A discussion paper, Small Fan Unit Product Profile, was launched in May 2012. Stakeholder workshops were held in Melbourne and Auckland in conjunction with the consultation process for a Product Profile for Non-Domestic Fans. Twenty-one written submissions were received. There was little noticeable divergence in the opinions expressed and comments provided between Australia and New Zealand.
The E3 Committee has decided not to progress the regulatory investigation on small fan units any further at this time.
Comments received are summarised in this issues paper.
Issues Paper: Stakeholder Feedback on
Small Fan Unit Product Profile
Key Issues
- Purpose of the Product Profile
Although the energy consumption of an individual small fan unit (fan and motor combination) is minimal, the cumulative consumption of electrical energy by this product type across the equipment stock could be substantial because there are so many units in operation.
The Product Profile for small fan units was developed to prompt discussion on the feasibility of regulatingfan units with input power of 5 to <125 W, and to collect data to proceed with investigations into the potential costs and benefits of regulatory actions. It complemented other E3 work streams as Product Profiles were being developed for fans with an input power of 125W to 500kW, and a Product Profile for electric motors considers extending Minimum Energy Performance Standards (MEPS) to include motors of smaller sizes. Other drivers for this work include the E3 non-domestic refrigeration strategy ‘In from the Cold’.
- Stakeholder responses
Stakeholders expressed concern that the varied applications small fan units would make themdifficult to regulate in a uniform and equitable manner. A discussion of scope should consider whether it is possible to exclude fans based on end-use application.
The most common arguments expressed in the submissions were that small fan units incorporated in appliances should be excluded from any potential MEPS and that it would be difficult to reliably test small fan units. Stakeholders asserted that MEPS should not be considered for small fan units if they are:
a)incorporated into appliances
Widespread concerns about applying MEPS to Small Fan units that are components within appliances relate to complications ranging from the difficulty of identifying which appliances incorporate fan units and how these fan units might be identified to how a fan built into an appliance couldbe tested. As the majority of appliances are imported it would be difficult to ensure components in imported products comply with any regulations.
In some cases the overall efficiency of the appliance could be reduced by fitting compliant efficient fan units that when installed in a product will not operate at the conditions for which they were designed.
b)incorporated into appliances that are regulated by MEPS.
Widespread concern was expressed about the effects of applying MEPS to Small Fan units that are components within appliances that are already regulated by MEPS. It was considered that such regulated products already have a requirement to be designedto meet a minimum level of efficiency. Being limited to using specified efficient components would add complexity and cost.
c)incorporated into heat generating appliances
There is opposition to regulating fan units in appliances that have a primary function of generating heat, such as room heaters, hairdryers, ovens, microwave ovens and various types of gas heaters. Reasons given are that the energy consumed by the fan unit is relatively small when compared to the output of the appliance and therefore efficiency gains wouldbe small. The heat from the fan motor adds to the overall heat output, rather than representing efficiency losses.
d)incorporated into appliances with low duty cycles
Several submissions contended that small fan units incorporated into appliances with low annual hours of operation or short time usage duration,eg. hair dryers and power tools,should be exempt from MEPS regulation as power savings would be small in relation to the cost of achieving them.
e)intended for use as spare parts in appliances
There is a strong view that regulation of small fan units should not apply to units that are required as spare parts for appliances or equipment sold orinstalled prior to the introduction of fan regulations.There are possible safety, performance, dimensional and certification issues with fitting a replacement part that may alter the design conditions of an appliance.
f)incorporated into appliances that use gas as an energy source
An opinion was expressed that any regulation for small fan units should not apply to fan units that are used as components in gas space heaters, gas ducted heaters and gas water heaters. Issues include lack of suitable efficient specialised fan units and the difficulty of testing the fan units used outside of the gas appliance.
- Alternative options
Alternatives to MEPS put forward by a number of submitters include:
a)Extending MEPS to other appliances that incorporate small fan units rather than regulating appliance components such as fan units.
b)Regulating against the use of shaded pole motors. This would force technology in the direction of more efficient permanent magnet or EC type motors.
- Test methods and regulation
There is no recognised standard for measuring the efficiency of fan units < 125 W and there is concern from some stakeholders that:
a)Accurate measurement of small fan unit performance will be difficult due to the low airflow such fans produce and the effect on measured results that any standard tolerances will have.
b)A fan unit integrated into an appliance in a purpose built installation with unique pressure and flow characteristics may not be able to be tested outside of the appliance with meaningful results.
Some submissionsquestion how small fan units that are components in imported products can be checked for compliance.
- Costs
A number of stakeholders feel that if MEPS for small fans coverapplications including fans in appliances, there will be significant costs in design, administration and compliance and this will have serious implications for suppliers of low cost appliances.
By introducing MEPS for small fan units ahead of other countries the relatively small local market will be at a disadvantage as overseas manufacturers would not be prepared to supply unique models just for this region. Most thought it would be better to await the final outcomes of the European Commissionfan regulations before creating unique standards specifically for Australia and New Zealand.
- Data
Several submissionssaid more extensive data and cost benefit analysis would be required before MEPS on fan units could be justified. Many data gaps remain, especially in terms of sales and stock of small fan units.
- Equipment Energy Efficiency (E3) Program Committee Response
The E3 Committee will continue to monitor domestic and international developments, particularly with regard to any international projects targeting small fan energy efficiency.