Energy Conservation Program for Consumer Products: Energy Conservation Standards for Residential Furnace Fans

Federal RegisterJul 3, 2014

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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:

Final rule.

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 final rule, DOE is adopting new energy conservation standards for residential furnace fans. DOE has determined that the prescribed energy conservation standards for these products would result in significant conservation of energy, and are technologically feasible and economically justified.

DATES:

The effective date of this rule is September 2, 2014. Compliance with the prescribed standards established for residential furnace fans in this final rule is required on and after July 3, 2019.

ADDRESSES:

The docket for this rulemaking, which includes

Federal Register

notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at

www.regulations.gov

. All documents in the docket are listed in the

www.regulations.gov

index. However, not all documents listed in the index may be publicly available, such as 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

. The

www.regulations.gov

Web page contains simple instructions on how to access all documents, including public comments, in the docket.

For further information on how to review the docket, 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 Office, EE-5B, 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

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Summary of the Final Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits and Costs

D. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Residential Furnace Fans

III. General Discussion

A. Test Procedures

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 Commercial Customers

b. Savings in Operating Costs Compared To Increase in Price (Life-Cycle Costs)

c. Energy Savings

d. Lessening of Utility or Performance of Equipment

e. Impact of Any Lessening of Competition

f. Need of the Nation To Conserve Energy

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

f. Other Components

D. Markups Analysis

E. Energy Use Analysis

F. Life-Cycle Cost and Payback Period Analysis

1. Installed Cost

2. Operating Costs

3. Furnace Fan Lifetime

4. Discount Rates

5. Compliance Date

6. Base-Case Efficiency Distribution

7. 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. Conversion Costs

b. Cumulative Regulatory Burden

c. Scope of MIA Coverage

d. Markups Analysis

e. Employment Impacts

f. Consumer Utility

g. Small Businesses

K. Emissions Analysis

L. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Development of Social Cost of Carbon Values

c. Current Approach and Key Assumptions

M. Utility Impact Analysis

N. Employment Impact Analysis

O. Comments on Proposed Standards

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. Conclusions

1. Benefits and Burdens of Trial Standard Levels Considered for Residential Furnace Fans

2. Summary of Benefits and Costs (Annualized) of Today's 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

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

M. Congressional Notification

VII. Approval of the Office of the Secretary

I. Summary of the Final Rule

Title III, Part B 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. Pursuant to EPCA, any new or amended energy conservation standard that DOE prescribes for certain products, such as furnace fans, 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)). Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)). In accordance with these and other statutory provisions discussed in this notice, DOE proposes amended energy conservation standards for furnace fans. The proposed standards shall have a fan energy rating (FER) value that meets or is less than the values shown in Table I.1. These standards would apply to all products listed in Table I.1 and manufactured in, or imported into, the United States on or after manufactured on and after July 3, 2019.

Table I.1.—Energy Conservation Standards for Covered Residential Furnace Fans

Product class

FER

(watts/cfm)

Percent

increase over baseline

(percent)

Non-Weatherized, Non-Condensing Gas Furnace Fan (NWG-NC)

FER = 0.044 x Q

Max

+ 182

Non-Weatherized, Condensing Gas Furnace Fan (NWG-C)

FER = 0.044 x Q

Max

+ 195

Weatherized Non-Condensing Gas Furnace Fan (WG-NC)

FER = 0.044 x Q

Max

+ 199

Non-Weatherized, Non-Condensing Oil Furnace Fan (NWO-NC)

FER = 0.071 x Q

Max

+ 382

Non-Weatherized Electric Furnace/Modular Blower Fan (NWEF/NWMB)

FER = 0.044 x Q

Max

+ 165

Mobile Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC)

FER = 0.071 x Q

Max

+ 222

Mobile Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)

FER = 0.071 x Q

Max

+ 240

Mobile Home Electric Furnace/Modular Blower Fan (MH-EF/MB)

FER = 0.044 x Q

Max

+ 101

Mobile Home Non-Weatherized Oil Furnace Fan (MH-NWO)

Reserved

Mobile Home Weatherized Gas Furnace Fan (MH-WG)

Reserved

* Q

Max

is the airflow, in cfm, at the maximum airflow-control setting measured using the final DOE test procedure at 10 CFR part 430, subpart B, appendix AA.

A. Benefits and Costs to Consumers

Table I.2 presents DOE's evaluation of the economic impacts of today's standards on consumers of residential furnace fans, as measured by the average life-cycle cost (LCC) savings and the median payback period (PBP). The average LCC savings are positive for all product classes.

Table I.2—Impacts of Energy Conservation Standards on Consumers of Residential Furnace Fans

Product class

Average LCC savings

(2013$)

Median payback period

(years)

Non-Weatherized, Non-Condensing Gas Furnace Fan

$506

5.4

Non-weatherized, Condensing Gas Furnace Fan

$341

5.8

Weatherized Non-Condensing Gas Furnace Fan

$447

4.4

Non-Weatherized, Non-Condensing Oil Furnace Fan

$46

1.7

Non-weatherized Electric Furnace/Modular Blower Fan

$204

3.2

Mobile Home Non-Weatherized, Non-Condensing Gas Furnace Fan

$36

2.7

Mobile Home Non-Weatherized, Condensing Gas Furnace Fan

$35

2.3

Mobile Home Electric Furnace/Modular Blower Fan

$85

4.1

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 (2014 to 2048). Using a real discount rate of 7.8 percent, DOE estimates that the INPV for manufacturers of residential furnace fans is $349.6 million.

Under today's standards, DOE expects that manufacturers may lose up to 16.9 percent of their INPV, which is approximately $59.0 million. Total conversion costs incurred by industry prior to the compliance date are expected to reach $40.6 million.

DOE calculated a present value in 2014; all monetary values in this document are expressed in 2013 dollars unless explicitly stated otherwise.

C. National Benefits and Costs

All monetary values in this section are expressed in 2013$ and are discounted to 2014.

DOE's analyses indicate that today's standards would save a significant amount of energy. The lifetime energy savings for residential furnace fans purchased in the 30-year period that begins in the year of compliance with the standards (2019-2048) amount to

3.99 quadrillion Btu (quads

). The estimated annual energy savings in 2030 (0.07 quads) are equivalent to 0.3 percent of total U.S. residential energy use in 2012.

A quad is equal to 10

British thermal units (Btu).

The cumulative net present value (NPV) of total consumer costs and savings of today's standards for residential furnace fans ranges from $10,024 million (at a 7-percent discount rate) to $28,810 million (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.

In addition, today's standards are expected to have significant environmental benefits. The energy savings would result in cumulative emission reductions of approximately 180.6 million metric tons (Mt)

of carbon dioxide (CO

), 695.0 thousand tons of methane (CH

), 235.7 thousand tons of sulfur dioxide (SO

), 84.0 thousand tons of nitrogen oxides (NO

), 6.2 thousand tons of nitrous oxide (N

O), and 0.4 tons of mercury (Hg).

The cumulative reduction in CO

emissions through 2030 amounts to 34 million Mt.

A metric ton is equivalent to 1.1 short tons. Results for NO

and Hg are presented in short tons.

DOE calculated emissions reductions relative to the Annual Energy Outlook 2013 (

AEO 2013

) Reference case, which generally represents current legislation and environmental regulations for which implementing regulations were available as of December 31, 2012.

The value of the CO

reductions is calculated using a range of values per metric ton of CO

(otherwise known as the Social Cost of Carbon, or SCC) developed by a recent Federal interagency process.

The derivation of the SCC values is discussed in section IV.L. Using discount rates appropriate for each set of SCC values, DOE estimates that the net present monetary value of the CO

emissions reductions is between 1,134 million to 16,799 million. DOE also estimates that the net present monetary value of the NO

emissions reductions is $53.1 million at a 7-percent discount rate, and $110.8 million at a 3-percent discount rate.

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; revised November 2013) (Available at:

http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf

DOE is investigating valuation of avoided Hg and SO

emissions.

Table I.3 summarizes the national economic costs and benefits expected to result from today's standards for residential furnace fans.

Table I.3—Summary of National Economic Benefits and Costs of Residential Furnace Fans Energy Conservation Standards*

Category

Present value

million 2013 $

Discount rate

(percent)

Benefits

Consumer Operating Cost Savings

13,409

34,999

Reduction Monetized Value ($12.0/t case)**

1,134

Reduction Monetized Value ($40.5/t case)**

5,432

Reduction Monetized Value ($62.4/t case)**

8,694

2.5

Reduction Monetized Value ($119/t case)**

16,799

Reduction Monetized Value (at $2,684/ton)**

111

Total Benefits†

18,894

40,542

Costs

Consumer Incremental Installed Costs

3,385

6,189

Net Benefits

Including CO

and NO

† Reduction Monetized Value

15,509

34,353

* 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

values represent global monetized values of the SCC, in 2013$, 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

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 average SCC with 3-percent discount rate.

The benefits and costs of today's 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 operating the product that meets the new or amended standard (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

emission reductions.

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 2014, the 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

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.

Although adding the value of consumer savings to the values of emission reductions provides a valuable perspective, two issues should be considered. First, the national operating cost savings are domestic U.S. consumer monetary savings that occur as a result of market transactions, whereas the value of CO

reductions is based on a global value. Second, the assessments of operating cost savings and CO

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 all future climate-related impacts resulting from the emission of one metric ton of carbon dioxide in each year. These impacts continue well beyond 2100.

Estimates of annualized benefits and costs of today's standards are shown in Table I.4. The results under the primary estimate are as follows. Using a 7-percent discount rate for benefits and costs other than CO

reduction (for which DOE used a 3-percent discount rate along with the SCC series that has a value of $40.5/t in 2015), the cost of the residential furnace fans standards in today's final rule is $358 million per year in increased equipment costs, while the benefits are $1416 million per year in reduced equipment operating costs, $312 million in CO

reductions, and $5.61 million in reduced NO

emissions. In this case, the net benefit amounts to $1,376 million per year. Using a 3-percent discount rate for all benefits and costs and the SCC series that has a value of $40.5/t in 2015, the cost of the residential furnace fans standards in today's rule is $355 million per year in increased equipment costs, while the benefits are $2010 million per year in reduced operating costs, $312 million in CO

reductions, and $6.36 million in reduced NO

emissions. In this case, the net benefit amounts to $1,973 million per year.

