Moja snimka 11

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This year,

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we have a new performance in the compressor and pump side.

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but hopefully can also show something which is going on in the world

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and in our business.

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I want to invite normally Brittany

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from AMCA but due to some reasons

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she couldn't try in and so we changed something both

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positions.

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So the first presentation we had from Mikey Runwich,

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she is the boss of Brittany,

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he is the director of public.

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for education and advocacy

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at AMCA International,

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also responsible for what's going on in the region.

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He is 15 years old,

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also a mechanical engineer from the University of Colorado,

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when I arrived informed.

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And I would say since he started at AMCA,

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he also knows a little bit about the European.

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fan regulation and fan business and a lot of stuff but the

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title today is updating what's going on in the US and fan

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recognition in our 3KD spirit.

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Thank you very much.

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So when Brittany and I put together a couple of presentations for EMOT,

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we were really anticipating that we were part of a larger group of fan presentations

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that others would be covering the US or the European or what's going

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on in the Asian or that nature.

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So it turns out that we're the only two fan presenters.

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Unfortunately,

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Brittany took seriously ill just before the trip,

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and so I'll be covering those slides.

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And that's so you don't have to listen to me for a full hour.

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Christian Tabor is here from Big Ass Fans.

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And I've asked him to substitute for me for my slides so

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that you can have two different presenters for the next hour.

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So first of all,

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I wanted to thank everybody for making the trip,

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for attending this session,

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and dedicating part of your lives to learning a little bit more about what's going on.

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And there's Brittany.

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Hello,

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Brittany.

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She's very,

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very sad she cannot make it.

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This would have been her first overseas trip in her life,

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so she's very sad.

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Anyway, so what we're going to cover today is a little bit about the

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background of how U .S.

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energy regulations and energy codes are structured.

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Our federal product regulations are promulgated

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by the federal agency,

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the U .S.

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Department of Energy,

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but the energy codes for buildings,

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for facilities,

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have a very strong influence on what are considered ban regulations in

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the United States.

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Then we'll talk about what I call the Fan Efficiency Regulation Unification

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Project.

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It's a long word,

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long phrase,

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but it'll have a very specific meaning and then status and time.

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So in terms of background,

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The federal federal regulations are run by what used

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to be called the Appliance and Equipment Standards Program by U .S.

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Department of Energy.

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Under the current presidential administration,

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it's been reshuffling.

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They totally eliminated the Energy Efficiency and Renewable

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Energy Office into some other department that I can't

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remember the names of,

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but minerals or something along those lines.

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But it's not energy efficient at all.

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So maybe someday they'll reorganize again.

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For product regulations,

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these are regulations for which manufacturers and importers are held

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responsible.

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So they're the ones who have to comply with the regulations.

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They're the ones who get fined with them and follow the regulations.

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So regulations focus on manufacturers

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and importers.

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Energy regulations are .

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So you'll see references

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to CFR section number six.

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So the Code of Federal Regulations is a mammoth publication.

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It's all electronic.

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But anyway,

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so regulations are in the Code of Federal Regulations.

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One of the values of a federal regulation is

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that they preempt state regulations and energy codes.

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So federal regulations...

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displace any other previous requirements,

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and any new requirements at the state level have to follow the

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federal regulations.

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Some states actually have state regulations that mimic the federal

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regulations for their own particular reasons,

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but in general,

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the value of a federal regulation is that there's only one regulation

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for the country,

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not 15 different state regulations.

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So federal preemption is a good thing.

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There are four parts generally to a federal efficiency regulation.

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There is a test procedure.

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The test procedure is a standalone federal regulation.

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And it defines the metric for which the minimum energy

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performance has to be.

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expressed as are represented.

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It also describes the method of test and the methods

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by which calculations are made to compute the metric for

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random differences.

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So it defines the metric,

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the method of test,

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and the method of calculation and how the values will be

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represented,

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the number of significant digits,

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how to rerouting them.

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Another part of our federal

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regulation is the certification.

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part where you talk about what parameters have to be filed in an

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online database and how frequently and any particular labeling

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requirements if there are any.

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And then also the last part is the surveillance part,

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which talks about enforcement procedures and fines.

