE used three spreadsheet tools to estimate the impact of this proposed standards. The first spreadsheet calculates LCCs and payback periods of potential standards. The second provides shipments forecasts, and then calculates national energy savings and net present value impacts of potential standards. Finally, DOE assessed manufacturer impacts, largely through use of the Government Regulatory Impact Model (GRIM). All three spreadsheet tools are available online at the rulemaking portion of DOE's Web site:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/41
.
Additionally, DOE estimated the impacts on utilities and the environment that would be likely to result from potential standards for residential furnace fans. DOE used a version of EIA's National Energy Modeling System (NEMS) for the utility and environmental analyses.
16
The NEMS simulates the energy sector of the U.S. economy. EIA uses NEMS to prepare its
Annual Energy Outlook,
a widely-known energy forecast for the United States. NEMS offers a sophisticated picture of the effect of standards because it accounts for the interactions between the various energy supply and demand sectors and the economy as a whole.
16
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(2003) (March, 2003).
A. Market and Technology Assessment
DOE develops information that provides an overall picture of the market for the products concerned, including the purpose of the products, the industry structure, manufacturers, market characteristics, and technologies used in the products. This activity includes both quantitative and qualitative assessments, based primarily on publicly-available information. The subjects addressed in the market and technology assessment for this residential furnace fans rulemaking include: (1) A determination of the scope of this rulemaking; (2) product classes and manufacturers; (3) quantities and types of products sold and offered for sale; (4) retail market trends; (5) regulatory and non-regulatory programs; and (6) technologies or design options that could improve the energy efficiency of the product(s) under examination. The key findings of DOE's market assessment are summarized below. See chapter 3 of the NOPR TSD for further discussion of the market and technology assessment.
1. Definition and Scope of Coverage
EPCA provides DOE with the authority to consider and prescribe new energy conservation standards for electricity used to circulate air through duct work. (42 U.S.C. 6295(f)(4)(D)) In the preliminary analysis, DOE defined a “furnace fan” as “any electrically-powered device used in residential, central heating, ventilation, and air-conditioning (HVAC) systems for the purpose of circulating air through duct
work.” 77 FR 40530, 40532 (July 10, 2012). DOE considered a typical furnace fan as consisting of a fan motor and its controls, an impeller, and a housing, all of which are components of an HVAC product that includes additional components, including the cabinet.
Interested parties disagreed with DOE's approach to set component-level regulations, which they warned would ignore system effects that could impact both fan and system energy consumption. CA IOUs suggested that “furnace fan” be defined as a unit consisting of a fan motor, its controls, an impeller, shroud, and cabinet that houses all of the heat exchange material for the furnace. According to CA IOUs, their suggested definition would reduce ambiguity and ensure that the components in HVAC products that affect furnace fan energy consumption are considered in this rulemaking. (CA IOUs, No. 56 at p. 1) Ingersoll Rand went further and suggested a system-level regulatory approach, where the entire duct and furnace system would be regulated, maintaining that such approach would produce a more useful metric to consumers when evaluating performance. (Ingersoll Rand, No. 43 at p. 42) Conversely, NEEP observed that by regulating fan energy use separately, the individual efficiency of the component is considered when it would otherwise be ignored by manufacturers. (NEEP, No. 51 at p. 3) Rheem commented that some designs require higher air velocity to improve heat transfer but also require more electrical consumption to drive the blower at the higher velocity. (Rheem, No. 43 at p. 63) Rheem commented that turbulent flow is considerably more efficient for heat transfer than laminar flow, but more energy is required to move turbulent air. (Rheem, No. 54 at p. 10) Similarly, Lennox and Morrison commented that in order to improve heating and cooling efficiency, often a second heating coil is added, but this also leads to higher electrical consumption by the furnace fan. (Lennox, No. 43 at p. 64; Morrison, No. 43 at p. 64) Ingersoll Rand argued that as the efficiency of the furnace fan motor increases, it dissipates less heat and a furnace consumes more gas to compensate and meet house heat load. (Ingersoll Rand, No. 43 at p. 66)
In response, DOE is required by EPCA to consider and prescribe new energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work. (42 U.S.C. 6295(f)(4)(D)) Pursuant to this statutory mandate, DOE plans to establish energy conservation standards for circulation fans used in residential central HVAC systems. DOE does not interpret its authority as including the duct work itself. DOE is aware that component-level regulations could have system-level impacts. Accordingly, DOE plans to conduct its analyses and set standards in such a way that meets the statutory requirements set forth by EPCA without ignoring system effects, which otherwise might compromise the thermal performance of the HVAC products that incorporate furnace fans. For example, the proposed test procedure outlined in the April 2, 2013 SNOPR specifies that the furnace fan be tested as factory-installed in the HVAC product, thereby enabling the rating metric to account for system effects on airflow delivery and, ultimately, energy performance. 78 FR 19606, 19612-13. In addition, the product class structure allows for differentiation of products with designs that achieve higher thermal efficiency but may have lower fan performance, such as condensing furnaces.
The scope of the preliminary analysis included furnace fans used in furnaces, modular blowers, and hydronic air handlers. Even though DOE has interpreted its authority as encompassing any electrically-powered device used in residential HVAC products to circulate air through duct work, the preliminary analysis scope excluded single package central air conditioners (CAC) and heat pumps (HP) and split-system CAC/HP blower-coil units. At the time of the preliminary analysis, DOE determined that it may consider these and other such products in a future rulemaking as data and information to develop credible analyses becomes available.
Efficiency advocates expressed concern at the exclusion of packaged and split-system CAC products because they believe current standards for these products do not maximize the technologically feasible and economically justified energy savings for the circulation fans integrated in these products. ASAP and Adjuvant stated that the metric used for CAC products does not accurately represent field conditions and requested that they be added to the scope. (ASAP, No. 43 at p. 17; Adjuvant, No. 43 at p. 39) Specifically, efficiency advocates found that the reference external static pressures (ESPs) used to determine the seasonal energy efficiency ratio (SEER) and heating seasonal performance factor (HSPF), which already rate these products, did not reflect field-installed conditions. (ASAP, No. 43 at p. 38; Earthjustice, No. 49 at p. 1) In a joint comment from ACEEE, ASAP, NCLC, NEEA, and NRDC (hereafter referred to as ACEEE,
et al.
), in addition to a comment from CA IOU, efficiency advocates and utilities stated that the reference ESP of 0.1-0.2 in. w.c. was too low when compared to the average field ESP of 0.73 in. w.c. identified in the TSD. (ACEEE,
et al.,
No. 55 at p. 1; CA IOU, No. 56 at p. 2) ACEEE,
et al.
also noted that SEER and HSPF do not account for continuous-circulation operation which is expected to increase as stricter building codes call for tighter building envelopes. (ACEEE,
et al.,
No. 55 at p. 2; CA IOU, No. 56 at p. 3) NEEP commented that SEER and HSPF do not reward for any efficiency gains made by the furnace fan. (NEEP, No. 51 at p. 3) By excluding these products from the analysis, ACEEE,
et al.
argued that DOE is ignoring a significant fraction of the furnace fan market. (ACEEE,
et al.,
No. 55 at p. 1)
In contrast, many manufacturers believe that the scope of coverage presented in the preliminary analysis exceeds the statutory authority granted to DOE because the statutory language for this rulemaking is found in 42 U.S.C 6295(f) under the title “Standards for furnaces and boilers.” Consequently, manufacturers stated that DOE should not include any non-furnace products such as central air conditioners, heat pumps, or condensing unit-blower-coil combinations. Lennox, Mortex, and First Co. explicitly stated that no equipment other than residential furnaces and boilers should be included, as doing so is beyond DOE's statutory authority. (Lennox, No. 47 at p. 4; Mortex, No. 59 at p. 1; First Co., No. 53 at p. 1) Mortex further stated that the electricity used to circulate air through duct work is already adequately accounted for in existing energy efficiency metrics, and that if DOE insists on proceeding on new energy conservation standards for furnace fans, DOE should limit it to residential warm air furnaces until there is a change made by Congress to include additional products. (Mortex, No. 59 at p. 1) Goodman and Ingersoll Rand argued that packaged equipment and air handlers should not be included in the scope because the electrical energy consumed by these products to circulate air through duct work is already accounted for in SEER and HSPF. (Goodman, No. 50 at p. 7; Ingersoll Rand, No. 57 at pp. A-1) Rheem and Morrison recommended that hydronic air handlers and modular blowers be excluded from the scope because these products have not been previously covered by an energy conservation standard and cannot be defined as furnaces. (Morrison, No. 43 at p. 94;
Morrison, No. 58 at p. 9; Rheem, No. 54 at p. 2)
Manufacturers also argued that the electricity used to circulate air through duct work for warm air furnaces with cooling capabilities is already covered by SEER. (Goodman, No. 50 at p. 7; Mortex, No. 59 at p. 1) Additionally, for a residential warm air furnace, Mortex stated that E
ae
already accounts for heating-mode-related energy consumption, including energy consumed by the fan. (Mortex, No. 59 at p. 2) Additionally, by including annual furnace fan cooling and heating electricity consumption in the FER metric, central air conditioner and heat pumps products will be covered by multiple metrics. (Goodman, No. 50 at p. 6; Mortex, No. 59 at p. 2)
As discussed in the furnace fan test procedure April 2, 2013 SNOPR, DOE notes that, although the title of this statutory section refers to “furnaces and boilers,” the applicable provision at 42 U.S.C. 6295(f)(4)(D) was written using notably broader language than the other provisions within the same section. 78 FR 19606, 19611. Specifically, that statutory provision directs DOE to “consider and prescribe energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work.” Such language could be interpreted as encompassing electrically-powered devices used in any residential HVAC product to circulate air through duct work, not just furnaces, and DOE has received numerous comments on both sides of this issue. At the present time, however, DOE is only proposing energy conservation standards for those circulation fans that are used in residential furnaces and modular blowers (see discussion below). As a result, DOE is not addressing public comments that pertain to fans in other types of HVAC products. The following list describes the furnace fans which DOE proposes to address in this rulemaking.
