After a regulatory action has been completed, Executive Order 12866 requires agencies 

to identify the substantive changes between the draft submitted to Office of Information 

and Regulatory Affairs (OIRA) for review and the action subsequently announced, and to 

identify those changes made at the suggestion or recommendation of OIRA.
1

[6450-01-P]

DEPARTMENT OF ENERGY

10 CFR Part 431

[Docket Number EERE–2010–BT–STD–0027]

RIN: 1904–AC28

Energy Conservation Program: Energy Conservation Standards for Commercial 

and Industrial Electric Motors

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of proposed rulemaking (NOPR) and public meeting.

SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as amended,

prescribes energy conservation standards for various consumer products and certain 

commercial and industrial equipment, including commercial and industrial electric 

motors. EPCA also requires the U.S. Department of Energy (DOE) to determine whether 

more-stringent, amended standards would be technologically feasible and economically 

justified, and would save a significant amount of energy. In this notice, DOE proposes

energy conservation standards for a number of different groups of electric motors that 

DOE has not previously regulated. For those groups of electric motors currently 

regulated, the proposed standards would maintain the current energy conservation 

standards for some electric motor types and amend the energy conservation standards for 
2

other electric motor types. The document also announces a public meeting to receive 

comment on these proposed standards and associated analyses and results.

DATES: DOE will hold a public meeting on [INSERT Day of week, Month, Day, Year], 

from 9 a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast as a 

webinar. See section VII Public Participation for webinar registration information, 

participant instructions, and information about the capabilities available to webinar 

participants. 

DOE will accept comments, data, and information regarding this NOPR before 

and after the public meeting, but no later than [INSERT DATE 60 DAYS AFTER 

DATE OF PUBLICATION IN THE FEDERAL REGISTER PUBLICATION]. See 

section VII Public Participation for details.

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, 

Forrestal Building, Room [NUMBER], 1000 Independence Avenue, SW., Washington, 

DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586–2945. Please note 

that foreign nationals visiting DOE Headquarters are subject to advance security 

screening procedures. Any foreign national wishing to participate in the meeting should 

advise DOE as soon as possible by contacting Ms. Edwards to initiate the necessary 

procedures. Please also note that those wishing to bring laptops into the Forrestal 

Building will be required to obtain a property pass. Visitors should avoid bringing 
3

laptops, or allow an extra 45 minutes. Persons can attend the public meeting via webinar. 

For more information, refer to the Public Participation section near the end of this notice. 

Any comments submitted must identify the NOPR for Energy Conservation 

Standards for electric motors, and provide docket number EE-2010–BT–STD–2027

and/or regulatory information number (RIN) number 1904-AC28. Comments may be 

submitted using any of the following methods: 

1. Federal eRulemaking Portal

2.

: www.regulations.gov. Follow the instructions for 

submitting comments. 

E-mail

3.

: ElecMotors-2010-STD-0027@ee.doe.gov. Include the docket number 

and/or RIN in the subject line of the message.

Mail

4.

: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies 

Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 

20585-0121. If possible, please submit all items on a CD. It is not necessary to 

include printed copies.

Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, 

Building Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, 

Washington, DC, 20024. Telephone: (202) 586-2945. If possible, please submit 

all items on a CD, in which case it is not necessary to include printed copies.

Written comments regarding the burden-hour estimates or other aspects of the 

collection-of-information requirements contained in this proposed rule may be submitted 
4

to Office of Energy Efficiency and Renewable Energy through the methods listed above 

and by e-mail to Chad_S_Whiteman@omb.eop.gov

For detailed instructions on submitting comments and additional information on 

the rulemaking process, see section VII of this document (Public Participation).

Docket: The docket, which includes Federal Register notices, public meeting 

attendee lists and transcripts, comments, and other supporting documents/materials, is 

available for review at regulations.gov. All documents in the docket are listed in the 

regulations.gov index. However, some documents listed in the index, such as those 

containing information that is exempt from public disclosure, may not be publicly 

available.

A link to the docket web page can be found at: [Web site. THIS WEB PAGE 

WILL CONTAIN A LINK TO THE DOCKET FOR THIS NOTICE ON THIS NOTICE 

ON THE REGULATIONS.GOV SITE]. This web page will contain a link to the docket 

for this notice on the regulations.gov site. The regulations.gov web page will contain 

simple instructions on how to access all documents, including public comments, in the 

docket. See section VII for further information on how to submit comments through 

www.regulations.gov. 
5

For further information on how to submit a comment, review other public 

comments and the docket, or participate in the public meeting, contact Ms. Brenda 

Edwards at (202) 586-2945 or by email: Brenda.Edwards@ee.doe.gov.

FOR FURTHER INFORMATION CONTACT: 

James Raba, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, 

SW., Washington, DC, 20585-0121. Telephone: (202) 586-8654. E-mail: 

Jim.Raba@ee.doe.gov.

Ms. Ami Grace-Tardy, U.S. Department of Energy, Office of the General 

Counsel, GC-71, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. 

Telephone: (202) 586-5709. E-mail: Ami.Grace-Tardy@hq.doe.gov. 

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Summary of the Proposed Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Electric Motors

3. Process for Setting Energy Conservation Standards

III. General Discussion

A. Test Procedure
6

B. Equipment Classes and Current Scope of Coverage

C. Expanded Scope of Coverage

D. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

E. Energy Savings

1. Determination of Savings

2. Significance of Savings

F. Economic Justification

1. Specific Criteria

a. Economic Impact on Manufacturers and Consumers

b. Life-Cycle Costs

c. Energy Savings

d. Lessening of Utility or Performance

e. Impact of Any Lessening of Competition

f. Need for National Energy Conservation

g. Other Factors

2. Rebuttable Presumption

IV. Methodology and Discussion of Related Comments

A. Market and Technology Assessment

1. Current Scope of Electric Motors Energy Conservation Standards

2. Expanded Scope of Electric Motor Energy Conservation Standards

3. Advanced Electric Motors

4. Equipment Class Groups and Equipment Classes

a. Electric Motor Design Letter

b. Fire Pump Electric Motors

c. Brake Motors

d. Horsepower Rating

e. Pole Configuration

f. Enclosure Type

g. Other Motor Characteristics

5. Technology Assessment

a. Decrease the Length of Coil Extensions

b. Increase Cross-Sectional Area of Rotor Conductor Bars

c. Increase Cross-Sectional Area of End Rings

d. Increase the Number of Stator Slots

e. Electrical Steel with Lower Losses

f. Thinner Steel Laminations

g. Increase Stack Length

h. More Efficient Cooling System

i. Reduce Skew on Conductor Cage

B. Screening Analysis

1. Technology Options Not Screened Out of the Analysis

a. Copper Die-Cast Rotors

b. Increase the Cross-Sectional Area of Copper in the Stator Slots

2. Technology Options Screened Out of the Analysis
7

C. Engineering Analysis

1. Engineering Analysis Methodology

2. Representative Units

a. Electric Motor Design Type

b. Horsepower Rating

c. Pole-Configuration

d. Enclosure Type

3. Efficiency Levels Analyzed

4. Test and Teardowns

5. Software Modeling

6. Cost Model

a. Copper Pricing

b. Labor Rate and Non-Production Markup

c. Catalog Prices

d. Product Development Cost

7. Engineering Analysis Results

8. Scaling Methodology

D. Markups Analysis

E. Energy Use Analysis

1. Comments on Operating Hours

2. Comments on Other Issues

F. Life-Cycle Cost and Payback Period Analysis

1. Equipment Costs

2. Installation Costs

3. Maintenance Costs

4. Repair Costs

5. Unit Energy Consumption

6. Electricity Prices and Electricity Price Trends

7. Lifetime

8. Discount Rate

9. Base Case Market Efficiency Distributions

10. Compliance Date

11. Payback Period Inputs

12. Rebuttable-Presumption Payback Period

G. Shipments Analysis

H. National Impact Analysis

1. Efficiency Trends

2. National Energy Savings

3. Equipment Price Forecast

4. Net Present Value of Customer Benefit

I. Consumer Subgroup Analysis

J. Manufacturer Impact Analysis

1. Overview

2. GRIM Analysis and Key Inputs

a. Product and Capital Conversion Costs

b. Manufacturer Production Costs
8

c. Shipment Forecast

d. Markup Scenarios

3. Discussion of Comments

a. Scope of Coverage

b. Conversion Costs

c. Enforcement of Standards

d. Motor Refurbishment

4. Manufacturer Interviews

a. Efficiency Levels above NEMA Premium

b. Increase in Equipment Repairs

c. Enforcement

K. Emissions Analysis

L. Monetizing Carbon Dioxide and Other Emissions Impacts

1. Social Cost of Carbon

a. Monetizing Carbon Dioxide Emissions

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

c. Current Approach and Key Assumptions

2. Valuation of Other Emissions Reductions

M. Utility Impact Analysis

N. Employment Impact Analysis

O. Other Comments Received

V. Analytical Results

A. Trial Standard Levels

B. Economic Justification and Energy Savings

1. Economic Impacts on Individual Customers

a. Life-Cycle Cost and Payback Period

b. Consumer Subgroup Analysis

c. Rebuttable Presumption Payback

2. Economic Impacts on Manufacturers

a. Industry Cash-Flow Analysis Results

b. Impacts on Employment

c. Impacts on Manufacturing Capacity

d. Impacts on Sub-Group of Manufacturers

e. Cumulative Regulatory Burden

3. National Impact Analysis

a. Significance of Energy Savings

b. Net Present Value of Customer Costs and Benefits

c. Indirect Impacts on Employment

4. Impact on Utility or Performance

5. Impact of Any Lessening of Competition

6. Need of the Nation to Conserve Energy

7. Summary of National Economic Impacts

8. Other Factors

C. Proposed Standards

1. Benefits and Burdens of Trial Standard Levels Considered for Electric Motors

2. Summary of Benefits and Costs (Annualized) of the Proposed Standards
9

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

b. Manufacturer Participation

c. Electric Motor Industry Structure and Nature of Competition

d. Comparison Between Large and Small Entities

2. Description and Estimate of Compliance Requirements

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

4. Significant Alternatives to the Proposed Rule

5. Significant Issues Raised by Public Comments

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Review Under the Information Quality Bulletin for Peer Review

VII. Public Participation

A. Attendance at the Public Meeting

B. Procedure for Submitting Prepared General Statements For Distribution

C. Conduct of the Public Meeting

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VIII. Approval of the Office of the Secretary

1. The authority citation for part 431 continues to read as follows:

2. Revise §431.25 to read as follows:

I. Summary of the Proposed Rule 

Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA or the 

Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy 

Conservation Program for Consumer Products Other Than Automobiles. Part C of Title 

III of EPCA (42 U.S.C. 6311–6317) established a similar program for “Certain Industrial 
10

Equipment,” including certain electric motors.1 (Within this preamble, DOE will use the 

terms “electric motors” and “motors” interchangeably.) Pursuant to EPCA, any new or 

amended energy conservation standard that DOE may prescribe for certain equipment, 

such as electric motors, shall be designed to achieve the maximum improvement in 

energy efficiency that DOE determines is technologically feasible and economically 

justified. (42 U.S.C. 6295(o)(2)(A) and 6316(a)). Furthermore, any new or amended 

standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)

and 6316(a)). 

In accordance with these and other statutory provisions discussed in this notice, 

the U.S. Department of Energy (DOE) proposes amending the energy conservation 

standards for electric motors by applying the standards currently in place to a wider scope 

of electric motors for which DOE does not currently regulate. In setting these standards, 

DOE is proposing to address a number of different groups of electric motors that have, to 

date, not been required to satisfy the energy conservation standards currently set out in 10 

CFR part 431. In addition, with the exception of fire pump electric motors, the proposal 

would require all currently regulated motors to satisfy the efficiency levels prescribed in 

Table 12-12 and Table 20-B2

 1 For editorial reasons, upon codification in the U.S. Code, Parts B and C were redesignated as Parts A and 

A-1, respectively.

of MG1-2011, published by the National Electrical 

Manufacturers Association; fire pump motors would continue to meet the current 

standards that apply. All other electric motors that DOE is proposing to regulate would 

also need to meet these efficiency levels (i.e. Tables 12-12 and 20-B). As a practical 

2 Table 20-B of MG1-2011 provides nominal full-load efficiencies for ratings without nominal full-load 

efficiencies in Table 12-12 of MG1-2011. 

Comment [A1]: Change recommended by OIRA.
11

matter, the many currently regulated motors would continue to be required to meet the 

standards that they already meet, but certain motors, such as those that satisfy the general 

purpose electric motors (subtype II) ("subtype II") or that are NEMA Design B motors 

from 201 through 500 horsepower, would need to meet the more stringent levels 

prescribed by MG1-2011 Tables 12-12 and 20-B. These proposed efficiency levels are 

shown in Table I.1. If adopted, the proposed standards would apply to all covered motor 

types listed in Table I.1 that are manufactured in, or imported into, the United States 

starting on December 19, 2015. DOE may, however, depending on the nature of the 

comments it receives, revisit this proposed compliance date. 

Table I.1 Proposed Energy Conservation Standards for 

Electric Motors (Compliance Starting December 19, 2015)

Equipment 

Class 

Group

Electric Motor

Design Type 

Horsepower 

Rating

Pole

Configuration Enclosure Proposed TSL

1 NEMA Design A & 

B* 1–500 2, 4, 6, 8 Open 2

Enclosed 2

2 NEMA Design C* 1–200 4, 6, 8 Open 2

Enclosed 2

3 Fire Pump* 1–500 2, 4, 6, 8

Open 2

Enclosed 2

4 Brake Motors* 1–30 4, 6, 8 Open 2

Enclosed 2

* Indicates IEC equivalentsequivalent electric motors are included.

The following tables (Tables I.2 to I.5) detail the various proposed standard levels 

that comprise TSL 2 and that DOE would apply to each group of motors. In determining 

where a particular motor with a certain horsepower (hp) or kilowatt rating would fall 

Comment [A2]: Change recommended by OIRA.
12

within the requirements, as in DOE’s current regulations, DOE would apply the 

following approach in determining which rating would apply for compliance purposes:

(1) A horsepower at or above the midpoint between the two consecutive 

horsepowers shall be rounded up to the higher of the two horsepowers;

(2) A horsepower below the midpoint between the two consecutive horsepowers 

shall be rounded down to the lower of the two horsepowers; or 

(3) A kilowatt rating shall be directly converted from kilowatts to horsepower 

using the formula 1 kilowatt = (1/0.746) horsepower. The conversion should 

be calculated to three significant decimal places, and the resulting horsepower 

shall be rounded in accordance with the rules listed in (1) and (2). 
13

Table I.2 Proposed Energy Conservation Standards for NEMA Design A and 

NEMA Design B Electric Motors (Excluding Fire Pump Electric Motors, Integral 

Brake Electric Motors, and Non-Integral Brake Electric Motors) (Compliance 

Starting December 19, 2015)

Motor 

Horsepower

/Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

2 Pole 4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open Enclosed Open

1/.75 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2

20/15 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0

30/22 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7

40/30 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7

50/37 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4

60/45 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0

75/55 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1

100/75 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1

125/90 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1

150/110 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1

200/150 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1

250/186 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0

300/224 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0

350/261 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0

400/298 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0

450/336 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0

500/373 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
14

Table I.3 Proposed Energy Conservation Standards for NEMA Design C Electric 

Motors (Excluding Non-Integral Brake Electric Motors and Integral Brake Electric 

Motors) (Compliance Starting December 19, 2015)

Motor 

Horsepower/ 

Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open

1/.75 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 92.4 93.0 91.7 91.7 89.5 90.2

20/15 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 93.6 93.6 93.0 93.0 90.2 91.0

30/22 93.6 94.1 93.0 93.6 91.7 91.7

40/30 94.1 94.1 94.1 94.1 91.7 91.7

50/37 94.5 94.5 94.1 94.1 92.4 92.4

60/45 95.0 95.0 94.5 94.5 92.4 93.0

75/55 95.4 95.0 94.5 94.5 93.6 94.1

100/75 95.4 95.4 95.0 95.0 93.6 94.1

125/90 95.4 95.4 95.0 95.0 94.1 94.1

150/110 95.8 95.8 95.8 95.4 94.1 94.1

200/150 96.2 95.8 95.8 95.4 94.5 94.1
15

Table I.4 Proposed Energy Conservation Standards for Fire Pump Electric Motors 

(Compliance Starting December 19, 2015)

Motor 

Horsepower

/Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

2 Pole 4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open Enclosed Open

1/.75 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0

1.5/1.1 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5

2/1.5 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5

3/2.2 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5

5/3.7 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5

7.5/5.5 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5

10/7.5 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5

15/11 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5

20/15 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2

25/18.5 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2

30/22 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0

40/30 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0

50/37 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7

60/45 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4

75/55 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6

100/75 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6

125/90 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6

150/110 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6

200/150 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6

250/186 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5

300/224 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5

350/261 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5

400/298 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5

450/336 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5

500/373 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5
16

Table I.5 Proposed Energy Conservation Standards for Integral Brake Electric 

Motors and Non-Integral Brake Electric Motors (Compliance Starting December 

19, 2015)

Motor 

Horsepower/ 

Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open

1/.75 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 92.4 93.0 91.7 91.7 89.5 90.2

20/15 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 93.6 93.6 93.0 93.0 90.2 91.0

30/22 93.6 94.1 93.0 93.6 91.7 91.7

A.

Table I.6

Benefits and Costs to Consumers

presents DOE’s evaluation of the economic impacts of the proposed 

standards on consumers of electric motors, as measured by the weighted average lifecycle cost (LCC) savings and the weighted average median payback period. 