Table I.4—Annualized Benefits and Costs of Standards for Residential Furnace Fans

Discount rate

Primary

estimate *

Low net benefits

estimate *

High net benefits

estimate *

million 2013$/year

Benefits

Consumer Operating Cost Savings

1416

2010

1167

1626

1718

2467

Reduction (at $12.0/t case) **

108

Reduction (at $40.5/t case) **

312

268

377

Reduction (at $62.4/t case) **

2.5%

459

393

555

Reduction (at $119/t case) **

965

828

1166

Reduction (at $2,684/ton) **

5.61

6.36

4.80

5.35

6.82

7.86

Total Benefits †

7% plus CO

range

1,512 to 2,387

1,734

1,249 to 2,000

1,439

1,833 to 2,891

2,102

3% plus CO

range

2,106 to 2,981

1,708 to 2,459

2,583 to 3,641

2,328

1,899

2,852

Costs

Consumer Incremental Product Costs

358

355

314

304

410

419

Net Benefits

Total †

7% plus CO

range

1,154 to 2,029

935 to 1,685

1,423 to 2,481

1,376

1,125

1,692

3% plus CO

range

1,750 to 2,625

1,404 to 2,155

2,164 to 3,222

1,973

1,595

2,433

* 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 from 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 2013

Reference case, Low Estimate, and High Estimate, respectively. In addition, incremental product costs reflect a flat rate for projected product price trends in the Primary Estimate, a slightly increasing rate for projected product price trends in the Low Benefits Estimate, and a slightly declining rate for projected product price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.

** The CO

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 the average SCC with a 3% discount rate. In the rows labeled “7% plus CO

range” and “3% plus CO

range,” the operating cost and NO

benefits are calculated using the labeled discount rate, and those values are added to the full range of CO

values.

D. Conclusion

Based on the analyses culminating in this final rule, DOE found the benefits to the nation of the standards (energy savings, consumer LCC savings, positive NPV of consumer benefit, and emission reductions) outweigh the burdens (loss of INPV and LCC increases for some users of these products). DOE has concluded that the standards in today's final rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy.

II. Introduction

The following section briefly discusses the statutory authority underlying today's final rule, 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

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”),

which includes the types of residential furnace fans that are the subject of this rulemaking. (42 U.S.C. 6295(f)(4)(D))

For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.

All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law 112-210 (Dec. 18, 2012).

Pursuant to EPCA, DOE's energy conservation program for covered products consists of 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 “electricity used for purposes of circulating air through duct work” (which DOE has referred to in shorthand as residential “furnace fans”). (42 U.S.C. 6295(f)(4)(D)) DOE is also required by EPCA 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)(A)(3) 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)) The DOE test procedures for residential furnace fans currently appear at title 10 of the Code of Federal Regulations (CFR) part 430, subpart B, appendix AA.

DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including furnace fans. As indicated above, any 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 standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven 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 of 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 for a group of products, DOE must consider such factors as the utility to the consumer of such a 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 furnace fan energy rating metric does not account for the electrical energy consumption in standby mode and off mode, because energy consumption in those modes is being fully accounted for in the DOE energy conservation standards for residential furnaces and residential central air conditioners (CAC) and heat pumps (HP). 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))

B. 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 (NOPR) 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).

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 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. DOE published in the

Federal Register

a final rule on January 3, 2014, which contained the final test procedure for residential furnace fans. 79 FR 500.

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. DOE published a NOPR in the

Federal Register

and made available an accompanying NOPR TSD on October 25, 2013. 78 FR 64068. In that document, DOE requested comment on the following matters discussed in the TSD: (1) Additional FER values; (2) the methodology for accounting for the relationship between FER and airflow capacity; (3) the reasonableness of the values that DOE used to characterize the rebound effect with high-efficiency residential furnace fans; (4) DOE's estimate of the base-case efficiency distribution of residential furnace fans in 2018; (5) the long-term market penetration of higher-efficiency residential furnace fans; (6) data regarding manufacturer product costs for furnace fan equipment and components; (7) the effect of standards on future furnace fan equipment shipments; (8) whether there are features or attributes of the more energy-efficient furnace fans that manufacturers would produce to meet the standards in the proposed rule that might affect how they would be used by consumers; (9) data that would refine the analytical timeline; (10) input on average equipment lifetimes; (11) the new SCC values used to determine the social benefits of CO

emissions reductions over the rulemaking analysis period; and (12) input on the cumulative regulatory burden.

Id.

DOE also invited written comments on these subjects, as well as any other relevant issues. A PDF copy of the NOPR TSD is available at

http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0011-0068

The NOPR TSD provided an overview of the activities DOE undertook in developing proposed energy

conservation standards for residential furnace fans, and discussed the comments DOE received in response to the Preliminary Analysis. 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

developed relationships that show the manufacturer's cost of achieving increased efficiency;

• A

markups analysis

developed distribution channel markups that relate the manufacturer production cost (MPC) to the cost to the consumer;

• An

energy use analysis

estimated the annual energy use of furnace fans at various potential standard levels;

• 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;

• A

manufacturer impact analysis

estimated the financial impact of new energy conservation standards on manufacturers and calculated impacts on competition, employment, and manufacturing capacity;

• A

consumer subgroup analysis

evaluated variations in customer characteristics that might cause a standard to affect particular consumer sub-populations (such as low-income households) differently than the overall population;

• An

emissions analysis

assessed the effects of the considered standards on emissions of carbon dioxide (CO

), sulfur dioxide (SO

) nitrogen oxides (NO

), mercury (Hg), nitrous oxide (N

0), and methane (CH

);

• An

emissions monetization

estimated the economic value of reductions in CO

and NO

emissions from the considered standards;

• A

utility impact analysis

estimated selected effects of the considered standards on electric utilities;

• An

employment impact analysis

assessed the impacts of the considered standards on national employment; and

• A

regulatory impact analysis

(RIA) evaluated alternatives to amended energy conservation standards in order to assess whether such alternatives could achieve substantially the same regulatory goal at a lower cost.

The NOPR public meeting took place on December 3, 2013. At this meeting, DOE presented the methodologies and results of the analyses set forth in the NOPR TSD. The numerous comments received since publication of the October 2013 NOPR, including those received at the NOPR public meeting, have contributed to DOE's resolution of the issues raised by interested parties.

The submitted comments include a comment from the American Council for an Energy-Efficiency Economy (ACEEE); a joint comment from the American Fuel and Petrochemical Manufacturers (AFPM), the U.S. Chamber of Commerce (the Chamber), the Council of Industrial Boiler Owners (CIBO), the American Forest and Paper Association (AF&PA), and the American Petroleum Institute (API); a comment from the American Gas Association (AGA); a comment from the Air-Conditioning, Heating, and Refrigeration Institute (AHRI); a comment from the American Public Gas Association (APGA); a joint comment from the Appliance Standards Awareness Project (ASAP), Alliance to Save Energy (ASE), National Consumer Law Center (NCLC) and the Natural Resources Defense Council (NRDC); 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 (SCGC), and San Diego Gas and Electric (SDGE); a comment from the Cato Institute; a comment from China WTO (WTO); a comment from Earthjustice; a comment from Edison Electric Institute (EEI); a comment from the George Washington University Regulatory Studies Center; a comment from Goodman Global, Inc. (Goodman); a comment from Heating, Air-Conditioning and Refrigeration Distributers International (HARDI); a comment from Johnson Controls; a comment from Laclede Gas Company (Laclede); a comment from a comment from Lennox International, Inc. (Lennox); a comment from the Mercatus Center at George Mason University; a comment from Morrison Products, Inc. (Morrison); a comment from Mortex Product, Inc. (Mortex); a comment from the National Association of Manufacturers (NAM); a joint comment from the Northwest Energy Efficiency Alliance (NEEA) and the Northwest Power and Conservation Council (NPCC); a comment from the Northeast Energy Efficiency Partnerships (NEEP); a comment from Rheem Manufacturing Company (Rheem); a comment from Southern Company; a comment from Ingersoll Rand; and a comment from Unico, Incorporated. Comments made during the public meeting by those not already listed include Nidec Motor Corporation (Nidec) and the motor manufacturer Regal Beloit. This final rule 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 Procedures

DOE published the furnace fan test procedure final rule in the

Federal Register

on January 3, 2014. 79 FR 499. DOE's test procedure for furnace fans (hereinafter referred to as “the test procedure”) is codified in appendix AA of subpart B of part 430 of the code of federal regulations (CFR).The test procedure is applicable to circulation fans used in weatherized and non-weatherized gas furnaces, oil furnaces, electric furnaces, and modular blowers. The test procedure is not applicable to any non-ducted products, such as whole-house ventilation systems without ductwork, central air-conditioning (CAC) condensing unit fans, room fans, and furnace draft inducer fans.

DOE aligned the test procedure with the DOE test procedure for furnaces by incorporating by reference specific provisions from an industry standard that is also incorporated by reference in the DOE test procedure for furnaces. DOE's test procedure for furnaces is codified in appendix N of subpart B of part 430 of the CFR. The DOE furnace test procedure incorporates by reference American National Standards Institute (ANSI)/American Society of Heating, Refrigerating and Air Conditioning

Engineers (ASHRAE) 103-1993,

Method of Testing for Annual Fuel Utilization Efficiency of Residential Central Furnaces and Boilers

(ASHRAE 103-1993). The DOE furnace fan test procedure incorporates by reference the definitions, test setup and equipment, and procedures for measuring steady-state combustion efficiency provisions of the 2007 version of ASHRAE 103 (ASHRAE 103-2007). In addition to these provisions, the test procedure includes provisions for apparatuses and procedures for measuring temperature rise, external static pressure, and furnace fan electrical input power. The test procedure also incorporates by reference provisions for measuring temperature and external static pressure from ANSI/ASHRAE 37-2009,

Methods of Testing for Rating Electrically Driven Unitary Air-Conditioning and Heat Pump Equipment

(ASHRAE 37-2009). There are no differences between the 2005 version (which is already incorporated by reference in the CFR) and the 2009 version of the ASHRAE 37 provisions incorporated by reference for the furnace fan test procedure. The test procedure also establishes calculations to derive the rating metric, fan energy rating (FER), for each furnace fan basic model based on the results of testing per the test method for furnace fans codified in appendix AA of subpart B of part 430 of the CFR.

FER is the estimated annual electrical energy consumption of a furnace fan normalized by: (a) The estimated total number of annual fan operating hours (1,870); and (b) the airflow in the maximum airflow-control setting. For the purposes of the furnace fan test procedure, the estimated annual electrical energy consumption is the sum of the furnace fan electrical input power (in Watts), measured separately for multiple airflow-control settings at different external static pressures (ESPs), multiplied by national average operating hours associated with each setting. These ESPs are determined by a reference system, based on operation at maximum airflow that represents national average ductwork system characteristics. Table III.1 includes the reference system ESP values by installation type that are specified by the test procedure. In previous rulemaking documents for the furnace fan test procedure and energy conservation standard rulemaking, DOE used the term “manufactured home furnace” to be synonymous with “mobile home furnace,” as defined in the Code of Federal Regulation (CFR). 10 CFR 430.2. DOE will use the term “mobile home” hereinafter to be consistent with the CFR definition for “mobile home furnace.” All provisions and statements regarding mobile homes and mobile home furnaces are applicable to manufactured homes and manufactured home furnaces.

