Energy Conservation Program: Energy Conservation Standards for Ceiling Fans
Federal RegisterJan 19, 2017
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2012-BT-STD-0045]
RIN 1904-AD28
Energy Conservation Program: Energy Conservation Standards for Ceiling Fans
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Final rule.
SUMMARY:
The Energy Policy and Conservation Act of 1975 (EPCA), as amended, prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including ceiling fans. EPCA also requires the U.S. Department of Energy (DOE) to periodically determine whether more-stringent standards would be technologically feasible and economically justified, and would save a significant amount of energy. In this final rule, DOE amends the energy conservation standards for ceiling fans. It has determined that the amended 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 March 20, 2017. Compliance with the amended standards established for ceiling fans in this final rule is required on and after January 21, 2020.
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
https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=5
. The docket web page contains instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Lucy deButts at: (202) 287-1604 or by e-mail:
ApplianceStandardsQuestions@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Lucy deButts, 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) 287-1604. E-mail:
ApplianceStandardsQuestions@ee.doe.gov
.
Elizabeth Kohl, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-7796. E-mail:
Elizabeth.Kohl@hq.doe.gov
.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis 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 Ceiling Fans
III. General Discussion
A. Product Classes and Scope of Coverage
1. Scope of Coverage
2. Product Classes
B. Test Procedure
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Product Classes
2. Technology Options
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. Standard and Hugger Ceiling Fans
2. VSD and HSSD Ceiling Fans
3. Large-Diameter Ceiling Fans
4. Reducing Fan Speed to Improve Efficiency
5. Standard Level Equations
D. Markups Analysis
E. Energy Use Analysis
1. Inputs for Standard, Hugger, and VSD Ceiling Fans
a. Sample of Purchasers
b. Operating Hours
c. Power Consumption at Each Speed and Standby
2. Inputs for Large-Diameter and High-Speed Small-Diameter Ceiling Fans
a. Sample of Purchasers
b. Operating Hours
c. Power Consumption at Each Speed and Standby
3. Impact on Air Conditioning or Heating Equipment Use
F. Life-Cycle Cost and Payback Period Analysis
1. Purchase Price
2. Electricity Prices
3. Electricity Price Trends
4. Repair Costs
5. Product Lifetime
6. Discount Rates
7. Efficiency and Blade Span Distribution in the No-New-Standards Case
8. Payback Period Analysis
G. Shipments Analysis
1. Shipments Demand Model
2. Stock-Accounting Model
3. Market-Share Projections
4. Price Trend
5. Impact of a Standard on Shipments
H. National Impact Analysis
1. National Energy Savings
2. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
a. Capital and Product Conversion Costs
b. Manufacturer Production Costs
c. Shipment Scenarios
d. Markup Scenarios
3. Discussion of Comments
4. Manufacturer Interviews
a. Shift to Air Conditioning
b. Testing Burden
c. Utility of Brushless DC Motors for Residential Consumers
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
2. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Ceiling Fan Standards
2. Summary of Annualized Benefits and Costs of the Adopted Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Need for, and Objectives of, the Rule
2. Significant Comments in Response to the IRFA
3. Comments Filed by the Chief Counsel for Advocacy
4. Description and Estimate of the Number of Small Entities Affected
5. Description of Compliance Requirements
6. Significant Alternatives Considered and Steps Taken to Minimize Significant Economic Impacts on Small Entities
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. Synopsis of the Final Rule
Title III, Part B
1
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309), established the Energy Conservation Program for Consumer Products Other Than Automobiles.
2
These products include ceiling fans, which are the subject of this rulemaking.
1
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.
2
All references to EPCA in this document refer to the statute as amended through the Energy Efficiency Improvement Act of 2015, Public Law 114-11 (April 30, 2015).
Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B))
In accordance with these and other statutory provisions discussed in this document, DOE is adopting amended energy conservation standards for ceiling fans. The amended standards, which are expressed for each product class as the minimum allowable efficiency in terms of cubic feet per minute per watt (CFM/W), as a function of ceiling fan diameter in inches, are shown in Table I.1. These standards would apply to all ceiling fans listed in Table I.1 and manufactured in, or imported into, the United States on and after January 21, 2020.
Table I.1—Energy Conservation Standards for Ceiling Fans
[Compliance starting January 21, 2020]
Product class
Minimum efficiency
equation
CFM/W *
Very Small-Diameter (VSD)
D ≤ 12 in.: 21
D > 12 in.: 3.16 D−17.04
Standard
0.65 D + 38.03
Hugger
0.29 D + 34.46
High-Speed Small-Diameter (HSSD)
4.16 D + 0.02
Large Diameter
0.91 D −30.00
* D is the ceiling fan's blade span, in inches, as determined in Appendix U.
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the adopted standards on consumers of ceiling fans, as measured by the average life-cycle cost (LCC) savings and the simple payback period (PBP).
3
The average LCC savings are positive for all product classes, and the PBP is less than the average lifetime of ceiling fans, which is estimated to be 13.8 years for all product classes (see section IV.F.5).
3
The average LCC savings are measured relative to the efficiency distribution in the no-new-standards case, which depicts the market in the compliance year in the absence of standards (see section IV.F.7). The simple PBP, which is designed to compare specific ceiling fan efficiency levels, is measured relative to the baseline product (see section IV.C), which corresponds to the least efficient model available to purchase.
Table I.2—Impacts of Amended Energy Conservation Standards on Consumers of Ceiling Fans
Product class
Average LCC savings *
(2015$)
Simple payback period
(years)
Standard
25.78
1.7
Hugger
21.50
1.8
Very Small-Diameter
4.29
9.3
High-Speed Small-Diameter
19.80
6.9
Large-Diameter
128.90
4.1
* The calculation excludes consumers with zero LCC savings (no impact).
DOE's analysis of the impacts of the adopted standards on consumers is described in section IV.F of this document.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted cash flows to the industry from the reference year through the terminal year of the analysis period (2016-2049). Using a real discount rate of 7.4 percent, DOE estimates that the INPV for manufacturers of ceiling fans in the case without amended standards is $1,211.6 million in 2015$. Under the adopted standards, DOE expects that manufacturers may lose up to 9.9 percent of this INPV, which is approximately $119.4 million.
DOE's analysis of the impacts of the adopted standards on manufacturers is described in section IV.J of this document.
C. National Benefits and Costs
4
4
All monetary values in this document are expressed in 2015 dollars and, where appropriate, are discounted to 2016 unless explicitly stated otherwise.
DOE's analyses indicate that the adopted energy conservation standards for ceiling fans would save a significant amount of energy. Relative to the case without amended standards (referred to as the “no-new-standards case”), the lifetime energy savings for ceiling fans
purchased in the 30-year period that begins in the anticipated first full year of compliance with the amended standards (2020-2049), amount to 2.008 quadrillion British thermal units (Btu), or quads.
5
This represents a total energy savings of 26 percent across all product classes relative to the energy use of these products in the no-new-standards case.
5
The quantity refers to full-fuel-cycle (FFC) energy savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and, thus, presents a more complete picture of the impacts of energy efficiency standards. For more information on the FFC metric, see section IV.H.1.
The cumulative net present value (NPV) of total consumer costs and savings of the standards for ceiling fans ranges from $4.488 billion (at a 7-percent discount rate) to $12.123 billion (at a 3-percent discount rate). This NPV expresses the estimated total value of future operating-cost savings minus the estimated increased product costs for ceiling fans purchased in 2020-2049.
In addition, the standards for ceiling fans are projected to yield significant environmental benefits. DOE estimates that the standards would result in cumulative greenhouse gas emission reductions (over the same period as for energy savings) of 120.2 million metric tons (Mt)
6
of carbon dioxide (CO
2
), 64.0 thousand tons of sulfur dioxide (SO
2
), 222.6 thousand tons of nitrogen oxides (NO
X
), 530.1 thousand tons of methane (CH
4
), 1.3 thousand tons of nitrous oxide (N
2
O), and 0.2 tons of mercury (Hg).
7
The cumulative reduction in CO
2
emissions through 2030 amounts to 18.2 Mt, which is equivalent to the emissions resulting from the annual electricity use of more than 1.9 million homes.
6
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
are presented in short tons.
7
DOE calculated emissions reductions relative to the no-new-standards-case, which reflects key assumptions in the
Annual Energy Outlook 2015
(
AEO 2015
).
The value of the CO
2
reductions is calculated using a range of values per metric ton (t) of CO
2
(otherwise known as the “Social Cost of Carbon”, or SCC) developed by a Federal interagency working group.
8
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
2
emissions reduction (not including CO
2
equivalent emissions of other gases with global warming potential) is between $0.8 billion and $11.7 billion, with a value of $3.8 billion using the SCC central value case represented by $40.6/metric ton (t) in 2015. DOE also estimates that the present monetary value of the NO
X
emissions reduction to be $0.2 billion at a 7-percent discount rate, and $0.4 billion at a 3-percent discount rate.
9
DOE is investigating appropriate valuation of the reduction in other emissions, and did not include any values for other emissions in this rulemaking.
8
United States Government-Interagency Working Group on Social Cost of Carbon.
Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866.
May 2013. Revised July 2015. Available at
https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf
.
9
DOE estimated the monetized value of NO
X
emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule,
published in August 2015 by EPA's Office of Air Quality Planning and Standards. Available at
www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.
See section IV.L.2 for further discussion.
On February 9, 2016, the U.S. Supreme Court stayed the rule implementing the Clean Power Plan
pending disposition of the applicants' petitions for review in the United States Court of Appeals for the District of Columbia Circuit and disposition of the applicants' petition for a writ of certiorari, if such writ is sought.
Chamber of Commerce, et al.
v.
EPA, et al.,
Order in Pending Case, available at
http://www.chamberlitigation.com/sites/default/files/scotus/files/2016/SCOTUS%20Order%20Granting%20U.S.%20Chamber%2C%20et%20al.%20Stay%20Application%20—%20States%20of%20West%20Virginia%2C%20Texas%2C%20et%20al.%20v.%20EPA%20%28ESPS%29.pdf
(last visited June 22, 2016). Pending the outcome of that litigation, DOE continues to use the benefit-per-ton estimates established in the Regulatory Impact Analysis for the Clean Power Plan. To be conservative, DOE is primarily using a national benefit-per-ton estimate for NO
X
emitted from the Electricity Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski
et al.
2009). If the benefit-per-ton estimates were based on the Six Cities study (Lepuele
et al.
2011), the values would be nearly two-and-a-half times larger.
Table I.3 summarizes the economic benefits and costs expected to result from the adopted standards for ceiling fans.
Table I.3—Selected Categories of Economic Benefits and Costs of Amended Energy Conservation Standards for Ceiling Fans *
Category
Present value
(billion 2015$)
Discount rate
(%)
Benefits
Consumer Operating Cost Savings
7.0
16.5
7
3
CO
2
Reduction (using mean SCC at 5% discount rate) **
0.8
5
CO
2
Reduction (using mean SCC at 3% discount rate) **
3.8
3
CO
2
Reduction (using mean SCC at 2.5% discount rate) **
6.1
2.5
CO
2
Reduction (using 95th percentile SCC at 3% discount rate) **
11.7
3
NO
X
Reduction †
0.2
0.4
7
3
Total Benefits ‡
11.0
20.7
7
3
Costs
Consumer Incremental Installed Costs
2.5
4.4
7
3
Total Net Benefits
Including CO
2
and NO
X
Reduction Monetized Value ‡
8.5
16.3
7
3
* This table presents the costs and benefits associated with ceiling fans shipped in 2020-2049. These results include benefits to consumers which accrue after 2049 from the products purchased in 2020-2049. The incremental installed costs include incremental equipment cost as well as installation costs. The CO
2
reduction benefits are global benefits due to actions that occur nationally.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. For example, for 2015 emissions, these values are $12.4/t, $40.6/t, and $63.2/t, in 2015$, respectively. The fourth set ($118/t in 2015$ for 2015 emissions), which represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change further out in the tails of the SCC distribution. The SCC values are emission year specific. See section IV.L.1 for more details.
† DOE estimated the monetized value of NO
X
emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule,
published in August 2015 by EPA's Office of Air Quality Planning and Standards. (Available at
www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis
.) See section IV.L.2 for further discussion. To be conservative, DOE is primarily using a national benefit-per-ton estimate for NO
X
emitted from the Electricity Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski
et al.
2009). If the benefit-per-ton estimates were based on the Six Cities study (Lepuele
et al.
2011), the values would be nearly two-and-a-half times larger.
‡ Total Benefits for both the 3-percent and 7-percent cases are presented using only the average SCC with 3-percent discount rate.
The benefits and costs of the adopted standards, for ceiling fans sold in 2020-2049, can also be expressed in terms of annualized values. The monetary values for the total annualized net benefits are the sum of (1) the national economic value of the benefits in reduced consumer operating costs, minus (2) the increases in product purchase prices and installation costs, plus (3) the value of the benefits of CO
2
and NO
X
emission reductions, all annualized.
10
10
To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2016, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE calculated a present value associated with each year's shipments in the year in which the shipments occur (
e.g.,
2020 or 2030), and then discounted the present value from each year to 2016. The calculation uses discount rates of 3 and 7 percent for all costs and benefits except for the value of CO
2
reductions, for which DOE used case-specific discount rates, as shown in Table I.3. Using the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in the compliance year,that yields the same present value.
The national operating cost savings are domestic private U.S. consumer monetary savings that occur as a result of purchasing the covered products. The national operating cost savings is measured for the lifetime of ceiling fans shipped in 2020-2049. The CO
2
reduction is a benefit that accrues globally due to decreased domestic energy consumption that is expected to result from this rule. Because CO
2
emissions have a very long residence time in the atmosphere, the SCC values in future years reflect future CO
2
-emissions impacts that continue beyond 2100.