Table I.6 Impacts of Proposed Standards on Consumers of Electric Motors

Weighted Average LCC 

Savings* (2012$)

Weighted Average

Median Payback Period*

(years)

Equipment Class Group 1 132 3.3

Equipment Class Group 2 38 5.0

Equipment Class Group 3 N/A** N/A**

Equipment Class Group 4 259 1.9

* The results for each equipment class group (ECG) are a shipment weighted average of results for the 

representative units in the group. ECG 1: Representative units 1, 2, and 3; ECG 2: Representative units 4 

and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units 9 and10and 10. The weighted 

average lifetime in each equipment classes is 15 years and ranges from 8 to 29 years depending on the 

motor horsepower and application.

** For equipment class group 3, the proposed standard level is the same as the baseline; thus, no customers 

are affected.

Comment [A3]: Change recommended by OIRA.
17

B.

The industry net present value (INPV) is the sum of the discounted cash flows to 

the industry from the base year through the end of the analysis period (2013 to 2044). 

Using a real discount rate of 9.1 percent, DOE estimates that the industry net present 

value (INPV) for manufacturers of electric motors is $3,371.2 million in 2012$. Under 

the proposed standards, DOE expects that manufacturers may lose up to 8.4 percent of 

their INPV, which corresponds to approximately $283.5 million. Additionally, based on 

DOE’s interviews with the manufacturers of electric motors, DOE does not expect any 

plant closings or significant loss of employment based on the energy conservation 

standards chosen in today’s Notice of Proposed Rulemaking (NOPR).

Impact on Manufacturers

C. National Benefits and Costs3

DOE’s analyses indicate that the proposed standards would save a significant 

amount of energy. Estimated lifetime savings for electric motors purchased over the 30-

year period that begins in the year of compliance with new and amended standards 

(2015–2044) would amount to 7.0 quads (full-fuel-cycle energy).4 This isThe annualized 

energy savings (0.23 quads) are equivalent to 30one percent of total U.S. industrial 

primary energy consumption in 2011.5

 3 All monetary values in this section are expressed in 2012 dollars and are discounted to 2013. 4 One quad (quadrillion Btu) is the equivalent of 293.1 billion kilowatt hours (kWh) or 172.3 million 

barrels of oil.

5 Based on U.S. Department of Energy, Energy Information Administration, Annual Energy Outlook 

(AEO) 2013 data.

Comment [A4]: Change recommended by OIRA.

Comment [A5]: Change recommended by OIRA.
18

The estimated cumulative net present value (NPV) of total consumer costs and 

savings attributed to the proposed standards for electric motors ranges from $8.7 billion 

(at a 7-percent discount rate) to $23.3 billion (at a 3-percent discount rate). This NPV 

expresses the estimated total value of future operating-cost savings minus the estimated 

increased equipment costs for equipment purchased in 2015–2044.

In addition, the proposed standards would have significant environmental 

benefits. Estimated energy savings would result in cumulative emission reductions of 396 

million metric tons (Mt)6 of carbon dioxide (CO2), 674 thousand tons of sulfur dioxide 

(SO2), 499 thousand tons of nitrogen oxides (NOX) and 0.8 tons of mercury (Hg).7

Through 2030, the estimated energy savings would result in cumulative emissions 

reductions of 96 Mt of CO2.

The value of the CO2 reductions is calculated using a range of values per metric 

ton of CO2 (otherwise known as the Social Cost of Carbon (SCC)) developed by an 

interagency process.).

8

 6 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are presented in short tons.

The derivation of the SCC values is discussed in section IV.M. 

DOE estimates the present monetary value of the CO2 emissions reduction is between 

$2.5 and $36.76 billion. DOE also estimates the present monetary value of the NOX

7 DOE calculates emissions reductions relative to the AEO2013 reference case, which generally represents 

current legislation and environmental regulations for which implementing regulations were available as of 

December 31, 2012

8 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 

12866. Interagency Working Group on Social Cost of Carbon, United States Government. May 2013; 

revised November 2013. http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technicalupdate-social-cost-of-carbon-for-regulator-impact-analysis.pdf.

Comment [A6]: Change recommended by OIRA.

Comment [A7]: Footnote recommended by 

OIRA.

Comment [A8]: Value updated to reflect revised 

Social Cost of Carbon values announced by OIRA 

on Nov. 1, 2013.
19

emissions reduction is $0.3 billion at a 7-percent discount rate and $0.6 billion at a 3-

percent discount rate.9

Table I.7 summarizes the national economic costs and benefits expected to result 

from the proposed standards for electric motors.

 9 DOE is currently investigating valuation of avoided Hg and SO2 emissions.
20

Table I.7 Summary of National Economic Benefits and Costs of Electric Motors 

Energy Conservation Standards, Present Value for Motors Shipped in 2015-2044 in 

Billion 2012$

Category

Present 

Value Discount 

Rate Billion 2012$

Benefits

Consumer Operating Cost Savings 14.8 7%

34.9 3%

CO2 Reduction Monetized Value ($12.911.8/t 

case)*

2.5 5%

CO2 Reduction Monetized Value ($40.839.7/t 

case)*

11.98 3%

CO2 Reduction Monetized Value ($6261.2/t 

case)*

19.118.9 2.5%

CO2 Reduction Monetized Value ($117.0/t case)* 36.76 3%

NOX Reduction Monetized Value (at 

$2,639/ton)**

0.3 7%

0.6 3%

Total Benefits† 27.026.9 7%

47.54 3%

Costs

Consumer Incremental Installed Costs 6.1 7%

11.7 3%

Net Benefits

Including CO2 and NOX Reduction Monetized 

Value 

20.98 7%

35.97 3%

* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of 

values are based on the average SCC from the three integrated assessment models, at discount rates of 2.5, 

3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all three models 

at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change 

further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The 

SCC time series incorporate an escalation factor.

** The value represents the average of the low and high NOX values used in DOE’s analysis.

† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to SCC value of 

$40.839.7/t in 2015.

The benefits and costs of today’s proposed standards for electric motors, sold in 

years 2015−2044, can also be expressed in terms of annualized values. The annualized 

monetary values are the sum of (1) the annualized national economic value of the benefits 

from operation of the commercial and industrial equipment that meet the proposed 

Comment [A9]: Values in table and footnote 

updated to reflect revised Social Cost of Carbon 

values announced by OIRA on Nov. 1, 2013.

Comment [A10]: Change recommended by 

OIRA

Comment [A11]: Change recommended by 

OIRA.
21

standards (consisting primarily of operating cost savings from using less energy, minus 

increases in equipment purchase and installation costs, which is another way of 

representing consumer NPV), and (2) the annualized monetary value of the benefits of 

emission reductions, including CO2 emission reductions.10

Although combining the values of operating savings and CO2 emission reductions 

provides a useful perspective, two issues should be considered. First, the national 

operating savings are domestic U.S. consumer monetary savings that occur as a result of 

market transactions while the value of CO2 reductions is based on a global value. Second, 

the assessments of operating cost savings and CO2 savings are performed with different 

methods that use different time frames for analysis. The national operating cost savings is 

measured over the lifetime of electric motors shipped in years 2015–2044. The SCC 

values, on the other hand, reflect the present value of some future climate-related impacts 

resulting from the emission of one ton of carbon dioxide in each year. These impacts 

continue well beyond 2100.

Estimates of annualized benefits and costs of the proposed standards for electric 

motors are shown in Table I.8. The results under the primary estimate are as follows. 

Using a 7-percent discount rate for benefits and costs other than CO2 reduction, for which 

 10 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized

values. First, DOE calculated a present value in 2013, the year used for discounting the NPV of total 

consumer costs and savings, for the time-series of costs and benefits using discount rates of three and seven 

percent for all costs and benefits except for the value of CO2 reductions. For the latter, DOE used a range of 

discount rates, as shown in Table I.3. From the present value, DOE then calculated the fixed annual 

payment over a 30-year period (2015 through 2044) that yields the same present value. The fixed annual 

payment is the annualized value. Although DOE calculated annualized values, this does not imply that the 

time-series of cost and benefits from which the annualized values were determined is a steady stream of 

payments.
22

DOE used a 3-percent discount rate along with the average SCC series that uses a 3-

percent discount rate, the cost of the standards proposed in today’s rule is $462 million 

per year in increased equipment costs; while the estimated benefits are $1,114 million per 

year in reduced equipment operating costs, $592586 million in CO2 reductions, and $21.5

million in reduced NOX emissions. In this case, the net benefit would amount to 

$1,265957 million per year. Using a 3-percent discount rate for all benefits and costs and 

the average SCC series, the estimated cost of the standards proposed in today’s rule is 

$577 million per year in increased equipment costs; while the estimated benefits are 

$1,730 million per year in reduced operating costs, $592586 million in CO2 reductions, 

and $31.5 million in reduced NOX emissions. In this case, the net benefit would amount 

to approximately $1,776354 million per year. Comment [A12]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
23

Table I.8 Annualized Benefits and Costs of Proposed Energy Conservation 

Standards for Electric Motors, in Million 2012$

Discount 

Rate

Primary 

Estimate*

Low Net 

Benefits 

Estimate*

High Net 

Benefits 

Estimate*

million 2012$/year

Benefits

Consumer Operating Cost 

Savings

7% 1,114 924 1,358

3% 1,730 1,421 2,134

CO2 Reduction Monetized 

Value ($12.911.8/t case)* 5% 155.9 134.7 180.3 179

CO2 Reduction Monetized 

Value ($40.839.7/t case)* 3% 591.9 586 511.4 506 685.5 679

CO2 Reduction Monetized 

Value ($6261.2/t case)* 2.5% 892.3 882 771.1 762 1,033.8 1022

CO2 Reduction Monetized 

Value ($117.0/t case)* 3% 1,819.0 811 1,571.7 565 2,107.2 098

NOX Reduction Monetized 

Value (at $2,639/ton)**

7% 21.46 18.55 24.68

3% 31.48 27.20 36.39

Total Benefits†

7% plus 

CO2 range

1,291290 to 

2,954947

1,077 to 

2,514507

1,563562 to 

3,490481

7% 1,727721 1,454449 2,068061

3% plus 

CO2 range

1,917916 to 

3,580572

7701,583 to 

2,2073,014

2,351350 to 

4,277268

3% 2,353347 1,146955 2,856849

Costs

Incremental Installed Costs

7% 462 492 447

3% 577 601 569

Net Benefits

Total†

7% plus 

CO2 range

829585 to 

2,492016

5861,115 to 

2,0233,033

1,116353 to 

3,043438

7% 1,265957 9621,614 1,621887

3% plus 

CO2 range

1,340982 to 

3,0032,413

1691,781 to 

1,6063,700

1,782957 to 

3,7094,043

3% 1,776354 5462,280 2,287492

Comment [A13]: Values in table updated to 

reflect revised Social Cost of Carbon values 

announced by OIRA on Nov. 1, 2013.

Comment [A14]: Change recommended by 

OIRA
24

* This table presents the annualized costs and benefits associated with electric motors shipped in 

2015−2044. These results include benefits to consumers which accrue after 2044 from the equipment 

purchased in years 2015−2044. Costs incurred by manufacturers, some of which may be incurred in 

preparation for the rule, are not directly included, but are indirectly included as part of incremental 

equipment costs. The Primary, Low Benefits, and High Benefits Estimates are in view of projections of 

energy prices from the Annual Energy Outlook (AEO) 2013 Reference case, Low Estimate, and High 

Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected 

equipment price in the Primary Estimate, a declining rate for projected equipment price trends in the Low 

Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits 

Estimate. The methods used to derive projected price trends are explained in section IV.F.1.

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of 

values are based on the average SCC from the three integrated assessment models, at discount rates of 2.5, 

3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all three models 

at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change 

further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The 

SCC time series incorporate an escalation factor. The value for NOX is the average of the low and high 

values used in DOE’s analysis.

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to 

average SCC with 3-percent discount rate. In the rows labeled “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values 

are added to the full range of CO2 values.

DOE has tentatively concluded that the proposed standards represent the 

maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in the significant conservation of energy. DOE 

further notes that equipment achieving these standard levels are already commercially 

available for most equipment classes covered by today’s proposal. Based on the analyses 

described above, DOE has tentatively concluded that the benefits of the proposed 

standards to the Nation (energy savings, positive NPV of consumer benefits, consumer 

LCC savings, and emission reductions) would outweigh the burdens (loss of INPV for 

manufacturers and LCC increases for some consumers).

DOE also considered more-stringent energy efficiency levels as trial standard 

levels, and is still considering them in this rulemaking. However, DOE has tentatively 

concluded that the potential burdens of the more-stringent energy efficiency levels would 
25

outweigh the projected benefits. Depending on the comments that DOE receives in 

response to this notice and related information collected and analyzed during the course 

of this rulemaking, DOE may adopt energy efficiency levels presented in this notice that 

are either higher or lower than the proposed standards, or some combination of level(s) 

that incorporate the proposed standards in part.

II. Introduction

The following section briefly discusses the statutory authority underlying today’s 

proposed rule, as well as some relevant historical background related to the establishment 

of standards for electric motors.

A.

Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA or the 

Act), Pub. L. 94−163, as amended (42 U.S.C. 6291−6309) established the “Energy 

Conservation Program for Consumer Products Other Than Automobiles.” Part C of Title 

III of EPCA (42 U.S.C. 6311–6317) established a similar program for ‘‘Certain Industrial 

Equipment,’’ including electric motors.

Authority

11

 11 For editorial reasons, upon codification in the U.S. Code, Parts B and C were redesignated as Parts A and 

A-1, respectively.

The Energy Policy Act of 1992 (EPACT 1992) 

(Pub. L. 102-486) amended EPCA by establishing energy conservation standards and test 

procedures for certain commercial and industrial electric motors (in context, “motors”) 

manufactured (alone or as a component of another piece of equipment) after October 24, 

1997. In December 2007, Congress passed into law the Energy Independence and 
26

Security Act of 2007 (EISA 2007) (Pub. L. No. 110–140). Section 313(b)(1) of EISA 

2007 updated the energy conservation standards for those electric motors already covered 

by EPCA and established energy conservation standards for a larger scope of motors not 

previously covered by standards. (42 U.S.C. 6313(b)(2)) EPCA directs the Secretary of 

Energy to publish a final rule no later than 24 months after the effective date of the 

previous final rule to determine whether to amend the standards already in effect. Any 

such amendment shall apply to electric motors manufactured after a date which is five 

years after either: (1) the effective date of the previous amendment or (2) if the previous 

final rule did not amend the standards, the earliest date by which a previous amendment 

could have been effective. (42 U.S.C. 6313(b)(4)(B)) 

DOE is issuing today’s proposal pursuant to Part C of Title III, which establishes 

an energy conservation program for covered equipment that consists essentially of four 

parts: (1) testing; (2) labeling; (3) the establishment of Federal energy conservation 

standards; and (4) certification and enforcement procedures. For those electric motors for 

which Congress established standards, or for which DOE amends or establishes 

standards, the DOE test procedure must be the prescribed procedures that currently 

appear at 10 CFR part 431 that apply to electric motors. The test procedure is subject to 

review and revision by the Secretary in accordance with certain criteria and conditions. 

(See 42 U.S.C. 6314(a))

Section 343(a)(5)(B)−(C) of EPCA, 42 U.S.C. 6314(a)(5)(B)−(C), provides in 

part that if the NEMA- and IEEE-developed test procedures are amended, DOE shall so 
27

amend the test procedures under 10 CFR part 431, unless the Secretary determines, by 

rule, that the amended industry procedures would not meet the requirements for test 

procedures to produce results that reflect energy efficiency, energy use, and estimated 

operating costs of the tested motor, or, would be unduly burdensome to conduct. (42 

U.S.C. 6314(a)(2)−(3), (a)(5)(B)) As newer versions of the NEMA and IEEE test 

procedures for electric motors were developed, DOE updated 10 CFR part 431 to reflect 

these changes. Manufacturers of covered equipment must use the prescribed DOE test 

procedure as the basis for certifying to DOE that their equipment complies with the 

applicable energy conservation standards adopted under EPCA and when making 

representations to the public regarding the energy use or efficiency of such equipment. 

(42 U.S.C. 6314(d)) Similarly, DOE must use these test procedures to determine whether 

the equipment comply with standards adopted pursuant to EPCA. Id. 

DOE must follow specific statutory criteria for prescribing new and amended 

standards for covered equipment. In the case of electric motors, the criteria set out in 

relevant subsections of 42 U.S.C. 6295, which normally applies to standards related to 

consumer products, also apply to the setting of energy conservation standards for motors

via 42 U.S.C. 6316(a). As indicated above, new and amended standards must be designed 

to achieve the maximum improvement in energy efficiency that is technologically 

feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 6316(a)) Furthermore, 

DOE may not adopt any standard that would not result in the significant conservation of 

energy. (42 U.S.C. 6295(o)(3) and 6316(a)) Moreover, DOE may not prescribe a 

standard: (1) for certain equipment, including electric motors, if no test procedure has 
28

been established for the product, or (2) if DOE determines by rule that the proposed 

standard is not technologically feasible or economically justified. (42 U.S.C. 

6295(o)(3)(A)-(B) and 6316(a)) In deciding whether a proposed standard is economically 

justified, DOE must determine whether the benefits of the standard exceed its burdens. 

