# Energy Conservation Program: Energy Conservation Standards for Ceiling Fans

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/fr%3A2023-12957

## Record

- **Collection:** Federal Register
- **Document type:** Proposed Rule
- **Published:** June 22, 2023
- **Citation:** 88 FR 40932

## Text

DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2021-BT-STD-0011]
RIN 1904-AE99
Energy Conservation Program: Energy Conservation Standards for Ceiling Fans

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Notice of proposed rulemaking and announcement of public meeting.

SUMMARY:

The Energy Policy and Conservation Act, as amended (“EPCA”), prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including ceiling fans. EPCA also requires the U.S. Department of Energy (“DOE”) to periodically determine whether more-stringent, standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking (“NOPR”), DOE proposes new and amended energy conservation standards for ceiling fans, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.

DATES:

Comments:
DOE will accept comments, data, and information regarding this NOPR no later than August 21, 2023.

Meeting:
DOE will hold a public meeting via webinar on Thursday, July 27, 2023 from 1:00 p.m. to 4:00 p.m. See section IV, “Public Participation,” for webinar registration information, participant instructions and information about the capabilities available to webinar participants.” Comments regarding the likely competitive impact of the proposed standard should be sent to the Department of Justice contact listed in the
ADDRESSES
section on or before August 21, 2023.

ADDRESSES:

Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at
www.regulations.gov
under docket number EERE-2021-BT-STD-0011. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, identified by docket number EERE-2021-BT-STD-0011, by any of the following methods:

Email: CeilingFans2021STD0011@ee.doe.gov.
Include the docket number EERE-2021-BT-STD-0011 in the subject line of the message.

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.

Hand Delivery/Courier:
Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, 1000 Independence Ave. SW, Washington, DC 20585. 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 VII of this document.

Docket:
The docket for this activity, which includes
Federal Register
notices, 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
www.regulations.gov/docket/EERE-2021-BT-STD-0011.
The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section VII of this document for information on how to submit comments through
www.regulations.gov.

EPCA requires the Attorney General to provide DOE a written determination of whether the proposed standard is likely to lessen competition. The U.S. Department of Justice Antitrust Division invites input from market participants and other interested persons with views on the likely competitive impact of the proposed standard. Interested persons may contact the Division at
energy.standards@usdoj.gov
on or before the date specified in the
DATES
section. Please indicate in the “Subject” line of your email the title and Docket Number of this proposed rulemaking.

FOR FURTHER INFORMATION CONTACT:

Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 506-9870. Email:
ApplianceStandardsQuestions@ee.doe.gov.

Mr. Nolan Brickwood, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 586-4498. Email:
nolan.brickwood@hq.doe.gov.

For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:
ApplianceStandardsQuestions@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Synopsis of the Proposed Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits and Costs

D. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Ceiling Fans

C. Deviation From Appendix A

III. General Discussion

A. General Comments

B. Product Classes and Scope of Coverage

C. Test Procedure

D. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

E. Energy Savings

1. Determination of Savings

2. Significance of Savings

F. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Consumers

b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)

c. Energy Savings

d. Lessening of Utility or Performance of Products

e. Impact of Any Lessening of Competition

f. Need for National Energy Conservation

g. Other Factors

2. Rebuttable Presumption

IV. Methodology and Discussion of Related Comments

A. Market and Technology Assessment

1. Product Classes

a. Very Small Diameter Ceiling Fans

b. High-Speed Belt-Driven Ceiling Fans

c. High- and Low-Airflow Large-Diameter Ceiling Fans

d. Very-Close Mount Hugger Ceiling Fans

2. Test Procedure and Certification

3. Technology Options

a. Standard and Hugger Ceiling Fans

b. Large-Diameter Ceiling Fans

c. High-Speed Belt-Driven Ceiling Fans

d. Summary of Technology Options

B. Screening Analysis

1. Screened-Out Technologies

a. Standard and Hugger Ceiling Fans

b. Large-Diameter Ceiling Fans

2. Remaining Technologies

C. Engineering Analysis

1. Representative Units

2. Efficiency Analysis

a. Baseline Efficiency

b. Higher Efficiency Levels

c. Large-Diameter Ceiling Fan Standby Power

3. Cost Analysis

a. Hugger and Standard Ceiling Fans

b. Large-Diameter Ceiling Fans

c. High-Speed Belt-Driven Ceiling Fans

d. Manufacturer Mark-Up

4. Cost-Efficiency Results

D. Markups Analysis

E. Energy Use Analysis

1. Inputs for Standard and Hugger Ceiling Fans

a. Sample of Purchasers

b. Operating Hours

c. Power Consumption at Each Speed and Standby

2. Inputs for Large-Diameter and High-Speed Belt-Driven Ceiling Fans

a. Sample of Purchasers

b. Operating Hours

c. Power Consumption at Each Speed and Standby

3. Impact on Air-Conditioning or Heating Equipment Use

F. Life-Cycle Cost and Payback Period Analysis

1. Product Cost

2. Installation Cost

3. Annual Energy Consumption

4. Energy Prices

5. Maintenance and Repair Costs

6. Product Lifetime

7. Discount Rates

a. Residential

b. Commercial and Industrial

8. Energy Efficiency Distributions in the No-New-Standards Case and Each Standard Case

9. Payback Period Analysis

G. Shipments Analysis

H. National Impact Analysis

1. National Energy Savings

2. Net Present Value Analysis

I. Consumer Subgroup Analysis

J. Manufacturer Impact Analysis

1. Overview

2. Government Regulatory Impact Model and Key Inputs

a. Manufacturer Production Costs

b. Shipments Projections

c. Product and Capital Conversion Costs

d. Markup Scenarios

3. Manufacturer Interviews

4. Discussion of MIA Comments

K. Emissions Analysis

1. Air Quality Regulations Incorporated in DOE's Analysis

L. Monetizing Emissions Impacts

1. Monetization of Greenhouse Gas Emissions

a. Social Cost of Carbon

b. Social Cost of Methane and Nitrous Oxide

2. Monetization of Other Emissions Impacts

M. Utility Impact Analysis

N. Employment Impact Analysis

V. Analytical Results and Conclusions

A. Trial Standard Levels

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Consumers

a. Life-Cycle Cost and Payback Period

b. Consumer Subgroup Analysis

c. Rebuttable Presumption Payback

2. Economic Impacts on Manufacturers

a. Industry Cash Flow Analysis Results

b. Direct Impacts on Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Subgroups of Manufacturers

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Significance of Energy Savings

b. Net Present Value of Consumer Costs and Benefits

c. Indirect Impacts on Employment

4. Impact on Utility or Performance of Products

5. Impact of Any Lessening of Competition

6. Need of the Nation To Conserve Energy

7. Other Factors

8. Summary of Economic Impacts

C. Conclusion

1. Benefits and Burdens of TSLs Considered for Ceiling Fan Standards

2. Annualized Benefits and Costs of the Proposed Standards

D. Reporting, Certification, and Sampling Plan

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description of Reasons Why Action Is Being Considered

2. Objectives of, and Legal Basis for, Rule

3. Description on Estimated Number of Small Entities Regulated

4. Description and Estimate of Compliance Requirements Including Differences in Cost, if Any, for Different Groups of Small Entities

5. Duplication, Overlap, and Conflict With Other Rules and Regulations

6. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Information Quality

VII. 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

VIII. Approval of the Office of the Secretary

I. Synopsis of the Proposed Rule

The Energy Policy and Conservation Act, Public Law 94-163, 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 B of EPCA
2

established the Energy Conservation Program for Consumer Products Other Than Automobiles. (42 U.S.C. 6291-6309) These products include ceiling fans, the subject of this proposed rulemaking.

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 B was redesignated Part A.

Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later than 6 years after issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a notice of proposed rulemaking (“NOPR”) including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6295(m))

In accordance with these and other statutory provisions discussed in this document, DOE proposes amended energy conservation standards for ceiling fans. The proposed standards, which are expressed in cubic feet per minute per watt (“CFM/W”) for standard and hugger ceiling fans and ceiling fan energy index (“CFEI”) for large-diameter ceiling fans (“LDCFs”) and high-speed belt-driven (“HSBD”) ceiling fans, are shown in Table I.1. These proposed standards, if adopted, would apply to all ceiling fans listed in Table I.1 manufactured in, or imported into, the United States starting on the date 3 years after the publication of the final rule for this proposed rulemaking.

Table I.1—Proposed Energy Conservation Standards for Ceiling Fans

Equipment class
CFM/W

Standard Ceiling Fans *

D ≤53 in.: 0.69 D + 53.25.
D >53 in.: 1.31 D + 52.08.

Hugger Ceiling Fans *

D ≤53 in.: 0.56 D + 48.75.
D >53 in.: 1.37 D + 38.5.

CFEI

Large-Diameter Ceiling Fans

1.22 at high speed.
1.31 at 40 percent speed or the nearest speed that is not less than 40 percent speed.

High-Speed Belt-Driven Ceiling Fans
1.89 at high speed.

* D is the representative value of blade span as determined in accordance with the DOE test procedure at appendix U to subpart B of 10 CFR part 430 and applicable sampling plans.

A. Benefits and Costs to Consumers

Table I.2 presents DOE's evaluation of the economic impacts of the proposed standards on consumers of ceiling fans, as measured by the average life-cycle cost (“LCC”) savings and the simple payback period (“PBP”).
3

The average LCC savings are positive for all product classes, and the PBP is less than the average lifetime of ceiling fans, which is estimated to be 14.6 years (see section IV.F.6 of this document).

3
The average LCC savings refer to consumers that are affected by a standard and are measured relative to the efficiency distribution in the no-new-standards case, which depicts the market in the compliance year in the absence of new or amended standards (see section IV.F.8 of this document). The simple PBP, which is designed to compare specific efficiency levels, is measured relative to the baseline product (see section IV.C of this document).

Table I.2—Impacts of Proposed Energy Conservation Standards on Consumers of Ceiling Fans
[TSL 3]

Ceiling fan class

Average
LCC savings
($2022)

Simple
payback
period
(years)

Standard
16.69
4.1

Hugger
5.14
6.6

HSBD
663.92
2.1

Large-Diameter
68.20
5.8

DOE's analysis of the impacts of the proposed standards on consumers is described in section IV.F of this document.