Table III.1—Required Reference System Criteria (i.e., ESP at Maximum Airflow) by Furnace Fan Installation Type

Installation type

ESP at

maximum

airflow

(in. wc)

Units with an internal evaporator coil

0.50

Units designed to be paired with an evaporator coil

0.65

Units designed to be installed in a mobile home

0.30

The

test procedure requires measurements for the airflow-control settings that correspond to fan operation while performing the cooling function (which DOE finds is predominantly associated with the maximum airflow-control setting), heating function, and constant-circulation function. Table III.2 describes the required airflow-control settings by product type.

Mobile home external static pressure is much lower because there is no return air ductwork in mobile homes. Also, the United States Department of Housing and Urban Development (HUD) requirements for mobile homes stipulate that the ductwork for cooling should be designed for 0.3 in. water column (wc). 24 CFR 3280.715.

Table III.2—Airflow-Control Settings at Which Measurements Are Required for Each Product Type

Product type

Airflow-control

setting 1

Airflow-control

setting 2

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.

* For the purposes of the test procedure, “absolute maximum” airflow-control setting refers to the airflow-control setting that achieves the maximum attainable airflow at the operating conditions specified by the test procedure.

As shown in Table III.2, for products with single-stage heating, the three airflow-control settings to be tested are: The default constant-circulation setting; the default heating setting; and the absolute maximum setting. For products with multi-stage heating or modulating heating, the airflow-control settings to be tested are: The default constant-circulation setting; the default low heating setting; and the absolute maximum setting. The absolute lowest airflow-control setting is used to represent constant circulation if a default constant-circulation setting is not specified. DOE defines “default airflow-control settings” as the airflow-control settings for installed use specified by the manufacturer in the product literature shipped with the product in which the furnace fan is integrated.

See

Section 2.2 of Appendix AA to Subpart B of 10 CFR part 430. 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. In instances where a manufacturer specifies multiple airflow-control settings for a given function to account for varying installation scenarios, the highest airflow-control setting specified for the given function shall be used for the DOE test procedure. High heat and reduced heat shall be considered different functions for multi-stage heating units. Manufacturer installation guides also provide detailed instructions regarding compatible thermostats and how to wire them to achieve the specified default settings.

The Watt measurements for calculating FER are weighted using designated annual operating hours for each function (

i.e.,

cooling, heating, and constant circulation) that represent national average operation. Table III.3 shows the estimated national average operating hours for each function.

Table III.3—Estimated National Average Operating Hour Values for Calculating FER

Operating mode

Variable

Single-stage

(hours)

Multi-stage

or modulating

(hours)

Heating

830

830/HCR

Cooling

640

Constant Circulation

CCH

400

For multi-stage heating or modulating heating products, the specified operating hours for the heating mode are divided by the heating 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 measured reduced heat input rate to the measured maximum heat input rate.

The FER equation is:

ER03JY14.000

Where:

CH = annual furnace fan cooling operating hours;

Max

= furnace fan electrical consumption at maximum airflow-control setting operating point;

HH = annual furnace fan heating operating hours;

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;

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);

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.

DOE received comments from interested parties regarding the furnace fan test procedure in response to the furnace fan energy conservation standard (ECS) NOPR. Interested parties' comments on the test procedure are summarized below. DOE addressed many of these issues in the test procedure final rule, published in the

Federal Register

on January 3, 2014. (79 FR 514). The publication of the test procedure final rule occurred after the standards NOPR public meeting, held on December 3, 2013, but before the close of the standards NOPR comment period on January 23, 2014. For comments that were addressed in the test procedure final rule, a reference to the applicable discussion contained in the test procedure final rule document is provided. DOE's detailed response is provided in this document for comments that were not addressed in the test procedure final rule document.

AHRI, Goodman, Morrison, Rheem, Southern Company, Johnson Controls, and Ingersoll Rand commented that DOE's schedule for finalizing the test procedure did not provide interested parties with sufficient time to evaluate product performance in accordance with the final test procedure in order to develop and submit substantive comments on the standards proposed in the NOPR. (AHRI, No. 98 at p. 2, 3; Goodman, No. 102 at pp. 7, 8; Morrison, No. 108 at p. 3; Rheem, No. 83 at p. 1; Southern Company, No. 85 at p. 2; Johnson Controls, No. 95 at p. 3; Ingersoll Rand, No. 43 at p. 33) Ingersoll Rand added that the comments they have submitted to date are based on the proposed test procedure, not the final test procedure. (Ingersoll Rand, No. 107 at pp. 2, 10) AGA and Allied Air agree and recommend that DOE delay promulgation of standards to give interested parties and DOE more time to conduct analyses using the final test procedure. (AGA, No. 110 at pp. 3, 4; Allied Air, Public Meeting Transcript, No. 43 at p. 48) Goodman recommended a delay of three months for this type of product and testing. (Goodman, No. 102 at p. 3) Prior to publication of the test procedure final rule, EEI expressed support for DOE issuing a supplemental notice of proposed rulemaking (SNOPR) for the standard if changes were made to the test procedure final rule that had significant impacts on DOE's analyses results. (EEI, No. 87 at p. 3) APGA and Southern Company also recommended that DOE publish a standards SNOPR. (APGA, No. 90 at p. 2; Southern Company, No. 43 at p. 37)

DOE recognizes that interested parties need sufficient time to collect and evaluate relevant fan performance data in order to submit meaningful comments on the proposed energy conservation standard for furnace fans. Thus, on December 24, 2013, DOE posted a pre-publication test procedure final rule notice to regulations.gov and issued a 30-day extension of the standards NOPR comment period to provide interested parties with time to evaluate DOE's proposed standards using the final test procedure.

AHRI, Johnson Controls, and Morrison stated that, even with the comment period extension, the 20 days between the publication of the test procedure final rule on January 3, 2014 and the close of the standards NOPR comment period on January 23, 2014 did not provide interested parties with sufficient time to assess the energy conservation standards NOPR based on the provisions within the final test procedure. AHRI added that DOE was obligated to issue the NOPR on the proposed energy conservation standards after the issuance of the final rule on the furnace fan test procedures per Section 7(c) of Appendix A to Subpart C of 10 CFR part 430. (AHRI, No. 98 at pp. 2, 3; Johnson Controls, No. 95 at p. 3; Morrison, No. 108 at p. 3) Mortex stated that they were not able to test any of their products according to the final test procedure by the time the energy conservation standard NOPR comment period closed. (Mortex, No. 104 at p. 2) Ingersoll Rand commented that DOE's standards NOPR analyses are invalid because they were not based on the test procedure final rule. (Ingersoll Rand, No. 107 at p. 2, 10). NEEA and NPCC provided there is a need for product testing using the final test procedure, and a re-assessment of the derivation of the proposed FER equations and standard levels. NEEA and NPCC added that they do not support a decision on

standards before there is sufficient data with which to verify that the proposed FER values will not disqualify from compliance the majority of the very products upon which they are founded, and for which DOE's economic analyses are valid. (NEEA and NPCC, No. 96 at p. 2)

DOE disagrees with AHRI and Morrison that the extended comment period was insufficient. DOE issued a test procedure SNOPR for furnace fans on April 2, 2013. 78 FR 19606. DOE did not make changes to the test procedure between the SNOPR and final rule that would significantly alter FER values for most products. Interested parties that conducted testing in accordance with the test procedure SNOPR proposal should not have to retest most furnace models to derive an FER value that is consistent with the final test procedure. For most furnaces, the FER value should not change or the FER value can be recalculated per the final test procedure requirements using the raw data measured according to the SNOPR test method. Therefore, notwithstanding the 20 days between the test procedure final rule and the close of the standards NOPR comment period, interested parties still had over nine months between the publication of the test procedure SNOPR and the close of the standards NOPR comment period to collect and evaluate fan performance data that is relevant to DOE's proposed standards. DOE received data that could be used to derive FER values that meet the final test procedure requirements from multiple manufacturers during this period.

DOE agrees with NEEA and NPCC that its proposed standards should be assessed based on FER values that are reflective of performance as measured by the final test procedure. For the reasons stated above, DOE was able to use much of the FER data it has collected in previous phases of this rulemaking to generate FER values that meet the requirements of the final test procedure. DOE also conducted testing prior to and during the development of the test procedure final rule that generated a broad set of results to enable DOE to derive FER values that are consistent with the requirements of the final test procedure. In addition, DOE continued to collect and use data from publicly-available product literature. DOE relied on the mathematical methods outlined in the test procedure NOPR for using this data to model fan performance and estimate FER values that meet the final test procedure requirements. 77 FR 28690 (May 15, 2012). DOE recognizes that this method is not identical to the final test procedure method. However, DOE believes the FER values generated in this manner are still relevant because the final test method is similar to the test method proposed by AHRI (with support from Goodman, Ingersoll Rand, Lennox, and Morrison) in response to the test procedure NOPR, which they argued would result in accurate and repeatable FER values that are comparable to the FER values resulting from the methods proposed in the NOPR. (AHRI, No. 16 at p. 3; Goodman, No. 17 at p. 4; Ingersoll Rand, No. 14 at p. 1; Morrison, No. 21 at p. 3.) For these reasons, Ingersoll Rand's comment stating that DOE's standards NOPR analyses are invalid because they are not based on the test procedure final rule is inaccurate. The standards proposed in the NOPR and those established by this final rule are based on relevant FER data.

Goodman stated that DOE's modifications to the test procedure since the April 2013 test procedure SNOPR will have a significant impact on FER. Goodman referred specifically to the modification in the test procedure that specifies that airflow be calculated based on firing the product in the absolute maximum airflow-control setting if that setting is a default heating setting. According to Goodman, most furnaces allow heating operation at the highest airflow setting. Thus, instead of heating airflow setting being a mid-range temperature rise as typically set by factory default, it will now be a low-range temperature rise at a much higher and less efficient setting for FER calculation (and a setting that will not be typical of a field installation). (Goodman, No. 102 at p. 7) Ingersoll Rand echoed Goodman's statement, adding that the modification would also result in higher watts in heating mode and a higher FER value than would have resulted using the procedure in the SNOPR for a majority of furnaces. (Ingersoll Rand, No. 107 at pp. 2, 10).