(42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) DOE must make this determination after 

receiving comments on the proposed standard, and by considering, to the greatest extent 

practicable, the following seven factors:

1. The economic impact of the standard on manufacturers and consumers of the 

products subject to the standard;

2. The savings in operating costs throughout the estimated average life of the 

covered products in the type (or class) compared to any increase in the price, initial 

charges, or maintenance expenses for the covered products that are likely to result from 

the imposition of the standard; 

3. The total projected amount of energy, or as applicable, water, savings likely to 

result directly from the imposition of the standard;

4. Any lessening of the utility or the performance of the covered products likely to 

result from the imposition of the standard;

5. The impact of any lessening of competition, as determined in writing by the 

Attorney General, that is likely to result from the imposition of the standard;

6. The need for national energy and water conservation; and

7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(I)–(VII) and 6316(a))
29

EPCA, as codified, also contains what is known as an “anti-backsliding” 

provision, which prevents the Secretary from prescribing any new or amended standards

that either increase the maximum allowable energy use or decrease the minimum required 

energy efficiency of a covered product. (42 U.S.C. 6295(o)(1) and 6316(a)) Also, the 

Secretary may not prescribe an amended or new standard if interested persons have 

established by a preponderance of the evidence that the standard is likely to result in the 

unavailability in the United States of any covered product type (or class) of performance 

characteristics (including reliability), features, sizes, capacities, and volumes that are 

substantially the same as those generally available in the United States. (42 U.S.C. 

6295(o)(4) and 6316(a))

Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less 

than three times the value of the energy savings during the first year that the consumer 

will receive as a result of the standard, as calculated under the applicable test procedure. 

(42 U.S.C. 6295(o)(2)(B)(iii) and 6316(a))

Additionally, 42 U.S.C. 6295(q)(1), as applied to covered equipment via 42 

U.S.C. 6316(a), specifies requirements when promulgating a standard for a type or class 

of covered product that has two or more subcategories. DOE must specify a different 

standard level than that which applies generally to such type or class of equipment for 
30

any group of covered equipment that have the same function or intended use if DOE 

determines that equipment within such group: (A) consume a different kind of energy 

from that consumed by other covered equipment within such type (or class); or (B) have 

a capacity or other performance-related feature which other equipment within such type 

(or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 

6294(q)(1) and 6316(a)). In determining whether a performance-related feature justifies a 

different standard for a group of products, DOE must consider such factors as the utility 

to the consumer of the feature and other factors DOE deems appropriate. Id. Any rule 

prescribing such a standard must include an explanation of the basis on which such 

higher or lower level was established. (42 U.S.C. 6295(q)(2) and 6316(a))

Federal energy conservation requirements generally supersede State laws or 

regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 

6297(a)–(c) and 6316(a)) DOE may, however, grant waivers of Federal preemption for 

particular State laws or regulations, in accordance with the procedures and other 

provisions set forth under 42 U.S.C. 6297(d)).

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011 (76 FR 3281 (Jan. 21, 2011)). EO 13563 is supplemental to and 

explicitly reaffirms the principles, structures, and definitions governing regulatory review 

established in Executive Order 12866. To the extent permitted by law, agencies are 

required by Executive Order 13563 to: (1) propose or adopt a regulation only upon a 

reasoned determination that its benefits justify its costs (recognizing that some benefits 
31

and costs are difficult to quantify); (2) tailor regulations to impose the least burden on 

society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in 

choosing among alternative regulatory approaches, those approaches that maximize net 

benefits (including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include identifying changing future compliance 

costs that might result from technological innovation or anticipated behavioral changes.

For the reasons stated in the preamble, DOE believes that today’s NOPR is consistent 

with these principles, including the requirement that, to the extent permitted by law, 

benefits justify costs and that net benefits are maximized.

Consistent with EO 13563, and the range of impacts analyzed in this rulemaking, 

the energy efficiency standard proposed herein by DOE achieves maximum net benefits. Comment [A15]: Change recommended by 

OIRA.
32

B.

1. Current Standards

Background

An electric motor is a device that converts electrical power into rotational 

mechanical power. The outside structure of the motor is called the frame, which houses a 

rotor (the spinning part of the motor) and the stator (the stationary part that creates a 

magnetic field to drive the rotor). Although many different technologies exist, DOE’s 

rulemaking is concerned with squirrel-cage induction motors, which represent the 

majority of electric motor energy use. In squirrel-cage induction motors, the stator drives 

the rotor by inducing an electric current in the squirrel-cage, which then reacts with the 

rotating magnetic field to propel the rotor in the same way a person can repel one 

handheld magnet with another. The squirrel-cage used in the rotor of induction motors 

consists of longitudinal conductive bars (rotor bars) connected at both ends by rings (end 

rings) forming a cage-like shape. Among other design parameters, motors can vary in 

horsepower, number of “poles” (which determines how quickly the motor rotates), and 

torque characteristics. Most motors have “open” frames that allow cooling airflow 

through the motor body, though some have enclosed frames that offer added protection 

from foreign substances and bodies. DOE regulates various motor types from between 1 

and 500 horsepower, with 2, 4, 6, and 8 poles, and with both open and enclosed frames. 

EPACT 1992 amended EPCA by establishing energy conservation standards and 

test procedures for certain commercial and industrial electric motors manufactured either 
33

alone or as a component of another piece of equipment after October 24, 1997. Section 

313 of EISA 2007 amended EPCA by: (1) striking the definition of “electric motor” 

provided under EPACT 1992, (2) setting forth definitions for “general purpose electric 

motor (subtype I)” and “general purpose electric motor (subtype II),” and (3) prescribing 

energy conservation standards for “general purpose electric motors (subtype I),” “general 

purpose electric motors (subtype II), “fire pump electric motors,” and “NEMA Design B 

general purpose electric motors” with a power rating of more than 200 horsepower but 

not greater than 500 horsepower. (42 U.S.C. 6311(13), 6313(b)). The current standards 

for these motors, which are reproduced in the proposed regulatory text at the end of this 

notice, are divided into four tables that prescribe specific efficiency levels for each of 

those groups of motors.

2. History of Standards Rulemaking for Electric Motors

On October 5, 1999, DOE published in the Federal Register, a final rule to 

implement the EPACT 1992 electric motor requirements. 64 FR 54114. In response to 

EISA 2007, on March 23, 2009, DOE updated, among other things, the corresponding 

electric motor regulations at 10 CFR part 431 with the new definitions and energy 

conservation standards. 74 FR 12058. On December 22, 2008, DOE proposed to update 

the test procedures under 10 CFR part 431 both for electric motors and small electric 

motors. 73 FR 78220. DOE finalized key provisions related to small electric motor 

testing in a 2009 final rule at 74 FR 32059 (July 7, 2009), and further updated the test 

procedures for electric motors and small electric motors at 77 FR 26608 (May 4, 2012). 

The May 2012 final rule primarily focused on updating various definitions and 
34

incorporations by reference related to the current test procedure. In that rule, DOE 

promulgated a regulatory definition of “electric motor” to account for EISA 2007’s 

removal of the previous statutory definition of “electric motor.” DOE also clarified 

definitions related to those motors that EISA 2007 laid out as part of EPCA’s statutory

framework, including motor types that DOE had not previously regulated. See generally, 

id. at 26613-26619. DOE published a new proposed test procedure rulemaking on June 

26, 2013, that proposes to further refine some existing electric motor definitions and add 

certain definitions and test procedure preparatory steps to address a wider variety of 

electric motor types than are currently regulated. 78 FR 38456.

Regarding the compliance date that would apply to the requirements of today’s 

proposed rule, EPCA directs the Secretary of Energy to publish a final rule no later than 

24 months after the effective date of the previous final rule to determine whether to 

amend the standards in effect for such equipment. Any such amendment shall apply to 

electric motors manufactured after a date which is five years after –

(i) the effective date of the previous amendment; or

(ii) if the previous final rule did not amend the standards, the earliest date by 

which a previous amendment could have been effective. (42 U.S.C. § 

6313(b)(4))

As described previously, EISA 2007 constitutes the most recent amendment to 

EPCA and energy conservation standards for electric motors. Because these amendments 
35

went into effectrequired compliance on December 19, 2010, DOE had indicated during 

the course of public meetings held in advance of today’s proposal that motors 

manufactured after December 19, 2015, would need to comply with any applicable new 

standards that DOE may set as part of this rulemaking. Today’s proposed standards

would apply to motors manufactured starting on December 19, 2015. As noted in detail 

later in this notice, however, DOE is interested in receiving comments on the ability of 

manufacturers to meet this deadline. 

DOE received numerous comments from interested parties who provided 

significant input to DOE in response to the framework document and preliminary 

analysis that the agency had issued. See 75 FR 59657 (Sept. 28, 2010) (framework 

document notice of availability) and 77 FR 43015 (July 23, 2012) (preliminary analysis 

notice of availability). During the framework document comment period for this 

rulemaking, several interested parties urged DOE to consider including additional motor 

types currently without energy conservation standards in DOE’s analyses and 

establishing standards for such motor types. In the commenters’ view, this approach 

would more effectively increase energy savings than setting more stringent standards for 

currently regulated electric motors. In response, DOE published a Request for 

Information (RFI) seeking public comments from interested parties regarding 

establishment of energy conservation standards for several types of definite and special 

purpose motors for which EISA 2007 did not provide energy conservation standards. 76 

FR 17577 (March 30, 2011). DOE received comments responding to the RFI advocating 

Comment [A16]: Change recommended by 

OIRA.
36

that DOE regulate many of the electric motors discussed in the RFI, as well as many 

additional motor types. 

Then, on August 15, 2012, a group of interested parties (the “Motor Coalition” 12)

submitted a Petition to DOE asking the agency to adopt a consensus stakeholder proposal

that would amend the energy conservation standards for electric motors. The Motor 

Coalition’s proposal advocated expanding the scope of coverage to a broader range of 

motors than what DOE currently regulates and it recommended that energy conservation 

standards for all covered electric motors be set at levels that are largely equivalent to 

what DOE proposes in today’s NOPR (i.e., efficiency levels in NEMA MG1-2011 Tables

12-12 and 20-B).

13 

DOE received several comments from NEMA regarding the December 19, 2015,

compliance date. First, NEMA pointed out that all publications and presentations prior to 

that preliminary analysis public meeting on August 21, 2012, indicated that DOE’s 

statutory deadline for any final rule was December 19, 2012, but at the public meeting 

DOE showed a final rule completion date as the end of 2013. (NEMA, No. 54 at pp. 2, 6-

7) NEMA questioned the authority by which DOE has decided to delay the Final Rule 

beyond the date of December 19, 2012, as stipulated in EPCA. (NEMA, No. 54 at p. 2) 

 12 The members of the Motor Coalition include: National Electrical Manufacturers Association, American 

Council for an Energy‐Efficient Economy, Appliance Standards Awareness Project, Alliance to Save 

Energy, Earthjustice, Natural Resources Defense Council, Northwest Energy Efficiency Alliance, 

Northeast Energy Efficiency Partnerships, and Northwest Power and Conservation Council. 13 DOE’s proposal differs from that of the Motor Coalition in that DOE’s proposal covers brake motors and 

does not set separate standards for U-frame motors. It also seeks supplemental information regarding 

certain 56-frame motors. See section IV.A.2 for details.
37

Second, NEMA commented that shortening the time to comply with any new 

standards from three years to two years would place additional burdens on manufacturers 

considering all of the electric motors types that DOE is considering in the preliminary 

TSD, the burdensome candidate standard levels that DOE is considering, and the 

possibility of expanding the scope of energy conservation standards. (NEMA, No. 54 at 

pp. 2, 7; NEMA, Public Meeting Transcript, No. 60 at p. 30) 

Third, NEMA also noted that when EPACT 1992 first added electric motors as 

covered equipment, motor manufacturers were allowed five years to modify motor 

designs and certify compliance to the new standards. (NEMA, No. 54 at p. 7) It further 

noted that NEMA MG 1-1998 subsequently introduced NEMA Premium efficiency 

standards, and between 1998 and 2007 manufacturers voluntarily increased the number of 

NEMA Premium efficiency motor models available. (NEMA, No. 54 at p. 7) NEMA 

commented that this transition period eased the burden of satisfying the added stringency 

of the standards set by EISA 2007, which allowed three years to update energy 

conservation standards to mandatory NEMA Premium levels for certain motor ratings. 

(NEMA, No. 54 at p. 7) NEMA added that adhering to the statutory deadline for setting 

any new and amended standards would minimize any disruption in the electric motor 

market. (NEMA, No. 54 at p. 8) NEMA also commented that since the EISA 2007 

standards were enacted, only a limited number of motor ratings above NEMA Premium 

have been offered because there is not sufficient space available in most frame ratings to 

increase the efficiency. (NEMA, No. 54 at p. 7) NEMA added that any standards above 
38

NEMA Premium would force manufacturers to redesign entire product lines and go 

through the process of certification and compliance, all of which would be expected to 

take longer than three years. (NEMA, No. 54 at pp. 7, 8)

Finally, NEMA also attempted to illustrate the difficulty of reaching NEMA 

Premium levels in IEC frame motors, noting that a comparison of certificates of 

compliance before and after EISA 2007 standards went into effect would demonstrate 

that some manufacturers were forced to abandon the U.S. electric motor market for some 

period of time before they could update their IEC frame motor product line. (NEMA, No. 

54 at p. 8) NEMA added that increasing the efficiency of subtype II motors to NEMA 

Premium efficiency and expanding the scope of motors subject to energy conservation 

standards (many of which currently have efficiency levels below EPACT 1992 energy 

conservation levels) will also require extensive redesign, and manufacturers would be 

forced to comply in only three years. (NEMA, No. 54 at p. 8)

During the course of preparing for the electric motors energy conservation 

standards rulemaking, information was submitted to DOE by NEMA, ASAP, and CDA in 

response to DOE’s RFI and then later in the Petition from the Motors Coalition14

 14 The Petition is available at: 

that 

caused DOE to reevaluate the scope of electric motors it was considering in this 

rulemaking. That Petition, and related supporting information, suggested that DOE apply 

the NEMA Premium efficiency levels (“NEMA Premium”) to a much broader swath of 

electric motors than are currently regulated by DOE, rather than increase the stringency 

http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD0027-0035
39

of the standards that had only recently come into effect (i.e., EISA 2007 standards). As 

part of its routine practice, DOE reviewed the information and the merits of the Petition. 

With the potential prospect of expanding the types of motors that would be regulated by 

standards, DOE recognized the need to amend its test procedures to add the necessary 

testing preparatory steps (i.e. test set-up procedures) to DOE’s regulations. The inclusion 

of these steps would help ensure that manufacturers of these new motor types would be 

performing the same steps as are performed when testing currently regulated motors.

The compliance date prescribed by statute would require manufacturers to begin 

manufacturing compliant motors by December 19, 2015. Accordingly, DOE is proposing 

a December 19, 2015, compliance date. DOE, however, recognizes that the statute also 

contemplated a three-year lead time for manufacturers in order to account for the 

potential logistical and production hurdles that manufacturers may face when 

transitioning to the new standards. Accordingly, while DOE is proposing a December 19, 

2015 compliance deadline, it is also interested in comments that detail any hurdles with 

meeting this compliance deadline along with the merits of receiving the three-year leadtime also set out in the statute.

3. Process for Setting Energy Conservation Standards

Section 325(o) provides criteria for prescribing new or amended standards which 

are designed to achieve the maximum improvement in energy efficiency and for which 

the Secretary of Energy determines are technologically feasible and economically 

justified. Consequently, DOE must consider, to the greatest extent practicable, the 

following seven factors:
40

(1) the economic impact of the standard on the manufacturers and consumers of 

the products subject to the standard;

(2) the savings in operating costs throughout the estimated average life of the 

products compared to any increase in the prices, initial costs, or maintenance 

expenses for the products that are likely to result from the imposition of the 

standard;

(3) the total projected amount of energy savings likely to result directly from the 

imposition of the standard;

(4) any lessening of the utility or the performance of the covered products likely 

to result from the imposition of the standard;

(5) the impact of any lessening of competition, as determined in writing by the 

Attorney General, that is likely to result from the imposition of the standard;

(6) the need for national energy conservation; and

(7) other factors the Secretary considers relevant. (42 U.S.C. 6295(o)(2)(B)(i) and 

6316(a))
41

Other statutory requirements are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), 

(2)(B)(ii)–(iii), and (3)–(4). These criteria apply to the setting of standards for electric 

motors through 42 U.S.C. 6316(a).

III. General Discussion

DOE developed today’s proposed rule after considering input, including verbal

and written comments, data, and information from interested parties that represent a 

variety of interests. All commenters, along with their corresponding abbreviations and 

affiliations, are listed in Table III.1 below. The issues raised by these commenters are 

addressed in the discussions that follow.

Table III.1 Summary of NOPR Commenters

Company or Organization Abbreviation Affiliation

Air Movement and Control 

Association International, Inc. AMCAI Trade Association

Alliance to Save Energy ASE Energy Efficiency Advocates

American Council for an EnergyEfficient Economy ACEEE Energy Efficiency Advocates

Appliance Standards Awareness 

Project ASAP Energy Efficiency Advocates

Baldor Electric Co. Baldor Manufacturers

BBF & Associates BBF Representative for Trade 

Association

California Investor Owned 

Utilities CA IOUs Utilities

Copper Development Association CDA Trade Association

Earthjustice Earthjustice Energy Efficiency Advocates

Electric Apparatus Service 

Association EASA Trade Association

Flolo Corporation Flolo Other

Industrial Energy Consumers of 

America IECA Trade Association

Motor Coalition* MC

Energy Efficiency Advocates, 

Trade Associations, 

Manufacturers, Utilities

National Electrical Manufacturers NEMA Trade Association

Comment [A17]: Changed recommended by 

OIRA.
42

Association

Northwest Energy Efficiency 

Alliance NEEA Energy Efficiency Advocates

Northwest Power & Conservation 

Council NPCC Utilities

SEW-Eurodrive, Inc. SEWE Manufacturer

UL LLC UL Testing Laboratory

* The members of the Motor Coalition include: National Electrical Manufacturers Association (NEMA), 

American Council for an Energy‐Efficient Economy (ACEEE), Appliance Standards Awareness Project

(ASAP), Alliance to Save Energy (ASE), Earthjustice, Natural Resources Defense Council (NRDC), 

Northwest Energy Efficiency Alliance (NEEA), Northeast Energy Efficiency Partnerships (NEEP), and 

Northwest Power and Conservation Council (NPCC).

