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Federal Register / Vol. 86, No. 232 / Tuesday, December 7, 2021 / Proposed Rules AMCA 23015, that does not have a ceiling mount option, or that has more than one mounting option even if one of the mounting options is a ceiling mount, is not a ceiling fan. Such fans do not meet the statutory criteria of being nonportable, suspended from the ceiling, and for the purpose of circulating air. 84 FR 51440, 51444
51445.
In addition to the alternate proposed definitions, DOE acknowledged AMCAs suggestion of using tip speed or outlet air speed to distinguish between ACFHs and ceiling fans, and requested comment and data on whether and how the test procedure could be amended to accommodate such a distinction. 84 FR
51440, 51445.
In response to the September 2019
NOPR, ALA explained that while the first option is better than the alternative definition, they opposed both options.
ALA stated that the first alternate definition distinguishing ceiling fans based on non-portable and mounting is too broad, could create a loophole for ceiling fans to be exempt from the standards, and that unregulated ceiling fans as a result of this proposed definition would eventually overtake the market. ALA
also stated that the second alternative definition referencing ACFHs and mounting it is too narrow, and products that would be innovative or meet a specific need in the market could not be made or sold. ALA, No. 34 at p.
2 AMCA stated the proposal will provide excessive opportunity for currently regulated fans to escape regulation. Further, AMCA identified three large-diameter ceiling fan LDCF manufacturers that offer or have offered ground-mounted LDCFs and suggested that with the proposed reinterpretation, LDCF manufacturers could chose to offer a floor-mount option for their products and be exempt from standards. AMCA also commented that the proposed definition of portable would open a significant loophole and explained that many LDCFs are not hardwired in place.
AMCA, No. 33 at pp. 23
CA IOUs stated that DOEs proposed interpretation to only address fans offered for mounting on a ceiling in the September 2019 NOPR deviates from the scope of products established under the existing legislation and raises concerns of potential gaming to avoid product testing, as well as potential backsliding for products that would be newly exempted after being included in the previous test procedure iteration.
CA IOUs No. 31 at p. 2

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Hunter commented that further clarification and additional stipulations beyond those proposed by DOE would be required to prevent unwelcomed loopholes and alleviate the possibility of gaming the system to claim an exemption from testing. Hunter No. 29
at p. 2 Anonymous commented that the interpretations put forth in the NOPR
limit the applicability to nonportable ceiling fans that are used to create air circulation, and recommended that the test procedures should apply to all fans, even portable ones that may plug into the wall, and are not necessarily for air circulation. Anonymous, No. 32 at p.
1 As an alternative to DOEs proposal, multiple interested parties recommended that the definition of ceiling fan be based on, in part, a ratio of diameter to maximum operating speed. Specifically, these commenters suggested that a diameter-to-maximum operating speed ratio less than 0.06
inches/RPM could be used to distinguish products that are not ceiling fans, i.e., air circulating fan heads.
Hunter Fans, BAFs, Public Meeting Transcript at pp. 3335, AMCA, No. 33
at pp. 36; ALA, No. 34 at p. 2; and Hunter No. 29 at p. 2. AMCA further recommended that air-circulating fan heads be named as a separate category by DOE. AMCA, No. 33 at p. 5 BAF
suggested that the ratio of diameter inches to the maximum speed RPM
provides a reasonable means for separating air circulating fan heads from LSSD, HSSD and large-diameter ceiling fans. BAF, No. 36 at pp. 12 As a justification of this ratio, AMCA
provided analysis of 528 fan models, which included a total of 397 LDCF, HSSD, and LSSD ceiling fan types, as well as 131 ACFHs. Among the sample of ACFH models, the highest diameterto-maximum operating speed ratio was 0.058, in comparison to the lowest diameter-to-maximum operating speed ratios for the three ceiling fan types 0.353, 0.091, and 0.087 for LDCF, HSSD, and LSSD, respectively.
Therefore, even the maximum ratio for the sample of ACFH models is significantly lower than the minimum ratio for the other ceiling fan types, thus showing a clear distinction between ACFH and other ceiling fan types. Based on this analysis, AMCA recommended that ACFHs be designated as a separate category by DOE in its ceiling fan regulations, and that fans meeting the definition of ACFH per AMCA 230 10
10 Section 5.1.1 of AMCA 23015 defines air circulating fan head as an assembly consisting of a motor, impeller and guard for mounting on a pedestal having a base and column, wall mount
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and having a diameter-to-maximum operating speed ratio less than or equal to 0.06 inches/RPM are not ceiling fans. AMCA, No. 33 at pp. 46
Similarly, Hunter provided data summarizing the ranges of diameter-tomaximum operating speed ratios for a total of 414 fan models representing LDCF, LSSD, and HSSD ceiling fan categories and ACFHs. The data indicated minimum values of the diameter-to-maximum operating speed ratio for the three ceiling fan types of around 0.10, 0.09, and 0.09 for LDCF, HSSD, and LSSD, respectively and a maximum value for ACFHs of around 0.03. Based on this data, Hunter suggested that a ratio of 0.06 would provide a clear separation between ACFHs and all other fan classifications.
Hunter No. 29 at pp. 23
ALA explained, in support of this proposal, that high-velocity fan heads are not used for the purpose of circulating air within the meaning of EPCAs ceiling fan definition as these fans do not create air circulation by discharging air in the downward direction for it to be returned to the intake side of the fan with significant momentum. Instead, ALA commented that high-velocity fan heads provide directional, concreated high speed airflow targeted to a specific location.
ALA, No. 34 at pp. 23
AMCA also provided comments on the extent to which the ceiling fan design criteria in 10 CFR
430.32s1 11 would be applicable for ACFHs. Specifically, AMCA stated that 1 the lighting requirements in 10 CFR
430.32s1i would only apply to a very small portion of the ACFH
market 12 and that AMCA is unaware of any ACFH with an integrated light kit;
2 the adjustable speed requirement in 10 CFR 430.32s1ii could be applicable, as some ACFHs offer multiple operating speeds, but requiring adjustable speeds would add cost to single-speed products; and 3 the capability of reverse fan action requirement in 10 CFR 430.32s1iii would not be applicable because reverse fan action is typically used for air bracket, ceiling mount bracket, I-beam bracket or other commonly accepted mounting means.
11 The ceiling fan design criteria outlined in 10
CFR 430.32s1 are: i Fan speed controls separate from any lighting controls: ii Adjustable speed controls either more than 1 speed or variable speed; ii the capability of reversible fan action, except for A fans sold for industrial applications, B fans sold for outdoor applications, and c cases in which safety standards would be violated by the use of the reversible mode.
12 AMCA explained that dock fans are the only air circulation fans that are typically sold with a light, but the light is typically attached to the mounting arm, not integrated into the fan. AMCA, No. 33 at p. 7

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