Estimates of annualized benefits and costs of the adopted 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
2
reduction, (for which DOE used a 3-percent discount rate along with the SCC series that has a value of $40.6/t in 2015),
11
the estimated annualized cost of the standards in this rule is $245.1 million per year in increased equipment costs, while the estimated annualized benefits are $688.1 million in reduced equipment operating costs, $214.1 million in CO
2
reductions, and $15.1 million in reduced NO
X
emissions. In this case, the annualized net benefit amounts to $672.2 million per year. Using a 3-percent discount rate for all benefits and costs and the SCC series has a value of $40.6/t in 2015, the estimated cost of the standards is $243.2 million per year in increased equipment costs, while the estimated annualized benefits are $919.0 million in reduced operating costs, $214.1 million in CO
2
reductions, and $21.5 million in reduced NO
X
emissions. In this case, the annualized net benefit amounts to $911.4 million per year.
11
DOE used a 3-percent discount rate because the SCC values for the series used in the calculation were derived using a 3-percent discount rate (see section IV.L).
Table I.4—Selected Categories of Annualized Benefits and Costs of Amended Standards for Ceiling Fans *
Discount rate
Primary estimate
Low-net-benefits estimate
High-net-benefits estimate
(million 2015$/year)
Benefits
Consumer Operating Cost Savings
7%
688.1
579.7
793.5
3%
919.0
764.2
1081.9
CO
2
Reduction (using mean SCC at 5% discount rate) **
5%
62.8
53.7
71.0
CO
2
Reduction (using mean SCC at 3% discount rate) **
3%
214.1
182.2
242.6
CO
2
Reduction (using mean SCC at 2.5% discount rate) **
2.5%
314.2
267.2
356.3
CO
2
Reduction (using 95th percentile SCC at 3% discount rate) **
3%
652.7
555.4
739.8
NO
X
Reduction
†
7%
15.1
13.1
38.1
3%
21.5
18.4
55.3
Total Benefits
‡
7% plus CO
2
range
766 to 1,356
647 to 1,148
903 to 1,571
7%
917.3
775.0
1,074.2
3% plus CO
2
range
1,003 to 1,593
836 to 1,338
1,208 to 1,877
3%
1,154.6
964.8
1,379.9
Costs
***
Consumer Incremental Product Costs
7%
245.1
288.1
272.8
3%
243.2
298.7
273.7
Net Benefits
Total
‡
7% plus CO
2
range
521 to 1,111
358 to 860
630 to 1,299
7%
672.2
487.0
801.4
3% plus CO
2
range
760 to 1,350
538 to 1,039
935 to 1,603
3%
911.4
666.1
1,106.2
* This table presents the annualized costs and benefits associated with ceiling fans shipped in 2020-2049. These results include benefits to consumers which accrue after 2049 from the ceiling fans purchased from 2020-2049. The incremental installed costs include incremental equipment cost as well as installation costs. The CO
2
reduction benefits are global benefits due to actions that occur nationally. The Primary Estimate assumes the Reference case electricity prices and housing starts from AEO 2015 and decreasing product prices for ceiling fans with DC motors, due to price trend on the electronics components. The Low Benefits Estimate uses the Low Economic Growth electricity prices and housing starts from AEO 2015 and no price trend for ceiling fans with DC motors. The High Benefits Estimate uses the High Economic Growth electricity prices and housing starts from AEO 2015 and the same product price decrease for ceiling fans with DC motors as in the Primary Estimate. The methods used to derive projected price trends are explained in section IV.G.4. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
** The CO
2
reduction benefits are calculated using 4 different sets of SCC values. The first three use the average SCC calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The fourth represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC values are emission year specific. See section IV.L.1 for more details.
†
DOE estimated the monetized value of NO
X
emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule,
published in August 2015 by EPA's Office of Air Quality Planning and Standards. (Available at
www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis
.) See section IV.L.2 for further discussion. For the Primary Estimate and Low Net Benefits Estimate, DOE used national benefit-per-ton estimates for NO
X
emitted from the Electric Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski
et al.
2009). For the High Net Benefits Estimate, the benefit-per-ton estimates were based on the Six Cities study (Lepuele
et al.
2011); these are nearly two-and-a-half times larger than those from the ACS study.
‡
Total Benefits for both the 3-percent and 7-percent cases are presented using only the average SCC with 3-percent discount rate. In the rows labeled “7% plus CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values.
*** For certain assumed design options (
e.g.,
fan optimization) that are included at the selected standard level, DOE estimated no incremental costs to consumers, but did estimate a one-time industry conversion cost to manufacturers to make their products compliant with the selected standards that are not reflected in the Consumer Incremental Product Costs. The one-time industry conversion cost to manufacturers of these design options contribute to a loss in industry net present value of $4.8 million, which is equivalent to an annualized cost of $0.4 million/year at a 7.4-percent discount rate over the analysis period.
DOE's analysis of the national impacts of the adopted standards is described in sections IV.H, IV.K, and IV.L of this notice.
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 this 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 this adopted rule, as well as some of the relevant historical background related to the establishment of standards for ceiling 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,
et seq.
) 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 ceiling fans that are the subject of this rulemaking. (42 U.S.C. 6295(ff)) EPCA, as amended, prescribes energy conservation standards for these products and authorizes DOE to consider energy efficiency or energy use standards for the electricity used by ceiling fans to circulate air in a room.
Id.
Under 42 U.S.C. 6295(m), DOE must periodically review its already established energy conservation standards for a covered product. Under this requirement, the next review that DOE would need to conduct must occur no later than 6 years from the issuance of any final rule establishing or amending a standard for a covered product. EPCA also provides that not later than 6 years after issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a notice of proposed rulemaking including new proposed energy conservation standards. (42 U.S.C. 6295(m))
Pursuant to EPCA, DOE's energy conservation program for covered products consists essentially of four parts: (1) Testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. The Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE implements the remainder of the program. Subject to certain criteria and conditions, DOE is required to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of each covered product. (42 U.S.C. 6295(o)(3)(A) and (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 ceiling fans appear at title 10 of the Code of Federal Regulations (CFR) part 430, subpart B, appendix U, 10 CFR 430.23(w) and 10 CFR 429.32.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including ceiling fans. Any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that 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 ceiling fans, if no test procedure has been established for the product, or (2) if DOE determines by rule that the standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:
(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;
(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA, 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. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA, as codified, also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States in any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
Additionally, EPCA specifies requirements when promulgating an energy conservation standard for a covered product that has two or more subcategories. DOE must specify a different standard level for a type or class of products 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)).
EPCA also requires that for any final rule for new or amended energy conservation standards promulgated after July 1, 2010, DOE must 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 amended standards DOE is adopting in this final rule incorporate standby mode and off mode energy use into a single standard.
B. Background
1. Current Standards
The Energy Policy and Conservation Act of 1975 (EPCA) defined and established design standards for ceiling fans. EPCA defined a “ceiling fan” as “a nonportable device that is suspended from a ceiling for circulating air via the rotation of fan blades.” (42 U.S.C. 6291(49)) In a final rule technical amendment published in the on October 18, 2005, DOE codified the statutorily-prescribed design standards for ceiling fans. 70 FR 60407, 60413. These standards are set forth in DOE's regulations at 10 CFR 430.32(s), and require all ceiling fans manufactured on or after January 1, 2007, to have the following features:
1. Fan speed controls separate from any lighting controls;
2. adjustable speed controls (either more than one speed or variable speed); and
3. the capability for reverse action (other than fans sold for industrial or outdoor application or where safety would be an issue)).
(42 U.S.C. 6295(ff)(1)(A) and (6))
2. History of Standards Rulemaking for Ceiling Fans
EPCA established energy conservation standards for ceiling fans as described in Section II.B.1 and authorized DOE to consider, if the requirements of 42 U.S.C. 6295(o) and (p) are met, establishing energy efficiency or energy use standards for the electricity used by ceiling fans to circulate air in a room. (42 U.S.C. 6295(ff))
As noted in section II.B.1, DOE codified the statutorily-prescribed design standards for ceiling fans in the CFR at 10 CFR 430.32(s). 70 FR 60407, 60413 (Oct. 18, 2005). DOE also adopted test procedures for ceiling fans at 10 CFR part 430, subpart B, appendix U and 10 CFR 430.23(w). 71 FR 71340, 71366-67 (Dec. 8, 2006). Sampling and certification requirements for ceiling fans are set forth at 10 CFR 429.32.
On March 15, 2013, DOE published a notice announcing the availability of the framework document, “Energy Conservation Standards Rulemaking Framework Document for Ceiling Fans and Ceiling Fan Light Kits,”
12
and a public meeting to discuss the proposed analytical framework for the energy conservation standards rulemaking. 78 FR 16643. DOE held the public meeting for the framework document on March 22, 2013,
13
to present the framework document, describe the analyses DOE planned to conduct during the rulemaking, seek comments from interested parties on these subjects, and inform them about and facilitate their involvement in the rulemaking.
12
The energy conservation standards final rule for ceiling fan light kits was published on January 6, 2016. 81 FR 580.
13
The framework document is available at
regulations.gov
under docket number EERE-2012-BT-STD-0045-0001.
On September 29, 2014, DOE published the preliminary analysis for the ceiling fan energy conservation standards rulemaking. 79 FR 58290. DOE posted the preliminary analysis, as well as the complete preliminary technical support document (TSD), on its website.
14
DOE held a public meeting on November 19, 2014, to present the preliminary analysis, which included presenting preliminary results for the engineering and downstream economic analyses, seek comments from interested parties on these subjects, and facilitate interested parties' involvement in the rulemaking.
14
The preliminary analysis, preliminary TSD, and preliminary analysis public meeting information are available at
regulations.gov
under docket number EERE-2012-BT-STD-0045-0066.
On January 13, 2016, DOE published a notice of proposed rulemaking (NOPR) for the ceiling fans energy conservation standards rulemaking (ceiling fans NOPR). 81 FR 1688. DOE posted the ceiling fans NOPR analysis, as well as the complete NOPR TSD on its Web site.
15
DOE held a public meeting on February 3, 2016 to present the ceiling fans NOPR, which included the engineering analysis, downstream economic analyses, manufacturer impact analysis, and proposed standards. In the public meeting, DOE also sought comments from interested parties on these subjects, and facilitated interested parties' involvement in the rulemaking. At the public meeting, and during the comment period, DOE received comments that helped DOE identify issues and refine the analyses presented in the ceiling fans NOPR for this final rule. The key changes since the ceiling fans NOPR were the following: (1) The engineering analysis was updated based on additional test data, and (2) the efficiency distribution in the no-new-standards case for the standard and hugger product classes was updated with significantly more market share at the lower efficiency levels based on comments from manufacturers.
15
The NOPR analysis, NOPR TSD and NOPR public meeting information are available at
regulations.gov
under docket number EERE-2012-BT-STD-0045-0130.
This final rule responds to issues raised by commenters in response to the framework document, preliminary analysis, and NOPR.
III. General Discussion
DOE developed this proposal after considering comments, data, and information from interested parties that represent a variety of interests. The following section provides general discussion of the final standards rule; section IV addresses the issues raised by these commenters.
A. Product Classes and Scope of Coverage
1. Scope of Coverage
EPCA defines a “ceiling fan” as “a nonportable device that is suspended from a ceiling for circulating air via the rotation of fan blades.” (42 U.S.C. 6291(49))
DOE previously interpreted the definition of a ceiling fan such that it excluded certain types of ceiling fans commonly referred to as hugger fans. 71 FR 71343 (Dec. 8, 2006). Hugger ceiling fans are typically understood to be set flush to the ceiling (
e.g.,
mounted without a downrod). The previous interpretation exempted hugger fans from standards on the basis that they are set flush to the ceiling. However, in the test procedure final rule for ceiling fan light kits, DOE reinterpreted the definition of a ceiling fan to include hugger fans, and clarified that the definition also included ceiling fans capable of producing large volumes of airflow. 80 FR 80209 (Dec. 24, 2015).
The changes in interpretation of the ceiling fan definition discussed above resulted in the applicability of the design standards set forth in EPCA at 42 U.S.C. 6295(ff)(1) to these fan types as of January 25, 2016. DOE research indicates that all ceiling fans currently on the market, including hugger ceiling fans and ceiling fans that produce a large volume of airflow, appear to meet the EPCA design standards. Compliance with requirements related to the ceiling fan reinterpretation was discussed in the Ceiling Fan Light Kit test procedure final rule. 80 FR 80209 (Dec. 24, 2015) Specifically, DOE will not assert civil penalty authority for violations of the applicable standards arising as a result of the reinterpretation of the ceiling fan definition before June 26, 2017.
DOE is also establishing efficiency standards for these fan types, which include hugger ceiling fans and ceiling fans that produce a large volume of airflow, in this ceiling fans final rule. Compliance with those standards, as discussed in the
DATES
section, is January 21, 2020.
Additionally, in the ceiling fan test procedure final rule, DOE provided clarification on those ceiling fans that are not subject to the test procedure. 81 FR 48620 (July 25, 2016). The test procedures do not apply to belt-driven ceiling fans, centrifugal ceiling fans, oscillating ceiling fans, or ceiling fans whose blades' plane of rotation cannot be within 45 degrees of horizontal. American Lighting Association (ALA) requested that DOE clarify that if the plane of rotation is not within 45 degrees of horizontal, the ceiling fan is not subject to DOE's proposed efficiency standards, certification requirements or labeling requirements. (ALA, No. 137 at p. 4) DOE confirms that it is not establishing performance standards for ceiling fans whose blades' plane of rotation cannot be within 45 degrees of horizontal in this final rule. The design standards set forth in EPCA at 42 U.S.C.
6295(ff) remain applicable to these fans and manufacturers must certify compliance with those design standards to DOE.
In summary, this DOE final rule is not establishing performance standards for belt-driven ceiling fans, centrifugal ceiling fans, oscillating ceiling fans, or ceiling fans whose blades' plane of rotation cannot be within 45 degrees of horizontal. DOE is also not establishing performance standards for highly decorative fans. Manufacturers must continue to submit certification reports to DOE for such fans with respect to the statutory design standards. Both DOE and manufacturers would determine whether a fan met the definition of a highly decorative fan using the final test procedure, though manufacturers would not be required to submit the supporting information, including any test data that supports their highly decorative classification as part of their certification submission to DOE. In addition, manufacturers would be required to test highly-decorative fans according to the test procedure established in the test procedure final rule to make representations of the energy efficiency of such fans (
e.g.,
for the EnergyGuide label)).