B. Impact on Manufacturers

The industry net present value (“INPV”) is the sum of the discounted cash flows to the industry from the base year through the end of the analysis period (2023-2057). Using a real discount rate of 7.4 percent, DOE estimates that the INPV for manufacturers of ceiling fans in the case without new and amended standards is $2,329 million in 2022$. Under the proposed standards, the change in INPV is estimated to range from −4.4 percent to −1.8 percent, which is approximately −$101 million to −$43 million. In order to bring products into compliance with new and amended standards, it is estimated that the industry would incur total conversion costs of $107.2 million.

DOE's analysis of the impacts of the proposed standards on manufacturers is described in section IV.J of this document. The analytic results of the manufacturer impact analysis (“MIA”) are presented in section V.B.2 of this document.

C. National Benefits and Costs
4

4
All monetary values in this document are expressed in 2022 dollars.

DOE's analyses indicate that the proposed energy conservation standards for ceiling fans would save a significant amount of energy. Relative to the case without new and amended standards, the lifetime energy savings for ceiling fans purchased in the 30-year period that begins in the anticipated first full year of compliance with the new and amended standards (2028-2057) amount to 0.92 quadrillion British thermal units (“Btu”), or quads,
5

of full-fuel-cycle energy savings. This represents a savings of 9 percent relative to the energy use of these products in the case without new and amended standards (referred to as the “no-new-standards case”).

5
The quantity refers to full-fuel-cycle (“FFC”) energy savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and, thus, presents a more complete picture of the impacts of energy efficiency standards. For more information on the FFC metric, see section IV.H.1 of this document.

The cumulative net present value (“NPV”) of total consumer benefits of the proposed standards for ceiling fans ranges from 1.84 billion USD (at a 7-percent discount rate) to 4.96 billion USD (at a 3-percent discount rate). This NPV expresses the estimated total value of future operating-cost savings minus the estimated increased product costs for ceiling fans purchased in 2028-2057.

In addition, the proposed standards for ceiling fans are projected to yield significant environmental benefits. DOE estimates that the proposed standards would result in cumulative emission reductions (over the same period as for energy savings) of 18.3 million metric tons (“Mt”)
6

of carbon dioxide (“CO
2
”), 4.5 thousand tons of sulfur dioxide (“SO
2
”), 31.3 thousand tons of nitrogen oxides (“NO
X
”), 141 thousand tons of methane (“CH
4
”), 0.15 thousand tons of nitrous oxide (“N
2
O”), and 0.03 tons of mercury (“Hg”).
7

6
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
are presented in short tons.

7
DOE calculated emissions reductions relative to the no-new-standards case, which reflects key assumptions in the
Annual Energy Outlook 2023
(“
AEO 2023
”). AEO 2023 represents current Federal and state legislation and final implementation of regulations as of the time of its preparation. See section IV.K of this document for further discussion of AEO 2023 assumptions that effect air pollutant emissions.

DOE estimates the value of climate benefits from a reduction in greenhouse gases (GHG) using four different estimates of the social cost of CO
2
(“SC-CO
2
”), the social cost of methane (“SC-CH
4
”), and the social cost of nitrous oxide (“SC-N
2
O”). Together these represent the social cost of GHG (SC-GHG). DOE used interim SC-GHG values developed by an Interagency Working Group on the Social Cost of Greenhouse Gases (IWG).
8

The

derivation of these values is discussed in section IV.L of this document. For presentational purposes, the climate benefits associated with the average SC-GHG at a 3-percent discount rate are estimated to be $0.95 billion. DOE does not have a single central SC-GHG point estimate and it emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates.

8
To monetize the benefits of reducing GHG emissions this analysis uses the interim estimates presented in the Technical Support Document:

Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 published in February 2021 by the IWG. (“February 2021 SC-GHG TSD”). www.whitehouse.gov/wp-content/uploads/2021/02/

TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.

DOE estimated the monetary health benefits of SO
2
and NO
X
emissions reductions using benefit per ton estimates from the scientific literature, as discussed in section IV.L of this document. DOE estimated the present value of the health benefits would be $0.6 billion using a 7-percent discount rate, and $1.7 billion using a 3-percent discount rate.
9

DOE is currently only monetizing (for SO
2
and NO
X
) PM
2.5
precursor health benefits and (for NO
X
) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions.

9
DOE estimates the economic value of these emissions reductions resulting from the considered TSLs for the purpose of complying with the requirements of Executive Order 12866.

Table I.3 summarizes the monetized benefits and costs expected to result from the proposed standards for ceiling fans. There are other important unquantified effects, including certain unquantified climate benefits, unquantified public health benefits from the reduction of toxic air pollutants and other emissions, unquantified energy security benefits, and distributional effects, among others.

Table I.3—Summary of Monetized Benefits and Costs of Proposed Energy Conservation Standards for Ceiling Fans
[TSL 3]

Billion 2022$

3% discount rate

Consumer Operating Cost Savings
6.43

Climate Benefits *
0.95

Health Benefits **
1.70

Total Benefits †
9.08

Consumer Incremental Product Costs
1.47

Net Benefits
7.61

7% discount rate

Consumer Operating Cost Savings
2.66

Climate Benefits * (3% discount rate)
0.95

Health Benefits **
0.64

Total Benefits †
4.25

Consumer Incremental Product Costs
0.82

Net Benefits
3.43

Note:
This table presents the costs and benefits associated with ceiling fans shipped in 2028-2057. These results include benefits to consumers which accrue after 2028 from the products shipped in 2028-2057.

* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO
2
), methane (SC-CH
4
), and nitrous oxide (SC-N
2
O) (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate) (see section IV.L of this document). Together these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the
Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.

** Health benefits are calculated using benefit-per-ton values for NO
X
and SO
2
. DOE is currently only monetizing (for SO
2
and NO
X
) PM
2.5
precursor health benefits and (for NO
X
) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions. See section IV.L of this document for more details.

† Total and net benefits include those consumer, climate, and health benefits that can be quantified and monetized. For presentation purposes, total and net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate.

The benefits and costs of the proposed standards can also be expressed in terms of annualized values. The monetary values for the total annualized net benefits are (1) the reduced consumer operating costs, minus (2) the increase in product purchase prices and installation costs, plus (3) the monetized value of climate and health benefits of emission reductions, all annualized.
10

10
To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2023, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE calculated a present value associated with each year's shipments in the year in which the shipments occur, and then discounted the present value from each year to 2023. Using the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in the compliance year, that yields the same present value.

The national operating cost savings are domestic private U.S. consumer monetary savings that occur as a result of purchasing the covered products and are measured for the lifetime of ceiling fans shipped in 2028-2057. The benefits associated with reduced emissions achieved as a result of the proposed standards are also calculated based on the lifetime of ceiling fans shipped in 2028-2057. Total benefits for both the 3-percent and 7-percent cases are presented using the average GHG social costs with 3-percent discount rate. Estimates of SC-GHG values are presented for all four discount rates in section IV.L.1 of this document.

Table I.4 presents the total estimated monetized benefits and costs associated with the proposed standard, expressed in terms of annualized values. The results under the primary estimate are as follows.

Using a 7-percent discount rate for consumer benefits and costs and health benefits from reduced NO
X
and SO
2
emissions, and the 3-percent discount rate case for climate benefits from reduced GHG emissions, the estimated monetized cost of the standards proposed in this rule is $86.6 million per year in increased equipment costs, while the estimated annual benefits are $281.1 million in reduced equipment operating costs, $54.7 million in monetized climate benefits, and $67.5 million in monetized health benefits. In this case the net monetized benefit would amount to $316.7 million per year.

Using a 3-percent discount rate for all benefits and costs, the estimated monetized cost of the proposed standards is $84.6 million per year in increased equipment costs, while the estimated annual benefits are $369.3 million in reduced operating costs, $54.7 million in monetized climate benefits, and $97.5 million in monetized health benefits. In this case, the net monetized benefit would amount to $436.9 million per year.

Table I.4—Annualized Benefits and Costs of Proposed Energy Conservation Standards for Ceiling Fans
[TSL 3]

Million 2022$/year

Primary
estimate

Low-net-
benefits
estimate

High-net-
benefits
estimate

3% discount rate

Consumer Operating Cost Savings
369.3
343.9
387.6

Climate Benefits *
54.7
52.4
55.5

Health Benefits **
97.5
93.6
98.9

Total Monetized Benefits †
521.4
489.9
542.1

Consumer Incremental Product Costs
84.6
85.8
81.3

Net Benefits
436.9
404.1
460.7

7% discount rate

Consumer Operating Cost Savings
281.1
263.2
294.3

Climate Benefits * (3% discount rate)
54.7
52.4
55.5

Health Benefits **
67.5
65.1
68.5

Total Monetized Benefits †
403.3
380.7
418.3

Consumer Incremental Product Costs
86.6
87.7
83.6

Net Monetized Benefits
316.7
293.0
334.7

Note:
This table presents the costs and benefits associated with ceiling fans shipped in 2028-2057. These results include benefits to consumers which accrue after 2057 from the products shipped in 2028-2057. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the AEO 2023 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. The methods used to derive projected price trends are explained in sections IV.F.1 and IV.H.2 of this document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.

* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this notice). For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown; however, DOE emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. To monetize the benefits of reducing GHG emissions, this analysis uses the interim estimates presented in the
Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990
published in February 2021 by the IWG.

** Health benefits are calculated using benefit-per-ton values for NO
X
and SO
2
. DOE is currently only monetizing (for SO
2
and NO
X
) PM
2.5
precursor health benefits and (for NO
X
) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions. See section IV.L of this document for more details.

† Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate.

DOE's analysis of the national impacts of the proposed standards is described in sections IV.H, IV.K and IV.L of this document.

D. Conclusion

DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. Specifically, with regards to technological feasibility products achieving these standard levels are already commercially available for all product classes covered by this proposal. As for economic justification, DOE's analysis shows that the benefits of the proposed standard exceed, to a great extent, the burdens of the proposed standards.

Using a 7-percent discount rate for consumer benefits and costs and NO
X
and SO
2
reduction benefits, and a 3-percent discount rate case for GHG social costs, the estimated monetized cost of the proposed standards for ceiling fans is $86.6 million per year in increased ceiling fan costs, while the estimated annual monetized benefits are $281.1 million in reduced ceiling fan operating costs, $54.7 million in monetized climate benefits and $67.5 million in monetized health benefits. The net monetized benefit amounts to $316.7 million per year.

The significance of energy savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking.
11

For example, some covered products and equipment have substantial energy consumption occur during periods of peak energy demand. The impacts of these products on the energy infrastructure can be more pronounced than products with relatively constant demand. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis.

11
Procedures, Interpretations, and Policies for Consideration in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment, 86 FR 70892, 70901 (Dec. 13, 2021).