•
Products addressed in this rulemaking:
furnace fans used in weatherized and non-weatherized gas furnaces, oil furnaces, electric furnaces, and modular blowers.
•
Products not addressed in this rulemaking:
furnace fans used in other products, such as split-system CAC and heat pump air handlers, through-the-wall air handlers, small-duct, high-velocity (SDHV) air handlers, energy recovery ventilators (ERVs), heat recovery ventilators (HRVs), draft inducer fans, exhaust fans, or hydronic air handlers.
DOE is using the term “modular blower” to refer to HVAC products powered by single-phase electricity that comprise an encased circulation blower that is intended to be the principal air circulation source for the living space of a residence. A modular blower is not contained within the same cabinet as a residential furnace, CAC, or heat pump. Instead, modular blowers are designed to be paired with separate residential HVAC products that provide heating and cooling, typically a separate CAC/HP coil-only unit. DOE finds that modular blowers and electric furnaces are very similar in design. In many cases, the only difference between a modular blower and electric furnace is the presence of an electric resistance heating kit. DOE is aware that some modular blower manufacturers offer electric resistance heating kits to be installed in their modular blower models so that the modular blowers can be converted to stand-alone electric furnaces. In addition, FER values for modular blowers can be easily calculated using the proposed test procedure. DOE proposes to address the furnace fans used in modular blowers in this rulemaking for these reasons.
After considering available information and public comments regarding fan operation in cooling mode, DOE maintains its proposal to account for the electrical consumption of furnace fans while performing all active mode functions (
i.e.,
heating, cooling, and constant circulation). DOE recognizes that furnace fans are used not just for circulating air through duct work during heating operation, but also for circulating air during cooling and constant-circulation operation. DOE anticipates that higher airflow-control settings are factory set for cooling operation. Therefore, DOE expects that the electrical energy consumption of a furnace fan is generally higher while performing the cooling function. Additionally, the design of the fan as well as its typical operating characteristics (
i.e.,
ESP levels during operation in different modes) is directly related to the performance requirements in cooling mode. DOE is also concerned that excluding some functions from consideration in rating furnace fan performance would incentivize manufacturers to design fans that are optimized to perform efficiently at the selected rating airflow-control settings but that are not efficient over the broad range of field operating conditions. In DOE's view, in order to obtain a complete assessment of overall performance and a metric that reflects the product's electrical energy consumption during a representative average use cycle, the metric must account for electrical consumption in a set of airflow-control settings that spans all active mode functions. This would ensure a more accurate accounting of the benefits of improved furnace fans.
DOE is aware that fan electrical consumption is accounted for in the SEER and HSPF metrics that DOE uses for CAC and heat pump products. However, DOE does not agree with manufacturers' comments suggesting that the electricity used to circulate air through duct work is already adequately accounted for in existing energy efficiency metrics of other covered products, particularly the SEER and HSPF metrics of CAC/HP. This is because SEER and HSPF are used to test cooling and heating performance of a CAC or heat pump product, whereas FER rates airflow performance of a furnace fan product. While furnace fan airflow performance contributes to cooling and heating performance, manufacturers can improve SEER and HSPF without improving fan performance. In short, SEER and HSPF-based standards do not directly regulate the efficiency of furnace fans, as required by 42 U.S.C. 6295(f)(4)(D). DOE recognizes that the energy savings in cooling mode from higher-efficiency furnace fans used in some higher-efficiency CAC and heat pumps is already accounted for in the analysis of energy conservation standards for those products. As a result, DOE conducted its analysis in this current rulemaking in such a way as to avoid double-counting these benefits by excluding furnace fan electricity savings that were already included in DOE's analyses for CAC and heat pump products. Chapter 7 of the NOPR TSD provides a more detailed discussion of this issue.
2. Product Classes
DOE identified nine key product classes in the preliminary analysis, each of which was assigned its own candidate energy conservation standard and baseline FER. DOE identified twelve additional product classes that represent significantly fewer shipments and significantly less overall energy use. DOE grouped each non-key product class with a key product class to which it is closely related in application-specific design and internal structure (
i.e.,
the primary criteria used to differentiate between product classes). DOE assigned the analytical results of each key product class to the non-key product classes with which it is grouped because DOE expected the energy use and incremental manufacturer production costs (MPCs) of improving
efficiency to be similar within each grouping. Table IV.1 lists the 21 preliminary analysis product classes.
Table IV.1—Preliminary Analysis Product Classes
Key product class
Additional product classes
Non-Weatherized, Non-Condensing Gas Furnace Fan (NWG-NC).
Non-weatherized, Condensing Gas Furnace Fan (NWG-C).
Weatherized Non-Condensing Gas Furnace Fan (WG-NC)
Weatherized, Non-Condensing Oil Furnace Fan (WO-NC).
Weatherized Electric Furnace/Modular Blower Fan (WEF/WMB).
Manufactured Home Weatherized Gas Furnace Fan (MH-WG).
Manufactured Home Weatherized Oil Furnace Fan (MH-WO).
Manufactured Home Weatherized Electric Furnace/Modular Blower Fan (MH-WEF/WMB).
Non-weatherized, Non-Condensing Oil Furnace Fan (NWO-NC)
Non-Weatherized, Condensing Oil Furnace Fan (NWO-C).
Manufactured Home Non-Weatherized Oil Furnace Fan (MH-NWO).
Non-weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB)
Heat/Cool Hydronic Air Handler Fan (HAH-HC)
Heat-Only Hydronic Air Handler Fan (HAH-H).
Hydronic Air Handler Fan with Coil (HAH-C).
Manufactured Home Heat/Cool Hydronic Air Handler Fan (MH-HAH-HC).
Manufactured Home Heat-Only Hydronic Air Handler Fan (MH-HAH-H).
Manufactured Home Hydronic Air Handler Fan with Coil (MH-HAH-C).
Manufactured Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC)
Manufactured Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)
Manufactured Home Electric Furnace/Modular Blower Fan (MH-EF/MB)
Goodman and Rheem agreed that the selected key product classes are an accurate representation of the market, with Rheem commenting that it manufactures six of the nine proposed key product classes. (Goodman, No. 50 at p. 1; Rheem, No. 54 at p. 4) NEEP found that the proposed key product class structure appropriately allows for differentiation of products with higher thermal efficiency. (NEEP, No. 51 at p. 2) Goodman, Rheem, and Ingersoll Rand disagreed with DOE's approach to specify additional product classes within a key product class, stating that shipment data indicates that the additional product classes are too small to be covered. (Goodman, No. 50 at p. 1; Ingersoll Rand, No. 57 at pp. A-1; Rheem, No. 54 at p. 4)
Mortex expressed concern that the key product classes only represent furnace fan products with the most shipments and, if the energy conservation standards are set inappropriately high for these key product classes, the additional products classes (some of which serve unique applications) may also have trouble meeting any scaled standards levels based thereon. (Mortex, No. 43 at p. 53)
DOE agrees with Goodman, Rheem, and Ingersoll Rand that the additional product classes represent products with few and in many cases, no shipments. Individual discussions with manufacturers for the MIA confirm DOE's assumption. Additionally, review of the AHRI appliance directory reveals that only two of the additional product classes have active models listed: (1) Manufactured home weatherized gas furnace fans (MH-WG) and (2) manufactured home non-weatherized oil furnace fans (MH-NWO). The number of active basic models for MH-WG and MH-NWO are 4 and 16, respectively. For this reason, DOE proposes to eliminate the additional product classes except for MH-WG and MH-NWO. Due to the limited number of basic models for MH-WG and MH-NWO, DOE did not have data to directly analyze and establish standards for these additional product classes. As a result, DOE proposes to reserve space to establish standards for MH-WG and MH-NWO furnace fans in the future as sufficient data become available.