2. Product Classes
When establishing energy conservation standards, DOE divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justify differing standards. In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility of the feature to the consumer and other factors DOE determines are appropriate. (42 U.S.C. 6295(q))
Currently there are no product classes for ceiling fans, because the previous final rule for ceiling fans published on October 18, 2005 set design standards, but did not establish product classes. 70 FR 60407. In the ceiling fans NOPR, DOE proposed seven product classes and their associated definitions, which included highly-decorative, belt-driven, very small-diameter, hugger, standard, high-speed small-diameter and large-diameter fans. 81 FR 1688 (January 13, 2016). Chapter 3 of the TSD provides additional discussion on the establishment of these product classes pursuant to 42 U.S.C. 6295(q). In the ceiling fans test procedure final rule, DOE finalized the definitions for these types of ceiling fans. 81 FR 48620 (July 25, 2016). In this final rule, DOE is finalizing all seven product classes proposed in the ceiling fans NOPR. For further details on product classes, see section IV.A.1 of this rulemaking.
B. Test Procedure
EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with energy conservation standards and to quantify the efficiency of their product. (42 U.S.C. 6293, 6295(s)) Similarly, DOE must use these test procedures to determine compliance with its energy conservation standards. (42 U.S.C. 6295(s)) As noted, the test procedures for ceiling fans are provided in 10 CFR 430.23(w) and appendix U to subpart B of 10 CFR part 430. DOE published a NOPR to amend the ceiling fan test procedures on October 17, 2014, 79 FR 62521, and published a supplemental NOPR (SNOPR) on June 3, 2015. 80 FR 31487. DOE finalized the test procedure on July 25, 2016. 81 FR 48620.
With respect to the process of establishing test procedures and standards for a given product, DOE notes that, while not legally obligated to do so, it generally follows the approach laid out in guidance found in 10 CFR part 430, subpart C, Appendix A (Procedures, Interpretations and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products). That guidance provides, among other things, that DOE issues final, modified test procedures for a given product prior to publication of the NOPR proposing energy conservation standards for that product. While DOE strives to follow the procedural steps outlined in its guidance, there may be circumstances in which it may be necessary or appropriate to deviate from it. In such instances, the guidance indicates that DOE will provide notice and an explanation for the deviation. Accordingly, DOE has provided notices while it continued to develop the final test procedure for ceiling fans. DOE received comments regarding test methods for ceiling fans for which the plane of rotation of the ceiling fan's blades cannot be within 45 degrees of horizontal, high-volume small-diameter ceiling fans and ceiling fans with blade spans greater than seven feet leading to modification to test methods proposed in the NOPR. (79 FR 62521 (October 17, 2014)). DOE also received comments regarding the variability of results from the test procedures proposed in the SNOPR (80 FR 31487 (June 3, 2015)), based on testing conducted by manufacturers. Lastly, DOE conducted a thorough review of all available test data, including additional test data supplied by manufacturers, to identify opportunities to decrease testing variation.
DOE attempted to issue the final test procedure prior to the NOPR proposing energy conservation standards. However, additional time to address comments received on the NOPR and SNOPR lead to modification of the test procedure, which caused deviations from the guidance provided in 10 CFR part 430, subpart C, Appendix A.
Currently no energy efficiency performance standards exist for ceiling fans, just design standards for certain ceiling fans. In this final rule, DOE is setting energy efficiency performance standards in terms of a minimum efficiency equation established in the test procedure final rule. 81 FR 48620 (July 25, 2016). The test procedure final rule established test procedures for an integrated efficiency metric measured in cubic feet per minute per watt (CFM/W) that is applicable to all ceiling fans for which DOE establishes energy conservation standards in this final rule.
In the July 2016 test procedure final rule, DOE: (1) Specified new test procedures for large-diameter ceiling fans, multi-mount ceiling fans, ceiling fans with multiple fan heads, and ceiling fans where the airflow is not directed vertically, and (2) adopted the following changes to the current test procedure: (a) Low-speed small-diameter ceiling fans must be tested at high and low speeds; (b) high-speed small-diameter ceiling fans must be tested at high speed only; (c) large-diameter ceiling fans must be tested at up to five speeds; (d) a test cylinder is not to be used during testing; (e) fans that can be mounted at more than one height are to be mounted in the configuration that minimizes the distance between the fan blades and the ceiling; (f) any heater installed with a ceiling fan is to be switched off during testing; (g) small-diameter ceiling fans must be mounted directly to the real ceiling; (h) the allowable measurement tolerance for air velocity sensors is ± 5%; (i) the allowable mounting distance tolerance for air velocity sensors is± 1/16”; (j) the air delivery room must be at 70 F ± 5 F during testing; (k) air delivery room doors and air conditioning vents must be closed and forced-air conditioning equipment turned off during testing; (l) low speed small diameter and HSSD fans capable of operating with single- and multi-phase power be tested with single-phase power, and large diameter fans capable of operating with single- and multi-phase power be tested with multi-phase
power; (m) the supply voltage must be 120 V if the ceiling fan's minimum rated voltage is 120 V or the lowest rated voltage range contains 120 V; 240 V if the ceiling fan's minimum rated voltage is 240 V or the lowest rated voltage range contains 240 V; the ceiling fan's minimum rated voltage (if a voltage range is not given) or the mean of the lowest rated voltage range, in all other cases; (n) measurement axes shall be perpendicular to test room walls; and (o) measurement stabilization requirements shall be met for a valid test (
i.e.,
average air velocity readings in each axis for each sensor are within 5% and average electrical power measurement in each axis for each sensor are within 1%). DOE also determined that belt-driven ceiling fans, centrifugal ceiling fans, oscillating ceiling fans, and ceiling fans for which the plane of rotation of the fan blades cannot be within 45 degrees of horizontal are not subject to the ceiling fan test procedure. Manufacturers of highly decorative ceiling fans must use the test procedure as described in section III.A.1.
C. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available products or in working prototypes to be technologically feasible. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i)
After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) Practicability to manufacture, install, and service; (2) adverse impacts on product utility or availability; and (3) adverse impacts on health or safety. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)-(iv) Additionally, it is DOE policy not to include in its analysis any proprietary technology that is a unique pathway to achieving a certain efficiency level. Section IV.B of this notice discusses the results of the screening analysis for ceiling fans, particularly the designs DOE considered, those it screened out, and those that are the basis for the standards considered in this rulemaking. For further details on the screening analysis for this rulemaking, see section IV.B of this notice and chapter 4 of the final rule TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for ceiling fans, using the design parameters for the most efficient products available on the market or in working prototypes. The max-tech levels that DOE determined for this rulemaking are described in section IV.C of this proposed rule and in chapter 5 of the final rule TSD.
D. Energy Savings
1. Determination of Savings
For each trial standard level (TSL), DOE projected energy savings from application of the TSL to ceiling fans purchased in the 30-year period that begins in the first full year of compliance with any amended standards (2020-2049).
16
The savings are measured over the entire lifetime of products purchased in the 30-year analysis period. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-new-standards case. The no-new-standards case represents a projection of energy consumption that reflects how the market for a product would likely evolve in the absence of amended energy conservation standards.
16
DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.
DOE used its national impact analysis (NIA) spreadsheet models to estimate national energy savings (NES) from potential amended standards for ceiling fans. The NIA spreadsheet model (described in section IV.H of this rulemaking) calculates energy savings in terms of site energy, which is the energy directly consumed by products at the locations where they are used. Based on the site energy, DOE calculates NES in terms of primary energy savings at the site or at power plants, and also in terms of full-fuel-cycle (FFC) energy savings. The FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards.
17
DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered products or equipment. For more information on FFC energy savings, see section IV.H.1 of this rulemaking.
17
The FFC metric is discussed in DOE's statement of policy and notice of policy amendment. 76 FR 51282 (August 18, 2011), as amended at 77 FR 49701 (Aug. 17, 2012).
2. Significance of Savings
To adopt standards for a covered product, DOE must determine that such action would result in significant energy savings. (42 U.S.C. 6295(o)(3)(B)) Although the term “significant” is not defined in the Act, the U.S. Court of Appeals, for the District of Columbia Circuit in
Natural Resources Defense Council
v.
Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended “significant” energy savings in the context of EPCA to be savings that are not “genuinely trivial.” The energy savings for all the TSLs considered in this rulemaking, which range from 0.807 quads to 3.738 quads, are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.
E. Economic Justification
1. Specific Criteria
As noted above, EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on manufacturers, DOE conducts a manufacturer impact analysis (MIA), as discussed in section IV.J. DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the
regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include (1) INPV, which values the industry on the basis of expected future cash flows; (2) cash flows by year; (3) changes in revenue and income; and (4) other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the changes in LCC and payback period (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.
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered product in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the covered product that are likely to result from a standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase price of a product (including its installation) and the operating cost (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. The LCC analysis requires a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and discount rates appropriate for consumers. To account for uncertainty and variability in specific inputs, such as product lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value.
The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of a more-efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost due to a more-stringent standard by the change in annual operating cost for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will purchase the covered products in the first full year of compliance with amended standards. The LCC savings for the considered efficiency levels are calculated relative to the case that reflects projected market trends in the absence of amended standards. DOE's LCC and PBP analysis is discussed in further detail in section IV.F.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section IV.H, DOE uses the NIA spreadsheet models to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes, and in evaluating design options and the impact of potential standard levels, DOE evaluates potential standards that would not lessen the utility or performance of the considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards adopted in this final rule would not reduce the utility or performance of the products under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) To assist the Department of Justice (DOJ) in making such a determination, DOE transmitted copies of its proposed rule and the NOPR TSD to the Attorney General for review, with a request that the DOJ provide its determination on this issue. In its assessment letter responding to DOE, DOJ concluded that the proposed energy conservation standards for ceiling 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.
f. Need for National Energy Conservation
DOE also considers the need for national energy conservation in determining whether a new or amended standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from the adopted standards may provide improvements to the security and reliability of the nation's energy system. Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the Nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the nation's needed power generation capacity, as discussed in section IV.M.
The adopted standards also are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases (GHGs) associated with energy production and use. DOE conducts an emissions analysis to estimate how potential standards may affect these emissions, as discussed in section IV.K; the emissions impacts are reported in section V.B.6 of this rulemaking. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section IV.L. To date, this accounting for environmental benefits has not had a decisive impact on the outcome of any standards rulemaking, which is also the case for today's final rule.
g. Other Factors
In determining whether an energy conservation standard is economically justified, DOE may consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent interested parties submit any relevant information regarding economic justification that does not fit into the other categories described above, DOE could consider such information under “other factors.”
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the
consumer of a product that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values used to calculate the effect potential amended energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the Nation, and the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable presumption payback calculation is discussed in section IV.F.8 of this final rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this rulemaking with regard to ceiling fans. Separate subsections address each component of DOE's analyses. DOE also responds to comments received on its analyses in this section.
DOE used several analytical tools to estimate the impact of the standards considered in this document. The first tool is a spreadsheet that calculates the LCC savings and PBP of amended energy conservation standards (the Life-Cycle Cost Analysis spreadsheet). The national impacts analysis uses a second spreadsheet set that provides shipments forecasts and calculates national energy savings and net present value of total consumer costs and savings expected to result from potential energy conservation standards (the National Impact Analysis spreadsheet). DOE uses the third spreadsheet tool, the Government Regulatory Impact Model (GRIM), to assess manufacturer impacts of potential standards. These three spreadsheet tools are available on the DOE website for this rulemaking:
https://www.regulations.gov/#!docketDetail;D=EERE-2012-BT-STD-0045
. Additionally, DOE used output from the latest version of EIA's
Annual Energy Outlook
(
AEO
), a widely known energy forecast for the United States, for the emissions and utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment that provides an overall picture of the market for the products concerned, including the purpose of the products, the industry structure, manufacturers, market characteristics, and technologies used in the products. This activity includes both quantitative and qualitative assessments, based primarily on publicly-available information. The subjects addressed in the market and technology assessment for this rulemaking include (1) the scope of the rulemaking and product classes, (2) manufacturers and industry structure, (3) existing efficiency programs, (4) shipments information, (5) market and industry trends, and (6) technologies or design options that could improve the energy efficiency of ceiling fans. See chapter 3 of the final rule TSD for further discussion of the market and technology assessment.
DOE received several comments regarding product classes, and the technology options DOE identified that can improve the efficiency of ceiling fans. The comments are discussed in the following sections.
1. Product Classes
DOE divides covered products into classes by: (a) The type of energy used by the product; (b) the capacity of the product; or (c) other performance-related features that justify different standard levels, considering the consumer utility of the feature and other relevant factors. (42 U.S.C. 6295(q))
In the ceiling fans NOPR, DOE proposed seven product classes based on the capacity of the product and other performance-related features that justify a different standard, considering the utility to the consumer. 81 FR 1688. The product classes include: Highly-decorative, belt-driven, very-small-diameter, hugger, standard, high-speed small-diameter and large-diameter ceiling fans. DOE also proposed definitions for these product classes in the ceiling fan energy conservation standard proposed rule. In the ceiling fan test procedure final rule, DOE finalized the definitions for the following types of ceiling fans: highly-decorative, belt-driven, very-small-diameter, hugger, standard, high speed small-diameter and large-diameter ceiling fans. DOE responded to any comments received in response to the ceiling fans NOPR regarding the definitions for these type of ceiling fans in the test procedure final rule. 81 FR 48620 (July 25, 2016).