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Fines can be considerable,

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$350 per day in your product

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that is not following the regulation from the date at which the infraction started.

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So if somebody gets caught violating the test procedure or the energy standard,

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you know,

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five years later,

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then they can be fined $350 per day per product since

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the day that they started putting that product on the market.

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out of compliance with the regulations.

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So fines can be millions of dollars in some cases.

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Product regulations are carried into energy codes.

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They're not completely independent.

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We have,

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and I'll talk about this in a second,

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in the United States we have what are called Model Energy Codes.

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These are published by ASHRAE and International Code

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Council, ICC.

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They're separate and somewhat related,

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but part of the federal regulations are embodied in energy

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codes.

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So my own state energy codes,

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these are codes by

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which system designers,

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consulting engineers...

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specifiers have to pay attention to,

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contractors are being held responsible for some parts of the codes,

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and facility owners are responsible.

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So these are like building codes,

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but for energy.

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And there are some factors like fire and life safety codes,

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energy codes,

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building codes.

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You know,

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so when you do a construction project in the United States,

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there's different bodies of codes that you have to be compliant with.

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Energy codes is one of them for many of the states.

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Generally,

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ASHRAE 90 .1 is the energy

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standard published by ASHRAE.

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It's also co -authored by the International Illuminating

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Society, IES.

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And it's an ANSI accredited standard.

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It's written in code enforceable language.

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It's an ASHRAE standard,

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but they rewrote it so that it reads like an energy code.

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And then there's also the International Energy Conservation Code,

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IECC.

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Generally,

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these codes are updated on three -year cycles,

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so they have standing committees that are continuously considering

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updates and changes to these model codes,

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and then they republish them roughly every three years.

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Individual states,

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if they have an energy code,

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they don't all have them.

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If they have an energy code,

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many of them adopt one or two of one or both of these model codes,

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and they may tailor them to their specific climates or construction practices.

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So even though a state might adopt the International Energy Conservation Code,

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you have to pay attention to if they make any particular changes to

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make it more or less stringent.

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than what's in the model code.

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That's why the word model is in the code.

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It's a model,

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but you don't have to follow it exactly.

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As I mentioned,

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there are different conditions are in place in different states.

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So there's one,

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several states have

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adopted an energy code that are earlier than 2013,

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and they're currently in force in their state.

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Some states have no energy code at all.

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Some states have what's called home rules,

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and they allow the cities within the states to adopt their own codes.

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So it gets very,

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very fractured when you get down into what I call jurisdictions

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for code compliance.

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Some states have their own code.

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They don't adopt a mild code.

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they actually have their own energy code California is one of them the

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most dominant one and then they update it on three -year cycles as well with

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their own processes that are apart from ASHRAE or the international program.

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So that's a little bit of background on the

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difference between product regulations and energy codes.

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With fans,

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it's even more complicated.

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When we started considering how to regulate fan efficiency in

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the United States,

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it was in the 2008,

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2009,

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2010 timeframe.

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At the same time that ISO was constructing the 12759

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fan efficiency standard of ISO,

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which led to the fan motor efficiency.

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grade FMEG metric.

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One of the precursors to FMEG is the

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FEG metric,

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the fan efficiency grade metric,

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and the United States fan manufacturers

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wanted an FEG,

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not an FMEG,

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because they didn't want to have anything to do with motors on drives as part of their fan efficiency

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calculation.

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So FEG was adopted early into

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the ASHRAE 90 .1 energy code in 2013.

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So between 2010 and 2013,

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when ISO is doing 12759,

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and is doing a standard called ANCO 205 for FBG,

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ASHRAE adopted FBG,

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2013.

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And there's a typo in that table,

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it should be 2016,

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not 26.

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You make an error in a slide presentation and

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it just lives forever.

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And I'll talk about this a little bit later,

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but the Department of Energy started a fan efficiency rulemaking in

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2011.

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So while ASHRAE was considering FEG for 90 .1,

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the Department of Energy said,

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we're going to create a fan product efficiency

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regulation similar to how the

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European Commission did for EC327,

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okay?

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Europe finished right around the time we were getting started.

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And in 2013,

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the DOE published a document called the Framework Document,

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which let the public know what their early thinking was and what a fan

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regulation would look like.

