Record of Communication Concerning Ceiling Fan and Ceiling Fan Light Kit Framework Document Docket No. EERE-2012-BT-STD-0045
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1 A LIMITED LIABILITY PARTNERSHIP 1050 Thomas Jefferson Street, NW Seventh Floor Washington, DC (202) Phone (202) Fax MEMORANDUM TO: FROM: DOE Office of General Counsel Doug Smith DATE: August 29, 2013 RE: Record of Communication Concerning Ceiling Fan and Ceiling Fan Light Kit Framework Document Docket No. EERE-2012-BT-STD-0045 This memo provides an overview of communications made to DOE staff on the subject of possible changes to standards and test procedures for ceiling fans and ceiling fan light kits. The communications occurred at a meeting held at 10:30 a.m. on August 20, 2013, following the close of the comment period on the initial framework document for ceiling fans and light kits. The meeting attendees included: John Cymbalsky (DOE/EERE) Lucy debutts (DOE/EERE) Eric Stas (DOE/OGC) Francine Pinto (DOE/OGC) Aris Marantan (Navigant) Tom Early (Burgess Lighting and Distributing) Dave Turner (Casablanca Fan Company/Hunter Fan Co.) Jeremy Tarr (Casablanca Fan Company/Hunter Fan Co.) Bill Walker (Casablanca Fan Company/Hunter Fan Co.) Rob Godlewski (Emerson Ceiling Fans) Nathan Frampton (Fanimation) Doreen Edelman (Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, for Hunter) Tony Davidson (Kichler Lighting) Tim Flannery (Minka Group) Clark Linstone (Pacific Coast Lighting, Inc.) Ed Kolb (Quorum) David Gatto (Westinghouse Lighting Corporation) Richard Upton (American Lighting Association) Terry McGowan (American Lighting Association) Doug Smith (Van Ness Feldman, LLP, for ALA) - 1 -
2 A group of 25 ceiling fan and light kit manufacturers, distributors and retailers (list attached), organized by the American Lighting Association (ALA), filed timely written comments on issues raised in the Framework Document. The companies in this group represent more than 90% of the annual U.S. sales of ceiling fans and ceiling fan light kits. This meeting was used to elaborate on issues raised in the group s written comments. The agenda for the meeting is attached. Key points made at the meeting included: - Many of the ceiling fan technology options identified in the Framework Document present significant technical, consumer utility, and/or cost problems. DC motors and associated electronic controls, for instance, present reliability issues and have high first costs that are very unlikely to be paid back in energy savings for typical consumers. A number of the technology options would create consumer utility problems, such as occupancy sensors incorrectly turning off a fan in bedrooms when occupants are asleep. - Ceiling fans are often used in conjunction with air conditioning in homes. DOE needs to take this effect into account in evaluating energy savings from any new fan standard, especially if increased first costs for fans drive down fan sales and thereby result in increased AC usage. More research is needed on this AC offset effect. - The primary driver of light fixture efficiency is the lamp, not the light kit. Lamp efficiency is comprehensively regulated by DOE. Further light kit standards are not appropriate. - For light kits with 3 or fewer candelabra sockets, or 4 or fewer intermediate base sockets, there is no need for the power limiter requirement given lamp efficiency standards. The limiter itself is a source of product failure and an added cost to consumers, so the existing requirement for a limiter should be eliminated for light kits with these configurations. - Test procedures that cover fan operation at low, medium, and high speed, such as the existing test procedure, are appropriate. If a single rating value is to be determined based on efficiency at three speeds, DOE will need to specify consumer usage factors. The AccuPoll data submitted by ALA provides a basis for consumer usage factors of: 29% on low; 51% on medium; and 21% on high. Attachments - 2 -
3 ROSTER ALA Industry Coalition Of Ceiling Fan Manufacturers And Retailers Responding To The DOE s Evaluation of Potential New Energy Efficiency Requirements For Ceiling Fans and Ceiling Fan Light Kits Air Cool International, Ltd. American Lighting Association Canarm Ltd. Casablanca Fan Company /Hunter Fan Co. Emerson Ceiling Fans Fanimation Feiss Monte Carlo Kendal Lighting Inc. Kichler Lighting King of Fans Lamps Plus Litex Industries Limited/Ellington Fans/Craftmade Lowe's Companies, Inc. Luminance Matthews Fan Company & WPT Design Maxim Lighting International Minka Group Pacific Coast Lighting, Inc. Progress Lighting, a Division of Hubbell Quorum International Regency Ceiling Fans Savoy House Lighting The Home Depot The Modern Fan Co. Vaxcel International Westinghouse Lighting Corporation 15 August 2013 Prepared By: The American Lighting Association
4 Time: 10:30 AM-1:00 PM Location: 950 L Enfant Plaza, #6162 Washington, D.C. DOE-ALA-Ceiling Fan Industry Meeting Agenda Tuesday, 20 August :30 AM I. Meeting Called to Order A. Introduction of DOE Attendees and Opening Comments B. Response and Introduction of ALA/Ceiling Fan Industry Attendees John Cymbalsky, Supervisor, Appliance Standards, DOE Dick Upton, ALA 10:37 AM 10:40 AM 10:45 AM 10:50 AM 11:05 AM 11:15 AM 11:25 AM 11:40 AM 11:45 AM 11:50 AM 11:55 AM 12:05 PM 12:10 12:15 II. ALA Ceiling Fan Industry Comments and Presentation A. Goals of the Meeting B. Key Points - CEILING FANS 1. Ceiling fan definition 2. Product classes 3. Technology option assessment a. Motors b. Blade design c. Occupancy sensors 4. Residential energy consumption offsetting changes in AC usage C. Key Points - LIGHT KITS 1. Primary efficiency driver is the lamp (not the light kit) 2. LEDs 3. Power limiters 4. Utilization/consumer wants and needs D. Test Procedures E. Legal Issues F. Flexibility to Defer the Rulemaking Clark Linstone, Chair ALA Gov. Affairs Dave Turner, Terry McGowan, ALA T. McGowan/ D. Turner Dave Gatto, Westinghouse Bill Walker, Doug Smith, Van Ness Feldman Jeremy Tarr, 12:30 PM III. Responding to DOE Questions Not Already Discussed D. Upton 12:40 PM IV. DOE s View of Areas Where More Study/Data is Needed A. The Framework Document B. Points made by the Industry today C. Linstone
5 DOE, ALA, Ceiling Fan Industry Meeting 20 August :47 PM 12:50 PM V. Close A. For DOE B. For the Industry J. Cymbalsky D. Upton 12:55/1:00 PM VI. Anticipated Adjournment 2
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