In this final rule, DOE finalizes the product classes proposed in the ceiling fans NOPR for the energy conservation standards. DOE received several comments to the ceiling fans NOPR regarding the product classes that were proposed. Westinghouse stated that they agree and appreciate the minor changes made to the product class structure, and that the changes make a big difference, particularly regarding safety. (Westinghouse, Public Meeting Transcript, No. 133 at p. 21) ALA commented that they agreed in general with the product class structure proposed in the NOPR. (ALA, No. 137 at p. 4) BAS stated that they are generally supportive of the product class structure. (BAS, No. 138 at p. 2) However, BAS expressed concern that the product classes may be too complex, in particular, comparing the standard fans to HSSD fans. The two different methods of tests may provide some confusion to end users. Specifically, BAS was concerned that HSSD ceiling fans will be tested at one speed, while standard ceiling fans will be tested at two speeds (BAS, Public Meeting Transcript, No. 133 at p. 22) (BAS, No. 138 at p. 2)
DOE finds that HSSD ceiling fans provide different utility to the consumer than standard ceiling fans. HSSD ceiling fans generally operate at much higher speeds (in terms of RPM) than standard ceiling fans, and are installed in commercial applications. HSSD ceiling fans are available in a blade span range similar to standard ceiling fans, but an HSSD fan typically provides more airflow at a given blade span because it runs at much higher RPMs. Additionally, DOE observed that HSSD ceiling fans are generally used in commercial buildings whereas standard fans are installed in residential buildings. Therefore, HSSD and standard ceiling fans provide distinct utility to different end-users and are not market substitutes. As a result, establishing separate product classes and differing test methods should not provide confusion to end-users.
Also, in general, the product class structure was developed to follow the Underwriters Laboratory (UL) ceiling fan existing safety standards (UL Standard 507-1999, “UL Standard for Safety for Electric Fans” (UL 507)).
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The UL 507 standard uses both blade thickness and maximum tip speed to differentiate fans, such that ceiling fans are safe for use in applications where
the distance between the fans blades and the floor is 10 feet or less. While standard ceiling fans are used in locations where blades are typically within 10 feet of the floor, HSSD ceiling fans are not and do not have to comply with the UL 507 standard. A product class structure that is consistent with UL 507 provides a method to differentiate standard and HSSD ceiling fans, while still ensuring that the safety standards are in place. Simplifying the product class structure without using the UL507 standard could result in safety issues.
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Underwriters Laboratories Inc. UL Standard for Safety for Electric Fans, UL 507. 1999. Northbrook, IL.
http://www.comm-2000.com/ProductDetail.aspx?UniqueKey=8782.
In summary, HSSD ceiling fans provide a different utility to consumers compared to standard fans, and that warrants a separate product class for these ceiling fans. Therefore, in this final rule, DOE continues to define separate product classes for HSSD and standard ceiling fans.
For the reasons discussed above, DOE finalizes the seven product classes proposed in the ceiling fans NOPR in this final rule. The product classes finalized in this final rule are: Highly-decorative, belt-driven, very-small-diameter, hugger, standard, high-speed small-diameter and large-diameter ceiling fans.
In the ceiling fans NOPR, DOE did not propose standards for ceiling fans in the highly-decorative fan and belt-driven ceiling fan product classes. EPCA requires DOE to consider exempting, or setting different standards for, certain product classes for which the “primary standards” are not technically feasible or economically justified. EPCA also requires DOE to consider establishing separate exempted product classes for highly-decorative fans for which air movement performance is a secondary design feature. (42 U.S.C.6295(ff)(6)(B)(i)-(ii)) DOE did not have data to determine whether standards for belt-driven ceiling fans were technically feasible and economically justified due to the limited number of basic models for belt-driven ceiling fans. DOE did not receive any comments regarding these product classes and has not received any additional data to analyze potential standards for belt-driven ceiling fans. As a result, in this final rule, DOE does not set any standards for highly-decorative and belt-driven ceiling fans.
DOE is also not establishing performance standards for centrifugal ceiling fans, oscillating ceiling fans, or ceiling fans whose blades' plane of rotation cannot be within 45 degrees of horizontal fans. In the ceiling fan test procedure final rule, DOE stated that those ceiling fans are also not subject to the test procedure. 81 FR 48620 (July 25, 2016).
2. Technology Options
In the NOPR market and technology assessment, DOE identified technology options that would improve the efficiency of ceiling fans, as measured by the DOE test procedure. These technology options fall into four main categories: (1) More efficient motors, which include larger direct-drive single phase induction motors, three-phase induction motors, geared brushless DC motors, gearless brushless DC motors, and brushless DC motors, and; (2) more efficient blades, which include curved blades, airfoil blades, twisted blades, beveled blades, blade attachments, alternative blade materials; (3) ceiling fan controls, which include occupancy sensors; and (4) fan optimization.
DOE received no comments in opposition to the technology options proposed in the ceiling fans NOPR. However, DOE did receive comments regarding including an additional technology option specific to large-diameter ceiling fans. BAS requested that an additional efficiency level be added to represent a large diameter fan using a premium AC motor instead of a three-phased geared brushless DC motor. BAS stated that premium AC motors are almost as efficient as permanent magnet motors. (BAS, Public Meeting Transcript, No. 133 at pp. 35-36)
In response to BAS's comment, and for the reasons discussed in section IV.C.3, DOE added premium AC motor as an additional technology option in this final rule to account for the costs and benefits of premium AC motors used in ceiling fans in DOE's analysis. Further discussion regarding how DOE implemented this technology option in the analysis is provided in chapter 5 of the TSD.
In the absence of adverse comments, DOE analyzed the same technology options from the ceiling fans NOPR, as well as the premium AC motor technology option specific to large-diameter ceiling fans, in this final rule. Table IV.1 provides the list of technology options considered in the analysis and their descriptions. The screening analysis, which is discussed in the next section, provides further discussion on which of these technology options DOE retained as design options for the engineering analysis.
Table IV.1—Technology Options and Descriptions
Technology option
Description
Fan optimization
This represents increasing the efficiency of a fan by adjusting existing fan design features. These adjustments could include changing blade pitch, fine-tuning motor RPM, and/or changing internal motor characteristics.
The material, mass, and design/assembly of the motor lamination stack will have an impact on efficiency (via reducing eddy current losses, for example). Similarly, the material, diameter, length, configuration, etc. of the wire in the motor will influence electrical resistance losses inside motor as well as the overall efficiency of the motor.
More efficient motors:
Larger direct drive single-phase induction motors
This represents increasing the mass and/or choosing steel with better energy efficiency characteristics for the stator and rotor stack, improving the lamination design, increasing the cross section and/or length of the copper wiring inside the motor.
Three-phase induction motors
Three-phase induction motors have lower thermal energy losses than the single-phase motors typically found in residential line-power applications. They also have a more even torque on the rotor resulting in a more efficient rotation and less motor “hum.”
However, three-phase power is extremely uncommon in residential applications. For most residences, these types of motors require electronic drive systems that convert single-phase power into a three-phase power supply.
Brushless DC motor
In residential applications, brushless DC motors typically consist of a permanent magnet synchronous AC motor that is driven by a multi-pole electronic drive system. Similar to DC motors, brushless DC motors typically achieve better efficiency than standard AC motors because they too have no rotor energy losses.
Geared Brushless DC motor
Brushless DC motor fans with geared motors have fan blades attached to the motor via a geared mechanism, which allows the fan blades to rotate at a different speed from the motor.
Premium AC motor
Premium AC motors are NEMA Premium® motors that are highly energy efficient electric motors. A motor can be marketed as a NEMA Premium motor if it meets or exceeds a set of minimum full-load efficiency levels.
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Such NEMA motors are available in integral horsepower capacities (
i.e.,
1 hp+).
Gearless Brushless DC motor
Fans with a brushless DC motor that drive the fan blades directly without the use of a geared mechanism.
More efficient blades:
Curved blades
Curved blades are blades for which the centerline of the blade cross section is cambered. Curved blades generally have uniform thickness and no significant internal volume.
Airfoil blades
Airfoil blades use curved surfaces to improve aerodynamics, but the thickness is not uniform and the top and bottom surfaces do not follow the same path from leading edge to trailing edge.
Airfoil blades typically do not operate as efficiently in reverse, potentially impacting consumer utility on models where reverse flow was an option.
Twisted blades
Twisted blades reduce aerodynamic drag and improve efficiency by decreasing the blade pitch or twist from where the blade attaches to the motor casing to the blade tip.
Blade attachments
Blade attachments refer to upswept blade tips or other components that can be fastened to a fan blade to potentially increase airflow or reduce drag.
Beveled blades
Beveled blades are typically beveled at the blade edges from the motor casing to the blade tip. Beveled fan blades are more aerodynamic than traditional fan blades.
Alternative blade materials
Use of alternative materials could enable more complex and efficient blade shapes (plywood vs. MDF vs. injection-molded resin, for example).
Ceiling fan controls:
Occupancy sensors
Occupancy sensors use technologies that detect the presence of people through movement, body heat, or other means. Ceiling fans used with an occupancy sensor could power down if they sense that a room is unoccupied.
Wind and Temperature Sensors
Wind and temperature sensors detect temperature changes in the surrounding space, or potential wind speed reductions below certain thresholds. Ceiling fans could potentially adjust fan speed based on the wind and temperature in the space the ceiling fan is located when coupled with these sensors.
B. Screening
Analysis
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NEMA Premium Motors Information Page:
https://www.nema.org/Policy/Energy/Efficiency/Pages/NEMA-Premium-Motors.aspx.
DOE uses the following four screening criteria to determine which technology options are suitable for further consideration in an energy conservation standards rulemaking:
(1)
Technological feasibility.
Technologies that are not incorporated in commercial products or in working prototypes will not be considered further.
(2)
Practicability to manufacture, install, and service.
If it is determined that mass production and reliable installation and servicing of a technology in commercial products could not be achieved on the scale necessary to serve the relevant market at the time of the projected compliance date of the standard, then that technology will not be considered further.
(3)
Impacts on product utility or product availability.
If it is determined that a technology would have significant adverse impact on the utility of the product to significant subgroups of consumers or would result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not be considered further.
(4)
Adverse impacts on health or safety.
If it is determined that a technology would have significant adverse impacts on health or safety, it will not be considered further.
10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b)
In sum, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the above four criteria, DOE will exclude it from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed below. The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (“screened out”) based on the screening criteria.
Westinghouse agreed in general with the screened in and screened out technologies, and said they appreciated that DOE considered a significant amount of stakeholder feedback. (Westinghouse, Public Meeting Transcript, No. 133 at p. 46) With the exception of brushless DC motors, ALA agreed with DOE's screening analysis for hugger and standard ceiling fans. (ALA, No. 137 at p. 6) The discussion regarding retaining brushless DC motors as a technology option is provided in section IV.B.2.
1. Screened-Out Technologies
In the ceiling fans NOPR, DOE screened out the following technologies: (1) For standard, hugger and VSD ceiling fans: Three-phase induction motors, occupancy sensors, and blade design elements including airfoil blades, beveled blades, twisted blades, blade attachments, and alternative blade materials; (2) For HSSD ceiling fans: Larger direct-drive single-phase induction motors, three-phase induction motors, twisted blades, blade attachments, alternative blade materials, and occupancy sensors; (3) For large-diameter ceiling fans: Larger direct-drive single-phase induction motors, beveled blades, twisted blades, blade attachments, alternative blade materials, and occupancy sensors. 81 FR 1688, (January 13, 2016).
DOE received several comments regarding the screened-out technologies, specifically occupancy sensors, and wind and temperature sensors. ALA supported screening out occupancy sensors from DOE's analysis. According to ALA, while this technology has the potential to reduce consumer ceiling fan usage, occupancy sensors would be
problematic for ceiling fans in bedrooms. (ALA, No. 137 at p. 7) BAS stated that in the Lawrence Berkeley National Laboratory (LBNL) study cited by DOE in the TSD, more than 50 percent of surveyed people indicated there is a ceiling fan operating in an empty room at least half of the time. BAS believes that adding occupancy sensors to those ceiling fans would dramatically reduce the annual energy use of the fan. (BAS, No. 138 at p. 6)
DOE acknowledges that occupancy sensors have the potential to save energy by reducing the number of ceiling fan operating hours. However, available data was insufficient for DOE to evaluate any potential tradeoff between consumer utility and the energy savings of reduced operating hours. DOE also researched the option of introducing occupancy sensors in ceiling fans. DOE did not find data to show that occupancy sensor can be installed reliably market-wide. Therefore, in this final rule, DOE continues to screen out occupancy sensors because DOE cannot satisfactorily evaluate the energy savings potential, technological feasibility and impact on consumer utility of implementing sensors or schedule controls.
In terms of wind and temperature sensors, Center for the Built Environment (CBE) commented that additional research is needed to demonstrate to what degree integrated temperature and wind sensors in a ceiling fan may save energy with current commercial building controls, or standard thermostats found in most homes. (CBE, No. 143 at p. 1) ALA agreed with DOE's decision to not include wind or temperature sensors as technology options. ALA stated they are not aware of any ceiling fans or working prototypes that include integrated wind or temperature sensors, or any data that would indicate that these products could lead to energy savings in real world applications. (ALA, No. 137 at p. 6) BAS stated that many large diameter fan manufacturers offer some sort of speed control based on space temperature (Big Ass Fans' SmartSense). (BAS, No. 138 at pp. 4-5)
Similar to occupancy sensors, DOE acknowledges that wind and temperature sensors have the potential to save energy by reducing the number of ceiling fan operating hours. As BAS stated, there are large-diameter manufacturers that offer some sort of speed control based on space temperature. However, available data is insufficient for DOE to evaluate any potential tradeoff between consumer utility and the energy savings of reduced operating hours based on implementing controls. DOE also did not find data to show that wind and temperature sensors can be installed reliably market-wide. Therefore, for this final rule, DOE continues to screen out wind and temperature sensors for all ceiling fans because DOE cannot satisfactorily evaluate the energy savings potential, technological feasibility and impact on consumer utility of implementing wind and temperature sensors.
