Manufacturers of Industrial-Process Equipment, Beware: Soon-to-Be-Finalized Regulation Poses Significant Burdens

Date: 2024-10-28 14:36:00

By Doug Yamashita

(Editor’s note: This article was published in the 2024 edition of AMCA inmotion magazine.)

Regulation has come to the U.S. market for commercial and industrial fans and blowers in the form of a test procedure published by the U.S. Department of Energy (DOE) that took effect Oct. 30, 2023, and an accompanying energy-conservation standard that is expected to be finalized by the close of 2024. If my conversations with manufacturers of industrial-process equipment across the United States are any indication, many are underinformed and ill-prepared for the redirection of engineering, design, testing, production, marketing, sales, and information-technology resources they face if the fans and blowers they are sourcing become unavailable because of noncompliance.

This article will provide a brief overview of the regulation and identify likely burdens and potential risks for industrial-process-equipment manufacturers.

The Regulation

The test procedure provides definitions, metrics, and test methods, while the proposed energy-conservation standard covers minimum levels, compliance, marking, and surveillance. The test procedure can be found in the Code of Federal Regulations, Title10, Energy; Chapter II, Department of Energy; Subchapter D, Energy Conservation; Parts 429 and 431, while the proposed energy-conservation standard (Document ID: EERE-2022-BT-STD-0002-0140) can be found at www.regulations.gov.

The regulation will apply to makers of complete fans manufactured or imported for sale in the United States. It will indirectly impact system designers, as certain operating points for certain fans no longer will be compliant. It is expected to become effective in late 2029—five years after the energy-conservation standard is finalized—and apply to all fans manufactured on or after that date. It will not apply to replacement fan components but will apply to equipment manufacturers that source wheels and cones from fan suppliers and incorporate them into their own fabricated fan housings and plenum assemblies.

The power range of the regulation is 1 hp at the fan shaft to 150-hp fan output power. (Fan output power is a value calculated with the flow rate and pressure of a given operating point.) Essentially, that translates to a 175- to 200-hp motor.

Fan Energy Index

The metric for determining compliance under the regulation will be fan energy index (FEI). For ease of use in codes and standards, FEI is a non-dimensional value reflecting the electrical-power consumption of a given fan at a specific operating point relative to the electrical-power consumption of a “reference fan” at the same operating point, with a minimum defined efficiency baked into the calculations:

For a more in-depth understanding of FEI, refer to ANSI/AMCA Standard 214-21, Test Procedure for Calculating Fan Energy Index (FEI) for Commercial and Industrial Fans and Blowers (available to download free of charge here). The reference fan is explained in Section 5.

So that it is applicable across a broad range of fan types, FEI relies on electrical-power measurement at the wall (wire-to-air [W2A] principal), rather than at the traditional fan shaft. This will result in a corresponding shift in power values in catalogs and selection software.

FEI has been utilized in commercial-construction codes and standards for years, with the typical requirement for general fans and blowers being an FEI greater than or equal to 1.0. It should be noted that, distinct from these codes and standards as well as Title 20, Public Utilities and Energy, of the California Code of Regulations, the DOE regulation introduces nine primary equipment classes with different FEI requirements:

axial inline
axial panel
axial power roof ventilator
centrifugal housed
centrifugal unhoused
centrifugal inline
radial housed
centrifugal power roof ventilator, exhaust
centrifugal power roof ventilator, supply

FEI is based on the fundamental characteristics of a fan—flow rate, pressure, and efficiency—and calculated for every combination of flow rate and pressure. The basis of FEI, then, is that the point of operation on a fan curve, not the fan itself, is limited. This is important, as the location of an operating point on a fan curve impacts the power consumption of the fan. The result is that fan-system designers choose fans operating in the most efficient region of their performance envelope (Figure 1).

