Energy Conservation Program: Test Procedure for Fans and Blowers
Federal RegisterJul 25, 2022
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 431
[EERE-2021-BT-TP-0021]
RIN 1904-AF17
Energy Conservation Program: Test Procedure for Fans and Blowers
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking, request for comment, and announcement of public meeting.
SUMMARY:
The U.S. Department of Energy (“DOE”) proposes to establish a test procedure for fans and blowers, including air-circulating fans, and to adopt through reference the relevant industry test standards as the DOE test procedure for measuring the fan electrical input power (“FEP”) and for determining the fan energy index (“FEI”). DOE also proposes to establish supporting definitions, requirements for alternative energy use determination methods, and sampling requirements to determine the represented values of FEP and FEI. DOE is seeking comment from interested parties on the proposal.
DATES:
DOE will accept comments, data, and information regarding this proposal no later than September 23, 2022. See section V, “Public Participation,” for details.
DOE will hold a webinar on Tuesday, August 2, 2022, from 1:00 p.m. to 4:00 p.m. See section V, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.
ADDRESSES:
Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at
www.regulations.gov,
under docket number EERE-2021-BT-TP-0021. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, identified by docket number EERE-2021-BT-TP-0021, by any of the following methods:
(1)
Email: FansBlowers2021TP0021@ee.doe.gov.
Include the docket number EERE-2021-BT-TP-0021 in the subject line of the message.
(2)
Postal Mail:
Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 287-1445. If possible, please submit all items on a compact disc (“CD”), in which case it is not necessary to include printed copies.
(3)
Hand Delivery/Courier:
Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, 950 L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202) 287-1445. If possible, please submit all items on a CD, in which case it is not necessary to include printed copies.
No telefacsimiles (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on this process, see section V of this document.
Docket:
The docket for this activity, which includes
Federal Register
notices, public meeting attendee lists and transcripts (if a public meeting is held), 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.
The docket web page can be found at
www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/65.
The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section V for information on how to submit comments through
www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-2J, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-9879 Email:
ApplianceStandardsQuestions@ee.doe.gov.
Ms. Amelia Whiting, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-2588. Email:
amelia.whiting@hq.doe.gov.
For further information on how to submit a comment, review other public comments and the docket, or participate in a public meeting (if one is held), contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:
ApplianceStandardsQuestions@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
DOE proposes to incorporate by reference the following industry standard into 10 CFR parts 429 and 431:
ANSI/AMCA Standard 214-21, “Test Procedure for Calculating Fan Energy Index for Commercial and Industrial Fans and Blowers.”
Copies of AMCA 214-21 can be obtained from AMCA International at 30 West University Drive, Arlington Heights, IL 60004-1893, (847) 394-0150, or by going to
www.amca.org.
DOE proposes to incorporate by reference the following industry standards into 10 CFR part 431:
American National Standard Institute (ANSI)/Air Movement and Control Association (AMCA) Standard 99-16 “Standards Handbook.”
ANSI/AMCA Standard 210/American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) 51-16, “Laboratory Methods of Testing Fans for Certified Aerodynamic Performance Rating.”
ANSI/AMCA 230-15 with errata, “Laboratory Methods of Testing Air Circulating Fans for Rating and Certification”, with technical errata sheet for ANSI/AMCA standard 230-15 density corrections.
ANSI/AMCA Standard 240-15 “Laboratory Methods of Testing Positive Pressure Ventilators for Aerodynamic Performance Rating.”
Copies of AMCA 99-16, AMCA 210-16, AMCA 214-21, AMCA 230-15, with errata and AMCA 240-15, can be obtained from AMCA International at 30 West University Drive, Arlington Heights, IL 60004-1893, or by going to
www.amca.org.
International Organization for Standardization (ISO) 5801:2017, “Fans—Performance testing using standardized airways,” approved 2017. ISO 80079-36:2016, “Explosive atmospheres—Part 36: Non-electrical equipment for explosive atmospheres—Basic method and requirements,” approved 2016.
Copies of ISO 5801:2017-2017 and ISO 80079-36:2016 can be obtained from the International Organization for Standardization, Chemin de Blandonnet 8, CP 401, 1214 Vernier, Geneva, Switzerland, or by going to
www.iso.org.
See section IV.M of this document for a further discussion of these standards.
Table of Contents
I. Authority and Background
A. Authority
B. Background
C. Deviation From the Process Rule
II. Synopsis of the Notice of Proposed Rulemaking
III. Discussion
A. Scope of Applicability
1. Proposed Test Procedure Scope
2. Proposed Fan and Blower Exclusions
3. Proposed Exclusion of Embedded Fans and Blowers
4. Air Circulating Fans
5. Non-Electric Drivers
6. Replacement Parts
B. Definitions
1. Fan and Blower Categories
2. Basic Model
3. Safety Fans
4. Air Circulating Fans
5. Definitions Related to Heat Rejection Equipment
6. Outlet Area
C. Industry Standards
D. Proposed Adoption of the Test Procedure in AMCA 214-21 and Modifications to the Test Procedure
1. Motor Efficiency Calculation
2. Combined Motor and Controller Efficiency Calculation
3. Annex A of AMCA 214-21
4. Annex E of AMCA 214-21
5. Section 6.5 of AMCA 214-21 and Annex F
6. Annex H and Annex I of AMCA 214-21
7. Section 8.3 of AMCA 214-21
8. Measurement of PRV Performance
9. Exclusively Embedded Fans
10. Wire-to-Air Testing for Air Circulating Fans
11. Total Pressure Calculation for Air Circulating Fans
12. Appurtenances
13. Voltage, Phase and Frequency
14. Test Speeds for Air Circulating Fans
15. Determination of Equilibrium
16. Test Figures
17. Reference Fan Electrical Input Power Calculation
18. Rounding
19. Location of Extraneous Airflow Measurement
20. Run-In Requirements
21. Transducer Type Barometers
E. Distinguishing Between Fans and Blower and Air Circulating Fans
F. Metric
G. Efficiency Considerations for Certain Unducted Fans
H. Control Credit Approach
I. Use of a Single Test Procedure Nationally
J. Alternative Energy Determination Methods (AEDM)
1. Validation
2. Additional AEDM Requirements
3. AEDM Verification Testing
K. Sampling Plan
L. Enforcement Provisions
M. Test Procedure Costs and Impact
1. Estimated Costs for Testing Fans and Blowers at a Third-Party Facility
2. Estimated Cost To Develop, Validate, and Implement an AEDM
3. Voluntary Representations
N. Compliance Date
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Descriptions of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, Rule
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
4. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration Act of 1974
M. Description of Materials Incorporated by Reference
V. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for Distribution
C. Conduct of the Webinar
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Authority and Background
On August 19, 2021, DOE published a coverage determination classifying fans and blowers as a covered equipment under 42 U.S.C. 6311(2)(A) and 42 U.S.C. 6312(b). 86 FR 46579 (“August 2021 Final Coverage Determination”). DOE does not currently have a test procedure or energy conservation standards for fans and blowers. The following sections discuss DOE's authority to establish a test procedure for fans and blowers and relevant background information regarding DOE's consideration of test procedures for this equipment.
A. Authority
The Energy Policy and Conservation Act, as amended (“EPCA”),
1
authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part C
2
of EPCA, added by Public Law 95-619, Title IV, section 441(a), established the Energy Conservation Program for Certain Industrial Equipment, which sets forth a variety of provisions designed to improve energy efficiency. EPCA provides that DOE may include a type of industrial equipment, including fans and blowers, as covered equipment if it determines that to do so is necessary to carry out the purposes of Part A-1. (42 U.S.C. 6311(2)(B)(ii) and (iii); 42 U.S.C. 6312(b)). EPCA specifies the types of equipment that can be classified as industrial equipment. (42 U.S.C. 6311(2)(B)) The purpose of Part A-1 is to improve the efficiency of electric motors and pumps and certain other industrial equipment in order to conserve the energy resources of the Nation. (42 U.S.C. 6312(a)) As stated, on August 19, 2021, DOE published a final determination determining that fans and blowers meet the three statutory criteria for classifying industrial equipment as covered (42 U.S.C. 6311(2)(A)), because fans and blowers are a type of industrial equipment (1) which in operation consume, or are designed to consume, energy; (2) are to a significant extent distributed in commerce for industrial or commercial use; and (3) are not covered under 42 U.S.C. 6291(a)(2). 86 FR 46579, 46586. DOE also determined that coverage of fans and blowers is necessary to carry out the purposes of Part A-1. 86 FR 46579, 46588.
1
All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020), which reflect the last statutory amendments that impact Parts A and A-1 of EPCA.
2
For editorial reasons, upon codification in the U.S. Code, Part C was redesignated Part A-1 and hereafter referred to as “Part A-1”.
The energy conservation program under EPCA consists essentially of four parts: (1) testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA include definitions (42 U.S.C. 6311), test procedures (42 U.S.C. 6314), labeling provisions (42 U.S.C. 6315), energy conservation standards (42 U.S.C. 6313), and the authority to require information and reports from manufacturers. (42 U.S.C. 6316; 42 U.S.C. 6296)
The Federal testing requirements consist of test procedures that manufacturers of covered equipment must use as the basis for: (1) certifying to DOE that their equipment complies with the applicable energy conservation standards adopted pursuant to EPCA (42 U.S.C. 6316(a); 42 U.S.C. 6295(s)), and (2) making other representations about the efficiency of that equipment. (42 U.S.C. 6314(d)) Similarly, DOE must use these test procedures to determine whether the equipment complies with relevant standards promulgated under EPCA.
3
(42 U.S.C. 6316(a); 42 U.S.C. 6295(s))
3
There are currently no energy conservation standards for fans and blowers.
Federal energy efficiency requirements for covered equipment established under EPCA supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6316(a); 42 U.S.C. 6316(b); 42 U.S.C. 6297) With respect to industrial equipment for which coverage is established under 42 U.S.C. 6312(b),
e.g.,
fans and blowers, the preemption provisions in EPCA apply beginning on the date on which a final rule establishing an energy conservation standard is issued by the Secretary,
except that any State or local standard prescribed or enacted or the equipment before the date on which the final rule is issued shall not be preempted until the energy conservation standard established by the Secretary for the equipment takes effect. (42 U.S.C. 6316(a)(10)) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions of EPCA. (42 U.S.C. 6316(b)(2)(D))
Under 42 U.S.C. 6314, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered equipment. EPCA requires that any test procedures prescribed or amended under this section must be reasonably designed to produce test results which reflect energy efficiency, energy use or estimated annual operating cost of a given type of covered equipment during a representative average use cycle and requires that test procedures not be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2))
If the Secretary determines that a test procedure amendment is warranted, the Secretary must publish proposed test procedures in the
Federal Register
and afford interested persons an opportunity (of not less than 45 days' duration) to present oral and written data, views, and arguments on the proposed test procedures. (42 U.S.C. 6314(b))
B. Background
As discussed, on August 19, 2021, DOE published in the
Federal Register
a final coverage determination classifying fans and blowers as covered equipment. 86 FR 46579. DOE determined that the term “blower” is interchangeable with the term “fan”. 86 FR 46579, 46583. DOE defines a fan (or blower) as a rotary bladed machine used to convert electrical or mechanical power to air power, with an energy output limited to 25 kilojoule (“kJ”) per kilogram (“kg”) of air. A fan (or blower) consists of an impeller, a shaft and bearings and/or driver to support the impeller, as well as a structure or housing. A fan (or blower) may include a transmission, driver, and/or motor controller. 10 CFR 431.172.
Prior to the August 2021 Final Coverage Determination, DOE published a notice of intent to establish an Appliance Standards and Rulemaking Federal Advisory Committee (“ASRAC”) Working Group (“Working Group”) for fans and blowers. 80 FR 17359 (April 1, 2015). The Working Group
4
commenced negotiations at an open meeting on May 18, 2015 and held 16 meetings and three webinars to discuss scope, metrics, test procedures, and standard levels for fans.
5
The Working Group concluded its negotiations on September 3, 2015, and, by consensus vote,
6
approved a term sheet containing recommendations for DOE on the scope of a test procedure, and energy conservation standards for fans. The term sheet containing the Working Group recommendations (“term sheet”) is available in the fans energy conservation standard rulemaking docket. (Docket No. EERE-2013-BT-STD-0006, No. 179)
7
ASRAC approved the term sheet on September 24, 2015. (Docket No. EERE-2013-BT-NOC-0005; Public Meeting Transcript, No. 58, at p. 29) Comments received on issues related to the test procedure during the Working Group negotiations and not resolved in the term sheet are discussed in this proposed rulemaking. Discussion of these comments will include a reference to Docket No. EERE-2013-BT-NOC-0005.
4
The Working Group was comprised of representatives from AAON, Inc.; AcoustiFLO LLC; AGS Consulting LLC; AMCA; AHRI, Appliance Standards Awareness Project; Berner International Corp; Buffalo Air Handling Company; Carnes Company; Daikin/Goodman; ebm-papst; Greenheck; Morrison Products; Natural Resources Defense Council; Newcomb & Boyd; Northwest Energy Efficiency Alliance; CA IOUs; Regal Beloit Corporation; Rheem Manufacturing Company; Smiley Engineering LLC representing Ingersoll Rand/Trane; SPX Cooling Technologies/CTI; The New York Blower Company; Twin City Companies, Ltd; U.S. Department of Energy; and United Technologies/Carrier.
5
Details of the negotiation sessions can be found in the public meeting transcripts that are posted to the docket for the energy conservation standard rulemaking at:
www.regulations.gov/docket?D=EERE-2013-BT-STD-0006.
6
At the beginning of the negotiated rulemaking process, the Working Group defined that before any vote could occur, the Working Group must establish a quorum of at least 20 of the 25 members and defined consensus as an agreement with less than 4 negative votes. Twenty voting members of the Working Group were present for this vote. Two members (Air-Conditioning, Heating, and Refrigeration Institute and Ingersoll Rand/Trane) voted no on the term sheet.
7
The references are arranged as follows: (commenter name, comment docket ID number, page of that document). If one comment was submitted with multiple attachments, the references are arranged as follows: (commenter name, comment docket ID number. Attachment number, page of that document). The attachment number corresponds to the order in which the attachment appears in the docket. The parenthetical reference provides a reference for information located in DOE Docket No. EERE-2021-BT-TP-0021. If the information was submitted to a different DOE docket, the DOE Docket number is additionally specified in the reference.
On January 10, 2020, DOE received a notice of petition received from the Air Movement and Control Association (“AMCA”), Air Conditioning Contractors of America, and Sheet Metal & Air Conditioning Contractors of America (“the Petitioners”) requesting that DOE establish test procedures for certain categories of commercial and industrial fans based on an industry test method in development, AMCA 214, which was published with a request for public comment on April 23, 2020;
8
85 FR 22677 (“April 2020 Notice of Petition”). As part of the April 2020 Notice of Petition, DOE sought data and information pertinent to whether an amended test procedures would (1) accurately measure energy efficiency, energy use, or estimated annual operating cost of fans during a representative average use cycle; and (2) not be unduly burdensome to conduct. 85 FR 22677, 22679.
8
At the time of the petition, AMCA 214-21 was available as a draft version (AMCA 214).
On October 1, 2021, DOE published a request for information (“RFI”) pertaining to potential test procedures for fans and blowers. 86 FR 54412 (“October 2021 RFI”). In the October 2021 RFI, DOE identified a variety of issues on which it sought input to determine whether, and if so how, potential test procedures for fans and blowers, including air circulating fans, would (1) comply with the requirements in EPCA that test procedures be reasonably designed to produce test results which reflect energy use during a representative average use cycle, and (2) not be unduly burdensome to conduct.
Id.
In response to requests from stakeholders,
9
DOE extended the comment period 14 days to November 15, 2021. 86 FR 59308 (Oct. 27, 2021).
9
AMCA requested at 21-day extension (AMCA, No. 2 at p. 1).
DOE also received comments related to the test procedure from its February 8, 2022, Energy Conservation Standards for Fans and Blower RFI (“February 2022 ECS RFI”). 87 FR 7048. Discussion of these comments will include a
reference to the docket (EERE-2022-BT-STD-0002).
Stakeholders that submitted written comment in response to the April 2020 Notice of Petition, the October 2021 RFI, and the February 2022 ECS RFI are listed in Table I-1 of this document.
10
See
Docket No. EERE-2020-BT-PET-0003.
