Date: 2023-10-30 12:02:00
In a long-anticipated but no less monumental development, regulation has come to the U.S. market for commercial and industrial fans and blowers. Where a federal test procedure and energy standard and a California efficiency regulation stand and where they likely are headed.
Note: This article appears in the 2023 edition of AMCA inmotion magazine.
By MICHAEL IVANOVICH, AMCA International
In developments called “the most significant events … in the history of the industry,”1 the U.S. Department of Energy (DOE) published a test procedure2 and the California Energy Commission (CEC) approved an efficiency regulation3 for commercial and industrial fans and blowers (CIFB), both of which took effect in 2023, with, as of this writing, a compliance deadline of Oct. 30, 2023, for the former and Nov. 16, 2023, for the latter. The road to regulation has been long—12 years—and winding, with changing metrics, standards, energy-code provisions, manufacturer software, and more. The good news is this period of regulatory development is nearing an end; the bad news is there are several more years of “hysteresis” before the regulations are stable.
This article will provide a brief history of fan regulations in the United States, a summary of where the federal and California fan regulations currently stand, and a forecast of impending changes. Its focus is CIFB; large-diameter ceiling fans and circulating fans are addressed in the article “U.S. Regulations for Air-Circulating Fans.”
Fan-Regulation History: Energy Codes
Around 2008, ASHRAE Technical Committee (TC) 5.1, Fans, and the mechanical subcommittee of ASHRAE Standing Standard Project Committee (SSPC) 90.1 were looking to establish minimum-energy-performance standards (MEPS) for fans. They decided on percent efficiency as the metric, setting a minimum efficiency of 65 percent for fans in ANSI/ASHRAE/IES 90.1, Energy Standard for Buildings Except Low-Rise Residential Buildings.
The bodies of experts soon realized that a 65-percent minimum efficiency would eliminate a large portion of fans with diameters of 20 in. (50.8 cm), regardless of how efficient the fans were in larger sizes. This led to the development of a new metric, fan-efficiency grade (FEG), which establishes bands of efficiency so that fans, regardless of size, have the same rating across a model’s efficiency range. Because it approximated a MEPS of 65 percent, a minimum FEG of 67 was established in ANSI/ASHRAE/IES 90.1.
Properties of FEG include:
- Consideration of fan-impeller and bearing losses only—no motor/drive losses are considered.
- Consideration of total efficiency only—static efficiency is not a factor.
- Consideration of full-load operation only.
- Formalized in ANSI/AMCA Standard 205, Energy Efficiency Classification for Fans.
It occurred to TC 5.1 and SSPC 90.1 that, with FEG being the same for smaller and larger fans and first-cost considerations being what they are, system designers could simply specify smaller fans in the FEG 67 band, defeating the purpose of the MEPS. Hence, a sizing window 15 percentage points from peak total efficiency was established to nudge fan selections to larger sizes.
FEG was incorporated into ANSI/ASHRAE/IES 90.1 with the 2013 edition and the International Energy Conservation Code (IECC) with the 2015 edition. Over time, FEG-based provisions were adopted into more than 25 state energy codes.
Fan-Regulation History: Energy Regulations
In June 2011, the DOE initiated a rulemaking for CIFB by soliciting stakeholders for market data as well as input on metrics and standards. Less than two years later, in January 2013, the DOE published a framework document summarizing its findings and describing a possible path forward.
The DOE determined FEG was not a suitable metric for a federal efficiency regulation for fans, explaining:
- A sizing window could not be applied in a product-efficiency regulation, which eliminated the energy savings of FEG.
- FEG considers the fan only; the DOE wanted a metric that also considers motor and drive losses.
- FEG is concerned with full-load operation only; the DOE wanted a metric concerned with part-load operation as well.
In the framework document, the DOE also dismissed fan-motor-efficiency grade (FMEG), setting the stage for the development of a new fan-efficiency metric.
Thus, just as FEG was emerging in U.S. energy codes, its future was scuttled in favor of an undetermined metric.
Air Movement and Control Association (AMCA) International, AMCA International member companies, and other stakeholders responded by developing fan energy index (FEI) and intermediary parameter fan electrical power (FEP). Through a series of public negotiations, the DOE and industry stakeholders made FEP the regulatory metric with FEI allowed “for marketing purposes.” The negotiations concluded in 2015 with the publication of a term sheet that ultimately would guide development of the DOE regulation, which, like all DOE regulations, has two main parts: a test procedure and an energy standard. The rulemaking was not complete at the time Donald Trump assumed the presidency and signed an executive order effectively halting the DOE’s development of new regulations in 2017.