DOE disagrees with Goodman's and Ingersoll Rand's comments. DOE expects that both interested parties have misinterpreted the test procedure requirement. DOE recognizes that product controls can be altered from factory settings to allow heating in the absolute maximum airflow-control setting. The test procedure does not allow for this practice. The test procedure only requires testing in factory-set configurations. Specific to the modification in question, the test procedure requires heating in the absolute maximum airflow-control setting only if that setting is a default heat setting.

See

Section 8.6.1.2 of Appendix AA to Subpart B of 10 CFR part 430. By definition, as outlined in the test procedure, a default heating airflow-control setting is factory-set and specified for installed-use as a heat setting by the manufacturer.

See

Section 2.2 of Appendix AA to Subpart B of 10 CFR part 430. Consequently, the resulting temperature rise is also factory-set by the manufacturer, and the measured performance will be representative of field use. In addition, the test procedure SNOPR and final rule requirements for

Heat

(the watts in heating mode input for FER) are consistent and the measured values for this input should not change. The impacts of the modification in question are explained in more detail in the test procedure final rule. 79 FR 514 (January 3, 2014).

AHRI commented that in the final test procedure that was published on January 3, 2014, DOE introduced a change within the test procedure that increases the measured FER. AHRI stated that DOE decided not to implement AHRI's recommendation that a furnace be fired at the maximum airflow rate to calculate the maximum airflow. Instead, according to AHRI, the final rule specifies that the maximum airflow is determined by applying the airflow equation for a heating setting and adjusting to the maximum setting based on pressure measurements. AHRI claims that this approach results in an increase of the measured FER and was not accounted within the analyses associated with the energy conservation standards NOPR TSD that was issued on October 25, 2013. AHRI recommends that DOE reevaluate the analyses within the entire TSD due to this single change. (AHRI, No. 98 at p. 3, 4)

DOE introduced the change referred to by AHRI in the April 2, 2013 test procedure SNOPR. A detailed discussion of DOE's reasoning for that change are provided in that notice. 78 FR 19616. DOE made additional changes to this provision in the test procedure final rule by requiring that the product under test be fired at the maximum airflow rate to calculate the maximum airflow for furnaces for which the maximum airflow-control setting is a default heat setting (consistent with AHRI's recommendation).

See

Section 8.6.1.2 of Appendix AA to Subpart B of 10 CFR part 430. DOE disagrees with AHRI that the change in question will result in higher FER values. DOE fan performance tests, including tests following the final test procedure, show that the maximum airflow calculated when firing the product under test in the maximum airflow control setting is typically lower than when applying the airflow equation for a heating setting

and adjusting to the maximum setting based on pressure measurements. Consequently, FER values would be lower if they were derived using airflow values calculated when firing in the maximum airflow-control setting. AHRI did not provide data to the contrary. As stated above, DOE's proposed standards and the standards established by this document are valid because they are based on FER values that are consistent with the final test procedure (to include FER values employing the airflow adjustment method in question).

AHRI, Morrison, and Ingersoll Rand commented that they are opposed to DOE eliminating the HCR from the denominator of the FER equation. According to AHRI, DOE did not provide a sound technical justification for such a modification and unnecessarily penalized the FER values associated with multi-stage and modulating units. (AHRI, No. 98 at p. 2, 3; Morrison, No. 108 at p. 3, 4; Ingersoll Rand, No. 107 at p. 2, 10)

As discussed in the test procedure final rule, DOE found that including HCR in the denominator of the FER equation resulted in percent reductions in estimated annual energy consumption, as calculated for FER, of 15 percent. 79 FR 515 (January 3, 2014). Further, DOE found percent reductions in FER of approximately 30 percent when comparing single-stage products using constant-torque brushless permanent magnet (BPM) motors to multi-stage products using constant-torque BPM motors. DOE eliminated HCR from the FER equation because, as a result, percent reductions in FER dropped to 15 percent on average, which is consistent with percent reduction in estimated annual energy consumption. 79 FR 515 (January 3, 2014). DOE did not receive any new FER values for products that use a constant-torque BPM motor and multi-stage heating. DOE was also unable to find data in the public domain with which to calculate new FER values to represent such products. In the absence of new data, DOE used the raw airflow, ESP, and fan electrical energy consumption data for single-stage furnaces with constant-torque BPM motors to generate FER values reflecting the addition of theoretical multi-stage heating capabilities. Single-stage furnaces using constant-torque BPM motors typically have additional airflow-control settings that provide less airflow than the factory-set heating airflow-control setting. Theoretically, these airflow-control settings could be used for a low heat setting in a multi-stage heating configuration. DOE identified as many models as possible that meet this criterion and for which DOE has sufficient data to calculate theoretical FER values for a multi-stage configuration. For each model, DOE first calculated the temperature rise in the default heating setting based on the airflow, thermal efficiency and input heat rating in that setting. Next, DOE used a variation of the same relationship between these parameters to calculate the theoretical low input capacity that would achieve the same temperature rise for each available airflow-control setting below the heat setting. DOE then evaluated the HCR for each of the lower airflow-control settings based on the theoretical input capacity of the lower setting and the rated input capacity of the default heat setting. DOE selected the low airflow-control setting that produced an HCR between 0.4 and 0.9 that was closest to 0.7 to represent the theoretical low heating setting. DOE chose these criteria based on investigation of typical HCR values observed in currently available products. Finally, DOE calculated estimated annual energy consumption and an FER value using the single-stage model's data for the absolute maximum and constant circulation airflow-control settings and the data for the theoretical low heating setting for the heating airflow-control setting. DOE's new data shows that multi-staging reduces estimated annual energy consumption by an average of 14 percent and FER by an average of 12 percent. These findings are consistent with DOE's previous findings and support its decision to eliminate HCR from the denominator of the FER calculation.

Ingersoll Rand stated that the final test procedure reduces the estimated savings associated with BPM motors. Ingersoll Rand commented that BPM motors consume more power as static pressure increases than permanent-split capacitor (PSC) motors. (Ingersoll Rand, No. 107 at p. 2, 10)

DOE addressed this issue in the energy conservation standards NOPR. 78 FR 64084 (October 25, 2013). While BPM motors consume more power as static pressure increases, they also provide more airflow. FER is normalized by airflow to account for this difference in behavior between BPM and PSC motors. In addition, the standards established in this document are a function of airflow. BPM motor-driven fan performance is evaluated relative to PSC motor-driven fans that provide the same amount of airflow at the same reference system static pressure as a result. Interested parties did not provide any evidence that these methods are inappropriate for evaluating relative fan performance.

China WTO commented that FER includes factors, such as HCR, to account for multi-stage heating but does not include analogous factors for multi-stage cooling. (China WTO, No. 92 at p. 1)

DOE considered accounting for fan performance during multi-stage cooling operation for the test procedure NOPR. 77 FR 28680. DOE did not include factors for multi-stage cooling in the final test procedure because the presence and capacity of low-stage cooling is dependent on the cooling system with which a product containing a furnace fan is paired. DOE found in its review of publicly-available product literature that detailed characteristics of the cooling system are not typically provided. Consequently, entities performing the DOE furnace fan test procedure cannot identify the airflow-control setting that would be designated for low-stage cooling operation. In addition, multi-stage heating is not necessarily associated with multi-stage cooling capability (e.g., multi-stage cooling equipment is much less common than multi-stage heating equipment).

China WTO stated that the final test procedure does not provide a method for calculating the maximum airflow when the maximum airflow-control setting is only designated for cooling. (China WTO, No. 92 at p. 1)

The method for calculating the maximum airflow when the maximum airflow-control setting is only designated for cooling is provided in the final rule and in Section 9 of appendix AA of subpart B of part 430 of the CFR. 79 FR 524 (January 3, 2014).

The California Investor Owned Utilities (CA IOU) commented that they observed a potential error in the calculation of airflow in the final test procedure. Specifically, CA IOU recommended that DOE include the humidity ratio in pounds water vapor per pounds dry air. CA IOU submits that this addition will increase the accuracy of the calculation of specific volume of test room air in cubic feet per pound of dry air to calculate airflow. (CA IOU, No. 106 at p. 4)

The equation for calculating airflow in the final test procedure already includes the humidity ratio in pounds water vapor per pounds dry air as codified in Section 9 of appendix AA of subpart B of part 430 of the CFR.

CA IOU recommended that in addition to reporting FER, which is the basis for the performance standard, DOE require manufacturers to report individual mode electrical energy consumption values (e.g.,

Heat

Max

, and

Circ

). According to CA IOU,

reporting these values would greatly facilitate the development of more targeted energy efficiency incentive programs, and manufacturers already have to measure and perform these calculations for the composite FER. CA IOU recognizes that

Max

could represent fan electrical energy consumption in either heating or cooling mode depending on the product. Nonetheless, CA IOU also recommends that DOE require manufacturers to report fan electrical energy consumption in cooling mode even if not included in FER because having it as an additional data point could be useful for the development of utility programs across the country. CA IOU stated that energy efficiency incentive programs typically require a rigorous level of review and justification for implementation. Gaps in performance data of commercially available equipment is one of the main limiting factors in program development, contributing to the lengthy and resource-intensive data collection and verification processes. In the case of this rulemaking, manufacturers will already be required to test their products in heating, cooling, and constant circulation modes. CA IOU believes that the minimal extra effort required by manufacturers to report these values would be outweighed by the opportunity for utilities and other public agencies to develop incentive programs using these performance metrics, which in turn would positively impact manufacturers of high performing products. For these reasons, CA IOU strongly urge DOE to require manufacturers to report tested and calculated metrics that feed into a composite metric for the standard. ASAP, ASE, NCLC, and NRDC, hereinafter referred to as ASAP,

et al.,

agree. (ASAP,

et al.,

No. 105 at p. 3)

At this time, DOE is declining to adopt reporting requirements for individual mode electrical consumption values as the CA IOU suggests. While DOE is open to considering additional reporting metrics in the future, DOE believes that establishing a Federal test procedure and metric (

i.e.,

FER) will provide utility programs with a basis for establishing meaningful incentive programs as the CA IOUs desire. Further, DOE believes that reporting the aggregated electrical consumption (

i.e.,

the FER metric) will provide market differentiation amongst currently- available models, thereby allowing the utility programs to set voluntary levels for incentive programs at meaningful levels to obtain energy savings. If data and analyses are provided, which show the disaggregated levels are necessary for the proper execution of utility incentive programs, DOE will consider modifying the certification requirements for furnace fans.