11
The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop test procedures for fans and blowers. Unless otherwise noted, all comments referenced in this notice are available in DOE's docket for this test procedure rulemaking. (Docket No., EERE-2021-BT-TP-0021 which is maintained at
www.regulations.gov/docket EERE-2021-BT-TP-0021/
). The references are arranged as follows: (commenter name, comment docket ID number, page of that document).
12
See
Docket No. EERE-2022-BT-STD-0002.
Table I-1—List of Commenters With Written Submissions in Response to the April 2020 Notice of Petition and October 2021 RFI
Organization(s)
Reference in this NOPR
Organization type
April 2020
notice of
petition
10
October 2021 TP RFI
11
February 2022 ECS RFI
12
Air-Conditioning, Heating, and Refrigeration Institute
AHRI
Trade Association
X
X
Air Movement and Control Association International
AMCA
Trade Association
X
X
Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, Natural Resources Defense Council
ASAP, ACEEE, NRDC
Efficiency Organizations
X
X
Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, Natural Resources Defense Council, Northwest Energy Efficiency Alliance
ASAP, ACEEE, NRDC, NEEA
Efficiency Organizations
X
China World Trade Organization/Technical Barriers to Trade
China WTO/TBT
Government Agency
X
Cooling Technology Institute
CTI
Trade Association
X
N/A
Corvino
Individual
X
Daikin Applied
Daikin
Manufacturer
X
ebm-papst Inc
ebm-papst
Manufacturer
X
X
Greenheck Group
Greenheck
Manufacturer
X
Harry Graves
Graves
Individual
X
Johnson Controls
Johnson Controls
Manufacturer
X
Lennox International Inc
Lennox
Manufacturer
X
Marley Engineering Products LLC
MEP
Manufacturer
X
Morrison Products Inc
Morrison
Manufacturer
X
Northwest Energy Efficiency Alliance
NEEA
Efficiency Organization
X
Northwest Energy Efficiency Alliance and Northwest Power and Conservation Council
NEEA and NWPCC
Efficiency Organizations
X
Pacific Gas and Electric Company, San Diego Gas and Electric, and Southern California Edison; collectively, the California Investor-Owned Utilities
CA IOUs
Utilities
X
X
Note:
“X” indicates the notice(s) that each stakeholder commented on.
In response to the April 2020 Notice of Petition, Lennox commented that DOE should reject the fan test procedure petition because no coverage determination had been finalized. (Docket No. EERE-2020-BT-PET-0003, Lennox, No. 5 at p. 1) AHRI and Johnson Controls commented that DOE would first need to establish fans as covered equipment before initiating a test procedure rulemaking. (Docket No. EERE-2020-BT-PET-0003, AHRI, No. 14 at p. 3; Johnson Controls, No. 10 at p. 1) In response to the October 2021 TP RFI, AHRI and Morrison commented that they appreciate DOE's efforts to define fans and blowers and commented that DOE should finalize the coverage determination process to determine if a stand-alone commercial and industrial fans regulation is “necessary or appropriate” to the achievement of EPCA's purposes. (AHRI, No. 10 at p. 3; Morrison, No. 8 at p. 2)
DOE is publishing this NOPR following the publication of the August 2021 Final Coverage Determination.
Corvino commented that there is a need for fan test procedures and suggested that DOE investigate costs related to testing. (Corvino, No. 3 at p. 1) MEP commented generally that the steps required to create new regulations place a tremendous burden upon the industry, especially for newly covered products. MEP asserted that the first efficiency rulemaking places a burden on the industry in preparation for the rulemaking that is larger than the average burden attributed to subsequent rulemakings during the life cycle cost analysis used in determining the minimum allowable efficiencies. (MEP, No. 5 at p. 2)
DOE analyzes the costs of any potential test procedure, as discussed in section III.M. DOE is proposing test procedures for fans and blowers. DOE is not proposing to establish energy conservation standards for such covered equipment in this proposed rule. To the extent that DOE were to propose energy conservation standards for fans and blowers, DOE would conduct a manufacturer impact analysis in that rulemaking.
II. Synopsis of the Notice of Proposed Rulemaking
In this NOPR, DOE proposes to establish a test procedure for fans and blowers in subpart J of part 431 and to modify part 429, as follows:
(1) Establish the scope of the test procedure for fans and blowers as to include standalone and embedded fans and blowers (
i.e.,
fans and blowers incorporated into other equipment), with fan shaft input power equal to or greater than 1 horsepower and fan airpower equal to or less than 150 horsepower that are either: (1) axial inline fans; (2) axial panel fans; (3) centrifugal housed fans; (4) centrifugal unhoused fans; (5) centrifugal inline fans; (6) radial-housed fans; or (7) power roof/wall ventilators (“PRVs”); air-circulating fans; and excluding some fans that are exclusively embedded in other products of equipment; and excluding radial housed unshrouded fans with diameter less than 30 inches or a blade width of less than 3 inches, safety fans, induced flow fans, jet fans, and cross-flow fans.
(2) Define “axial inline fan”, “axial panel fan”, “centrifugal housed fan”, “centrifugal unhoused fan”, “centrifugal inline fan”, “radial-housed fan”, “power roof ventilator”, “cross-flow fan”, “induced flow fan”, “jet fan”, “basic model,” “safety fan,” “air circulating fan,” and related terms. Define terms related to heat rejection equipment;
(3) Adopt through reference in newly proposed appendix A to subpart J of 10 CFR part 431 (“appendix A”) certain provions of ANSI/AMCA 214-21, “Test Procedure for Calculating Fan Energy Index for Commercial and Industrial Fans and Blowers” (“AMCA 214-21”), with modifications, as the test procedure for determining FEP and FEI of fans and blowers other than circulating fans;
(4) Adopt through reference in newly propsoed appendix B to subpart J of 10 CFR part 431 (“appendix B”) certain provisions of AMCA 214-21, with modifications, as the test procedure for determining FEP and FEI of air circulating fans;
(5) Adopt through reference certain provisions of the following industry standards referenced by AMCA 214-21: ANSI/AMCA 210-16, (“AMCA 210-16”) “Laboratory Methods of Testing Fans for Certified Aerodynamic Performance Rating”; ANSI/AMCA 230-15, (“AMCA 230-15 with errata”) “Laboratory Methods of Testing Air Circulating Fans for Rating and Certification” with errata; and ISO 5801:2017, “Fans—Performance testing using standardized airways”;
(6) Establish fan and blower sampling requirements and provisions related to determining represented values in 10 CFR 429.64;
(7) Establish an alternative effiency determination method (“AEDM”) for fans and blowers in 10 CFR 429.70; and
(8) Establish enforcements provisions for fan and blower basic models.
The proposal is summarized in Table II.2.
Table II.2—Summary of Proposals in This TP NOPR, Their Proposed Location Within the Code of Federal Regulations, and the Applicable Preamble Discussion
Topic
Location in CFR
Summary of proposals
Applicable preamble
discussion
Scope
10 CFR 431.174
Establish the scope of the test procedure for fans and blowers as to include standalone and embedded fans and blowers (
i.e.,
fans and blowers incorporated into other equipment), with fan shaft input power equal to or greater than 1 horsepower and fan airpower equal to or less than 150 horsepower that are either: (1) axial inline fans; (2) axial panel fans; (3) centrifugal housed fans; (4) centrifugal unhoused fans; (5) centrifugal inline fans; (6) radial-housed fans; or (7) power roof/wall ventilators (“PRVs”); air-circulating fans; and excluding some fans that are exclusively embedded in other products of equipment; and excluding radial housed unshrouded fans with diameter less than 30 inches or a blade width of less than 3 inches, safety fans, induced flow fans, jet fans, and cross-flow fans
Section III.A.
Definitions
10 CFR 431.172
Define “axial inline fan”, “axial panel fan”, “centrifugal housed fan”, “centrifugal unhoused fan”, “centrifugal inline fan”, “radial-housed fan”, “power roof ventilator”, “cross-flow fan”, “induced flow fan”, “jet fan”, “basic model,” “safety fan,” “air circulating fan,” and related terms. Define terms related to heat rejection equipment;
Section III.B.
Test Procedure
10 CFR 431.174
Establish FEI as the metric for fans and blowers, incorporate by reference AMCA 214-21, AMCA 210-16, AMCA 230-15 (with errata) and provide additional instructions for determining the FEI (and other applicable performance characteristics) for fans and blowers
Sections III.C, III.D, and III.F.
Sampling Plan
10 CFR 429.66
Specify the minimum number of fans or blowers to be tested to rate a basic model and determine representative values
Section III.K.
AEDM
10 CFR 429.70
Establish requirements for applying an alternative energy use determination method
Section III.J.
Enforcement Provisions
10 CFR 429.110 & 10 CFR 429.134
Establish a method for determining compliance of fan and blower basic models
Section III.L.
DOE's proposed test method for fans and blowers includes measurements of pressure, flow rate, and fan shaft or electrical input power, all of which are required to calculate FEP and FEI, as well as other quantities to characterize rated fans and blowers performance (
e.g.,
speed). DOE has tentatively determined that the relevant sections of AMCA 214-21, AMCA 210-16 and AMCA 230-15 with errata, in conjunction with the additional provisions proposed in this test procedure, would produce test results that reflect the energy efficiency and energy use of a fan or blower during a representative average use cycle. (42 U.S.C. 6314(a)(2)) Additionally, DOE has tentatively determined that the proposed test procedure, which is based on the relevant industry testing standard, would not be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2)) DOE's analysis of the burdens associated with the proposed test procedure is presented in section III.M of this document.
III. Discussion
In the following sections, DOE proposes to establish test procedures and related definitions for fans and blowers in subpart J of part 431, to establish sampling plans for this equipment, to establish an alternative energy determination method for this equipment, and to establish enforcement provisions for this equipment. In the following section, DOE provides relevant background information, explains why the proposal merits consideration, discusses relevant public comments, and proposes a potential approach.
A. Scope of Applicability
This rulemaking applies to fans and blowers. A fan or blower is defined as a rotary bladed machine that is used to convert electrical or mechanical power to air power with an energy output limited to 25 kilojoule (“kJ”)/kilogram (“kg”) of air. 10 CFR 431.172. It consists of an impeller, a shaft and bearings and/or driver to support the impeller, as well as a structure or housing.
Id.
A fan or blower may include a transmission, driver, and/or motor controller.
Id.
As discussed, DOE has classified fans and blowers as covered equipment. 86 FR 46579. “Covered equipment” consists of certain industrial equipment, which in turn excludes covered products, other than industrial equipment that is a component of a covered product. (42 U.S.C. 6311(1) and (2)(A)(iii)). DOE explained in the coverage determination that the fans and blowers, the subject to this rulemaking, do not include ceiling fans and furnace fans, as defined at 10 CFR 430.2.
See
86 FR 46579, 46586.
In the August 2021 Final Coverage Determination, DOE did not establish definitions for specific categories of fans and blowers. DOE stated that it would consider specific categories of fans and blowers and the scope of applicability of test procedures and energy conservation standards in their respective rulemakings. 86 46579, 46585.
This section discusses the fans and blowers that DOE is proposing to include in the scope of applicability of the test procedure as well as proposed exemptions.
1. Proposed Test Procedure Scope
This section discusses fans and blowers, other than air circulating fans, proposed for inclusion in the scope of applicability of the test procedure. Air circulating fans are discussed in section III.A.4 of this document.
The Working Group recommended that the test procedure be applicable to certain classifications of fans and blowers, listed in Table III-1 of this document. (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #1 at p. 1) The Working Group did not provide definitions for the specified classifications of the fans and blowers identified for inclusion in the scope of a test procedure. AMCA 214-21 provides terms and associated definitions for certain classifications of fans and blowers that DOE has tentatively determined correspond to the Working Group recommendation. The Working Group further recommended that the test procedure apply only to fans with a fan shaft power equal to or greater than 1 horsepower (“hp”) and fan air power
13
equal to or less than 150 hp. The Working Group recommended that airpower be calculated using static pressure for unducted fans (“static airpower”) and total pressure for ducted fans (“total airpower”).
14
(Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #5, at p. 4)
13
The air power of a fan is the fan's output power. It is proportional to the product of the fan airflow rate and the fan pressure.
14
The terms “ducted” and “unducted” refer to the recommended test configuration used when conducting a fan test. Appendix C of the term sheet specifies which fan categories are typically ducted (
i.e.,
tested using a ducted outlet and for which the FEI is calculated on a total pressure basis): axial cylindrical housed, centrifugal housed, excluding inline and radial, inline and mixed flow, radial housed; and which fan types are considered unducted (
i.e.,
tested with a free outlet and for which the FEI is calculated on a static pressure basis): panel, centrifugal unhoused, excluding inline and radial, and power roof ventilators.
On February 24, 2022, the California Energy Commission (“CEC”) published a proposed rulemaking for fans and blowers that includes terms and definitions that DOE has tentatively determined correspond to the Working Group recommendations.
15
CEC proposes to cover the following fan categories: axial inline, axial panel, centrifugal housed, centrifugal unhoused, centrifugal inline, radial housed, and power roof/wall ventilators, and to define these terms largely based on the definitions in AMCA 214-21, with revisions to indicate a fan's intended application and if a fan's inlet or outlet can be (optionally, as applicable) ducted. In addition, the CEC proposal considers fans and blowers that have a rated fan shaft power greater than or equal to 1 horsepower, or, for fans without a rated shaft input power, an electrical input power greater than or equal to 1 kW, and a fan output power less than or equal to 150 horsepower.
16
15
All documents related to this rulemaking can be found in the rulemaking Docket 22-AAER-01 accessible at:
www.energy.ca.gov/rules-and-regulations/appliance-efficiency-regulations-title-20/appliance-efficiency-proceedings-11.
16
See
Proposed regulatory language for Commercial and Industrial Fans and Blowers available in the following Docket: 22-AAER-01 at:
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
The classification of fans and blowers recommended by the Working Group for coverage under a test procedure and the corresponding terms and definitions in AMCA 214-21 and the proposed CEC regulations are presented in Table III-1 of this document.
Table III-1—Scope Recommended by the Working Group, Corresponding Terms and Definitions
Working group scope recommendations
Corresponding term and definition in AMCA 214-21
Corresponding CEC definitions
Axial cylindrical housed fan
“Axial inline fan” means a fan with an axial impeller and a cylindrical housing with or without turning vanes
“Axial-inline fan” means a fan with an axial impeller and a cylindrical housing with or without turning vanes. Inlets and outlets can optionally be ducted.
Panel fan
“Axial panel fan” means an axial fan, without cylindrical housing, that is mounted in a panel, an orifice plate or ring
“Axial-panel fan” means a fan with an axial impeller mounted in a short housing, non-cylindrical, that can be a panel, ring, or orifice plate. The housing is typically mounted to a wall separating two spaces, and the fans are used to increase the pressure across this wall. Inlets and outlets are not ducted.
Centrifugal housed fan, excluding inline fan and radial fan
“Centrifugal housed fan” means a fan with a centrifugal or mixed flow impeller in which airflow exits into a housing that is generally scroll-shaped to direct the air through a single fan outlet. A centrifugal housed fan does not include a radial impeller *
“Centrifugal housed fan” means a fan with a centrifugal or mixed flow impeller in which airflow exits into a housing that is generally scroll-shaped to direct the air through a single fan outlet. Inlets and outlets can optionally be ducted. It does not include a radial impeller.
Centrifugal unhoused fan, excluding radial fan
“Centrifugal unhoused fan” means a fan with a centrifugal or mixed flow impeller in which airflow enters through a panel and discharges into free space. Inlets and outlets are not ducted. This fan type also includes fans designed for use in fan arrays that have partition walls separating the fan from other fans in the array **
“Centrifugal unhoused fan” means a fan with a centrifugal or mix-flow impeller in which airflow enters through a panel and discharges into free space. Inlets and outlets are not ducted. This fan type also includes fans designed for use in fan arrays that have partition walls separating the fan from other fans in the array.
Inline and mixed-flow fan
“Centrifugal inline fan” means a fan with a centrifugal or mixed flow impeller in which airflow enters axially at the fan inlet and the housing redirects radial airflow from the impeller to exit the fan in an axial direction
“Centrifugal inline fan” means a fan with a centrifugal or mixed-flow impeller in which airflow enters axially at the fan inlet and the housing redirects radial airflow from the impeller to exit the fan in an axial direction. Inlets and outlets can optionally be ducted.
Radial housed fan
“Radial-housed fan” means a fan with a radial impeller in which airflow exits into a housing that is generally scroll-shaped to direct the air through a single fan outlet. Inlets and outlets can optionally be ducted
“Radial-housed fan” means a fan with a radial impeller in which airflow exits into a housing that is generally scroll-shaped to direct the air through a single fan outlet. Inlets and outlets can optionally be ducted.