As previously mentioned, the standards are projected to result in estimated national energy savings of 0.92 quad FFC for ceiling fans shipped between 2028 and 2057, the equivalent of the primary annual energy use of almost 10 million homes. In addition, they are projected to reduce CO
2
emissions by 18.3 million metric tons for ceiling fans shipped from 2028 to 2057.
12

Based on these findings, DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B). A more detailed discussion of the basis for these tentative conclusions is contained in the remainder of this document and the accompanying technical support document.

12
These results include benefits to consumers which accrue after 2057 from the products shipped in 2028-2057.

DOE also considered more-stringent energy efficiency levels as potential

standards, and is still considering them in this rulemaking. However, DOE has tentatively concluded that the potential burdens of the more-stringent energy efficiency levels would outweigh the projected benefits.

Based on consideration of the public comments DOE receives in response to this document and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy efficiency levels presented in this document that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.

II. Introduction

The following section briefly discusses the statutory authority underlying this proposed rule, as well as some of the relevant historical background related to the establishment of standards for ceiling fans.

A. Authority

EPCA authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. Title III, Part B of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles. These products include ceiling fans, the subject of this document. (42 U.S.C. 6292(a)(20)) This NOPR covers those consumer products that meet the definition of “ceiling fans” codified at 10 CFR 430.2 as nonportable devices suspended from a ceiling for circulating air via the rotation of fan blades. EPCA, as amended, prescribed energy conservation standards for these products and authorized DOE to consider energy efficiency or energy use standards for the electricity used by ceiling fan to circulate air in a room.
13

(42 U.S.C. 6295(ff)(6))

13
While ceiling fans are often sold with light kits, this notice only considers the electricity used by ceiling fans to circulate air in a room. DOE evaluates energy efficiency standards associated with ceiling fan light kits in a separate rulemaking (Docket No. EERE-2019-BT-STD-0040).

EPCA further provides that, not later than 6 years after the issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a NOPR including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6295(m)(1))

The energy conservation program under EPCA consists essentially of four parts: (1) testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA specifically include definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293), labeling provisions (42 U.S.C. 6294), energy conservation standards (42 U.S.C. 6295), and the authority to require information and reports from manufacturers (42 U.S.C. 6296).

Federal energy efficiency requirements for covered products established under EPCA generally supersede State laws and regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of Federal preemption for particular State laws or regulations, in accordance with the procedures and other provisions set forth under EPCA. (See 42 U.S.C. 6297(d))

Subject to certain criteria and conditions, DOE is required to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of each covered product. (42 U.S.C. 6295(o)(3)(A) and 42 U.S.C. 6295(r)) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 42 U.S.C. 6295(s)) Similarly, DOE must use these test procedures to determine whether the products comply with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) The DOE test procedures for ceiling fans appear at title 10 of the Code of Federal Regulations (“CFR”) part 430, subpart B, appendix U.

DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including ceiling fans. Any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that the Secretary of Energy determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(3)(B)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3))

Moreover, DOE may not prescribe a standard: (1) for certain products, including ceiling fans, if no test procedure has been established for the product, or (2) if DOE determines by rule that the standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:

(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;

(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;

(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;

(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;

(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;

(6) The need for national energy and water conservation; and

(7) Other factors the Secretary of Energy (“Secretary”) considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))

Further, EPCA establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. (42 U.S.C. 6295(o)(2)(B)(iii))

EPCA also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States in any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those

generally available in the United States. (42 U.S.C. 6295(o)(4))

Additionally, EPCA specifies requirements when promulgating an energy conservation standard for a covered product that has two or more subcategories. DOE must specify a different standard level for a type or class of product that has the same function or intended use, if DOE determines that products within such group: (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))

Finally, pursuant to the amendments contained in the Energy Independence and Security Act of 2007 (“EISA 2007”), Pub. L. 110-140, any final rule for new or amended energy conservation standards promulgated after July 1, 2010, is required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into a single standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE's current test procedures for ceiling fans does address measuring standby mode and off mode energy use. In this rulemaking, for small-diameter ceiling fans
14

DOE intends to incorporate such energy use into any amended energy conservation standards that it may adopt. For LDCFs
15

and HSBD ceiling fans, DOE has determined that incorporating this energy use into a single standard and establishing a separate standard is not justified under 42 U.S.C. 6295(o).

14
A small-diameter ceiling fan is a ceiling fan that is less than or equal to seven feet in diameter. 10 CFR part 430 subpart B appendix U section 1.18.

15
A large-diameter ceiling fan is a ceiling fan that is greater than seven feet in diameter. 10 CFR part 430 subpart B appendix U section 1.12.

B. Background

1. Current Standards

In a final rule published on October 18, 2005, DOE codified the design standards prescribed by EPCA for ceiling fans. 70 FR 60407, 60413. These standards are set forth in DOE's regulations at 10 CFR 430.32(s)(1) and require all ceiling fans manufactured on or after January 1, 2007, to have: (1) fan speed controls separate from any lighting controls; (2) adjustable speed controls (either more than one speed or variable speed); and (3) the capability for reverse action (other than fans sold for industrial or outdoor application or where safety would be an issue). (42 U.S.C. 6295(ff)(1)(A))

In a final rule published on January 19, 2017, (“January 2017 ECS Final Rule”), DOE prescribed the current energy conservation standards for ceiling fans manufactured in, or imported into, the United States on and after January 21, 2020. 82 FR 6826, 6827.

On December 27, 2020, the Energy Act of 2020 (Pub. L. 116-260) was signed into law. The Energy Act of 2020 amended performance standards for LDCFs. (42 U.S.C. 6295(ff)(6)(C)(i), as codified) Pursuant to the Energy Act of 2020, LDCFs are subject to standards in terms of the CFEI metric, with one standard based on operation of the fan at high speed and a second standard based on operation of the fan at 40 percent speed or the nearest speed that is not less than 40 percent speed. (42 U.S.C. 6295(ff)(6)(C)(i), as codified)

On May 27, 2021, DOE published a final rule to amend the current regulations for LDCFs (“May 2021 Technical Amendment”). 86 FR 28469. The May 2021 Technical Amendment was published to codify provisions enacted by Congress through the Energy Act of 2020. Specifically, section 1008 of the Energy Act of 2020 amended section 325(ff)(6) of EPCA to specify that LDCFs manufactured on or after January 21, 2020, are not required to meet minimum ceiling fan efficiency requirements in terms of the ratio of the total airflow to the total power consumption, as established in the January 2017 ECS Final Rule, and instead are required to meet specified minimum efficiency requirements based on the CFEI metric. 86 FR 28469, 28469-28470. On November 28, 2022, DOE also published a final rule to implement the full scope of standards for LDCFs as set forth in the Energy Act of 2020. 86 FR 72863.

The current standards are set forth in DOE's regulations at 10 CFR 430.32(s) and are summarized in Table II.1.

Table II.1—Current Federal Energy Conservation Standards for Ceiling Fans

Product class as
defined in appendix U [of 10 CFR 430.32(s)]

Minimum efficiency

(CFM/W)
1

Very small diameter (VSD)
D ≤12 in.: 21.

D >12 in.: 3.16D-17.04.

Standard
0.65D + 38.03.

Hugger
0.29D + 34.46.

High-speed small diameter (HSSD)
4.16D + 0.02.

Minimum Efficiency (CFEI)

Large-diameter ceiling fans (LDCFs)

1.00 at high speed.
1.31 at 40 percent speed or the nearest speed that is not less than 40 percent speed.

1
D is the ceiling fan's blade span, in inches, as determined in Appendix U of [10 CFR 430.32(s)].

2. History of Standards Rulemaking for Ceiling Fans

On May 7, 2021, DOE published a notice that it was initiating an early assessment review to determine whether any new or amended standards would satisfy the relevant requirements of EPCA for a new or amended energy conservation standard for ceiling fans and a request for information (“RFI”). 86 FR 24538 (“May 2021 RFI”).

On February 10, 2022, DOE published a notice of public webinar and availability of preliminary technical support document (“TSD”). 87 FR 7758 (“February 2022 Preliminary Analysis”). The purpose of the February 2022 Preliminary Analysis was to make publicly available the initial technical and economic analyses conducted for ceiling fans and present initial results of those analyses. DOE held the public webinar on March 16, 2022, to present its preliminary analysis and to seek comments from interested parties.

DOE received comments in response to the February 2022 Preliminary Analysis from the interested parties listed in Table II.2.

Table II.2—February 2022 Preliminary Analysis Written Comments

Commenter(s)
Abbreviation
Comment number in the docket
Commenter type

American Lighting Association
ALA
26
Trade Association.

Air Movement and Control Association
AMCA
23
Trade Association.

Pacific Gas and Electric Company, Southern California Edison, San Diego Gas & Electric Company
CA IOUs
22
Utilities.

Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, Natural Resources Defense Council, New York State Energy Research and Development Authority
Efficiency Advocates
25
Efficiency Organizations.

Lutron Electronics Co.
Lutron
24
Controller Manufacturer.

Northwest Energy Efficiency Alliance
NEEA
27
Efficiency Organization.

A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.
16

To the extent that interested parties have provided written comments that are substantively consistent with any oral comments provided during the March 2022 public meeting, DOE cites the written comments throughout this document. Any oral comments provided during the webinar that are not substantively addressed by written comments are summarized and cited separately throughout this document.

16
The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop energy conservation standards for ceiling fans. (Docket No. EERE-2021-BT-STD-0011, which is maintained at
www.regulations.gov
). The references are arranged as follows: (commenter name, comment docket ID number, page of that document).

C. Deviation From Appendix A

In accordance with section 3(a) of 10 CFR part 430, subpart C, appendix A (“appendix A”), DOE notes that it is deviating from the provision in appendix A regarding the NOPR stage for an energy conservation standard rulemaking. Section 6(f)(2) of appendix A specifies that the length of the public comment period for a NOPR will vary depending upon the circumstances of the particular rulemaking, but will not be less than 75 calendar days. DOE is opting to deviate from this step by providing a 60-day comment period. As previously discussed, DOE requested comment on its analytical approach in section ES.3 of the February 2022 Preliminary Analysis TSD and provided stakeholders with a 60-day comment period. Given that this NOPR relies largely on the same analytical approach taken in the February 2022 Preliminary Analysis, DOE believes a 60-day comment period is appropriate and will provide interested parties with a meaningful opportunity to comment on the proposed rule.

III. General Discussion

DOE developed this proposal after considering oral and written comments, data, and information from interested parties that represent a variety of interests. The following discussion addresses issues raised by these commenters.