The FEI Bubble

A fan is not a simple appliance that consumes a relatively fixed amount of energy when operated. Rather, it is a pressure-dependent device that delivers a specific flow rate and consumes a specific amount of power based on actual system resistance. The fan curve represents a continuum of flow rate and pressure for a given speed. When speed is extended across the allowable range of a fan, an allowable zone of compliant performance points—commonly referred to as an “FEI bubble”—is generated (Figure 2).

Exclusions

Like California Title 20, the proposed DOE regulation excludes safety fans and high-temperature fans. The regulations also are in agreement concerning the exemption of fans and blowers embedded in the equipment listed in Paragraph (a)(3) of Code of Federal Regulations Title 10, Energy; Chapter II, Department of Energy; Subchapter D, Energy Conservation; Part 431, Energy Efficiency Program for Certain Commercial and Industrial Equipment; Subpart J, Fans and Blowers; Section 431.174, Test Procedure for Fans or Blowers. Where the regulations significantly differ is on the matter of embedded fans as defined in ANSI/AMCA Standard 214-21—that is, fans “part of a manufactured assembly where the assembly includes functions other than air movement.” This definition describes most industrial-process equipment. California Title 20 has evolved to exempt fans and blowers that are available only as part of manufactured assemblies. The proposed DOE regulation does not allow for this broader embedded-fan exemption.

FIGURE 1. FEI requirements will lead to better fan selections.

FIGURE 2. FEI bubble of compliant operating points.

Areas of Concern

Considering the diversity and demanding nature of industrial applications—the venerable resource “Fan Engineering: An Engineer’s Handbook on Fans and Their Applications”¹ devotes two chapters to commercial applications but eight to industrial, many of which have constraints for proper and safe operation and requirements for durable design that take priority over energy efficiency—four aspects of the proposed DOE regulation should be of particular concern to industrial-process-equipment manufacturers:

very high FEI levels
the inclusion of embedded fans
the inclusion of open radial-bladed impellers above 30 in. in diameter and greater than 3-in. wide
the 150-air-horsepower upper end of the power range

FEI levels. The proposed FEI levels are dramatically higher than the 1.0 in California Title 20; Title 24 of California’s Building Energy Efficiency Standards (Energy Code); ANSI/ASHRAE/IES Standard 90.1, Energy Standard for Buildings Except Low-Rise Residential Buildings; and the International Energy Conservation Code (IECC). Even the more stringent “stretch” codes of these base codes and standards set a premium level of only 1.1.

Equipment designers undoubtedly will have to select larger fans for their given operating points or choose a different type of fan, which may present challenges in matching the utility, outlet airflow distribution, and velocity profile of the original fan.

Embedded fans. The inclusion of California Title 20-defined embedded fans is the aspect of the proposed DOE regulation most impactful to industrial-process-equipment manufacturers, as their equipment typically includes functions other than air movement.

Larger open radial-bladed fans. With their airborne abrasive materials, industrial processes such as dust collection and material handling can be very hard on fan wheels. The optimal wheel style for withstanding such harsh conditions for a reasonable period of time is open radial-bladed. Unfortunately, wheels optimized for energy efficiency in ventilation applications do not have the design characteristics to withstand harsh industrial environments. The regulation likely will result in fans that are more energy-efficient but have shorter life cycles.

High-horsepower industrial applications. With the 150-hp-fan-output-power upper end of the power range, the proposed regulation will impact a significant portion of the marketplace. Ninety-eight percent of the records in the 90,000-record Life-Cycle Cost database maintained by the DOE represent fans with power levels below 50 hp. This means there are likely to be unintended consequences for manufacturers and buyers of the underrepresented fans above 50 hp.

Additional Concerns

Extensive product-design resources will be required. When cost was the primary driver, smaller, less expensive fans typically would be chosen over larger, more efficient fans. The regulation will shift design decision-making to larger, more efficient fans. As a result, equipment manufacturers may have to redesign and extensively reconfigure their systems, if a larger fan will not fit within the available space.