Power roof ventilator
“Power roof/wall ventilator (PRV)” means a fan with an internal driver and a housing to prevent precipitation from entering the building. It has a base designed to fit over a roof or wall opening, usually by means of a roof curb
“Power roof ventilator (PRV)” or “power wall ventilator (PWV)” means a fan with an internal driver and a housing to prevent precipitation from entering the building. It has a base designed to fit over a roof or wall opening, usually by means of a roof curb.
* The inclusion of “scroll-shaped” in this definition excludes inline fans.
** Radial fans are housed and therefore not included in this definition.
In response to the April 2020 Notice of Petition, ebm-papst commented in favor of a broader test procedure scope and stated that any limitation on scope should be made in future labeling requirements, certification requirements, or energy conservation standards. ebm-papst stated that AMCA 214-21 was designed for fans above 0.745 mechanical kilowatts shaft power (equivalent to 1 hp) or 0.890 electrical kilowatts, and below 112 kilowatts (equivalent to 150 hp) air power, and that these requirements should be the only scope restrictions on the test procedure. (Docket No. EERE-2020-BT-PET-0003, ebm-papst, No. 9)
In response to the April 2020 Notice of Petition for Rulemaking, AHRI commented that the scope of the DOE test procedure should ideally align with the scope of AMCA 214 as finalized and that AHRI was working with AMCA to resolve scope concerns in AMCA 214 (Docket No. EERE-2020-BT-PET-0003, AHRI, No. 14 at p. 2).
In this NOPR, DOE proposes to include all fans and blowers that are included within the scope of AMCA 210-16 (referenced by AMCA 214-21) and proposes that the test procedure would be applicable to the following fans and blowers, as proposed in section III.A.10 of this document and subject to the exclusions discussed in section III.A.2 of this document: (1) axial inline fan; (2) axial panel fan; (3) centrifugal housed fan; (4) centrifugal unhoused fan; (5) centrifugal inline fan; (6) radial-housed fan; and (7) power roof/wall ventilator (“PRV”).
17
17
PRVs include: Centrifugal PRV exhaust fans; Centrifugal PRV supply fans; and Axial PRVs, as defined in AMCA 214-21.
DOE is proposing that the scope of the test procedure cover fans and blowers with a fan shaft input power equal to or greater than 1 horsepower and a fan static or total air power equal to or less than 150 horsepower.
DOE has tentatively determined that the 1 hp fan shaft power lower limit may not be a practical unit of measurement for all fans because some fans are designed such that the measurement of the shaft input power is not feasible, and the only feasible measurement is the FEP, which is measured in units of kW. For example, some fans incorporate the bare-shaft and the motor in the same enclosed housing and do not provide access to the fan shaft (
i.e.,
between the motor and the fan), where the measurement of the fan shaft power would be conducted. DOE relied on the motor efficiency equations provided in Section 6.4.2.3 of AMCA 214-21 to convert the fan shaft power into electrical input power
18
and has tentatively determined that 0.89 kW is appropriate to establish a standardized equivalent to the 1 hp fan shaft input power limit. Additionally, Section 6.5.3.1.3 “Fan Efficiency Requirements” of ANSI/ASHRAE/IES 90.1, “Energy Standard for Buildings except Low-Rise Residential Buildings (2019)” (“ASHRAE 90.1-2019”) relies on the value of 0.89 kW as the corresponding threshold to a value of 1 hp of shaft input power.
18
The electrical input power is equal to the fan shaft input power divided by the motor efficiency.
Accordingly, DOE proposes that the test procedure would be applicable to a fan or blower with duty points
19
with the following characteristics: (1) a fan shaft input power equal to or greater than 1 horsepower and a fan static or total air power equal to or less than 150 horsepower, or (2) a FEP equal to or greater than 0.89 kW and a fan static or total airpower equal to or less than 150 horsepower.
19
A duty point is characterized by a given airflow and pressure and has a corresponding operating speed.
DOE further proposes to establish the 150 hp upper limit in terms of total airpower for fans and blowers that use a total pressure basis FEI and would be required to be tested with a ducted outlet according to the proposed provisions adopted through reference to AMCA 214-21. For fans and blowers that use a static pressure basis FEI and that would be required to be tested using a free outlet under the provisions of AMAC 214-21 proposed to be adopted by reference, DOE proposes to establish the airpower limit in terms of
static airpower. Table III-9 of this document lists the fan and blower categories that rely on a total or static pressure basis in accordance with AMCA 214-21.
DOE proposes the lower 1 hp limit to match the technical applicability of the AMCA 214-21 and AMCA 210-16 test procedures. DOE is proposing the upper air power limit at this time because fans that operate above the proposed upper limit are typically custom orders and are too large to be tested in a laboratory setting. In addition, these limits are in line with the Working Group recommendations and the CEC scope. DOE may consider methods for test for these fans in a future rulemaking.
Finally, to define total airpower, DOE proposes to rely on the definition of “fan output power” in AMCA 210-16. DOE proposes to define “total airpower” as the total power delivered to air by the fan; it is proportional to the product of the fan airflow rate, the fan total pressure, and the compressibility coefficient and is calculated in accordance with Section 7.8.1 of AMCA 210-16. See the definition of “fan output power” in Section 3.1.31 of AMCA 210-16 and calculation formulas in Section 7.8.1 of AMCA 210-16. DOE also proposes to define “static air power” as the static power delivered to air by the fan; it is proportional to the product of the fan airflow rate, the fan static pressure, and the compressibility coefficient and is calculated in accordance with Section 7.8.1 of AMCA 210-16, using static pressure instead of total pressure.
Fan and blower categories proposed to be exempted from the scope of this test procedure are discussed in section III.A.2 of this document.
DOE requests comment on the fans and blowers, other than air circulating fans, proposed for inclusion in the DOE test procedure.
DOE requests comment on the proposed limits based on fan airpower, fan shaft input power and fan electrical input power for fans other than air circulating fans. Specifically, DOE requests comment on the proposed definitions of “static airpower” and “total airpower” used to characterize the upper 150 horsepower limit for fans other than air circulating fans.
2. Proposed Fan and Blower Exclusions
DOE proposes to explicitly exclude certain fans and blowers from the scope of the test procedure.
The Working Group recommended to exclude circulating fans (also known as air circulating fans), induced flow fans, jet fans, and cross-flow fans. (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #2, at pp. 2-3) The Working Group also recommended to exclude safety fans due to low operating hours and specific design features that impair efficiency (
e.g.,
high tip clearance), and a subset of radial fans that are used for material handling applications
20
(
e.g.,
to move paper dust, sand).
21
(Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #2, at pp. 2-3) Table III-2 of this document presents the exclusions recommended by the Working Group.
20
Specifically, radial housed unshrouded fans, which means a radial housed fan for which the impeller blades are attached to a backplate and hub (
i.e.,
open radial blade), or to a hub only (
i.e.,
open paddle wheel), and with an open front at the impeller's inlet. These are different than radial shrouded fans, for which the impeller blades are attached to a backplate and to a ring or “shroud” at the impeller's inlet.
21
The discussions of the Working Group related to these exclusions can be found in the meeting transcripts, available in the fans energy conservation standard rulemaking docket. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 161 at pp. 63-70; Public Meeting Transcript, No. 85 at pp. 60-62).
Table III-2—Fan Categories Recommended for Exclusion by the Working Group
Fan category recommended for
exclusion by the working group *
Definition in AMCA 214-21
Radial housed unshrouded fan with diameter less than 30 inches or a blade width of less than 3 inches
Included in the definition “radial housed fan” as noted in Table III-1.
Safety fan
Not defined in AMCA 214-21.
Induced flow fan
“Induced flow fan” means a type of laboratory exhaust fan with a nozzle and windband; the fan's outlet airflow is greater than the inlet airflow due to induced airflow. All airflow entering the inlet exits through the nozzle. Airflow exiting the windband includes the nozzle airflow plus the induced airflow.
Jet fan
“Jet fan” means a fan designed and marketed specifically for producing a high velocity air jet in a space to increase its air momentum. Jet fans are rated using thrust. Inlets and outlets are not ducted but may include acoustic silencers.
Cross-flow fan
“Cross-flow fan” means a fan with a housing that creates an airflow path through the impeller in a direction at right angles to its axis of rotation and with airflow both entering and exiting the impeller at its periphery. Inlets and outlets can optionally be ducted.**
*
Note:
the Working Group also recommended to exclude circulating fans, (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #2, at pp. 2-3) which are defined in AMCA 214-21 as a fan that is not a ceiling fan that is used to move air within a space that has no provision for connection to ducting or separation of the fan inlet from its outlet. The fan is designed to be used for the general circulation of air. Circulating fans are discussed in Section III.A.4 of this document.
** Excluded from AMCA 214-21 and defined in ANSI/AMCA Standard 208, “Calculation of the Fan Energy Index for calculating FEI” (“AMCA 208-18”).
The Petitioners requested that the scope of any future DOE test procedure be consistent with the scope described in the term sheet, and requested to exclude fans that cannot be tested per AMCA 210-16 (
i.e.,
the physical test method referenced in AMCA 214-21).
22
The Petitioners also requested that the scope of the test procedure be consistent with ASHRAE 90.1-2019. (Docket No. EERE-2020-BT-PET-0003, The Petitioners, No. 1, attachment “AMCA Petition to DOE Cover Letter and Petition [sic] 2020110” at pp. 7-8)
22
For example, circulating fans, ceiling fans, desk fans, jet tunnel fans, and induced flow fans (
e.g.,
used in laboratory exhaust systems). This is consistent with the scope of the terms sheet.
Table III-3 of this document compares the scope exclusions requested by the Petitioners in accordance with the commercial and industrial fan and blower requirements in ASHRAE 90.1-2019 and the scope of exclusions as recommended by the Working Group (other than embedded fans and blowers). DOE reviewed the fan and blower exclusions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 “Fan Efficiency Requirements” as listed in Table III-3 of this document and has tentatively
determined that these exclusions are covered by the exclusions recommended by the Working Group.
Table III-3—Exceptions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 “Fan Efficiency Requirements”
[Other than for embedded fans and blowers]
Exceptions to Section 6.5.3.1.3 of ASHRAE 90.1-2019
“Fan Efficiency Requirements”
Included in the exclusions recommended by the Working Group?
Fans that are not embedded fans with a motor nameplate horsepower of less than 1.0 hp or with a fan nameplate electrical input power of less than 0.89 “kW”
Yes.
Ceiling fans
Yes (Note: ceiling fans are not within the scope of the definition of fans and blowers).
Fans used for moving gases at temperatures above 482 °F
Yes (safety fans).
Fans used for operation in explosive atmospheres
Yes (safety fans).
Reversible fans used for tunnel ventilation
Yes (jet fans, safety fans).
Fans outside the scope of AMCA 208-18
Yes (AMCA 208-18 references the scope of AMCA 210-16).
Fans that are intended to operate only during emergency conditions
Yes (safety fans).
In response to the April 2020 Notice of Petition, Greenheck commented in support of a scope consistent with the term sheet and with ASHRAE 90.1-2019. (Docket No. EERE-2020-BT-PET-0003, Greenheck, No. 6.1 at p. 2) Johnson Controls commented in support of the exclusions requested by the Petitioners. (Docket No. EERE-2020-BT-PET-0003, Johnson Controls, No. 10 at pp. 1-2)
In its proposed rulemaking for commercial and industrial fans and blowers, the CEC proposes to exclude the following categories of fans: (1) safety fans (see section III.B.3 of this document for more details on this definition), (2) ceiling fans as defined in 10 CFR 430.2; (3) circulating fans; (4) induced-flow fans; (5) jet fans; (6) cross-flow fans; (7) embedded fans as defined in ANSI/AMCA 214-21;
23
(8) fans mounted in or on motor vehicles or other mobile equipment; (9) fans that create a vacuum of 30 in. water gauge or greater;
24
and (10) air curtain unit.
25
See Table III-4 of this document; section III.A.3 of this document for a discussion of embedded fans and air curtain units; and section III.A.5 of this document for a discussion of fans mounted in or on motor vehicles or other mobile equipment.
23
As defined in ANSI/AMCA 214-21: “A fan that is part of a manufactured assembly where the assembly includes functions other than air movement.”
24
CEC proposed excluding these fans because AMCA 214-21 is not applicable to this equipment. See CEC's Initial Statement of Reason, available at:
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
25
The CEC defines an air curtain unit as equipment providing a directionally controlled stream of air moving across the entire height and width of an opening that reduces the infiltration or transfer of air from one side of the opening to the other and/or inhibits the passage of insects, dust, or debris.
Table III-4 Fans Recommended for Exclusion by the Working Group and the Corresponding CEC Proposed Exclusions
Fans recommended for exclusion by the working group *
Corresponding term and definition proposed for exclusion in CEC proposed regulatory text
Radial housed unshrouded fan with diameter less than 30 inches or a blade width of less than 3 inches
Not excluded by the CEC proposed regulatory text.
Safety fan
“Safety Fan” See section III.B.3 of this document.
Induced flow fan
“Induced-flow fan” means a type of laboratory exhaust fan with nozzle and windband; the fan's outlet airflow is greater than the inlet airflow due to induced airflow. All airflow entering the inlet exits through the nozzle. Airflow exiting the windband includes the nozzle airflow as well as the induced airflow.
Jet fan
“Jet fan” means a fan designed and marketed specifically to produce a high-velocity air jet in a space to increase its air momentum. Jet fans are rated using thrust. Inlets and outlets are not ducted but may include acoustic silencers.
Cross-flow fan
“Cross-flow fan” means a fan with a housing that creates an airflow path through the impeller, in a direction at right angles to the axis of rotation and with airflow both entering and exiting the impeller at the periphery. Inlets and outlets can optionally be ducted.
*
Note:
The Working Group also recommended to exclude circulating fans, which are also excluded from the CEC proposed regulation and defined as a fan that is not a ceiling fan that is used to move air within a space, that has no provision for connection to ducting or separation of the fan inlet from its outlet. The fan is designed to be used for the general circulation of air. Circulating fans are discussed in Section III.A.4 of this document.
DOE reviewed the exclusions recommended by the Working Group, the exclusions requested by Petitioners, the exclusions provided in the proposed CEC regulations, and comments received. DOE is proposing to exclude from the proposed DOE test procedure the following fans and blowers: (1) radial housed unshrouded fans with a diameter less than 30 inches or a blade width of less than 3 inches; (2) safety fans; (3) induced flow fans; (4) jet fans; and (5) cross-flow fans.
Based on input from AMCA during the ASRAC negotiations, DOE has tentatively determined that radial housed unshrouded fans with a diameter less than 30 inches or a blade width of less than 3 inches are designed for materials handling applications.
These fans have specific design features (
e.g.,
built to resist the impact and erosive wear from large quantities of various materials passing through the fan housing) that generally limit the opportunity for improved efficiency. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 85 at p. 60). Furthermore, testing these fans based on the test method for clean air fans would not provide a measurement of energy use or energy efficiency that is representative of an average use cycle. For these reasons, DOE proposes to exclude radial housed unshrouded fans with a diameter less than 30 inches or a blade width of less than 3 inches at this time.
DOE proposes to exclude safety fans at this time, which operate intermittently and may have specific design features that generally limit the opportunity for improved efficiency.
DOE also proposes to exclude induced flow fans; jet fans; and cross-flow fans because a test using AMCA 210-16 would not provide a measurement of energy use or energy efficiency that is representative of an average use cycle, as described further in the following paragraphs.
Induced flow fans are used for laboratory exhaust applications, and their performance is tested based on AMCA Standard 260-20, “Laboratory Methods of Testing Induced Flow Fans for Rating.” AMCA 260-20 is an adjunct to AMCA 210-16 in order to accommodate the induced flow fans' unique characteristics, namely the impact of the windband on performance. The windband is a component of induced flow fans used to direct the fume exhaust and maximize plume height and the amount of air mixed with the lab exhaust to increase the dilution ratio. Induced flow fans produce a high plume of air at the outlet in order to exhaust laboratory fumes and hazardous chemicals in such a manner that diminishes the likelihood that exhausted air will be re-entrained into the building's intake air. Their performance does not only depend on the flow of air that they provide, but also on the “effective plume height,” which is the plume rise provided by the induced flow fan added to the stack height of the fan (
i.e.,
from the roof to the outlet of the windband). DOE has tentatively determined that a test using AMCA 210-16 would not provide a measurement of energy use or energy efficiency during a representative average use cycle for induced flow fans and proposes to exclude these fans from the scope of the test procedure at this time.