A. General Comments

This section summarizes general comments received from interested parties regarding rulemaking timing and process.

NEEA commented generally that they support DOE's continued development of energy conservation standards and use of transparent and comparable efficiency metrics to encourage market adoption of efficient products. (NEEA, No. 27 at p. 1)

B. Product Classes and Scope of Coverage

When evaluating and establishing energy conservation standards, DOE divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justify differing standards. In determining whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility of the feature to the consumer and other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) This NOPR covers those consumer products that meet the definition of “ceiling fans,” as codified at 10 CFR 430.2. See section IV.A.1 of this document for discussion of the scope of coverage and product classes analyzed in this NOPR.

C. Test Procedure

EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with energy conservation standards and to quantify the efficiency of their product. DOE's current energy conservation standards for ceiling fans are expressed in terms of CFM/W and CFEI. (
See
10 CFR 430.32(s)(2).)

D. Technological Feasibility

1. General

In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially-available products or in working prototypes to be technologically feasible. Sections 6(b)(3)(i) and 7(b)(1) of appendix A to 10 CFR part 430 subpart C (“Process Rule”).

After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) practicability to manufacture, install, and service; (2) adverse impacts on product utility or availability; (3) adverse impacts on health or safety, and (4) unique-pathway proprietary technologies. Sections 6(b)(3)(ii)-(v) and 7(b)(2)-(5) of the Process Rule. Section IV.B of this document discusses the results of the screening analysis for ceiling fans,

particularly the designs DOE considered, those it screened out, and those that are the basis for the standards considered in this proposed rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the NOPR technical support document (“TSD”).

2. Maximum Technologically Feasible Levels

When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for ceiling fans, using the design parameters for the most efficient products available on the market or in working prototypes. The max-tech levels that DOE determined for this rulemaking are described in section IV.C of this proposed rule and in chapter 5 of the NOPR TSD.

E. Energy Savings

1. Determination of Savings

For each trial standard level (“TSL”), DOE projected energy savings from application of the TSL to ceiling fans purchased in the 30-year period that begins in the first full year of compliance with the proposed standards (2028-2057).
17

The savings are measured over the entire lifetime of ceiling fans purchased in the previous 30-year period. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-new-standards case. The no-new-standards case represents a projection of energy consumption that reflects how the market for a product would likely evolve in the absence of amended energy conservation standards.

17
Each TSL is composed of specific efficiency levels for each product class. The TSLs considered for this NOPR are described in section V.A of this document. DOE conducted a sensitivity analysis that considers impacts for products shipped in a 9-year period.

DOE used its national impact analysis (“NIA”) python programming language model to estimate national energy savings (“NES”) from potential amended or new standards for ceiling fans. The NIA python programming language model (described in section IV.H of this document) calculates energy savings in terms of site energy, which is the energy directly consumed by products at the locations where they are used. For electricity, DOE reports national energy savings in terms of primary energy savings, which is the savings in the energy that is used to generate and transmit the site electricity. DOE also calculates NES in terms of FFC energy savings. The FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards.
18

DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered products or equipment. For more information on FFC energy savings, see section IV.H.1 of this document.

18
The FFC metric is discussed in DOE's statement of policy and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as amended at 77 FR 49701 (Aug. 17, 2012).

2. Significance of Savings

To adopt any new or amended standards for a covered product, DOE must determine that such action would result in significant energy savings. (42 U.S.C. 6295(o)(3)(B))

The significance of energy savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking.
19

For example, some covered products and equipment have most of their energy consumption occur during periods of peak energy demand. The impacts of these products on the energy infrastructure can be more pronounced than products with relatively constant demand. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis, taking into account the significance of cumulative FFC national energy savings, the cumulative FFC emissions reductions, and the need to confront the global climate crisis, among other factors. DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B).

19
The numeric threshold for determining the significance of energy savings established in a final rule published on February 14, 2020 (85 FR 8626, 8670), was subsequently eliminated in a final rule published on December 13, 2021 (86 FR 70892).

F. Economic Justification

1. Specific Criteria

As noted previously, EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) The following sections discuss how DOE has addressed each of those seven factors in this proposed rulemaking.

a. Economic Impact on Manufacturers and Consumers

In determining the impacts of a potential amended standard on manufacturers, DOE conducts an MIA, as discussed in section IV.J of this document. DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include (1) INPV, which values the industry on the basis of expected future cash flows, (2) cash flows by year, (3) changes in revenue and income, and (4) other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.

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

b. Savings in Operating Costs Compared To Increase in Price (LCC and PBP)

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

The LCC is the sum of the purchase price of a product (including its

installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. The LCC analysis requires a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and discount rates appropriate for consumers. To account for uncertainty and variability in specific inputs, such as product lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value.

The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of a more-efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost due to a more-stringent standard by the change in annual operating cost for the year that standards are assumed to take effect.

For its LCC and PBP analysis, DOE assumes that consumers will purchase the covered products in the first full year of compliance with new or amended standards. The LCC savings for the considered efficiency levels are calculated relative to the case that reflects projected market trends in the absence of new or amended standards. DOE's LCC and PBP analysis is discussed in further detail in section IV.F of this document.

c. Energy Savings

Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section III.D of this document, DOE uses the NIA python programming language model to project national energy savings.

d. Lessening of Utility or Performance of Products

In establishing product classes and in evaluating design options and the impact of potential standard levels, DOE evaluates potential standards that would not lessen the utility or performance of the considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards proposed in this document would not reduce the utility or performance of the products under consideration in this proposed rulemaking.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed rule to the Attorney General with a request that the Department of Justice (“DOJ”) provide its determination on this issue. DOE will publish and respond to the Attorney General's determination in the final rule. DOE invites comment from the public regarding the competitive impacts that are likely to result from this proposed rule. In addition, stakeholders may also provide comments separately to DOJ regarding these potential impacts. See the
ADDRESSES
section for information to send comments to DOJ.

f. Need for National Energy Conservation

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

DOE maintains that environmental and public health benefits associated with the more efficient use of energy are important to take into account when considering the need for national energy conservation. The proposed standards are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases (“GHGs”) associated with energy production and use. DOE conducts an emissions analysis to estimate how potential standards may affect these emissions, as discussed in section IV.K of this document; the estimated emissions impacts are reported in section V.B.6 of this document. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section IV.L of this document.

g. Other Factors

In determining whether an energy conservation standard is economically justified, DOE may consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent DOE identifies any relevant information regarding economic justification that does not fit into the other categories described previously, DOE could consider such information under “other factors.”

2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values used to calculate the effects that proposed energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the Nation, and the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable presumption payback calculation is discussed in section V.B.1.c of this proposed rule.

IV. Methodology and Discussion of Related Comments

This section addresses the analyses DOE has performed for this rulemaking with regard to ceiling fans. Separate subsections address each component of DOE's analyses.

DOE used several analytical tools to estimate the impact of the standards proposed in this document. The first tool is a spreadsheet that calculates the LCC savings and PBP of potential

amended or new energy conservation standards. The national impacts analysis uses a second spreadsheet set that provides shipments projections and calculates national energy savings and net present value of total consumer costs and savings expected to result from potential energy conservation standards. DOE uses the third spreadsheet tool, the Government Regulatory Impact Model (“GRIM”), to assess manufacturer impacts of potential standards. These three spreadsheet tools are available on the DOE website for this rulemaking
: www.regulations.gov/docket/EERE-2021-BT-STD-0011.
Additionally, DOE used output from the latest version of the Energy Information Administration's (“EIA's”)
Annual Energy Outlook
(“
AEO
”), a widely known energy projection for the United States, for the emissions and utility impact analyses.

A. Market and Technology Assessment

DOE develops information in the market and technology assessment that provides an overall picture of the market for the products concerned, including the purpose of the products, the industry structure, manufacturers, market characteristics, and technologies used in the products. This activity includes both quantitative and qualitative assessments, based primarily on publicly-available information. The subjects addressed in the market and technology assessment for this rulemaking include (1) a determination of the scope of the rulemaking and product classes, (2) manufacturers and industry structure, (3) existing efficiency programs, (4) shipments information, (5) market and industry trends; and (6) technologies or design options that could improve the energy efficiency of ceiling fans. The key findings of DOE's market assessment are summarized in the following sections. See chapter 3 of the NOPR TSD for further discussion of the market and technology assessment.

1. Product Classes

When evaluating and establishing energy conservation standards, DOE may establish separate standards for a group of covered products (
i.e.,
establish a separate product class) if DOE determines that separate standards are justified based on the type of energy used, or if DOE determines that a product's capacity or other performance-related feature justifies a different standard. (42 U.S.C. 6295(q)) In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility of the feature to the consumer and other factors DOE determines are appropriate. (
Id.
)

DOE currently defines separate energy conservation standards for the following ceiling fan product classes: hugger, standard, very small diameter (“VSD”), high-speed small diameter (“HSSD”), and LDCF. 10 CFR 430.32(s)(2).

In section 2.2 of the February 2022 Preliminary Analysis TSD, DOE requested comment on VSD ceiling fans, HSBD ceiling fans, high- and low-airflow LDCFs, and very-close mount hugger ceiling fans. These comments are discussed in detail as follows:

a. Very Small Diameter Ceiling Fans

A VSD ceiling fan is defined as a small-diameter ceiling fan less than or equal to 18 inches. Appendix U to subpart B of part 430 (“appendix U”). On August 16, 2022, DOE published a test procedure final rule for ceiling fans (“August 2022 TP Final Rule”). 87 FR 50396. The August 2022 TP Final Rule amended the definition of ceiling fan to clarify that a ceiling fan must provide circulating air, and clarified that “a ceiling fan that has a ratio of fan blade span (in inches) to maximum rotation rate (in revolutions per minute) greater than 0.06 provides circulating air.”
Id.
at 87 FR 50402.

DOE included VSD fans in the February 2022 Preliminary Analysis, but in section 2.2.1 of the preliminary analysis TSD stated that all VSD fans DOE was aware of had a diameter-to-maximum operating speed ratio of less than or equal to 0.06 inches to revolutions per minute (“in/RPM”). Therefore, with the amended definition of “circulating air”, DOE expected that there would no longer be any ceiling fans on the market that would meet the definition of a VSD ceiling fan. In the February 2022 Preliminary Analysis, DOE requested comment on its observation that all VSD ceiling fans would have a diameter-to-maximum operating speed ratio of less than or equal to 0.06 in/RPM.