The executive order led to two milestones in the fan regulatory initiative:
- Without a federal test procedure, FEI and FEP needed to be formalized, so AMCA International developed ANSI/AMCA Standard 208, Calculation of the Fan Energy Index, published in 2018.
- The CEC initiated a product-efficiency regulation under Title 20, Public Utilities and Energy, of the California Code of Regulations.
With the publication of ANSI/AMCA Standard 208, AMCA International and other stakeholders began a campaign to replace FEG with FEI in energy codes, beginning with the 2019 edition of ANSI/ASHRAE/IES 90.1 and continuing with the 2021 IECC and Title 24, Part 6, of California’s 2022 Building Energy Efficiency Standards (Energy Code).
In 2020, AMCA International petitioned the DOE to at least finish the CIFB test procedure to establish uniformity in terms of method of test, ratings calculations, and representations. From that point, the thinking was, varying state efficiency requirements could be suffered until a federal energy standard came along and preempted them all. In 2021, after the Biden administration took office, the DOE initiated action to finish the test procedure.
Meanwhile, with the development of product regulations using FEI requiring extractions from and references to four AMCA International standards and publications (ANSI/AMCA Standard 207, Fan System Efficiency and Fan System Input Power Calculation; ANSI/AMCA Standard 208; AMCA Publication 211, Certified Ratings Program Product Rating Manual for Fan Air Performance; and ANSI/AMCA Standard 210/ASHRAE Standard 51, Laboratory Methods of Testing Fans for Certified Aerodynamic Performance Rating), AMCA International published a “test standard” for FEI. That standard, ANSI/AMCA Standard 214, Test Procedure for Calculating Fan Energy Index (FEI) for Commercial and Industrial Fans and Blowers, was adopted by the CEC for its CIFB regulation.
The CEC approved the Title 20 efficiency regulation on Nov. 16, 2022. As of this writing, manufacturers of covered CIFB manufactured for sale in California on or after Nov. 16, 2023, will have to comply. Compliance will mean a fan bears a label and has specified characteristics of fan models filed in the Modernized Appliance Efficiency Database System (MAEDbS). Project engineers and other market participants are to consult MAEDbS before purchasing a fan for installation in California.
On May 1, 2023, the DOE published a final rule establishing a federal test procedure for fans and blowers. In the lead-up to the compliance deadline of Oct. 30, 2023, manufacturers would have to examine their legacy test data and determine if their fans were tested in a manner that would yield performance data greater than or equal to data produced using the federal test procedure. If they were not, the fans would have to be re-tested, be re-rated, have their ratings removed from the market, or be removed from the market themselves. This would be a considerable undertaking, involving changes to software, websites, electronic catalogs, and more. Hard-copy literature, it was determined, could remain in use until being phased out.
Unlike the Title 20 efficiency regulation, the federal test procedure covers embedded fans and circulating fans that are not ceiling fans. Circulating fans in 2022 were added to the federal rulemaking in a way allowing this magazine to treat them separately (see “U.S. Regulations for Air-Circulating Fans”).
Entering the summer of 2023, the future of CIFB regulation appeared set: The fan industry had until Oct. 30, 2023, to be in compliance with the federal test procedure and Nov. 16, 2023, to be in compliance with the Title 20 efficiency regulation. The DOE then would progress to finalizing a federal energy standard, with publication estimated to occur during the first half of 2024. Manufacturers would have three to five years to meet the provisions of the federal energy standard; in the meantime, they would continue to comply with the Title 20 efficiency regulation.
And that, dear reader, was what this article was to focus on—advising engineers, manufacturers, and other air-system-industry stakeholders on how to find and specify CEC-compliant fans, how to distinguish DOE-compliant fans that are outside the scope of Title 20, and where the federal energy standard could lead.
Much of the feeling of certainty regarding the regulations was upset when, during an AMCA International members-only webinar on June 22, 2023, the CEC announced that it had concluded the federal test procedure preempted the Title 20 efficiency regulation and not only would it be adopting the federal test procedure, it would be expanding the scope of the Title 20 efficiency regulation to include embedded fans to the extent the federal test procedure covers embedded fans. The CEC further announced it would be initiating a “language cleanup” rulemaking in mid-September but not extending the Nov. 16, 2023, compliance deadline. Considering the 45 days the rulemaking would be open for public review and comment, the regulation would have been final for only approximately two weeks prior to the compliance deadline.
With that, this much-abridged history of CIFB regulation is complete. The remainder of the article will discuss the federal test procedure, as that much is certain, and the portions of the Title 20 efficiency regulation that seem certain as of this writing.