Jet fans are typically used in vehicular tunnels to provide ventilation and improve air quality. Jet fans can also be used in the event of a fire in the tunnel to remove the smoke and fumes from the source of the incident, if necessary, by reversing their airflow. Jet fan performance is characterized by thrust and horsepower and not based on the airflow and pressure they can provide. AMCA 250-22
26
provides methods of measuring thrust, volume airflow, and power and includes provisions for deriving efficiency in terms of “thrust power ratio”. Therefore, DOE has tentatively determined that a test using AMCA 210-16 would not provide a measurement of energy use or energy efficiency during a representative average use cycle of jet fans and proposes to exclude these fans from the scope of the test procedure.
26
ANSI/AMCA 250-22: Laboratory Methods of Testing Jet Tunnel Fans for Performance. Available at
www.amca.org.
Cross-flow fan performance is related to the ability to produce a wide, uniform airflow as opposed to the airpower output, which is what is accounted for in AMCA 210-16. Therefore, DOE has tentatively determined that cross-flow fans would necessitate consideration of a different metric to better capture the energy use of these under a representative cycle of use. Therefore, DOE proposes that cross-flow fans will not be addressed in its test procedure at this time.
DOE is considering including an exclusion, consistent with the findings of the CEC, for fans that create a vacuum of 30 inches water gauge or greater. DOE has tentatively determined that a test using AMCA 210-16 may not result in a measurement of energy use or energy efficiency during a representative average use cycle for fans that are exclusively used to create a vacuum rather than produce airflow. DOE requests additional information on fans exclusively used to create a vacuum and on the 30 inches water gauge criteria used by the CEC.
DOE requests comment on its proposed exclusions from the proposed scope of applicability of the test procedure, listed as follows: (1) radial housed unshrouded fans with a diameter less than 30 inches or a blade width of less than 3 inches; (2) safety fans; (3) induced flow fans; (4) jet fans; and (5) cross-flow fans. DOE seeks additional information to support exclusion from the scope of potential test procedures.
DOE seeks comment and input on the applicability of AMCA 214-21 and AMCA 210-16 to fans that create a vacuum of 30 inches water gauge or greater. DOE requests comment on the 30 inches water gauge limit used by the CEC.
3. Proposed Exclusion of Embedded Fans and Blowers
In addition to the specific exclusions discussed in the prior section, DOE has also considered excluding certain “embedded” fans from the scope of the test procedure. Fans can be distributed in commerce as standalone equipment or can be distributed in commerce incorporated into other equipment that requires a fan to operate.
Section 3.25.3 of AMCA 214-21 defines a “standalone fan” as “a fan in at least a minimum testable configuration. This includes any driver, transmission or motor controller if included in the rated fan. It also includes any appurtenances included in the rated fan, and it excludes the impact of any surrounding equipment whose purpose exceeds or is different than that of the fan.”
27
Section 3.25.4 of AMCA 214-21 defines the term “embedded fan” in section 3.25.4 as “a fan that is part of a manufactured assembly where the assembly includes functions other than air movement.”
27
Additionally, AMCA 214-21 defines a minimum testable configuration as “A fan having at least an impeller; shaft and bearings and/or driver to support the impeller; and its structure or its housing”.
See
Section 3.53 of AMCA 214-21.
The Working Group recommended excluding certain embedded fans. See Table III-5 of this document. (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendations #2 and #3 at pp. 2-4)
Table III-5—Embedded Fans Recommended for Exclusion by the Working Group
Fans embedded in:
Single-phase central air conditioners and heat pumps rated with a certified cooling capacity less than 65,000 British thermal units per hour (“Btu/h”), that are subject to DOE's energy conservation standard at 10 CFR 430.32(c).
Three-phase, air-cooled, small commercial packaged air-conditioning and heating equipment rated with a certified cooling capacity less than 65,000 Btu/h, that are subject to DOE's energy conservation standard at 10 CFR 431.97(b).
Residential furnaces that are subject to DOE's energy conservation standard at 10 CFR 430.32(y).
Transport refrigeration (
i.e.,
Trailer refrigeration, Self-powered truck refrigeration, Vehicle-powered truck refrigeration, Marine/Rail container refrigerant), and fans exclusively powered by internal combustion engines.
Vacuum cleaners.*
Heat Rejection Equipment:
• Packaged evaporative open circuit cooling towers.
• Evaporative field-erected open circuit cooling towers.
• Packaged evaporative closed-circuit cooling towers.
• Evaporative field-erected closed-circuit cooling towers.
• Packaged evaporative condensers.
• Field-erected evaporative condensers.
• Packaged air-cooled (dry) coolers.
• Field-erected air-cooled (dry) coolers.
• Air-cooled steam condensers.
• Hybrid (water saving) versions of all of the previously listed equipment that contain both evaporative and air-cooled heat exchange sections.
Air curtains:
Air-cooled commercial package air conditioners and heat pumps (CUAC, CUHP) with a certified cooling capacity between 5.5 tons (65,000 Btu/h) and 63.5 tons (760,000 Btu/h) that are subject to DOE's energy conservation standard at 10 CFR 431.97(b).**
Water-cooled and evaporatively-cooled commercial air conditioners and water-source commercial heat pumps that are subject to DOE's energy conservation standard at 10 CFR 431.97(b).**
Single package vertical air conditioners and heat pumps that are subject to DOE's energy conservation standard at 10 CFR 431.97(d).**
Packaged terminal air conditioners (PTAC) and packaged terminal heat pumps (PTHP) that are subject to DOE's energy conservation standard at 10 CFR 431.97(c).**
Computer room air conditioners that are subject to DOE's energy conservation standard at 10 CFR 431.97(e).**
Variable refrigerant flow multi-split air conditioners and heat pumps that are subject to DOE's energy conservation standard at 10 CFR 431.97(f).**
* Although the term sheet specifies “vacuum”, the term was intended to designate vacuum cleaners. (Docket No. EERE-2013-BT-STD-0006; AHRI, Public Meeting Transcript, No. 166 at p. 11).
** The recommendation only applies to supply and condenser fans embedded in this equipment.
Stated more generally, the exclusions recommended by the Working Group would exclude from the scope of the test procedure, fans that are embedded in regulated equipment for which the DOE metric captures the energy consumption of the fan.
28
28
The Working Group created a subgroup to propose potential embedded fan exclusions, which were subsequently voted on by the Working Group. The information used by the subgroup to develop the proposal is available in the fans energy conservation standard rulemaking docket. (Docket No. EERE-2013-BT-STD-0006, No. 125.2).
The Working Group further recommended for fans embedded in non-regulated equipment, and/or embedded in regulated equipment other than listed in appendix B, and/or any fans that are not supply and condense fans in regulated equipment listed in appendix B that the first manufacturer of a testable configuration
29
would be responsible for certifying the standalone fan performance to DOE. (Docket No. EERE-2013-BT-STD-0006, No. 179, Recommendation #4 at pp. 4)
30
29
AMCA 214-21 defines the “minimal testable configuration” as a fan having at least an impeller; shaft and bearings and/or driver to support the impeller; and its structure or its housing.
30
As part of this recommendation, the Working Group also recommended that if a manufacturer purchases a standalone fan to incorporate in a product or in equipment, that manufacturer must ensure that the design operating range (or design point) of the embedded fan is within the certified operating range of the standalone fan and disclose the design operating range (or design point) of the embedded fan to the end-user. This issue does not relate to the test procedure and is not discussed in this document.
The Petitioners requested that the scope of any DOE test procedure be consistent with the scope of the term sheet. Petitioners also requested the test-procedure scope for commercial fans be consistent with ASHRAE 90.1-2019, and additionally exclude embedded fans that are part of equipment listed in Section 6.4.1.1 of ASHRAE 90.1-2019. ASHRAE 90.1-2019 (
See
Table III-7 of this document). (Docket No. EERE-2020-BT-PET-0003, The Petitioners, No. 1, attachment “AMCA Petition to DOE Cover Letter and Petition [sic] 2020110” at pp. 7-8)
The additional exclusions for embedded fans that are part of equipment listed in Section 6.4.1.1 of ASHRAE 90.1-2019 as requested by AMCA is included in the fan and blower exclusions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 “Fan Efficiency Requirements” as listed in section in Section 6.5.3.1.3 of ASHRAE 90.1-2019 and presented in Table III-6 of this document.
Table III-6—Embedded Fan and Blowers Exclusions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 “Fan Efficiency Requirements”
Embedded fan and blowers exclusions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 “Fan Efficiency Requirements”
Included in the
exclusion
recommended by
the Working Group?
Embedded fans and fan arrays with a combined motor nameplate horsepower of 5 hp or less or with a fan system electrical input power of 4.1 kW or less
No.
Embedded fans that are part of equipment listed under Section 6.4.1.1
See Table III-7.
Embedded fans included in equipment bearing a third party-certified seal for air or energy performance of the equipment package
No.
Table III-7—Equipment Listed in Section 6.4.1.1 of ASHRAE 90.1-2019 “Minimum Equipment Efficiencies—Listed Equipment—Standard Rating and Operating Conditions”
Fans embedded in:
Included in the embedded fan exclusions recommended by the
Working Group?
Electrically Operated Unitary Air Conditioners
Partially. This category includes equipment above 760,000 Btu/h. The exclusions in the term sheet apply only to fans embedded in equipment above 65,000 Btu/h and below 760,000 Btu/h (equivalent to 5.5 tons and 63.5 tons, respectively as stated in the term sheet). In addition, the term sheet specifies that the exclusions would apply only to embedded “supply and condenser fans.”
Electrically Operated Air-Cooled Unitary Heat Pumps
Partially. This category includes equipment above 760,000 Btu/h. The exclusions in the term sheet apply only to fans embedded in equipment below 760,000 Btu/h. In addition, the term sheet specifies that the exclusion would apply only to embedded “supply and condenser fans.”
Air-, water-, and evaporatively cooled Condensing Units
Yes, these fans are below 1 hp. In addition, it is specified in Table 6.8.1-1 of ASHRAE 90.1-2019 that this category only includes equipment greater than or equal to 135,000 Btu/h.
Water-Chilling Packages
No.
Electrically Operated Packaged Terminal Air Conditioners, Packaged Terminal Heat Pumps, Single-Package Vertical Air Conditioners, and Single-Package Vertical Heat Pumps
Yes. However, the term sheet specifies that the exclusion would apply only to embedded “supply and condenser fans.”
Room Air-conditioners and Air-conditioner Heat pumps
Yes. These fans are below 1 hp.
Warm-Air Furnaces and Combination Warm-Air Furnaces/Air-Conditioning Units, Warm-Air Duct Furnaces, and Unit Heaters
No.
Gas- and Oil-Fired Boilers
Partially. Some of these fans are below 1 hp.
Heat-Rejection Equipment
Yes.
Electrically Operated Variable-Refrigerant-Flow Air Conditioners
Yes. However, the term sheet specifies that the exclusion would apply only to embedded “supply and condenser fans.”
Electrically Operated Variable-Refrigerant-Flow and Applied Heat Pumps
Partially. This category includes ground water source and ground source equipment that is not regulated by DOE and that was not included in the term sheet exclusions. In addition, the term sheet specifies that the exclusion would apply only to embedded “supply and condenser fans.”
Floor-Mounted Air Conditioners and Condensing Units Serving Computer Rooms
Partially. This category includes equipment greater than or equal to 760,000 Btu/h, which are not regulated by DOE.
Commercial Refrigerators, Commercial Freezers, and Refrigeration
Yes, these fans are below 1 hp.
Vapor-Compression-Based Indoor Pool Dehumidifiers
Yes, these fans are below 1 hp.
Electrically Operated direct-expansion dedicated outdoor air system Units, Single-Package and Remote Condenser, without Energy Recovery
No.
Electrically Operated direct-expansion dedicated outdoor air system Units, Single-Package and Remote Condenser, with Energy Recovery
No.
Electrically Operated Water-Source Heat Pumps
Partially. This category includes ground water source and ground source equipment that is not regulated by DOE and was not included in the term sheet exclusions. In addition, the term sheet specifies that the exclusion would apply only to embedded “supply and condenser fans.”
Heat Pump and Heat Recovery Chiller Packages
No.
Ceiling-Mounted Computer-Room Air Conditioners
Partially. The term sheet only excludes embedded fans in computer room air conditioners that are subject to DOE energy conservation standards.
Walk-In Cooler and Freezer Display Door
Yes, these fans are below 1 hp.
Walk-In Cooler and Freezer Non-Display Door
Yes, these fans are below 1 hp.
Walk-In Cooler and Freezer Refrigeration System
Yes, these fans are below 1 hp.
As previously noted, in response to the April 2020 Notice of Petition, Greenheck commented in support of a scope consistent with the term sheet and with ASHRAE 90.1-2019 (Docket No. EERE-2020-BT-PET-0003, Greenheck, No. 6.1 at p. 2) Johnson Controls commented in support of the exclusions requested by the Petitioners (Docket No. EERE-2020-BT-PET-0003, Johnson Controls, No. 10 at pp. 1).
CTI commented in support of the exclusion of fans used in heat rejection equipment as requested by the Petitioners. CTI commented that this exclusion was included in the term sheet scope recommendation based on the widespread usage of equipment-level energy efficiency metrics; the low potential for energy savings; the potential unintended increases in fan and system energy use ; and the associated design challenges due to the very large size of fans used in heat rejection equipment. (Docket No. EERE-2020-BT-PET-0003, CTI, No. 11 at pp. 1-2)
AHRI commented in support of the Petitioners' request to exclude from the scope of the test procedure condenser fans embedded in commercial and industrial chillers, condensing units, and unregulated packaged air conditioners and heat pumps with cooling capacity greater than 760,000 Btu/h, consistent with Section 6.4.1.1 of ASHRAE 90.1-2019. AHRI also supported the exclusions listed in the
term sheet for heat rejection equipment, including but not limited to air cooled condensers, dry coolers, cooling towers, evaporative condensers, and hybrid wet/dry units. (Docket No. EERE-2020-BT-PET-0003, AHRI, No. 14 at p. 2) Further, AHRI commented in support of additional exclusions to exclude all fans in all regulated equipment and asserted that EPCA does not permit two standards to be applied to regulated equipment. AHRI stated that the list of equipment in Section 6.4.1.1 of ASHRAE 90.1-2019 strictly applies to air distribution equipment and does not include all regulated equipment incorporating fans, such as boilers. (Docket No. EERE-2020-BT-PET-0003, AHRI, No. 14 at p. 2) In addition, AHRI questioned the representativeness of applying a standalone fan metric for embedded fans in regulated equipment.
31
AHRI asserted that the standalone fan metric, after accounting for system effect, would not provide an appropriate basis for comparison of performance. (Docket No. EERE-2020-BT-PET-0003, AHRI, No. 14 at p. 2) Daikin commented in support of all of AHRI's comments on the petition. (Daikin, No. 8 at p. 1).
31
The AMCA 214-21 metric describes fan performance as tested in a standalone configuration (
i.e.
not installed inside other equipment).
Lennox commented that fans embedded in DOE regulated HVACR equipment should be excluded from the scope to avoid duplicative burdens for HVACR equipment already subject to DOE regulation. (Docket No. EERE-2020-BT-PET-0003, Lennox, No. 5 at p. 3)
Several interested parties commented in support of an equipment level approach (
i.e.,
system approach) that would regulate the HVACR equipment rather than what they described as a component level approach. CTI commented that energy conservation standards based on already established equipment-level metrics are more effective at reducing energy consumption compared to energy savings obtained by using a fan efficiency metric, and at a lower regulatory burden. (Docket No. EERE-2020-BT-PET-0003, CTI, No. 11 at p. 2) Daikin commented that DOE had recently stated that it may seek to establish regulatory coverage over equipment, rather than the components in such equipment. (Docket No. EERE-2020-BT-PET-0003, Daikin, No. 8 at p. 1) In addition, Daikin commented that the purpose of the FEI established by AMCA 214 is to help drive fan sizing and better fan selection. Daikin commented that while there were benefits to improving fan sizing and incentivizing better fan selection for standalone fans, not all possible FEI improvement approaches are practical for embedded fans (
e.g.,
increasing fan size or increasing the number of fans). Daikin stated that certain equipment incorporating embedded fans must comply with multiple safety standards and performance standards. Daikin commented that embedded fans are carefully selected to adhere to such safety and performance standards, and that component sizes or the number of components cannot be altered to meet the needs of a component level test procedure. (Docket No. EERE-2020-BT-PET-0003, Daikin, No. 8 at p. 1)
Daikin generally supported the exclusions requested by the Petitioners, stating that such exclusions should be reflected in the scope of AMCA 214. (Docket No. EERE-2020-BT-PET-0003, Daikin, No. 8 at p. 1). CTI also commented that the exclusions requested by the Petitioners should be reflected in the scope of AMCA 214 and expressed concern that the draft AMCA 214 test standard
32
could allow for the inclusion of embedded fans at some point in the future. CTI further stated that AMCA 214 is not suitable for inclusion in a regulatory program due to testing and accuracy issues. CTI did not provide a description of these issues. (Docket No. EERE-2020-BT-PET-0003, CTI, No. 11 at p. 3)
32
AMCA 214-21 had not yet published at the time of these comments.