In response, ALA supported delineating air circulating fan heads from ceiling fans using the 0.06 ratio, and provided data that shows a distinct difference in the ratio for air circulating fan heads and ceiling fans. (ALA, No. 26 at p. 7) The Efficiency Advocates encouraged DOE to cover VSD ceiling fans in the fans and blowers rulemaking. (Efficiency Advocates, No. 25 at p. 3)

DOE notes that comments related to scope and definitions for fans and blowers are available at Docket No. EERE-2021-BT-TP-0021. DOE did not receive any comments identifying VSD fans that exceed the 0.06 ratio. Further, DOE notes that the maximum diameter for a VSD fan is 18 inches. Based on the 0.06 ratio, a VSD fan would have to operate at a maximum of 300 rpm to meet the definition of circulating air and therefore meet the definition of a ceiling fan. Most fans with blade spans 18 inches or less on the market advertise blade speeds greater than 1,000 rpm.

In theory, a ceiling fan could exist that meets the definition of both circulating air and VSD ceiling fan. In that case, the DOE test procedure at appendix U to subpart B of part 430 would be applicable, and the current energy conservation standards for VSD ceiling fans at 10 CFR 430.32(s)(2) would apply. However, DOE does not expect fans to enter the market that meet the definition of both ceiling fan and VSD ceiling fan because a fan with a blade span of 18 inches or less spinning at fewer than 300 rpm would provide limiting cooling utility for consumers. As such, for this NOPR, DOE has assumed that VSD ceiling fan shipments are zero, and has not evaluated amended energy conservation standards for VSD ceiling fans.

DOE requests comment on its assumption that there are zero products on the market that meet the definition of both ceiling fan and VSD ceiling fan, and its decision not to evaluate amended energy conservation standards for VSD ceiling fans on that basis.

b. High-Speed Belt-Driven Ceiling Fans

Belt-driven ceiling fans are defined as “a ceiling fan with a series of one or more fan heads, each driven by a belt connected to one or more motors that are located outside of the fan head.” Appendix U to subpart B of part 430. On July 25, 2016, DOE published a test procedure final rule (“July 2016 TP Final Rule”), in which it stated it would not propose standards for belt-driven ceiling fans due to the limited number of basic models and lack of available data. 81 FR 48619, 48622. In the January 2017 ECS Final Rule, DOE noted that belt-driven ceiling fans were generally highly customizable, and that customers can decide on the number of fan heads, distance from the motor to the fan head, and type of belt. (See chapter 3 of the January 2017 ECS Final Rule TSD). While DOE did establish a definition and product class, belt-driven ceiling fans were exempt from the test procedure, and energy conservation standards were therefore not established. 81 FR 48619, 48622, 48624.

In response to the May 2021 RFI, BAF
20

and AMCA commented that a new type of belt-driven ceiling fan that

uses a larger motor and higher tip speeds has recently entered the market. (BAF, No. 14 at p. 2; AMCA, No. 9 at p. 4) BAF and AMCA recommended that DOE create a high-speed product class and a low-speed product class for these belt-driven ceiling fans.
Id.
BAF and AMCA additionally suggested that the HSBD ceiling fans be subject to testing according to the American National Standards Institute (“ANSI”)/AMCA Standard 230-15 “Laboratory Methods of Testing Air Circulating Fans for Rating and Certification” (“AMCA 230-15”).
Id.
BAF also recommended that HSBD ceiling fans be subject to energy conservation standards, but that low-speed belt-driven ceiling fans should be exempted. (BAF, No. 14 at p. 2) The CA IOUs identified one of these HSBD ceiling fans (drum-type circulating ceiling fan) and asked DOE to clarify whether industrial belt-driven fans are covered as ceiling fans or as fans and blowers. (CA IOUs, No. 12 at p. 4-5)

20
This notice uses BAF to refer to comments from Big Ass Fans, a manufacturer of ceiling fans.

In its August 2022 TP Final Rule, DOE defined HSBD ceiling fan, stated that these fans shall be tested according to AMCA 230-15, and stated that HSBD ceiling fans will use the CFEI metric. 87 FR 50396. DOE did not establish separate definitions for small- and large-diameter HSBD fans, but rather included all HSBD ceiling fans into one definition.
Id.
at 87 FR 50404. DOE notes that belt-driven ceiling fans that do not meet the definition of HSBD remain exempt from the DOE test procedure.
See
appendix U.

DOE notes that a ceiling fan must be “distributed in commerce with components that enable it to be suspended from a ceiling.” 87 FR 50396, 50402. Belt-driven fans are often distributed in commerce without components that enable the fan to be suspended from a ceiling. For example, some belt-driven fans are sold connected to wheels or to a pedestal base. In this case, such a fan would not meet the definition of a ceiling fan because it has not been manufactured to be suspended from the ceiling, and therefore would not be subject to the HSBD test procedure or any potential energy conservation standards even though a consumer could independently purchase their own straps or chains and elect to hang this fan from the ceiling.

HSBD fans in contrast, are distributed in commerce with specific straps, chains, or other similar components that are designed and tested by the manufacturer to safely support the weight of the ceiling fan in an overhead configuration. Further, they circulate air, since they meet the 0.06 blade span to maximum rpm ratio.

Many belt-driven fans are housed (meaning the fan blades are contained within a cylindrical enclosure, often with solid metal sides and a cage on the front and back); however, the presence of a housing is not relevant in determining whether a product meets the definition of ceiling fan. While a housing is generally included to better direct air, a housing could be added to a ceiling fan, including those that are clearly intended to circulate air. As such, DOE emphasizes that the definition of a ceiling fan requires that fan to be “suspended from a ceiling” and to “circulate air”, rather than the presence or absence of a fan housing.

In this NOPR, DOE has evaluated potential energy conservation standards for HSBD ceiling fans.

c. High- and Low-Airflow Large-Diameter Ceiling Fans

BAF and AMCA previously commented that two product classes, separated based on airflow, may be justified for LDCFs to reflect unique characteristics for products intended for commercial versus industrial applications. (BAF, No. 14 at p. 2; AMCA, No. 9 at p. 7). In response to these comments, DOE considered whether to establish separate high-airflow and low-airflow product classes for LDCFs in section 2.4.1.1 of its February 2022 Preliminary Analysis TSD.

In response, the CA IOUs, AMCA, and NEEA all commented that DOE should not divide the LDCF product class into separate high- and low-airflow classes because doing so would not provide any benefit or be warranted by differences in features or technology. (AMCA, No. 23 at pp. 2-4; NEEA, No. 27 at p. 2; CA IOUs, No. 22 at pp. 2-4) The CA IOUs provided results from a study they conducted that analyzed the performance data of 90 AMCA-certified LDCFs. (CA IOUs, No. 22 at pp. 2-4) The results showed that 66 percent of fans were included in the low-airflow class and that many were near the airflow cutoff between the two classes that DOE defined in the February 2022 Preliminary Analysis.
Id.
They noted that slight changes in fan speed could therefore cause a fan to move from one class into another.
Id.
The CA IOUs suggested that the similarity in the airflow data therefore indicated that it is unnecessary to separate low- and higher-airflow fans, and that if different energy conservation standards were used for the two classes it could result in market distortion.
Id.
Additionally, the results also showed that commercial LDCFs generally had a higher CFEI than industrial LDCFs, which the CA IOUs attributed to commercial LDCFs often using more efficient motors. They stated that these results also indicate that airflow is not a driver of efficiency for LDCFs.
Id.

To establish a separate product class, DOE must determine that a product has a capacity or other performance-related feature which other covered products do not have, and that such feature justifies a different standard through the feature's utility to the consumer and other factors. (42 U.S.C. 6295(q)) DOE reviewed the data provided by the CA IOUs and manufacturer literature and found that while some fans are marketed for lower airflow and commercial applications, and that others are marketed for higher-airflow, DOE agrees with commenters that there is not a clear performance-related distinction between the two. Therefore, DOE did not evaluate low- and high-airflow LDCFs as separate product classes in this analysis.

d. Very-Close Mount Hugger Ceiling Fans

Hugger ceiling fans offer consumer utility since they have less distance between the ceiling fan blades and the ceiling. This allows them to be installed in applications with lower ceilings, where a standard ceiling fan with a down rod could be a safety issue or would not be desirable to consumers.

In section 2.4.1.1 of the February 2022 Preliminary Analysis TSD, DOE discussed that moving a hugger fan further from the ceiling could increase airflow without an associated increase in power consumption, although this would be at the expense of consumer preferences for a very-close mounted fan. DOE requested comment on whether consumers consider all hugger ceiling fans equal, or if there is additional consumer utility associated with hugger fans that are closer to the ceiling.

ALA commented that there is no additional utility associated with hugger fans that are closer to the ceiling and encouraged DOE to maintain only one product class for hugger ceiling fans as doing so would avoid the need for additional testing. (ALA, No. 26 at p. 9) DOE did not receive any comment suggesting that very-close mount hugger fans warranted a separate equipment class.

In this NOPR, DOE did not further evaluate a separate product class for ceiling fans that are closer to the ceiling. However, DOE did modify its engineering analysis for hugger ceiling fans to reflect that moving a hugger fan further from the ceiling (although still less than or equal to 10 inches from the

ceiling) represents a possible path toward meeting higher efficiency standards. This is discussed in greater detail in section IV.C of this document.

2. Test Procedure and Certification

DOE's test procedure for measuring the energy efficiency of ceiling fans is available at appendix U and requirements for certification in DOE's compliance certification database (“CCD”) specific to ceiling fans are provided at 10 CFR 429.32. In section 2.3 of the February 2022 Preliminary Analysis TSD, DOE stated that proposed rules had been issued to amend both the ceiling fan test procedure and ceiling fan certification requirements. Since the February 2022 Preliminary Analysis, the August 2022 TP Final Rule (87 FR 50396) and a certification Final Rule (“July 2022 Certification Final Rule”) (87 FR 43952) have published, and updates were included in their respective sections of the CFR.

In response to the February 2022 Preliminary Analysis, stakeholders commented on test procedure and certification issues. These comments are summarized and addressed as follows.