Extensive research and development likely will be required to maintain a system’s operation based on a new configuration or just a different outlet airflow distribution and velocity profile. A larger fan certainly will have more mass and require a structural review of the support system. Third-party recertification may be required for products governed by other codes and regulations. Lastly, new performance data will have to be collected and new technical, sales, and marketing materials created. In effect, manufacturers will be launching new products. Existing business plans will be affected by these unexpected tasks. Given the nature of regulations to expand in scope and increase in stringency, these additional resources are likely to be necessary for some time.

Some industrial-process-equipment manufacturers will be considered fan manufacturers. Under the regulation, manufacturers that source wheels and cones from fan suppliers and incorporate them into their own fabricated fan housings and plenum assemblies will be regarded as fan manufacturers and be subject to potentially substantial fines for noncompliance. They will have to devote a new level of resources to ensuring their fans are compliant, including documenting air performance and power and labelling products.

Fan-performance-testing resources will be strained. With the specter of substantial fines for excessive energy consumption, accurate fan-performance testing by an experienced laboratory will be vital. As a 2029 effective date draws nearer, a surge in demand for fan testing that significantly outstrips capacity is envisioned.

Many replacement fans will not fit existing installations. One of the most difficult challenges facing equipment manufacturers concerns the replacement of fans in installed equipment with compliant fans of equal size. Typically, smaller fans are chosen over larger fans in a prioritization of cost over efficiency. In such cases, if a duplicate replacement fan is not compliant, a larger fan may be. The customer, then, will have to invest in the design work necessary to modify the equipment to accommodate the larger fan. If space is limited and a larger fan cannot be accommodated, the entire assembly will be rendered defunct.

To Learn More

Fan engineers across the nation have reviewed the DOE regulation and, through the coordination of Air Movement and Control Association (AMCA) International, produced a comprehensive document of comments, suggestions, and questions (www.regulations.gov, Docket ID: EERE-2022-BT-STD-0002-0166). Review of this document to quickly familiarize oneself with the insights and concerns of the companies most directly impacted by the regulation is highly recommended.

In particular, the comments submitted by Donaldson Company Inc. and the American Boiler Manufacturers Association (ABMA) are representative of the thoughts, concerns, and perspectives of many industrial-process-equipment manufacturers. Their key concerns are the high FEI levels, the inclusion of ANSI/AMCA Standard 214-21-defined embedded fans, downstream impacts of the regulation, and distinct differences between commercial-ventilation and industrial-process equipment. Both Donaldson Company Inc. and the ABMA request that the FEI levels start lower and that the DOE align the regulation with the original version of California Title 20 in regard to exemptions.

Conclusion

System efficiency is the mathematical product of component efficiencies. From my days as a fan design and applications engineer, it has been evident that fan engineers wish fans would be selected where they had been designed to operate, in the optimally efficient region of the fan curve. Although the work may be difficult, the proposed regulation will align with the trend in commercial building codes of funneling system designers to more efficient fan selections and, thus, more efficient systems while raising the floor so more efficient systems are not necessarily at a cost disadvantage.

Once awareness of this new era of fan regulation has risen and industrial-process-equipment manufacturers have adjusted their approach to product development, changes to scope and efficiency levels will be absorbed more easily.

Reference

Jorgensen, R. (Ed.). (1983). Fan engineering: An engineer's handbook on fans and their applications (8th ed.). Buffalo: Buffalo Forge.

About the Author

Doug Yamashita is vice president, OEM sales, for The New York Blower Co. Prior to joining New York Blower in 2022, he spent nearly 30 years in the industrial-and-commercial-fan market as executive vice president of sales and marketing for Acme Engineering & Manufacturing Corp. and as a sales engineer for Howden Buffalo and Novenco. He served for 10 years on the Air Movement and Control Association (AMCA) International board of directors, including as president (2017-2018) and chairman (2018-2019).