Title 20 Efficiency Regulation
Technical provisions of the Title 20 efficiency regulation that fan-system designers and procurers need to know about are very few. That is not the case with manufacturers. Resources are available for manufacturers in the members area of the AMCA International website and for the public through the website of California Public Utilities Commission contractor Energy Code Ace.
System designers working on projects in California should know that fans covered by the regulation must be listed in MAEDbS if manufactured after the compliance deadline. As of this writing, the compliance deadline remains Nov. 16, 2023. That may change as a result of the 45-day “language cleanup” rulemaking, however. Energy Code Ace will communicate any new developments through its website.
According to Section 1602 of the Title 20 efficiency regulation: “‘Commercial and industrial fan or blower’ means a rotary-bladed machine used to convert electrical or mechanical power to air power, with an energy output limited to 25 kilojoule per kilogram (kJ/kg) of air. A commercial and industrial fan or blower has a rated fan shaft power greater than or equal to 1 horsepower, or, for fans without a rated shaft input power, an electrical input power greater than or equal to 1 kilowatt (kW); and a fan output power less than or equal to 150 horsepower. They consist of an impeller, a shaft, bearings, and a structure or housing. It may include a transmission, driver, and/or controller at the time of sale.”
The fan types covered by the Title 20 efficiency regulation are:
- Axial inline fan.
- Axial panel fan.
- Power roof ventilator (axial supply and exhaust and centrifugal supply and exhaust).
- Centrifugal housed.
- Centrifugal inline.
- Centrifugal unhoused (includes fans designed for use in a fan array with partition walls separating them from other fans in the array).
- Radial housed.
Per Section 1602, the following are exempt from the regulation:
- Safety fans, meaning: “(1) a reversible axial fan in cylindrical housing that is designed and marketed for use in ducted tunnel ventilation that will reverse operations under an emergency ventilation condition; (2) a fan for use in explosive atmospheres tested and marked according to ISO 80079-36:2016, Explosive atmospheres -- Part 36: Non-electrical equipment for explosive atmospheres -- Basic method and requirements; (3) a Positive Pressure Ventilator; or (4) fans complying with ANSI/UL 705 (August 23, 2021) Standard for Safety for Power Ventilators and listed as ‘Power Ventilators for Smoke Control Systems.’”
- Ceiling fans as defined in Section 430.2 of Code of Federal Regulations Title 10, meaning “a nonportable device that is suspended from a ceiling for circulating air via the rotation of fan blades.”
- Circulating fans.
- Induced-flow fans.
- Jet fans.
- Cross-flow fans.
- Embedded fans as defined in ANSI/AMCA Standard 214-21, meaning fans “part of a manufactured assembly where the assembly includes functions other than air movement,” including embedded fans sold exclusively for replacement of another embedded fan.
- Fans mounted in or on motor vehicles or other mobile equipment.
- Fans that create a vacuum of 30 in. w.g. or more.
- Air-curtain units, meaning: “equipment that produces a directionally controlled stream of air with a minimum width-to-depth aspect ratio of 5:1 and a discharge that is not intended to be connected to unitary ductwork. The controlled stream of air spans the entire height and width of an opening and reduces the infiltration or transfer of air from one side of the opening to the other and/or inhibits the passage of insects, dust, or debris.”
- Fans designed and marketed to operate at or above 482⁰F (250⁰C).
Note that, as of this writing, the definition of safety fan is likely to change and the exemption for embedded fans is expected to go away with the “language cleanup” rulemaking.
Note also that covered fans must bear a permanent label or separate permanent labels noting:
- The name of the manufacturer, the model number, and the date of manufacture.
- Fan-performance boundaries as defined in ANSI/AMCA Standard 214, operating duty points at which FEI is 1.00 or higher and beyond which energy inefficiency results.
A label must be affixed to a fan where it can be read without parts of the fan being removed or a magnifying glass or other instrument being used.
Federal Test Procedure
The jurisdiction of the federal test procedure is the United States, U.S. territories, and, in accordance with a memorandum of understanding between the DOE and Natural Resources Canada, Canada. Like all DOE regulations, it applies at the point of manufacture, meaning imported products are covered.
When the DOE published the final rule for the federal test procedure on May 1, 2023, it did so with a 180-day grace period for manufacturers making voluntary representations (values or ratings) of fan-performance parameters. Hence, the Oct. 30, 2023, compliance deadline. Compliance means all performance representations that are made were calculated using methods and data consistent with the test procedure.