Regarding the test procedure for LDCFs, NEEA commented that they generally support use of the CFEI metric for LDCFs. (NEEA, No. 27 at pp. 1-2) AMCA recommended that DOE define a minimum testable configuration for LDCFs that specifies which components and accessories should and should not be included for testing. (AMCA, No. 23 at p. 9) Additionally, AMCA recommended that, for a minimum LDCF testable configuration, the fan should be tested as a complete fan with a single-fan controller and that any optional features that do not relate to air movement should not be energized during testing. (AMCA, No. 23 at p. 9)

Regarding AMCA's suggestion to test ceiling fans without including additional accessories and in a minimum testable configuration, DOE notes that appendix U requires that additional accessories not related to ceiling fan airflow be turned off during testing and that testing shall be completed with the default or minimally functional controller. Specifically, section 3.3.1 of appendix U lists specifications for testing with additional accessories for standard and hugger fans and section 3.5.1 of appendix U lists specifications for testing with additional accessories for LDCFs and HSBD fans.

AMCA also commented that additional parameters, like blade span, CFEI100, CFEI40, airflow at high speed, and airflow at 40 percent speed, should be included in the reporting requirements for the CCD so that the data can be used in the next rulemaking to adjust CFEI ratings and standby power requirements. AMCA added that standby power should also be reported for compliance filing. AMCA further stated that adding these reporting requirements would not create an additional burden on manufacturers because the additional data being reported would come directly from the test report that is already produced for DOE compliance testing. (AMCA, No. 23 at pp. 3, 7)

Regarding compliance with existing energy conservation standards, AMCA commented that, based on an internet market survey they conducted, they believe many LDCFs on the market are not currently registered in DOE's CCD. AMCA estimated that less than half of the LDCF models available for sale in the United States were certified to DOE and that only 7 of the 23 LDCF manufacturers/importers they identified had registered products in the CCD. (AMCA, No. 23 at pp. 7, 14-15) Additionally, AMCA commented that some of the published performance data for fan models identified in their internet market survey may be physically impossible. (AMCA, No. 23 at pp. 14-15; Ivanovich, Public Meeting Transcript, No. 21 at p. 10)

AMCA expressed concern that increased standards would have a disproportionate impact on manufacturers that are certifying their fans and working to meet the energy conservation standards, and they encouraged DOE to enforce its standards across the ceiling fan industry. (AMCA, No. 23 at pp. 14-15; Ivanovich, Public Meeting Transcript, No. 21 at p. 10)

AMCA estimated that the performance of many products identified through their internet market survey but not registered in the CCD may be below the current energy conservation standards.
Id.
AMCA further stated that these unregistered products could muddy DOE's analysis by suggesting that the current energy conservation standards are being easily met. (AMCA, No. 23 at pp. 1-2,7) AMCA commented that current energy conservation standards were met through investment by manufacturers, and enacting higher efficiency standards today would penalize manufacturers that have invested to comply with current energy conservation standards while rewarding bad actors who never invested. (AMCA, No. 23 at p. 1,2)

Regarding ceiling fan certification requirements, DOE notes that the July 2022 Certification Final Rule amended 10 CFR 429.32 to require additional data submission at the time of certification for LDCFS, including blade span, CFEI40, and CFEI100, amongst other data. 87 FR 43952, 43964-66. Further, DOE notes that 10 CFR 429.12(a) specifies that “[e]ach manufacturer, before distributing in commerce any basic model of a covered product or covered equipment subject to an applicable energy conservation standard set forth in parts 430 or 431, and annually thereafter on or before the dates provided in paragraph (d) of this section, shall submit a certification report to DOE certifying that each basic model meets the applicable energy conservation standard(s).” 10 CFR 429.12(a). DOE's current energy conservation standards are listed at 10 CFR 430.32(s)(2) and are relevant to all ceiling fans manufactured on or after January 21, 2020. Consistent with 10 CFR parts 429 and 430, manufacturers are required to submit a certification report to DOE that their basic models meet the relevant energy conservation standards at10 CFR 430.32(s)(2) along with the additional information as required in 10 CFR 429.32.

Regarding the sampling requirements when testing LDCFs, AMCA stated that the data they provided to DOE were based on single-sample tests, rather than the two-sample tests required by 10 CFR 429.32. AMCA also commented that the current Federal energy conservation standards are based on single-sample test data as well. AMCA provided calculations showing the impact of using the confidence limits in 10 CFR 429.32 to determine the represented CFEI values from two samples.

AMCA further commented that after the Energy Act of 2020 was published, which prescribed the current energy conservation standards at CFEI100 and CFEI40, a technical errata to AMCA 230-15 was published on May 15, 2021 to account for air density differences between test labs. (AMCA, No. 23 at pp. 12-13) AMCA commented that because DOE has incorporated the technical errata to AMCA 230-15 into DOE's test procedure, (
see
appendix U and 87 FR 50396, 50405), the manufacturer data on which DOE's analysis is based overestimates performance by an average of 3 percent.

AMCA estimated that correcting for the test lab air density, as required in the AMCA 230 technical errata, and two-sample requirements in 10 CFR 429.32 increase CFEI 100 and CFEI 40 by an average of 12 percent and 17 percent, respectively. (AMCA, No. 23 at pp. 2-3) AMCA encouraged DOE to both account for the impact of the technical errata and ensure that its analysis is based on two-sample data. (AMCA, No. 23 at pp. 13-14) Given the impact of the

technical errata and the requirement to use two-sample test data, AMCA commented that the current energy conservation standards are stricter than congress intended and therefore AMCA recommended that DOE maintain the current CFEI requirements of CFEI100 = 1.00 and CFEI40 = 1.31 in this proposed rulemaking. (AMCA, No. 23 at p. 3)

DOE disagrees with AMCA's comment that the statistical requirements in 10 CFR 429.32 result in a more stringent standard when conducting a two-sample test. 10 CFR 429.32(a)(2)(i) states that reported airflow should use the lower of “the mean of the sample” or “the lower 90 percent confidence limit (LCL) of the true mean divided by 0.9.” Similarly, 10 CFR 429.32(a)(2)(ii) states that reported power consumption should use the higher of “the mean of the sample” or “the upper 95 percent confidence limit (UCL) of the true mean divided by 1.1.” In the example data AMCA included in their comments (AMCA No. 23 at p. 14), the values listed as “Represented Value” are the 90 percent lower confidence limit (“LCL”) of the true mean of the airflow and the 95 percent upper confidence limit (“UCL”) of the true mean of the power consumption. These values do not include the “divided by 0.9” in 10 CFR 429.32(a)(2)(i)(B) and the “divided by 1.1” in 10 CFR 429.32(a)(2)(ii)(B). If the statistical calculations were applied as written in 10 CFR 429.32(a)(2), the mean of the sample is lower than the 90 percent LCL of the true mean divided by 0.9 and therefore the mean of the sample should be used to represent the airflow. Similarly, the mean of the power consumption is greater than the mean of the 95 percent UCL of the true mean divided by 1.1 and therefore the mean of the sample should be used to represent power consumption.

DOE notes that the only time the mean of the two-sample test is not used is when there is a large deviation between the measured results of the two tests. Even in a scenario where the two-sample test requirement results in large deviation, manufacturers have the option to conduct additional tests to increase the confidence of the sample mean. Therefore, DOE has not modified its analysis to reflect any difference between reported single-sample results and two-sample results in this NOPR.

Regarding using the AMCA 230-15 technical errata, DOE agrees that if manufacturer data did not correct for air density, it may overstate a CFEI values for a given LDCF. DOE notes that current energy conservation standards must be met using appendix U, which includes the AMCA 230-15 technical errata. However, DOE has modified its analysis of higher efficiency levels in this NOPR to reflect the possibility that some manufacturer data on which DOE's analysis is based may not include air density corrections. This modification is discussed in more detail in section IV.C.2.b of this document.

3. Technology Options

In the preliminary market analysis and technology assessment, DOE identified several technology options that would be expected to improve the efficiency of ceiling fans, as measured by the DOE test procedure. As previously discussed, standard and hugger ceiling fan efficiency is based on a weighted average CFM/W metric, whereas LDCF and HSBD ceiling fan efficiency is evaluated using CFEI. Standard and hugger ceiling fans are also typically installed in residential applications whereas LDCF and HSBD ceiling fans are typically installed in commercial and/or industrial applications. The differences in metric, market, and utility mean that the technology options for improving the efficiency as measured by the DOE test procedure are unique for each product class.

In section 2.4.3 of the February 2022 Preliminary Analysis TSD, DOE identified technologies for improving the efficiency of each ceiling fan product class. The following sections discuss the technology options identified in the February 2022 Preliminary Analysis, stakeholder comment, and DOE's technology options included in this NOPR analysis.

a. Standard and Hugger Ceiling Fans

Generally, at both low and high speeds an increase in standard and hugger ceiling fan efficiency can be achieved by increasing airflow and decreasing power consumption. In section 2.4.3 of the February 2022 Preliminary Analysis TSD, DOE identified three primary categories for increasing standard and hugger fan efficiency: (1) more efficient motors, including larger direct-drive single-phase induction motors and brushless direct current (“BLDC”) motors; (2) more efficient ceiling fan blades using common blade materials, twisted blades, and beveled blades; and (3) advanced ceiling fan controls, including occupancy sensors, wind sensors, and temperature sensors.

As discussed previously, moving a hugger fan further from the ceiling is one way of increasing the CFM/W for these fans because it increases airflow without reducing power consumption. Hugger ceiling fans with fan blades very close to the ceiling can create a vacuum between the fan blades and the ceiling that prevents air from returning to the input side of the fan (
i.e.,
the air choking effect). However, certain consumers may prefer closely mount ceiling fans, despite the reduced airflow, because they do not protrude as far into the ceiling. DOE requested data regarding the impact that the distance between the ceiling fan blades and the ceiling had on airflow.

In response, ALA conducted testing in which they measured high speed CFM for multiple fan models while increasing the distance between the fan blades and the ceiling. (ALA, No. 26 at pp. 9-11) ALA's said that their test data showed that for most models the benefit of having a fan closer to the ceiling than 10 inches decreases significantly for each additional inch closer to the ceiling, and that hugger fan airflow approximately doubled when the distance between the fan blades and the ceiling increased from 6 inches to 10 inches.
Id.

DOE interprets the “benefit of having a fan closer to the ceiling than 10 inches decreases significantly” stated in ALA's comment to mean that the airflow of a hugger fan decreases below 10 inches. DOE does not interpret this text to mean that there is no reason for consumers to want a fan that is mounted closer than 10 inches from the ceiling. DOE has previously determined that ceiling fans mounted closer to ceiling (
i.e.,
hugger fans) warrant a separate energy conservation standard. 86 FR 6826, 6841. The fact that fans exist on market that are fewer than 10-inches from the ceiling indicate that there are some consumer preferences for these fans, even if the airflow is somewhat reduced. Specifically, the ability for that fan to be installed in areas with low ceilings where additional clearance between the ceiling fan and the floor are desired.