In the absence of any adverse comments regarding the technology options that were screened out in the NOPR, DOE continues to screen-out the same technology options from the NOPR in this final rule. Specifically, DOE screened out the following technologies in this final rule—(1) For standard, hugger and VSD ceiling fans: Three-phase induction motors, and blade design elements including airfoil blades, beveled blades, twisted blades, blade attachments, and alternative blade materials, and occupancy, wind and temperature sensors; (2) For HSSD ceiling fans: More efficient direct-drive single-phase induction motors, three-phase induction motors, twisted blades, blade attachments, alternative blade materials, and occupancy, wind and temperature sensors; (3) For large-diameter ceiling fans: More efficient direct-drive single-phase induction motors, beveled blades, twisted blades, blade attachments, alternative blade materials, and occupancy, wind and temperature sensors.
2. Remaining Technologies
In the ceiling fans NOPR, DOE retained the following technology options—(1) For standard, hugger and VSD ceiling fans: Fan optimization, larger direct-drive single-phase induction motor and brushless DC motors; (2) For HSSD ceiling fans: fan optimization, curved blades, airfoil blades and brushless DC motors; (3) For large-diameter ceiling fans: Fan optimization, airfoil blades, geared brushless DC motors and gearless brushless DC motors. 81 FR 1688 (January 13, 2016).
DOE received several comments regarding the retained technology options. For fan optimization, Westinghouse commented that there are always a few changes that can be made to fans to optimize fans, but not all of the options can be made or it will result in a completely different product. (Westinghouse, Public Meeting Transcript, No. 133 at p. 48) DOE recognizes Westinghouse's concern that making changes to a ceiling fan to improve performance may result in what the industry or consumer would consider a different fan model. DOE defined “fan optimization” for its analysis as adjusting existing design features. These adjustments include adjusting blade pitch, fine-tuning motor rpm, and changing internal motor characteristics. DOE does not expect any of these adjustments to require significant changes to the appearance, materials, or outputs of the fan. Consequently, the optimized fan should look and feel almost identical to the non-optimized version of the same fan, only consume less energy.
Regal requested that DC motors be referred to as “brushless DC motors” instead of just “DC motors” in the standard. (Regal, Public Meeting Transcript, No. 133 at p. 52) DOE agrees with Regal and recognizes that “brushless DC motors” is a more accurate technical descriptor for these motors. As such, DOE refers to these motors as “brushless DC motors” throughout this final rule notice and accompanying TSD.
For brushless DC motors in standard and hugger ceiling fans, ALA commented that they are concerned about the technological feasibility of DC motors due to concerns about their reliability and their incompatibility with existing wall-mounted controls. (ALA, No. 137 at p. 6) Appliance Standards Awareness Project (ASAP), Alliance to Save Energy (ASE), American Council for an Energy-Efficient Economy (ACEEE), Natural Resources Defense Council (NRDC), and Northwest Energy Efficiency Alliance (herein knows as “Advocates”) claimed they were unaware of any data indicating any reliability issues associated with DC motors for ceiling fans. (Advocates, No. 142 at p. 4)
DOE has observed that several ceiling fan manufacturers offer small-diameter ceiling fans that use brushless DC motors, and that these fans are some of the most efficient small-diameter ceiling fans on the market. DOE does acknowledge, however, that brushless DC motors are a relatively new technology. Consequently, most small diameter ceiling fans that use brushless DC motors that are currently installed in the field are early in their expected lifespan and, in turn, any reliability issues may become apparent as these fans age. Nevertheless, their availability in the market indicates to DOE that brushless DC motors meet the screening criteria of technological feasibility, practicability to manufacture, install, and service, and no significant impacts on utility (including reliability and product availability). Consequently, DOE screened in brushless DC motors
for this final rule for standard and hugger fans. DOE accounted for differences in reliability between brushless DC and AC motors in the life cycle cost analyses. In addition, the energy conservation standard efficiency level adopted in this final rule (see section V.C.1 for discussion on TSLs) is consistent with performance achieved by standard and hugger ceiling fans that use larger direct-drive single-phase induction motors. As a result, any issues, if they exist, with the use of brushless DC motors in standard and hugger ceiling fans, should not be influenced by this rule.
For brushless DC motors in VSD ceiling fans, ALA objected to screening in this technology option. ALA stated they are not aware of any brushless DC motor VSD fans on the market, or currently in development, that would provide an acceptable substitute for the functionality of AC motors in VSD fans. (ALA, No. 137 at p. 6) Pacific Gas and Electric Company (PG&E), Southern California Gas Company (SCGC), San Diego Gas and Electric (SDG&E), Southern California Edison (SCE), and Arizona Public Service (APS) (herein known as California Investor Owned Utilities, or CA IOUs), on the other hand, commented that they continue to support the inclusion of brushless DC motor technology for all product classes, including VSD ceiling fans. CA IOUs also identified several VSD models that use brushless DC motors, including Vaxcel F1008, Fanimation MAD3255, and Sunpentown SF-1691C. In addition, CA IOUs stated that several pedestal and desk fans that are similar in technology, utility, and physical dimensions to VSD ceiling fans use brushless DC motors. (CA IOUs, No. 144 at p. 2)
DOE's understanding from manufacturer interviews is that brushless DC motors in VSD ceiling fans could be technologically feasible, as brushless DC motors are used in traditional standard and hugger ceiling fans. DOE reviewed the list provided by CA IOUs regarding VSD ceiling fans with brushless DC motors that are available in the market. The Fanimation MAD 3255 ceiling fan model specifications on the Fanimation website states that the smallest diameter for the model is 44-inches;
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therefore, this fan is not a VSD ceiling fan. The Vaxcel F0018 and the Sunpentown SF-1619C, however, are VSD ceiling fans that have a brushless DC motor. Therefore, DOE confirms that there are VSD ceiling fan in the market with brushless DC motors. DOE also did some online research regarding pedestal and desk fans that use brushless DC motors, and observed that there are several models available in the market at blade spans 18 inches or less. Desk fans and pedestal fans are similar in utility compared to VSD ceiling fans because they generally provide consumers with targeted airflow, and can be used to provide air to smaller spaces. However, more importantly, these fans have similar physical characteristics to VSD ceiling fans in terms of fan design; the fans typically have similar blade spans, similar airflows, and similar design (
e.g.,
axial blades and a single motor). Additionally, desk fans and VSD fans have similar size constraints for the motor housing. Because DOE has observed that brushless DC motors are commercially available in VSD ceiling fans, and in desk and pedestal fans, DOE concludes that brushless DC motor is practicable to manufacture, install, and service that does not have significant adverse impacts on utility (including reliability and product availability). Therefore, in this final rule, DOE continues to retain brushless DC motors as a technology option for VSD ceiling fans. In addition, the energy conservation standard efficiency level adopted in this final rule (see section V.C.1 for discussion on TSLs) is consistent with performance achieved by VSD ceiling fans that use larger direct-drive single-phase induction motors. As a result, any issues, if they exist, with the use of brushless DC motors in VSD ceiling fans, should not be influenced by this rule.
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http://www.fanimation.com/products/index.php/louvre.html.
For the large-diameter product class, BAS requested that an additional efficiency level be added with a premium AC motor instead of the three-phased geared brushless DC motor. (BAS, Public Meeting Transcript, No. 133 at p. 35) DOE acknowledges that for large-diameter ceiling fans, premium AC motors and three-phase geared motors are readily available in the market. Therefore, DOE retained both technology options in the screening analysis because they meet the four screening criteria for this final rule.
Through a review of each technology, DOE concludes that all of the other identified technologies listed in this section meet all four screening criteria to be examined further as design options in DOE's final rule analysis. In summary, DOE retained the following technology options: (1) For standard, hugger and VSD ceiling fans: Fan optimization, larger direct-drive single-phase induction motors and brushless DC motors; (2) For HSSD ceiling fans: Fan optimization, curved blades, airfoil blades and brushless DC motors; (3) For large-diameter ceiling fans: Fan optimization, airfoil blades, premium AC motors, geared brushless DC motors and gearless brushless DC motors.
DOE determined that these technology options are technologically feasible because they are being used in commercially-available products or working prototypes. DOE also finds that all of the remaining technology options meet the other screening criteria (
i.e.,
practicable to manufacture, install, and service and do not result in adverse impacts on consumer utility, product availability, health, or safety). For additional details, see chapter 4 of the final rule TSD.
C. Engineering Analysis
In the engineering analysis, DOE establishes the relationship between the manufacturer production cost (MPC) and improved ceiling fan efficiency. This relationship serves as the basis for cost-benefit calculations for individual consumers, manufacturers, and the Nation.
In this final rule, for small-diameter ceiling fans (VSD, Standard, Hugger and HSSD ceiling fans), DOE performed its analysis in terms of incremental increases in efficiency due to the implementation of selected design options. DOE selected representative sizes, and for each size, DOE identified a baseline efficiency as a reference point from which to measure changes resulting from each design option. For large-diameter ceiling fans, DOE performed its analysis based on a representative data set of ceiling fan performance data. DOE determined efficiency as observed in the representative dataset by best-fitting lines to the data for fans that incorporate each design option analyzed. Efficiency for all ceiling fans is represented in terms of the metric finalized in the test procedure. 81 FR 48620 (July 25, 2016).
For both small and large-diameter ceiling fans, MPCs for each successive design option are based on reverse-engineering, which includes product teardowns and a bottom-up manufacturing cost assessment. The estimated MPCs also include the costs of controls. DOE then developed the relationship between MPC and ceiling fan efficiency; this relationship is referred to as a cost-efficiency curve. The efficiency ranges from that of the least-efficient ceiling fan sold today (
i.e.,
the baseline) to the maximum-technologically feasible (max-tech) efficiency level.
The following is a summary of the method DOE used to determine the
cost-efficiency relationship for ceiling fans:
• Perform airflow and power consumption tests on a representative sample of ceiling fans in each product class.
• Develop a detailed BOM for the tested ceiling fans through product teardowns, and construct a ceiling fan cost model.
DOE used a combination of test data, data from spec sheets, the cost model, and feedback from manufacturers to calculate the incremental increase in efficiency and cost increase from baseline to max-tech. Further details can be found in chapter 5 of the TSD.
1. Standard and Hugger Ceiling Fans
In the ceiling fans NOPR, DOE combined the cost-efficiency curves of flat-blade fans and unconventional-blade fans in the standard and hugger product classes to create an aggregate curve for all standard ceiling fans and all hugger ceiling fans. DOE used the following design options to create the curves: Fan optimization, larger direct drive motors, and brushless DC motors. DOE used the maximum efficiency of the unconventional-blade fans as the max-tech for the aggregate curve to ensure that all types of ceiling fans, including designs with unconventional-blades, can achieve the max-tech level of efficiency. DOE received several comments on the engineering analysis specific to the standard and hugger product classes.
Advocates commented that the energy savings associated with EL 4 for standard and hugger fans are likely to be significantly greater than shown in the analysis. They stated that it looks like the analysis is assuming that the power consumption of a flat-blade fan incorporating a DC motor would be equivalent to that of an unconventional-blade fan with a DC motor. In practice, it seems very unlikely that flat-blade fans with DC motors would not significantly exceed the efficiency levels given that DOE's analysis shows that a flat-blade fan with a DC motor is 30% more efficient than an unconventional-blade fan with a DC motor. (Advocates, No. 142 at p. 4)
For the NOPR, because DOE set the max-tech efficiency for standard and hugger ceiling fan product classes as the max-tech efficiency for unconventional-blade fans, DOE also set the power consumption at max-tech as the max-tech power consumption for unconventional-blade fans to match the max-tech efficiency. DOE acknowledges that to comply with the EL 4 efficiency for both flat blade fans and unconventional-blade fans, manufacturers are likely to employ brushless DC motors. Therefore, at the max-tech efficiency, there is potential for energy savings for the flat-blade fans. For this final rule, DOE adjusted the power consumption at max-tech to include the potential energy savings from the flat-blade fans. DOE used the same weighting between flat and unconventional blade fans at max tech (
i.e.,
unconventional blade fans make up about 2 percent of the market, while flat blade fans are about 98 percent of the market) as at all the other efficiency levels.
In the engineering analysis for standard and hugger ceiling fans, DOE used an aggregate cost-efficiency curve for flat and unconventional blade fans, as opposed to defining two separate product classes, because fans with flat blades and fans with unconventional blades are functionally indistinguishable. Both fan types move air via the rotation of fan blades, improve comfort by this air movement, and can be used in similar spaces (unlike the distinction between standard and hugger fans, where the former cannot be used in rooms with low ceilings). Further, because flat blade and unconventional blade fans on the market appear to operate within the same CFM range, they have the same product capacity. Therefore, when setting the max-tech for the standard and hugger ceiling fan product classes, DOE set it at the max-tech efficiency for unconventional-blade fans, because this ensures that even at max-tech, all types of ceiling fans, including designs with unconventional blades, can achieve this level of efficiency.
Advocates also stated that the costs associated with EL4 for standard and hugger fans are likely to be lower than shown in the analysis, but did not provide supporting data for this statement. (Advocates, No. 142 at p. 4) As described in section IV.C, DOE reverse engineered several ceiling fans at EL4 (with brushless DC motors) to determine the MPC for that EL. To investigate the Advocates' claims, DOE reverse engineered several more brushless DC motor fans, and revisited the cost model to review the costs used in the NOPR. Based on the review, DOE corroborated the costs presented in the NOPR, rather than lower costs. Absent any additional cost data, DOE continues to use the MPC results from the NOPR for EL4 for standard and hugger fans in this final rule.
In summary, in this final rule, DOE continues to use the combined cost-efficiency curves of flat-blade fans and unconventional-blade fans in the standard and hugger product classes to create an aggregate curve for all standard ceiling fans and all hugger ceiling fans.