In response to the October 2021 RFI, AHRI commented that there have been many changes since the conclusion of the Working Group. For example, the introduction of FEI in ASHRAE 90.1, the development of a new test procedure for FEI, and the publication of AMCA 214. AHRI commented that itis chiefly concerned with ensuring that the scope of coverage does not impose double regulation on covered equipment. AHRI commented that AMCA 214-21 does not specifically exclude embedded fans other than in the foreword (which states that “AMCA Standard 214 primarily is for fans that are tested alone or with motors and drives; it does not apply to fans tested embedded inside of other equipment”); however, AHRI stated that there is no normative procedure for applying a stand-alone fan metric to embedded applications. (AHRI, No. 10 at p. 2)
In response to the October 2021 RFI, AHRI and Morrison commented that any fan and blower regulations should exclude all fans and blowers used in regulated equipment because EPCA does not permit two standards to be applied to a single federally regulated product. AHRI and Morrison cited DOE's discussion in a final rule published July 22, 2009
33
in which DOE stated, “EPCA authorizes DOE to establish a performance standard or a single design standard. As such, a standard that establishes both a performance standard and a design requirement remain beyond the scope of DOE's legal authority.” AHRI and Morrison, citing 42 U.S.C. 6313(a)(6)(C), asserted that introducing component regulation on regulated products creates a secondary redesign cycle contrary to EPCA. AHRI and Morrison also asserted that EPCA is clear that DOE is prohibited from setting a new efficiency standard on products within certain defined time limits. Specifically, AHRI and Morrison commented that DOE cannot set new efficiency standards for products manufactured after a date that is the later of (1) the date that is three years after publication of the final rule establishing a new standard; or (2) the date that is six years after the effective date of the current standard for a covered product, citing 42 U.S.C. 6313(a)(6)(C)(iv). AHRI and Morrison commented that introducing a fan regulation on top of a regulation for covered equipment would complicate the regulatory, design and compliance cycles. AHRI and Morrison added that clearly excluding fans in regulated products will help DOE comply with the legally mandated schedule and parameters laid out under EPCA. AHRI and Morrison additionally commented that DOE should maintain consistency in its rulemaking process and seek to establish regulatory coverage over equipment rather than the components in such equipment. (AHRI, No. 10 at pp. 3-4; Morrison, No. 8 at p. 2)
33
Energy Conservation Program for Certain Industrial Equipment: Energy Conservation Standards and Test Procedures for Commercial Heating, Air-Conditioning, and Water-Heating Equipment. 74 FR 36312, 36322 (July 22, 2009).
Morrison added that DOE should only regulate standalone fans and not those embedded in equipment since none of the referenced test methods are for embedded fans. Further, Morrison commented that the vast majority of fans manufactured by |Morrison are incorporated in HVAC equipment that already have energy efficiency measures that account for the fan energy, and thus should continue to be out of scope for this regulation. (Morrison, No. 8 at p. 1)
In its proposed regulation, the CEC proposes to exclude embedded fans, as defined in AMCA 214-21, including embedded fans in air curtain units.
34
In
its staff report, the CEC stated that its proposal would exclude fans embedded in regulated and nonregulated equipment where the main function is other than the movement of air, as long as the fan is not sold or offered for sale as a standalone product.
35
As reasons for exclusion, the CEC stated that these fans are either manufactured by an original equipment manufacturer (OEM), who embeds the fan in a piece of equipment where the main function is something other than the movement of air, or because they are manufactured for the purpose of being embedded into an appliance after market.
36
The CEC also discussed the potential complexity of testing embedded fans and the accuracy of the results. See section III.D.8 of this document for further discussion related to testing.
37
34
See
Proposed regulatory language for Commercial and Industrial Fans and Blowers
available in the following Docket: 22-AAER-01 at:
efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=22-AAER-01.
35
See
CEC Commercial and Industrial Fans and Blowers Staff Report, Docket No. 22-AAER-01, TN# 241951, at p. 16.
36
Id.
37
See CEC Commercial and Industrial Fans and Blowers Staff Report, Docket No. 22-AAER-01, TN# 241951, at p. 30
DOE proposes to exclude fans embedded in equipment listed in Table III-5, as long as the fan is not distributed in commerce as a standalone product, consistent with the Working Group term sheet scope recommendations related to embedded fans. The equipment listed in Table III-5 includes equipment that is separately regulated by DOE (“covered equipment”) as well as non-covered equipment (
i.e.,
transportation refrigeration equipment, vacuum cleaners, heat rejection equipment, and air curtains).
Fans used in transportation equipment are often designed to accommodate the limited space available and are built following specific construction requirements to withstand shock and vibrations. These design constraints significantly limit potential opportunities for improvements in efficiency. Consistent with the Working Group term sheet (Docket No. EERE-2013-BT-STD-0006-0179, Recommendation #2 at p. 2), DOE proposes to exclude fans that are exclusively embedded in transport refrigeration (
i.e.,
trailer refrigeration, self-powered truck refrigeration, vehicle-powered truck refrigeration, and marine/rail container refrigeration) at this time.
DOE proposes to exclude fans that are exclusively embedded in vacuum cleaners. AHRI initially made this recommendation on the basis that these fans represent low energy savings potential due to their low operating hours. (Docket No. EERE-2013-BT-STD-0006; AHRI, Public Meeting Transcript, No. 166 at p. 11) Fans embedded in vacuums cleaners are not used to produce airflow. Rather, they are used to create a vacuum for material handling purposes (
i.e.,
moving dust, small particles etc.). DOE has tentatively determined that a clean air test using AMCA 210-16 would not result in a measurement of energy use or energy efficiency during a representative average use cycle. For this reason, and consistent with the Working Group term sheet scope recommendations, DOE proposes to exclude fans embedded in vacuum cleaners from the scope of the test procedure.
Fans used in heat rejection equipment are primarily fabricated in-house by the heat rejection equipment manufacturer and that these fans are not sold in a standalone configuration.
38
For this reason, and consistent with the Working Group term sheet scope recommendations, DOE proposes to exclude fans embedded in heat rejection equipment from the scope of the test procedure.
38
In some cases, the heat rejection equipment manufacturer may purchase the impeller and assemble the fan in a housing which is tied to the structure of the heat rejection equipment.
Air curtains are used in entrances to buildings or openings between two spaces conditioned at different temperatures. Their performance does not depend on the airpower alone, but on their ability to create a uniform airstream that separates two spaces from each other. Air curtains are subject to a separate AMCA testing standard.
39
This standard establishes uniform methods for the testing of an air curtain to determine aerodynamic performance in terms of airflow rate, outlet air velocity uniformity, power consumption, and air velocity projection. Air curtains include fans packaged with a motor, filter, outlet section (a nozzle, discharge grille, etc.), and in some cases a mounting plate, and/or an electric heater or water heater. The performance of fans embedded in air curtains is related to airflow rate, outlet air velocity uniformity, and air velocity projection as opposed to the airpower output alone, which is what is accounted for in AMCA 210-16. Therefore, DOE has tentatively determined that fans embedded in air curtain fans would necessitate consideration of a different metric to better capture the energy use of air curtain fans under a representative cycle of use. Therefore, DOE proposes that fans embedded in air curtains not be addressed in the proposed test procedure.
39
AMCA, Standard 220-21, “Laboratory Methods of Testing Air Curtains for Aerodynamic Performance Ratings,” 2021. Available at
www.amca.org.
In addition, at this time, DOE proposes that the test procedure would exclude fans in covered equipment in which the fan energy use is already captured in the equipment specific test procedures. DOE is proposing to adopt an exclusion for fans embedded in equipment listed in Table III-5,
40
as long as the fan is not distributed in commerce as a standalone product. DOE proposes to also exclude fans embedded in direct-expansion dedicated outdoor systems (“DX-DOAS”) to reflect the DOE proposed test procedure and metric for DX-DOAS that, if adopted, would incorporate fan energy use.
See
86 FR 72874, 72889-72890 (December 23, 2021). These proposed exclusions are consistent with the recommendations of the Working Group. The proposed approach would avoid regulating fans for which existing DOE regulations account for their energy use by excluding such fans from the test procedure if distributed solely embedded in the listed equipment. To the extent a fan is distributed in commerce as a stand-alone fan, and therefore is not limited to use in specific equipment, or embedded in equipment in which its energy use is not addressed in a DOE test procedure, such a fan would be subject to the DOE test procedure.
40
DOE notes that while the Working Group recommended to exclude fans in residential furnaces that are subject to DOE's energy conservation standard at 10 CFR 430.32(y), furnace fans are excluded from the definition of “fan and blower” and therefore do not need to be listed as a proposed exclusion.
Table III-8 summarizes the exclusively embedded fans proposed for exclusions from the scope of the test procedure.
Table III-8—Exclusively Embedded Fans Proposed for Exclusion From the Scope of the Test Procedure
Fans exclusively embedded in:
Direct-expansion dedicated outdoor systems (“DX-DOASes”) subject to any DOE test procedures in appendix B to subpart F of part 431.*
Single-phase central air conditioners and heat pumps rated with a certified cooling capacity less than 65,000 British thermal units per hour (“Btu/h”), that are subject to DOE's energy conservation standard at 10 CFR 430.32(c).
Three-phase, air-cooled, small commercial packaged air-conditioning and heating equipment rated with a certified cooling capacity less than 65,000 Btu/h, that are subject to DOE's energy conservation standard at 10 CFR 431.97(b).
Transport refrigeration (
i.e.,
Trailer refrigeration, Self-powered truck refrigeration, Vehicle-powered truck refrigeration, Marine/Rail container refrigerant), and fans exclusively powered by fan combustion engines.
Vacuum cleaners.
Heat Rejection Equipment:
• Packaged evaporative open circuit cooling towers.
• Evaporative field-erected open circuit cooling towers.
• Packaged evaporative closed-circuit cooling towers.
• Evaporative field-erected closed-circuit cooling towers.
• Packaged evaporative condensers.
• Field-erected evaporative condensers.
• Packaged air-cooled (dry) coolers.
• Field-erected air-cooled (dry) coolers.
• Air-cooled steam condensers.
• Hybrid (water saving) versions of all of the previously listed equipment that contain both evaporative and air-cooled heat exchange sections.
Air curtains.
** Air-cooled commercial package air conditioners and heat pumps (CUAC, CUHP) with a certified cooling capacity between 5.5 tons (65,000 Btu/h) and 63.5 tons (760,000 Btu/h) that are subject to DOE's energy conservation standard at 10 CFR 431.97(b).
** Water-cooled and evaporatively-cooled commercial air conditioners and water-source commercial heat pumps that are subject to DOE's energy conservation standard at 10 CFR 431.97(b).
** Single package vertical air conditioners and heat pumps that are subject to DOE's energy conservation standard at 10 CFR 431.97(d).
** Packaged terminal air conditioners (PTAC) and packaged terminal heat pumps (PTHP) that are subject to DOE's energy conservation standard at 10 CFR 431.97(c).
** Computer room air conditioners that are subject to DOE's energy conservation standard at 10 CFR 431.97(e).
** Variable refrigerant flow multi-split air conditioners and heat pumps that are subject to DOE's energy conservation standard at 10 CFR 431.97(f).
** DX-DOASes are not currently subject to a DOE test procedure. However, there is an ongoing rulemaking to establish a test procedure for DX-DOASes that DOE anticipates will be finalized before the final rule of the fans and blowers rulemaking. Information about this rulemaking can be found at
regulations.gov
under the Docket Number EERE-2017-BT-TP-0018.
* The exclusion only applies to supply and condenser fans embedded in this equipment.
As discussed, DOE is proposing to exclude embedded fans that are not distributed in commerce as standalone fans. DOE acknowledges that in a number of instances, a standalone fan purchased by a manufacturer for incorporation into a unit of listed equipment may be indistinguishable based on physical features from a fan that is purchased by a manufacturer for incorporation into non-listed equipment or from a fan used as a standalone fan. During the ASRAC negotiations, AHRI conducted a survey of its members to determine the number of fans purchased versus manufactured by the equipment manufacturer. (Docket No. EERE-2013-BT-STD-0006, AHRI, No. 125.3, at p. 1) AHRI estimated that over 80 percent of all fans that are used as components across all commercial regulated equipment are manufactured by the equipment manufacturer.
Id.
This percentage was higher for commercial air-conditioning and heat pump equipment and was estimated to be between 94 and 99 percent.
Id.
In order to provide additional specificity as to the fans that would be subject to the embedded fan exclusion, DOE proposes to use the term “exclusively embedded fans” to designate the fans covered by the embedded fan exclusion. DOE proposes to define “exclusively embedded fan” as: a fan or blower that is manufactured and incorporated into a product or equipment manufactured by the same manufacturer and that is exclusively distributed in commerce embedded in another product or equipment. Based on this information, DOE has tentatively determined that the vast majority of fans used as components in regulated commercial HVACR equipment would meet the proposed definition of exclusively embedded fan and would not be subject to the test procedure as proposed in this NOPR.
The following examples illustrate how the proposed definition of exclusively embedded fan would impact whether a fan must be tested and certified to DOE:
• If a manufacturer makes a fan and incorporates it into equipment that the manufacturer also makes, that fan would meet the definition of exclusively embedded fan. If the embedded fan is part of equipment listed in Table III-8 of this document, that fan would be excluded from the proposed scope of the test procedure so long as the manufacturer does not also sell that fan as a standalone fan. If the embedded fan is not part of equipment listed in Table III-8 of this document, the embedded fan would be included in the proposed scope of the test procedure and the fan would be subject to the test procedure.
• If Manufacturer A makes (or imports) a fan and then only sells it to Manufacturer B who then only distributes that fan in commerce embedded within a larger piece of equipment, that fan would not meet the definition of exclusively embedded fan (even if the equipment is listed in Table III-8 of this document), as it would be distributed in commerce as a standalone fan by Manufacturer A, and therefore the fan would be subject to the test procedure under the proposal.
• If a fan is exclusively imported as part of a larger piece of equipment, that fan would meet the definition of exclusively embedded fan. If the embedded fan is part of equipment listed in Table III-8 of this document, that fan would be excluded from the proposed scope of applicability of the test procedure. If the embedded fan is not part of equipment listed in Table III-8 of this document, the embedded fan would be included in the proposed
scope of applicability of the test procedure.
DOE requests comment on the proposed exclusively embedded fan exclusions listed in Table III-8 of this document.
DOE seeks information on whether it is common practice for standalone fan manufacturers that supply fans to HVACR equipment manufacturers to test these fans in accordance with AMCA 214-21 or AMCA 210-16 in a standalone configuration, and to provide fan performance data for these fans.
DOE seeks information on whether it is common practice for manufacturers of HVACR equipment that manufacture and incorporate fans into their equipment to test these fans in accordance with AMCA 214-21 or AMCA 210-16 in a standalone configuration, and to provide fan performance data to their customers.
DOE seeks comment on the estimates provided for the percentage of fans that are incorporated in HVACR equipment that are purchased by the HVACR equipment manufacturer vs. manufactured in-house.
DOE seeks comment and input regarding any physical features that could be used to distinguish a fan that is exclusively designed for use in equipment listed in Table III-8 of this document.
DOE seeks comment on the proposed definition of “exclusively embedded fan”.
4. Air Circulating Fans
In the October 2021 RFI, DOE requested information regarding potential test procedures for fans and blowers, including air circulating fans, specifically air circulating fan heads (“ACFHs”), and requested feedback on definitions provided in AMCA 230-15 and on the scope of any potential test procedure for air circulating fans. 86 FR 54412, 54414-54415. DOE described ACFHs as designed to provide concentrated directional airflow and consisting of a motor, impeller and guard for mounting on a pedestal, wall mount bracket, ceiling mount bracket, I-beam bracket or other mounting means. 86 FR 54412, 54414. DOE stated that ACFHs are different from ceiling fans, which are designed to circulate air rather than provide concentrated directional airflow; and as a result, ACFHs have lower diameter-to-maximum operating speed ratio (expressed in inches per revolutions per minute (“in/RPM”)) than ceiling fans.
