16-0812 v2.1/Ceiling Fans and I14-E4 8/2008

QUESTION

We are submitting the following request for an exemption to Imperative 14 Appropriate Sourcing (under v2.1). Outlined below are the issues that the project is facing, which have resulted in the need for this request. We have considered four possible options for ceiling fans for our project as follows:

Casablanca Fan Company

This company’s line of ceiling fans was the homeowners’ first selection simply based on the product aesthetics. Upon further research, we found that the product is manufactured (final assembly) in the within Zone 5 from the project site; however, our efforts to gather compliance with Red List and FSC tracking for their wood blades resulted in lack of support from the manufacturer. Our inquiries went unanswered; therefore, we had to move forward to other options. 

Big Ass Fans

As we were determining that the Casablanca product would not likely comply with the LBC requirements, our second option was to pursue compliance for the Haiku fan. We were fortunate that the manufacturer was very willing to help. Their low energy-use is also ideal to help keep the energy demands for the home low. A signed letter stating v2.0 Red List compliance was provided, the final assembly location is within Zone 5 from the project site, and they were able to provide FSC documentation for I13. However, the major deterrent for the homeowners is the expense of the fans. With four ceiling fan locations planned throughout the home to enhance the natural ventilation strategies, it has been determined that the fans simply will not fit within the budget. We have pursued in two different calendar years to work with BAF for a sponsor request; however, these requests were unsuccessful for various reasons.

Aeratron

In an effort to find a fan that is similar to the Haiku, but at a lower price point, our team began to research the Aeratron AE2 unit. We found that their product was in line with the energy performance for the Haiku unit, the manufacturer is able to demonstrate compliance with RoHS (I11-E20 5/2013) for all parts, fits the desired aesthetic that the homeowners are pursuing, and is about half of the cost of the Haiku. However, their products are completely manufactured oversees and final assembly is in Taichung, Taiwan, which is well outside of Zone 5 from the project site.

Salvaged Fans

The homeowners’ last consideration is to use fans from another property or reuse center in order to be able to comply with the Materials Petal as well as keep the expense to a minimum. The downfall to this approach is that older fans typically don’t have the same energy efficiency has do the newer products currently offered.

We are requesting guidance for the following:

Can the I14-E4 8/2008 exemption for Small Components be applied to ceiling fans in order to allow the Aeratron AE2 unit to be installed in the project?  

ANSWER

The I14-E4 Small Components Exception cannot be used to exclude entire products from the tracking requirements. Small components within a complex product may be excluded from tracking if they comprise less than 10%, by weight and volume, of the assembly and are discrete forms that remain discrete at the end of the product life. However, the overall product point of assembly would still need to be tracked.
A zone jump is not allowed when a compliant product with the same functionality is available in the required zone, unless the more distant product is more transparent through their participation in Declare. Please see Exception I14-E15 Declare in the v2.1 May 2013 Materials Petal Handbook (MPH p26). 

Post ID 6015

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