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The U.S. Department of Energy (DOE) on April 20 released a pre-publication draft of a final rule establishing a test procedure for commercial and industrial fans and blowers, including air-circulating fans.
The draft follows a notice of proposed rulemaking (NOPR) issued in July 2022 and a public review period that concluded in September 2022, during which AMCA and many other industry stakeholders submitted comments.
An initial review of the test procedure indicates the negotiated “ASRAC term sheet” published in 2015 is largely being honored. Following is a summary of how the DOE ruled on items of primary concern to AMCA and its members:
- For the testing of non-circulating fans, one-unit samples will be permitted. For the testing of circulating fans, two-unit samples will be required.
- Fan energy index (FEI) will be the metric for non-circulating fans. For circulating fans, the metric will be cubic feet per minute per Watt (cfm/W).
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The requirement that all appurtenances sold with non-circulating fans be tested was withdrawn; appurtenances sold with non-circulating fans will be handled in accordance with Section 7.3 of ANSI/AMCA Standard 214-21, Test Procedure for Calculating Fan Energy Index (FEI) for Commercial and Industrial Fans and Blowers.
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ANSI/AMCA Standard 230-23, Laboratory Methods of Testing Air Circulating Fans for Rating and Certification, will be the test procedure for circulating fans with electrical input power of 125 W or more.
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The test procedure will take effect 30 days after it is published in the Federal Register. The deadline for compliance will be 180 days after the test procedure is published. Thus, it appears the compliance date for the DOE test procedure will be very close to the Nov. 16, 2023, compliance date for the efficiency regulation for commercial and industrial fans and blowers approved by the California Energy Commission (CEC) as part of Title 20, Public Utilities and Energy, of the California Code of Regulations.
- Compliance with the test procedure is required only if FEI or cfm/W ratings are marketed or publicized in any way (e.g., nameplates, brochures, software outputs). AMCA staff is investigating this nuance, but it appears it may have utility to industrial-fan manufacturers. This option will go away when the DOE publishes an energy standard setting minimum efficiency requirements for all covered fans.
Further analysis is needed regarding stipulations for embedded fans and default values for fans tested without a motor and drive.
“The test procedure has been substantially improved since the draft the DOE published in July 2022,” AMCA Senior Director, Global Affairs Michael Ivanovich said. “There remain some tough spots in the regulation, but, given the hard line the DOE has taken with other regulated products, things could have been much worse. The North America Region Air Movement Advocacy Committee, chaired by Christian Taber, Big Ass Fans, and its Energy Efficiency Subcommittee, chaired by Mark Bublitz, New York Blower, worked hard with AMCA staff to diplomatically challenge the DOE on provisions that would have severely damaged the fan industry.
“Staff and members need to work together to ensure everyone understands how to apply the regulation correctly,” Ivanovich added. “Look for future webinars on this topic.”
The test procedure eventually will be adopted by Canada, which has a memorandum of understanding with the DOE to adopt DOE standards.
AMCA will provide additional analysis and communications related to the test procedure in the coming weeks. In the meantime, AMCA members are advised to begin reviewing the test procedure and assessing its impact on their business, participate on AMCA committees, and attend related AMCA webinars.
With the test procedure finalized, the DOE is expected to publish a draft energy standard later this year. The energy standard will set minimum FEI requirements for covered fans and describe marking, filing, and surveillance requirements. Once the final energy standard is published, which is expected to be in 2024, a grace period of five years will commence. Thus, California’s and other states’ regulations would remain in effect until 2029. For the foreseeable future, California’s is expected to remain “as is.”
For more information, contact Ivanovich at mivanovich@amca.org or Senior Manager, Advocacy Aaron Gunzner, PE, at agunzner@amca.org.
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