As discussed previously in section IV.A.1, DOE proposes to also exclude hydronic air handlers from consideration in this rulemaking, thereby further reducing the number of product classes addressed by this rulemaking to eight. Table IV.2 includes a list of the revised set of product classes for residential furnace fans.
Table IV.2—Proposed Product Classes for Residential Furnace Fans
Product class
Non-Weatherized, Non-Condensing Gas Furnace Fan (NWG-NC).
Non-Weatherized, Condensing Gas Furnace Fan (NWG-C).
Weatherized Non-Condensing Gas Furnace Fan (WG-NC).
Non-Weatherized, Non-Condensing Oil Furnace Fan (NWO-NC).
Non-Weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB).
Manufactured Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC).
Manufactured Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C).
Manufactured Home Electric Furnace/Modular Blower Fan (MH-EF/MB).
Manufactured Home Weatherized Gas Furnace Fan (MH-WG).
Manufactured Home Non-Weatherized Oil Furnace Fan (MH-NWO).
3. Technology Options
In the preliminary analysis, DOE considered seven technology options that would be expected to improve the efficiency of furnace fans: (1) Fan housing and airflow path design modifications; (2) high-efficiency fan motors (in some cases paired with multi-stage or modulating heating controls); (3) inverter-driven permanent-split capacitor (PSC) fan motors; (4) backward-inclined impellers; (5) constant-airflow brushless permanent magnet (BPM) motor control relays; (6) toroidal transformers; and (7) switching mode power supplies. Since that time, DOE notes that its proposed scope of coverage no longer includes hydronic air handlers, the only furnace fan product class for which standby mode and off mode energy consumption is not accounted for in a separate DOE rulemaking. Consequently, the standby mode and off mode technology options (options 5 through 7 in the list above) are no longer applicable, because energy consumption in those modes is already fully accounted for in the DOE energy conservation standards rulemaking for residential furnaces and residential CAC and HP for the remaining proposed product classes. 76 FR 37408 (June 27, 2011); 76 FR 67037 (Oct. 31, 2011). In addition, DOE found that multi-staging and modulating heating controls can also improve FER, so hence DOE evaluated multi-staging and modulating heating controls as a separate technology option for the NOPR. Thus, the resultant list of potential technology options identified for the NOPR include: (1) Fan housing and airflow path design modifications; (2) inverter-driven PSC fan motors; (3) high-efficiency fan motors; (4) multi-staging and modulating heating controls; and (5) backward-inclined impellers. Each identified technology option is discussed below and in more detail in chapter 3 of the NOPR TSD.
a. Fan Housing and Airflow Path Design Improvements
The preliminary analysis identified fan housing and airflow path design modifications as potential technology options for improving the energy efficiency of furnace fans. Optimizing the shape of the inlet cone
17
of the fan housing, minimizing gaps between the impeller and fan housing inlet, and optimizing cut-off location and manufacturing tolerances were identified as enhancements to a fan housing that could improve efficiency. Separately, modification of elements in the airflow path, such as the heat exchanger, could reduce internal static pressure and as a result, reduce energy consumption. Manufacturer input was requested to determine the use and practicability of these potential technology options.
17
The inlet cone is the opening of the furnace fan housing through which return air enters the housing. The inlet cone is typically curved inward, forming a cone-like shape around the perimeter of the opening, to provide a smooth surface to direct air from outside the housing to inside the housing and into the impeller.
ASAP expressed support for DOE's consideration of the aerodynamics of furnace fan cabinets in its initial analysis of technology options. (ASAP, No. 43 at p. 16) In particular, ASAP cited a 2003 GE study
18
that quantified energy savings produced by modifying fan housing as justification for its inclusion as an option. (ASAP, No. 43 at p. 71) ACEEE,
et al.
also cited a Lawrence Berkeley National Laboratory (LBNL) study
19
that linked changes in efficiency to modifying the clearance between fan housing and an air handler cabinet wall. (ACEEE,
et al.,
No. 55 at p. 2) According to Ingersoll Rand, there are proprietary fan housing designs on the market that already improve mechanical efficiency by 10-20 percent at a cost much lower than the cost to implement high-efficiency motors or make changes to the impeller and its tolerances. (Ingersoll Rand, No. 57 at pp. A-3)
18
Wiegman, Herman, Final Report for the Variable Speed Integrated Intelligent HVAC Blower (2003) (Available at:
http://www.osti.gov/bridge/servlets/purl/835010-GyvYDi/native/835010.pdf
).
19
Walker, I.S, State-of-the-art in Residential and Small Commercial Air Handler Performance (2005) LBNL 57330 (Available at:
http://epb.lbl.gov/publications/pdf/lbnl-57330plus.pdf
).
DOE is aware of the studies cited by ASAP and ACEEE, as well as the proprietary housing design mentioned by Ingersoll Rand. For the NOPR, DOE decided to include fan housing design modifications as a technology to be evaluated further in the screening analysis because of these indications that each could improve fan efficiency.
Many interested parties requested that DOE keep airflow path design as a technology option. (Unico, No. 43 at p. 72; EPA, No. 43 at p. 76; ASAP, No. 43 at p. 77; CA IOU, No. 56 at p. 3; ACEEE,
et al.,
No. 55 at p. 2) Manufacturers stated that improving airflow path design, like modifying fan housing, is highly cost-effective when compared to other enhancements. (Rheem, No. 43 at p. 74; Lennox, No. 43 at p. 74; Adjuvant, No. 43 at p. 74) Lennox noted a 10-20 percent improvement in efficiency could be achieved by changing the airflow path when evaluated against a baseline design coupled with a PSC motor. (Lennox, No. 47 at p. 9; Morrison, No. 58 at p. 5) However, the EPA questioned whether considering modified airflow path as a technology option was appropriate when DOE plans to only regulate the fan itself and not the entire air handler. (EPA, No. 43 at p. 62)
While Morrison agreed that airflow path and fan housing design affect performance and efficiency, it argued that establishing a baseline design (over which to determine improvement) might be difficult because parameters used to select an individual manufacturer's design may have taken into account considerations outside the scope of the furnace fan rulemaking. (Morrison, No. 43 at p. 75) Rheem suggested that AHRI should present airflow path and fan housing design data to the DOE in order to help establish the two technology options. (Rheem, No. 43 at p. 79)
Similar to the fan housing design modifications, DOE decided to include airflow path design as a technology option to be evaluated further in the screening analysis as a result of these claims of potential fan efficiency improvement. In response to the comment received from the EPA, DOE believes including airflow path design is appropriate because of its potential to impact fan efficiency. Airflow path design will impact the proposed rating metric, FER, because DOE is proposing to test the furnace fan as it is factory installed in the HVAC product. As discussed previously in section IV.A.1, DOE has conducted its NOPR analyses in such a way as to meet the statutory requirements set forth by EPCA without ignoring system effects. Chapter 3 of the NOPR TSD provides more technical detail regarding fan housing and airflow path design modifications and how these measures could reduce furnace fan energy consumption.
b. Inverter Controls for PSC Motors
In the preliminary analysis, DOE identified inverter-driven PSC motors as a technology option. DOE is aware of a series of non-weatherized gas furnaces with inverter-driven PSC furnace fan motors that was once commercially available. DOE has determined that inverter controls provide efficiency improvement by offering additional intermediate airflow-control settings and a wider range of airflow-control settings (
i.e.,
lower turndown ratio) than conventional PSC controls. The additional airflow-control settings and range enable the furnace fan to better match demand. Publically-available performance data for the series of furnaces using inverter-driven PSCs demonstrate that the use of this technology results in reduced FER
values compared to baseline PSC furnace fans. Consequently, DOE considered inverter-driven PSCs as a technologically feasible option for reducing furnace fan energy consumption.