Since the NOPR, DOE received additional test data for hugger and standard fans from manufacturers, which was used in the analysis for the final rule. The additional test data was used to update some of the efficiency deltas (
i.e.,
the difference in efficiency for a particular design option) in the analysis. Additionally, the test data informed the conversion factors used to convert efficiencies from ENERGY STAR test method, to efficiencies based on testing small-diameter ceiling fans using the test method in the July 2016 test procedure final rule (
i.e.,
mounting fans directly to the real ceiling). Based on the new test data, DOE increased the conversion factors since the NOPR. DOE then used these conversion factors to determine the efficiency results for the engineering analysis. Further details on the updates to the conversion factor is provided in Chapter 5 of the TSD.
2. VSD and HSSD Ceiling Fans
For the NOPR analysis, DOE was not aware of unconventional blade and flat blade fan variations for VSD and HSSD fans, so DOE did not use an aggregate curve approach for these ceiling fans. DOE used the same design option approach as standard and hugger ceiling fans to determine cost-efficiency relationships for all representative sizes in both VSD and HSSD product classes. DOE used the following design options for VSD ceiling fans to create the curves: Fan optimization, larger direct drive single-phase induction motors, and brushless DC motors. DOE used the following design options for HSSD ceiling fans to create the curves: Fan optimization, curved blades, airfoil blades and brushless DC motors.
DOE did not receive any specific comments on the engineering approach used for the VSD product class. However, DOE received several comments specific to the HSSD engineering analysis. Westinghouse commented that they were concerned with the additive approach used in calculating cost differences for the HSSD efficiency levels. They stated that the approach may not be fully calculating or capturing what the true cost increase will be. (Westinghouse, Public Meeting Transcript, No. 133 at p. 92)
DOE interprets Westinghouse's comment to mean that the full cost for the ELs with multiple design options is not being captured in the engineering analysis. As described in section IV.C, DOE developed the manufacturer production costs based on actual
product teardowns. When actual torn down models were not available for certain design options, DOE estimated costs based on materials and manufacturing processes necessary for each design option, and by using input from manufacturers. DOE performed this analysis through a catalog teardown, which uses published manufacturer product literature and supplementary component data to estimate the costs of major physical differences between the catalog teardown unit and a similar physical teardown unit. Some efficiency levels are consistent with performance of ceiling fans that use multiple design options, such as fan optimization and larger direct-drive single-phase induction motors. When determining the MPCs for efficiency levels that incorporate several design options, DOE's engineering analysis incorporates the costs of all design options included in that efficiency level (
i.e.,
the additive approach) added to the baseline MPC. The result, therefore, includes all of the production costs associated with manufacturing a baseline fan and all the incremental costs of adding or substituting technology options to improve efficiency. Westinghouse did not identify specific costs not captured by DOE's analysis, or provide information to support a contention that the additive approach does not fully calculate or capture the actual cost increase. Absent additional information, DOE concludes that its MPC estimates capture all manufacturing costs applicable to the efficiency levels analyzed. See chapter 5 of the final rule TSD for further discussion on the HSSD ceiling fan engineering analysis, which includes details about the costs included in DOE's MPC estimates. DOE did increase the conversion costs for all ceiling fans as part of the MIA. See section IV.J.2.a for further discussion on manufacturer conversion costs.
Westinghouse also asked if DOE had considered reordering the HSSD efficiency levels to have EL3 with DC motor and with flat metal blade followed by EL4 with DC motor and airfoil blades instead of adding the airfoil blades in EL3 and DC motor in EL4. Westinghouse commented that this is different from hugger and standard fans, where the motor options are what drive the cost. They stated that the airfoil blade is a high cost adder with not the same payback as a motor upgrade would be. (Westinghouse, Public Meeting Transcript, No. 133 at p. 113) Fanimation agreed with Westinghouse's comments. (Fanimation, Public Meeting Transcript, No. 133 at pp. 113-114) ALA commented that they are skeptical of DOE's estimate of the net benefits that DC motor-based fan provide to consumers, and generally believe that DC motor-based ceiling fan efficiency standards, like DOE's proposed TSL 4-based standard for HSSD fans, are not technologically feasible. Additionally, ALA stated that DOE's proposed max-tech standard is not economically justified because it relies upon the airfoil blade design option, which is not economically justified. ALA stated that if DOE declines to adopt a standard at EL 3 or below for HSSD fans, DOE should consider adopting a standard for HSSD fans based on an efficiency level that corresponds to the fan optimization and DC motor design options, without the use of curved blades or airfoil blades. (ALA, No. 137, pp. 2-3)
Pursuant to EPCA, DOE must adopt standards that achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) To do this, DOE first establishes TSLs by combining specific efficiency levels for each of the product classes analyzed. Higher TSLs generally consist of a combination of higher efficiency levels for each product class, and the highest TSL generally represents the max-tech efficiency level for all product classes. Therefore, higher TSLs typically represent higher potential energy savings. (See section V.A for more details on TSLs chosen for this rulemaking). DOE then considers the impacts of amended standards for ceiling fans at each TSL beginning with the maximum technologically feasible level, to determine whether that level is economically justified. Where the max-tech level is not justified, DOE then “walks down” to the next most efficient level and conducts the same evaluation until it reached the highest efficiency level that is both technologically feasible and economically justified and saves a significant amount of energy.
For this final rule, TSLs 4 and 5 correspond to the max-tech efficiency level for HSSD ceiling fans.
21
Therefore, when DOE performed a walk-down from TSL 5 and determined that TSL 4 would result in the maximum improvement in energy efficiency that was technologically feasible and economically justified (see section V.C.1), the efficiency level for HSSD ceiling fans still corresponded to the max-tech EL for HSSD ceiling fans. Because TSL 4 is justified, EPCA prohibits DOE from considering TSL 3, which included a lower efficiency level for HSSD ceiling fans (EL 3, which included only airfoil blades and fan optimization as design options on a baseline fan). Thus, the change to the order of the efficiency levels for HSSD ceiling fans suggested by Westinghouse would not change the results of DOE's walkdown analysis. Therefore, DOE has not analyzed an alternate EL3 with a brushless DC motor and with flat metal blades in this final rule.
21
For HSSD ceiling fans, the max-tech efficiency level analyzed included fan optimization, airfoil blades and a brushless DC motor as design options on a baseline fan.
Since the NOPR, DOE received additional test data for hugger and standard fans from manufacturers that was used in the analysis for the final rule. The additional test data was used to update some of the efficiency deltas in the analysis. Because some of the VSD and HSSD efficiency deltas are dependent on the standard and hugger analysis, the engineering results for VSD and HSSD analyses were updated accordingly. Further details on the engineering analysis is provided in Chapter 5 of the TSD.
3. Large-Diameter Ceiling Fans
In the NOPR, DOE used a combination of the reverse-engineering and design option approach for the large-diameter ceiling fan engineering analysis. DOE relied on test data and feedback from manufacturers to determine energy ELs to analyze. DOE estimated baseline ceiling fan efficiencies based on test data for large-diameter ceiling fans at intermediate ELs adjusted by efficiency deltas. After establishing the baseline efficiency for large-diameter ceiling fans, DOE applied efficiency deltas associated with each design option to the baseline to calculate the efficiency consistent with performance of large-diameter ceiling fans that use each design option from baseline to max-tech. In DOE's analysis, efficiency deltas are estimated differences in ceiling fan efficiency based on comparing performance of ceiling fans that use different technology options, but are otherwise identical. This analysis resulted in an efficiency curve, as a function of ceiling fan diameter, for each efficiency level.
During the NOPR public meeting, BAS requested that an additional efficiency level be added to represent large-diameter ceiling fans that use a premium AC motor instead of a three-phased geared brushless DC motor, and stated that the premium AC motors are almost as efficient as permanent magnet motors. (BAS, Public Meeting Transcript, No. 133 at pp. 35-36)
DOE received test data from BAS that included ceiling fans using premium AC
motors. After evaluating the data, DOE confirmed BAS's assertions that large-diameter ceiling fans that use premium AC motors have comparable efficiencies to those that use geared brushless DC motors. In addition, DOE conducted a teardown analysis, which estimated that ceiling fans with a premium AC motor have lower MPC than ceiling fans with a geared brushless DC motor. Therefore, DOE expects that manufacturers would use the lower-cost premium AC motors instead of geared brushless DC motors to meet a standard that is consistent with the performance of ceiling fans that use either of these technologies. Consequently, DOE replaced the geared brushless DC motor design option with premium AC motors for EL 3 in this analysis to reflect this expectation.
In addition to the test data for fans with premium AC motors, DOE also received additional test data from BAS for the other efficiency levels analyzed in the analysis. With this data, DOE's database of large-diameter fan performance includes 87 ceiling fans at EL 2, EL 3 and EL 4, comprising of ceiling fans from six different manufacturers, and with blade spans of 8, 10, 12, 14, 16, 18, 20 and 24 feet. Due to the large number of ceiling fans, the range of efficiency levels, and the variety of manufacturers, DOE determined that this dataset is representative of the EL 2, EL 3 and EL 4 large-diameter ceiling fans in the market.
A representative dataset allowed DOE to shift from the design option approach used in the NOPR (
i.e.,
evaluating technology pairs to determine efficiency deltas associated with each design option) to an efficiency-level approach (
i.e.,
representing efficiency as observed in the representative dataset by using best-fit lines for each technology option analyzed). In its dataset, DOE observed a broad range of efficiencies in ceiling fans with a gearless brushless DC motor and airfoil blades (
i.e.,
max-tech), and a narrow range of efficiencies in ceiling fans either with airfoil blades (
i.e.,
EL 2) or with a premium AC motor and airfoil blades (
i.e.,
EL3). This change in methodology also updated the engineering results for the large-diameter analysis. Further discussion regarding the efficiency-level approach and the engineering results for large-diameter ceiling fans is provided in chapter 5 of the TSD.
During the NOPR public meeting, BAS recommended that efficiencies be gauged using a CFM/W curve as a function of airflow for each diameter. This would essentially require a CFM per watt standard equation as a function of airflow at every diameter available. (BAS, Public Meeting Transcript, No. 133 at p. 39) In written comments, BAS stated that the fundamental assumption that all ceiling fans of the same diameter move the same amount of air is untrue, allows inefficient low airflow products to remain on the market, and creates an upper limit to ceiling fan performance at each diameter. (BAS, No. 138 at p. 12) BAS further urged DOE to consider a metric that will not eliminate high efficiency, high utility ceiling fans from the market. BAS recommended that an efficiency metric based on ceiling fan diameter and maximum airflow be used to provide energy savings across all airflows and diameters, while still allowing the continued development of high utility products. (BAS, No. 138 at p. 15) In this discussion, DOE understood BAS' use of the phrase “high utility ceiling fans” to mean ceiling fans with high maximum airflows. The Advocates also encouraged DOE to consider standards for large-diameter ceiling fans that take both diameter and airflow into account. According to the Advocates, by taking only diameter into account in establishing ELs for large-diameter ceiling fans, the standards may have little impact on ceiling fans that deliver relatively low airflow rates, while simultaneously prohibiting ceiling fans of the same diameter that deliver higher airflow rates than those assumed in the analysis. (Advocates, No. 142 at pp. 1-2)
DOE's understanding of both BAS and Advocates concern is that an efficiency standard only based on diameter only could disproportionally impact ceiling fans that deliver higher airflows, compared to those that deliver lower airflows. To investigate this further, DOE analyzed the test data provided by BAS, in addition to DOE's own test data of large-diameter ceiling fans.
DOE began its analysis by confirming that the relationship between diameter and ceiling fan efficiency is an appropriate basis for an energy efficiency standard. DOE plotted a best fit line between diameter and efficiency of all the ceiling fans at max-tech and observed a R
2
correlation of 0.51 between diameter and efficiency. DOE conducted a similar exercise for ceiling fans at EL 2 and EL 3. At these ELs, however, DOE observed a narrower range of efficiencies at each diameter, which resulted in better R
2
correlations of 0.87 and 0.97 for EL 2 and EL 3, respectively, compared to max-tech. Therefore, the greater variation in max-tech test data suggests that the variation in efficiency with airflow is much greater for ceiling fans with gearless brushless DC motors than those with AC motors. DOE realizes that the data for EL 4 ceiling fans is more scattered meaning that not all ceiling fans produce the same amount of airflow and that airflow has a direct effect on the efficiency of ceiling fans. However, for EL 2 and EL 3, the tight range of efficiency and airflow data at EL 2 and EL 3 suggests that the slope from the best fit line is a good representation of the relationship between efficiency and diameter.
For this final rule, the energy conservation standard efficiency level adopted is consistent with performance achieved by large-diameter ceiling fans with EL 3 characteristics. See section V.C.1 for discussion on TSLs. Therefore, DOE believes that the relationship between diameter and efficiency is an appropriate basis for an energy efficiency standard. However, based on the data, DOE did observe that there were some high airflow ceiling fans that might be disproportionally disadvantaged based on a standard using the best fit line. Therefore, to preserve consumer utility that require ceiling fans with high airflow, DOE decreased the y-intercept of the best fit equations, while maintaining the slopes. DOE aimed to preserve consumer utility by maintaining the maximum airflow produced at each diameter, or identify a close alternative, by shifting the equation downwards.
For each of the eight diameters analyzed (ranging from 8-24 feet), DOE identified the ceiling fan with the maximum tested airflow from all efficiency levels. At two of the eight diameters, a ceiling fan at EL 2 produces the largest airflow, and at the other six diameters, a ceiling fan at EL 3 produces the maximum airflow. At three of the eight diameters, the fan with the highest airflow achieves the efficiency level established in this final rule.
For the other five diameters, where the highest airflow ceiling fan does not meet the established standard level, DOE identified the ceiling fan with the highest airflow that achieves the standard level and compared it to the ceiling fan with the maximum airflow at that diameter. DOE calculated the percentage of maximum airflow for these ceiling fans to determine whether the EL 3 standard is still achievable with an EL 3 ceiling fan, without eliminating ceiling fans with high maximum airflows. DOE further investigated any diameter where the maximum airflow ceiling fan did not achieve the standard level, in order to see if the maximum airflow or a close alternative could be achieved. At two of the remaining five diameters, the ceiling fan with the highest airflow that achieved the standard level produced 99
percent of the airflow recorded for the ceiling fan with the maximum airflow. At two other diameters, the ceiling fans that meet the standard produced 90 percent of airflow of the highest airflow ceiling fan. For the last diameter, the highest airflow of a ceiling fan achieving the standard was 85 percent of the ceiling fan with the maximum airflow. The lower percentages at the three diameters may be a representation of smaller sample size, and not an outcome of the stringency of the standard.