Subsequent to DOE’s preliminary analysis public meeting, several other 

interested parties submitted comments supporting the Petition. Those supporters 

included: BBF and Associates, the Air Movement and Control Association International, 

Inc., U.S. Senators Lisa Murkowski and Jeff Bingaman, the Hydraulic Institute, the 

Arkansas Economic Development and Commission- Energy Office, and the Power 

Transmission Distributors Association.

A.

On June 26, 2013, DOE published a notice that proposed to incorporate

definitions for certain motor types not currently subject to energy conservation standards

(78 FR 38456). The notice also proposed to clarify several definitions for motor types 

currently regulated by energy conservation standards and adding some necessary steps to 

facilitate the testing of certain motor types that DOE does not currently require to meet

standards. During its preliminary analysis stage, DOE received comments concerning 

definitions and test procedure set-up steps suggested for testing motors under an 

expanded scope approach. DOE addressed the comments as part of the test procedure 

NOPR. For additional details, see 78 FR 38456 (June 26, 2013). 

Test Procedure
43

B.

When evaluating and establishing energy conservation standards, DOE divides 

covered equipment into equipment classes by the type of energy used or by capacity or 

other performance-related features that would justify a different standard. In making a 

determination whether a performance-related feature would justify a different standard, 

DOE must consider factors such as the utility to the consumer of the feature and other 

factors that DOE determines are appropriate. (42 U.S.C. 6295(q) and 6316(a))

Equipment Classes and Current Scope of Coverage

Existing energy conservation standards cover electric motors that fall into four 

categories based on physical design features of the motor. These four categories are:

general purpose electric motors (subtype I), general purpose electric motors (subtype II), 

fire pump electric motors, and NEMA Design B motors (with a horsepower rating from 

201 through 500). Definitions for each of these terms can be found at 10 CFR 431.12. 

C.

DOE has the authority to set energy conservation standards for a wider range of 

electric motors than those classified as general purpose electric motors (e.g., definite or 

special purpose motors). EPACT 1992 amended EPCA to include, among other things, a 

definition for the term “electric motor” – which the statute defined as including certain 

“general purpose” motors. (42 U.S.C. 6311(13)(A) (1992)) The amendments also defined 

the terms “definite purpose motors” and “special purpose motor.” (42 U.S.C. 

6311(13)(C) and (D)) (1992)) EPACT 1992 initially prescribed energy conservation 

standards for “electric motors” (i.e., subtype I general purpose electric motors) and 

Expanded Scope of Coverage
44

explicitly stated that these standards did not apply to definite purpose or special purpose 

motors. (42 U.S.C. 6313(b)(1) (1992)) However, EISA 2007 struck the narrow EPACT 

1992 definition of “electric motor.” With the removal of this definition, the term 

“electric motor” became broader in scope. As a result of these changes, both definite and 

special purpose motors fell under the broad heading of “electric motors” that previously 

only applied to “general purpose” motors. While EISA 2007 prescribed standards for 

general purpose motors, the Act did not apply those standards to definite or special 

purpose motors. (42 U.S.C. 6313(b) (2012)) 

Although DOE believes that EPCA, as amended through EISA 2007, provides 

sufficient statutory authority for the regulation of special purpose and definite purpose 

motors as “electric motors,” DOE notes it has additional authority under section 10 of the 

American Energy Manufacturing Technical Corrections Act, Pub. L. 112-210, which 

amended DOE’s authority to regulate commercial and industrial equipment under section 

340(2)(B) of EPCA to include “other motors,” in addition to “electric motors”. (42 

U.S.C. 6311(2)(B)(xiii)). Therefore, even if special and definite purpose motors were not 

“electric motors,” special and definite purpose motors would be considered as “other 

motors” that EPCA already treats as covered industrial equipment.15

 15 EPCA specifies the types of industrial equipment that can be classified as covered in addition to the 

equipment enumerated in 42 U.S.C. 6311(1). This equipment includes “other motors” (to be codified at 42 

U.S.C. 6311(2)(B)). Industrial equipment must also, without regard to whether such equipment is in fact 

distributed in commerce for industrial or commercial use, be of a type that: (1) in operation consumes, or is 

designed to consume, energy in operation; (2) to any significant extent, is distributed in commerce for 

industrial or commercial use; and (3) is not a covered product as defined in 42 U.S.C. 6291(a)(2) of EPCA, 

other than a component of a covered product with respect to which there is in effect a determination under 

42 U.S.C. 6312(c). (42 U.S.C. 6311 (2)(A)). Data from the 2002 United States Industrial Electric Motor 

Systems Market Opportunities Assessment estimated total energy use from industrial motor systems to be 

747 billion kWh. Based on the expansion of industrial activity, it is likely that current annual electric motor 

 
45

Consistent with EISA 2007’s reworking of the definition, the 2012 test procedure 

final rule broadly defined the term “electric motor.” at 10 CFR 431.12. (77 FR 26608 

(May 4, 2012)). That definition covers “general purpose,” “special purpose” and “definite

purpose” electric motors (as defined by EPCA). As noted above, EPCA did not require 

either “special purpose” or “definite purpose” motor types to meet energy conservation 

standards because they were not considered “general purpose” under the EPCA definition 

of “general purpose motor” − a necessary element to meet the pre-EISA 2007 “electric 

motor” definition. See 77 FR 26612. Because of the restrictive nature of the prior electric 

motor definition, along with the restrictive definition of the term “industrial equipment,” 

DOE would have been unable to set standards for such motors without this change. (See 

42 U.S.C. 6311(2)(B) (2006) (limiting the scope of equipment covered under EPCA)) In 

view of the changes introduced by EISA 2007 and the absence of energy conservation 

standards for special purpose and definite purpose motors, as noted in chapter 2 of DOE’s 

July 2012 electric motors preliminary analysis technical support document (TSD),16

 energy use is higher than this figure. Electric motors are distributed in commerce for both the industrial and 

commercial sectors. According to data provided by the Motor Coalition, the number of electric motors 

manufactured in, or imported into, the United States is over five million electric motors annually, including 

special and definite purpose motors. Finally, special and definite purpose motors are not currently regulated 

under Title 10 of the Code of Federal Regulations, part 430 (10 CFR part 430).

it is 

DOE’s view that both of these motors are categories of “electric motors” covered under 

To classify equipment as covered commercial or industrial equipment, the Secretary must also determine 

that classifying the equipment as covered equipment is necessary for the purposes of Part A-1 of EPCA. 

The purpose of Part A-1 is to improve the efficiency of electric motors, pumps and certain other industrial 

equipment to conserve the energy resources of the nation. (42 U.S.C. 6312(a)-(b)) In today’s proposal, 

DOE has tentatively determined that the regulation of special and definite purpose motors is necessary to 

carry out the purposes of part A-1 of EPCA because regulating these motors will promote the conservation 

of energy supplies. Efficiency standards that may result from coverage would help to capture some portion 

of the potential for improving the efficiency of special and definite purpose motors.

16 The preliminary TSD published in July 2012 is available at: 

http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0027-0023
46

EPCA, as currently amended. Accordingly, DOE is proposing standards for certain 

definite purpose and special purpose motors. To this end, DOE is considering setting 

energy conservation standards for those motors that exhibit all of the following nine 

characteristics: 

• Is a single-speed, induction motor,

• Is rated for continuous duty (MG 1) operation or for duty type S1 (IEC),

• Contains a squirrel-cage (MG 1) or cage (IEC) rotor,

• Operates on polyphase alternating current 60-hertz sinusoidal line power,

• Is rated 600 volts or less,

• Has a 2-, 4-, 6-, or 8-pole configuration,

• Has a three-digit NEMA frame size (or IEC metric equivalent) or an 

enclosed 56 NEMA frame size (or IEC metric equivalent),

• Has no more than 500 horsepower, but greater than or equal to 1 

horsepower (or kilowatt equivalent), and

• Meets all of the performance requirements of a NEMA Design A, B, or C 

electric motor or an IEC design N or H electric motor.

However, motor types that exhibit all of the characteristics listed above, but that 

DOE does not believe should be subject to energy conservation standards at this time 

because of the current absence of a reliable and repeatable method to test them for 

efficiency, would be listed as motors that would not at this time be subject to energy 

conservation standards. Once a test procedure becomes available, DOE may consider 
47

setting standards for these motors at that time. See generally, 78 FR 38456 (June 26, 

2013). DOE requests comment on these nine characteristics and their appropriateness for 

outlining scope of coverage.

To facilitate the potential application of energy conservation standards to special 

and definite purpose motors, DOE proposed to define such motors and provide certain 

preparatory test procedure steps. 78 FR 38456 (June 26, 2013). The definitions under 

consideration would address motors currently subject to standards, specific motors DOE 

is considering requiring to meet standards, and some motors that will continue to not be 

required to meet particular energy conservation standards. Some of the clarifying 

definitions, such as the definitions for NEMA Design A and C electric motors, come 

from NEMA Standards Publication MG 1−2009, “Motors and Generators.” DOE 

understands that some of the motors addressed, such as partial motors and integral brake 

motors, do not have standard industry-accepted definitions. For such motor types, DOE 

worked with subject-matter experts (SMEs), manufacturers, and the Motor Coalition to 

create the working definitions that are proposed in the test procedure NOPR. (8 FR 38456

(June 26, 2013).

D.

1. General

Technological Feasibility

EPCA requires that any new or amended energy conservation standard that DOE 

prescribes shall be designed to achieve the maximum improvement in energy efficiency 

that DOE determines is technologically feasible. (42 U.S.C. 6295(o)(2)(A) and 6316(a)). 

Comment [A18]: Change recommended by 

OIRA.
48

In each standards rulemaking, DOE conducts a screening analysis based on information 

gathered on all current technology options and prototype designs that could improve the 

efficiency of the products or equipment that are the subject of the rulemaking. As the first 

step in such an analysis, DOE develops a list of technology options for consideration in 

consultation with manufacturers, design engineers, and other interested parties. DOE then 

determines which of those means for improving efficiency are technologically feasible.

Where DOE determines that particular technology options are technologically 

feasible, it further evaluates each technology option in view of the following additional 

screening criteria: (1) practicability to manufacture, install, or service; (2) adverse 

impacts on product utility or availability; and (3) adverse impacts on health or safety. 

Section IV.B of this notice addresses the results of the screening analysis for electric 

motors, particularly the designs DOE considered − those it screened out, and those that 

are the basis for the trial standard levels (TSLs) in this rulemaking. For further details on 

the screening analysis for this rulemaking, see chapter 4 of the NOPR TSD.

2. Maximum Technologically Feasible Levels

When DOE proposes to adopt a new or amended standard for a type or class of 

covered product, it must determine the maximum improvement in energy efficiency or 

maximum reduction in energy use that is technologically feasible for such product. (42 

U.S.C. 6295(p)(1)) This requirement also applies to DOE proposals to amend the 

standards for electric motors. See 42 U.S.C. 6316(a). Accordingly, in its engineering 

analysis, DOE determined the maximum technologically feasible (“max-tech”) 
49

improvements in energy efficiency for electric motors, using the design parameters for

the most efficient motors available on the market or in working prototypes. (See chapter 

5 of the NOPR TSD.) The max-tech levels that DOE determined for this rulemaking are 

described in section IV.C.3 of this proposed rule.

E.

1. Determination of Savings

Energy Savings

Section 325(o) of EPCA also provides that any new or amended energy 

conservation standard that DOE prescribes shall be designed to achieve the maximum 

improvement in energy efficiency that DOE determines is economically justified. (42 

U.S.C. 6295(o)(2)(A)−(B) and 6316(a)). In addition, in determining whether such 

standard is technologically feasible and economically justified, DOE may not prescribe 

standards for certain types or classes of electric motors if such standards would not result 

in significant energy savings. (42 U.S.C. 6295(o)(3)(B) and 6316(a)). For each TSL,

DOE projected energy savings from the motors that would be covered under this 

rulemaking and that would be purchased in the 30-year period that begins in the year of 

compliance with the new and amended standards (2015–2044). The savings are measured 

over the entire lifetime of equipment purchased in the 30-year period.17

 17 In the past DOE, presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings 

measured over the entire lifetime of equipment purchased in the 30-year period. DOE has chosen to modify 

its presentation of national energy savings to be consistent with the approach used for its national economic 

analysis.

DOE quantified 

the energy savings attributable to each TSL as the difference in energy consumption 

between each standards case and the base case. The base case represents a projection of 
50

energy consumption in the absence of new or amended mandatory efficiency standards, 

and considers market forces and policies that affect demand for more efficient equipment. 

DOE used its national impact analysis (NIA) spreadsheet model to estimate the 

energy savings from new and amended standards for the equipment that would be subject

to this rulemaking. The NIA spreadsheet model (described in section IV.H of this notice) 

calculates energy savings in site energy, which is the energy directly consumed by motors 

at the locations where they are used. For electricity, DOE reports national energy savings 

in terms of the savings in the energy that is used to generate and transmit the site 

electricity. To calculate source energy, DOE derives annual conversion factors from the 

model used to prepare the Energy Information Administration’s (EIA) Annual Energy 

Outlook (AEO).

DOE has begun to also estimate full-fuel-cycle energy savings. 76 FR 51282 

(August 18, 2011), as amended at 77 FR 49701 (August 17, 2012). The full-fuel-cycle 

(FFC) metric includes the energy consumed in extracting, processing, and transporting 

primary fuels, and thus presents a more complete picture of the impacts of energy 

efficiency standards. DOE’s approach is based on the calculation of an FFC multiplier for 

each of the energy types used by covered equipmentDOE’s evaluation of FFC savings is 

driven in part by the National Academy of Science’s (NAS) report on FFC measurement 

approaches for DOE’s Appliance Standards Program.18

 18 “Review of Site (Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building 

Appliance Energy- Efficiency Standards,’’ (Academy report) was completed in May 2009 and included 

The NAS report discusses that 
51

FFC was primarily intended for energy efficiency standards rulemakings where multiple 

fuels may be used by a particular product. In the case of this rulemaking pertaining to 

electric motors, only a single fuel—electricity—is consumed by the equipment. DOE’s 

approach is based on the calculation of an FFC multiplier for each of the energy types 

used by covered equipment. The methodology for estimating FFC does not project how 

fuel markets would respond to this particular standard rulemaking. The FFC methodology 

simply estimates how much additional energy, and in turn how many tons of emissions, 

may be displaced if the estimated fuel were not consumed by the equipment covered in 

this rulemaking. It is also important to note that inclusion of FFC savings does not affect 

DOE’s choice of proposed standards.

 

2. Significance of Savings

As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting a standard 

for a covered product unless such standard would result in “significant” energy savings. 

Although the term “significant” is not explicitly defined in EPCA, the U.S. Court of 

Appeals, in Natural Resources Defense Council v. Herrington

V.A

, 768 F.2d 1355, 1373 

(D.C. Cir. 1985), indicated that Congress intended “significant” energy savings in this 

context to be savings that were not “genuinely trivial.” DOE believes that the energy 

savings for all of the TSLs considered in this rulemaking (presented in section ) are 

 five recommendations. A copy of the study can be downloaded at: 

http://www.nap.edu/catalog.php?record_id=12670.

Comment [A19]: Change recommended by 

OIRA.
52

nontrivial, and, therefore, DOE considers them “significant” within the meaning of 

section 325 of EPCA.

F.

1. Specific Criteria

Economic Justification

EPCA provides seven factors to be evaluated in determining whether a potential 

energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The 

following sections detail how DOE addresses each of those factors in this rulemaking.

a. Economic Impact on Manufacturers and Consumers

In determining the impacts of a new or amended standard on manufacturers, DOE 

first uses an annual cash-flow approach to determine the quantitative impacts. This step 

includes both a short-term assessment—based on the cost and capital requirements during 

the period between when a regulation is issued and when entities must comply with the 

regulation—and a long-term assessment over a 30-year period.19

 19 DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.

The industry-wide 

impacts analyzed include industry net present value (INPV), which values the industry on 

the basis of expected future cash flows; cash flows by year; changes in revenue and 

income; and other measures of impact, as appropriate. Second, DOE analyzes and reports 

the impacts on different types of manufacturers, including impacts on small 

manufacturers. Third, DOE considers the impact of standards on domestic manufacturer 

employment and manufacturing capacity, as well as the potential for standards to result in 

Comment [A20]: Footnote recommended by 

OIRA.
53

plant closures and loss of capital investment. Finally, DOE takes into account cumulative 

impacts of various DOE regulations and other regulatory requirements on manufacturers.

For individual consumers, measures of economic impact include the changes in 

life-cycle cost (LCC) and payback period (PBP) associated with new or amended 

standards. The LCC, addressed as “savings in operating costs” at 42 U.S.C. 