Like the Title 20 efficiency regulation, the federal test procedure establishes the scope of products it governs, permissible metrics and means of calculating those metrics, and more. It does not promulgate energy-efficiency requirements, filing and marking/labeling requirements, compliance-assurance (surveillance) measures, or financial and civil penalties for noncompliance; those will be covered in the federal energy standard currently in development.
While large portions of ANSI/AMCA Standard 214, the original test procedure for the Title 20 efficiency regulation, were adopted for the federal test procedure, the DOE excluded some ratings-calculation sections of ANSI/AMCA Standard 214 that, on the whole, made the federal test procedure considerably different from the test procedure in the Title 20 efficiency regulation. That the CEC decided to switch to the DOE test procedure a little over seven months into the Title 20 efficiency regulation’s 12-month grace period is no minor development, causing hardships for manufacturers of covered fans sold or offered for sale in California.
With changes to the Title 20 efficiency regulation of such significance announced so close to the compliance deadline, AMCA and its members will be seeking an extension of the deadline.
Additionally, it is quite possible the DOE will publish a draft energy standard around the time this edition of AMCA inmotion is distributed. Readers can track the release and resolution of the energy standard through the Federal Register by going here and performing a keyword search for “fans.” Alternatively, readers can stay abreast of developments through the Appliance and Equipment Standards Rulemakings and Notices Web page.
- Arnold, S. (2022). Q&A with new AMCA Executive Director Kevin Faltin and 2022-2023 AMCA President Mark Bublitz. AMCA inmotion, pp. 2-11. Retrieved from https://bit.ly/Faltin_Bublitz
- DOE. (2023, May 1). Energy conservation program: Test procedure for fans and blowers. Federal Register. Retrieved from https://bit.ly/DOE_CIFB
- CEC. (2023). California code of regulations, title 20: Division 2, chapter 4, article 4, sections 1601‐1609: Appliance efficiency regulations. Retrieved from https://bit.ly/ReferenceAce_Title20
About the Author
Michael Ivanovich is senior director, global affairs, for Air Movement and Control Association (AMCA) International. In this role, he works with AMCA committees in North America, Asia, Europe, and the Middle East to develop strategies and tactics that manifest the mission of the association “to advance the knowledge, growth, and integrity of the air-movement-and-control industry.” Most of this work involves energy-efficiency codes, standards, and regulations for fans, dampers, and air curtains. Advocacy arenas include the U.S. Department of Energy, ASHRAE, the International Organization for Standardization (ISO), the International Code Council, and the California Energy Commission.
Three main categories of fans are regulated. As defined by the U.S. Department of Energy, they are:
- Large-diameter ceiling fan—a ceiling fan with a blade span larger than 7 ft (2.1 m).
- Circulating fan that is not a ceiling fan—an air-circulating fan head or other type of circulating fan that is not a ceiling fan that has an electrical input power of 125 W or more.
- Commercial or industrial fan or blower: A rotary-bladed machine used to convert electrical or mechanical power to air power, with an energy output limited to 25 kJ/kg of air. It consists of an impeller, a shaft, bearings and/or a driver supporting the impeller, and a structure or housing. It may include a transmission, a driver, and/or a motor controller.
Types of Regulations
Regulations take many forms:
- Federal test standard—defines procedures, metrics, and other particulars for testing and rating products.
- Federal energy-performance standard—sets minimum efficiency criteria for products and establishes compliance-filing and market-surveillance mechanisms.
- State energy-efficiency regulation—establishes testing and listing/filing requirements and a market-surveillance mechanism for products sold within a state.
- Consensus test standard—typically a method of test for a specific product.
- Consensus rating (calculation) standard—sometimes combined with a test standard, it describes how to calculate one or more metrics used by regulators.
- Commercial model energy code—typically an energy code that is adopted in whole or in part by a state.
- Commercial state energy code—an energy code adopted in its entirety by a state or a specified version of a model energy code or standard adopted and, often, “customized” to local construction practices and policies by a state.
It is important to note:
- Energy codes govern at the point of application, while energy regulations govern at the point of manufacture.
- Consensus test and rating (calculation) standards are foundations for energy codes and regulations.
- Federal test procedures and energy standards have primacy over state regulations and model and state energy codes. Energy codes cannot be more stringent than the federal minimum.
- State energy codes and efficiency regulations tend to harmonize; minimum efficiency levels tend to be the same.
- Update cycles can create messy situations, as energy codes typically are on three-year cycles, test/rating standards are on five-year cycles, and DOE regulations are on six-year cycles.