Id.
Comments received related to definitions are discussed in section III.B.4 of this document. As discussed in section III.B.4, DOE proposes to define air circulating fans and related terms.
AMCA commented in support of developing test procedures for ACFHs. AMCA recommended that for clarity, repeatability, and market confidence, DOE should harmonize with IEC 60879:2019 “Comfort fans and regulators for household and similar purposes—Methods for measuring performance,” and set a simple electrical-input-power threshold by excluding ACFHs less than 125 Watts (“W”) from a commercial and industrial ACFH test procedure. AMCA stated this would cover the vast majority of fans used in commercial and industrial applications and would exclude fans mostly used for residential applications. (AMCA, No. 6 at p. 6) In addition, AMCA commented in support of developing a test procedure for additional categories of air circulating fans defined in AMCA 230-15 (
i.e.,
personnel coolers, box fans, and table fans),
41
using AMCA 230-15 as the basis for a test procedure and including fans of greater than or equal to 125 W electrical input power. AMCA also stated that, should DOE develop energy conservation standards for air circulating fans, all categories of circulating fans should be subject to the same efficiency standard and lower wattage scope limit. (AMCA, No. 6 at p. 6) AMCA commented that impeller diameter is not an appropriate criteria to use to delimit the scope of a potential test procedure for ACF, specifically for ACFHs. AMCA commented that typical impeller diameters for ACFHs offered for sale in the United States range from 12 inches to 36 inches; however, there is no practical reason that an ACFH with a diameter outside that range could not be manufactured and/or sold. AMCA stated that limiting the DOE test procedure to specific diameters could encourage the introduction of fans outside of the covered diameters into the marketplace. AMCA added that typical motor sizes range from
1/10
hp to
2/3
hp, with
1/10
,
1/8
,
1/4
,
1/3
,
1/2
, and
2/3
hp being the most common; but because there is no mandated test procedure and reporting requirements, fan electrical-input-power data is not readily available for the majority of ACFHs and cannot be estimated using the motor horsepower. AMCA commented that ACFH motors typically are loaded above their nameplate horsepower, such that simply multiplying the published hp by the conversion factor of 746 Watts per hp and dividing by a nominal motor efficiency does not provide a useful input-power estimate. (AMCA, No. 6 at p. 7) AMCA stated that IEC 60879:2019 covers additional product classes, such as “tower fans” and “bladeless fans” and that these categories of fans should be excluded from the test procedure. (AMCA, No. 6 at p. 6)
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AMCA 230-15 defines “personnel cooler” as a fan used in shops, factories, etc., generally supplied with wheels or casters on the housing or frame to aid in portability, and with motor and impeller enclosed in a common guard and shroud; “box fan” as a fan used in an office or residential application and having the motor and impeller enclosed in an approximately square box frame having a handle; and “table fan” as a fan intended for use on a desk, table or countertop, and which may also be provided with the means for mounting to a wall.
See
Sections 5.1.2 through 5.1.5 of AMCA 230-15.
ASAP, ACEEE, NRDC commented that additional categories of air circulating fans other than ACFHs, such as personnel coolers, box fans, and table fans, meet the definition of “fan and blower” and thus should be included in the test procedure. ASAP, ACEEE, NRDC added that these additional air circulating fan categories are covered in the existing AMCA 230-15 test procedure for air circulating fans, such that it is feasible to include them within the scope of the DOE test procedure. ASAP, ACEEE, NRDC commented that generally, air circulating fans are fans used to circulate air within a confined space for use in agriculture, manufacturing, etc. and estimated the total global market for all fans and blowers to be approximately $20 billion, while agricultural ventilation, a major market for air circulating fans, is expected to reach $1.3 billion by 2027. ASAP, ACEEE, NRDC commented that establishing standardized DOE test procedures and efficiency ratings for air circulating fans will ensure that purchasers have access to comparable information about efficiency, enabling informed purchasing decisions. (ASAP, ACEEE, NRDC, No. 7 at p. 1) ASAP, ACEEE, NRDC supported limiting the definition of air circulating fans to input powers of 125 W and above, stating that this would be consistent with IEC 60879:20195 and fan standards in the European Union. ASAP, ACEEE, NRDC added that a minimum input power cut-off of 125 W is sufficient to reasonably distinguish air circulating fans that are to any significant extent distributed in commerce for industrial or commercial use. (ASAP, ACEEE, NRDC, No. 7 at p. 2)
The CA IOUs recommended that DOE regulate all commercial air circulating fans not currently covered, which could be defined as having a minimum power draw threshold such as 125 W. Additionally, the CA IOUs stated that personnel and agricultural fans that have solid housings or that may not meet the diameter-to maximum
operating speed ratio
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should be regulated, but are not considered ACFHs. The CA IOUs further commented that there is support by the industry to regulate all commercial air circulating fans, and they recommended that DOE undertake an additional rulemaking(s) to cover them. (CA IOUs, No. 9 at p. 3)
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As discussed in section I.A.4 of this document, ACFH have a maximum diameter-to maximum operating speed ratio of 0.06 inches per rotations per minute (“in/RPM”).
NEEA recommended that DOE consider evaluating efficiency standards and test procedures for additional categories of air circulating fans, such as industrial personnel coolers, box fans, and table fans that meet the definition of circulating fan. NEAA stated that the RFI focused primarily on ACFHs, and that other, non-ceiling categories of air circulating fans such as industrial personnel coolers, box fans, and table fans fall within the definition of a “fan” as defined in the final determination published on August 19, 2021. NEEA asserted that DOE has the authority to develop an efficiency standard for these types of equipment. NEEA supports the development of efficiency standards and test procedures for these industrial equipment categories and recommended that DOE consider regulating other fans listed in AMCA 230-15 under the same standard and utilize the same test procedure. NEEA additionally commented that with this scope expansion, DOE has the potential to influence the market towards more efficient technologies where possible and could realize significant energy savings for these equipment categories. (NEEA, No. 11 at p. 2)
MEP recommended that the definition for an ACFH should include a requirement for polyphase electric current with a fan shaft power greater than 3 hp, to avoid including “residential fans” in regulations and to align ACFHs with the upper limit of the small electric motors hp range as presented in § 431.446(a). (MEP, No. 5 at p. 1)
In response to an energy conservation standards RFI published on February 8, 2022 (“February 2022 ECS RFI”; 87 FR 7048), ASAP, ACEEE, NRDC, and NEEA stated that, should very small-diameter (“VSD”) ceiling fans not be included in the scope of the ongoing ceiling fan rulemaking, DOE should cover them as ACFHs under the fans and blowers rulemaking. These commenters supported this by stating that, since the diameter-to-maximum operating speed ratios of VSDs are often less than 0.06, they would not qualify as ceiling fans according to the ceiling fan definition in the proposed ceiling fan scope, but would qualify as ACFHs. They also commented that VSDs and ACFHs have similar physical characteristics. (Docket No. EERE-2022-BT-STD-0002, ASAP, ACEEE, NRDC, and NEEA, No. 6 at pp. 2-3)
In response to the February 2022 ECS RFI, ebm papst stated that fan airflow rate can be reliably determined for air circulating fans using the AMCA 230 testing method, particularly for air circulating fans with an input power greater than 125 W. (Docket No. EERE-2022-BT-STD-0002, ebm-papst, No. 8 at p. 2)
AMCA 230-15 (with errata) does not include any limitation in terms of input power of the air circulating fans that can be tested in accordance with the test procedure. The AMCA committee is considering limiting the scope of AMCA 230-15 (with errata) to air circulating fans with input power of 125 W and above to focus on commercial and industrial fan applications and exclude residential fans such as tower fans and bladeless fans.
DOE has tentatively determined that the proposed test procedure would provide a representative measurement of energy use or energy efficiency during a representative average use cycle for all air circulating fans as defined as proposed in section III.B.4 of this document. Therefore, at this time, DOE proposes to include all categories of air circulating fans in the scope of the proposed test procedure;
i.e.,
including equipment with input power less than 125 W. Should DOE identify additional information to justify excluding fans with input power less than 125 W from the scope (or any other power limit that may be justified), DOE may consider applying a power limit in the final rule as considered by the AMCA committee and supported by stakeholders. In addition, DOE may consider specifying that the 125 W corresponds to the air circulating fan's input power at maximum speed.
MEP recommended that the scope of a DOE test procedure should only include products exclusively used to move air. MEP commented that products that perform additional combustion, humidification, dehumidification, heating, or cooling functions should be excluded from this test procedure. MEP added that the rationale for this recommendation is found in the foreword of AMCA 214-21, which states, “AMCA Standard 214 primarily is for fans that are tested alone or with motors and drives; it does not apply to fans tested embedded inside of other equipment”. MEP also stated that fans used in supplementary electric heater products and portable electric heaters should also be excluded from the fan regulations, asserting that any inefficiencies of supplementary electric heater products and portable electric heaters would serve to provide heat to a space in addition to that which is supplied by a primary electric heater.
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(MEP, No. 5 at p. 2)
43
MEP referenced Direct Heating equipment rulemakings: 85 FR 77017 and 86 FR 20053.
DOE's proposed test procedure for air circulating fans, if finalized, would apply to the equipment that meets the definition of fan and blower. The air circulating fan would be tested in a standalone configuration (
i.e.,
not incorporated inside other equipment) in accordance with the proposed DOE test procedure, which would be based on AMCA 214-21.
DOE requests comments on the proposed scope of applicability of the test procedure for air circulating fans.
5. Non-Electric Drivers
Some fans operate with non-electric drivers, such as engines or generators, and such fans may be used in non-stationary applications or stationary applications. The Working Group recommended that DOE exclude fans that are exclusively powered by internal combustion engines from the test procedure and related energy conservation standards. (Docket No. EERE-2013-BT-STD-0006; No. 179, Recommendation #2, at p. 2)
AMCA 214-21 does not provide for the testing of fans and blowers powered by internal combustion engines. In order to measure the energy efficiency or energy use the energy performance of non-electric drivers during a representative average use cycle, separate test methods would be necessary for each type of driver (
e.g.,
engine, generators). DOE is not currently aware of a relevant industry test procedure and does not have information regarding the test set-up required to test fans powered by internal combustion engines. As such, DOE is not proposing test procedures for fans and blowers powered exclusively by an internal combustion engine at this time, regardless of whether such fan or blower is used in a stationary or non-stationary application.
Certain bare-shaft fans can be powered by either electric drivers (
i.e.,
motors) or non-electric drivers. DOE has tentatively determined that to the extent that such a fan is powered by an electric driver, the proposed test procedure would provide for measurement of the energy efficiency or energy use the
energy performance of non-electric drivers during a representative average use cycle when powered by an electric driver. As such, DOE is proposing that such a fan would be subject to the proposed test procedure.
DOE requests comment on excluding fans and blowers that are exclusively powered by internal combustion engines from the scope of this test procedure and associated energy conservation standards.
DOE requests feedback and information on the physical features that would help distinguish fans and blowers that are exclusively powered by internal combustion engines from other fans and blowers.
6. Replacement Parts
The Working Group did not address the issue of replacement parts in the term sheet. (Docket EERE-2013-BT-TP-0055; No. 179, Appendix F at p. 19).
Clarage commented that no exemptions should be made for replacement parts. (Docket EERE-2013-BT-STD-0006; Clarage, Public Meeting Transcript, No. 161 at p. 43) The CA IOUs commented that no exemptions should be made for replacement fans (Docket EERE-2013-BT-STD-0006; CA IOUs, Public Meeting Transcript, No. 163 at p. 185)
ebm-papst commented that replacements for identical fan models that are not compliant should be exempt from the regulation for no more than 5 years. (Docket EERE-2013-BT-STD-0006; ebm-papst, No. 152 at p. 3)
Several stakeholders commented that replacement fans for fans embedded in larger pieces of equipment should be exempted from the test procedure and energy conservation standard rulemaking. Ingersoll Rand/Trane commented that replacement fans used as components should be exempted. Ingersoll Rand/Trane stated that replacement fans under the new regulation may not be suitable for the existing equipment, and thus replacement of the equipment may be required in order for the fan to comply. In addition, Ingersoll Rand/Trane expressed safety concerns that could arise from using replacement fans on existing equipment that serves applications such as combustion air, or heating applications. (Docket EERE-2013-BT-STD-0006; Ingersoll Rand/Trane, No. 153 at p. 5) AHRI commented that replacement fans for fans embedded in equipment made before the compliance date should be exempt because the life of the equipment is longer than the life of the fan. In addition, AHRI noted that most replacement fan parts are supplied from the original equipment manufacturers and are not sold in a testable configuration; therefore the exemption of replacement fans is unlikely to create enforcement loopholes. (Docket EERE-2013-BT-STD-0006; AHRI, No. 158 at p. 7)
AMCA commented that no consensus was obtained amongst AMCA's membership regarding an approach for replacement fans. (Docket EERE-2013-BT-TP-0006; AMCA, Public Meeting Transcript, No. 164 at p. 325) In response to the October 2021 RFI, AHRI and Morrison commented that the scope of any fan regulation should be limited to standalone fans and should recognize the utility of replacement parts. These commenters stated that HVACR and water heating equipment are built, tested, rated, and certified as a completed design, which is reliant upon a specific set of components, and that modifying these components changes the performance of the equipment. AHRI and Morrison also commented that in many cases, such as supply air fans for gas fired heat exchangers, hot water coils or electric resistance units, there are a variety of equipment safety and performance standards affected by the precisely engineered fan performance. AHRI and Morrison stated that if a replacement fan is made non-compliant because of new regulations, the continued safe use of the system would be called into question and the negative consequences could be catastrophic. (AHRI, No. 10 at p. 3; Morrison, No. 8 at p. 2) Morrison commented that replacement parts used in HVAC equipment should therefore be out of scope for safety reasons. (Morrison, No. 8 at p. 2)
As discussed, fans and blowers as defined consist of an impeller, a shaft and bearings and/or driver to support the impeller, as well as a structure or housing. They may include a transmission, driver, and/or motor controller. The proposed test procedure would apply to the fan and blower as complete equipment (
i.e.,
inclusive of all the parts listed in the definition) and not to a single component of the fan (
e.g.,
the impeller alone). DOE proposes to include all fans and blowers that: (1) meet the criteria for scope inclusion as described in section III.A.1 of this document, and (2) are not proposed for exclusion as listed in section III.A.2 of this document or Table III-8 of this document, regardless of whether that fan is a replacement fan. DOE is not proposing to include fan parts (
e.g.,
impeller, housing) in the scope of the test procedure, as such components do not meet the definition of fan and blower. At this time, DOE is not proposing energy conservation standards for fans and blowers, and the proposed test procedure would not impact the availability of current models. The proposed test procedure, if final, would not set any energy conservation standards and would not result in any non-compliant fans.
B. Definitions
This section discusses DOE's proposed definitions for specific terms used in the proposed test procedure.
1. Fan and Blower Categories
DOE proposes to define several fan and blower categories to support the scope proposals described in section III.A of this document.
As previously discussed, the classification of fans and blowers recommended by the Working Group for coverage under a test procedure and the corresponding terms and definitions in AMCA 214-21 and in the CEC proposed regulations are presented in Table III-1 of this document. The CEC definitions are similar to the AMCA 214-21 definitions. The inclusion of additional language in the CEC definitions to indicate a fan's intended application or whether a fan's inlet or outlet is (optionally, as relevant) ducted is informative, but does not further distinguish the terms. In addition, for axial panel fans, the CEC definitions specifies that the housing is typically mounted to a wall separating two spaces, and the fans are used to increase the pressure across this wall. Inlets and outlets are not ducted.
DOE proposes to utilize the terminology and definitions specified in AMCA 214-21 to define the categories of fans and blowers proposed in the scope of applicability of the test procedure and tested using AMCA 210-16 as follows: (1) axial inline fan; (2) centrifugal housed fan; (3) centrifugal unhoused fan; (4) centrifugal inline fan; (5) radial-housed fan; and (6) PRVs. (See Table III-1 of this document). DOE proposes to modify the definition of axial panel fan as provided in AMCA 214-21 to distinguish these fans from air circulating axial panel fans.
