Energy Conservation Standards for Commercial & Industrial ... · compliance with any standards set for commercial and industrial fans – In addition to energy conservation standards,

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Charles Llenza BUILDING TECHNOLOGIES PROGRAM

February 21, 2013

Energy Conservation Standards for Commercial & Industrial Fans and Blowers: Framework Public Meeting

2

Welcome and Introduction

• Introductions

• Role of the Facilitator

• Ground Rules (Norms) – Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; state your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

• Agenda Review

• Opening Remarks

3

Morning Agenda

9:00 – 9:05 am Welcome

9:05 – 9:15 am Opening Remarks, Introductions, and Agenda Review

9:15 – 9:30 am Rulemaking Process Overview

9:30 – 10:30 am Authority, Definitions, and Regulatory Options

10:30 – 10:45 am Break

10:45 – 11:00 am Regulatory Regimes

11:00 – 11:15 am Test Procedure and Efficiency Metrics

11:15 – 12:00 pm Market &Technology Assessment, Screening Analysis

12:00 – 1:00 pm Break for Lunch

4

Afternoon Agenda

1:00 – 1:45 pm Engineering Analysis

1:45 – 2:15 pm Markups and Energy Use Determination

2:15 – 2:45 pm Life-Cycle Cost and Payback Period Analysis

2:45 – 3:00 pm

Break

3:00 – 3:15 pm Shipments Analysis and National Impact Analysis

3:15 – 3:30 pm Preliminary Manufacturer Impact Analysis

3:30 – 3:45 pm NOPR Analyses

3:45 – 4:00 pm Next Steps and Closing Remarks

5

Opening Remarks

Interested parties who contacted DOE to request an

opportunity to issue an opening statement should speak

now.

6

5

3

2

Test Procedure & Efficiency Metrics

Rulemaking Process Overview

Authority & Definitions

1 Introduction

6 Rulemaking Analyses

Public Meeting Agenda

7 Closing Remarks

4 Regulatory Regimes

7

Purpose of the Framework Document Public Meeting

• Present the analytical approaches to be used to

evaluate energy conservation standards for

commercial and industrial fans and blowers

• Inform interested parties of and facilitate the

rulemaking process

• Provide a forum for public discussion of rulemaking

issues

• Encourage interested parties to submit data,

information, and written comments

Introduction

8

Introduction

Request for Comment

Item #-#: DOE solicits comment on a range of specific issues throughout the Framework Document.

• Throughout this presentation, these issues will be highlighted for discussion in comment boxes such as this.

• Item numbers correspond to those in the Framework Document.

• DOE welcomes comments concerning these specific issues and any other issues related to this rulemaking.

9

Instructions for Submitting Comments

• In all correspondence, please refer to this Commercial and Industrial Fans and

Blowers Rulemaking by:

– Docket # EERE-2013-BT-STD-0006, and/or RIN 1904-AC55

• Electronic: [email protected] or www.regulations.gov

• Postal Mail: Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE-2J 1000 Independence Avenue, SW. Washington, D.C. 20585-0121

• Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

• Phone: (202) 586-2945

Introduction

Comment period closes May 2, 2013

mailto:[email protected]

http://www.regulations.gov/

10

5

3

2




1 Introduction



7 Closing Remarks


11

Standards Development

• The Energy Policy and Conservation Act of 1975 (EPCA), as amended,

contains a list of 12 types of industrial equipment that are considered

covered equipment for which the Secretary of Energy is authorized to

establish energy conservation standards.

• Fans and blowers are two of the specified types of industrial equipment

that the Secretary has classified as covered industrial equipment. (42 USC

6311 (2)(B)).

• EPCA directs DOE to develop new or amended standards designed to

achieve the maximum improvement in energy efficiency that is

technologically feasible and economically justified for which DOE’s

rulemaking process provides the schedule and analyses to do so.


12

• EPCA directs DOE to consider seven factors for analysis when setting

technologically feasible and economically justifiable standards:

• : EPCA Requirement Corresponding DOE Analyses

1. Economic impact on consumers and manufacturers

• Life-Cycle Cost Analysis • Manufacturer Impact Analysis

2. Lifetime operating cost savings compared to increased product cost • Life-Cycle Cost Analysis

3. Total projected energy savings • National Impact Analysis

4. Impact on utility or performance • Engineering Analysis • Screening Analysis

5. Impact of any lessening of competition • Manufacturer Impact Analysis 6. Need for national energy conservation • National Impact Analysis

7. Other factors the Secretary considers relevant • Emissions Analysis • Utility Impact Analysis • Employment Impact Analysis


Source: (42 U.S.C. § 6295(o)(2)(B)(i) and 42 U.S.C. § 6316(a))

13


• TP and ECS rulemakings are separate processes but have integrated timelines.

• The TP rulemaking timeline duration is about 1.5 years from cradle to grave.

• The ECS rulemaking timeline duration is about 3 years from cradle to grave.

• For additional information on the rulemaking process go to:

http://www1.eere.energy.gov/buildings/appliance_standards/standards_dev_and_revision.html

Energy Conservation

Standards (ECS)

Test Procedure (TP) NOPR Final Rule

Test Procedure and Standard Rulemakings Timelines

Framework Document Preliminary

Analysis NOPR Final Rule




14

Framework Document

• Provides an overview of the rulemaking process and encourages early participation from interested parties

• Invites comments on proposed approach and issues

• Accompanying Federal Register Notice of Public Meeting (NOPM) – 78 FR 7306, February 1, 2013

– Gives notice of the public meeting and availability of the Framework Document being discussed today

– Encourages interested parties to submit comments


Framework Document

Preliminary Analysis

NOPR Final Rule

Today

15

Preliminary Analysis Document


Framework Document


NOPR Final Rule

Planned Federal Register Notice and Public Meeting (NOPM) – Planned Q3 2014: Gives notice of the public meeting and availability of the Technical

Support Document (TSD). Encourages interested parties to submit comments.