6295(o)(2)(B)(i)(II), is one of seven factors considered in determining the economic 

justification for a new or amended standard and is discussed in the following section. For 

consumers in the aggregate, DOE also calculates the national net present value of the 

economic impacts applicable to a particular rulemaking.

b. Life-Cycle Costs

The LCC is the sum of the purchase price of a piece of equipment (including its 

installation) and the operating expense (including energy, maintenance, and repair 

expenditures) discounted over the lifetime of that equipment. The LCC savings for the 

considered efficiency levels are calculated relative to a base case that reflects projected 

market trends in the absence of new or amended standards. The LCC analysis requires a 

variety of inputs, such as equipment prices, equipment energy consumption, energy 

prices, maintenance and repair costs, equipment lifetime, and consumer discount rates. 

For its analysis, DOE assumes that consumers, as users of electric motors, will purchase 

the considered equipment in the first year of compliance with new or amended standards. 
54

To account for uncertainty and variability in specific inputs, such as equipment 

lifetime and discount rate, DOE uses a distribution of values with probabilities attached 

to each value. DOE identifies the percentage of consumers estimated to receive LCC 

savings or experience an LCC increase, in addition to the average LCC savings 

associated with a particular standard level. DOE also evaluates the LCC impacts of 

potential standards on identifiable subgroups of consumers that may be affected 

disproportionately by a national standard.

c. Energy Savings

Although significant conservation of energy is a separate statutory requirement 

for imposing an energy conservation standard, EPCA requires DOE, in determining the 

economic justification of a standard, to consider the total projected energy savings that 

are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As 

discussed in section IV.H, DOE uses the NIA spreadsheet to project national energy 

savings.

d. Lessening of Utility or Performance

In establishing classes of products, and in evaluating design options and the 

impact of potential standard levels, DOE evaluates standards that would not lessen the 

utility or performance of the considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) As 

noted earlier, the substance of this provision applies to the equipment at issue in today’s 

proposal as well. TheDOE has determined that the standards proposed in today’s notice

will not reduce the utility or performance of the equipment under consideration in this 
55

rulemaking. One piece of evidence for this claim includes the fact that many motors are 

already commonly being sold at the proposed levels (NEMA’s “Premium” designation). 

A second piece of evidence is that the proposed standards closely track the 

recommendations of NEMA, which represents manufacturers who understand deeply the 

design compromises entailed in reaching higher efficiencies and who would be acting 

against the interest of their customers in recommending standards that would harm 

performance or utility.

e. Impact of Any Lessening of Competition

EPCA directs DOE to consider the impact of any lessening of competition, as 

determined in writing by the Attorney General, that is likely to result from the imposition 

of a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V). It also directs the Attorney General to 

determine the impact, if any, of any lessening of competition likely to result from a 

proposed standard and to transmit such determination to the Secretary of Energy within 

60 days of the publication of a proposed rule, together with an analysis of the nature and 

extent of the impact. (42 U.S.C. 6295(o)(2) (B)(ii)) DOE will transmit a copy of today’s 

proposed rule to the Attorney General with a request that the Department of Justice 

(DOJ) provide its determination on this issue. DOE will address the Attorney General’s 

determination in the final rule.

f. Need for National Energy Conservation

The energy savings from the proposed standards are likely to provide 

improvements to the security and reliability of the Nation’s energy system. Reductions in 

Comment [A21]: Change recommended by 

OIRA.
56

the demand for electricity also may result in reduced costs for maintaining the reliability 

of the Nation’s electricity system. DOE conducts a utility impact analysis to estimate how 

standards may affect the Nation’s needed power generation capacity. 

The proposed standards also are likely to result in environmental benefits in the 

form of reduced emissions of air pollutants and greenhouse gases associated with energy 

production. DOE reports the emissions impacts from today’s standards, and from each 

TSL it considered, in section V.B.4 of this notice. DOE also reports estimates of the 

economic value of emissions reductions resulting from the considered TSLs.

g. Other Factors

EPCA allows the Secretary of Energy, in determining whether a standard is 

economically justified, to consider any other factors that the Secretary deems to be 

relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) 

2. Rebuttable Presumption

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable 

presumption that an energy conservation standard is economically justified if the 

additional cost to the consumer of a product that meets the standard is less than three 

times the value of the first year’s energy savings resulting from the standard, as 

calculated under the applicable DOE test procedure. DOE’s LCC and PBP analyses 

generate values used to calculate the effects that proposed energy conservation standards 

would have on the payback period for consumers. These analyses include, but are not 
57

limited to, the three-year payback period contemplated under the rebuttable-presumption 

test. In addition, DOE routinely conducts an economic analysis that considers the full 

range of impacts to consumers, manufacturers, the Nation, and the environment, as 

required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis 

for DOE’s evaluation of the economic justification for a potential standard level (thereby 

supporting or rebutting the results of any preliminary determination of economic 

justification). The rebuttable presumption payback calculation is discussed in section 

IV.F.12 of this proposed rule.

IV. Methodology and Discussion of Related Comments

DOE used four spreadsheet tools to estimate the impact of today’s proposed 

standards. The first spreadsheet calculates LCCs and PBPs of potential new energy 

conservation standards. The second provides shipments forecasts and the third calculates 

national energy savings and net present value impacts of potential new energy 

conservation standards. The fourth tool helps assess manufacturer impacts, largely 

through use of the Government Regulatory Impact Model (GRIM).

Additionally, DOE estimated the impacts of energy conservation standards for 

electric motors on utilities and the environment. DOE used a version of EIA’s National 

Energy Modeling System (NEMS) for the utility and environmental analyses. The NEMS 

model simulates the energy sector of the U.S. economy. EIA uses NEMS to prepare its 

Annual Energy Outlook (AEO), a widely known energy forecast for the United States. 
58

The version of NEMS used for appliance standards analysis is called NEMS-BT20 and is 

based on the AEO version with minor modifications.21 The NEMS-BT model offers a 

sophisticated picture of the effect of standards because it accounts for the interactions 

between the various energy supply and demand sectors and the economy as a whole.

A.

For the market and technology assessment, DOE develops information that 

provides an overall picture of the market for the equipment concerned, including the 

purpose of the equipment, the industry structure, and market characteristics. This activity 

includes both quantitative and qualitative assessments, based primarily on publicly 

available information. The subjects addressed in the market and technology assessment 

for this rulemaking include scope of coverage, equipment classes, types of equipment 

sold and offered for sale, and technology options that could improve the energy 

efficiency of the equipment under examination. Chapter 3 of the TSD contains additional 

discussion of the market and technology assessment.

Market and Technology Assessment

 20BT stands for DOE’s Building Technologies Program.

21 The EIA allows the use of the name “NEMS” to describe only an AEO version of the model without any 

modification to code or data. Because the present analysis entails some minor code modifications and runs 

the model under various policy scenarios that deviate from AEO assumptions, the name “NEMS-BT” refers 

to the model as used here. For more information on NEMS, refer to The National Energy Modeling 

System: An Overview, DOE/EIA–0581 (98) (Feb.1998), available at: 

http://tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf.
59

1. Current Scope of Electric Motors Energy Conservation Standards

EISA 2007 amended EPCA to prescribe energy conservation standards for four 

categories of electric motors: general purpose electric motors (subtype I) (hereinafter, 

“subtype I”), general purpose electric motors (subtype II) (hereinafter, “subtype II”), fire 

pump electric motors, and NEMA Design B, general purpose electric motors that also 

meet the subtype I or subtype II definitions and are rated above 200 horsepower through

500 horsepower. DOE’s most recent test procedure final rule added clarity to the 

definitions for each of these motor categories, which are now codified at 10 CFR 431.12. 

77 FR 26608.

Although DOE is not proposing to modify these definitions, commenters sought 

additional clarifications. During the preliminary analysis public meeting, NEMA 

expressed confusion regarding whether IEC frame motors would fall under the subtype I 

or subtype II designation, as DOE defined them to be related to both definitions. NEMA 

added that because subtype I and subtype II electric motors are subject to different 

efficiency standards, manufacturers producing IEC frame motors are confused as to 

whether IEC frame motors are subject to NEMA MG 1 Table 12-11 or Table 12-12 

efficiency standards.22 (NEMA, Public Meeting Transcript, No. 60 at pp. 36, 37)

DOE understands that an IEC frame motor could be treated as either a subtype I 

or subtype II motor depending on its other characteristics. Having an IEC frame alone 

does not dictate whether a motor is a general purpose subtype I or subtype II motor; 

 22 The efficiency levels found in Table 12-12 are the more stringent of the two sets of efficiency tables.
60

rather, other physical characteristics, such as equivalency to a NEMA Design A, B, or C 

electric motor, and whether it has mounting feet could determine the subtype designation 

and associated energy efficiency standard level. All of these elements flow directly from 

the statutory changes enacted by EISA 2007. (See EISA 2007, sec. 313(a)(3), codified at 

42 U.S.C. 6311(13)) Currently, electric motors are required to meet energy conservation 

standards as follows:

Table IV.1 Current Electric Motor Energy Conservation Standards23

Electric Motor Category Horsepower Range Energy Conservation 

Standard Level

General Purpose Electric 

Motors (Subtype I) 1 to 200 (inclusive) MG 1-2011 Table 12-12

General Purpose Electric 

Motors (Subtype II) 1 to 200 (inclusive) MG 1-2011 Table 12-11

NEMA Design B and

IEC Design N Motors 201 to 500 (inclusive) MG 1-2011 Table 12-11

Fire Pump Electric Motors 1 to 500 (inclusive) MG 1-2011 Table 12-11

Additionally, NEMA requested clarification on the terminology DOE intends to 

use for NEMA Design B motors, namely whether the term is “NEMA Design B motor” 

or “NEMA Design B electric motor” and what, if any, differences there are between the 

two terms. (NEMA, No. 54 at p. 14) DOE understands that the terms “motor” and 

“electric motor” may refer to a variety of machines outside of its regulatory context. 

However, because there are no NEMA Design B motors that are not electrically-driven,

in DOE’s view, the potential for ambiguity is minimal. DOE clarifies that it is using the 

term “NEMA Design B motor,” as is currently codified in 10 CFR 431.12. Additionally, 

 23 For the purposes of determining compliance, DOE assesses a motors horsepower rating according to the 

provisions of 10 CFR 431.25(e).

Comment [A22]: Footnote recommended by 

OIRA.
61

DOE does not consider there to be any meaningful difference between the two terms and 

notes that all motors currently regulated under 10 CFR part 431, subpart B, are electric 

motors.

DOE requests comment on whether the proposed standards help resolve the 

potential issue on which it had previously issued clarification of whether a [IEC] motor 

may be considered to be subject to two standards.

2. Expanded Scope of Electric Motor Energy Conservation Standards

As referenced above, on August 15, 2012, the Motor Coalition petitioned DOE to 

adopt the Coalition’s consensus agreement, which, in part, formed the basis for today’s 

proposal24

 24 The Petition is available at: 

. The Motor Coalition petitioned DOE to simplify coverage to address a broad 

array of electric motors with a few clearly identified exceptions. The Motor Coalition 

advocated this approach to simplify manufacturer compliance and to help facilitate 

DOE’s enforcement efforts. The Petition highlighted potential energy savings that would 

result from expanding the scope of covered electric motors. (Motor Coalition, No 35 at 

pp. 1-30) Subsequent to DOE’s preliminary analysis public meeting, several other 

interested parties submitted comments supporting the Petition. Those supporters 

included: BBF and Associates, the Air Movement and Control Association International, 

Inc., U.S. Senators Lisa Murkowski and Jeff Bingaman, the Hydraulic Institute, the 

Arkansas Economic Development and Commission- Energy Office, and the Power 

Transmission Distributors Association.

http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD0027-0035

Comment [A23]: Change recommended by 

OIRA.
62

The California Investor Owned Utilities (CA IOUs), represented by the Pacific 

Gas and Electric Company (PG&E), Southern California Gas Company (SCGC), San 

Diego Gas and Electric (SDG&E), and Southern California Edison (SCE) commented 

that they supported the Petition’s intent to expand the scope of coverage to the vast 

majority of single speed, polyphase, and integral horsepower induction motors between 1 

and 500 horsepower, as well as increasing energy conservation standards for some 

covered products. (CA IOUs, No. 57 at p. 2) 

The Air Movement and Control Association International, Inc. (AMCA 

International) endorsed the Petition. AMCA International encouraged DOE to adopt the 

Petition to save energy as soon as possible. (AMCA International, No. 59 at p. 1)

The CDA and BBF supported DOE’s preliminary analysis and the Petition, 

indicating that the Petition sets minimum efficiency levels that represent a challenge to 

the industry and can have a great impact on U.S. energy use. (BBF & Associates, No. 51 

at pp. 1, 2; CDA, No. 55 at p. 1) BBF also urged DOE to investigate energy conservation 

standards for motors over 500 horsepower because preliminary indications suggest that as 

much as 27 percent of total motor power consumed in the U.S. is from motors over 500 

horsepower, and higher efficiencies can provide substantial savings. (BBF, No. 51 at p. 4)

EASA supported the Motor Coalition’s Petition, asserting that it is in the best 

interests of saving energy, U.S. jobs, and the economy overall to adopt that Petition’s 
63

approach. EASA strongly encouraged the DOE to adopt the recommendations of the 

Motor Coalition, citing large and economically justified energy savings. (EASA, No. 47 

at p. 1)

ACEEE commented on behalf of the Motor Coalition, stating that expanding the 

scope of energy conservation standards and only excluding a small group of motor types 

will enhance enforcement efforts by the government, by simplifying the standards to only 

include explicit exclusions. (ACEEE, Public Meeting Transcript, No. 60 at p. 19) 

After reviewing the Petition, DOE is proposing to require electric motor types 

beyond those currently covered (and discussed in section IV.A.1) to meet energy 

conservation standards. DOE’s proposed expansion is similar to the approach 

recommended by the Motor Coalition in its Petition (Motor Coalition, No. 35 at pp. 1-3). 

DOE’s proposal would establish energy conservation standards for electric motors that 

exhibit all of the characteristics listed in Table IV.2, with a limited number of exceptions.

Table IV.2 Characteristics of Motors Regulated Under Expanded Scope of 

Coverage

Motor Characteristic

Is a single-speed, induction motor,

Is rated for continuous duty (MG 1) operation or for duty type S1 (IEC),

Contains a squirrel-cage (MG 1) or cage (IEC) rotor,

Operates on polyphase alternating current 60-hertz sinusoidal power,

Is rated for 600 volts or less,

Is built with a 2-, 4-, 6-, or 8-pole configuration,

Is a NEMA Design A, B, or C motor (or IEC Design N or H)

Is built in a three-digit NEMA frame size or an enclosed 56-frame (or any IEC 

equivalent), and

Is rated from 1 to 500 horsepower (inclusive)
64

In response to its preliminary analysis, DOE received several comments about the 

characteristics that DOE should use to define the broad scope of electric motors 

potentially subject to energy conservation standards. First, NEMA suggested that DOE 

define motor types exhibiting the nine characteristics listed in Table IV.2. (NEMA, No. 

54 at p. 32) NEMA also requested that DOE clarify the range of horsepower ratings 

included and the scope of 56- and IEC-frame motors covered. The Energy Advocates 

(NPCC, NEEA, ACEEE, ASAP, Earthjustice, ASE) also suggested that DOE include 

IEC-equivalents and NEMA 56-frame sizes in the scope of coverage. (NPCC, No. 56 at 

p. 2)

Additionally, DOE is proposing to clarify the design, construction, and 

performance characteristics of covered electric motors. Specifically, DOE is proposing to 

clarify that only motors rated from 1 to 500 horsepower (inclusive), or their IEC 

equivalents, would be covered by the standards being proposed in today’s rulemaking. 

Finally, with regard to IEC-frame motors, DOE would not cover IEC motors on the 

singular basis of frame size, but would consider covering such motors when they meet 

the criteria of Table IV.2. In other words, an IEC-frame motor would need to satisfy these 

nine criteria for the proposed standards to apply.

In its submitted Petition, the Coalition requested that DOE cover all single-speed, 

polyphase, 56-frame induction motors rated at one horsepower or greater that do not meet 

the regulatory definition for “small electric motor” in 10 CFR part 431, subpart X. This 

definition applies to both single-phase and polyphase open-frame general purpose AC 
65

induction motors built in a two-digit frame size. The proposal put forth by the Coalition 

would expand energy conservation standards to polyphase, enclosed 56-frame motors 

rated at one or more horsepower along with polyphase, special and definite purpose open 

56-frame motors of horsepower greater than or equal to one that are not covered by 

DOE’s small electric motor regulations. 

Regarding 56-frame motors at 1-hp or greater, DOE is proposing standards for

polyphase, enclosed 56-frame motors that are rated at 1-hp or greater. DOE is also 

tentatively proposing TSL 2 for polyphase, open 56-frame special and definite purpose 

motors that are rated at 1-hp or greater as advocated by the Motor Coalition. With respect 

to these motors (i.e. 56-frame, open, special and definite purpose), DOE seeks additional 

data related to these motors, including, but not limited to the following categories: motor 

efficiency distributions; shipment breakdowns between horsepower ratings, open and 

enclosed motors, and between general and special and definite purpose electric motors; 

and information regarding the typical applications that use these motors. If this proposal 

is adopted in the final rule, DOE will account for a substantial majority of 56-frame 

motors that are not already regulated by efficiency standards and ensure coverage for all 

general purpose motors along with a substantial number of special and definite purpose 

motors. 

Based on currently available data, DOE estimates that approximately 270,000 

polyphase, open 56-frame special and definite purpose motors (1-hp or greater) were 

shipped in 2011 and at least 70% of these motors have efficiency levels below NEMA 
66

Premium.25 In addition, based on this data, DOE believes that establishing TSL 2 for 

this subset of 56-frame motors would result in national energy savings of 0.58 quads 

(full-fuel-cycle) and net present value savings of $1.11 billion (2012$), with a 7 percent 

discount rate.26 DOE has not merged its data and analyses related to this subset of 56-

frame motors with the other analyses in today’s NOPR. As described above, DOE seeks

additional information that can be incorporated into its final analysis.