For the reasons mentioned, DOE believes that the high efficiency, high airflow ceiling fans will not be eliminated from the market when using the shifted best fit equation. Therefore, DOE continued with the methodology outlined in the NOPR by adopting a standard equation that is only a function of diameter, and not airflow.
BAS commented that the repair costs should be separated for the geared and gearless versions for DC motors used in the large-diameter analysis. BAS stated that the gearless DC motor will take more hours to service than the geared motor because the entire fan assembly has to be removed to repair the gearless motor. (BAS, Public Meeting Transcript, No. 133 at p. 99) BAS also stated that efficiency losses resulting from gearboxes are generally less than 5 percent, not 20 percent. (BAS, Public Meeting Transcript, No. 133 at p. 31)
In the final rule, DOE replaced the geared brushless DC motor with the premium AC motor for efficiency level 3. Therefore, these comments do not affect the large-diameter analysis in the final rule.
4. Reducing Fan Speed To Improve Efficiency
In the NOPR analysis, DOE had requested comments on what an acceptable reduction of fan speed may be to improve ceiling fan efficiency such that it does not affect consumer utility for each of the proposed product classes. DOE received several comments regarding this topic.
CBE stated that, based on CBE laboratory tests, at least one ceiling fan tested is more efficient at lower speed. However, limiting the maximum air speed would not satisfy human comfort at higher temperatures. CBE suggested that one way to avoid this may be setting a limit for the maximum air speed for a ceiling fan, while requiring that the energy efficiency standard be met as well. (CBE, No. 143 at p. 1) BAS commented that a decrease of 50% in airflow nets an approximate gain of 220% on efficiency, but would result in a dramatic reduction in cooling effect and consumer utility. BAS stated that the impact of the reduced performance will likely not be known to the consumer because there are no guidelines, equations or standards that allow consumers to translate CFM into cooling effect. BAS felt this would be especially true if the labeling requirements do not prominently display the maximum CFM of the fan. (BAS, No. 138 at p. 7) ALA stated they do not believe that reducing fan speeds available to a consumer is a viable way to improve efficiency because reducing fan speed directly impairs consumer utility. ALA therefore agreed with DOE's statement in the NOPR, that “manufacturers will not reduce airflow to levels that are unacceptable when other cost-justified pathways to compliance are available.” (ALA, No. 137 at p. 7) CA IOUs asked whether companies may simply reduce their fans' RPMs in order to meet the efficiency standard, and ASAP suggested that in such a case, consumers may run their fans at higher speeds, thereby reducing the energy savings from the standard. (CA IOUs, Public Meeting Transcript, No. 133 at p. 159; ASAP, Public Meeting Transcript, No. 133 at pp. 154-155) Westinghouse responded by suggesting that manufacturers that try to meet the standard by reducing the utility (
i.e.,
airflow) of their fans would lose business. (Westinghouse, Public Meeting Transcript, No. 133 at pp. 155-156) In addition, Westinghouse noted that if a manufacturer tried to make an obsolete product simply to meet the standard, demand for the product would wane over time and competition would publicize how that manufacturer's products are lacking in performance. (Westinghouse, Public Meeting Transcript, No. 133 at pp. 158-159)
DOE understands that slowing down a fan can significantly reduce energy consumption. However, DOE also recognizes that airflow, which diminishes at lower fan speeds, factors heavily into consumer utility. DOE observes that the airflow produced by commercially available fans of the same diameter varies. While DOE interprets this to mean that some variation in airflow at a given diameter is acceptable to the market and does not represent a reduction in utility, DOE did not include slowing down the fan as a design option to avoid setting standards that may result in reduced utility. Leaving out reducing fan speed as a design option ensures that manufacturers can meet the level adopted by this final rule in a cost-justified manner without reducing fan speed. While manufacturers may opt to do so, it is unlikely that many will due to the market pressures identified by Westinghouse. In addition, the FTC is primarily responsible for labeling, and issued amendments to the ceiling fan label for all ceiling fans except large-diameter and HSSD ceiling fans on September 15, 2016. 81 FR 63634. The ceiling fan label includes a prominent display of the CFM based on typical use of a ceiling fan. The FTC is planning to seek comments on the need for, and content of, fan labels for large-diameter and HSSD ceiling fans in a separate notice. 81 FR 63634, 63637.
5. Standard Level Equations
In the ceiling fans NOPR, DOE proposed best-fit linear standard level equations in terms of ceiling fan diameter, based on the efficiency results for the representative sizes analyzed for each product classes. The linear standard level equations were established so that the proposed minimum efficiencies could be calculated for all ceiling fan diameters within a product class. DOE received a comment regarding the standard level equations proposed.
In general, ALA commented that DOE should, in adopting final efficiency standards for ceiling fans, clarify that the efficiency equation found in the table in proposed 10 CFR § 430.32(s)(2) represents minimum ceiling fan efficiency. (ALA, No. 137 at p. 3) DOE appreciates the comment from ALA, and has updated references to the standard level equations in this final rule to clarify that it represents minimum ceiling fan efficiency.
In this final rule, DOE continues to develop standard level equations based on diameter for all product classes. As discussed in the ceiling fans NOPR, DOE believes that blade diameter is a better proxy for utility than airflow. The size of a fan determines the cooling area, impacts room aesthetics, and determines if a fan physically fits into a room. Literature published by manufacturers clearly indicates that blade span is an important criterion for consumer fan selection. Manufacturers include sizing guides in published product literature to instruct consumers on how to properly size a fan for a given room size. These fan sizing guides specify the affected square footage of a room based on fan blade diameter. DOE did not find such guides for other ceiling fan characteristics such as airflow.
Therefore, based on the updates to the engineering analyses described in sections IV.C.1 through IV.C.3 for all product classes, DOE also updated the best-fit linear standard level equations.
DOE is not aware of commercially available VSD fan models below 12 inches in diameter. However, extending a best-fit linear equation below 12 inches for VSD would result in minimum ceiling fan efficiency standards below 0 CFM/Watt at near 0 inch diameters. In this final rule, DOE is continuing to use a best-fit linear equation for VSD fans 12 inches in diameter and above (the range in which all known commercially-available VSD models currently exist). However, DOE is extending the minimum ceiling fan efficiency required at 12 inches to all VSD fans below 12 inches in diameter to avoid standards 0 CFM/Watt and below for any VSD models that may exist in this range.
D. Markups Analysis
The markups analysis develops appropriate markups (
e.g.,
manufacturer markups, retailer markups, distributor markups, contractor markups) in the distribution chain and sales taxes to convert the MPC estimates derived in the engineering analysis to consumer prices, which are then used in the LCC and PBP analysis and in the manufacturer impact analysis. At each step in the distribution channel, the markups are multipliers that are applied to the purchase cost to cover business costs and profit margin.
DOE characterized four distribution channels to describe how standard, hugger and VSD ceiling fans pass from manufacturers to consumers. These four distribution channels can be characterized as follows:
Manufacturer → Home Improvement Center → Consumer
Manufacturer/Home Improvement Center (in-store label) → Consumer
Manufacturer → Wholesaler → Contractor → Consumer
Manufacturer → Showroom → Consumer
DOE developed separate markups for home improvement centers that have their in-store label ceiling fans and for those that sell independent-label ceiling fans. As indicated in the market assessment, two of the top three ceiling fan brands in the market are the in-store brands for two home improvement centers. These home improvement centers therefore serve as both in-store brand manufacturers and home improvement centers that carry both store-brand and independent-brand ceiling fans. For in-store label ceiling fans, DOE developed an overall markup that encompasses the margins for manufacturing as well as selling the product. For the independent-label ceiling fans sold through home centers, separate markups were developed for the brand manufacturer and for the home improvement centers which serve only as a retailer.
For large-diameter and HSSD ceiling fans, the two distribution channels that DOE considered can be characterized as follows:
Manufacturer → Dealer → Customer
Manufacturer → In-house Dealer → Customer
The second distribution channel for large-diameter and HSSD ceiling fans is a direct sale channel where the manufacturer sells the product directly to a customer through its in-house dealer. DOE assumed the markup for in-house dealers is the same as the conventional dealer markup; therefore, the overall markup for these two distribution channels is the same.
To account for manufacturers' non-production costs and profit margin, DOE applied the manufacturer markup to the full MPC derived in the engineering analysis. The resulting manufacturing selling price (MSP) is the price at which the manufacturer can recover all production and non-production costs and earn a profit. To meet new or amended energy conservation standards, manufacturers typically introduce design changes to their product lines, which increase manufacturer production costs. As production costs increase, manufacturers typically incur additional overhead.
To calculate the manufacturer markups, DOE reviewed 10-K reports
22
submitted to the U.S. Securities and Exchange Commission (SEC) by publicly-owned ceiling fan companies. The financial figures necessary for calculating the manufacturer markup are net sales, costs of sales, and gross profit. Few ceiling fan manufacturing companies are publicly owned, and most of the publicly-owned ceiling fan manufacturing companies are subsidiaries of more diversified parent companies, so the financial information summarized may not be exclusively for the ceiling fan portion of their business and can also include financial information from other product sectors. DOE discussed the manufacturer markup with manufacturers during interviews, and used product specific feedback on market share, markups and cost structure from manufacturers to adjust the manufacturer markup calculated through review of SEC 10-K reports.
22
U.S. Securities and Exchange Commission, Annual 10-K Reports (various years between 2007 and 2013), available at
http://sec.gov
.
To develop markups for the market participants involved in the distribution of ceiling fans, DOE utilized several sources, including: (1) The SEC 10-K reports and U.S. Census Bureau's annual retail trade survey for building material and supplier dealer industry
23
(to develop home improvement center markups); (2) the U.S. Census Bureau's annual wholesale trade report for electrical and electronic appliance, television, and radio set merchant wholesaler industry
24
(to develop wholesaler markups); (3) 2014 RSMeans Electrical Cost Data
25
(to develop contractor markups); and (4) the SEC 10-K reports (to develop dealer markups).
23
U.S. Census Bureau.
2012 Annual Retail Trade Survey.
Building Material and Supplier Dealer. 2012 (Last Accessed April 22, 2015)
http://www.census.gov/retail/arts/historic_releases.html.
24
U.S. Bureau of the Census.
2012 Annual Wholesale Trade Report, NAICS 423620: Electrical and Electronic Appliance, Television and Radio Set Merchant Wholesaler.
2012. Washington, DC. (Last Accessed April 22, 2015)
http://www.census.gov/wholesale/index.html.
25
RS Means Company Inc.
Electrical Cost Data: 36th Annual Edition.
2014. Kingston, MA.
To develop the markups when home centers serve as both brand manufacturer and retailer, DOE relied upon input from an industry expert.
26
26
Mehta, V. Independent ceiling fan industry consultant. Personal communication. E-mail to Colleen Kantner, LBNL. November 24, 2013.
For each of the market participants, DOE developed baseline and incremental markups based on the product markups at each step in the distribution chain. The baseline markup relates the change in the MSP of baseline models to the change in the consumer purchase price. The incremental markup relates the change in the MSP of higher-efficiency models (the incremental cost increase) to the change in the consumer purchase price.
In addition to the markups, DOE derived state and local taxes from data provided by the Sales Tax Clearinghouse.
27
These data represent weighted average taxes that include county and city rates. DOE derived shipment-weighted average tax values for each region considered in the analysis.
27
Sales Tax Clearinghouse Inc., State Sales Tax Rates Along with Combined Average City and County Rates (2014) available at
http://thestc.com/STrates.stm
(last accessed May 27, 2014).
Chapter 6 of the final rule TSD provides details on DOE's development of markups for ceiling fans.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual energy consumption of ceiling fans at different efficiency levels in
representative U.S. homes and commercial buildings, and to assess the energy savings potential of increased ceiling fan efficiency. To develop annual energy use estimates, DOE multiplied ceiling fan input power by the number of hours of use (HOU) per year. The energy use analysis estimates the range of operating hours of ceiling fans in the field (
i.e.,
as they are actually used by consumers). The energy use analysis provides the basis for other analyses that DOE performed, particularly assessments of the energy savings and the savings in consumer operating costs that could result from adoption of amended standards.
1. Inputs for Standard, Hugger, and VSD Ceiling Fans
a. Sample of Purchasers
As in the NOPR analysis, DOE has included only residential applications in the energy use analysis of standard, hugger, and VSD ceiling fans. DOE used the Energy Information Administration (EIA) 2009 Residential Energy Consumption Survey (RECS)
28
to choose a random sample of households in which new ceiling fans could be installed. RECS is a national sample survey of housing units that collects statistical information on the consumption of, and expenditures for, energy in housing units, along with data on energy-related characteristics of the housing units and occupants. RECS collected data on 12,083 housing units, and was constructed by EIA to be a national representation of the household population in the United States.
28
U.S. Department of Energy-Energy Information Administration.
2009 RECS Survey Data.
(Last accessed May 3, 2016.)
http://www.eia.gov/consumption/residential/data/2009/
.
In creating the sample of RECS households, DOE used the subset of RECS records that met the criterion that the household had at least one ceiling fan. DOE chose a sample of 10,000 households from RECS to estimate annual energy use for standard, hugger, and VSD ceiling fans. Because RECS provides no means of determining the type of ceiling fan in a given household, DOE used the same sample for the standard, hugger, and VSD product classes.
b. Operating Hours
As in the NOPR analysis, DOE used data from an LBNL study
29
that surveyed ceiling fan owners to estimate the total daily operating hours for each sampled RECS household. In that study, the authors asked a nationally representative sample of more than 2,500 ceiling fan users to report their ceiling fan operating hours for high, medium, and low speeds. The LBNL study reported a distribution of operating hours, with an average of 6.45 hours of operation per day. The operating hours for each sample household were drawn from the distribution of operating hours reported in the LBNL study, and further apportioned into operating hours at different fan speeds.