Analysis:

16

Notice of Proposed Rulemaking (NOPR) Document

• Discussion of comments received in response to Preliminary Analysis TSD

• Analysis of the impacts of potential standards on consumers, manufacturers, and

the Nation and weighting of these impacts

• Any proposed standard levels for public comment

• Accompanying Federal Register publication – Planned Q2 2015

– Gives notice of the public meeting and availability of the revised TSD

– Encourages interested parties to submit comments


Framework Document


NOPR Final Rule

17

Final Rule Publication

• Discuss comments received in response to the NOPR

– DOE will consider all written & verbal input in preparing the final rule

• Revise analysis of the impacts of standards & weighting of these impacts of the final rule

• Determine any standard levels DOE will adopt

• Establish the compliance date for any adopted standards

• Accompanying Federal Register Final Rule – Planned Q1 2016


Framework Document


NOPR Final Rule

18

2013

Framework Document Public

Meeting February 2013

Preliminary Analysis Public Meeting

Planned – Q3 2014

NOPR Public Meeting

Planned – Q2 2015

2015 2016 2019

Proposed Energy Conservation Standard

Final Rule Effective Date Q1 2019

2014

TP NOPR Public Meeting

Planned – Q2 2014

Rulemaking Schedule

19

5

3

2

Regulatory Regimes



1 Introduction



7 Closing Remarks

4


20

Authority and Background

• Currently no energy conservation standards for commercial and industrial fans

• Title III Part C of the Energy Policy and Conservation Act of 1975 (EPCA), as amended, sets forth various provisions designed to improve energy efficiency of commercial and industrial equipment. (42 U.S.C. 6311–6317)

– Section 6311 includes a list of industrial equipment which the Secretary may classify as covered equipment

• This list includes fans and blowers (42 U.S.C. 6311(2)(B)(ii) and (iii))

» Notice of Proposed Coverage Determination published June 28, 2011 (76 FR 37678)

• Manufacturers must use a DOE prescribed test procedure to establish compliance with any standards set for commercial and industrial fans

– In addition to energy conservation standards, DOE will undertake a test procedure rulemaking for commercial and industrial fans


http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/fbf_nod_06_28_2011.pdf

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/fbf_nod_06_28_2011.pdf

21

Definitions

• Currently there are no statutory definitions for fans and blowers

– Framework Document discusses the considered definitions

• DOE Proposed Definitions –

• Commercial/Industrial Fan: A device used in commercial or industrial systems to provide a continuous flow of a gas, typically air, by an impeller fit to a shaft and bearing(s). A fan may be manufactured with or without a housing component.

• Fan Manufacturer: An entity responsible for assembling a fan into a testable configuration such that the fan impeller is fit to a shaft, bearings, and in some cases installed within a housing component,

• Axial Fan: A fan in which airflow enters and exits the impeller parallel to the shaft axis. The axial fan may or may not be equipped with a cylindrical housing, orifice panel/ring, inlet or outlet guide vanes


22

Definitions (cont.)

• DOE Proposed Definitions (cont.) – • Centrifugal Fan: A fan in which airflow enters the impeller parallel to the shaft

axis but changes direction and exits perpendicular to the shaft in a radial direction at the impeller discharge. The impeller may have one or two inlets and may or may not have a housing component.

• Cross Flow Fan: A type of centrifugal fan in which the fluid path though the impeller is in a direction that is substantially at right angles to its axis with air both entering and leaving radially at its periphery

• Mixed Flow Fan: A fan in which the direction of airflow through the impeller takes on characteristics that are intermediate between centrifugal and axial fans in that the air exits the fan in a direction which is neither parallel nor perpendicular to the shaft


23

Definitions (cont.)

• DOE Proposed Definitions (cont.) –

• Blower: An axial or centrifugal fan with a specific ratio between 1.11 and 1.20 were the specific ratio is the total pressure at the fan outlet divided by the total pressure at the fan inlet, measured at peak fan total efficiency (European Union 2011 Non-domestic fans legislation):

– The term “blower” is used in many contexts by the industry, however, generally used to describe high pressure fans. DOE considers specific ratio a way to quantify “high pressure”.

– AMCA 99 definition of blower emphasizes the application and not the specific technological features of the equipment

• Safety Fan: An axial or centrifugal fan designed for use in applications requiring extra safety measures, such as:

– Those designed to operate in potentially explosive atmospheres

– Those designed for emergency use only, short-time duty, fire safety requirements

– Those designed specifically to operate where gases temperature exceed 500ºF

– Those designed in toxic, highly corrosive, or flammable environments.


24

Considered Fan Coverage

• Fan Types

– Inclusion of all fan types (axial, centrifugal, mixed flow, blowers)

• Physical and Performance Criteria for Standards

– Impeller Diameter: inclusion of fans up to 98 inches

– Transmission Type: all

– Rotational Speed: speeds up to 8,000 RPM


25


Request for Comment

Item 2-1: DOE requests data on how fans are sold. Item 2-2: DOE requests comment on the suggested cross flow fan definition. Item 2-3: DOE requests comment on the suggested blower definition. Item 2-4: DOE requests comment on the suggested safety fans definition. Item 2-7: DOE requests comment on fan coverage as fans are defined in the Framework Document.

26

5

3

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1 Introduction



7 Closing Remarks


1 Introduction

27

Combined Fan, Motor, & Control Equipment

• DOE is considering defining commercial and industrial fans as:

– "a device used in commercial or industrial systems to provide a continuous flow of a gas, typically air, by an impeller for ventilation, circulation, or industrial process needs. A fan may be manufactured with a housing component, motor, drive, and/or a VSD".

• Addressing losses besides the bare shaft fan

– Example is in the EU Commission where they regulate non-domestic fans inclusive of motor & controls

Regulatory Regime

28

Combined Fan Equipment (cont.)