DOE notes that enclosed 56-frame motors with horsepower ratings below 1 

horsepower would not, however, be covered as part of today’s proposal. DOE is not 

proposing to cover 56-frame size fractional motors because EPCA, as amended, 

establishes energy conservation standards for electric motors at 1-hp or greater and DOE 

requires the use of different test procedures for motors above and below 1-hp. In 

particular, DOE’s regulations prescribe, consistent with industry practice, the use of the 

Institute of Electrical and Electronics Engineers (IEEE) Standard 112 (Test Method A) to 

test motors rated below 1-hp, and IEEE Standard 112 (Test Method B) to test motor rated 

at or above 1-hp. To ensure consistent testing results, DOE requires application of the 

same test procedure to all electric motors. Therefore, DOE is not proposing to regulate

 25 Shipments for these 56-open frame motors were estimated from data provided by the Motor Coalition. 

DOE assumed 56-frame open motors are distributed across 2-, 4-, and 6- pole configurations and 1 to 5 

horsepower ratings. With this assumption, DOE used the shipments distributions from ECG 1 motors 

across these motor configurations and ratings to establish shipments data for open 56-frame motors by 

motor configuration and horsepower rating. Efficiency distributions were based on a limited survey of 

electric motor models from six major manufacturer catalogs.

26 DOE used the same NIA model and inputs described in section IV.H to estimate these values of NES 

and NPV, but adjusted the shipments and efficiency distributions to match the data specific to these 56-

frame open motors. 
67

enclosed 56-frame size motors rated under 1-hp.

27 This tentative decision, however, does 

not foreclose the possibility that DOE may regulate the efficiency of these motors and 

may change depending on the nature of the feedback provided by commenters with 

respect to this issue. DOE requests comment on its tentative decision to not address 

fractional horsepower enclosed 56-frame motors as part of today’s proposal, along with 

any relevant information and data.

In view of Table IV.2, Table IV.3 lists the various electric motor types that would 

be covered by DOE’s proposed approach. Further details and definitions for the motor 

types can be found in DOE’s electric motors test procedure NOPR, which was published 

on June 26, 2013 (78 FR 38456). 

Table IV.3 Currently Unregulated Motor Types DOE Proposes to Cover

Electric Motor Type

NEMA Design A from 201 to 500 horsepower Electric motors with non-standard endshields or 

flanges

Electric motors with moisture resistant windings Electric motors with non-standard bases

Electric motors with sealed windings Electric motors with special shafts

Partial electric motors Vertical hollow-shaft electric motors

Totally enclosed non-ventilated (TENV) electric 

motors Electric motors with sleeve bearings

Immersible electric motors Electric motors with thrust bearings

Integral brake electric motors Non-integral brake electric motors

In view of DOE’s proposed approach described in Table IV.3, DOE is proposing 

to include certain motor types that some interested parties have suggested that DOE 

continue to exclude from any energy efficiency requirements. For example, the Motor 

Coalition would exclude integral brake motors from coverage, as DOE once did through 

 27 DOE notes that general purpose, open 56-frame motors are already addressed by the standards for small 

electric motors. 

Comment [A24]: Change recommended by 

OIRA.
68

policy guidance, see 62 FR 59978 (November 5, 1997), but which was subsequently 

removed. See 77 FR 26638 (May 4, 2012). (Motor Coalition, No. 35 at p. 3) SEWEurodrive also commented that there are two basic types of integral gearmotor: (1) one 

that meets the definition in DOE’s preliminary analysis, and (2) another having a special 

shaft or mounting configuration. SEW-Eurodrive contended that the second type of 

integral gearmotor would require replacement of the entire rotor shaft and rotor cage to 

be tested. (SEWE, No. 53, p. 3) 

In view of the foregoing, DOE continues to believe that consistent and repeatable 

test procedures can be prescribed for integral brake motors, integral gearmotors, integral 

partial motors, and partial 3⁄4 motors. See 78 FR 38456 (June 26, 2013). In particular, 

DOE believes that an integral brake motor that meets the nine criteria in Table IV.2, 

could be readily tested and satisfy the proposed standards. In addition, DOE believes that 

the definition for “partial electric motor” and “component set” proposed in its June test 

procedure NOPR will clarify what types of items would meet these definitions, which 

should help manufacturers determine whether the equipment they manufacture fall under 

these terms. See 78 FR 38456 (June 26, 2013). Furthermore, DOE believes that the type 

of integral gearmotor addressed by SEW-Eurodrive (i.e., with a special shaft or mounting 

configuration) would likely satisfy DOE’s proposed definition of component set, because 

it would require more than the addition of end shields and a bearing to create an operable 

motor. (Component sets would not be required to meet standards under today’s proposal)
69

ACEEE supported the Motor Coalition’s Petition in its approach to expand the 

scope of covered motors to comply with the energy efficiency levels found in Table 12-

12 of NEMA Standards Publication MG 1-2011. According to ACEEE, such approach 

could be easily accomplished by manufacturers and, at the same time, allow them to 

refocus resources on designing and building the next generation of electric motor. 

(ACEEE, Public Meeting Transcript, No. 60 at pp. 18, 19) UL agreed with the ACEEE 

approach and suggested that DOE clarify the scope of coverage with a statement whereby 

all electric motors are subject to standards, except for those specifically mentioned as 

excluded. (UL, Public Meeting Transcript, No. 60 at pp. 60, 61) Finally, the California 

Independently Owned Utilities (CA IOUs) submitted similar comments, suggesting that 

DOE expand the scope of coverage and explicitly define those motor types excluded 

from standards. The CA IOUs stressed that this approach would provide clarity both to 

compliance and enforcement efforts by government agencies and manufacturers. (CA 

IOUs, No. 57 at p. 1)

After considering these comments, and further analyzing available relevant 

information, DOE believes that a simplified approach to determining coverage would 

help ensure consistency to the extent possible when applying the proposed standards. 

Therefore, in today’s notice, DOE is proposing that an electric motor that meets the nine 

characteristics in Table IV-3 would be covered and required to meet the applicable 

energy conservation standards, either in NEMA MG 1 Table 12−11 or 12−12. 

Additionally, DOE is proposing not to set standards at this time for the following motors: 

component sets, liquid-cooled motors, submersible motors, and definite-purpose inverter-
70

fed motors. DOE is not proposing to set standards for these motors in light of the 

substantial difficulties and complexities that would be involved in testing these motors at 

this time. In addition, DOE is proposing not to set standards at this time for air-over 

motors, but intends to address these types of motors in a separate rulemaking. 

Definitions for the motor types and additional details about these issues are addressed at 

78 FR 38456 (June 26, 2013).

3. Advanced Electric Motors

In its preliminary analysis, DOE addressed various “advanced electric motor,” 

which included those listed in Table IV.4. While DOE recognized that such motors could 

offer improved efficiency, regulating them would represent a significant shift for DOE, 

which has primarily focused on the efficiency of polyphase, single-speed induction 

motors. Seeking more information, DOE solicited public comments about these types of 

motors and how they would be tested for energy efficiency.

Table IV.4 Advanced Electric Motors

Motor Description

Inverter drives

Permanent magnet motors

Electrically commutated motors

Switched-reluctance motors

DOE received comments about advanced motors from various interested parties. 

NEMA asserted that, in certain applications, inverter drives, permanent-magnet motors, 

electronically commutated motors, and switched-reluctance motors, could offer improved 

efficiency. However, NEMA also noted that these motors may include technologies 
71

where standard test procedures are still being developed, making it unable to comment. 

(NEMA, No. 54 at pp. 18-19) DOE understands that a test procedure would be necessary 

before it contemplates setting energy conservation standards for these types of motors. 

Additionally, during the preliminary analysis public meeting, ACEEE commented that 

advanced motor designs present the largest opportunity for future energy savings within 

the motor marketplace and NEMA member manufacturers are already exploring the 

standards-setting process for advanced motor designs in the NEMA MG 1 standards 

publication. (ACEEE, Public Meeting Transcript, No. 60 at p. 19) 

Other interested parties submitted comments regarding the efficiency of 

“advanced motor systems” and, in general, motor-driven systems. Danfoss commented 

that system efficiency improvements would provide significant energy savings, and cited 

variable frequency drives (VFDs) as an example of a way to improve system efficiency. 

VFDs, or inverter drives, are external components used in motor-driven systems to 

control motor speed and torque by varying motor input frequency and voltage Danfoss 

elaborated that VFDs could save 20 to 30 percent of the energy that typical, non-VFDmotors consume and urged that DOE consider this approach, instead of seeking minimal 

energy conservation improvements in across-the-line start polyphase electric motors.28

 28 For this rulemaking, “across-the-line start” indicates the electric motor is run directly on polyphase, 

alternating current (AC) sinusoidal power, without any devices or controllers manipulating the power 

signal fed to the motor. 

(Danfoss, Public Meeting Transcript, No. 60 at pp. 21-23, 174, 175) UL submitted 

similar comments during the preliminary analysis public meeting, indicating that DOE 

and the industry should focus on improving system-level efficiency. UL added that if a 
72

motor is not properly matched to its load then the system efficiency could be 20 or 30 

percent less efficient than possible. (UL, Public Meeting Transcript, No. 60 at pp. 69, 70) 

BBF and the CDA commented that the overall evaluation of system efficiency is very 

important, and the evaluation of VFDs and the motor system represents many major 

opportunities for improved efficiency. (BBF, No. 51, p. 4; CDA, No. 55, p. 2)

DOE understands the concerns from interested parties regarding advanced motor 

efficiency and its connection with the possible regulation of advanced electric motors. At 

this time, however, DOE has chosen not to regulate advanced motors and knows of no 

established definitions or test procedures that could be applied to them. Because DOE 

agrees that significant energy savings may be possible for some advanced motors, DOE 

plans to keep abreast of changes to these technologies and their use within industry, and 

may consider regulating them in the future. DOE invites comment on the topic of 

advanced motors, including any related definitions or test procedures that it should 

consider applying as part of today’s rulemaking.

4. Equipment Class Groups and Equipment Classes

When DOE prescribes or amends an energy conservation standard for a type (or 

class) of covered equipment, it considers (1) the type of energy used; (2) the capacity of 

the equipment; or (3) any other performance-related feature that justifies different 

standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) Due to 

the large number of characteristics involved in electric motor design, DOE has used two 

constructs to help develop its energy conservation standards proposals for electric 
73

motors: “equipment class groups” and “equipment classes.” An equipment class 

represents a unique combination of motor characteristics for which DOE is proposing a 

specific energy conservation standard. There are 580 potential equipment classes that

consist of all permutations of electric motor design types (i.e., NEMA Design A & B, 

NEMA Design C, fire pump electric motor, or brake electric motor), standard horsepower 

ratings (i.e., standard ratings from 1 to 500 horsepower), pole configurations (i.e., 2-, 4-, 

6-, or 8-pole), and enclosure types (i.e., open or enclosed). An equipment class group is a 

collection of equipment classes that share a common design type. For example, given a 

combination of motor design type, horsepower rating, pole-configuration, and enclosure 

type, the motor’s design type dictates its equipment class group, while the combination of 

the remaining characteristics dictates its specific equipment class.29

In the preliminary analysis, DOE divided electric motors into three groups based 

on two main characteristics: NEMA (or IEC) design letter and whether the motor met the 

definition of a fire pump electric motor. For the NOPR, DOE is keeping these three 

groups and adding a fourth equipment class group for electric motors with brakes 

(integral and non-integral). DOE’s four resulting equipment class groups are: NEMA 

Design A and B motors (ECG 1), NEMA Design C motors (ECG 2), fire pump electric 

motors (ECG 3), and electric motors with brakes (ECG 4). Within each of these groups, 

DOE would use combinations of other pertinent motor characteristics to enumerate 

individual equipment classes. To illustrate the differences between the two terms, 

 29 At its core, the equipment class concept, which is being applied only as a structural tool for purposes of 

this rulemaking, is equivalent to a “basic model.” See 10 CFR 431.12. The fundamental difference 

between these concepts is that a “basic model” pertains to an individual manufacturer’s equipment class. 

Each equipment class for a given manufacturer would comprise a basic model for that manufacturer.
74

consider the following example. A NEMA Design B, 50 horsepower, two-pole enclosed 

electric motor and a NEMA Design B, 100 horsepower, six-pole open electric motor 

would be in the same equipment class group (ECG 1), but each would represent a unique 

equipment class that will ultimately have its own efficiency standard. Table IV.5 outlines 

the relationships between equipment class groups and the characteristics used to define 

equipment classes.

Table IV.5 Electric Motor Equipment Class Groups for the NOPR Analysis

Equipment 

Class Group Electric Motor Design Horsepower Poles Enclosure

1 NEMA Design A & B* 1-500 2, 4, 6, 8 Open

Enclosed

2 NEMA Design C* 1-200 4, 6, 8 Open

Enclosed

3 Fire Pump* 1-500 2, 4, 6, 8 Open

Enclosed

4 Brake Motors* 1-30 4, 6, 8 Open

Enclosed

*Including IEC equivalents.

NEMA submitted multiple comments about DOE’s equipment class groups and 

equipment classes. First, NEMA argued that such expansive groups could make it 

difficult to properly determine efficiency standards, particularly given the large 

expansion of scope being contemplated by DOE. (NEMA, No. 54 at p. 40) NEMA 

recommended that “for ‘electric motors’ the term ‘equipment class’ be identified as those 

electric motors which are of the polyphase squirrel-cage induction type.” It added that: 

“An ‘equipment class group’ can be defined as a particular ‘group’ of such 

‘electric motor’ having a particular set of common characteristics, such as NEMA 
75

Design A and B electric motors or NEMA Design C electric motors, or fire pump 

electric motors. Each ‘equipment class group’ can be organized according to 

‘rating’ where ‘rating’ is as it is presently defined in §431.12 [of 10 CFR Part 

431]. When appropriate, an AEDM [alternative efficiency determination method] 

can then be substantiated for the complete ‘equipment class’ of polyphase 

squirrel-cage induction electric motors as is permitted and done today.

Additionally, NEMA suggested that DOE separate U-frame motors from T-frame 

motors during the analysis because any proposed increase in efficiency standards for the 

low volume production of U-frame motors would likely result in a reduction in the 

availability of U-frame motors, which they assert, is not permitted under 42 U.S.C. 

6295(o)(4). (NEMA, No. 54 at pp. 20, 26) Citing the high cost of redesigning these 

motors relative to the potential savings, the Motor Coalition predicted manufacturers 

would exit the U-frame market leaving only one or two manufacturers. (Motor Coalition, 

No. 35 at p. 13) NEMA also stated that the demand for this type of motor has been 

declining since the 1960’s and U-frame motors have not been included in the NEMA MG

1 standard since U-frame motors were replaced by T-frame motors as the NEMA 

standard in the 1960s. (NEMA, No. 54 at pp. 19, 20) NEMA added that the challenge 

created by substituting a U-frame motor with a T-frame motor must be accounted for in 

the manufacturer and national impact analyses.
76

EISA 2007 prescribed energy conservation standards for electric motors built with 

a U-frame, whereas previously only electric motors built with a T-frame were covered.30

(Compare 42 U.S.C. 6311(13)(A)(1992) with 42 U.S.C. 6311(13)(B)(2011)) In general, 

for the same combination of horsepower rating and pole configuration, an electric motor 

built in a U-frame is built with a larger "D" dimension than an electric motor built in a Tframe. The “D” dimension is a measurement of the distance from the centerline of the 

shaft to the bottom of the mounting feet. Consequently, U-frame motors should be able to 

reach efficiencies as high, or higher, than T-frame motors with similar ratings (i.e., 

horsepower, pole-configuration, and enclosure) because the larger frame size allows for 

more active materials, such as copper wiring and electrical steel, which help reduce I2

R 

(i.e., losses arising from the resistivity of the current-carrying material) and core losses 

(losses that result from magnetic field stability changes). Furthermore, U-frame motors 

do not have any unique utility relative to comparable T-frame motors. In general, a Tframe design could replace an equivalent U-frame design with minor modification of the 

mounting configuration for the driven equipment. By comparison, a U-frame design that 

is equivalent to a T-frame design could require substantial modification to the mounting 

configuration for the same piece of driven equipment because of its larger size. DOE’s 

research indicated that manufacturers sell conversion brackets for installing T-frame 

motors into applications where a U-frame motor had previously been used.31 

 30 The terms “U-frame” and “T-frame” refer to lines of frame size dimensions, with a T-frame motor 

having a smaller frame size for the same horsepower rating as a comparable U-frame motor. In general, “T” 

frame became the preferred motor design around 1964 because it provided more horsepower output in a 

smaller package.

31 See, for example, http://www.overlyhautz.com/adaptomounts1.html
77

Regarding NEMA’s contention that U-frame motors will become unavailable if 

DOE does not separate these motors from T-frame motors when developing efficiency 

standards, DOE understands NEMA’s concerns regarding the diminishing market size of 

U-frame motors and the potential for them to disappear. However, DOE believes that 

such an occurrence would not be the result of an efficiency standard that is 

technologically infeasible for U-frame motors, but because U-frame motors offer no 

unique utility relative to T-frame motors. Furthermore, DOE believes that the proposed 

standards are unlikely to result in the unavailability of U-frame motors. Based on catalog 

data from several large electric motor manufacturers, DOE observed that 70 percent of 

currently available U-frame models meet the proposed standard (TSL 2). With much of 

the U-frame market already at the proposed standard, DOE sees no technical reason that 

U-frame manufacturers would not be able to comply with TSL 2. 