In this NOPR, DOE included increasing the distance from the ceiling as a possible technology option for hugger ceiling fans but has retained flexibility in its maximum technology options for fans to be fewer than 10 inches from the ceiling.

b. Large-Diameter Ceiling Fans

An increase in LDCF efficiency is associated with a reduction in power consumption while maintaining airflow. In section 2.4.3 of the February 2022 Preliminary Analysis TSD, DOE identified three primary technology options: (1) more efficient motors, including three-phase geared induction motors, three-phase geared premium induction motors, and permanent magnet direct-drive motors; (2) more

efficient ceiling fan blades, including twisted blades and blade attachments; and (3) advanced ceiling fan controls, including occupancy sensors, wind sensors, and temperature sensors.

AMCA commented that changing from a lower-efficiency geared motor to an IE3
21

motor would improve the efficiency of a LDCF. (AMCA, No. 23 at p. 2) However, AMCA stated that all its members that manufacture gear-driven ceiling fan already use IE3 motors.
Id.

21
“IE3” is the International Electrotechnical Commission (“IEC”) designation for premium efficiency motors. IE3, National Electrical Manufacturers Association (“NEMA”) premium, and EISA 2007 standards for electric motors are often considered equivalent efficiency requirements, although the actual values differ depending on pole, horsepower and enclosure.

AMCA is correct that IE3 motors, or similarly efficient motors (for those below 1 horsepower (“HP”) where IE3 levels do not exist) are typical in the industry. Therefore, DOE is no longer considering three-phase geared induction motors that are not premium efficiency as a technology option in this NOPR. DOE did not receive any other comments regarding other technology options and therefore has retained them in this analysis.

In addition to the technology options identified in the February 2022 Preliminary Analysis, DOE has identified LDCF optimization as an additional technology option evaluated in this NOPR for improving the efficiency of LDCFs.

Section 1008 of the Energy Act of 2020, as codified in appendix U, specifies that LDCF CFEI be calculated using AMCA 208-18
22

with modifications. Broadly, the CFEI metric is the evaluation of the real-world performance of a given fan relative to the performance of a theoretical reference fan. In determining the power required for a reference fan, the CFEI calculation assumes the power input that would be required to produce the tested airflow, given the ceiling fan blade span. AMCA 208-18 assumes four efficiency metrics for the reference fan: (1) airfoil efficiency; (2) transmission efficiency; (3) motor efficiency; and (4) controller efficiency.

22
ANSI/AMCA Standard 208-18 (“AMCA 208-18”), Calculation of the Fan Energy Index, ANSI approved January 24, 2018.

The reference fan calculation in AMCA 208-18 assumes that airfoil blades are 42 percent efficient and that controllers are 100 percent efficient. Further, the reference fan calculation assumes the transmission efficiency is consistent with a perfectly sized V-belt drive. DOE notes that LDCF manufacturers typically use a two-stage helical gearbox rather than a V-belt drive; however, in interviews, manufacturers stated that the reference fan V-belt drive efficiency is a reasonable approximation of a two-stage helical gearbox. The reference fan calculation also assumes the motor efficiency is consistent with a perfectly sized (relative to the required input power) IE3 motor. DOE notes that IE3 motor specifications exist at distinct motor sizes and not as a smooth curve across all possible motor horsepower sizes. Therefore, the motor efficiency formula in AMCA 208-18 is only an approximation. Further, motors are typically sold at distinct horsepower sizes, and therefore the motor size used will not exactly align with the assumed reference fan horsepower and the efficiency may vary.

To meet higher CFEI, some manufacturers may increase fan motor efficiency, others may increase airfoil efficiency, and others may increase transmission efficiency. Further, these various efficiencies can compound with one another. A higher airfoil efficiency means that a smaller gearbox and a smaller motor, with less energy loss, can be used since more power input to the fan blades is converted to airflow.

For example, a 24-foot LDCF with a high-speed airflow of 230,000 CFM has a reference fan power consumption of 1,683 W. A fan with the same efficiency characteristics of the reference fan would have a CFEI100 equal to 1.00 and use 1,683 W at 100 percent speed. If a manufacturer were to improve the airfoil efficiency by one percent (from the reference value of 42 percent to 43 percent), that fan would consume 1,647 W, corresponding to a CFEI equal to 1.022.

LDCFs are commonly offered as a fan “family” with one brand name spanning a variety of blade spans. Typically, a single fan family will be offered in 8-, 10-, 12-, 14-, 16-, 18-, 20-, and 24-foot diameters. To reduce the number of custom parts, it is common for manufacturers to use the same motor/transmission part across several LDCF blade spans. While this practice reduces the burden on manufacturers, it means that the motor size and blade angle is better optimized for certain blade spans and less well optimized for others. This practice also results in a range of CFEI values on the market even within a single fan family, despite the fact that the motor size, transmission, and airflow may be similar. Therefore, in addition to the technology options evaluated in the February 2022 Preliminary Analysis, DOE included LDCF optimization as a technology option in this NOPR for improving the efficiency of LDCFs.

c. High-Speed Belt-Driven Ceiling Fans

Similar to LDCF efficiency, HSBD ceiling fan efficiency is achieved by reducing power consumption while maintaining airflow. In the February 2022 Preliminary Analysis, DOE stated that it did not have sufficient data to analyze a baseline efficiency level or evaluate higher efficiency levels for HSBD ceiling fans. DOE requested comment on technology options for improving HSBD ceiling fan efficiency. DOE received no comments regarding specific technology options for improving the efficiency of HSBD ceiling fans.

Given the similarities between large, housed, air-circulating fan heads and HSBD ceiling fans, DOE expects that technologies which improve air-circulating fan head efficiency would also improve HSBD ceiling fan efficiency. As such, the technology options evaluated for HSBD ceiling fans in this NOPR align with the technology options analyzed in the Fans and Blowers Notice of Data Availability regarding air circulating fans published October 13, 2022 (“Air Circulating Fans NODA”). The technology options analyzed in the Air Circulating Fans NODA included: split-phase motors, permanent split-capacitor (“PSC”) motors, high-efficiency PSC motors, electronically commutated motors (“ECMs”), and aerodynamic redesign. 87 FR 62038, 62042.

d. Summary of Technology Options

For this NOPR, DOE has tentatively selected the technology options listed in Table IV.1 for its NOPR analysis.

Table IV.1—Technology Options and Descriptions

Technology option
Description

Small-diameter ceiling fans:

Larger direct-drive motors
Direct-drive, single-phase, PSC motors with an external rotor are the most common type of motor used in ceiling fans. These motors typically have a flat, pancake-style construction. Larger direct-drive motors have increased mass and/or use steel with better energy efficiency characteristics for the stator and rotor stack. These motors also typically have improved lamination design which increases the cross section and/or length of the copper wiring inside the motor.

BLDC motors
BLDC motors are electronically commutated, synchronous motors with permanent magnets embedded in or on their rotors. BLDC motors are driven by a converter plus inverter combination control system, which converts the AC power supplied by a building into DC power and controls the power flow into the motor to create continuously switching currents in the motor phases. BLDC motors can be much more efficient than induction motors.

Blade materials

Use of alternative materials could enable more complex and efficient blade shapes (plywood vs. MDF vs. injection-molded resin, for example). Further, some ceiling fans use a natural material that is somewhat porous (
i.e.,
allows air to pass through the blades without contributing to airflow). Replacing this natural material with more common materials can increase ceiling fan efficiency.

Occupancy, wind, and temperature sensors and ceiling fan controls
Occupancy sensors use technologies that detect the presence of people through movement or body heat. Wind sensors measure airflow speed and can be used in conjunction with a ceiling fan to determine whether the fan is providing the ideal amount of airflow in a room. Temperature sensors measure the temperature of a room. Ceiling fans can be paired with these sensors and a control system to automatically adjust and optimize their power consumption. Control systems can be mounted into the wall to allow consumers to conveniently turn ceiling fans off or slow their speed as they leave a room or building, reducing unnecessary power consumption.

Distance from the ceiling (hugger ceiling fans only)
Ceiling fans mounted such that their blades are closer to the ceiling are unable to produce as much airflow as if their blades were further from the ceiling. Therefore, hugger ceiling fans mounted close to the ceiling have a reduced energy efficiency potential compared to those with a greater distance between the ceiling and the blades. Increasing this distance improves airflow and efficiency.

Large-diameter ceiling fans:

Permanent magnet direct-drive motors

Permanent magnet motors are able to offer high-torque even at low-speeds and as such are able to be used without a gear-box. The rotor spins in a synchronous manner (
i.e.,
the motor rotates at the same speed as the revolving magnetic field), which is why these motors are sometimes referred to as “permanent magnet synchronous motors.” Permanent magnet motors can be significantly more efficient than induction motors. Several types of permanent magnet direct-drive motors are currently used in the large-diameter ceiling fans industry, including BLDC, permanent magnet AC, and transverse flux.

Fan Optimization
LDCFs are typically not optimized for every blade span for which they are offered. To minimize parts, manufacturers often use the same motor/transmission assembly across numerous blade spans, rather than having an optimized design for each blade span. Optimizing the fan for each blade span represents an opportunity to increase efficiency.

Airfoil blades
Airfoil blades increase ceiling fan efficiency by reducing drag and therefore reducing power consumption. Airfoil blades use curved surfaces to improve aerodynamics. The thickness is not uniform, and the top and bottom surfaces do not follow the same path from leading edge to trailing edge.

Beveled blades
Beveled fan blades are typically beveled at the blade edges from the motor casing to the blade tip. Beveled fan blades are more aerodynamic than traditional fan blades, which reduce drag and increase airflow efficiency.

Curved blades
Curved blades increase ceiling fan efficiency by reducing drag and therefore reducing power consumption. Curved blades are blades for which the centerline of the blade cross section is cambered. Curved blades generally have uniform thickness and no significant internal volume.

HSBD ceiling fans:

Improved Motor Efficiency
The efficiency of an HSBD fan can be increased by improving the efficiency of the HSBD motor. Several different motor technologies exist, ranging from split-phase motors, PSC motors, higher-efficiency PSC motors, and ECMs.

Improved aerodynamic design
The efficiency of a fan can be increased by improving the aerodynamic design of its components. This includes optimizing the blade shape to reduce drag and optimizing the housing or guard design to increase airflow.

B. Screening Analysis

DOE uses the following five screening criteria to determine which technology options are suitable for further consideration in an energy conservation standards rulemaking:

(1)
Technological feasibility.
Technologies that are not incorporated in commercial products or in commercially viable, existing prototypes will not be considered further.