Manufacturers were opposed to listing inverter-driven PSCs as a viable technology option. Goodman commented that there are alternate, more cost-effective solutions to reduce energy consumption for air-moving systems, such as airflow path design. (Goodman, No. 50 at p. 2) Ingersoll Rand and Morrison commented that the small energy savings provided by inverter-driven PSCs are not worth the added cost and complexity when ECM (referred to herein by DOE as a “constant-airflow BPM motor”) technology is available at a comparable cost and greater efficiency. (Ingersoll Rand, No. 57 at pp. A-1; Morrison, No. 58 at p. 2; Rheem, No. 54 at p. 6) Morrison suggested that the motor industry was seeking lower-cost alternatives to ECM motors, such as fractional horsepower switched reluctance motors or inverter-driven PSCs, but that no low-cost alternative currently exists. (Morrison, No. 58 at p. 2) NMC, a motor manufacturer, went further, stating that inverter-driven PSC motors using wave chopper controls are not typically more efficient than multi-tap PSC motors and that they are not a practical alternative to brushless permanent magnet technology. (NMC, No. 60 at p. 2)
DOE recognizes manufacturers' concerns with the cost-effectiveness of inverter-driven PSC fan motors. However, DOE decided to include inverter-driven PSC motors as a technology option to be evaluated further in the screening analysis due to their potential to reduce furnace fan energy consumption. DOE evaluates in the engineering analysis the cost-effectiveness of all energy-saving technology options that are not screened out. Chapter 3 of the NOPR TSD provides a more detailed discussion of inverter-driven PSC furnace fan motors.
c. High-Efficiency Motors
In the preliminary analysis, DOE identified four motor types that are typically used in furnace fan assemblies: (1) PSC motors; (2) PSC motors that have more than 3 airflow-control settings and sometimes improved materials (hereinafter referred to as “improved PSC” motors); (3) constant-torque BPM motors (often referred to as “X13 motors”); and (4) constant-airflow BPM motors (often referred to as “ECMs”).
20
DOE finds that furnace fans using high-efficiency motor technology options operate more efficiently than furnace fans using baseline PSC motors by:
20
“ECM” and “X13” refer to the constant-airflow and constant torque (respectively) BPM offerings of a specific motor manufacturer. Throughout this notice, DOE will refer to these technologies using generic terms, which are introduced in the list above. However, DOE's summaries of interested-party submitted comments include the terminology used by the interested party when referring to motor technologies.
• Functioning more efficiently at a given operating condition;
• Maintaining efficiency throughout the expected operating range; and
• Achieving a lower turndown ratio
21
(
i.e.,
ratio of airflow in lowest setting to airflow in highest setting).
21
A lower turndown ratio can significantly improve furnace fan efficiency because fan input power has a cubic relationship with airflow.
Ingersoll Rand commented that a PSC motor will use less energy at higher static pressures, while an ECM increases energy use as static pressure rises. Ingersoll Rand stated that as a result, understanding the impact of switching to an ECM at higher static pressures may confuse the consumer. (Ingersoll Rand, No. 43 at p. 67)
DOE is aware that consumers may be confused when BPM motors (referred to as ECMs by Ingersoll Rand above) consume more energy than PSC motors at higher static pressures, because consumers expect BPM motors to consume less energy than PSC motors under the same operating conditions. In general, input power to the fan motor increases as static pressure increases to provide a given airflow (
i.e.,
the fan motor has to work harder in the face of increased resistance to provide a desired amount of air).
22
DOE agrees with Ingersoll Rand that as static pressure increases, input power to a PSC-driven furnace fan will decrease, which is seemingly contradictory to the principle described above. DOE finds that input power to a PSC-driven furnace fan decreases because the airflow provided by the fan decreases as static pressure rises (
i.e.,
the fan does not have to work as hard in the face of increased resistance because the fan is not providing as much air). Input power to a constant-airflow BPM motor-driven furnace fan, on the other hand, will increase as static pressure rises because the BPM motor-driven fan is designed to maintain the desired level of airflow. Recognizing that this behavior could complicate comparing the relative performance of these motor technologies, DOE's proposed rating metric, FER, is normalized by airflow to result in ratings that are in units of watts/cfm. DOE believes that a comparison using a watts/cfm metric will mitigate confusion by accurately reflecting that even though a constant-airflow BPM motor is consuming more power at higher statics, it is also providing more airflow, which is useful to the consumer.
22
See chapter 3 of the TSD for more details regarding fan operation.
Interested parties recognized the benefits provided by constant-torque and constant-airflow BPM motors. NMC agreed that variable-speed technology is useful in furnace fan applications, because the airflow settings can be adjusted and optimized for a range of static pressure levels. (NMC, No. 60 at p. 1) NEEP supported DOE's proposal for an efficiency level based on a constant-torque ECM as part of the furnace fan analysis, given that these motors are widely available and less expensive than “full blown” ECM motors. (NEEP, No. 51 at p. 3) Morrison commented that ECM technology offers the best cost for performance value. (Morrison, No. 58 at p. 2)
Interested parties agreed that the BPM motor variations (
i.e.,
constant-torque and constant-airflow) and inverter-driven PSC motors generally have lower turndown ratios than a three-speed PSC motor. Table IV.3 contains the turndown ratio estimates supplied publicly by interested parties. Manufacturers generally provided similar feedback during interviews. NMC stated that the turndown ratios achieved by ECM technology allow for continuous circulation at optimal CFM levels, unlike PSC options, which cannot achieve low enough CFM. (NMC, No. 60 at p. 1) Lennox commented that including constant circulation as part of FER will penalize PSCs and artificially inflate the performance of ECMs. (Lennox, No. 47 at p. 9) Ingersoll Rand stated that furnace fan turndown ability is limited by the physical characteristics of the impeller and bearings. (Ingersoll Rand, No. 57 at pp. A-2)
Table IV.3—Stakeholder Estimated Fan Motor Turndown Ratios
Stakeholder
PSC
Wave chopper
controller PSC
Constant-torque
ECM
Constant-
airflow ECM
NMC (NMC, No. 60 at p. 1)
0.45
0.36
0.45
0.20
Goodman (Goodman, No. 50 at p. 2)
0.70-0.75
0.40-0.50
0.25-0.35
Rheem (Rheem, No. 54 at p. 6)
0.60
0.30
0.20
Overall, comments regarding high-efficiency motor turndown ratio validated DOE's expectation that lower turndowns are associated with improved PSCs, inverter-driven PSCs, and BPM motor variations. These motors consume significantly less energy over a typical residential furnace fan operating range. DOE disagrees with Lennox that including constant circulation as part of FER would “artificially” inflate the performance of BPM motors compared to PSC motors, because DOE concludes that there is non-trivial use of this mode by consumers. As part of the test procedure rulemaking, DOE estimates that on average, consumers operate furnace fans in constant-circulation mode 400 hours annually. This estimate is used to weight fan constant-circulation electrical energy consumption in FER. Excluding this mode from the rating metric would underestimate the potential efficiency improvements of technology options, such as BPM motors, that could reduce fan electrical consumption while performing this function. A detailed discussion of DOE's estimate for national average constant-circulation furnace fan operating hours can be found in the test procedure NOPR. 77 FR 28674, 28682 (May 15, 2012). DOE did not revise these estimates in the test procedure SNOPR published on April 2, 2013. 78 FR 19606.
d. Multi-Stage or Modulating Heating Controls
In the preliminary analysis (77 FR 40530 (July 10, 2012)), DOE identified two-stage and modulating heating controls (hereinafter collectively referred to as “multi-stage” controls) as a method of reducing residential furnace fan energy consumption. Multi-stage furnaces typically operate at lower heat input rates and, in turn, a lower airflow-control setting for extended periods of time compared to single-stage furnaces to heat a residence.
23
Due to the cubic relationship between fan input power and airflow, operating at the reduced airflow-control setting reduces overall fan electrical energy consumption for heating despite the extended hours. In the preliminary analysis, DOE analyzed multi-staging controls paired with use of a constant-airflow BPM fan motor as one technology option, because DOE found the two to be almost exclusively used together in commercially-available products.
23
A further discussion of multi-stage heating controls is found in chapter 3 of the preliminary analysis TSD, which can be found at the following web address:
http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0011-0037.
ASAP, ACEEE, NCLC, NRDC, and NEEA encouraged DOE to consider X13-level motors applied with multi-stage furnace controls as a technology option. ACEEE
et al.
added that they expect an X13-level motor paired with multi-stage furnace controls to operate at a lower speed (corresponding to the lower burner output) in heating mode for a greater number of hours compared to an X13-level motor applied with single-stage furnace controls. According to ACEEE
et al.,
the net effect of operating at a lower speed for a greater number of hours could be electricity savings, because motor power decreases with the cube of the speed. (ACEEE
et al.,
No. 55 at p. 3) Rheem commented that it does use modulating furnace controls with PSC and X13 motors, not just ECM motors. (Rheem, No. 43 at p. 81) During interviews, other manufacturers also commented that multi-stage heating controls can be and are used regardless of motor type.