DOE also notes that under 42 U.S.C. 6295(o)(4), EPCA proscribes the 

promulgation of standards that would result in the “unavailability in the United States in 

any covered product type (or class) of performance characteristics (including reliability), 

features, sizes, capacities, and volumes that are substantially the same as those generally 

available in the United States at the time of the Secretary’s finding.” The provision does 

not require the continued protection of particular classes or types of product -- or in this 

case, electric motors –if the same utility continues to be available for the consumers who

are purchasing the given product. Consequently, based on available information, DOE 

has not separated U-frame motors into a unique equipment class group. DOE welcomes 

any additional data relevant to this finding, including data that would suggest the need for 
78

an alternate approach. DOE also requests additional information from manufacturers on 

whether covering U-frame motors would cause them to be unavailable in the U.S. and 

whether U-frame motors have any particular performance characteristics, features, sizes, 

capacities, or volumes.

Finally, NEMA questioned DOE's use of the term "equipment class" to describe a 

combination of horsepower rating, pole configuration, and enclosure type instead of 

using the term "rating," which is defined in 10 CFR 431.12, as part of the definition of a 

“basic model.” (NEMA, No. 54 at p. 25) NEMA believes that this could cause confusion 

because of proposals regarding certification, alternative efficiency determination methods 

(AEDMs), and enforcement in a separate rulemaking, which are all centered around 

"equipment classes." (NEMA, No. 54 at p. 25) NEMA stated that DOE’s definition in 

this rulemaking has the adverse impact of requiring substantiation of an AEDM 

separately for every rating for which it is to be used and would constitute a significant 

increase in compliance burden. (NEMA, No. 54 at p. 25) DOE understands NEMA’s 

concerns regarding the potential of undue compliance burden. DOE notes that it has not 

proposed a regulatory definition for the term “equipment class.” It is merely a construct 

for use in the various analyses in today’s rulemaking. The term “equipment class” as 

described in this rulemaking should not be misconstrued as having any regulatory 

meaning as it relates to the definition of “basic model.” In today’s rulemaking, DOE is 

continuing to use the terminology as described in the preliminary analysis and above. 

DOE intends to address NEMA’s concerns regarding the potential compliance burden in 

Comment [A25]: Change recommended by 

OIRA.
79

a separate rulemaking that will address compliance, certification and enforcement-related 

issues.

a. Electric Motor Design Letter

The first criterion that DOE considered when disaggregating equipment class 

groups was based on the NEMA (and IEC) design letter. The NEMA Standards 

Publication MG 1−2011, "Motors and Generators," defines a series of standard electric 

motor designs that are differentiated by variations in performance requirements. These 

designs are designated by letter -- Designs A, B, and C. (See NEMA MG 1−2011, 

paragraph 1.19.1). These designs are categorized by performance requirements for fullvoltage starting and developing locked-rotor torque, breakdown torque, and locked-rotor 

current, all of which affect an electric motor’s utility and efficiency. DOE is proposing to 

regulate the efficiency of each of these design types. 

The primary difference between a NEMA Design A and NEMA Design B electric 

motor is that they have different locked-rotor current requirements. NEMA Design B 

motors must not exceed the applicable locked-rotor current level specified in NEMA MG

1−2011, paragraph 12.35.1. NEMA Design A motors, on the other hand, do not have a 

maximum locked-rotor current limit. In most applications, NEMA Design B motors are 

generally preferred because locked-rotor current is constrained to established industry 

standards, making it easier to select suitable motor-starting devices. However, certain 

applications have special load torque or inertia requirements, which result in a design 

with high locked-rotor current (NEMA Design A). When selecting starting devices for 

Comment [A26]: Change recommended by 

OIRA.
80

NEMA Design A motors, extra care must be taken in properly sizing electrical protective 

devices to avoid nuisance tripping during motor startup. The distinction between NEMA 

Design A and NEMA Design B motors is important to users who are sensitive to high 

locked-rotor current; however, both NEMA Design A and Design B motors have 

identical performance requirements in all other metrics, which indicates that they offer 

similar levels and types of utility. Given these similarities, DOE is proposing to group 

these motors together into a single equipment class grouping for the purposes of this 

rulemaking.

In contrast, DOE believes that the different torque requirements for NEMA 

Design C electric motors represent a change in utility that can affect efficiency 

performance. NEMA Design C motors are characterized by high starting torques. 

Applications that are hard to start, such as heavily loaded conveyors and rock crushers, 

require this higher starting torque. The difference in torque requirements will restrict 

which applications can use which NEMA Design types. As a result, NEMA Design C 

motors cannot always be replaced with NEMA Design A or B motors, or vice versa. 

Therefore, as in the preliminary analysis, DOE has analyzed NEMA Design C motors in 

an equipment class group separate from NEMA Design A and B motors.

In chapter two, “Analytical Framework,” of the preliminary technical support 

document, DOE noted numerous instances where manufacturers were marketing electric 

motors rated greater than 200 horsepower as NEMA Design C motors. DOE understands 

that NEMA MG 1−2011 specifies Design C performance requirements for motors rated 
81

1−200 hp in four-, six-, and eight-pole configurations -- a motor rated above 200 hp or 

using a two-pole configuration would not meet the Design C specifications. DOE 

requested public comment about whether motors that are name-plated as NEMA Design 

C, but that fall outside the ratings for which NEMA Design C is defined, can be 

considered to be NEMA Design C motors. In its comments, NEMA asserted it did not 

support marking a motor as NEMA Design C where no standard exists for two-pole 

designs, or four-, six- or eight-pole motors over 200 horsepower. NEMA recommended 

that any such improperly marked motor be examined for determination of its proper 

Design letter relative to the applicable standards in NEMA MG 1. Furthermore, NEMA 

recommended that DOE not include efficiency standards for motors of any design type 

for which NEMA or IEC standards do not exist. (NEMA, No. 54 at p. 19)

DOE understands that without established performance standards that form the 

basis for a two-pole NEMA Design C motor or a NEMA Design C motor with a 

horsepower rating above 200, motors labeled as such would not meet the proposed 

regulatory definition for “NEMA Design C motor.” 78 FR 38456 (June 26, 2013). DOE 

considers motors at these ratings to be improperly labeled if they are name-plated as 

NEMA Design C. Mislabeled NEMA Design C motors, however, are still subject to 

energy conservation standards if they meet the definitions and performance standards for 

a regulated motor – e.g. NEMA Design A or B. And since these motors either need to 

meet the same efficiency levels or would be required by customers to meet specific 

performance criteria expected of a given design letter (i.e. Design A, B, or C), DOE does 

not foresee at this time any incentive that would encourage a manufacturer to identify a 
82

Design A or B motor as a Design C motor for standards compliance purposes. DOE 

understands, however, that NEMA Design C motors as a whole constitute an extremely 

small percentage of motor shipments— less than two percent of shipments— covered by 

this rulemaking, which would appear to create an unlikely risk that mislabeling motors as 

NEMA Design C will be used as an avenue to circumvent standards. Nevertheless, DOE 

will monitor the potential presence of such motors and may reconsider standards for them 

provided such practice becomes prevalent.

b. Fire Pump Electric Motors

In addition to considering the NEMA design type when establishing equipment 

class groups, DOE considered whether an electric motor is a fire pump electric motor. 

EISA 2007 prescribed energy conservation standards for fire pump electric motors (42 

U.S.C. § 6313(b)(2)(B)) and, subsequently, DOE adopted a definition for the term “fire 

pump electric motor,” which incorporated portions of National Fire Protection 

Association Standard (NFPA) 20, “Standard for the Installation of Stationary Pumps for 

Fire Protection” (2010). Pursuant to NFPA 20, a fire pump electric motor must comply 

with NEMA Design B performance standards and must continue to run in spite of any 

risk of damage stemming from overheating or continuous operation. The additional 

requirements for a fire pump electric motor constitutes a change in utility that DOE 

believes could also affect its performance and efficiency. Therefore, DOE established a 

separate equipment class group for such motors in the preliminary analysis to account for 

the special utility offered by these motors. In its comments, NEMA agreed with DOE’s 

decision to separate fire pump electrical motors as a separate equipment class group. 
83

(NEMA, No. 54 at p. 20) Consequently, DOE is proposing to continue using a separate 

equipment class group for fire pump electric motors.

c. Brake Motors

In its NOPR analyses, DOE considered whether the term “electric motor” should 

include an integral brake electric motor or a non-integral brake electric motor 

(collectively, “brake motors”). In the test procedure NOPR, DOE proposed definitions 

both for integral and non-integral brake electric motors. 78 FR 38456 (June 26, 2013).

Both of these electric motor types are contained in one equipment class group as separate 

from the equipment class groups established for NEMA Design A and B motors, NEMA 

Design C motors, and fire pump electric motors. 

DOE understands that brake motors contain multiple features that can affect both 

utility and efficiency. In most applications, electric motors are not required to stop 

immediately. Instead, electric motors typically slow down and gradually stop after power 

is removed from the motor due to a buildup of friction and windage from the internal 

components of the motor. However, some applications require electric motors to stop 

quickly. Such motors may employ a brake component that, when engaged, abruptly slows 

or stops shaft rotation. The brake component attaches to one end of the motor and 

surrounds a section of the motor’s shaft. During normal operation of the motor, the brake 

is disengaged from the motor’s shaft— it neither touches nor interferes with the motor’s 

operation. However, under normal operating conditions, the brake is drawing power from 

the electric motor’s power source and may also be contributing to windage losses, 
84

because the brake is an additional rotating component on the motor’s shaft. When power 

is removed from the electric motor (and therefore the brake component), the brake 

component de-energizes and engages the motor shaft, quickly slowing or stopping 

rotation of the rotor and shaft components. Because of these utility related features that 

affect efficiency, DOE has preliminarily established a separate equipment class group for 

electric motors with an integral or non-integral brake.

d. Horsepower Rating

In its preliminary analysis, DOE considered three criteria when differentiating 

equipment classes. The first criterion was horsepower, a critical performance attribute of 

an electric motor that is directly related to the capacity of an electric motor to perform 

useful work and that generally scales with efficiency. For example, a 50-horsepower 

electric motor would generally be considered more efficient than a 10-horsepower 

electric motor. In view of the direct correlation between horsepower and efficiency, DOE 

preliminarily used horsepower rating as a criterion for distinguishing equipment classes 

in the framework document and continued with that approach for the preliminary 

analysis.

NEMA agreed with DOE’s view that horsepower is a performance attribute that 

must be considered when evaluating efficiency and urged that this long-established and 

workable concept not be abandoned. (NEMA, No. 54 at p. 40) In today’s proposal, DOE 

continues to use horsepower as an equipment class-setting criterion.
85

e. Pole Configuration 

The number of poles in an induction motor determines the synchronous speed 

(i.e., revolutions per minute) of that motor. There is an inverse relationship between the 

number of poles and a motor’s speed. As the number of poles increases from two to four 

to six to eight, the synchronous speed drops from 3,600 to 1,800 to 1,200 to 900 

revolutions per minute, respectively. In addition, manufacturer comments and 

independent analysis performed on behalf of DOE indicate that the number of poles has a 

direct impact on the electric motor’s performance and achievable efficiency because 

some pole configurations utilize the space inside of an electric motor enclosure more 

efficiently than other pole configurations. DOE used the number of poles as a means of 

differentiating equipment classes in the preliminary analysis.

In response to the preliminary analysis, NEMA agreed that the number of poles of 

an electric motor has impacts a motor’s achievable efficiency and supported DOE’s 

decision to take this characteristic into consideration. (NEMA, No. 54 at p. 41) In today’s 

proposal, DOE continues to use pole-configuration as an equipment class-setting 

criterion.

f. Enclosure Type

EISA 2007 prescribes separate energy conservation standards for open and 

enclosed electric motors. (42 U.S.C. 6313(b)(1)) Electric motors manufactured with 

open construction allow a free interchange of air between the electric motor’s interior and 

exterior. Electric motors with enclosed construction have no direct air interchange 
86

between the motor’s interior and exterior (but are not necessarily air-tight) and may be 

equipped with an internal fan for cooling (see NEMA MG 1−2011, paragraph 1.26). 

Whether an electric motor is open or enclosed affects its utility; open motors are 

generally not used in harsh operating environments, whereas totally enclosed electric 

motors often are. The enclosure type also affects an electric motor’s ability to dissipate 

heat, which directly affects efficiency. For these reasons, DOE used an electric motor’s 

enclosure type (open or enclosed) as an equipment class setting criterion in the 

preliminary analysis.

NEMA acknowledged in its comments that the enclosure type is an important 

characteristic that affects the achievable efficiency for any particular electric motor. 

NEMA added that it may become necessary to consider separate groups for various 

enclosures as DOE continues to expand the scope of electric motors subject to energy 

conservation standards, but did not make any specific suggestions regarding which 

enclosures could be considered separately. (NEMA, No. 54 at p. 42) 

At this time, DOE is continuing to use separate equipment class groups for open 

and enclosed electric motors but is declining to further break out separate equipment 

classes for different types of open or enclosed enclosures because DOE does not have 

data supporting such separation.
87

g. Other Motor Characteristics

In the preliminary analysis, DOE addressed various other motor characteristics, 

but did not use them to disaggregate equipment classes. In the preliminary analysis TSD, 

DOE provided its rationale for not disaggregating equipment classes for vertical electric 

motors, electric motors with thrust or sleeve bearings, close-coupled pump motors, or by 

rated voltage or mounting feet. DOE believes that none of these electric motor 

characteristics provide any special utility that would impact efficiency and justify 

separate equipment classes.

In response to the preliminary analysis, DOE received comments about how it 

should treat other motor characteristics. NEMA agreed with DOE’s decision that vertical 

motors, motors with thrust or sleeve bearings, and close-coupled pump motors do not 

merit separate equipment classes. (NEMA, No. 54 at p. 20) With no comments 

suggesting that DOE use any one of the alternative characteristics as a criterion for 

equipment class, DOE is using the approach it laid out in its preliminary analysis.

 

DOE also requests additional information from manufacturers on whether 

covering any of these technology options would reduce consumer utility or performance 

or cause any of the covered electric motors to be unavailable in the U.S. and whether Uframe motors have any particular performance characteristics, features, sizes, capacities, 

or volumes. In particular, DOE requests any information or data if these technology 

options would lead to increases in the size of the motors such that it would no longer 

work in a particular space constricted application, to decreases in power thereby 
88

affecting their usability of these motors, or to changes in any other characteristics that 

would affect the performance or utility of the motor. 

5. Technology Assessment

The technology assessment provides information about existing technology 

options and designs used to construct more energy-efficient electric motors. Electric 

motors have four main types of losses that can be reduced to improve efficiency: losses 

due to the resistance of conductive materials (stator and rotor I2

R losses), core losses, 

friction and windage losses, and stray load losses. These losses are interrelated such that 

measures taken to reduce one type of loss can result in an increase in another type of 

losses. In consultation with interested parties, DOE identified several technology options 

that could be used to reduce such losses and improve motor efficiency. These technology 

options are presented in Table IV.6. (See chapter 3 of the TSD for details).

Comment [A27]: Change recommended by 

OIRA.
89

Table IV.6 Technology Options to Increase Electric Motor Efficiency

Type of Loss to Reduce Technology Option

Stator I2R Losses

Increase cross-sectional area of copper in stator slots

Decrease the length of coil extensions

Rotor I2R Losses

Use a die-cast copper rotor cage

Increase cross-sectional area of rotor conductor bars

Increase cross-sectional area of end rings

Core Losses

Use electrical steel laminations with lower losses (watts/lb)

Use thinner steel laminations 

Increase stack length (i.e., add electrical steel laminations) 

Friction and Windage 

Losses

Optimize bearing and lubrication selection

Improve cooling system design

Stray-Load Losses

Reduce skew on rotor cage

Improve rotor bar insulation

In response to the preliminary analysis, DOE received multiple comments about 

these options. 

At the preliminary analysis public meeting, NEMA requested clarification on 

what was meant by the technology option listed as “improving rotor bar insulation.” 

(NEMA, Public Meeting Transcript, No. 60 at p. 158) NEMA commented on the option 

of increasing the cross sectional area of the stator windings and clarified that this is one 

way to decrease stator resistance, but not necessarily a separate technology option. 

(NEMA, No. 54 at p. 44) NEMA also clarified that reducing rotor resistance through a 

change in volume is synonymous with an increase in rotor slot size, unless DOE intends 

to include variations in the volume of the end rings. (NEMA, No. 54 at p. 45)
90

NEMA also noted that chapter 3 of DOE’s preliminary TSD did not discuss the 

option of increasing the flux density in the air gap, while chapter 4 did. (NEMA, No. 54 

at p. 46) NEMA added that the air gap flux density is not a design option that can be 

independently adjusted and that for a given core length the only option available for 

changing the air gap flux density is to change the number of effective turns in the stator 

winding. (NEMA, No. 54 at pp. 62, 63) NEMA also commented on the limitations 

associated with reducing a motor’s air gap by noting that manufacturers must ensure that 

the motor is still functional and that the air gap is not so small such that the rotor and 

stator may strike each other during operation. (NEMA, No. 54 at pp. 44-45)

Lastly, during the preliminary analysis public meeting, Danfoss commented that 

the term “technology options” is a bit misleading because of the design tradeoffs that 

must be made in order to maintain motor performance (other than efficiency). (Danfoss, 

Public Meeting Transcript, No. 60 at pp. 98, 99)

Regarding the requested clarifications, DOE notes the listed option of “improved 

rotor insulation” refers to increasing the resistance between the rotor squirrel-cage and 

the rotor laminations. Manufacturers use different methods to insulate rotor cages, such 

as applying an insulating coating on the rotor slot prior to die-casting or heating and 

quenching32

 32 Quenching is rapid cooling, generally by immersion in a fluid instead of allowing the rotor temperature 

to equalize to ambient

the rotor to separate rotor bars from rotor laminations after die-casting. DOE 

has updated the discussion in the TSD chapter to clarify that there are multiple ways to 

implement this technology option. 
91

DOE agrees with NEMA that increasing the cross-sectional area of copper in the 

stator is synonymous with reducing the stator resistance, and has updated the discussion 

in TSD chapter 3 for clarity. Furthermore, DOE agrees with NEMA that increasing rotor 

slot size is a technique that reduces rotor resistivity. DOE also considered other 

techniques to reduce rotor resistivity such as increasing the volume of the rotor end rings 

and using die-cast copper rotors. For the sake of clarity, DOE has replaced the technology 

option “reduce rotor resistance” in the TSD discussion with the specific techniques that 

DOE considered in its analysis: increasing the cross-sectional area of the rotor conductor 

bars, increasing the cross-sectional area of the end rings, and using a die-cast copper rotor 

cage. 