Unico pointed out that DOE presents the required minimum reference system ESP values inconsistently across rulemaking documents. Unico noticed that in some documents DOE presents these values as a range for each installation type, and in other rulemaking documents DOE presents only the lower value within each range with an asterisk. (Unico, No. 93 at p. 6)

As explained in the test procedure final rule, DOE's test experience confirms manufacturer concerns that specific ESP values are difficult to achieve and maintain when measuring airflow. The final test procedure specifies that products maintain an ESP level between the minimum reference system value and 0.05 in. wc. above that minimum value to allow for slight variations. 79 FR 508 (January 3, 2014). Consequently, DOE presents the minimum required ESP values as a range in Section 8.6.1.2 in appendix AA of subpart B of part 430 in the CFR or as the minimum value with an asterisk accompanied by the explanation above in other DOE documents.

AHRI commented that DOE should provide the option of employing an alternative efficiency determination method (AEDM) to determine FER. AHRI insists that an AEDM is critical for manufacturers to implement new requirements on a timely basis while minimizing burden. AHRI believes that the number of furnace fan basic models will be greater than the number of furnace basic models. According to AHRI, the pressure drop due to the gas heat exchanger will require that each furnace basic model also be considered as a furnace fan basic model. AHRI added that additional furnace fan basic models would be created in order to account for the type of installation. AHRI also pointed out that many furnace fan manufacturers also produce several other DOE regulated products. AHRI submits that rather than requiring manufacturers to spend valuable resources on conducting several tests, DOE should recognize that those resources could be better spent on innovating more efficient products. (AHRI, No. 98 at p. 13)

DOE provided a detailed discussion of this issue in the test procedure final rule. 79 FR 513 (January 3, 2014). DOE currently does not allow the use of AEDMs for residential products, with the exception of central air conditioners and heat pumps due to the uniquely large number of combinations of split-system air conditioners and heat pumps that are rated. DOE recognizes that the number of furnace fan basic models may outnumber furnace basic models for the reasons AHRI lists. Even so, DOE expects the number of basic models of furnace fans to be significantly less than the number of basic models of residential central air conditioners and heat pumps (CAC and HP) for which alternative rating methods are currently allowed. DOE has not found the residential furnace fan market to be highly customized (

i.e.,

containing many unique built-to-order designs) and expects that manufacturers will be able to group similar individual furnace fan types into basic models to reduce testing burden. DOE notes that it currently has over 1 million CAC combinations certified in the Compliance Certification Management System (CCMS) compared to approximately 12,500 certified furnace basic models. Consequently, DOE does not agree with AHRI's assertion that an alternative rating method needs to be considered at this time. Should AHRI or the industry provide additional data or substantiation for its requests demonstrating why testing furnace fans are unique, as compared to the majority of other residential products for which AEDMs are not allowed, then DOE may consider such requests in a separate rulemaking.

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. However, in this rulemaking, DOE is only covering 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 final test procedure. DOE addresses 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 differentiates 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 final rule technical support document (TSD). DOE includes 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)

• Mobile Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC)

• Mobile Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)

• Mobile Home Electric Furnace/Modular Blower Fan (MH-EF/MB)

• Mobile Home Weatherized Gas Furnace Fan (MH-WG)

• Mobile 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. “Mobile home” products meet certain design requirements that allow them to be installed in mobile 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 document 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 tcrial standard levels (TSLs) in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the final rule 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 final rule and in chapter 5 of the final rule TSD.

D. Energy Savings

1. Determination of Savings

For each TSL, DOE projected energy savings from the products that are the subjects of this rulemaking purchased during a 30-year period that begins in the year of compliance with amended standards (2019-2048).

The savings are measured over the entire lifetime of products purchased in the 30-year period.

DOE used the NIA model to estimate the NES for products purchased over the above period. The model forecasts total energy use over the analysis period for each representative product class at efficiency levels set by each of the considered TSLs. DOE then

compares the aggregated energy use at each TSL to the base-case energy use to obtain the NES. The NIA model is described in section IV. H of this document and in chapter 10 of the final rule TSD.

DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.

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 during 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 NIA spreadsheet model to estimate energy savings from amended 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. For electricity, DOE reports national energy savings in terms of the primary (source) energy savings, which are the savings in the energy that is used to generate and transmit the site electricity. To convert site energy to primary energy, DOE derives annual conversion factors from the model used to prepare the Energy Information Administration's (EIA)

Annual Energy Outlook 2013

(

AEO 2013

DOE also has begun to estimate full-fuel-cycle energy savings. 76 FR 51282 (August 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 energy efficiency standards. DOE's evaluation of FFC savings is driven in part by the National Academy of Science's (NAS) report on FFC measurement approaches for DOE's Appliance Standards Program.

The NAS report discusses that FFC was primarily intended for energy efficiency standards rulemakings where multiple fuels may be used by a particular product. In the case of this rulemaking pertaining to residential furnace fans, only a single fuel—electricity—is consumed by the product. DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered products. Although the addition of FFC energy savings in the rulemakings is consistent with the recommendations, the methodology for estimating FFC does not project how fuel markets would respond to this particular standards rulemaking. The FFC methodology simply estimates how much additional energy, and in turn how many tons of emissions, may be displaced if the estimated fuel were not consumed by the products covered in this rulemaking. It should be noted that inclusion of FFC savings has not affected DOE's choice of the energy conservation standards adopted in today's final rule. For more information on FFC energy savings, see section IV. H.2.

“Review of Site (Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building Appliance Energy-Efficiency Standards,” (Academy report) was completed in May 2009 and included five recommendations. A copy of the study can be downloaded at:

http://www.nap.edu/catalog.php?record_id=12670

2. Significance of Savings

EPCA prohibits DOE from adopting a standard for a covered product that would not result in significant energy savings. (42 U.S.C. 6295(o)(3)(B)) Although the term “significant” is not defined in EPCA, the U.S. Court of Appeals for the District of Columbia, in

Natural Resources Defense Council

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 today's standards (presented in section V of this notice) are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.

E. Economic Justification

1. Specific Criteria

As discussed in section II.A, 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 generally discuss how DOE is addressing each of those seven factors in this rulemaking. For further details and the results of DOE's analyses pertaining to economic justification, see sections IV and V of today's document.

Economic Impact on Manufacturers and Commercial Customers

In determining the impacts of a potential new or amended energy conservation standard on manufacturers, DOE conducts a manufacturer impact analysis (MIA), as discussed in section IV.J. DOE first determines a potential standard's quantitative impacts using an annual cash flow approach. This step includes both a short-term assessment (based on the cost and capital requirements associated with new or amended standards during the period between the announcement of a regulation and the compliance date of the regulation) and a long-term assessment (based on the costs and marginal impacts over the 30-year analysis period). The impacts analyzed include: (1) Industry net present value (INPV) (which values the industry based on 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 potential impacts on different types of manufacturers, paying particular attention to impacts on small manufacturers. Third, DOE considers the impact of new or amended standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for new or amended 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 other DOE regulations and non-DOE regulatory requirements on manufacturers.

For individual customers, measures of economic impact include the changes in LCC and the PBP associated with new or amended standards. These measures are discussed further in the following section. For consumers in the aggregate, DOE also calculates the national net present value of the economic impacts applicable to a particular rulemaking. DOE also evaluates the LCC impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a national standard.

Savings in Operating Costs Compared to Increase in Price (Life-Cycle Costs)

EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered product compared to any increase in the price of the covered product that are likely to result from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.

The LCC is the sum of the purchase price of a product (including the cost of its installation) and the operating costs (including energy, maintenance, and repair costs) discounted over the lifetime of the equipment. 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. For its analysis, DOE assumes that consumers will purchase the covered product in the first year of compliance with new standards.

The LCC savings and the PBP for the considered efficiency levels are calculated relative to a base-case scenario, which reflects likely market trends in the absence of new or amended standards. 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's LCC analysis is discussed in further detail in section IV.F.

Energy Savings

Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA also 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)) DOE uses NIA spreadsheet results in its consideration of total projected savings. For the results of DOE's analyses related to the potential energy savings, see section V.B of this notice and chapter 10 of the final rule TSD.

Lessening of Utility or Performance of Equipment

In establishing product classes, and in evaluating design options and the impact of potential standard levels, DOE follows EPCA's requirement to develop standards that would not lessen the utility or performance of the products under consideration. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) DOE has determined that none of the TSLs presented in today's final rule would reduce the utility or performance of the products under consideration in this rulemaking. During the screening analysis, DOE eliminated from consideration any technology that would adversely impact customer utility. See section IV.B of this notice and chapter 4 of the final rule TSD for further details.

Impact of Any Lessening of Competition

EPCA requires DOE to consider any lessening of competition that is likely to result from setting new or amended 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))

To assist the Department of Justice (DOJ) in making such a determination, DOE provided DOJ with copies of both the NOPR and NOPR TSD for review. In its assessment letter responding to DOE, DOJ concluded that the proposed energy conservation standards for residential furnace fans are unlikely to have a significant adverse impact on competition. DOE is publishing the Attorney General's assessment at the end of this final rule.

Need of the Nation To Conserve Energy

Another factor that DOE must consider in determining whether a new or amended standard is economically justified is the need for national energy and water conservation. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from new or amended standards are likely to provide improvements to the security and reliability of the Nation's energy system. Reductions in the demand for electricity may also result in reduced costs for maintaining the reliability of the Nation's electricity system. DOE conducts a utility impact analysis to estimate how new or amended standards may affect the Nation's needed power generation capacity, as discussed in section IV.M.

Energy savings from energy conservation standards are also likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases associated with energy production (

i.e.,

from power plants). For a discussion of the results of the analyses relating to the potential environmental benefits of today's standards, see sections IV.K, IV.L and V.B.6 of this notice. DOE reports the expected environmental effects from today's standards, as well as from each TSL it considered, in chapter 13 of the final rule TSD. DOE also reports estimates of the economic value of emissions reductions resulting from the considered TSLs in chapter 14 of the final rule TSD.

Other Factors

EPCA allows the Secretary, in determining whether a new or amended 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)) There were no other factors considered for today's final rule.

2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA provides for a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the new or amended standard is less than three times the value of the first-year energy (and, as applicable, water) savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values that calculate the PBP for consumers of products subject to potential new and amended energy conservation standards. These analyses include, but are not limited to, the 3-year PBP contemplated under the rebuttable presumption test. However, 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 these analyses serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable presumption payback calculation is discussed in section IV.F of this rulemaking and chapter 8 of the final rule TSD.

