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3 Energy Groups Issue Public Comment on Energy Efficiency & Renewable Energy Office Proposed Rule


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    WASHINGTON, Nov. 18 -- Three Energy Groups have issued a public comment on the Energy Efficiency and Renewable Energy Office proposed rule entitled "Energy Conservation Program: Test Procedures for Fans and Blowers; Request for information". The comment was written on Nov. 15, 2021, and posted on Nov. 16, 2021:

    The comment was co-signed by Patrick Eilert, manager for codes and standards at Pacific Gas and Electric Co.; Karen Klepack, senior manager, building electrification and codes and standards at Southern California Edison; and Kate Zeng, ETP/C&S/ZNE manager for customer programs at San Diego Gas and Electric Co.

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    This letter comprises the comments of the Pacific Gas and Electric Company (PG&E), San Diego Gas and Electric (SDG&E), and Southern California Edison (SCE) in response to the United States (U.S.) Department of Energy (DOE) Request for Information (RFI) on Test Procedures for Air Circulating Fan Heads (ACFH).

    The signatories of this letter, collectively referred to herein as the California Investor-Owned Utilities (CA IOUs), represent some of the largest utility companies in the Western U.S., serving over 32 million customers. As energy companies, we understand the potential of appliance efficiency standards to cut costs and reduce consumption while maintaining or increasing consumer utility of products. We have a responsibility to our customers to advocate for standards that accurately reflect the climate and conditions of our respective service areas, so as to maximize these positive effects.

    We appreciate this opportunity to provide the following comments about this RFI. We commend DOE for seeking to clarify how test procedures should apply to different types of air circulating fans (e.g., ACFHs, ceiling fans, personnel coolers, and agricultural fans). We agree with DOE that ACFHs should be more clearly distinguished from ceiling fans and suggest that the efficiency metric for these fans be based on Fan Energy Index (FEI), per AMCA 214-21. We recommend that DOE begin a rulemaking to regulate all other commercial air circulating fans as soon as possible.

    1. The CA IOUs suggest that DOE add further specificity to the definition of ACFH.

    After discussion with the Air Movement and Control Association (AMCA), the CA IOUs recommend that DOE add the following sentences (bolded below for emphasis) to the definition of ACFH to the existing definition in ANSI/AMCA Standard 230-15: Laboratory Methods of Testing Air Circulating Fans for Rating and Certification/1 to distinguish ACFHs from ceiling fans and other air circulating fans such as personnel and livestock coolers:

    "An assembly consisting of a motor, impeller, and guard for mounting on a pedestal having a base and column, wall mount bracket, ceiling mount bracket, I-beam bracket, or other commonly accepted mounting means. ACFHs do not have housings with solid walls such as tubes, boxes, or panels. An ACFH has a maximum value of diameter-to-maximum operating speed ratio of 0.06 in/RPM (inch per revolution per minute)" [emphasis added].

    This addition would clarify that ACFHs are basket-type fans that do not have solid housings. As shown in Figure 1 below, the fan on the left would be considered an ACFH per the suggested definition, while the fan on the right with the solid housing would not. The diameter-to-maximum operating speed ratio will further distinguish these products from ceiling fans, which have a higher diameter-to-maximum speed ratio.

    Figure omitted: https://downloads.regulations.gov/EERE-2021-BT-TP-0021-0009/attachment_1.... The CA IOUs suggest that DOE use the Fan Energy Index (FEI) metric from AMCA 214-21 for ACFHs.

    In this RFI, DOE suggests using the fan electrical input power (FEP) metric, obtained according to ACMA 214-21, for adoption in the test procedure for ACFHs. However, FEP on its own is not an efficiency metric. FEP is a measurement of the fan's input power, taking motor, motor controller, and transmission losses into account. The CA IOUs believe that FEI, which is a ratio of the product's FEP to the electrical input power of a reference fan, is a more appropriate metric for these products. FEI will also account for the air velocity generated by the fan, which is an important consideration for ACFHs, since one of the primary services of an ACFH is to deliver a focused airstream at a relatively moderate to high velocity. Additionally, FEI has become the default metric for fans in building codes and incentive programs. It is the efficiency metric used in ASHRAE 90.1, IECC, and the California Energy Code. We note that since FEP and ACFH airflow in cubic feet per minute is needed to calculate overall efficiency and efficacy per AMCA 230-15, testing labs and manufacturers can still report those metrics in their product literature without additional burden.

    3. We encourage DOE to start a rulemaking as soon as possible to regulate other commercial air circulating fans.

    The CA IOUs recommend that DOE regulate all commercial air circulating fans not currently covered, which could be defined as having a minimum power draw threshold such as 125 Watts.2 Personnel and agricultural fans that have solid housings or that may not meet the diameter-to maximum operating speed ratio should be regulated but are not considered ACFHs. There is support by the industry to regulate all commercial air circulating fans, and we recommend that DOE undertake an additional rulemaking(s) to cover them.

    In conclusion, we would like to reiterate our support for DOE's Request for Information on ACFHs and support moving forward with this rulemaking. We thank DOE for the opportunity to be involved in this process.

    Sincerely,

    Patrick Eilert, Manager, Codes & Standards, Pacific Gas and Electric Company

    Karen Klepack, Senior Manager, Building Electrification and Codes & Standards, Southern California Edison

    Kate Zeng, ETP/C&S/ZNE Manager, Customer Programs, San Diego Gas & Electric Company

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    Footnotes:

    1/ https://www.amca.org/publish/publications-and-standards/amca-standards/a... IEC 60879 International Standard: Comfort fans and regulators for household and similar purposes - Methods for measuring performance limits the scope of household fans to having a rated input power less than 125 W.

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    The proposed rule can be viewed at https://www.regulations.gov/document/EERE-2021-BT-TP-0021-0001">https://... NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, mailto:editor@targetednews.com">editor@targetednews.com, Springfield, Virginia; 703/304-1897; https://targetednews.com">https://targetednews.com

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