• VSDs are control devices

– Enables the fan rotational speed to match process requirements

• Benefits variable load applications and depends on time spent at various operating conditions

• VSDs may not be appropriate for all applications and may degrade efficiency under constant load operation

– Same fans can be used in constant and variable load applications

• DOE is not aware of any specific fan type that is always used in an application that would benefit from a VSD

• Manufacturers cannot control if or how a VSD is used

– DOE will conduct analyses across the full spectrum of fan applications and baseline conditions to determine VSDs impact on the field energy use

Regulatory Regime

29

Fans For Which DOE is Considering Standards

• Bare Shaft Fans: Fans without drives, attachments, or accessories

– Regulatory Regime #1: single set of equipment classes

• Bare shaft fan regulatory approach for all fan types regardless of how they are sold

• Combined Fan Equipment: Fan+Motor or Fan+Motor+VSD

– Regulatory Regime #2: two sets of equipment classes

• Fans without VSD (sold with or without motor)

• Fans with VSD

– Regulatory Regime #3 : two sets of equipment classes

• Fans without motor

• Fans with motor (sold with or without VSD), VSD is a design option to increase efficiency

Regulatory Regime

30

Regulatory Regime

Request for Comment

Item 2-9: DOE requests comment on whether establishing standards for fans defined inclusive of the motor, transmission, and controls could increase the benefits of using VSDs in the field. Item 2-10: DOE requests data and comment on whether fans are more often combined with motors, VSDs, or both by the fan manufacturer or by distributors/contractors. Item 2-11: DOE requests information on how often and in what circumstances the intended application is known when the fan is sold. Item 2-12: DOE seeks comment on whether to consider establishing standards only for fans with diameters below a certain maximum and/or above a certain minimum.

31

Request for Comment

Item 2-14: DOE requests comment on covering fans+motors with motor power requirements between 125 W and 500 kW for this rulemaking. Item 2-16: DOE requests comment on what percentage of fan motors are covered by the small and medium electric motor standards. Item 2-17: DOE seeks comment on the market share (by fan type) and applications of fans that are driven by equipment other than electric motors. Item 2-18: DOE requests comment on fan transmission types. Item 2-19: DOE requests comment on the VSDs sold with fans and whether there is efficiency variability (and if so, to what extent) among VSDs.

Regulatory Regime

32

5

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7 Closing Remarks


1 Introduction 1 Introduction

33

Test Procedures

• DOE is developing a test procedure for commercial and industrial fans.

• When establishing test procedures, DOE reviews existing industry test procedures to measure the energy use or efficiency of the covered equipment as a starting point in the process.

• Manufacturers must use DOE test procedures to ensure compliance with the standards and to make representations of the energy use of the covered equipment.


34

Current Industry Test Procedures

• ANSI/AMCA 210-07 / ANSI/ASHRAE 51-07: “Laboratory Methods of Testing Fans for Aerodynamic Performance Rating”

• Applicable to all fan types

• Widely recognized and utilized in U.S.

• AMCA Standard 220 “Laboratory Methods of Testing Air Curtain Units for Aerodynamic Performance Rating”

• Includes modifications for AMCA 210 for air curtain testing.

• ISO 5801-07 “Industrial fans - Performance testing using standardized airways”

• International standard developed based on standards: AMCA 210, BS 848 Part 1:1980 (U.K.) and DIN 24163-2: 1985 (Germany)


35

Potential Test Configurations Considered

• Defines the use and geometry of connections to a fan outlet and/or inlet.

• There are four test configurations (also referred to as installation categories) specified in ISO 5801 and AMCA 210-07:

• DOE is considering specifying a single test configuration per equipment class for consistency of results since ducting impacts fan performance.


Installation Category/ Test Configuration

Location of Ducting for Testing

A Free inlet, free outlet

B Free inlet, ducted outlet

C Ducted inlet, free outlet

D Ducted inlet, ducted outlet

36


Request for Comment

Item 3-1: DOE requests comment on the use of the AMCA 210-07 test procedure as a base for the development of a DOE test procedure. Item 3-3: DOE requests comment on AMCA Standard 220-05 for measuring performance of cross flow fans. Item 3-6: DOE requests comment on using a clean air only test procedure for dust air or material handling fans.

37


Request for Comment

Item 3-7: DOE requests comment on which test configuration should be considered for each of the considered equipment classes (axial housed, axial un-housed, centrifugal clean air housed, centrifugal clean air unhoused, centrifugal dust air, centrifugal material handling, centrifugal cross flow, mixed flow, blowers, safety fans). Item 3-8: DOE requests comment on requiring an air straightener to reduce air swirl at the outlet for axial fans tested in configuration B (free inlet, ducted outlet) or D (ducted inlet, ducted outlet).

38

Currently Available Fan Efficiency Data & Definitions

• Sources

– Information from manufacturer websites and catalogs .

• Efficiency Definitions

– Peak Total Efficiency (AMCA 99)

• Ratio of fan air power output to fan shaft power input for the operating condition for which this value is highest.

– Overall Efficiency (ISO 12759)

• Fan peak total efficiency multiplied by drive components efficiency (includes efficiency of motor and any components between the motor and the power supply and any mechanical devices between motor and fan).

• Each fan and motor combination has a unique efficiency value.


39

Potential Efficiency Metric Considered for Bare Shaft Fans

• Fan Efficiency Grades (FEG) per AMCA 205-10 (Rev. 2012)

– Numerical rating that represents fan efficiency

– Each FEG represents a relationship of peak total efficiency as a function of a fan's impeller diameter

– DOE plans to evaluate an FEG metric by developing fan efficiency grades unique to each equipment class


40

Potential Efficiency Metric Considered for Bare Shaft Fans (cont.)


• DOE is interested in expanding the FEG approach to incorporate operational conditions of a fan

– DOE would evaluate efficiency against combinations of size and operational parameters, for example, diameter and specific speed*

*Specific speed is a function of a fan’s airflow, rotational speed, and pressure.