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The addition in the CEC definitions specifies that axial panel fans are typically mounted to a wall separating two spaces, and the fans are used to increase the pressure across this wall. This description distinguishes axial panel fans from axial air circulating panel fans, which do not have provisions for connection to ducting or separation of the fan inlet from its outlet. However,
the CEC distinction is based on how the fan is installed. Instead, DOE proposes to rely on physical features and to define axial panel fans as follows:
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The AMCA 214-21 and CEC definitions for these terms appear in Table III-1 of this document.
Axial panel fans means an axial fan, without cylindrical housing, that includes a panel, orifice plate, or ring with brackets for mounting through a wall, ceiling, or other structure that separates the fan's inlet from its outlet.
In addition, to support the exclusions proposed in section III.A.2 of this document, and clarify which fans would fall under the proposed exclusions. DOE proposes a definition of “safety fan”, as discussed in section III.B.3 of this document. DOE also proposes to adopt definitions of the terms “induced flow fan” and “jet fan” as established in AMCA 214-21. In addition, DOE proposes to define “cross-flow fan” as defined in AMCA 208-18. See section III.A.2 of this document.
DOE requests comment on the definitions proposed for the following fan categories: (1) axial inline fan; (2) axial panel fan; (3) centrifugal housed fan; (4) centrifugal unhoused fan; (5) centrifugal inline fan; (6) radial-housed fan; and (7) PRVs, consistent with AMCA 214-21. If any of the definitions are not appropriate, DOE seeks input on how they should be amended and why.
DOE seeks input and comments on the proposed definitions of (1) induced flow fan, (2) jet fan, and (3) cross-flow fan consistent with AMCA 214-21 and AMCA 208-18. If any of the definitions are not appropriate, DOE seeks input on how they should be amended and why.
2. Basic Model
The basic model concept allows manufacturers to group like models for the purpose of making representations of energy efficiency and/or energy use, including for the purpose of demonstrating compliance with DOE's energy conservation standards to the extent DOE has established such standards. The concept of basic model may allow manufacturers to reduce the amount of testing they must do to rate the energy use or efficiency of their product. DOE's current regulations provide equipment-specific basic model definitions, which typically state that models within the same basic model group have “essentially identical” energy or water use characteristics; as well as a general definition that provides (with some exceptions noted in the regulatory text) that a basic model means “all units of a given type of product (or class thereof) manufactured by one manufacturer, having the same primary energy source, and which have essentially identical electrical, physical, and functional characteristics that affect energy consumption, energy efficiency, water consumption, or water efficiency.”
See for example
10 CFR 430.2; 431.62, 431.152, 431.192, 431.202, 431.222, and 431.292.
DOE proposes to add a definition of basic model specific to fans and blowers that specifies a “basic model” as “all units of fans and blowers manufactured by one manufacturer, having the same primary energy source, and having essentially identical electrical, physical, and functional (
e.g.,
aerodynamic) characteristics that affect energy consumption.”
Fan and blower manufacturers may offer for sale the same bare shaft fan assembled, packaged, or integrated with different motor, transmission, and control combinations. Based on DOE's proposed basic model definition, the same bare shaft fan, sold with different combinations of motor, transmission, and controls (or as a bare shaft fan) could be grouped under the same basic model. In addition, fan manufacturers would be able to elect to group similar individual fan models within the same basic model under the same ratings to reduce testing burden, provided that all representations regarding the energy use of fans within that basic model are identical and are based on the most consumptive unit.
See
76 FR 12422, 12428-12429 (March 7, 2011).
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Manufacturers would have the option to certify separate ratings for each combination of bare shaft fan, motor, transmission and/or control in order to make separate representations of the performance of each specific combination.
45
These provision would allow manufacturers to group individual models with essentially identical, but not exactly the same, energy performance characteristics into a basic model to reduce testing burden. Under DOE's certification requirements, all the individual models within a basic model identified in a certification report as being the same basic model must have the same certified efficiency rating and use the same test data underlying the certified rating. The March 7, 2011, final rule also established that the efficiency rating of a basic model must be based on the least efficient or most energy consuming individual model
(i.e.,
all individual models within a basic model must be at least as energy efficient as the certified rating). 76 FR 12422, 12428-12429.
In view of the substantial number of fans that could be subject to an individual certification requirement for each basic model, the Working Group discussed various options to reduce the burden of certification when the basic models only differed in terms of a single bare shaft fan feature,
e.g.,
number of blades on the impeller, wheel width, or pitch angle as opposed to a different motor, transmission or control combination. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 162 at pp. 24-63. One option discussed was to only require testing and certifying a fan model based on a single value or setting of the bare shaft fan feature, and only publishing one rating for that fan model, without differentiating for the variations in the given bare shaft fan feature. However, because this would provide inaccurate performance information, this option was not further considered. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 162, at pp. 45-46)
A second option that was discussed was to require that manufacturers certify a limited number of basic models and provide DOE with a mathematical formula to enable interpolating results for non-certified models. However, because these formulas can be proprietary algorithms, this option was not further considered. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 162 at p. 38 and at p. 48)
A third option that was discussed was to require manufacturers to certify a limited number of basic models and to provide DOE with a statement that all other fan variations based on changing one of the bare shaft fan's features was also compliant. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 162 at pp. 48, 61) For example, a manufacturer would be required to certify one basic model at the feature-setting corresponding to the highest energy consumption and to submit to DOE a statement certifying that all other fan variations based on changing that one feature were also compliant. Another example would be to require manufacturers to certify the bounds of a range, for example maximum and minimum impeller width, and submit a statement that any fan model in between would be compliant. Under this option, manufacturers would still be allowed to make representations of the FEP and FEI of the non-certified basic models. (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 162 at p. 61)
A fourth option discussed was to allow manufacturers to be able to submit an executable version of their selection programs to DOE for certification instead of submitting a separate compliance statement and certification report for each individual basic model, or variation of a basic model which would constitute a new basic model. In addition, because all manufacturers may not have a selection software, the Working Group discussed that the equivalent alternative would be to have to submit individual
certification statements and reports for each individual basic model and any of their variations that would constitute a new basic model. Test results for each basic model would need to be provided in a tabular format, with the possibility of replacing the tabular format by equations providing equivalent results (Docket No. EERE-2013-BT-STD-0006; Public Meeting Transcript, No. 162, at pp. 62-77)
This fourth and last option was the one recommended by the Working Group. (Docket No. EERE-2013-BT-STD-0006; No. 179, Recommendation #26, at p. 13) Specifically, AMCA recommended that DOE use a process similar to the Electronic Catalog Checking System (referred to as “ECAT”) used by AMCA to check the validity of fans offered for sale in manufacturer selection programs. AMCA suggested that DOE use ECAT or a comparable system to evaluate selection software that represents what manufacturers offer for sale. (Docket No. EERE-2013-BT-STD-0006; AMCA, No. 168 at p. 2) AMCA added that their members are especially concerned with how manufacturers would certify fans with partial-width wheels and reiterated that their preference is to allow submission of selection software, or to tie each sale to a certified full width model with an AEDM to simplify certification of a modified certified fan after production. AMCA explained that very few partial-width wheel fans are likely to ever be produced twice, however, manufacturers offer them for sale using selection programs, displaying and documenting their performance to customers. (Docket No. EERE-2013-BT-STD-0006; AMCA, No. 169 at p. 5)
Some manufacturers may distribute in commerce a fan model that can be “configured.” For example, an adjustable-pitch axial fan of a given size may be offered at 30 different blade pitches. Similarly, a centrifugal fan of a given size may be offered in small increments of impeller widths and impeller diameters without changing the housing size. As each blade pitch angle is a variation of the same fan model, DOE proposes that all blade pitches of a certain size adjustable-pitch axial fan may be represented as a single basic model.
Similar to the approach taken for pumps for trimmed impellers (
see
81 FR 4086, 4092-4093 (January 26, 2016), DOE proposes that, for centrifugal fans, manufacturers represent efficiency at the full-impeller width (
i.e.,
100 percent impeller width) and full-impeller diameter (
i.e.,
100 percent impeller diameter). Fan performance information is typically provided at 100 percent impeller width and 100 percent impeller diameter in manufacturer product literature. Additionally, DOE proposes that all variations of a given full-size impeller width and full-size impeller diameter may be considered to be part of a single basic model represented by the fan with the full-size impeller width and full-size diameter. As such, DOE proposes to define “full-width impeller” and “full-diameter impeller” as “the maximum impeller width and the maximum impeller diameter with which a given fan basic model is distributed in commerce.” The grouping of impeller diameter variation under the same basic model would not allow grouping of fans of different full-impeller size together. Rather, the proposal would capture small increments of impeller widths and impeller diameters (without changing the housing or structure of the fan). For example, if a manufacturer offers the same fan model in the following full-impeller sizes: 60, 70, 80, and 90 inches, each full-impeller size would constitute a separate basic model. However, a fan with an impeller trimmed to 69 inches could be grouped with the same 70-inch untrimmed fan.
In summary, DOE proposes to define “basic model” as meaning “all units of fans and blowers manufactured by one manufacturer, having the same primary energy source, and having essentially identical electrical, physical, and functional (
e.g.,
aerodynamic) characteristics that affect energy consumption. In addition: (1) all variations of blade pitches of an adjustable-pitch axial fan may be considered a single basic model; and (2) all variations of impeller widths and impeller diameters of a given full-width impeller and full-diameter impeller centrifugal fan may be considered a single basic model.”
DOE believes this approach will address concerns expressed by commenters regarding the potentially large number of models that would need to be considered.
DOE requests comment on the proposed definition of basic model, with respect to fans and blowers.
3. Safety Fans
DOE proposes a definition of safety fan to support the exclusion for safety fans proposed in section III.A.2 of this document.
In the energy conservation standards framework document published February 1, 2013, DOE presented a definition for safety fans, as follows: “an axial or centrifugal fan designed for use in applications requiring extra safety measures, such as: (a) those designed to operate in potentially explosive atmospheres; (b) those designed for emergency use only, at short-time duty, with regard to fire safety requirements; (c) those designed specifically to operate where the temperature of gases being moved exceed 500 °F; and (d) those designed for toxic, highly corrosive, or flammable environments with abrasive substances.” (Docket No. EERE-2013-BT-STD-0006, No. 1, at p. 9) This definition was based on the European Commission Regulation No. EU 327/2011.
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46
The definition from the European Commission Regulation No. EU 327/2011 is provided in Article 1, Section 3 of the European Commission Regulation No. EU 327/2011 which defines safety fans as (1) Fans designed specifically to operate in potentially explosive atmospheres; (2) Fans designed for emergency use only, at short-time duty, with regard to fire safety requirements; (3) Fans designed specifically to operate: (a) Where temperatures of the gas being moved exceed 100 °C; (b) Where ambient temperatures for the motor, if located outside the gas airstream, driving the fan exceed 65 °C; (c) Where the annual average temperature of the gas being moved and/or the operating ambient temperature for the motor, if located outside the gas stream, are lower than −40 °C; (d) In toxic, highly corrosive or flammable environments or in environments with abrasive substances.
See eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011R0327.
The Working Group recommended to exclude safety fans and further included a recommended definition for these fans, consistent with the European definition as follows: fans designed for use in applications requiring extra safety measures, such as: (a) those designed to operate in potentially explosive atmospheres (“ATEX” fans);
47
(b) those designed for emergency use only, at short-time duty, with regard to fire safety requirements (
e.g.,
smoke extraction fans, emergency reversible tunnel fans); (c) those designed specifically to operate where the temperature of gases being moved exceed 200 °F;
48
or (d) those designed for use in toxic, highly corrosive, or flammable environments [or in environments] with abrasive substances (
e.g.
NQ-1).
49
(Docket No. EERE-2013-
BT-STD-0006; No. 179, Recommendation #2, at p. 2; No. 179, Appendix D, at p. 17)
47
ATEX Directive 2014/34/EU covers equipment and protective systems intended for use in potentially explosive atmospheres or “Atmosphere Explosive” (“ATEX”).
48
The temperature limit in the safety fan definition as written in the term sheet should have been of 200 °C (392 °F), and not 200 °F. As specified in the term sheet, the intent of the Working Group was to align the safety fan definition with the European definition. The limit of 200 °C corresponds to “high temperature fans” as defined in EN 12101-3:2002 “Smoke and heat control systems. Specification for powered smoke and heat exhaust ventilators”, class F200 (resistant to 200 °C during 20 minutes) and to the “T3” temperature classification in NFPA 70 (National Electrical Code, NEC) article 500 and 505.
49
Fans for nuclear applications were discussed during the July 21, 2015 meeting of the Working
Group. (Docket No. EERE-2013-BT-STD-0006, No. 161, Public Meeting transcript, at p. 75) There was a typographic error in the public meeting transcript and the term sheet. The intent of “NQ-1” as written in the term sheet was to refer to nuclear fans and refers to “NQA-1” or fans that meet the requirements in American Society of Mechanical Engineering (“ASME”) NQA-1 certification program “Quality Assurance Requirements for Nuclear Facility Applications.”
To help identify safety fans, the Working Group relied on the description of physical characteristics, third party testing, or third party verification terms such as ATEX and NQA-1 to identify nuclear fans. The Working Group stated that the definition recommended in appendix D may be subject to potential edits necessary to accomplish the same intent.
Id.
After publication of the term sheet, AMCA commented, with regard to safety fans, that fans for nuclear installations should be exempted from the rulemaking scope. (Docket No. EERE-2013-BT-STD-0006; AMCA, No. 169 at p. 3). In addition, AMCA noted that Working Group members agreed that the high temperature limit for fans should be set at 200 °C, rather than 200 °F, which is the temperature limit in the term sheet. (Docket No. EERE-2013-BT-STD-0006; AMCA, No. 169 at p. 4).
As discussed in section III.A.2 of this document, the exceptions to section 6.5.3.1.3 (“Fan Efficiency Requirements”) of ASHRAE 90.1-2019 related to safety fans include: fans used for moving gases at temperatures above 482 °F (equivalent to 250°C); reversible fans used for tunnel ventilation; and fans that are intended to only operate during emergency conditions.
The CEC has proposed the following definition of safety fan: (1) a fan that is designed and marketed to operate only at or above 482 °F (250 °C); (2) a reversible axial fan in cylindrical housing that is designed and marketed for use in ducted tunnel ventilation that will reverse operations under emergency ventilation conditions; (3) a fan bearing an Underwriter Laboratories or Electric Testing Laboratories listing for “Power Ventilators for Smoke Control Systems”; (4) an open discharge exhaust fan with integral discharge nozzles which develop or maintain a minimum discharge velocity of 3000 feet per minute (“FPM”); (5) a fan constructed in accordance with AMCA type A or B spark resistant construction as defined in ANSI/AMCA Standard 99-16 Standards Handbook; (6) a fan designed and marketed for use in explosive atmospheres and tested and marked according to EN 13463-1:2001 Non-electrical Equipment for Potentially Explosive Atmospheres; or (7) an electric-motor-driven- Positive Pressure Ventilator as defined in ANSI/AMCA Standard 240-15 Laboratory Methods of Testing Positive Pressure Ventilators for Aerodynamic Performance Rating.
50
50
See CEC Docket No. 22-AAER-01, TN # 241950, Proposed regulatory language for Commercial and Industrial Fans and Blowers, at pp. 7-8.
Regarding item (1) of the CEC definition, the temperature limit in the CEC definition is 250 °C, compared to 200 °C recommended in the term sheet. This higher temperature aligns with the exceptions to Section 6.5.3.1.3 of ASHRAE 90.1-2019 “Fan Efficiency Requirements,” which excludes fans used for moving gases at temperatures above 482 °F (equivalent to 250°C). Items (2), (3), (5),
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and (6) of the CEC definition describe fans that are used in explosive atmospheres or for smoke extraction. Item (4) of the CEC definition includes the minimum discharge velocity of 3000 FPM, which corresponds to the minimum safe discharge velocity per ANSI Z9.5-2012 “Laboratory Ventilation,”
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which describes fans that are used in laboratory environments. Finally, item (7) of the CEC definition, which relates to positive pressure ventilator fans, describes fans that are used (typically by firefighters) to remove heat and combustion products from a structure. Positive pressure ventilator fans are excluded from AMCA 210-16 and are tested per AMCA 240-15, Laboratory Methods of Testing Positive Pressure Ventilators for Aerodynamic Performance Rating.
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Fan applications with airstreams of explosive or flammable particles or gases require spark resistant construction in accordance with AMCA spark resistant specifications as described in ANSI/AMCA Standard 99-16 “Standards Handbook”. Spark resistant construction is intended to prevent any two or more fan components from generating sparks within the airstream by rubbing or striking during operation. AMCA 99-16 defines three classes of spark construction resistant constructions: A, B and C, with level C being the “entry level” and level A offering the highest degree of spark resistance.