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And in that document,

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they rejected FEG and they rejected FMG.

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Okay,

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they rejected both methods.

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And so that left the fan industry to develop a new metric.

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And long story short,

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short story long,

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however you want to see it,

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we came up with the Fan Energy Index,

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FEI,

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in 2015.

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And then,

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again, I'm going to get ahead of myself here,

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but the FEI metric was later adopted into ASHRAE 90

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.1 to replace FEG starting in 2019.

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So we went from 2013 to 2019,

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completely different metrics in the energy codes.

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So we had about six years during which states were

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adopting a metric that was already dead in

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2013.

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So that's going to lead to some problems down the line.

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Generally for,

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I'm not going to explain the FEI metric,

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we've done this numerous times,

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but just trust me to say that the

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minimum energy performance level is an FEI metric.

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And the energy codes was 1 .00 for constant

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speed bands and 0 .95 for variable speed applications.

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They felt that credit was necessary for VFD

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applications because at full speed you're getting an energy penalty from the VFD.

13:07

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So they got credit for that.

13:09

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you know a small product for that uh for rearview applications the size

13:13

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range for these uh energy codes uh is at 0 .75

13:17

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kilowatts on the small and up to 150 horsepower uh

13:21

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on the higher side okay some fans don't are rated with

13:25

S… Speaker 1 (Moja snimka 11)

electrical input power like the external rotor motor fans right so they have a their

13:30

S… Speaker 1 (Moja snimka 11)

requirement is 0 .89 kilowatts for their minimum size okay

13:37

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so this is what

13:40

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we have to deal with in the United States for fan efficiency metrics at

13:45

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the state energy code level.

13:46

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The blue states have adopted a model energy

13:50

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code that includes FEI.

13:53

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Okay,

13:54

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so ASHRAE 90 .1 in 2019 or later.

13:57

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Yeah,

13:59

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2019 or later.

14:01

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And then the orange states like Texas,

14:05

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Arizona, Nevada,

14:06

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those are FEG states.

14:09

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And then the lighter,

14:10

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the darker gray states,

14:12

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Oklahoma,

14:13

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Arizona, Tennessee.

14:14

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These are states that have old energy efficiency codes

14:18

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that predate 2013.

14:20

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And then the white states have no energy code at all.

14:23

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So we've got four different cases spread around 50 different

14:27

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states.

14:28

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And it's kind of a mess.

14:29

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But this is what we're contending with.

14:32

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Now, in 2025,

14:35

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10 years after DOE decided on the FBI metric,

14:39

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it took 10 years for the states to have more

14:43

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states with FBI than FBG.

14:46

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So I tell people that looks like an ugly sweater you'd

14:50

S… Speaker 1 (Moja snimka 11)

wear for a Christmas party.

14:51

S… Speaker 1 (Moja snimka 11)

It's bad.

14:52

S… Speaker 1 (Moja snimka 11)

So let's talk about what's going on with the product regulation.

14:55

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So federal,

14:56

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as I mentioned,

14:57

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while ASHRAE

15:00

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was considering FEG,

15:01

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and then published in 2013,

15:04

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that same year DOE decided not to use FEG

15:08

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in a rulemaking they started two years earlier.

15:10

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Between 2011 and 2023,

15:14

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a lot happened and nothing happened,

15:17

S… Speaker 2 (Moja snimka 11)

okay?

15:18

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In other words,

15:19

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there was a lot of meetings,

15:20

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a lot of discussions,

15:21

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a lot of preliminary analyses.

15:24

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within the private energy rulemaking,

15:26

S… Speaker 2 (Moja snimka 11)

some of it public,

15:27

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some of it private,

15:28

S… Speaker 1 (Moja snimka 11)

but it took until 2023 for

15:33

S… Speaker 1 (Moja snimka 11)

DOE to publish the test procedure.

15:36

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So 12 years to

15:40

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get a test procedure out the door.

15:41

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That test procedure did specify FEI as

15:46

S… Speaker 1 (Moja snimka 11)

the regulatory metric and how to test for it and how to calculate it,

15:49

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and it stopped there.

15:54

S… Speaker 1 (Moja snimka 11)

That same year,

15:55

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the state of California created their own product regulation

16:00

S… Speaker 1 (Moja snimka 11)

for fans.