Based on comments from Rheem and other manufacturers, DOE recognizes that multi-stage controls can be paired with other motor types, not just constant-airflow BPM motors. DOE agrees with ACEEE
et al.
that implementing multi-stage heating controls independent of motor type could result in residential furnace fan efficiency improvements. Consequently, DOE has decided to de-couple multi-staging controls from the constant-airflow BPM motor technology option. Accordingly, DOE has evaluated multi-staging controls as a separate technology option for the NOPR.
e. Backward-Inclined Impellers
DOE determined in the preliminary analysis that using backward-inclined impellers could lead to possible residential furnace fan energy savings. Although limited commercial data regarding backward-inclined impeller performance were available, DOE cited research by General Electric that showed large improvements in efficiency were achievable under certain operating conditions.
24
24
Wiegman, Herman, Final Report for the Variable Speed Integrated Intelligent HVAC Blower (2003) (Available at:
http://www.osti.gov/bridge/servlets/purl/835010-GyvYDi/native/835010.pdf
).
Morrison disagreed with the DOE's findings, stating that literature indicates there are varying degrees of performance improvement when backward-inclined impellers are used in place of forward-curved impellers. (Morrison, No. 43 at p. 132) Specifically, Morrison cited an LBNL study
25
where a furnace with a backward-inclined impeller exhibited no efficiency gains compared to a low efficiency forward-curved impeller. (Morrison, No. 58 at p. 3) According to Morrison, limitations on operating speed also make it necessary to couple backward-inclined impellers with high-efficiency motors. (Morrison, No. 58 at p. 2) Other commenters asserted that the optimal range of operation for backward-inclined impellers may fall outside that of typical residential furnace fan use. (SCE, No. 43 at p. 59; Ingersoll Rand, No. 57 at p. A-3; EEI, No. 60 at p. 2; CA IOU, No. 56 at p. 4) CA IOU testing showed that backward-inclined impellers are more sensitive to external static pressures, which could also limit their use. (CA IOU, No. 56 at p. 4) Rheem stated that improved efficiency of backward-inclined impellers is often achieved at mid-flow rates and high static levels. (Rheem, No. 54 at p. 7) Rheem commented that research by the replacement part manufacturer (Lau) reveals that backward-inclined impellers, at diameters typically used in residential applications, offer no significant efficiency improvements. (Rheem, No. 43 at p. 132)
25
Walker, I.S., Laboratory Evaluation of Residential Furnace Blower Performance (2005) (Available at:
http://www.escholarship.org/uc/item/7tx9c86s#page-1
).
Ebm-papst, a company that provides custom air-movement products, offered a diverging opinion from most manufacturers regarding the energy-saving potential of backward-inclined impellers. That company retrofitted
several HVAC products with furnace fan assemblies that incorporated backward-inclined impellers without increasing cabinet size and tested them. Depending on the application and the external static pressure load (typically 0.5 in.w.c. to 1 in.w.c.), ebm-papst found that the backward-inclined impeller achieved input power reductions from 15-30 percent. (ebm-papst Inc., No. 52 at p. 1) Ebm-papst did note that for backward-inclined impellers to match the performance of forward-curved impellers without increasing impeller dimensions, fan speed must increase. However, ebm-papst did not anticipate that this would be an obstacle to implementation using available motor technologies. (ebm-papst Inc., No. 52 at p. 1)
DOE recognizes that backward-inclined impellers may not be more efficient than forward-curved impellers under all operating conditions and that there may be considerable constraints to implementation. However, the GE prototype and ebm-papst prototype both demonstrate that significant energy consumption reduction is achievable at some points within the range of residential furnace fan operation. For this reason, DOE has included backward-inclined impellers as a technology option to be evaluated further in the screening analysis, where DOE investigates any other concerns regarding the use of a technology option, such as the practicability to manufacture or impacts on reliability, utility, and safety in the screening analysis.
B. Screening Analysis
DOE uses the following four screening criteria to determine which technology options are suitable for further consideration in an energy conservation standards rulemaking:
1.
Technological feasibility.
Technologies that are not incorporated in commercial products or in working prototypes will not be considered further.
2.
Practicability to manufacture, install, and service.
If it is determined that mass production and reliable installation and servicing of a technology in commercial products could not be achieved on the scale necessary to serve the relevant market at the time of the compliance date of the standard, then that technology will not be considered further.
3.
Impacts on product utility or product availability.
If it is determined that a technology would have significant adverse impact on the utility of the product to significant subgroups of consumers or would result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not be considered further.
4.
Adverse impacts on health or safety.
If it is determined that a technology would have significant adverse impacts on health or safety, it will not be considered further.
(10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b))
In sum, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the above four criteria, it will be screened out from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed below.
The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (“screened out”) based on the screening criteria.
1. Screened-Out Technologies
DOE screened out fan housing and airflow path design improvements in the preliminary analysis. DOE had little quantitative data to correlate specific fan housing alterations with efficiency improvements. Additionally, DOE anticipated that any improvements to airflow path design that would result in fan efficiency improvement would require an increase in furnace fan cabinet size or negatively impact heat exchanger performance, thereby compromising the practicability to manufacture or reducing utility to consumers.
Interested parties stated many concerns associated with modifying airflow path designs to reduce residential furnace fan electrical energy consumption. Morrison provided an example illustrating the tradeoffs in thermal performance of selecting an airflow path that enhances fan performance. Specifically, Morrison stated that, “a 90%+ efficient furnace will have higher pressure drop through the furnace than a similarly sized 80%+ efficient furnace because of the added heat transfer surface area.” (Morrison, No. 58 at p. 5) Conversely, manufacturers noted that higher SEER requirements call for increased central air conditioner or heat pump indoor coil size, leaving reduced space for other HVAC system components. Having to decrease the size of the fan due to these additional regulations could also make the furnace fan less efficient. (Morrison, No. 43 at p. 62) Mortex and Morrison also commented that the primary concern when selecting an airflow path design is usually safety or impact on heat transfer, not efficiency. (Mortex, No. 43 at p. 135; Morrison, No. 58 at p. 5) AHRI and Rheem outlined all of the possible housing design modifications that would affect airflow path design, including housing shape, distance between components, size of duct openings, and motor mounting. (AHRI, No. 48 at p. 3; Rheem, No. 54 at p. 9) AHRI emphasized that some modifications could improve or decrease efficiency, but all would require an increase in product size and, thus, manufacturing costs. (AHRI, No. 48 at p. 3) During manufacturer interviews, many manufacturers reiterated or echoed that airflow path design modifications would likely require increasing HVAC product size. Manufacturers explained that increasing HVAC products size would have adverse impacts on practicability to install and consumer utility, because the furnace fan market is predominantly a replacement market. Installing HVAC products that are larger in size compared to the products they are purchased to replace would likely present issues, mainly significant increases in installation costs or minimizing product availability to consumers.
DOE did not receive or find additional quantitative data that shows a measurable increase in fan efficiency as a result of a specific fan housing or airflow path design modification. Even after individual discussion with manufacturers, DOE was not able to identify a case where fan housing or airflow path design modifications could lead to potential fan energy savings without increasing the size of the HVAC product in which the furnace fan is used or compromising thermal performance or safety. In response to Morrison's comment, DOE assumes that the “added heat transfer surface area” in the 90%+ efficient furnace that Morrison refers to is the secondary heat exchanger typically used in condensing furnaces. DOE is aware of the impacts on thermal efficiency and furnace fan performance of the additional heat exchanger in condensing furnaces. As discussed in section III.B, DOE accounted for these impacts in its criteria for differentiating product classes. The 90%+ furnace (condensing) and 80%+ furnace (non-condensing) that Morrison refers to would not be in the same product class
according to DOE's proposed product classes. In addition, DOE concurs with manufacturers' observations that an increase in envelope size would adversely impact practicability to manufacture and install, as well as product utility. Accordingly, DOE has decided to screen out fan housing and airflow path design modifications until quantitative data become available to show that a fan housing or airflow path design modification results in improved fan efficiency without increasing HVAC product size or compromising thermal performance or safety.
2. Remaining Technologies
Through a review of each technology, DOE found that all of the other identified technologies met all four screening criteria to be examined further in DOE's analysis. In summary, DOE did not screen out the following technology options: (1) Inverter-driven PSC fan motors; (2) high-efficiency fan motors; (3) multi-stage heating controls; and (4) backward-inclined impellers. DOE understands that all of these technology options are technologically feasible, given that the evaluated technologies are being used (or have been used) in commercially-available products or working prototypes. These technologies all incorporate materials and components that are commercially available in today's supply markets for the residential furnace fans that are the subject of this NOPR. Therefore, DOE believes all of the efficiency levels evaluated in this notice are technologically feasible. For additional details, please see chapter 4 of the NOPR TSD.
