2013-05-28 Comment response to the published Framework Document

I am the Editorial Director of a trade magazine serving the residential lighting and ceiling fan industry. While I support programs like Energy Star that help consumers identify the most efficient products in a category, I feel strongly that the proposed requirements for ceiling fans will not achieve the desired outcome of reduced energy use. It seems counter-intuitive to me to take a product that is by nature designed to save energy (by reducing the need for air conditioning) and restrict its design and engineering such that it becomes cost-prohibitive for some to use, and undesirable for others because of the limitations on fan blade design. The ceiling fan industry is already incorporating more DC motors in their offerings, but to require a DC motor adds cost that only benefits the end user when a fan is at its highest setting. And the reliability of DC motors has been an issue. Ceiling fans are no longer simply appliances. While they continue to serve an important function (especially in warmer climates), fans are now available in models that suit any home decor scheme, making their form equally important in terms of their acceptance among consumers. I feel it would be more beneficial to educate consumers on the most efficient use of ceiling fans, rather than imposing well-meaning but misguided regulations that could stand to discourage their use due to initial cost or utilitarian design. One fan manufacturer has even suggested a National Ceiling Fan Day for Sept. 18, when consumers would be encouraged to turn off their air conditioning for one day to learn just how well ceiling fans cool their air by themselves. It is fair to continue an ongoing dialogue with our industry about how we can continue to make our products as efficient as possible, and to encourage proper use among consumers to minimize overall energy use. I just don't believe the proposed measures are steps in the right direction to minimizing carbon footprints.