16:00

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So long story short,

16:02

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in 2017,

16:04

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the Department of Energy,

16:06

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under the president at the time,

16:08

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they said no more DOE regulations.

16:11

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So they stopped the fan rulemaking in its tracks.

16:15

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We felt at that time they were very close to publishing at least a test procedure.

16:19

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We actually petitioned DOE to restart the

16:23

S… Speaker 1 (Moja snimka 11)

rulemaking and at least get the test procedure done so that there would be a consistent method

16:27

S… Speaker 1 (Moja snimka 11)

of test for a fan regulation if any state were to do it,

16:30

S… Speaker 1 (Moja snimka 11)

but they didn't start it.

16:32

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So California started their own rulemaking for a state

16:36

S… Speaker 1 (Moja snimka 11)

chronic regulation in 2017.

16:39

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Even though they had a head start with what DOE had accomplished by then,

16:42

S… Speaker 1 (Moja snimka 11)

it took them six years to finish their product regulation.

16:47

S… Speaker 1 (Moja snimka 11)

The good news is that it used a DOE test procedure,

16:49

S… Speaker 2 (Moja snimka 11)

because it has to,

16:50

S… Speaker 2 (Moja snimka 11)

because it's federal preemption.

16:51

S… Speaker 1 (Moja snimka 11)

So in 2023,

16:53

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significant developments were we have a federal test procedure with a metric and

16:57

S… Speaker 2 (Moja snimka 11)

a method of test,

16:58

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and we also have a state product regulation,

17:01

S… Speaker 1 (Moja snimka 11)

which not only included the testing,

17:03

S… Speaker 1 (Moja snimka 11)

but a minimum energy performance standard,

17:05

S… Speaker 1 (Moja snimka 11)

and also labeling requirements.

17:08

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So the fans had to have a label.

17:10

S… Speaker 1 (Moja snimka 11)

And then the first,

17:11

S… Speaker 1 (Moja snimka 11)

when it covers the regulation for the label,

17:16

S… Speaker 1 (Moja snimka 11)

The font was so big that the labels would stretch across

17:20

S… Speaker 1 (Moja snimka 11)

the diameter of the fan.

17:22

S… Speaker 1 (Moja snimka 11)

And they didn't want to change it.

17:24

S… Speaker 1 (Moja snimka 11)

They said,

17:25

S… Speaker 1 (Moja snimka 11)

no, no, it's already done.

17:26

S… Speaker 2 (Moja snimka 11)

We can't change it.

17:27

S… Speaker 1 (Moja snimka 11)

So I had some of our members print out labels.

17:30

S… Speaker 2 (Moja snimka 11)

Zealopic was one of them,

17:31

S… Speaker 2 (Moja snimka 11)

right?

17:32

S… Speaker 1 (Moja snimka 11)

Print out labels and put them on your fans.

17:34

S… Speaker 2 (Moja snimka 11)

He sent it to me.

17:35

S… Speaker 1 (Moja snimka 11)

So then I sent the photographs to the California Energy Commission.

17:38

S… Speaker 2 (Moja snimka 11)

I said,

17:39

S… Speaker 1 (Moja snimka 11)

I'm willing to go public with this.

17:40

S… Speaker 1 (Moja snimka 11)

Do you really want the public to see that you're requiring people to do this?

17:43

S… Speaker 2 (Moja snimka 11)

He said,

17:44

S… Speaker 1 (Moja snimka 11)

no.

17:44

S… Speaker 2 (Moja snimka 11)

So they fixed it.

17:46

S… Speaker 2 (Moja snimka 11)

I should show you the picture sometime.

17:49

S… Speaker 1 (Moja snimka 11)

It's kind of fun.

17:50

S… Speaker 1 (Moja snimka 11)

Anyway.

17:51

S… Speaker 1 (Moja snimka 11)

So, 2023.

17:52

S… Speaker 1 (Moja snimka 11)

Now, in 2024,

17:53

S… Speaker 1 (Moja snimka 11)

things began to pick up.

17:55

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We have a different presidential administration,

17:57

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and they're going to get to the end of their administration,

18:01

S… Speaker 1 (Moja snimka 11)

actually, when they started coming out with some new stuff.