41

Expanded FEG - Example


30

40

50

60

70

80

90

100

2040

6080

1000020000

3000040000

5000060000

Tota

l Effic

iency

(%)

Impeller Diameter (inch)

Specific Speed Ns

30 40 50 60 70 80 100

42

Expanded FEG Efficiency Metric - Example


30%

40%

50%

60%

70%

80%

90%

0 10 20 30 40 50 60 70 80 90 100

To

tal

Effi

cien

cy (%

)

Impeller Diameter (inches)

10000

11833

13667

15500

17333

19167

21000

22833

24667

26500

28333

30167

32000

33833

35667

37500

39333

41167

43000

Specific Speed

43

Efficiency Metric for Fans Inclusive of Motor & Controls

• Efficiency may need to include motor power to reflect energy-efficiency changes for fan-motor systems.

• DOE would consider a metric that can be used to account for the use of more efficient VSDs.

• DOE would consider a metric that can capture the energy impacts from using a VSD in comparison to a fan with a motor but without a VSD.

• Example: European Union’s Fan-Motor Efficiency Grade (FMEG)

– Uses overall efficiency with a VSD compensation factor.


44

Efficiency Metric for Fans Inclusive of Motor & Controls (cont.)

• If DOE pursues an regulatory regime for fans inclusive of the motor & controls, then two sets of equipment classes will be developed - may require different efficiency metrics for each set

• Separate metrics:

– DOE would use different metrics for the two equipment class sets

– Would not allow direct comparison of fan efficiency when comparing bare shaft fans vs. fans with additional components

• Same metrics:

– DOE would use the same efficiency metric for both equipment class sets

– Would allow direct comparison of fan efficiency across the equipment class sets


45


Regulatory Regime Equipment Class Set Metric Alignment Options

Separate Same Multiple

1 Bare Shaft fans Only one set of equipment classes

N/A N/A N/A

2 Fans inclusive of the motor and VSD

Fans Without VSD (with or without motor)

Fan Peak Total Efficiency

Overall Efficiency (standardized

motor and VSD) N/A

Fans With VSD Overall

Efficiency Overall Efficiency

Fan Peak Total Efficiency and Overall

Efficiency

3 Fans inclusive of motor

Bare Shaft Fans Fan Peak Total

Efficiency

Motor Input Power Based

(standardized motor)

N/A

Fans With Motor (with or without VSD)

Electric Input Power Based

Electric Input Power Based

Fan Peak Total Efficiency and Electric

Input Power Based Metric

Regulatory Regimes and Efficiency Metric Options for Equipment Class Sets Summary Table

46


Request for Comment

Item 3-9: DOE requests comment on the appropriateness of using publicly available performance data in lieu of original test data Item 3-10: DOE requests original fan performance data generated from AMCA 210 tests Item 3-11a: DOE requests comment on the considered efficiency metric approaches for bare shaft fans Item 3-11b: DOE requests comment on the EU’s FMEG efficiency metric for fans sold with motors

47


Request for Comment

Item 3-11c: DOE requests comment on the use of overall efficiency for fans sold with both motors and VSDs Item 3-18: DOE requests comment on the use of input power based efficiency for fans sold with motors Item 3-19: DOE requests comment on whether fans that perform under variable load conditions should be required to meet multiple standards Item 3-20: DOE seeks comment on setting standards based on different efficiency metrics for fans sold alone and fans sold with motors & VSDs

48

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1 Introduction



7 Closing Remarks


49


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis

Engineering Analysis

Energy Use Analysis

Shipments Analysis

National Impact Analysis

Markups for Product Price Determination

Life-Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis

50

• Purpose:

– Characterize the commercial and industrial fan markets and the measures to improve efficiency.

• Method:

– Identify and characterize manufacturers of commercial and industrial fans

– Estimate shipments and trends in the market

– Identify technologies that could improve efficiency

– Identify regulatory and non-regulatory initiatives intended to improve the efficiency of the equipment covered under this rulemaking

Market and Technology Assessment

51

Considered Commercial and Industrial Fan Equipment Classes, Bare Shaft*


Fan Type Equipment Class

Axial

Housed

Unhoused

Safety Fans

Centrifugal

Clean Air Housed

Clean Air Unhoused

Dust Air Housed

Material Handling Housed

Cross Flow Housed

Safety Fans

Mixed Flow All

Blowers Axial

Centrifugal

*Note: If DOE uses regulatory option #2 or #3, a second set of equipment classes could be developed that mirror the set

shown for bare shaft fans.

52

Technology Options to Improve Efficiency

Bare Shaft Fans

• Improving aerodynamic design

• Blade shape

• Material selection

• Guide vanes

• Optimization of housing design

Fans Sold with Motors/VSD

• Improved motor efficiency

• Variable speed drive

• Improved variable speed design


53


Request for Comment

Item 5-1: DOE requests information that would contribute to the market assessment for fans. Examples of information sought include current equipment features, efficiencies and efficiency trends, historical shipments and prices by equipment class. Item 5-2: DOE requests comment on the estimates of the number of U.S. fan manufacturers that could be considered small businesses.

54


Request for Comment

Item 5-3: DOE welcomes comments on performance-related features DOE should consider when defining fan equipment classes. Item 5-5: DOE requests comment on whether transmission type should be considered when determining equipment classes. Item 5-6: DOE requests comment on whether the development of separate equipment classes is necessary to accommodate different performance characteristics of fans sold bare shaft versus fans sold with the motor, transmission, and/or controls. Item 5-7: DOE requests comment on splitting axial fan types into housed and unhoused equipment classes or whether a single equipment class would sufficiently represent axial fan applications. Item 5-8: DOE requests comment on what types of axial fan designs or characteristics are unique to axial-type safety fans. Item 5-9: DOE requests comment on whether there are any other commercial or industrial applications (beyond clean air, dust air and material handling) that should be considered while defining equipment classes for centrifugal fans.

55


Request for Comment

Item 5-10: DOE requests comment on the considered groupings of housed centrifugal fans. Specifically, DOE requests comment on the use of air quality (Clean Air, Dust Air, Material Handling) and housing characteristics for classification purposes. Item 5-11: DOE requests comment on setting cross flow fans as a separate equipment class within the centrifugal fans category. Item 5-13: DOE requests comment on what types of centrifugal fan designs or characteristics are unique to centrifugal-type safety fans. Item 5-14: DOE requests comment on setting a separate equipment class for blowers. Item 5-15: DOE requests comment on whether there is a need of more than one blower equipment class to account for the differences between centrifugal and axial blowers. Item 5-16: DOE requests comment on setting a separate equipment class for mixed flow fans. Item 5-17: DOE requests comment on whether there are differences among mixed flow fans that might warrant more than one equipment class for this fan type.

