Fan Efficiency Regulations in the United States
U.S. regulation of energy efficiency for commercial and industrial fans (CIF), i.e., those analogous to fans covered by EC 327 Lot 6, is still incomplete after more than a decade since rulemaking efforts started. The regulatory effort can be divided into three eras defined by presidential administrations. In 2011, during the Obama Administration, the U.S. Department of Energy (USDOE) initiated a CIF rulemaking in June 2011 by publishing a preliminary determination that USDOE had the authority to regulate CIF. This effort culminated in 2015 with a "term sheet" publicly negotiated by USDOE and stakeholders representing manufacturers, advocacy organizations, and industry associations. The term sheet outlined a proposed structure of a USDOE fan-efficiency regulation, including scope, metrics, and types of fans to be included and excluded. The term sheet was important in that it solidified support for two new fan efficiency metrics, Fan Electrical Power (FEP) and Fan Energy Index (FEI). FEP and FEI are known as wire-to-air metrics because they consider the impacts of fans, motors, and drives toward the calculation of the metrics. Also, FEP and FEI can be calculated at any point on the fan-performance curve, enabling part-load efficiency determinations.
Progress on the fan regulation then stalled during the Trump Administration by executive order halting new USDOE regulations. Air Movement and Control Association (AMCA) International remained engaged in fan regulation during this time, first by completing two standards – AMCA 207, for determining part-load losses of certain motors and drives, and AMCA 208, for calculating the Fan Energy Index, and then by advocating for the adoption of the FEI metric in model energy codes that would ultimately be adopted into state energy codes. ASHRAE Standard 90.1-2019 and the 2021 International Energy Conservation Code adopted FEI, referencing ANSI/AMCA 208-18. Florida and Oregon became the first states to use FEI in state energy codes, followed by California for its 2022 commercial energy code. Also during this time, the California Energy Commission initiated development of a fan regulation under its state authority for appliance efficiency regulations, known as Title 20. Early work on the yet-incomplete regulation adopted much of the 2015 USDOE term sheet and the FEI metric.
Also during the Trump administration, AMCA integrated portions of AMCA 207 and 208 into an FEI “test procedure” that could be adopted by regulators, referencing ANSI/AMCA 210 and ISO 5801 as test methods for CIF. ANSI/AMCA 214 was published in January 2021, at the start of the Biden Administration, with the purpose “to aid federal and state rulemaking efforts to establish energy-efficiency standards for commercial and industrial fans and blowers, providing a consistent method of calculating FEI…”
In 2021, USDOE published a final determination that it had the authority to regulate CIF, signaling a re-start of the CIF rulemaking. In doing so, USDOE adopted the AMCA 214 definition of Fan, and, in a separate preliminary rule, expanded the scope of the CIF regulation to cover circulating fans that are not ceiling fans.
This presentation will outline how CIF are currently regulated in U.S. state energy codes and where a federal CIF regulation seems to be heading based on the 2015 term sheet and the draft California CIF regulation.