IV. Methodology and Discussion

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; (3) manufacturers; (4) quantities and types of products sold and offered for sale; (5) retail market trends; (6) regulatory and non-regulatory programs; and (7) 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 final rule 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)) DOE adopted the term “furnace fan” as shorthand to describe the range of products encompassed by this statutory mandate. In the preliminary analysis, DOE interpreted its statutory mandate by defining “furnace fan” to include “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.

In response to the preliminary analysis, many interested parties disagreed with DOE's definition of “furnace fan” and corresponding approach to set component-level regulations, which they warned would ignore system effects that could impact both fan and HVAC system energy consumption. California investor-owned utilities CA IOUs suggested that “furnace fan” should 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, PA Public Meeting Transcript, 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, PA Public Meeting Transcript, 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 consequently, the furnace will consume more gas to compensate and meet the desired house heat load. (Ingersoll Rand, No. 43 at p. 66)

“Laminar flow” is as term to describe when all fluid particles move in paths parallel to the overall flow direction (

i.e.,

in layers). Laminar flow may occur when the flow channel is small and the speed is low. “Turbulent flow” is characterized by a three-dimensional movement of the fluid particles superimposed on the overall direction of motion. Turbulent flow may occur when the flow speed is higher and when there are obstacles in the channel that disrupt the flow profile. The turbulent flow intensifies the heat transfer, thus resulting in more efficient heat exchange.

In the NOPR, DOE responded by explaining that DOE is required by EPCA to consider and prescribe new energy conservation standards or energy use standards for electricity used for purposes of circulating air through duct work. (42 U.S.C. 6295(f)(4)(D)) Consequently, in the context of furnace fans, DOE does not have latitude to apply only a single standard for the larger HVAC product (which is already regulated). Pursuant to this statutory mandate, DOE issued a NOPR which proposed energy conservation standards for circulation fans used in residential central HVAC systems (78 FR 64068 (Oct. 25, 2013)). DOE added that it did not interpret its authority as including regulating the duct work itself. DOE recognized that component-level regulations could have system-level impacts. Accordingly, DOE conducted its NOPR analyses and selected the standard levels proposed in the NOPR 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 final test procedure codified in DOE's regulations at 10 CFR part 430, subpart B, appendix AA specifies that the furnace fan be tested as factory-installed in the HVAC product, thereby enabling the rating metric, FER, to account for system effects on airflow delivery and, ultimately, energy performance. In addition, the product class structure proposed in the NOPR allowed for differentiation of products with designs that achieve higher thermal efficiency but may have lower fan performance, such as condensing furnaces. 78 FR 64068, 64082 (Oct. 25, 2013).

In the January 3, 2014 test procedure final rule, DOE broadened its definition of “furnace fan” to mean “an electrically-powered device used in a consumer product for the purpose of circulating air through ductwork.” 79 FR 500, 521.

In response to the NOPR, DOE did not receive comments from interested parties regarding the definition of “furnace fan” established by the test procedure final rule. Consequently, in this standards final rule, DOE is maintaining the definition for “furnace fan,” codified at 10 CFR 430.2. However, DOE did receive comments on its definitions for certain product types that include furnace fans. DOE summarizes and responds to these comments later in this section of the notice.

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.

In response to the preliminary analysis, efficiency advocates expressed concern at DOE's exclusion of packaged and split-system CAC products because advocates 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. 78 FR 64068, 64080 (Oct. 25, 2013).

In contrast, many manufacturers submitted comments in response to the preliminary analysis that they 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. Manufacturers also claimed that the electricity used to circulate air through duct work is already adequately accounted for in existing energy efficiency metrics for CAC and HP products that use circulation fans. 78 FR 64068, 64080-81 (Oct. 25, 2013).

In the October 25, 2013 furnace fan energy conservation standard NOPR, DOE noted 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 64068, 64081. 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.”

Id.

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. In the standards NOPR, however, DOE only proposed energy conservation standards for those circulation fans that are used in residential furnaces and modular blowers (see discussion below). As a result, DOE did not address public comments that pertain to fans in other types of HVAC products (other than to clarify instances where there was uncertainty as to whether a given product fits within the scope of the current rulemaking). The following list describes the furnace fans which DOE proposed to address in the standards NOPR.

•

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 indoor units, through-the-wall indoor units, small-duct, high-velocity (SDHV) indoor units, energy recovery ventilators (ERVs), heat recovery ventilators (HRVs), draft inducer fans, exhaust fans, or hydronic air handlers.

Id.

In the October 25, 2013 NOPR, DOE also maintained its proposal to account for the electrical consumption of furnace fans while performing all active mode functions (

i.e.,

heating, cooling, and constant circulation) because 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. 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.

Id.

China WTO commented that DOE's definition for “furnace fan” and the proposed scope show that residential furnace fans primarily perform the heating function. For this reason, China WTO recommended that DOE exclude fan performance for cooling operation to avoid unnecessary test procedure burden. (China WTO, No. 92 at pp. 1-2).

For the reasons stated above, the energy conservation standards established by this notice account for the electrical consumption of furnace fans while performing all active mode functions (

i.e.,

heating, cooling, and constant circulation). The commenter did not dispute the fact that fans will operate in cooling or constant-circulation mode, often for non-trivial periods of time. Because the electrical energy consumption of the fan may vary substantially depending on its mode of operation, DOE has concluded that testing fan operation in all these modes is necessary to reflect the product's energy consumption during a representative use cycle and that such testing would not be unduly burdensome to conduct.

Unico submitted comments regarding concerns with DOE's test procedure and proposed standard levels as they apply to SDHV systems. Unico explains that DOE proposed to exclude SDHV products from the rulemaking but included modular blowers and electric furnaces, resulting in a potential conflict. Unico added that most of their SDHV air handlers are modular in construction. Unico also offers an add-on electric furnace to provide secondary or backup heat, but very few systems are installed as an electric furnace. As a result, Unico expressed uncertainty whether this rule applies to SDHV modular blowers and SDHV electric furnaces. Unico provided data showing that SDHV blowers operate at different conditions compared to the products proposed to be covered and cannot meet the proposed FER levels. Ultimately, Unico expressed concerns that this rule could potentially eliminate many SDHV products from the market if they are subject to DOE's proposed standards. (Unico, No. 93 at pp.1-4)

In response to the comment, DOE clarifies that the furnace fan test procedure and the energy conservation standards established by this final rule do not apply to SDHV products, including SDHV modular blowers and electric furnaces. DOE recognizes that these products operate at different conditions which significantly impact their fan performance, as compared to the products addressed in this rulemaking. While DOE's regulations at 10 CFR 430.2 include a definition for “small duct high velocity systems,” it does not include a definition for small duct high velocity modular blowers or SDHV electric furnaces. Absent clarification, DOE realizes that confusion may result regarding which products are and are not covered by today's standards. Accordingly, DOE is adopting the following definition of “small-duct high-velocity (SDHV) modular blower,” which has been drafted to be consistent with the existing definition of “SDHV system” at 10 CFR 430.2:

Small-duct high-velocity (SDHV) modular blower

means a product that:

• Meets the definition of “modular blower,” as set forth in 10 CFR part 430, subpart B, appendix AA;

• Is designed for, and produces, at least 1.2 inches of external static pressure when operated at the certified air volume rate of 220-350 CFM per rated ton of cooling in the highest default cooling airflow-controls setting; and

• When applied in the field, uses high velocity room outlets generally greater than 1,000 fpm that have less than 6.0 square inches of free area.

Similarly, DOE is adopting a definition for “small-duct high-velocity (SDHV) electric furnace” to read as follows:

Small-duct high-velocity (SDHV) electric furnace

means a product that:

• Meets the definition of “electric furnace,” as set forth in 10 CFR 430.2;

• When applied in the field, uses high velocity room outlets generally greater than 1,000 fpm that have less than 6.0 square inches of free area.

DOE has concluded that these amendments should eliminate any confusion associated with DOE not addressing SDHV modular blowers and SDHV electric furnaces in the present rulemaking. Unico also submitted other SDHV-related concerns, but DOE need not discuss those issues further because SDHV products are not addressed in this rulemaking.

AHRI, Morrison, Goodman, Johnson Controls, and Mortex stated that modular blowers should be excluded from the scope of this rulemaking. (AHRI, No. 98 at pp. 1, 2; Morrison, No. 108 at p. 1; Goodman, No. 102 at p. 5; Johnson Controls, No. 95 at p. 2; and Mortex, NOPR Public Meeting Transcript, No. 91 at pp. 78-79). AHRI,

Morrison, and Johnson Controls continue to advance an interpretation of 42 USC 6295(f)(4)(D) as being only applicable to furnaces, and these commenters argued that absent a legislative change, DOE has exceeded its statutory authority in terms of the NOPR's proposed coverage of modular blowers. (AHRI, No. 98 at pp. 1-2; Morrison, No. 108 at p. 1; and Johnson Controls, No, 95 at p. 2). AHRI and Johnson Controls added that some modular blowers in today's marketplace are not designed to operate with electric resistance heat kits, rendering the final test procedure insufficient for these products. (AHRI, No. 98 at pp. 1, 2; and Johnson Controls, No. 95 at p. 3).

ASAP,

et al.,

on the other hand, expressed support for the inclusion of modular blowers in the scope of coverage. ASAP,

et al.

stated that they understand that the strip heat used with electric furnaces is often installed in the field, which means that an “electric furnace” is often sold by the manufacturer as a “modular blower.” ASAP,

et al.

cite DOE's finding that non-weatherized and mobile home electric furnace/modular blower furnace fans represent 10 percent of all furnace fan sales. According to ASAP,

et al.,

excluding modular blowers from the scope of coverage would not only reduce energy savings from this rulemaking, but would also create a loophole—

i.e.,

manufacturers would have an incentive to sell electric furnaces as modular blowers (without strip heat installed) in order to avoid compliance with the furnace fan energy conservation standards. (ASAP,

et al.,

No. 105 at pp. 1, 2)

As stated above, DOE maintains its interpretation that the relevant statutory language at 42 U.S.C. 6295(f)(4)(D) is broader in its applicability than just furnaces, and consequently, it provides DOE authority to cover modular blowers in this rulemaking. These same arguments were already addressed in some detail in the NOPR (see 78 FR 64068, 64081 (Oct. 25, 2013)). DOE also disagrees with the contention of AHRI and Johnson Controls that the final test procedure is not sufficient to address all modular blowers. All modular blower models of which DOE is aware can be operated in conjunction with an electric resistance heat kit, and commenters did not identify any models of modular blowers that cannot. Even assuming

arguendo

that modular blowers do exist that are not designed to operate with an electric resistance heat kit, DOE expects that number of such models would be

de minimis

and that manufacturers producing modular blowers that cannot be operated in conjunction with an electric resistance heat kit would apply for a waiver from the test procedure. DOE provides more details regarding this issue in the January 3, 2014 test procedure final rule. 79 FR 504.