18:04

S… Speaker 1 (Moja snimka 11)

They came out with the draft energy standard in January 2024.

18:09

S… Speaker 1 (Moja snimka 11)

They gave industry three months to review it.

18:12

S… Speaker 2 (Moja snimka 11)

Not a lot of time,

18:13

S… Speaker 1 (Moja snimka 11)

given the volumes of information that you have to process when

18:17

S… Speaker 1 (Moja snimka 11)

you evaluate a federal standard like that.

18:19

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And it was actually pretty rough shape.

18:21

S… Speaker 1 (Moja snimka 11)

There was a lot of fundamental problems with the DOE structure

18:26

S… Speaker 1 (Moja snimka 11)

of the regulation,

18:26

S… Speaker 1 (Moja snimka 11)

and their technical analyses were highly flawed.

18:29

S… Speaker 1 (Moja snimka 11)

And they really were,

18:30

S… Speaker 1 (Moja snimka 11)

okay?

18:31

S… Speaker 2 (Moja snimka 11)

Trust me.

18:33

S… Speaker 1 (Moja snimka 11)

But they took our comments and other comments from other stakeholders,

18:38

S… Speaker 1 (Moja snimka 11)

and they created a final regulation.

18:41

S… Speaker 1 (Moja snimka 11)

It was done.

18:41

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And so before a federal regulation is published,

18:45

S… Speaker 1 (Moja snimka 11)

it undergoes what's called an interagency review.

18:47

S… Speaker 1 (Moja snimka 11)

They said, all right,

18:48

S… Speaker 1 (Moja snimka 11)

we're done, but we want other DOE or other federal agencies to review the

18:52

S… Speaker 1 (Moja snimka 11)

regulation to make sure it complies with the regulations of other agencies.

18:56

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And that sat in that place

19:00

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for four months.

19:03

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And then when the next president took over,

19:06

S… Speaker 1 (Moja snimka 11)

signaling a different regime change in how the DOE would treat

19:11

S… Speaker 1 (Moja snimka 11)

regulations,

19:11

S… Speaker 1 (Moja snimka 11)

the outgoing president's administration withdrew

19:16

S… Speaker 1 (Moja snimka 11)

the fan rule and others that were in consideration.

19:19

S… Speaker 1 (Moja snimka 11)

They withdrew it from interagency

19:23

S… Speaker 1 (Moja snimka 11)

review.

19:24

S… Speaker 1 (Moja snimka 11)

So it went nowhere.

19:25

S… Speaker 1 (Moja snimka 11)

It stopped right there.

19:27

S… Speaker 1 (Moja snimka 11)

And when they did that,

19:29

S… Speaker 1 (Moja snimka 11)

They have to do this with an official statement or an official document.

19:33

S… Speaker 1 (Moja snimka 11)

And they said,

19:35

S… Speaker 1 (Moja snimka 11)

all right, we're going to stop the rulemaking for fans.

19:38

S… Speaker 1 (Moja snimka 11)

There's a lot of controversy.

19:40

S… Speaker 1 (Moja snimka 11)

But hey,

19:41

S… Speaker 1 (Moja snimka 11)

individual states,

19:43

S… Speaker 1 (Moja snimka 11)

you can regulate fans.

19:45

S… Speaker 1 (Moja snimka 11)

And there's a lot of energy savings.

19:47

S… Speaker 1 (Moja snimka 11)

And if you wanted to use our draft energy standard as a basis,

19:51

S… Speaker 2 (Moja snimka 11)

go right ahead.

19:52

S… Speaker 1 (Moja snimka 11)

So that draft energy standard is in the public domain still,

19:55

S… Speaker 1 (Moja snimka 11)

and it's very scary because,

19:57

S… Speaker 2 (Moja snimka 11)

as I said earlier,

19:58

S… Speaker 2 (Moja snimka 11)

it's highly flawed.

20:00

S… Speaker 1 (Moja snimka 11)

DOE through fans to the walls of individual states to

20:04

S… Speaker 2 (Moja snimka 11)

create their own state rules.