(2)
Practicability to manufacture, install, and service.
If it is determined that mass production of a technology in commercial products and reliable installation and servicing of the technology could not be achieved on the scale necessary to serve the relevant market at the time of the projected compliance date of the standard, then that technology will not be considered further.

(3)
Impacts on product utility.
If a technology is determined to have a significant adverse impact on the utility of the product to subgroups of consumers, or result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not be considered further.

(4)
Safety of technologies.
If it is determined that a technology would have significant adverse impacts on health or safety, it will not be considered further.

(5)
Unique-pathway proprietary technologies.
If a technology has proprietary protection and represents a unique pathway to achieving a given efficiency level, it will not be considered further, due to the potential for monopolistic concerns.

10 CFR 431.4; 10 CFR part 430, subpart C, appendix A, sections 6(c)(3) and 7(b).

In summary, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the listed five criteria, it will be excluded from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed in the following sections.

The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (“screened out”) based on the screening criteria.

1. Screened-Out Technologies

a. Standard and Hugger Ceiling Fans

In section 2.5 of the February 2022 Preliminary Analysis TSD, DOE screened out the following technology option for small-diameter ceiling fans: three-phase induction motors, blade shape, blade attachments, occupancy sensors, wind sensors, temperature sensors, and brushed DC motors. ALA commented that they agreed with the technologies DOE screened out in the February 2022 Preliminary Analysis. (ALA, No. 26 at p. 6)

In this NOPR, DOE has continued to screen these technology options. Each of these technology options is discussed further in Section 4 of the TSD.

In response to the May 2021 RFI, numerous stakeholders commented that the DOE CFM/W metric for small-diameter ceiling fans penalizes smart technologies that use standby power but does not credit any reduction in active mode power consumption that results from implementing advanced controls and smart technology. (AMCA, No. 9 at p. 9, 13; ALA No. 8 at p. 2) ALA and Center for the Built Environment (“CBE”) recommended DOE credit products with smart technologies to account for active mode energy reduction and system wide energy reductions. (ALA, No. 8 at p. 2; CBE, No. 7 at pp. 2-4)) In section 2.4.3.3 of the February 2022 Preliminary Analysis TSD, DOE acknowledged that smart technologies have the potential to reduce ceiling fan CFM/W, on account of using additional power while in standby operation which is accounted for in an operating hour-based weighted average power consumption used in the denominator of the CFM/W metric, despite the fact that smart technologies may reduce operating hours. In response to stakeholder's suggestion that DOE's test procedure “credit” potential operating hour reductions in the CFM/W metric to better convey to consumers on the fan's label which products use less power, DOE noted that smart technologies are currently incorporated into high-efficiency products that easily exceed energy conservation standards, and therefore a smart technology credit was not needed.

Regarding ceiling fan smart technology's ability to reduce building wide energy usage, DOE noted in section 2.4.3.3 of the February 2022 Preliminary Analysis TSD that, while studies show there are potential system-wide energy savings associated with incorporation of automated controls, these studies reported connectivity challenges that led to DOE questioning whether any potential savings of automated controls would be fully realized by consumers. Therefore, DOE did not account for any potential operating hour savings in the February 2022 Preliminary Analysis.

In response, Lutron stated that, while smart technologies are typically used for high-efficiency fans, they can also be integrated into lower-efficiency fans to save energy. (Lutron, No. 24 at pp. 3-4) Lutron added that DOE's decision not to include operating hour savings associated with smart technologies is based on a single field study of a single fan model and that the issues described in this field study are uncommon with smart technologies. (Lutron, No. 24 at p. 3)

DOE agrees that smart technologies can be incorporated into lower-efficiency ceiling fans. In Table IV.2, DOE has provided example numbers to demonstrate why a credit is not needed for theoretical operating hour savings associated with smart technology.

Table IV.2—Example Smart Tech Power Consumption

Fan 1
AC motor—
no smart tech

Fan 2
AC motor—with smart tech

Fan 3
BLDC motor—no smart tech

Fan 4
BLDC motor—with smart tech

Airflow High (CFM)
4,500
4,500
4,500
4,500

Airflow Low (CFM)
1,200
1,200
1,200
1,200

Power High (W)
58.7
55.0
28.3
27.0

Power Low (W)
12.0
11.0
3.9
3.5

Standby Power (W)
0.0
1.4
0.7
1.4

CFM/W
80
77
157
149

In the CFM/W efficiency metric, the denominator is a weighted average of high-speed power consumption, low-speed power consumption and standby power consumption. In high-efficiency fans, such as fans with BLDC motors, standby power energy consumption can make up a much larger percentage of the denominator, because high-speed and low-speed power are relatively low. Therefore, more efficient active mode fans run the risk of appearing on consumer labels to be less efficient by having lower CFM/W. In Table IV.2, Fan 3 has a higher certified CFM/W than Fan 4, despite the fact that Fan 4 uses less power in active mode. However, as stated both fans are very efficient and there is little difference in power consumption. Therefore, there is no need to “credit” potential operating hour savings of Fan 4 such that it appears equally or more efficient than Fan 3.

Regarding lower-efficiency ceiling fans, and specifically fans with AC motors, DOE notes that high-speed and low-speed power consumption is considerably more than fans with BLDC motors and therefore the standby power usage contributes less to the denominator of the CFM/W metric and the difference in certified CFM/W values is going to be relatively small between fans with smart tech and fans without smart tech. In Table IV.2, Fan 1 has a higher certified CFM/W than Fan 2, despite the fact that Fan 2 uses less power in active mode. Because standby power is a small component of total power consumption, there is only a 3 CFM/W difference between Fan 1 and Fan 2 and there is little risk to consumers in purchasing Fan 1, thinking it is more efficient than Fan 2. Therefore, there is no need to “credit” potential operating hour savings of Fan

2 such that it appears equally or more efficient than Fan 1.

DOE therefore maintains its position that a CFM/W “credit” is not needed for ceiling fans incorporating sensors or other smart technologies for the purpose of communicating to consumers which products are more efficient.

Regarding potential building-wide energy savings, DOE notes that regardless of whether smart technologies/automated controls are included in minimally compliant products or high-efficiency products, the operating hours impact would be the same. DOE does not expect that amended efficiency standards would impact the prevalence of smart technologies in ceiling fans and has therefore screened out smart technologies in this NOPR.

b. Large-Diameter Ceiling Fans

DOE screened out and did not receive comment on the following technology options for LDCFs in the February 2022 Preliminary Analysis: alternative blade materials; twisted blades; blade attachments; occupancy, wind, and temperature sensors; and brushed DC motors. DOE therefore continues to screen out these technology options in this NOPR. These technology options are discussed further in Chapter 4 of the TSD.

2. Remaining Technologies

Regarding DOE's decision to screen-in BLDC motors in the February 2022 Preliminary Analysis, several stakeholders suggested BLDC motors may not satisfy DOE's screening criteria. ALA commented that a standard level that eliminates ceiling fans with AC motors is not in the public interest and recommended non-mandatory measures, such as consumer education programs, a properly designed and promoted ENERGY STAR specification, utility rebates or other manufacturer incentives combined with a less stringent standard level can yield substantial energy savings by accommodating consumer design and utility preferences. (ALA, No. 26 at pp. 1-2) ALA added that when the ENERGY STAR program moved to a level that could be met only by BLDC motor ceiling fans, the result was a 70-percent reduction in ceiling fan ENERGY STAR units sold, and HSSD fans were almost eliminated when DOE's efficiency standard moved to requiring a DC motor. (ALA, No. 26 at p. 2) ALA commented that BLDC motor ceiling fans have a delayed start-up where they may change rotational direction (from clockwise to counterclockwise) which can be confusing and annoying to consumers. (ALA, No. 26 at p. 5)

ALA further commented that DC motor manufacturing relies on ferrite magnet materials and rare earth magnet materials sourced from China. They added that a standard that requires BLDC motors would further U.S. ceiling fan manufacturer reliance on Chinese imports. (ALA, No. 26 at p. 14) In section 2.6.3.3 of the February 2022 Preliminary Analysis TSD, DOE noted small-diameter ceiling fan manufacturers already rely on China for the vast majority of their production and it does not expect that a transition to BLDC motors would change this reliance. ALA provided no comment suggesting that BLDC motor ceiling fans are manufactured in a different location than AC motor ceiling fans.

Regarding ALA's comments that the ENERGY STAR level requiring BLDC motors resulted in a significant reduction in shipments, DOE notes that ENERGY STAR is a voluntary standard and ENERGY STAR products are typically offered at a price premium. BLDC motor ceiling fans sold today are not sold as the lowest price point products but as premium products with marketing for their sleek designs, additional speed controls, and quiet operation. In the case of amended efficiency standards, consumers choose between purchasing a ceiling fan and not purchasing a ceiling fan, not between purchasing an ENERGY STAR certified fan and a non-ENERGY STAR certified fan. Products that do not meet amended efficiency standards would no longer be an option for consumers to choose. In this analysis, DOE has accounted for purchase price elasticity between efficiency levels requiring BLDC motors and the no-new standards case (as discussed in section IV.G of this document), but DOE does not expect a 70-percent reduction in shipments or a similar dynamic as stakeholders suggested.

In section 2.4.3.3 of the February 2022 Preliminary Analysis TSD, DOE acknowledged that the control mechanism is different for AC motor ceiling fans and BLDC motor ceiling fans but did not determine that these differences represented a significant loss in consumer utility. DOE noted that while some AC motor ceiling fans are controlled with a remote control, the vast majority are controlled with electromechanical controllers,
e.g.,
a pull chain or a wired wall-control. BLDC motors, by contrast, require an electronic controller to operate with either a remote control or an electronic receiver.

In response, Lutron commented that setting an energy efficiency level where AC powered fans are removed from the market would not be in the public interest. (Lutron, No. 24 at p. 2) Lutron stated that the near-universal compatibility of wall-mounted fan speed controls with AC motors has allowed consumers to purchase fan speed controls for reliability, aesthetics, potential energy savings, and integration features. (Lutron, No. 24 at p. 2) Lutron commented that high-tech, integrated lighting and fan control systems do not control only ceiling fans, but can save significant energy in a home, and that a ceiling fan efficiency standard that requires BLDC motors would result in the elimination of this energy savings potential and consumer utility. (Lutron, No. 24 at pp. 2, 3) Lutron provided

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2023-12957. Public record. Not legal advice.