DOE finds that all of the remaining technology options also meet the other screening criteria (
i.e.,
practicable to manufacture, install, and service and do not result in adverse impacts on consumer utility, product availability, health, or safety). Interested parties, however, voiced concerns regarding these screening criteria as they apply to BPM fan motors and backward-inclined impellers. DOE addresses these concerns in the sections immediately below. DOE did not receive public comments relevant to the screening analysis criteria for the other remaining technology options.
a. High-Efficiency Motors
AHRI stated that there are a limited number of ECM motor suppliers to furnace fan manufacturers. (AHRI, No. 48 at p. 2) Lennox commented that the technology is proprietary and dominated by a single motor manufacturer. Lennox added that industry competition is adversely affected as a result. (Lennox, No. 47 at p. 6) AHRI and Lennox noted that furnace fan manufacturers already have difficulties securing an adequate supply, so mandating ECM use would impact product availability. (Lennox, No. 47 at p. 8; AHRI, No. 48 at p. 2) AHRI and Mortex stated that no alternative ECM exists at the scale of Regal Beloit ECMs and that limiting PSC applicability would reduce product flexibility. (AHRI, No. 48 at p. 2; Mortex, No. 43 at p. 129) Both Goodman and Ingersoll Rand do not expect that a technology with better or equivalent performance to brushless permanent magnet motors will be available at a reasonable cost in the next decade. (Goodman, No. 50 at p. 2; Ingersoll Rand, No. 57 at pp. A-2)
Regal Beloit disagreed with residential furnace fan manufacturers, claiming that there is more than just a single motor manufacturer offering ECM technology. (Regal Beloit, No. 43 at p. 130) NMC concurred with Regal Beloit, stating that it too sells brushless permanent magnet motors in high volumes to furnace fan manufacturers. (NMC, No. 60 at p. 2) NMC supported DOE's assumption that after implementation of furnace fan efficiency standards, brushless permanent magnet motor technologies will become increasingly available over time. (NMC, No. 60 at p. 2) Ingersoll Rand confirmed that brushless DC motors are an ECM alternative available from several suppliers, although prices vary. (Ingersoll Rand, No. 57 at pp. A-2) Although Rheem commented that they have applied brushless DC motors produced by more than just a single vendor, their current designs and production processes have been developed to be specifically paired with Regal Beloit products. (Rheem, No. 54 at p. 7) DOE discovered during interviews with manufacturers that there are multiple suppliers of BPM motors. DOE also found further evidence that some manufacturers purchase BPM motors from multiple suppliers. EEI stated that the expiration of Regal Beloit ECM patents around 2020 may increase the availability of this motor type while decreasing cost. (EEI, No. 43 at p. 127)
In the preliminary analysis, DOE requested comment as to whether manufacturers could alternatively develop BPM motor controls in-house when using high-efficiency motors from other, non-Regal Beloit, suppliers. Currently, Regal Beloit offers BPM motors packaged with controls. Manufacturers may buy BPM motors that are not pre-packaged with controls from a supplier other than Regal Beloit, and develop their own controls. DOE anticipated that if furnace fan manufacturers had the ability to develop controls independently of Regal Beloit, this might drive down costs as well as dependency on a single manufacturer.
Most furnace fan manufacturers claimed that development of in-house controls for BPM motors is not an option. For example, Rheem uses General Electric and Regal Beloit software tools to program motors and does not currently have the capability to design motor controls without this tool. (Rheem, No. 54 at p. 6) Lennox and Morrison noted that having to design, build, and test motor controls would increase burden for large manufacturers and be prohibitively expensive to small manufacturers, neither of which have the expertise to develop these types of complex controls internally. (Lennox, No. 47 at p. 6; Morrison, No. 58 at p. 2) Lennox was also fearful that ECM suppliers might find motor control development an attempt to develop a replacement product and cut ties with furnace fan manufacturers. (Lennox, No. 47 at p. 7)
NMC confirmed that many U.S. motor suppliers bring in equipment from a fan manufacturer and develop unique ECM controls tailored to the manufacturer. (NMC, No. 43 at p. 128)
While DOE recognizes that Regal Beloit possesses a number of patents in the BPM motor space, other motor manufacturers (
e.g.,
Broad Ocean or NMC) also offer BPM models. Additionally, DOE is aware that in years past, residential furnace fans paired with constant-airflow BPM motors accounted for 30 percent of the market. While DOE estimates that constant-airflow BPM motors represent only 10-15 percent of the current furnace fan market, the manufacturing capability to meet BPM motor demand exists. Thus, DOE has tentatively concluded that BPM motor technology is currently available from more than one source and will become increasingly available to residential furnace fan manufacturers.
Some fan manufacturers expressed concern that high-efficiency motor reliance on rare earth metals would impact supply. However, DOE is aware of high-efficiency motors that do not contain rare earth materials. DOE is also confident, after manufacturer discussions, that if BPM motors are adopted as a means to meet a future residential furnace fan energy conservation standard, manufacturers would have a number of cost- and performance-competitive suppliers from which to choose who have available, or could rapidly develop, control systems independently of the motor manufacturer.
b. Backward-Inclined Impellers
According to Rheem, backward-inclined impellers must have larger diameter and operate at higher speed than forward-curve impellors in order to attain equivalent performance (
i.e.,
flow and pressure rise). (Rheem, No. 54 at p. 7) Goodman asserted that a 40-50 percent increase in diameter would be necessary for backward-inclined impellers to outperform their forward-curved counterparts. (Goodman, No. 50 at p. 2) According to AHRI, an impeller diameter increase would lead to an increase in overall product size, a change which may not be possible without redesigning the product. (AHRI, No. 48 p. 2) Morrison and Rheem argued that the larger evaporator coil size required to meet higher SEER requirements already limits the space available for furnaces, so an increase in product size due to backward-inclined impellers would severely restrict product application. (Morrison, No. 58 at p. 3; Rheem, No. 54 at p. 7) Ingersoll Rand stated that when used with backward-inclined impellers, motors typically operate at twice the RPM of forward-curved impellers for the same air delivery and static pressure. (Ingersoll Rand, No. 57 at pp. A-3) However, ebm-papst stated that they retrofitted existing equipment with backward-curved impellers, which only required making minor changes to the airflow path within the equipment. Ebm-papst also stated that it tested the retrofitted products, which achieved reductions of input power to the furnace fan in the range of 15-30 percent, depending on the specific equipment and the external static pressure (typically tested at 0.5 in.w.c. and 1.0 in.w.c.). (ebm-papst, No. 52 at p. 1)
AHRI and Rheem were also concerned with the potential impacts that backward-inclined impellers could have on heat exchanger temperatures. AHRI and Rheem stated that the air distribution out of a blower housing with a forward-curved wheel is maximum at the outside edges of the wheel and decreases at the center of the wheel. The air distribution out of a blower housing with a backward-inclined wheel is maximum at the center of the wheel and tapers off at the outside edges. The modified air distribution out of the blower housing would require assessment of heat exchanger temperatures for reliability and safety, as temperature limits operation. (AHRI, No. 48 at p. 2; Rheem, No. 54 at p. 8)
Some commenters also argued that backward-inclined impellers may affect furnace fan utility, because the noise produced by this impeller type may limit product application. Utilities have claimed that a backward-inclined impeller, in combination with increased fan motor speeds to achieve higher efficiency, leads to amplified noise levels. (EEI, No. 60 at p. 3; SCE, No. 43 at p. 59) However, during its testing of HVAC products retrofitted with a backward-inclined impeller, ebm-papst expressed a contrary view, observing that noise levels produced by the backward-inclined impeller were not significantly different from forward-curved impellers. (ebm-papst Inc., No. 52 at p. 1)
DOE finds that there are multiple approaches to implementing backward-inclined impellers to reduce furnace fan energy consumption. DOE recognizes that one approach is to use a backward-inclined impeller that is larger than a standard forward-curved impeller, which may lead to larger HVAC products. Another approach is to pair the backward-inclined impeller with a motor that operates at increased RPM. Ebm-papst tests show a significant potential to reduce fan electrical energy consumption for a backward-inclined impeller assembly that uses existing motor technology at higher RPMs and is implemented in existing HVAC products (
i.e.,
no increase in product size required). Ebm-papst does not believe that achieving higher RPMs with existing motor technology is an obstacle for implementing this technology. DOE believes that this prototype represents a backward-inclined implementation approach that could achieve fan energy savings while avoiding the negative impacts listed by manufacturers. Consequently, DOE decided not to screen out the backward-inclined impeller technology option.