In its comments, Johnson Controls stated that DOE's use of the phrase “primary heat source” is too ambiguous, especially when certain products might be modified in the field. According to Johnson Controls, DOE's characterizations of air handlers and modular blowers when an air handler or modular blower is the primary heating source is still confusing and brings uncertainty to the NOPR market assessment. Johnson Controls commented that none of the residential air handlers, modular blowers, or residential single-package finished good models built by Johnson Controls includes factory-installed electric heat kits. Therefore, according to the commenter, electric heat kits installed in these products cannot be considered to be the primary source for heat in their applications, and so none of these products should be included in this rulemaking. Johnson Controls added that while field-installed electric heat kits are available and used frequently, the use of field kits is outside of the air handler or modular blower manufacturer's control, unlike gas furnaces where the application is known to usually be the primary heating source in the vast number of situations. (Johnson Controls, No. 95 at p. 2) NEEA, Mortex, and Daikin agreed that the contractor determines whether a CAC/HP blower-coil unit with electric resistance heat is the principal source of heating for a residence, rendering any such determination speculative for other entities. (NEEA, NOPR Public Meeting Transcript, No. 91 at pp. 64-65; Mortex, NOPR Public Meeting Transcript, No. 91 at pp. 78-79; and Daikin, NOPR Public Meeting Transcript, No. 91 at pp. 75-76)

Modular blowers are not a source of heat per DOE's definition of “modular blower” as provided in 10 CFR part 430, subpart B, appendix AA. Consequently, the “principal heating source” qualifier (per the definition of “furnace” at 10 CFR 430.2) does not apply to modular blowers, so this part of the “furnace” definition has the effect of excluding modular blowers from that definition. However, the “furnace” definition is not the only factor in deciding whether modular blowers are covered in this rulemaking, contrary to what Johnson Controls suggests. If electric resistance heat is added to a modular blower product, that product no longer meets DOE's definition of a “modular blower.” Instead, DOE considers the modified product an electric furnace, absent other design changes. Regardless of whether the electric resistance heat is factory-installed, both product variations are covered in the final test procedure and this energy conservation standard.

DOE recognizes that interested parties may have trouble determining whether a CAC/HP blower-coil unit with electric resistance heating is considered an electric furnace and thereby covered by the energy conservation standards established by this final rule. Strictly following the DOE definition for “electric furnace” (which references the DOE definition of “furnace”) as set forth at 10 CFR 430.2, coverage in this final rule of a CAC/HP blower-coil with electrical resistance heating depends on whether the electric resistance heating is the “principal heating source for the residence.” As Johnson Controls points out, this is not as easily determined as for gas and oil furnaces. DOE expects that in the significant majority of CAC/HP blower-coil models that have electric resistance heat, the electric resistance heat is supplemental in nature and not the principal heating source for the residence. For this reason, DOE has decided that the energy conservation standards established by this rule will not cover CAC/HP blower-coil units, regardless of whether they include electric resistance heat.

Lennox argued that including weatherized commercial products in this rulemaking is unrealistic and improper. Specifically, Lennox expressed concerns that DOE mischaracterizes single-package weatherized products as “residential” when these products are offered with a single-phase power source. The commenter stated that these products are often used in commercial applications, explaining that single-phase weatherized products are often designed to have higher duct static pressure capability than a traditional residential furnace. Lennox commented that they have single-phase belt-drive products that are capable of operating up to 2 inches water column external static pressure to meet commercial duct static requirements. According to Lennox, BPM motors (including both constant-torque and constant-airflow BPM motors) typically used in residential products cannot achieve the high static pressures required in these commercial installations. Therefore, Lennox recommended that DOE should exclude all products marked not for residential use from standards coverage. (Lennox, No. 100 at p. 4).

DOE recognizes that industry may differentiate between residential products and commercial equipment differently than DOE. The standards

established by this final rule do not cover all single-phase, single-package HVAC products, only single-phase weatherized furnaces (

i.e.,

single-phase, single-package HVAC products that include a “furnace” as defined at 10 CFR 430.2). Lennox did not identify, and after additional research, DOE is not aware of any weatherized gas furnace models that operate at the static pressures mentioned by the commenter. DOE expects that the operating conditions mentioned by Lennox are typical of single-package heat pump equipment, which is not covered by this rule. DOE expects the number of models covered by this rule that DOE defines as residential but are designed and operated in commercial applications to be

de minimis.

Any manufacturer which can substantiate its case that it would suffer serious hardship, gross inequity, and an unfair distribution of burdens if required to comply with the furnace fan standards may seek exception relief from DOE's Office of Hearings and Appeals (OHA).

For information about obtaining exception relief, see 10 CFR part 1003 (available at

http://www.ecfr.gov/cgi-bin/text-idx?SID=d95bf6ed9cd849253fab734656f80c2e&node=10:4.0.3.5.3&rgn=div5

ACEEE commented that if manufacturers offered air handlers as a separate product, without the coil, the modified product would not be inherently different than a modular blower. ACEEE stated that DOE should cover CAC/HP blower-coil units following the same logic that DOE used to justify covering modular blowers (

i.e.,

because of their similarities to electric furnaces). ACEEE also commented that the DOE definition for “modular blower” is confusing because, in their experience, all (or almost all) conventional indoor blower units—whether furnaces, HP, or CAC—use a separate assembly (or field-fabricated `plenum') to house the coil used as the evaporator (CAC) or evaporator and condenser (HP). (ACEEE, No. 94 at pp. 1-2, 4).

DOE disagrees with ACEEE's assessment that a CAC/HP blower-coil unit with the coil removed and an electric furnace are equally comparable to a modular blower. For example, modular blowers are typically designed to accommodate the addition of electric resistance heating kits (after which DOE would consider them as electric furnaces) without modifying the product envelope. Modular blower envelope dimensions are similar, and in many cases identical, to electric furnace dimensions as a result. In addition, the final test procedure requires an electric resistance heat kit to be installed in modular blowers to produce a temperature rise allowing for calculation of airflow for the rating metric, FER. The test configurations for electric furnaces and modular blowers are almost identical as a result. In turn, the FER values for an electric furnace and modular blower with no other design difference other than the presence of an electric resistance heat kit are expected to be approximately equivalent. On the other hand, the coils typically included in CAC/HP blower-coil units are larger than heat resistance kits. Consequently, blower-coil unit envelope dimensions are different than modular blower dimensions, which impacts fan performance. CAC/HP blower-coil unit design, as it relates to fan performance, cannot be compared to modular blower design for this reason. The final test procedure does not include methods for deriving an FER value for CAC/HP blower-coil units. Furthermore, the coil and envelope dimension differences mentioned would preclude the circulation fan performance of a CAC/HP blower-coil unit from being deemed equivalent to an otherwise similarly-designed modular blower. In addition, modular blowers and electric furnaces are product configurations installed in the field. DOE doubts that a CAC/HP blower-coil unit with the coil removed would be offered by manufacturers or purchased and installed in the field. Regarding the criticism of its definition of “modular blower,” DOE recognizes that the definition for “modular blower” as set forth at 10 CFR part 430, subpart B, appendix AA may be confusing because it does not explicitly state that a modular blower does not include an indoor refrigerant coil, only that it does not provide heating or cooling. An “indoor unit,” on the other hand, is defined at 10 CFR 430.2 as containing a “coil.” This notice modifies the definition of “modular blower” to explicitly exclude products that contain an indoor refrigerant coil in order to eliminate ambiguity between the two definitions.

ACEEE, Earthjustice, and CA IOU stated that DOE's decision to exclude products such as CAC/HP and hydronic air handlers is inappropriate and in conflict with DOE's interpretation of the statutory language. These interested parties also commented that DOE does not provide a justification for its decision to exclude products for which DOE claims to have authority to set energy conservation standards. (ACEEE, No. 94 at pp. 1-2, 4; and CA IOU, No. 106 at pp. 1, 2) According to Earthjustice, DOE's decision to exclude products for which it claims authority to cover represents a failure to carry out EPCA's command to adopt “standards for electricity used for purposes of circulating air through ductwork” and does not comply with the statute's requirement that standards “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). Earthjustice adds that EPCA authorizes DOE not to prescribe an amended or new standard for a type or class of covered product in three situations: (1) The standard will eliminate certain product features from the market; (2) the standard will not result in significant conservation of energy or is not technologically feasible or economically justified; or (3) for certain products, test procedures have not been established. (42 U.S.C. 6295(o)(3) and (4)). Earthjustice states that DOE has failed to show that the products it is not addressing in this rule meet those criteria. (Earthjustice, No. 101 at p. 1).

ASAP,

et al.

encouraged DOE to adopt standards and/or test procedure changes to drive improved efficiency of furnace fans that are part of single-package and blower-coil central air conditioners and heat pumps in the future. According to ASAP,

et al.,

CA IOU and ACEEE, the operating conditions and metrics used in the DOE test procedures for CAC/HP (

i.e.,

SEER and HSPF) are insufficient for representing furnace fan performance in the field for those products. (ASAP,

et al.,

No. 105 at pp. 2, 3; CA IOU, No. 106 at pp. 1, 2; and ACEEE, No. 94 at pp. 1-2, 4). Further, ASAP,

et al.

are concerned that heat pump indoor units will increasingly be installed and operated as electric furnaces (without an outdoor unit) to avoid both the DOE standard for CAC/HP and the standards established by this rule. ASAP,

et al.

added that consumers will have greater incentive to install heat pump indoor units to operate as electric furnaces if a heat pump indoor unit with a PSC motor is less expensive than an electric furnace/modular blower with a constant-torque BPM motor. (ASAP,

et al.,

No. 105 at pp. 2, 3) Earthjustice also identified CAC/HP blower-coil units installed without an outdoor unit and operated as an electric furnace as a potential loophole. (Earthjustice, No. 101 at p. 1) While ASAP,

et al.,

stated that they recognize that it may be too late to include furnace fans that are part of single-package and blower-coil central air conditioners and heat pumps in the scope of coverage in the current rulemaking, they encourage