29
Kantner, C. L. S., S. J. Young, S. M. Donovan, and K. Garbesi.
Ceiling Fan and Ceiling Fan Light Kit Use in the U.S.—Results of a Survey on Amazon Mechanical Turk.
2013. Lawrence Berkeley National Laboratory: Berkeley, CA. Report No. LBNL-6332E.
http://www.escholarship.org/uc/item/3r67c1f9
.
As in the NOPR analyses, DOE estimated that the average fraction of time that standard, hugger, and VSD ceiling fans were operated at each speed was equal to the simple average of the fractions reported by the LBNL survey and an AcuPOLL
30
survey submitted by ALA in response to the ceiling fan test procedure NOPR. This average yields an estimate of 33 percent of time spent in active mode on high speed, 38 percent on medium speed, and 29 percent on low speed. In written comments received in response to the NOPR, Westinghouse and ALA indicated agreement with these estimated average hours of use for standard, hugger, and VSD ceiling fans. (Westinghouse, Public Meeting Transcript, No. 133 at p. 79; ALA, No. 137 at p. 8)
30
AcuPOLL® Precision Research, Inc.
Survey of Consumer Ceiling Fan Usage and Operations.
2014.
For the final rule, DOE refined the NOPR approach by accounting for a distribution in operating hours spent at each speed.
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Specifically, for each sampled household, the fraction of time that the fan spends at each of low and medium speed was drawn from a uniform distribution over the interval between zero and twice the average fraction of time for that speed. Since the sum of fractions of time spent at each speed must equal one, the fraction of time spent at high speed is simply given by the remaining fraction. DOE then used these fractions to apportion the total hours of use into hours of use at high, medium and low speeds.
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For the final rule, DOE used a distribution of operating hours at each speed, rather than an average, to better represent the distribution of impacts on a sample of 10,000 households. The average time at each speed from the distribution is unchanged from average value used in the NOPR analysis.
c. Power Consumption at Each Speed and Standby
DOE determined the power consumption at high, medium, and low speed for each representative fan size in the engineering analysis. These values are shown in chapter 5 of the final rule TSD. DOE estimated that all ceiling fans with brushless DC motors expend standby power, and that 7 percent of standard, hugger, and VSD ceiling fans with AC motors come with a remote, and therefore consume power while in standby mode. DOE further estimated 0.7 watts as the power consumption value for standby for all representative fans belonging to the standard, hugger, and VSD product classes, based on testing conducted in association with developing the engineering analysis.
BAS commented that the percentage energy savings for ceiling fans with occupancy sensors will be similar to that of lighting systems with occupancy sensors and that this similarity could be used to estimate savings from ceiling fans with occupancy sensors. (BAS, No. 138 at p. 5) DOE acknowledges that occupancy sensors have the potential to have an impact on the energy consumption of ceiling fans. However, available data is insufficient for DOE to determine what impact occupancy sensors may have on energy use in practice. In the absence of supporting data or evidence to substantiate energy savings, DOE does not believe it is appropriate to assume ceiling fans and lighting systems to have similar percentage energy savings. Furthermore, occupancy sensors have been screened out of the final rule analysis (see section IV.B.1), and it is unclear if fans with occupancy sensors will make up a non-negligible portion of the market in the future, especially in the residential sector.
The CA IOUs indicated that many hugger, standard, and VSD ceiling fans with brushless DC motors have six speeds, not three speeds. Therefore, the CA IOUs recommended that DOE consider incorporating the advantages of six-speed ceiling fans by averaging the performance characteristics at the lowest two speeds, the middle two speeds, and the highest two speeds as proxies for the currently-proposed low-speed setting, middle-speed setting, and high-speed setting, respectively. (CA IOUs, No. 144 at p. 3) As previously mentioned, in the energy use analysis, DOE used the power consumption estimates developed for each representative fan in the engineering analysis. In the engineering analysis, power consumption estimates at high, medium, and low speed were developed based on the test method set forth in the test procedure final rule (CITE). Consistent with the test procedure final rule, testing was conducted at the lowest and highest speed for fans for with brushless DC motors. Testing was not conducted at the other four fan
speeds. Power consumption at medium speed for such fans was estimated based on scaling the power consumption at the middle speed setting from representative fans with three speeds. The specific distribution of time between the six fan speeds commonly had by DC-motor fans is unknown, but DOE concludes that the current approach should be a representative estimate of overall energy use for DC-motor ceiling fans.
2. Inputs for Large-Diameter and High-Speed Small-Diameter Ceiling Fans
a. Sample of Purchasers
As in the NOPR analysis, DOE has included only commercial and industrial applications in the energy use analysis of large-diameter and HSSD ceiling fans. Although some large-diameter and HSSD fans are used in residential applications, they represent a very small portion of the total market for large-diameter and HSSD ceiling fans. Similar to standard, hugger, and VSD ceiling fans, DOE developed a sample of 10,000 fans to represent the range of large-diameter and HSSD ceiling fan energy use. The sample captured variations in operating hours.
b. Operating Hours
In the NOPR analysis, DOE used feedback from manufacturers to estimate total hours of operation for HSSD ceiling fans. Manufacturers suggested a range of possible hours of operation, depending on industry and application, with 12 hours per day as a representative value. To represent a range of possible operating hours around this representative value, DOE drew 10,000 samples from a uniform distribution between 6 hours per day and 18 hours per day when calculating the energy use of HSSD fans. DOE also used manufacturer feedback to determine the proportion of operating time spent at each speed, estimating that, on average, HSSD fans spend approximately 10 percent of the time at high or low speed, and the rest of their time (approximately 80 percent) at a medium speed.
Westinghouse and ALA agreed with the average hours of use estimate for HSSD fans in the NOPR analysis, and no stakeholders expressed disagreement. (Westinghouse, Public Meeting Transcript, No. 133 at p. 79; ALA, No. 137 at p. 8) Accordingly, DOE assumed for this final rule that HSSD fans operate for 12 hours a day on average when conducting analysis for the final rule, and has maintained its assumptions regarding the operating hours distribution.
In the energy conservation standards NOPR analysis, DOE's estimate of the daily total hours of operation for large-diameter fans was consistent with total hours of operation estimate from the test procedure SNOPR. (80 FR 31487 (Jun. 3, 2015)) In the test procedure SNOPR, to weight the performance results of the ceiling fans at each of the five speeds, DOE took a simple average of the total daily hours-of-use estimate of 18 hours per day provided by MacroAir and an example of the fraction of time spent at each speed from BAS that DOE assumed implicitly agreed with the 12 hours per day estimate from the October 2014 test procedure NOPR, which yielded an average value of 15 hours per day. Id. BAS took issue with DOE's assumption and, therefore, disagreed with DOE's estimate of 15 hours of use per day (BAS, No. 138 at p. 6)
To estimate the energy consumption of large-diameter ceiling fans, DOE must make an estimate of average operating hours for such fans. Based on the available data on daily operating hours, for the final rule DOE estimated 12 hours of use per day in active mode for large-diameter ceiling fans, consistent with the hours of use estimate for HSSD fans, which are also used in commercial and industrial applications, and also consistent with estimate from the test procedure final rule (CITE).
In the NOPR analysis, DOE also modeled the fraction of time spent at each of five speeds by large-diameter ceiling fans in an approach aligned with the ceiling fans test procedure SNOPR, which proposed to test all large-diameter ceiling fans at maximum speed, 80% speed, 60% speed, 40% speed, and 20% speed. 80 FR 31487 (June 3, 2015). Taking the average of manufacturer inputs yielded the following hours of use distribution for the NOPR analysis: 1.8 hours at maximum speed, 3.5 hours at 80% speed, 3.6 hours at 60% speed, 2 hours at 40% speed, and 4.1 hours at 20% speed. BAS clarified that the input on distribution of time at different speeds was intended as an example and not as an estimate to be used in calculations. (BAS, No. 138 at p. 8) BAS further commented that there is insufficient data to assign operating hours or estimate percentages of operation. (BAS, Public Meeting Transcript, No. 133 at pp. 83-84) BAS recommended against the use of an average of two sets of operating hours in deriving operating hours for large-diameter ceiling fans and recommended measuring at high speed only or using a metric that includes equal weighting at the five proposed operating speeds. (BAS, No. 138 at p. 6)
For the final rule, based on lack of available data to suggest otherwise, DOE gave equal weighting to each of the five speeds from the test procedure, consistent with BAS's suggestion and consistent with the approach in the test procedure final rule. (CITE)
c. Power Consumption at Each Speed and Standby
For the large-diameter ceiling fan product class, the power consumption for a given representative fan was determined by the weighted average of power consumption at the five speeds discussed previously, where each speed was weighted by an equal fraction of time spent at that speed, as detailed in chapter 5 of the final rule TSD.
For the HSSD ceiling fan product class, as in the NOPR analysis, DOE determined power consumption at high speed for each representative fan in the engineering analysis. To estimate the power consumption at medium speed, DOE multiplied the high-speed power by the average ratio between high-speed power and medium-speed power in the standard, hugger, and VSD fans engineering analysis. DOE used the same approach for low-speed power, using the average ratio between high-speed power and low-speed power from the standard, hugger, and VSD fans engineering analysis.
As in the NOPR analysis, in this final rule DOE considered all HSSD fans at the efficiency levels with a brushless DC motor to have standby power, assuming a remote control was included for all such fans. DOE estimated 0.7 watts as the standby power value for all representative fans in the HSSD product class. Because these fans also have standby power as a result of a remote control receiver, this is the same value used for standard, hugger and VSD fans, as discussed in section IV.E.1.c.
DOE also considered large-diameter fans to have standby power, because available information indicated that the majority of large-diameter ceiling fans in the market use a variable-frequency drive and/or are operated by remote control, which consumes standby power. The standby power for large-diameter ceiling fans was estimated to be 7 watts in the engineering analysis (see chapter 5 of the final rule TSD).
For HSSD and large-diameter ceiling fans with standby power consumption, DOE assumed that all hours not spent in active mode were in standby mode.
3. Impact on Air Conditioning or Heating Equipment Use
DOE did not account for any interaction between ceiling fans and air conditioning or heating equipment in
the NOPR analyses. In DOE's estimation it appeared unlikely that consumers would substantially increase air conditioning use, or forego purchasing a ceiling fan in lieu of an air conditioning unit, due to a modest increase in the initial cost of a ceiling fan due to an amended energy conservation standard. Therefore the interaction between ceiling fan use and air conditioning use would be unlikely to be different in the case of amended standards than it would be in the no-new-standards case.
ASAP, et al. and the CA IOUs agree that the interaction between ceiling fan and air conditioning use would be negligible on a national level. (ASAP, et al., No. 142 at p. 5) The CA IOUs also agreed with DOE's decision not to include the air conditioning interaction in its analyses for this rule, based on the lack of available data. (CA IOUs, No. 144 at p. 2) ALA suggested that DOE's proposed ceiling fan efficiency standards could result in increased air conditioning use, because many ceiling fan consumers already have air conditioning units—which provide substitutionary cooling at no additional cost—and will therefore be more price sensitive to the price of ceiling fans. (ALA, No. 137 at p. 8) BAS pointed out that shipments projections do not directly reflect the possibility of consumers increasing their air conditioning set point and using the ceiling fan at high speeds. (BAS, Public Meeting Transcript, No. 133 at pp. 77-78)
As noted in the NOPR, DOE agrees that ceiling fans have the theoretical potential to be an inexpensive and effective replacement for air conditioning use; however, the interaction between ceiling fan use and air conditioning use is unlikely to be different in the case of amended standards than it would be in the no-new-standards case. The shipments analysis projects a modest change of shipments for standard, hugger, and VSD fans of less than 1% under the adopted standard level, and it is unclear what would motivate consumers to change their air conditioner's set point or otherwise change their air-conditioning behavior if they own a ceiling fan regardless of whether there is a new or amended standard. DOE did not account for such interaction in the final rule analyses.
The Center for the Built Environment at the University of California, Berkeley (CBE) agreed with DOE that a modest increase in ceiling fan price is unlikely to increase air conditioning use, but suggested that DOE conduct analyses on the building level rather than only considering ceiling fan cost savings. (CBE, No. 143 at p. 2) BAS cited three projects using building automation systems to vary ceiling fan speed that resulted in a reduction or elimination of air conditioning use. (BAS, No. 138 at p. 10) It was reported in one of the projects cited by BAS that the use of ceiling fans in a school can provide up to 4 °F of “additional effective” or “perceived” cooling. In the other two projects, the use of ceiling fans resulted in expanded temperature ranges in buildings, such as from a 72 °F to 75 °F range to a 68 °F to 82 °F range.
While DOE appreciates the provision of quantifiable outcomes, it is not clear if and how such cooling translates to applications beyond the specific cases cited, which may not be representative of ceiling fan usage in general. Moreover, as discussed previously, the interaction between ceiling fan use and air conditioning use is unlikely to be significantly different in the case of amended standards than it would be in the no-new-standards case. Customers who would purchase ceiling fans as a cost-effective substitute are for air-conditioning or heating equipment are free to do so regardless of whether there is any amended standard.
F. Life-Cycle Cost and Payback Period Analysis
DOE conducts LCC and PBP analyses to evaluate the economic impacts on individual consumers of potential energy conservation standards. The effect of new or amended energy conservation standards on individual consumers usually involves a reduction in operating cost and an increase in purchase cost. DOE uses the following two metrics to measure consumer impacts:
• The LCC (life-cycle cost) is the total consumer expense of an appliance or product over the life of that product, consisting of total installed cost (manufacturer selling price, distribution chain markups, sales tax, and installation costs) plus operating costs (expenses for energy use, maintenance, and repair). To compute the operating costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the product.
• The PBP (payback period) is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of a more-efficient
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