C. Engineering Analysis
In the engineering analysis (corresponding to chapter 5 of the NOPR TSD), DOE establishes the relationship between the manufacturer selling price (MSP) and improved residential furnace fan efficiency. This relationship serves as the basis for cost-benefit calculations for individual consumers, manufacturers, and the Nation. DOE typically structures the engineering analysis using one of three approaches: (1) Design option; (2) efficiency level; or (3) reverse engineering (or cost-assessment). The design-option approach involves adding the estimated cost and efficiency of various efficiency-improving design changes to the baseline to model different levels of efficiency. The efficiency-level approach uses estimates of cost and efficiency at discrete levels of efficiency from publicly-available information, and information gathered in manufacturer interviews that is supplemented and verified through technology reviews. The reverse engineering approach involves testing products for efficiency and determining cost from a detailed bill of materials derived from reverse engineering representative products. The efficiency values range from that of a least-efficient furnace fan sold today (
i.e.,
the baseline) to the maximum technologically feasible efficiency level. For each efficiency level examined, DOE determines the MSP; this relationship is referred to as a cost-efficiency curve.
1. Efficiency Levels
In this rulemaking, DOE used an efficiency-level approach in conjunction with a design-option approach to identify incremental improvements in efficiency for each product class. An efficiency-level approach enabled DOE to identify incremental improvements in efficiency for efficiency-improving technologies that furnace fan manufacturers already incorporate in commercially-available models. A design-option approach enabled DOE to model incremental improvements in efficiency for technologies that are not commercially available in residential furnace fan applications. In combination with these approaches, DOE used a cost-assessment approach to determine the manufacturing production cost (MPC) at each efficiency level identified for analysis. This methodology estimates the incremental cost of increasing product efficiency. When analyzing the cost of each efficiency level, the MPC is not for the entire HVAC product, because furnace fans are a component of the HVAC product in which they are integrated. The MPC includes costs only for the components of the HVAC product that impact FER.
a. Baseline
During the preliminary analysis, DOE selected baseline units typical of the least-efficient furnace fans used in commercially-available, residential HVAC models that have a large number of annual shipments. This sets the starting point for analyzing potential technologies that provide energy efficiency improvements. Additional details on the selection of baseline units may be found in chapter 5 of the NOPR TSD. DOE compared the FER at higher energy efficiency levels to the FER of the baseline unit and compared baseline MPCs to the MPCs at higher efficiency levels.
DOE reviewed FER values that it calculated using test data and
performance information from publicly-available product literature to determine baseline FER ratings. Table IV.4 presents the baseline FER values identified in the preliminary analysis for each product class.
Table IV.4—Preliminary Analysis Baseline FER
Product class
FER
(W/1000 cfm)
Non-Weatherized, Non-condensing Gas Furnace Fan
380
Non-Weatherized, Condensing Gas Furnace Fan
393
Weatherized, Non-Condensing Gas Furnace Fan
333
Non-Weatherized, Non-Condensing Oil Furnace Fan
333
Electric Furnace/Modular Blower Fan
312
Manufactured Home Non-weatherized, Non-condensing Gas Furnace Fan
295
Manufactured Home Non-weatherized, Condensing Gas Furnace Fan
319
Manufactured Home Electric Furnace/Modular Blower Fan
243
Manufacturers asserted that the baseline FER values presented in the preliminary analysis were not representative of the furnace fans in the least-efficient residential HVAC models offered for sale today. Specifically, manufacturers stated that non-weatherized, non-condensing gas furnaces should be assigned a baseline FER of 451 instead of 380 and that non-weatherized, condensing gas furnaces should have an FER of 494 rather than 393. (AHRI, No. 48 at p. 5; Morrison, No. 58 at p. 6; Goodman, No. 50 at p. 5) Rheem also doubted that the difference in efficiency between non-condensing and condensing gas furnaces was only 13 points, a FER of 380 versus 393, as presented in the DOE's preliminary analysis. (Rheem, No. 43 at p. 96) Mortex calculated that their manufactured home, non-weatherized, non-condensing gas furnace had an FER of 420, not 295 as suggested by the DOE. Mortex also stated that published data used to calculate FER values were generated using ASHRAE Standard 103, not AMCA Standard 210, and that calculating FER based on published data may not be the best approach. (Mortex, No. 59 at p. 3; Mortex, No. 43 at p. 25) In contrast, Ingersoll Rand stated that the baseline FER presented in the preliminary analysis was consistent with the figures presented in AHRI Standard 210/240. (Ingersoll Rand, No. 57 at pp. A-7) Unico emphasized that the DOE should consider the broad range of designs fitting the “baseline” definition, lest the selected FER only be achievable by one manufacturer's design. (Unico, No. 43 at p. 79) Mortex disagreed with the DOE's key product approach, arguing that the selected product classes will have huge variation in efficiency (
i.e.,
baseline FER). (Mortex, No. 43 at p. 50) Manufacturers also provided additional baseline FER estimates during manufacturer interviews.
Some manufacturers also requested that DOE alter FER to better reflect unit capacity. Goodman suggested that DOE should consider using only one metric for all furnace fan capacities falling within the residential range (< 130 kBtuh) after making adjustments to the metric to include higher capacity units. (Goodman, No. 50 at p. 2) Alternatively, Mortex recommended that DOE should set maximum FER values for sub-product classes based on cooling capacity and cabinet size. (Mortex, No. 59 at p. 3) Similarly, AHRI stated that residential furnace fans having a 5-ton capacity also have higher FERs and recommended that DOE adjust baseline FER values to include the largest-capacity fan within a product class. (AHRI, No. 48 at p. 2) Rheem calculated FER for 19 models of gas-fired furnaces that used the same blower housing design, and it found that FER was generally not dependent on capacity. A graphic summary of Rheem's results are available in the written comment that Rheem submitted.
26
(Rheem, No. 54 at p. 5).
26
Publically available at:
http://www.regulations.gov/# !documentDetail;D=EERE-2010-BT-STD-0011-0054
.
DOE evaluated the feedback it received and used the data provided by interested parties to generate new FER values and to revise its baseline, intermediate efficiency levels, and max-tech FER estimates. DOE's revisions included FER results for furnace fan models that span the capacity range of residential products. After reviewing all of the available FER values based on new data, DOE concluded that FER can best be represented as a linear function of airflow capacity (
i.e.,
a first constant added to airflow multiplied by a second constant). The slope characterizes the change in FER for each unit of airflow capacity increase, and the y-intercept represents where the FER line intersects the y-axis (where airflow capacity is theoretically zero). DOE proposes to use such linear functions to represent FER for the different efficiency levels of the different product classes. A more detailed description of the analysis and the methodology DOE used to generate FER equations for each efficiency level can be found in chapter 5 of the NOPR TSD.
Table IV.5 shows the revised FER baseline efficiency levels estimates that DOE used for the NOPR.
Table IV.5—NOPR Baseline FER Estimates
Product class
FER*
(W/1000 cfm)
Non-Weatherized, Non-condensing Gas Furnace Fan
FER = 0.057 × Q
Max
+ 362 .
Non-Weatherized, Condensing Gas Furnace Fan
FER = 0.057 × Q
Max
+ 395.
Weatherized Non-Condensing Gas Furnace Fan
FER = 0.057 × Q
Max
+ 271.
Non-Weatherized, Non-Condensing Oil Furnace Fan
FER = 0.057 × Q
Max
+ 336.
Electric Furnace/Modular Blower Fan
FER = 0.057 × Q
Max
+ 331.
Manufactured Home Non-weatherized, Non-condensing Gas Furnace Fan
FER = 0.057 × Q
Max
+ 271.
Manufactured Home Non-weatherized, Condensing Gas Furnace Fan
FER = 0.057 × Q
Max
+ 293.
Manufactured Home Electric Furnace/Modular Blower Fan
FER = 0.057 × Q
Max
+ 211.
Manufactured Home Weatherized Gas Furnace Fan
Reserved.
Manufactured Home Non-Weatherized Oil Furnace Fan
Reserved.
* Q
Max
is the airflow, in cfm, at the maximum airflow-control setting measured using the proposed DOE test procedure. 78 FR 19606, 19627 (April 2, 2013).
b. Percent Reduction in FER
For the preliminary analysis, DOE determined average FER reductions for each efficiency level for a subset of key product classes and applied these reductions to all product classes. DOE found from manufacturer feedback and its review of publically-available product literature that manufacturers use similar furnace fan components and follow a similar technology path to improving efficiency across all product classes. DOE does not expect the percent reduction in FER associated with each design option, whether commercially available or prototype, to differ across product classes as a result. Table IV.6 includes DOE's preliminary analysis estimates for the percent reduction in FER from baseline for each efficiency level.
Table IV.6—Preliminary Analysis Estimates for Percent Reduction in FER From Baseline for Each Efficiency Level
Efficiency level (EL)
Design option
Percent reduction
in FER from
baseline
1
Improved PSC
2
2
Inverter-Driven PSC
10
3
Constant-Torque BPM Motor
45
4
Constant-Airflow BPM Motor + Multi-Staging
59
5
Premium Constant-Airflow BPM Motor + Multi-Staging + Backward-Inclined Impeller
* 63
* DOE estimates that implementing a backward-inclined impeller at EL 5 results in a 10% reduction in FER from EL 4. This is equivalent to a reduction of 4% percent of the baseline FER. The total percent reduction in FER from baseline for EL 5 includes the 59% reduction from EL 4 and the 4% net reduction of the backward-inclined impeller for a total percent reduction of 63% from baseline.