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ANSI/AIHA/ASSE Z9.5-2012, “Laboratory Ventilation” provides laboratory ventilation requirements and practices.
Based on a review of the existing industry and regulatory definitions of “safety fan,” DOE has tentatively determined that the definition proposed by the CEC is representative of the equipment considered “safety fans”;
i.e.,
fans that can operate at high temperatures, fans that are used in explosive atmospheres or for smoke extraction, fans that are used in laboratory environments, and fans used to remove heat and combustion products from a structure. Therefore, DOE proposes to adopt a definition in line with the definition proposed by the CEC with the following edits. Regarding item (1) of the CEC definition: DOE proposes not to include the term “only” from “a fan that is designed and marketed to operate only at or above 482 degrees Fahrenheit (250 degrees Celsius)” because DOE has tentatively determined that a fan that can operate at or above a certain temperature can also operate below. Regarding item (4) DOE has tentatively determined that the definition of safety fans is equivalent to “laboratory exhaust fans” as defined in Section 3.52 of AMCA 214-21: fans designed and marketed specifically for exhausting contaminated air vertically away from a building using a high-velocity discharge. DOE is considering replacing item (4) with “laboratory exhaust fans” and to define it in accordance with AMCA 214-21. DOE also reviewed item (6) and notes that the referenced industry standard is no longer current has been replaced. In 2008, the International Electrotechnical Commission System for Certification to Standards Relating to Equipment for Use in Explosive Atmospheres replaced EN 13463-1 by ISO 80079-36,” Explosive atmospheres—Part 36: Non-electrical equipment for explosive atmospheres—Basic method and requirements”.
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The latest version of ISO 80079-36 is the 2016 edition. Therefore, DOE proposes to reference ISO 80079-36:2016, instead of EN 13463-1:2001. In addition, DOE notes that AMCA 230-15 is under review and DOE proposes to update the reference to the latest version of AMCA 230 available at the time of publication of the test procedure final rule.
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See www.intertek.com/blog/2019-03-14-hazloc/.
DOE requests comments on its proposed definition of safety fans. Specifically, DOE requests comments in whether item (4) of the CEC definition of safety fans is equivalent to “laboratory exhaust fans” as defined in Section 3.52 of AMCA 214-21.
4. Air Circulating Fans
In the October 2021 RFI, DOE published a request for information regarding potential test procedures for fans and blowers, specifically for air circulating fans and ACFHs. 86 FR 54412. DOE noted that Section 5.1 of AMCA 230-15 defines an “air circulating fan” as “a non-ducted fan used for the general circulation of air within a confined space.” 86 FR 54412, 54414. Further, AMCA 230-15 classifies ACFHs as a category of air circulating
fans and defines ACFHs in Section 5.1.1 of AMCA 230-15 as follows: “an assembly consisting of a motor, impeller and guard for mounting on a pedestal having a base and column, wall mount bracket, ceiling mount bracket, I-beam bracket or other commonly accepted mounting means.” Section 5.1.1 of AMCA 230-15. DOE noted that Section 3.15 of AMCA 214-21 defines the term “circulating fan” as “a fan that is not a ceiling fan that is used to move air within a space that has no provision for connection to ducting or separation of the fan inlet from its outlet. The fan is designed to be used for the general circulation of air.”
Id.
DOE also noted that AMCA 214-21 does not include a definition for ACFH.
Id.
DOE requested feedback on the definitions of air circulating fan and ACFHs as provided in AMCA 230-15, and of other categories of air circulating fans (
i.e.,
personnel coolers, box fans, and table fans). 86 FR 54412, 54414.
AMCA commented that it did not support using the AMCA 230-15 definition of “air circulating fan” because it had been updated in AMCA 214-21. In addition, AMCA recommended adding “air” to the defined term (
i.e.,
“air circulating fan”). (AMCA, No. 6 at p. 3)
In response to the February 2022 ECS RFI, ebm papst commented that the descriptions of the different types of ACFs in AMCA 230 were not intended to be used for delineating ACFs into different classes in DOE regulations. (Docket No. EERE-2022-BT-STD-0002, ebm-papst, No. 8 at p. 2)
Since the end of the comment period, the AMCA 230 committee
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has been considering a revised definition of air circulating fan as follows: a fan that has no provision for connection to ducting or separation of the fan inlet from its outlet using a pressure boundary, operates against zero external static pressure loss, and is not a jet fan (as defined in AMCA 214-21).
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A technical Committee was formed to review AMCA 230-15. For more information see
https://www.cognitoforms.com/AMCA1/_230TechnicalCommitteeInvitation10132021.
DOE reviewed the definition of “air circulating fan” in AMCA 214-21 and notes that the description of the intended application is unnecessary and may create confusion with the proposed ceiling fan definition, as discussed further in this section. In addition, as noted previously, DOE does not consider ceiling fans as fans and blowers, and therefore ceiling fans are not included as “air circulating fans”. For this reason, DOE has determined that it is unnecessary to specify that an air circulating fan is not a ceiling fan within the definition of air circulating fan. DOE also reviewed the definition being considered by the AMCA 230 committee which adds the following terms ” using a pressure boundary” and “operates at zero static pressure” to further specify that air circulating fans do not have any provision for connection to ducting or separation of the fan inlet from its outlet that would create a static pressure differential between the inlet and the outlet of the fan. In addition, DOE agrees that jet fans should be excluded as discussed in section III.A.2 of this document.
Therefore, DOE proposes to define air circulating fan using the definition being considered by the AMCA 230 committee as it provides further specificity and proposes to define air circulating fans as “a fan that has no provision for connection to ducting or separation of the fan inlet from its outlet using a pressure boundary, operates against zero external static pressure loss, and is not a jet fan.”
Air circulating fans exist in different configurations depending on the impeller design (axial or centrifugal), presence or absence of a guard and/or housing, and the shape of the housing. As discussed, AMCA 230-15 (with errata) includes the following equipment categories discussed in the remainder of this section: (1) ACFHs; (2) personnel coolers; (3) box fans; and (4) table fans.
In response to the October 2021 RFI, AMCA commented that it does not support DOE using the AMCA 230-15 definition of ACFH because AMCA believes the definition seems insufficient to distinguish ACFHs from ceiling fans. AMCA additionally commented that because ACFHs can be sold with mounting kits for installation onto ceilings, I-beams, or other overhead structures, there is confusion in the industry as to whether they meet the statutory definition of ceiling fan. Instead, AMCA recommended adopting a modified ACFH definition as follows: “An assembly consisting of a motor, impeller and guard for mounting on a pedestal having a base and column, wall mount bracket, ceiling mount bracket, I-beam bracket or other commonly accepted mounting means. ACFH do not have housings with solid walls, such as tubes, boxes or panels. An ACFH has a maximum value of diameter-to-maximum-operating-speed ratio (
e.g.,
0.06 inches per rotations per minute (“in/RPM”)) to distinguish ACFH from ceiling fans. ACFH are known by other names in the various industries in which they are used, including basket fan, horizontal-airflow fan, and stir fan”. AMCA suggested that the revisions would ensure the definition separates ACFHs from other types of air circulating fans and that including the maximum-value threshold of 0.06 in/RPM would separate ACFHs from ceiling fans. AMCA additionally commented that the suggested revisions further highlight alternative names for ACFHs used in industry. (AMCA, No. 6 at p. 4) AMCA also provided supporting analysis of the performance data of 178 models of air circulating fan heads, all of which had a diameter-to-maximum-operating-speed ratio less than 0.06 in/RPM, as recommended in the ACFH definition. (AMCA, No. 6 at p. 5)
The CA IOUs recommended that DOE add the following sentence to the definition of ACFH to the existing definition in AMCA 230-15 to distinguish ACFHs from ceiling fans and other air circulating fans such as personnel and livestock coolers: “ACFHs do not have housings with solid walls such as tubes, boxes, or panels. An ACFH has a maximum value of diameter-to-maximum operating speed ratio of 0.06 in/RPM (inch per revolution per minute)”. The CA IOUs explained that the addition would clarify that ACFHs are basket-type fans that do not have solid housings. (CA IOUs, No. 9 at pp. 1-2)
NEEA commented in support of AMCA's analysis of the existing market and of using 0.06 in/RPM as the maximum value for ACFHs. (NEEA, No. 11 at p.1)
AHRI supported the explicit inclusion of ACFHs under fans and blowers, with modifications to the definition of ACFHs as recommended by AMCA. AHRI commented in support of AMCA's proposed additions to the ACFH definition to specify that an ACFH “do(es) not have housings with solid walls, such as tubes, boxes or panels.” AHRI commented that the inclusion of this text is important, stating that it not only helps define the product, but it also clearly fits within the scope of AMCA 214-21. AHRI stated that AMCA 214-21 specifies that “AMCA Standard 214 primarily is for fans that are tested alone or with motors and drives; it does not apply to fans tested embedded inside of other equipment,” and as such, that it is only necessary to regulate standalone fans. (AHRI, No. 10 at p. 2)
MEP commented that broad definitions result in significant and undue burden on manufacturers that use any type of fan in any of their products, as those manufacturers have to evaluate each product against each proposed aspect of each step in the regulatory process. MEP recommended that DOE establish ACFH as a product
category of fans as defined at 10 CFR 431.172 with the following definition: “ACFHs are fans powered by poly-phase electric current with a fan shaft power greater than 3 hp and which only provide concentrated directional airflow and where the construction consists of a motor, impeller, guard, and may include connections for mounting or support and which are exclusive of other covered products or fans embedded inside of other equipment or products.” MEP commented that the definition of ceiling fan is obvious and exclusionary from an ACFH. MEP further stated that AMCA recognizes the definition of “embedded fan” in Section 3.25.4 of ANSI/AMCA 214-21 as “a fan that is part of a manufactured assembly where the assembly includes functions other than air movement” and recommended that DOE include this qualification in the Federal definition of ACFH to clarify the separation between ceiling fans and other products that use fans for purposes other than air circulation (
e.g.,
combustion, humidification, dehumidification, heating, or cooling to name a few). (MEP, No. 5 at p. 1) .
Since the end of the comment period, the AMCA 230 committee has considered a revised definition of ACFH, under the term “ACFH, unhoused” as follows: an air circulating fan without housing, having an axial impeller with a ratio of fan-blade span (in inches) to maximum rate of rotation (in revolutions per minute) less than or equal to 0.06. The impeller may or may not be guarded.
On December 7, 2021, DOE published a supplemental notice of proposed test procedures for ceiling fans. 86 FR 69544 (“December 2021 Ceiling Fans SNOPR”). In the December 2021 Ceiling Fans SNOPR, DOE proposed a definition of ceiling fan that specifies the term “circulating air” based on diameter-to-maximum operating speed ratio: a fan for “circulating air” is one with a ratio of fan blade span (in inches) to maximum rotation rate (in revolutions per minute) greater than 0.06. 86 FR 69544, 69551. To support this proposed definition, DOE performed an independent analysis and tentatively determined that ACFHs have a diameter-to-maximum operating speed ratio of less than or equal to 0.06 in/RPM. 86 FR 69544, 69550.
ACFHs are air circulating fans without a housing (
i.e.,
cylindrical housing, box housing, or panel). They have an axial impeller which is typically surrounded by a guard and are commonly called “basket fans”. Therefore, the added specification of “unhoused” in the definition from the AMCA 230 committee is helpful to further distinguish these fans. DOE reviewed comments from stakeholders and has tentatively determined that the definition being considered by the AMCA 230 committee would address stakeholder comments and would ensure that ACFH are distinguished from other types of fans and blowers and air circulating fans. Therefore, DOE proposes to define an unhoused ACFH as follows: “An air circulating fan without housing, having an axial impeller with a ratio of fan-blade span (in inches) to maximum rate of rotation (in revolutions per minute) less than or equal to 0.06. The impeller may or may not be guarded. ” The 0.06 in/RPM threshold is appropriate to differentiate ACFHs from ceiling fans and aligns with the December 2021 Ceiling Fans SNOPR. In addition, the additional description of the absence of a housing would ensure that ACFHs are distinguished from other categories of fans and blowers and air circulating fans. Table fans would be included in the proposed definition of unhoused ACFHs.
As previously noted, air circulating fans also come with housings. To describe air circulating fans with housings, the AMCA 230 committee is considering a definition of housed ACHFs as: an air circulating fan with an axial or centrifugal impeller, and a housing. DOE has tentatively determined that the definition considered by the AMCA 230 committee accurately describes all categories of equipment that fall under housed ACFHs, therefore, DOE proposes to adopt the definition established by the AMCA 230 committee. The AMCA 230 committee is further considering establishing definitions for four categories of housed ACFHs, as follows: (1) an air circulating axial panel fan means an axial air circulating fan without a cylindrical housing or box housing that is mounted on a panel, orifice plate or ring (also commonly known as panel fan, cow cooler, livestock cooler); (2) a box fan means an axial air circulating fan without a cylindrical housing that is mounted on a panel, orifice plate or ring and is mounted in a box housing; (3) a cylindrical air circulating fan means an axial air circulating fan in a cylindrical housing that is not a positive pressure ventilator (“PPV”) (also commonly known as personnel cooler, barrel fan, drum fan, high velocity fan, portable cooler, thermal mixing fan, destratification fan, downblast fan); and (4) a housed centrifugal air circulator means a fan with a centrifugal or radial impeller in which airflow exits into a housing that is generally scroll shaped to direct the air through a single, narrow fan outlet (also commonly known as utility blower, loading dock fan, carpet dryer, floor fan).
DOE reviewed additional air circulating fans with housing distributed in commerce and has tentatively identified four categories of air circulating fans based on the blade design (
i.e.,
axial or centrifugal) and housing configuration (
i.e.,
panel, box, cylindrical, or scroll shaped), matching the equipment segmentation considered by the AMCA 230 committee. In addition, as discussed in section III.B.3, DOE proposes to exclude PPVs and proposes to add this clarification when defining cylindrical air circulating fans. DOE has tentatively determined that the definitions considered by the AMCA 230 committee accurately describes the four categories of equipment that DOE identified as meeting the definition of housed ACFH. Therefore, DOE proposes to adopt the definitions of air circulating axial panel pan, box fan, cylindrical air circulating fan, and housed centrifugal air circulator as considered by the AMCA 230 committee, with the following clarifications: (1) DOE proposes to replace “air circulating fan” by “housed air circulating fan head” to explicitly indicate that each of these fans are housed ACFHs; (2) replace the term “circulator” by ” circulating fan” for consistency in terminology; (3) remove the examples of additional terms used commonly by industry. Personnel coolers (as defined in AMCA 230-15 (with errata)) would be included under the proposed cylindrical air circulating fan definition.
In response to the February 2022 ECS RFI, the CA IOUs commented that DOE should include panel fans as ACFs and that panel fans are often used as ACFs for air circulation and cooling for residential, commercial, and agricultural spaces. They also stated that most of the ACFs in the Bioenvironmental and Structural System Lab (“BESS Lab”) database are panel fans. (Docket No. EERE-2022-BT-STD-0002, CA IOUs, No. 7 at p. 5-6) ebm papst recommended that the DOE test procedure should clearly state that basket fans (consisting of a motor, axial impeller, and a basket-style guard that partially or completely encloses the rotating parts) should be tested according to AMCA 230. (Docket No. EERE-2022-BT-STD-0002, ebm-papst, No. 8 at p. 2)
As noted previously, DOE proposes to include axial panel air circulating fan as a category of housed ACFH. In addition, DOE notes that basket fans meet the
proposed definition of unhoused ACFH and would therefore be tested in accordance with AMCA 214-21, referencing AMCA 230-15 (with errata) and modifications proposed in this notice.
For all definitions related to air circulating fans, DOE is aware that the revisions being considered by the AMCA 230 committee are subject to change and could further be revised in the next version of AMCA 230. Should the revised version of AMCA 230 publish prior to the publication of any DOE test procedure final rule, DOE intends, after considering stakeholder feedback received in response to the proposals in this document, to revise the definitions in line with the latest AMCA 230 standard, provided the updates in this standard are consistent with the definitions DOE is proposing in this NOPR or the updates are related to topics that DOE has discussed and for which DOE has solicited comments in this NOPR.
DOE requests comment on the proposed definitions for air circulating fan and related terms.
5. Definitions Related to Heat Rejection Equipment
As stated, DOE is proposing
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