DOE to address furnace fan efficiency in these products in the future through one of two options: (1) Amend the test procedures for central air conditioners and heat pumps to incorporate more realistic external static pressure values; or (2) include furnace fans that are part of single-package and blower-coil central air conditioners and heat pumps in a future rulemaking for furnace fans. ASAP,

et al.,

submitted that if DOE pursued the second option, changing the external static pressure values in the central air conditioner and heat pump test procedures would be less critical, because fan efficiency would be addressed through standards for furnace fans. (ASAP,

et al.,

No. 105 at pp. 2, 3) CA IOU also expressed support for a separate, expedited rulemaking to set energy conservation standards for products not addressed in this rule. CA IOU claims that such a rule would ensure that the entire market for furnace fans is regulated, thereby avoiding the negative market impacts due to the prevalence of unregulated products. (CA IOU, No. 106 at pp. 1, 2). NEEA and NPCC also expressed disappointment that DOE is choosing to cover only two-thirds of furnace fan products by excluding indoor blower/cool units used with split system heat pump and air conditioning systems and hydronic air handlers, which leaves substantial energy savings on the table. (NEEA and NPCC, No. 96 at p. 3). ACEEE estimated that approximately two quads of potential cumulative energy savings are left uncaptured by DOE's decision to exclude CAC/HP blower-coil units, which ACEEE claims could jeopardize achievement of the Administration's goal of 3 billion tons of CO

avoided. (ACEEE, No. 94 at p. 1-2, 4). CA IOU cited these potential energy savings as another reason that a separate, expedited rulemaking is warranted. (CA IOU, No. 106 at pp. 1, 2). Laclede, APGA, and AGA also recommended that DOE expand the scope of this rule to include products such as split-system central air conditioners, heat pump air handlers, through-the-wall air handlers, and small-duct high-velocity air handlers that compete with the types of natural gas furnaces covered by this rules. Each cited concerns that DOE's decision to exclude fans used in these products could lead to fuel switching. (Laclede, No. 89 at p. 2; APGA, No. 90 at p. 2; and AGA, No. 110 at p. 2). Laclede believes the Department failed to adequately explain why fans in heat pumps are excluded and to clearly demonstrate how this exclusion serves the best interests of the American public.

EEI, on the other hand, supports DOE's exclusion of CAC/HP blower-coils and hydronic air handlers from this rulemaking. EEI commented that the energy used by the fans operating in the cooling mode is part of the calculation of SEER, EER, and HSPF. EEI explains that manufacturers have already made design decisions that reduce the energy usage of such fans for these systems to meet the higher air conditioner and heat pump energy conservation standards (based on SEER and HSPF) that took effect in 1992 and 2006, and will take effect in 2015. EEI stated that including these fans in this rule would be a form of “double regulation” of the same product. (EEI, No. 87 at p. 3) Southern Company agreed that CAC/HP fan energy is already covered by the SEER and HSPF rating. (Southern Company, NOPR Public Meeting, No. 43 at p. 70).

As explained previously, DOE has noted the relatively broad scope of the language of 42 U.S.C. 6295(f)(4)(D), which provides DOE authority to regulate “electricity used for purposes of circulating air through duct work.” At the present time, however, DOE is only adopting energy conservation standards for those circulation fans that are used in residential furnaces and modular blowers. The DOE test procedure for furnace fans is not currently equipped to address fans contained in central air conditioners, heat pumps, or other products, as would be required for the adoption of standards under 42 U.S.C. 6295(o)(3). Consequently, DOE is not considering standard setting for other products beyond the current scope of the rulemaking at this time.

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).

Mobile Home Weatherized Gas Furnace Fan (MH-WG).

Mobile Home Weatherized Oil Furnace Fan (MH-WO).

Mobile 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).

Mobile 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).

Mobile Home Heat/Cool Hydronic Air Handler Fan (MH-HAH-HC).

Mobile Home Heat-Only Hydronic Air Handler Fan (MH-HAH-H).

Mobile Home Hydronic Air Handler Fan with Coil (MH-HAH-C).

Mobile Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC)

Mobile Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)

Mobile Home Electric Furnace/Modular Blower Fan (MH-EF/MB)

Manufacturers agreed that the selected key product classes are an accurate representation of the market. Some manufacturers 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.

In the NOPR, DOE agreed with manufacturers' assertion that the additional non-key product classes represent products with few and in many cases, no shipments. 78 FR 64082. Individual discussions with manufacturers for the MIA confirmed this assertion. Additionally, review of the AHRI appliance directory revealed that only two of the additional non-key product classes have active models listed: (1) Mobile home weatherized gas furnace fans (MH-WG) and (2) mobile 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 proposed in the NOPR to eliminate the additional non-key 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 proposed to reserve space to establish standards for MH-WG and MH-NWO furnace fans in the future as sufficient data become available. DOE also proposed to exclude hydronic air handlers from consideration in this rulemaking, thereby further reducing the number of product classes addressed in the NOPR to 10. 78 FR 64082. Table IV.2 includes a list of the revised set of product classes for residential furnace fans used in the NOPR.

DOE did not receive comment or additional information on the proposed product classes, thus, DOE is not making changes to the product classes in this Final Rule. Table IV.2 includes a list of the product classes for residential furnace fans used in the Final Rule.

Table IV.2—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)

Mobile Home Non-Weatherized, Non-Condensing Gas Furnace Fan (MH-NWG-NC)

Mobile Home Non-Weatherized, Condensing Gas Furnace Fan (MH-NWG-C)

Mobile Home Electric Furnace/Modular Blower Fan (MH-EF/MB)

Mobile Home Weatherized Gas Furnace Fan (MH-WG)

Mobile 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 energy 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. In the NOPR, DOE revised its proposed scope of coverage to no longer address hydronic air handlers, the only furnace fan product class for which standby mode and off mode energy consumption is not already fully accounted for in the DOE energy conservation standards rulemakings for residential furnaces and residential CAC and HPs. 76 FR 37408 (June 27, 2011); 76 FR 67037 (Oct. 31, 2011). Consequently, the standby mode and off mode technology options (options 5 through 7 in the list above) are no longer applicable. In addition, DOE found that multi-staging and modulating heating controls can also improve FER, so DOE evaluated multi-staging and modulating heating controls as a separate technology option for the NOPR. 78 FR 64083.

DOE did not receive comment or additional information regarding the evaluated technology options, so DOE did not make any changes to the list of technology options identified in the NOPR. The resultant list of technology options identified to be evaluated in the screening analysis before consideration in the engineering analysis for the Final Rule 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 Final Rule TSD.

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

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.

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.

Interested parties expressed support for DOE's consideration of the aerodynamics of furnace fan cabinets in its initial analysis of technology options. In particular, ASAP cited a 2003 GE study

that quantified energy savings produced by modifying fan housing as justification for its inclusion as an option. ACEEE,

et al.

also cited a Lawrence Berkeley National Laboratory (LBNL) study

that linked changes in efficiency to modifying the clearance between fan housing and an air handler cabinet wall. Ingersoll Rand stated that 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. 78 FR 64083.

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

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. 78 FR 64083.

Many interested parties requested that DOE keep airflow path design as a technology option. Manufacturers stated that improving airflow path design, like modifying fan housing, is highly cost-effective when compared to other enhancements. 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. 78 FR 64083. DOE believes including airflow path design is appropriate because of its potential to impact fan efficiency. Airflow path design will impact the rating metric, FER, because the DOE test procedure requires the furnace fan to be tested as it is factory-installed in the HVAC product.

DOE did not receive comment or additional information on fan housing about including airflow path design improvements as a technology option, thus, DOE is including these as technologies to be evaluated further in the screening analysis. Chapter 3 of the Final Rule TSD provides more technical detail regarding fan housing and airflow path design modifications and how these measures could reduce furnace fan energy consumption.

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. Manufacturers commented that there are alternate, more cost-effective solutions to reduce energy consumption for air-moving systems, such as airflow path design or ECM (referred to herein by DOE as a “constant-airflow BPM motor”) technology. 78 FR 64084.

For the NOPR analysis, DOE recognized 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. 78 FR 64084.

DOE did not receive comment or additional information on including inverter controls for PSC motors as a technology option, thus, DOE is including this technology option in the Final Rule. DOE evaluates in the engineering analysis the cost-effectiveness of all energy-saving technology options that are not screened out. Chapter 3 of the Final Rule TSD provides a more detailed discussion of inverter-driven PSC furnace fan motors.

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”).

DOE finds that furnace fans using high-efficiency motor technology options operate more efficiently than furnace fans using baseline PSC motors by:

“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

(

i.e.,

ratio of airflow in lowest setting to airflow in highest setting).

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, PA Public Meeting Transcript, No. 43 at p. 67)

For the NOPR analysis, DOE stated that it 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).

DOE agreed 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 found 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). 78 FR 64084. 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 rating metric, FER, is normalized by airflow to result in ratings that are in units of watts/cfm. DOE believed 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.

See chapter 3 of the TSD for more details regarding fan operation.

As detailed in the NOPR, interested parties recognized the benefits provided by constant-torque and constant-airflow BPM motors. Interested parties also 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. 78 FR 64084. Table IV.3 contains the turndown ratio estimates supplied publicly by interested parties. Manufacturers generally provided similar feedback during interviews.

Table IV.3—Interested Party Estimated Fan Motor Turndown Ratios

Interested party

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 disagreed with Lennox that including constant circulation as part of FER would “artificially” inflate the performance of BPM motors compared to PSC motors, because DOE concluded that there is non-trivial use of this mode by consumers. 78 FR 64085. As part of the test procedure rulemaking, DOE estimated 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 Final Rule published on January 3, 2014. 79 FR 499.

DOE did not receive comment or additional information on including high-efficiency motors as a technology option, thus, DOE is including this technology option in the Final Rule. DOE evaluates in the engineering analysis the cost-effectiveness of all energy-saving technology options that are not screened out. Chapter 3 of the Final Rule TSD provides a more detailed discussion of high-efficiency furnace fan motors.

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.

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.

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

Interested parties encouraged DOE to consider X13-level motors applied with multi-stage furnace controls as a technology option. 78 FR 64085. During interviews, manufacturers commented that multi-stage heating controls can be and are used regardless of motor type.

Based on comments from manufacturers, DOE recognized that multi-stage controls can be paired with other motor types, not just constant-airflow BPM motors. DOE agreed with interested parties that implementing multi-stage heating controls independent of motor type could result in residential furnace fan efficiency improvements. Consequently, DOE decided to de-couple multi-staging controls from the constant-airflow BPM motor technology option. Accordingly, DOE evaluated multi-staging controls as a separate technology option for the NOPR. 78 FR 64085.

DOE did not receive comment or additional information on multi-staging controls as a technology option, thus, DOE is including this technology option in the Final Rule.

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 (GE) that showed large improvements in efficiency were achievable under certain operating conditions.

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

Interested parties 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. 78 FR 64085. 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).

DOE recognized 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

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