56


Request for Comment

Item 5-18: DOE requests comment and/or information on the effect of different blade materials on efficiency. Item 5-20: DOE requests comment on whether there are compatibility issues with certain fans and VSDs that DOE should be aware of when considering a VSD as a means to improve fan efficiency. Item 5-21: DOE welcomes comments on the preliminary technology options identified in the Framework and whether there are other technology options it should consider.

57


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





58

• Purpose:

– Screen out technology options that DOE will not consider in the engineering analysis for commercial and industrial fans

• Method:

– DOE will evaluate each technology option based on the following criteria:

• Technological feasibility

• Practicability to manufacture, install and service

– Note: practicability is on a commercial scale at the compliance date of any final standards

• Impacts on product utility or available to consumers

• Impact on health and safety

Screening Analysis

59

Request for Comment

Item 6-1: Are there any technologies that DOE should not consider because of any of the four screening criteria? If so, which screening criteria apply to the cited technology or technologies?

Screening Analysis

60


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





61


• Develop the cost-efficiency curve, which characterizes the relationship between manufacturer selling price (MSP) and energy efficiency.

• The cost-efficiency curves for the examined equipment classes are key inputs for the downstream rulemaking analyses.

Rulemaking Analyses

• Life-Cycle Cost and Payback Period Analysis

• Manufacturer Impact Analysis

• Employment Impact Analysis

Manufacturer Selling Price – Efficiency Relationship

Man

ufa

ctu

rer

Se

llin

g P

rice

(M

SP)

Efficiency Level

Engineering Analysis – Purpose

62

Representative Equipment Classes and Representative Units

• The equipment classes identified by DOE cover a range of fan designs and

allow for a wide range of fan sizes.

• DOE may focus its analysis on a subset of representative equipment

classes and a representative group of units within these classes.


63

Requests for Comment

Item 7-1 Once DOE establishes any representative equipment classes and representative units, it selects a baseline model as a reference point for each representative unit from which to measure changes resulting from the design options. DOE develops separate engineering analyses for each baseline model analyzed. DOE intends to use fan teardowns and fan efficiency (determined from fan performance tests) to develop cost-efficiency relationships for the fans analyzed. DOE intends to develop the necessary test procedures through a test procedure rulemaking. Item 7-2 DOE seeks input on the methods and approaches used by manufacturers to improve the efficiency of fans. Item 7-3 DOE welcomes comment from interested parties on the best methodology for scaling the representative units to other fan sized within the equipment class.


64

Data Sources

• DOE may use publicly available data from manufacturer websites and

catalogs, but such information may be limited.

Request for Comment

Item 7-4 DOE seeks fan test data to improve DOE’s understanding of fan performance to select appropriate representative units for the respective equipment classes.


65

Engineering Analysis Methodology

• Determine characteristics of common or typical models which will serve as reference points to assess changes due to energy conservation standards.

Define Baseline Models

• Conduct tests to verify efficiency ratings.

• Perform equipment disassembly to identify design options and provide input to manufacturing cost models to determine designs and costs associated with each efficiency level.

Reverse-Engineering

• Collect manufacturer cost data on efficient fan designs.

• Conduct interviews with manufacturers to enhance understanding of efficiency improvements and associated costs.

Data Collection, & Interviews

• Develop cost-efficiency curves based on reverse-engineering and cost data from available sources including manufacturer interviews.

Develop Engineering Analysis Curves


66

Reverse-Engineering Methodology

Fabricated Parts

Selection of Units

Physical Teardown

Bill of Materials

Assembly Process

Manufacturer Costs

Purchased Parts


67


Item 7-5 For each equipment class, DOE welcomes stakeholder comments on methods and approaches that DOE intends to employ to determine potential fan efficiency improvements. Detailed information on fan performance and the incremental manufacturing costs (e.g., material costs, labor costs, overhead costs , building conversion capital expenditures, tooling/equipment conversion capital expenditures associated with more efficient designs, research and development (R&D) expenses, and marketing expenses) would be useful.


68

Manufacturing Selling Price (MSP)

• MSP includes manufacturer production costs (MPC) as well as non-

production costs, such as maintenance, depreciation, and taxes.

• Markups will be used to represent non-production costs and convert the

MPC to the MSP.

• DOE intends to estimate manufacturer markups based on publicly

available financial information and manufacturer interviews.


Item 7-6 DOE welcomes comment on the markup approach proposed for developing estimates of manufacturer selling prices. Item 7-7 DOE welcomes comment on the proposed approach to determine the relationship between manufacturer selling prices and fan efficiency.


69

Conversion Costs

• Includes the difference in investments required to build production facilities

required for higher-efficiency designs as compared with investments for

production facilities used for current designs.

• DOE typically does not include conversion costs in the engineering analysis.

• One option to improve fan efficiency is re-design. The non-recurring R&D costs

required to develop such new designs also would not be part of the MSP

calculated in the engineering analysis. It will be addressed in the Manufacturer

Impact Analysis.


Item 7-8 DOE welcomes comment on the conversion costs required to improve the efficiency of the fans to various levels, as well as what portion of these costs would be passed on to the consumer.


70

Selecting Representative Units and Scaling Results

• Within each representative equipment class, DOE would select

representative unit fans in size ranges and of specific speed values that

represent a large number of models.

• DOE would also plan to evaluate fans of small and large sizes for at least

one fan series to characterize a size-efficiency relationship.

• DOE would use this relationship to scale results for representative units to

smaller and larger units.


71

Request for Comment

Item 7-9: DOE requests comment on limiting representative unit selection to fan size(s) that include the most available units. Item 7-10: DOE requests comment on the selection of additional fans at both larger and smaller sizes to determine a fan size-efficiency scaling relationship. DOE requests comment on the number of additional fans to test to develop the size-efficiency scaling relationship.


