Appliance Standards Awareness Project American Council for an Energy-Efficient Economy

In the NOPR, DOE proposes to allow manufacturers to make representations at non-compliant operating points provided that the representations include a disclaimer;5 the Department further states that the manufacturer would be responsible for ensuring that a fan is not sold and selected at non-compliant operating points. [...] In other words, while a user could see the full operating range for each of the fans that are compliant at the user-specified operating point, the user would be unable to see noncompliant fans. [...] In the NOPR, DOE excludes some but not all types of embedded fans from the scope of the analysis;12 most of the proposed exclusions are for regulated equipment where the efficiency metric includes fan energy use. [...] Using an existing larger diameter fan at a lower speed to deliver the same airflow as a smaller fan is a common way to improve FEI at a given operating point and may be a likely path to meeting the proposed standards for some fan installations. [...] Therefore, we encourage DOE to develop an equaon-based standard for ACFs that considers airflow in order to avoid large jumps in the standards as diameter increases and to account for the fact that ACFs of the same diameter may deliver very different airflows.