20:05

S… Speaker 2 (Moja snimka 11)

AMCA

20:11

S… Speaker 2 (Moja snimka 11)

We really,

20:12

S… Speaker 1 (Moja snimka 11)

the fan industry has already suffered through 13 years of

20:16

S… Speaker 1 (Moja snimka 11)

rulemaking within the DOE.

20:17

S… Speaker 1 (Moja snimka 11)

Two different metrics,

20:19

S… Speaker 1 (Moja snimka 11)

different state regulations now,

20:21

S… Speaker 1 (Moja snimka 11)

different state energy codes.

20:23

S… Speaker 1 (Moja snimka 11)

We needed some consistency in the fan efficiency world.

20:27

S… Speaker 2 (Moja snimka 11)

So what we did,

20:29

S… Speaker 1 (Moja snimka 11)

and I'll talk about that in a second,

20:30

S… Speaker 1 (Moja snimka 11)

is we worked with the industry stakeholders to create a fan regulation

20:35

S… Speaker 1 (Moja snimka 11)

template.

20:36

S… Speaker 2 (Moja snimka 11)

at individual states.

20:37

S… Speaker 1 (Moja snimka 11)

Okay,

20:38

S… Speaker 1 (Moja snimka 11)

it's called the Unification Project,

20:39

S… Speaker 2 (Moja snimka 11)

and I'll talk about that.

20:40

S… Speaker 2 (Moja snimka 11)

So,

20:41

S… Speaker 2 (Moja snimka 11)

you know,

20:42

S… Speaker 2 (Moja snimka 11)

we wanted all the wolves.

20:43

S… Speaker 2 (Moja snimka 11)

Okay,

20:43

S… Speaker 2 (Moja snimka 11)

wolves, you can regulate fast,

20:45

S… Speaker 1 (Moja snimka 11)

but we all want to regulate them the same way.

20:47

S… Speaker 1 (Moja snimka 11)

In 2026,

20:49

S… Speaker 1 (Moja snimka 11)

so this was college in December,

20:52

S… Speaker 1 (Moja snimka 11)

November, December,

20:53

S… Speaker 1 (Moja snimka 11)

2025.

20:53

S… Speaker 1 (Moja snimka 11)

And then in 2026,

20:55

S… Speaker 1 (Moja snimka 11)

the first state picked up the model of the will,

20:58

S… Speaker 2 (Moja snimka 11)

Rhode Island.

20:59

S… Speaker 1 (Moja snimka 11)

and they expect to complete it maybe this year but

21:03

S… Speaker 1 (Moja snimka 11)

meanwhile there's no enforcement of the test procedure so unfortunately

21:08

S… Speaker 1 (Moja snimka 11)

there's yes

21:14

S… Speaker 2 (Moja snimka 11)

I'm getting too much fun.

21:16

S… Speaker 1 (Moja snimka 11)

All right.

21:16

S… Speaker 1 (Moja snimka 11)

So as I mentioned,

21:17

S… Speaker 1 (Moja snimka 11)

we did the fan unification project to update.

21:21

S… Speaker 1 (Moja snimka 11)

It was called a model bill published by another organization,

21:24

S… Speaker 1 (Moja snimka 11)

Appliant Standards Awareness Project.

21:26

S… Speaker 1 (Moja snimka 11)

So we worked with that organization,

21:28

S… Speaker 1 (Moja snimka 11)

an NGO,

21:29

S… Speaker 1 (Moja snimka 11)

a consulting firm that works with the California investor -owned utilities like

21:33

S… Speaker 1 (Moja snimka 11)

PG &E and Southern California and Edison.

21:37

S… Speaker 1 (Moja snimka 11)

And then HRI,

21:39

S… Speaker 1 (Moja snimka 11)

which is the equivalent of Neuroment within the United States.

21:42

S… Speaker 1 (Moja snimka 11)

and another consulting firm Energy Solutions that does a lot of wave eight programs and

21:46

S… Speaker 2 (Moja snimka 11)

state advocacy.

21:47

S… Speaker 1 (Moja snimka 11)

So we work with advocacy organizations,

21:49

S… Speaker 1 (Moja snimka 11)

another trade association,

21:51

S… Speaker 1 (Moja snimka 11)

my staff,

21:52

S… Speaker 1 (Moja snimka 11)

and then members of AMGA,

Moja snimka 11

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