72

Baseline Models

• DOE typically selects models that just meet current energy conservation

standards to represent the baseline.

• Energy conservation standards for fans do not currently exist. Hence, for

this rulemaking, DOE will select baseline models at the bottom-of-market

efficiency representing substantial shipments.


73

Request for Comment

Item 7-12: DOE seeks comment on the selection, appropriate features, and performance characteristics of baseline models for each equipment class. Specifically, DOE requests comment on choosing the least efficient fan design as the baseline model for the equipment class. DOE will define the characteristics of the proposed baseline models based on comments from interested parties in addition to DOE's analysis.


74

Efficiency Levels

• Within a given size selected for analysis, the fan models for which performance

data is available will be assessed to determine efficiency levels for analysis.


Item 7-1 DOE requests comment on the method of using fan unit efficiencies as the basis for determining efficiency levels.


75

Efficiency Levels (cont.)

• Once DOE establishes a baseline for each representative unit, it

establishes efficiency levels based on measured improvements in

efficiency resulting from implementation of technology options. DOE will

develop separate engineering analyses for each baseline model analyzed.

•

• DOE intends to determine fan efficiency from fan performance tests

performed using the proposed DOE test procedure.


76

Request for Comment

Item 7-14: DOE seeks input from interested parties regarding the range of efficiency levels that should be examined as part of its analysis. Item 7-15: DOE requests comment on whether manufacturers generally do not offer fans of varying efficiencies that meet the same duty requirement.


77

Max Tech

• DOE is required to analyze maximum technologically feasible (“max tech”)

efficiency levels.

• DOE will seek interested party input on the appropriate max tech levels.


Item 7-1A DOE welcomes inputs from interested parties on a methodology that would be appropriate for determining the max-tech models for each fan analyzed.


78

Outside Regulatory Changes

• DOE will consider the effects of other DOE energy conservation standards and

regulatory changes outside DOE’s rulemaking process that can impact

manufacturers of covered equipment.

• Some regulatory changes can also affect the efficiency or energy consumption of

the fans covered under this rulemaking.

• DOE will attempt to identify any outside engineering issues that could impact the

engineering analysis.

Request for Comment

Item 7-16: DOE welcomes comment on whether there are outside regulatory changes that DOE should consider in its engineering analysis of fans.


79


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





80

• Purpose:

– Estimate actual user prices from manufacturer selling prices of baseline and higher efficiency designs of equipment

• Method:

– Identify distribution channels and estimate share of each channel in the aggregate sales volume

– Estimate how equipment is marked up along each level of the distribution chain

Markups Analysis

81

Proposed Distribution Channels

Markups Analysis

Manufacturer OEM OEM Product Distributor User (OEM Channel-A) Manufacturer Distributor Contractor User (Distributor Channel -B) Manufacturer Distributor User (Distributor Channel-C) Manufacturer User (Direct End-User Channel-D) Manufacturer Other User (Channel-E)

Manufacturer Representatives

Figure 1. Commercial and Industrial Fan Distribution Channels

82

Types of Markups in Distribution Chain

• Baseline Markups:

- Markups relate end-user price to manufacturers selling price (MSP) averaged over all distribution channels.

- Baseline markups relate price to MSP for all currently sold equipment.

- Baseline markups indicate a consumer price that covers all of a distributor’s or contractor’s current expenses plus profit.

• Incremental Markups:

- Incremental markups relate the incremental change in end-user price to the incremental change in MSP due to higher efficiency designs.

- Some of the distributor’s costs, such as direct labor costs (salaries, payroll, rental and occupancy), do not vary with efficiency induced changes and are excluded from the calculation of incremental markups.

- Incremental markups cover only expenses that are expected to vary with higher cost of equipment sold e.g., business promotion, interest and insurance etc.

Markups Analysis

83

Mark-Ups Analysis

Request for Comment

Item 8-1: DOE requests information regarding the functioning of the manufacturer representatives/distributors for different equipment classes and market segments. Item 8-2: DOE requests information on OEM market segments, and the downstream distributor channels, if any. Item 8-3: DOE requests comments on the applications and market segments identified by interested parties and information on other market segments, including their corresponding distributor channel(s) and the trade association(s) representing the distributors.

Markups Analysis

84

Request for Comment

Item 8-4: DOE requests information on the proposed distribution channels and the share of industry shipments expected for each distribution channel for the commercial and industrial fans in terms of either each specific equipment class or the broader equipment categories described above. Item 8-5: DOE seeks comment on other sources of relevant data that could be used to characterize markups for commercial and industrial fans. Item 8-6: DOE requests feedback on its proposal to use incremental distribution channel markups for the LCC analysis.

Mark-Ups Analysis Markups Analysis

85


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





86

• Purpose:

– Identify how fans are actually operated by users and to determine the energy savings potential of more efficient designs in the field

– Estimate annual energy consumption (AEC) for baseline and higher-efficiency designs

• Issues:

– End-use load profiles are expected to be highly variable across equipment classes and applications

– In practice many, if not all, fans typically operate at points other than their peak efficiency

– Useful work done by any fan will vary widely across a range of possible applications

Energy Use Analysis

87

Approach

• Estimate annual energy consumption (AEC) for baseline and higher-efficiency designs using use the load profiles developed for each application:

• Develop statistical models describing the expected range of duty profiles for fans in different applications

Energy Use Analysis

Where: AEC = annual energy consumption (kWh) 𝐻𝑓𝑎𝑛 = air horsepower at the operating point i Ni = operating hours at the operating point i ηOverall =ηF × ηT × ηM × ηC at the operating point i ηF = fan efficiency ηT = transmission efficiency ηM = motor efficiency ηC = control system efficiency

spooperatingAll

iiioverallfan NH

HPkWAEC

int__

1)/(746.0

Where:

AEC = annual energy consumption (kWh) 𝐻𝑓𝑎𝑛 = air horsepower at the operating point i Ni = operating hours at the operating point i ηOverall =ηF × ηT × ηM × ηC at the operating point i ηF = fan efficiency ηT = transmission efficiency ηM = motor efficiency ηC = control system efficiency

spooperatingAll

iiioverallfan NH

HPkWAEC

int__

1)/(746.0

Hfan

88

Request for Comment

Item 9-1: DOE requests input and recommendations for identifying high sales volume and large installed base market segments corresponding to specific industries and specific applications for which the fan equipment may have similar load profiles. Item 9-2: DOE welcomes recommendations on sources of data or analysis methods that would provide end-use load profiles for each of the commercial and industrial fans in the different market segments. Item 9-3: DOE requests input on ways to characterize fan sizing and selection practices for different equipment classes and applications and to help define the design or peak fan load for the purpose of generating normalized load profiles Item 9-4: DOE welcomes comment on methods for determining generic (non-market segment specific) load profiles for fan equipment classes considered in this rulemaking.

Energy Use Analysis

89

Request for Comment

Item 9-5: DOE welcomes comment on the current penetration level of variable-speed drives in the installed base of products or applications for each of the equipment classes considered in this rulemaking. Item 9-7: DOE requests comment and recommendations on the range of and number of fan rotation speeds over which the analysis should be carried out for different equipment classes. Item 9-8: DOE requests information on current industry practices and recommendations on the selection of representative operating points for a given rotational speed. DOE welcomes comment on whether the analysis should be extended to a range of operating points away from the peak efficiency. Item 9-9: DOE requests comment and estimates to establish the mean value and the ranges of likely values for motor, transmission, and motor control efficiencies.

Energy Use Analysis

90


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





91

• Purpose:

– Assess life-cycle cost (LCC) impacts of different efficiency levels on the consumer

• Method:

– LCC equals consumer price plus the sum of annual operating costs (including repair and maintenance costs) discounted to a particular base year

– Economic evaluation from the consumer perspective

– Results are expressed as LCC difference (base case minus higher efficiency level)

– Payback Period (PBP) is also calculated and reported in this analysis


92

Approach

• For each of the representative units in each equipment class:

– Develop fan selection process to reflect product choices by customers

– Develop distribution of equipment efficiencies expected for the compliance year

– Aggregate the annual energy consumption over a fan’s lifetime

– Model uncertainty and variability in the inputs using a Monte Carlo simulation method and probability distributions

– Perform an analysis to determine whether the three-year rebuttable presumption of economic justification applies


93

Approach

• Installation Costs

– Consists of labor and any miscellaneous materials and parts.

• Energy Prices

– DOE will collect information about commercial and industrial electricity tariffs as a means of establishing marginal electricity prices.

– DOE will use EIA’s Annual Energy Outlook to estimate future energy prices.

• Maintenance & Repair Costs

– DOE plans to consider maintenance and repair costs and plans to determine whether it changes with increased efficiency.


94

Approach

• Equipment Lifetime

– The operational lifetime of a fan can be determined from the number of revolutions until failure.

– Revolutions until failure are usually limited by the fan’s bearing.

– Basic bearing lifetime for medium-sized light duty fans is approximately 40,000 hours; for heavy duty fans is approximately 100,000 hours*.

• A fan operating full-time is estimated to run 4,000 hours per year, translating into a fan lifetime of 10-25 years.

• The RSMeans method uses an average fan lifetime of 15 years.

*Source: Cory, W.T.W., Fans and Ventilation: A practical guide.


95

Approach

• Discount Rates

– DOE will derive the discount rates for the commercial and industrial users by estimating the capital costs for companies that purchase fans

• Base Case Efficiency

– Used to characterize the commercial and industrial fan market in the compliance year in the absence of DOE standards

– If market share efficiency data are not available, DOE may develop efficiency distributions based on available models and information from fan manufacturers and experts


96

Request for Comment

Item 10-1: DOE welcomes comment on the factors that impact the installation costs for fans and on whether installation cost increases with higher-efficiency equipment. Item 10-2: DOE welcomes input on the proposed methodology for estimating current and future electricity prices. Item 10-3: DOE invites comment on how repair costs may change for more efficient fans. DOE also invites comment on repair practices, and how usage patterns may impact equipment repair and maintenance. Item 10-4: DOE welcomes information that will assist in determining an appropriate distribution of fan lifetimes for the equipment classes covered in this rulemaking. Item 10-5: DOE welcomes input on the proposed approaches for estimating discount rates for fan users. Item 10-6: DOE requests data on the efficiency distribution and welcomes comment on the likelihood and degree of improvement in efficiency of commercial and industrial fans in the next 5 to 10 years as a result of market forces or industry trends.


97


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





98

• Purpose:

– Project future shipments by equipment class

• Approach:

– DOE typically projects shipments for a 30-year period beginning in the expected compliance date of the standard

– Characterize the production of fans by using

• Gross Domestic Product (GDP) as an indicator of the performance of industrial and commercial sectors where fans are used

• Private fixed investment data for equipment incorporating fans from the U.S. Department of Commerce’s Bureau of Economic Analysis

– DOE may use different shipments projection in the standards case as compared to the base case

Shipments Analysis

99

Shipments Analysis

Request for Comment

Item 11-1: DOE welcomes comment on the shipments projection methodology. DOE invites comments regarding the selection of appropriate economic drivers and sources of data for historical shipments and shipment breakdowns by equipment class. Item 11-2: DOE requests historical shipments data for each of the considered equipment classes. Item 11-3: DOE welcomes comment on how an energy conservation standard for fans might impact shipments of the equipment covered in this rulemaking.