Interested parties questioned DOE's estimates for the FER reduction for high-efficiency motors. NMC commented that the company offers a special high-efficiency PSC motor line called PEP® that can achieve 10 points of efficiency improvement over standard PSC motors rather than 1.6-percent improvement shown in the preliminary analysis. (NMC, No. 60 at p. 1) Other interested parties provided similar estimates for improved PSC motors during manufacturer interviews. Unico noted that the high-efficiency BPM motor technology options in the Engineering Analysis (constant-torque or constant-air-flow BPM) do not improve fan efficiency as much as DOE's percent reduction in FER estimates suggest. (Unico, No. 43 at p. 109) Lennox suggested that a more accurate estimate of reduction in FER resulting from PSC to X13 motor conversions would be 30 percent as opposed to the 45 percent presented in the preliminary analysis. (Lennox, No. 47 at p. 2) Goodman provided a reference to a report from Advanced Energy of North Carolina
27
that stated that replacing PSC motors with full-ECM motors results in a 51-percent reduction in full-load efficiency. (Goodman, No. 50 at p. 3) Goodman would expect that the reduction in FER for X13 and ECM conversions be lower than presented in the preliminary analysis such as 35-50 percent for X13s and 45-50 percent for ECM. (Goodman, No. 50 at p. 5)
27
Fitzpatrick and Murray,
Residential HVAC Electronically Commutated Motor Retrofit Report
(2012) (Available at:
http://www.advancedenergy.org/ci/services/testing/files/Residential%20HVAC%20Electronically%20Commutated%20Motor%20Retrofit%20Final%20Report.pdf
).
DOE reviewed its estimates of percent reduction in FER from baseline for each efficiency level based on interested party feedback. In addition to the comments presented above, interested parties also provided FER values for higher-efficiency products in manufacturer interviews. DOE used these data to revise its percent reduction estimates. Table IV.7 shows DOE's revised estimates for the percent reduction in FER for each efficiency level that DOE used in the NOPR analyses. For a given product class, DOE applied the percent reductions below to both the slope and y-intercept of the baseline FER equation to generate FER equations to represent each efficiency level above baseline.
Table IV.7—NOPR Estimates for Percent Reduction in FER From Baseline for Each Efficiency Level
Efficiency level (EL)
Design option
Percent reduction
in FER from
baseline
1
Improved PSC
10
2
Inverter-Driven PSC
25
3
Constant-Torque BPM Motor
42
4
Constant-Torque BPM Motor and Multi-Staging
50
5
Constant-Airflow BPM Motor and Multi-Staging
53
6
Premium Constant-Airflow BPM Motor and Multi-Staging + Backward-Inclined Impeller
* 57
* DOE estimates that implementing a backward-inclined impeller at EL 6 results in a 10% reduction in FER from EL 5. This is equivalent to a 4% percent reduction in FER from baseline. The total percent reduction in FER from baseline for EL 6 includes the 53% reduction from EL 5 and the 4% net reduction from the backward-inclined impeller for a total percent reduction of 57% from baseline.
DOE believes that these revised estimates are consistent with the comments received from interested parties. Note that EL 4 in the table above is a newly proposed efficiency level. As discussed in section IV.A.3, DOE analyzed multi-staging as a separate technology option. For the NOPR, DOE also has evaluated a separate efficiency level representing applying multi-staging to a furnace fans with a constant-torque BPM motor. DOE recognizes that the percent reduction in FER for inverter-driven PSC increased considerably. However, since the baseline FER values increased for the NOPR, DOE believes that the percent reductions cannot directly be compared to those proposed in the preliminary analysis. DOE notes that the cited reductions may not appear to be fully consistent with stakeholder comments in part because they are FER reductions rather than reductions in full-load electrical efficiency. DOE expects that FER reductions may be significantly higher than full-load input power reductions, especially for efficiency levels based on use of BPM motors, because FER includes electrical energy consumption at reduced operating modes, for which these motors achieve much greater power reduction than PSC designs.
2. Manufacturer Production Cost (MPC)
In the preliminary analysis, DOE estimated the manufacturer production cost associated with each efficiency level to characterize the cost-efficiency relationship of improving furnace fan performance. The MPC estimates are not for the entire HVAC product because furnace fans are a component of the HVAC product in which they are integrated. The MPC estimates includes costs only for the components of the HVAC product that impact FER, which DOE considered to be the:
• Fan motor and integrated controls;
• Primary control board (PCB);
• Multi-staging components;
• Impeller;
• Fan housing; and
• Components used to direct or guide airflow.
DOE separated the proposed product classes into high-volume and low-volume product classes and generated high-volume and low-volume MPC estimates to account for the increased purchasing power of high-volume manufacturers.
28
28
High-volume and low-volume product classes are discussed further in chapter 5 of the NOPR TSD.
a. Production Volume Impacts on MPC
Morrison stated that DOE's assumption that large manufacturers have the same purchasing power across product types, even when those products are low volume, may or may not be true, because low-volume products may run through different processes. (Morrison, No. 43 at p. 118) Rheem stated that, in some cases, it uses the same blower system in low-volume products that it uses in high-volume products. (Rheem, No. 43 at p. 118) Unico commented that it uses different manufacturing processes than those presented in DOE's analysis and recommended that a different metric should be used to evaluate technologies that differ by process. (Unico, No. 43 at p. 122) Mortex stated that the motor costs for smaller manufacturers can be 15-20 percent greater than for large manufacturers because they do not, as stated by NEMA, benefit from economies of scale. (Mortex, No. 59 at p. 3; NEMA, No. 43 at p. 113)
DOE recognizes that high-volume manufacturers may use different processes to manufacture low-volume products than to manufacture high-volume products. However, DOE finds that 94 percent of the MPC for furnace fans is attributed to materials (including purchased parts like fan motors), which are not impacted by process differences. DOE's estimates also already account for process differences between manufacturers for high-volume and low-volume products. The products that DOE evaluated to support calculation of MPC included furnace fans from various manufacturers, including both high-volume and low-volume models. Observed process differences are reflected in the bills of materials for those products. DOE agrees with Mortex that low-volume manufacturers experience higher costs for materials, such as motors. DOE believes that its approach to distinguish between high-volume and low-volume product classes accounts for the expected difference in MPC between high-volume and low-volume product classes.
29
29
High-volume and low-volume product classes are discussed further in chapter 5 of the NOPR TSD.
b. Inverter-Driven PSC Costs
In the preliminary analysis, DOE estimated that the MPC of inverter control for a PSC motor is $10-$12, depending on production volume. Ingersoll Rand stated that an inverter cannot be added to a PSC for only $10-$12. (Ingersoll Rand, No. 57 at pp. A-7) NMC also questioned the validity of the inverter controller cost estimate, stating that the cost of an inverter driven controller is significantly higher than $12, unless DOE is erroneously equating inverters to wave chopper technology, which is far less efficient. (NMC, No. 60 at p. 1)
DOE's preliminary analysis estimate for the MPC of an inverter-driven PSC was indeed based on a wave chopper drive. DOE finds that more sophisticated and costly inverters are required to achieve the efficiencies reflected in DOE's analysis. Consequently, DOE has adjusted its cost estimate for PSC inverter technology. DOE gathered more information about the cost of inverters that are suited for improving furnace fan efficiency. In addition to receiving cost estimates during manufacturer interviews, DOE also reviewed its cost estimates for inverter drives used in other residential applications, such as clothes washers. DOE finds that $30 for high-volume
products and $42.29 for low-volume products are better estimates of the MPC for inverters used to drive PSC furnace fan motors. Accordingly, DOE has updated these values for the NOPR.
c. Furnace Fan Motor MPC
Manufacturers stated that DOE underestimated the incremental MPC to implement high-efficiency motors in HVAC products, other than oil furnaces. (Rheem, No. 54 at p. 10) Most manufacturers stated that the cost increase to switch from PSCs to more-efficient motor technologies was at least twice that of the DOE's estimate. (Lennox, No. 43 at p. 23, 113 and No. 47 at p. 1; Mortex, No. 43 at p. 25; Rheem, No. 43 at p. 112; Goodman, No. 50 at p. 3) AHRI and Morrison claimed incremental costs associated with an X13 motor should be $60, instead of the $22.73 reported by DOE and in the case of ECMs, $133 instead of the $91.95 repo
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