Redundant Regulations?

The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) has opposed the DOE’s intent to regulate commercial and industrial fans and blowers since the DOE first acknowledged it had the authority to implement such standards nearly two years ago. And now, AHRI contends, the DOE is attempting to regulate equipment that is already well regulated by the industry.

“We feel that regulating fans and blowers by the DOE is inappropriate for the simple reason that they’re already being regulated through ASHRAE Standard 90.1,” said Karim Amrane, vice president of regulatory policy and research for AHRI. “It’s an additional burden on manufacturers.”

“It’s a 79-page framework document, and as far as 90.1 is concerned, the only mention of that standard is one of the addendums that mentions the fan efficiency grade,” said Aniruddh Roy, regulatory engineer, AHRI. “There’s no mention of the tables or the sections that discuss fan energy consumption.”

ASHRAE Standard 90.1, “Energy Standard for Buildings Except Low-Rise Residential Buildings,” was first published in 1975 and has been updated numerous times as technology has advanced in the industry. It was recently amended to include revisions affecting minimum-efficiency requirements for many types of HVAC equipment, including fans. The standard has been adopted by many states, which apply the rules to commercial construction or retrofit projects.

While AHRI asserts that any additional standards from the DOE would be unwarranted and redundant, Armane said if DOE does decide to go down the regulatory path, AHRI will work with the agency.

“Obviously, we will submit comments and interact with them on a personal level as we do in all rulemakings, with an eye toward making the final rule as palatable as possible for the industry,” he said.

Michael Ivanovich, director of strategic energy initiatives for the Air Movement and Control Association Intl. (AMCA), agreed that changing current industry standards could result in an increased regulatory burden on manufacturers.

“Essentially, the scope covers almost every type and size of fan for commercial and industrial applications,” Ivanovich said.

“This is a concern because more than 80 percent of AMCA’s members are small businesses making less than $10 million per year in revenue. Having to adjust fan designs, factory tooling, marketing, distribution, etc. all at once could be devastating.”

Working Together

AMCA and its members, which manufacture air system components, expressed some concern over how the DOE intends to develop these standards.

“We believe, and have been advised that, DOE will regulate fans if it wants to regulate fans, so it’s better to collaborate and shape the regulation in a proactive way,” Ivanovich said. “Some members are extremely upset by what they perceive as government intrusion.”

Ivanovich acknowledged other members see regulation as a growth opportunity for larger, more efficient fans, resulting in the potential for higher profit margins.

“These members also believe customers will benefit from less noise, longer life, and lower operating expenses,” he said. “AMCA listens to all of its members and our positions are based on consensus. The consensus at this time is that it’s better to collaborate with DOE and other stakeholders to shape regulation.”

In its July 26, 2011 comments to the DOE, AMCA pointed out that fans and blowers are already regulated by the industry and encouraged the DOE to adopt the terminology and testing procedures already put in place by AMCA, ASHRAE, and ANSI (American National Standards Institute), in lieu of researching and developing its own set of definitions and testing procedures.

“In preparing the framework document, DOE reviewed AMCA test standards for rating fan efficiency, and it appears they were regarded as good standards,” Ivanovich said. “This is critical because DOE has to either adopt existing test standards in whole or start from scratch. AMCA’s primary test standard is jointly sponsored by ASHRAE and it is ANSI accredited. It’s also harmonized with the ISO fan test standard.”

Tony Rossi, vice president of marketing for Greenheck Fan Corp., said developing effective energy- efficiency standards will take hard work and cooperation with the DOE and other organizations.

“It is very difficult to develop a single energy standard for fans and blowers, due to the fact that there are many different types of fans used in applications that vary greatly,” Rossi said. “Greenheck, other fan manufacturers, and AMCA are committed to working with the DOE to ensure that the standards that are created for regulation help to save energy while being economically practical in applications.”

Industry Voices Concerns

While the DOE gathers information from interested parties, several organizations are concerned that implementing new efficiency standards for fans and blowers could affect other products, too, since a component, such as a fan or blower, often does not behave the same by itself as it would as part of a larger system.

Consequently, altering how a component operates can change the way an entire system functions.

“Air system design, or the efficiency of a fan operating within a system, is a shared responsibility between the manufacturer of the fan, the system designer, and the contractor executing the design,” AMCA wrote in its July 26, 2011 comments to the DOE. “A fan’s efficiency at its operating point is greatly influenced on how it is sized, selected, installed, controlled, and operated within the system. These factors have an influence; an order of magnitude greater than the marginal gains possible when attempting to increase the efficiency of the fan alone. This is well known within our industry and is a subject of research within ASHRAE.”

Roy also expressed concern over regulating component efficiency, saying, “In many cases, these fans work in a part-load capacity, so that’s not the true or accurate way of determining the efficiency of the fan within the appliance system.”

“The realities of the field also take their toll on fan operating efficiency, such as putting 90-degree turns at the fan inlet and outlet without allowing sufficient duct runs for uniform flow to develop,” Ivanovich said. “Leaky ducts, boxes, and terminal devices will also increase fan consumption, and so will poor controls. Regulating the fan’s efficiency, per se, is probably the least effective way to reduce fan energy consumption. However, that’s the only avenue the DOE Appliance and Equipment Standards program has for reducing energy consumption, so that’s the avenue they can take.”

Richard DesJardins, of DesJardins and Associates, Murrieta, Calif., agreed that a component cannot be changed without affecting the whole system. He wrote at length about the negative effects additional efficiency standards could have on cooling towers, specifically, in his March 4 comments submitted to the DOE regarding the framework document.

“I am concerned you may take action that would write undesirable design requirements for fans used on cooling towers and air-cooled heat exchangers,” DesJardins wrote. “You cannot change one thing without it affecting something else. If you change a fan, or make energy demands that limit power consumption, you may cause problems that could cause failures in other areas of the equipment.”

Charlie McCrudden, vice president of government relations for Air Conditioning Contractors of America (ACCA), said he understands why manufacturers and the organizations that represent them are worried. “These are valid concerns,” he said. “I think that’s what DOE is trying to figure out — who are all the stakeholders, and what impact this rulemaking will have on those stakeholders.”

McCrudden added that ACCA is not yet involved and is still reviewing the framework document and deciding whether they’ll comment on the implications for contractors.

Both AHRI and AMCA intend to submit additional comments to the DOE before the comment deadline. If you are interested in commenting on the framework document, visit http://1.usa.gov/XEgxJG.

SIDEBAR: Submitting a Comment to DOE

Comments may be submitted through www.regulations.gov, email, postal mail, or by hand delivery/courier. All comments must be received by June 3. Comments must identify the commercial and industrial fans and blowers energy conservation standards rulemaking by name and provide its docket number EERE-2013-BT-STD-0006 and/or Regulation Identifier Number (RIN) 1904-AC55. Comments may be submitted using any of the following methods:

Federal e-Rulemaking Portal: The rulemaking docket is available at www.regulations.gov. Follow the instructions for submitting comments.

Email: CIFB2013STD0006@ee.doe.gov. Include the docket number and/or RIN in the subject line of the message.

Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE–2J, 1000 Independence Ave., SW, Washington, DC 20585–0121. Please submit one signed original paper copy.

Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L’Enfant Plaza, SW, Ste. 600, Washington, DC 20024. Telephone: 202-586-2945. Please submit one signed original paper copy.

Publication date: 4/29/2013 

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