Shipments Analysis

100


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





101

• Purpose:

– Determine the projected national energy savings (NES) and consumer national net present value (NPV)

• Method:

– Develop annual series of national energy and economic impacts

– Utilize the shipments model to estimate stock each year

– Utilize the LCC to develop input about total installed cost and energy use per unit (UEC) in any year

– Aggregate the costs and energy use for all years in the analysis period

– Report NES in primary and full fuel cycle (FFC) savings

– Report change in national customer NPV (in constant year dollars)

– Account for the time-value of money though defined discount rates


102


Framework Document


NOPR Final Rule

Effective Date

Market & Technology

Screening Analysis


Energy Use Analysis

Shipments Analysis





103

• Purpose:

– Assessment of the potential impacts of energy conservation standards on manufacturers of fans

• Method:

– Conduct interviews with manufacturers

– Collate the interview results and prepare a summary of the major issues and outcomes

– Industry cash-flow analysis


104

Manufacturer Subgroups

• DOE will identify any subgroups that may be disproportionately affected by efficiency standards

• DOE will identify small businesses and conduct a Regulatory Flexibility Act analysis to determine the impacts of any standards these manufactures

• DOE will identify and consider the impact of multiple product-specific regulations on the manufacturers


Cumulative Regulatory Burden

105

Request for Comment

Item 14-1: DOE seeks comments on the subgroups of the fan equipment manufacturers that it should consider in a manufacturer subgroup analysis. Item 14-2: DOE seeks comments on what other existing regulations or pending regulations it should consider in its examination of cumulative regulatory burden. Item 14-A: DOE seeks comment on small businesses that could be impacted by potential energy conservation standards for commercial and industrial fans, as well what these impacts might be.


106

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Customer Subgroup Analysis

Revise Preliminary Analysis

Emissions Analysis and Monetization

Regulatory Impact Analysis


Life-Cycle Cost & Payback Period Analysis


Framework Document


NOPR Final Rule

Effective Date

NOPR Analyses

107

• Purpose:

– Analyze the economic impacts of standards on consumers, including subgroups who may be disproportionately impacted compared with the general user population

• A subgroup comprises a subset of the population likely to be disaffected disproportionately by new or revised energy conservation standards

• Method:

– Extend the LCC analysis to examine the impacts for defined subgroups

– DOE will use inputs specific to each of the considered consumer subgroups


108


Request for Comment

Item 13-1: DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for fans.

109











Framework Document


NOPR Final Rule

Effective Date

NOPR Analyses

110

• Purpose:

– Assess the overall impacts on domestic energy supplies that would result from the imposition of standards

• Method:

– DOE proposes to use NEMS-BT, a variant of the NEMS (National Energy Modeling System) developed and used by DOE/EIA for their Annual Energy Outlook (AEO) report, as the basis of the Utility Impact Analysis

– Outputs of the utility impact analysis include projections of electricity sales, price, and avoided capacity resulting from a comparison of base and standards cases

– DOE will model the energy savings impacts from amended energy conservation standards using NEMS-BT to generate projections that deviate from the AEO reference case


111


Request for Comment

Item 15-1: DOE welcomes input from interested parties on its proposed approach to conduct the utility impact analysis.

112











Framework Document


NOPR Final Rule

Effective Date

NOPR Analyses

113


• Purpose:

– Assess the overall impact on national employment from the imposition of efficiency standards at differing levels

– Include both direct and indirect employment impacts

• Direct employment impacts are estimated in the manufacturer impact analysis

• Indirect employment impacts result from shifting consumer expenditures among goods and services ( “substitution effect”) and changing equipment and energy costs (“income effect”)

• Method:

– DOE intends to use the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect employment impacts


114


Request for Comment

Item 16-1: DOE welcomes comments on its proposed approach to assessing national employment impacts.

115











Framework Document


NOPR Final Rule

Effective Date

NOPR Analyses

116

• Purpose:

– Estimate environmental impacts from potential energy conservation standards for fans including changes in Full Fuel Cycle (FFC) emissions

• Method:

– DOE will base the emission factors for FFC on EIA’s Annual Energy Outlook, supplemented by data from other sources. The following emissions are assessed:

• Carbon dioxide (CO2)

• Sulfur dioxide (SO2)

– SO2 emissions from affected electric generating units are subject to nationwide and regional emissions cap and trading programs

• Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern States and DC

• Methane (CH4)

• Nitrous Oxide (N2O)

• Mercury (Hg)

Emissions Analysis

117

• DOE intends to use the most current Social Cost of Carbon (SCC) values developed by interagency reviews

– SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including but not limited to agricultural productivity loss, human health effects, property damage from rising sea level, and changes in the ecosystem

• At present, the most recent interagency estimates of the potential global benefits resulting from reduced CO2 emissions in 2015, expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton avoided

– For emission reductions that occur in later years, these values grow in real terms over time

• DOE will also estimate the potential monetary benefit of reduced NOx emissions resulting from the considered standard levels

Monetization of Emission Reductions

118

Request for Comment

Item 17-1: DOE welcomes comments on its proposed approach to analyzing emissions impacts on potential standards for commercial and industrial fans.

Emissions Analysis & Monetization

119











Framework Document


NOPR Final Rule

Effective Date

NOPR Analyses

120


• Purpose:

– Explore the potential for non-regulatory alternatives to new energy efficiency standards

• Method:

– Base the assessment on the actual impacts of any such initiatives to date, but consider information presented regarding the impacts that any existing initiative might have in the future

NOPR Analyses

121

5

3

2




1 Introduction



7 Closing Remarks


122

How to Submit Written Comments

In all correspondence, please refer to the Commercial and Industrial Fans and Blowers rulemaking by:

– Framework Document for Commercial and Industrial Fans and Blowers – Docket Number: EERE-2013-BT-STD-0006 – Regulatory Identification Number (RIN): 1904-AC55

Electronic: [email protected] or www.regulations.gov

Postal Mail: Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE-2J 1000 Independence Avenue, SW Washington, DC 20585-0121

Courier: Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program Sixth Floor, 950 L’Enfant Plaza, SW Washington, DC 20024

Telephone: (202) 586-2945

Comment period closes: May 2, 2013

Closing Remarks

mailto:[email protected]

http://www.regulations.gov/

Documents

Energy Conservation Standards for Commercial & Industrial ... · compliance with any standards set for commercial and industrial fans – In addition to energy conservation standards,