With regard to increasing the flux density in the air gap, DOE consulted with its 

subject matter expert and acknowledges that this approach is not necessarily an 

independently adjustable design parameter used to increase motor efficiency and has 

removed it from its discussion in chapters 3 and 4 of the TSD. DOE notes that it 

understands that the technology options that it discusses do have limits, both practical 

limits in terms of manufacturing and design limits in terms of their effectiveness. DOE 

also understands that a manufacturer must balance any options to improve efficiency 

against the possible impacts on the performance attributes of its motor designs.
92

a. Decrease the Length of Coil Extensions

One method of reducing resistance losses in the stator is decreasing the length of 

the coil extensions at the end turns. Reducing the length of copper wire outside the stator 

slots not only reduces the resistive losses, but also reduces the material cost of the electric 

motor because less copper is being used.

NEMA submitted comments acknowledging decreased coil extension as an option 

to increase efficiency, but did not see the practicability. NEMA asserted that decreasing 

the length of a coil extension has been a common industry practice for over 50 years and 

it would be difficult to achieve any further reductions in motor losses under this option. 

NEMA added that any design changes that would decrease the length of a coil extension 

must be carefully considered to ensure that the coil heads meet all applicable creep and 

strike distance requirements.33 (NEMA, No. 54 at p. 57) 

DOE understands that there may be limited efficiency gains, if any, for most 

electric motors using this technology option. DOE also understands that electric motors 

have been produced for many decades and that many manufacturers have improved their 

production techniques to the point where certain design parameters may already be fully 

optimized. However, DOE maintains that this is a design parameter that affects efficiency 

and should be considered when designing an electric motor. 

 33 Creep distance is the shortest path between two conductive parts. An adequate creep distance protects 

against tracking, a process that can lead to insulation deterioration and eventual short circuit. Strike 

distance is the shortest distance through air from one conductor to another conductor or to ground. 

Adequate strike distance is required to prevent electrical discharge between two conductors or between 

conductors and ground.
93

b. Increase Cross-Sectional Area of Rotor Conductor Bars

Increasing the cross-sectional area of the rotor bars, by changing the crosssectional geometry of the rotor, can improve motor efficiency. Increasing the crosssectional area of the rotor bars reduces the resistance and thus lowers the I2

R losses. 

However, changing the shape of the rotor bars may affect the size of the end rings and 

can also change the torque characteristics of the motor. 

NEMA acknowledged that increasing the cross-sectional area of rotor bars is an 

option to increase efficiency, but doubted whether any additional reductions in motor 

losses were possible by using this method. After 50 years of increasing efficiency through 

this technique, NEMA questioned whether manufacturers could further increase the 

cross-sectional area of the rotor bars, adding that the increase in rotor current cannot 

exceed the square of the decrease in the rotor resistance in order for the rotor losses to 

decrease. NEMA added that any design changes using this option must be carefully 

considered to ensure that the motor will meet the applicable NEMA MG 1 performance 

requirements (i.e., stall time, temperature rise, overspeed) and, for certain applications, 

any other industry standards (i.e., IEEE 84134) to maintain the same level of utility. 

(NEMA, No. 54 at pp. 57, 58) 

 34 IEEE 841-2009, “IEEE Standard for Petroleum and Chemical Industry--Premium-Efficiency, SevereDuty, Totally Enclosed Fan-Cooled (TEFC) Squirrel Cage Induction Motors--Up to and Including 370 kW 

(500 hp),” identifies the recommended practice for petroleum and chemical industry severe duty squirrelcage induction motors.
94

DOE recognizes that increasing the cross-sectional area of a conductor rotor bar 

may yield limited efficiency gains for most electric motors. However, DOE maintains 

that this is a design parameter that affects efficiency and must be considered when 

designing an electric motor. Additionally, when creating its software models, DOE 

considered rotor slot design, including cross sectional areas, such that any software model 

produced was designed to meet the appropriate NEMA performance requirements for 

torque and locked rotor current. 

c. Increase Cross-Sectional Area of End Rings 

End rings are the components of a squirrel-cage rotor that create electrical 

connections between the rotor bars. Increasing the cross-sectional area of the end rings 

reduces the resistance and thus lowers the I2

R losses in the end rings. A reduction in I2R 

losses will occur only when any proportional increase in current as a result of an increase 

in the size of the end ring is less than the square of the proportional reduction in the end 

ring resistance

NEMA commented that increasing the end ring size increases the rotor weight, 

and consideration must be given to the effects a heavier end ring will have on the life of 

the rotor. NEMA added that any design changes using this option must be carefully 

considered to ensure that the applicable design requirements are met and intended utility 

retained. (NEMA, No. 54 at p. 58)
95

When developing its software models, DOE relied on the expertise of its subject 

matter expert. Generally, increases to end ring area were limited to 10–20% are unlikely 

to have significant impacts on the mechanical aspects of the rotor. Furthermore, DOE 

ensured that the appropriate NEMA performance requirements for torque and lockedrotor current were maintained with its software modeled motors. 

d. Increase the Number of Stator Slots

Increasing the number of stator slots associated with a given motor design can, in 

some cases, improve motor efficiency. Similar to increasing the amount of copper wire in 

a particular slot, increasing the number of slots may in some cases permit the 

manufacturer to incorporate more copper into the stator slots. This option would decrease 

the losses in the windings, but can also affect motor performance. Torque, speed and 

current can vary depending on the combination of stator and rotor slots used.

NEMA indicated that increasing the number of slots to allow the motor design 

engineer to incorporate additional copper into the stator slots is contrary to any practical 

analysis. NEMA elaborated that the stator core holds the stator winding in the slots and 

carries the magnetic flux in the electrical steel. As stator slots increase, insulating 

material will increase, reducing the total amount of cross-sectional area for stator 

winding. Additionally, too large of an increase in the number of stator slots may make it 

impractical to wind the stator on automated equipment and the same may be true for a 

low number of stator slots. NEMA also commented that while it agrees with DOE that 

the number of stator slots can affect motor torque and efficiency, there is a relationship 
96

between the number of rotor slots and stator slots, and the combination of the two can 

have significant effects on starting torque, sound levels, and stray load losses. NEMA 

concluded that all of these effects must be considered to ensure the practicability of 

manufacturing the affected motors. Other factors NEMA noted included winding and 

potential sound levels – all of which could impact utility along with health and safety 

concerns. (NEMA, No. 54 at p. 61)

With respect to stator slot numbers, DOE understands that a motor manufacturer 

would not add stator slots without any appreciation of the impacts on the motor’s 

performance. DOE also understands that there is an optimum combination of stator and 

rotor slots for any particular frame size and horsepower combination. DOE consulted 

with its subject matter expert and understands that optimum stator and rotor slot 

combinations have been determined by manufacturers and are in use on existing 

production lines.” Consequently, DOE has removed this technology option from chapter 

4 of the TSD. 

e. Electrical Steel with Lower Losses

Losses generated in the electrical steel in the core of an induction motor can be 

significant and are classified as either hysteresis or eddy current losses. Hysteresis losses 

are caused by magnetic domains resisting reorientation to the alternating magnetic field. 

Eddy currents are physical currents that are induced in the steel laminations by the 

magnetic flux produced by the current in the windings. Both of these losses generate heat 

in the electrical steel.
97

In studying the techniques used to reduce steel losses, DOE considered two types 

of materials: conventional silicon steels, and “exotic” steels, which contain a relatively 

high percentage of boron or cobalt. Conventional steels are commonly used in electric 

motors manufactured today. There are three types of steel that DOE considers 

“conventional:” cold-rolled magnetic laminations, fully processed non-oriented electrical 

steel, and semi-processed non-oriented electrical steel.

One way to reduce core losses is to incorporate a higher grade of core steel into 

the electric motor design (e.g., switching from an M56 to an M19 grade). In general, 

higher grades of electrical steel exhibit lower core losses. Lower core losses can be 

achieved by adding silicon and other elements to the steel, thereby increasing its 

electrical resistivity. Lower core losses can also be achieved by subjecting the steel to 

special heat treatments during processing. 

The exotic steels are not generally manufactured for use specifically in the electric 

motors covered in this rulemaking. These steels include vanadium permendur and other 

alloyed steels containing a high percentage of boron or cobalt. These steels offer a lower 

loss level than the best electrical steels, but are more expensive per pound. In addition, 

these steels can present manufacturing challenges because they come in nonstandard 

thicknesses that are difficult to manufacture.
98

NEMA and Baldor submitted multiple comments concerning DOE’s discussion 

during the preliminary analysis regarding the use of Epstein testing to determine an 

electrical steel grade that would improve the efficiency of an electric motor. (NEMA, No. 

54 at pp. 21-23, 62; NEMA, Public Meeting Transcript, No. 60 at pp. 100, 102, 103) The 

grading of electrical steel is made through a standardized test known worldwide as the 

Epstein Test.35 This test provides a standardized method of measuring the core losses of 

different types of electrical steels. NEMA commented that relying solely on Epstein test 

results to select grades of steel could result in a motor designer inadvertently selecting a 

steel grade that performs poorly in a motor design. NEMA supplied data on two different 

samples of steel supplied by different manufacturers, but consisting of the same steel 

grade. The data illustrated how the lower loss steel (as determined by Epstein test results) 

resulted in a less efficient motor when used in a prototype. NEMA noted that this 

situation poses a problem for computer software modeling because a model that 

represents only the general class of electrical steel and not the steel source (manufacturer) 

would not be able to calculate the difference in the results between the supposedly 

equivalent grades of steels from separate manufacturers. 

DOE clarifies that its computer software did not model general classes of 

electrical steel, but instead modeled vendor-specific electrical steel. DOE’s software 

utilized core loss vs. flux density curves supplied by an electrical steel vendor as one 

component of the core loss calculated by the program. A second component was also 

 35 ASTM Standard A343 / A343M, 2003 (2008), “Standard Test Method for Alternating-Current Magnetic 

Properties of Materials at Power Frequencies Using Wattmeter-Ammeter-Voltmeter Method and 25-cm 

Epstein Test Frame,” ASTM International, West Conshohocken, PA, 2008
99

added to account for high frequency losses. DOE agrees with NEMA’s claim that relative 

performance derived from Epstein testing might not be indicative of relative performance 

in actual motor prototypes. DOE did not solely rely on relative steel grade when selecting 

electrical steels for its designs. To illustrate this point, DOE notes that almost all of its 

software modeled designs utilized M36 grade steel, even though it was not the highest 

grade of electrical steel considered in the analysis. When higher grade M15 steel was 

evaluated in DOE’s software modeled designs, the resulting efficiencies were actually 

lower than the efficiencies when using M36 grade steel for several reasons including the 

reasons cited by NEMA. The Epstein test results for various grades of steel provided in 

chapter 3 of the preliminary analysis TSD were purely informational and intended to give 

an indication of the relative performance of a sample of electrical steels considered. That 

information has been removed from chapter 3 of the TSD to avoid any further confusion. 

f. Thinner Steel Laminations

As addressed earlier, there are two types of core losses that develop in the 

electrical steel of induction motors -- hysteresis losses and losses due to eddy current. 

Electric motors can use thinner laminations of core steel to reduce eddy currents. The 

magnitude of the eddy currents induced by the magnetic field become smaller in thinner 

laminations, making the motor more energy efficient. In the preliminary analysis, DOE 

only considered conventional steels with standard gauges available in the market.

NEMA agreed with DOE’s initial decision to consider only lamination 

thicknesses that are currently used in motor manufacturing, as there is a practical limit on 
100

how thick the laminations can be in electric motors before additional losses may become 

significant. (NEMA, No. 54 at p. 62) DOE continues to consider this as a viable 

technology option in the NOPR analysis.

g. Increase Stack Length

Adding electrical steel to the rotor and stator to lengthen the motor can also 

reduce the core losses in an electric motor. Lengthening the motor by increasing stack 

length reduces the magnetic flux density, which reduces core losses. However, increasing 

the stack length affects other performance attributes of the motor, such as starting torque. 

Issues can arise when installing a more efficient motor with additional stack length 

because the motor becomes longer and may not fit into applications with dimensional 

constraints.

NEMA requested clarification of the phrase “add stack height,” which DOE 

included in its summary of technology options for improving efficiency in chapter 3 of 

the preliminary TSD. NEMA was unsure if this meant increasing the length of the core or 

increasing the outer diameter of the stator core laminations. (NEMA, no. 54 at p. 45)

DOE clarifies that it was referring to increasing the length of the stator and rotor. 

However, increasing the outside diameter of the stator core is another way in which 

manufacturers could add active material to their electric motor designs and potentially 

increase efficiency.
101

NEMA agreed that changing the stack length of an electric motor can improve 

core losses (i.e. reduce them), but may also change other performance characteristics 

such as torque, speed and current. However, NEMA stressed that there are limits to this 

technology option because too much additional stack could cause the motor to increase in 

size (i.e., frame length), which might introduce utility problems in space-constrained 

applications (NEMA, No. 54 at p. 62) NEMA also commented that since the EISA 2007 

standards were enacted, only a limited number of motor ratings above NEMA Premium 

have been offered because there is not sufficient space available in most frame ratings to 

increase the efficiency. (NEMA, No. 54 at p. 7) DOE understands that there are limits to 

increased stack length and, as discussed in IV.C, DOE established criterion to limit the 

length of the stack considered in the engineering analysis. DOE also understands that 

stack length affects consumer utility, which is a factor that DOE considers in its selection 

of a standard. 

h. More Efficient Cooling System

Optimizing a motor’s cooling system that circulates air through the motor is 

another technology option to improve the efficiency of electric motors. Improving the 

cooling system reduces air resistance and associated frictional losses and decreases the 

operating temperature (and associated electrical resistance) by cooling the motor during 

operation. This can be accomplished by changing the fan or adding baffles to the current 

fan to help redirect airflow through the motor.
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NEMA agreed that changes in the cooling system may reduce the total losses of a 

motor, but did not agree that this is equivalent to a more efficient cooling system, as DOE 

described. NEMA elaborated that when the design of an electric motor is changed, losses 

associated with the cooling system may increase in order to provide a decrease in losses 

associated with some other part of the design. (NEMA, No. 54 at p. 63) DOE appreciates 

NEMA’s comments and has clarified its phrasing of this technology option to reflect the 

fact that it is the motor that becomes more efficient, not necessarily the cooling system.

i. Reduce Skew on Conductor Cage

In the rotor, the conductor bars are not straight from one end to the other, but 

skewed or twisted slightly around the axis of the rotor. Decreasing the degree of skew can 

improve a motor’s efficiency. The conductor bars are skewed to help eliminate harmonics 

that add cusps, losses, and noise to the motor’s speed-torque characteristics. Reducing the 

degree of skew can help reduce the rotor resistance and reactance, which helps improve 

efficiency. However, overly reducing the skew also may have adverse effects on starting, 

noise, and the speed-torque characteristics.

NEMA inquired if this design option was considered for any of the designs used 

in the engineering analysis, as the preliminary TSD did not indicate if any rotors were 

skewed. (NEMA, No. 54 at p. 63) NEMA also inquired why the option to reduce skew on 

the conductor cage, was associated with I2

R losses in chapter 3 of the preliminary TSD, 

but in chapter 4 of the preliminary TSD this option was associated with reducing stray 

load losses. (NEMA, No. 54 at p. 46) 
103

DOE notes that all software designs used in the analysis had skewed rotor designs 

and, in general, the skews used were approximately 100 percent of a stator or rotor slot 

pitch, whichever had the smaller number of slots. Additionally, DOE intended for the 

option of reducing the skew on the conductor cage to be an option associated with 

reducing stray load losses and has made the appropriate adjustments to its text and tables.

B.

After DOE identified the technologies that might improve the energy efficiency of 

electric motors, DOE conducted a screening analysis. The purpose of the screening 

analysis is to determine which options to consider further and which to screen out. DOE 

consulted with industry, technical experts, and other interested parties in developing a list 

of design options. DOE then applied the following set of screening criteria, under 

sections 4(a)(4) and 5(b) of appendix A to subpart C of 10 CFR Part 430, “Procedures, 

Interpretations and Policies for Consideration of New or Revised Energy Conservation 

Standards for Consumer Products,” to determine which design options are unsuitable for 

further consideration in the rulemaking:

Screening Analysis

• Technological Feasibility: DOE will consider only those technologies 

incorporated in commercial equipment or in working prototypes to be 

technologically feasible.
104

• Practicability to Manufacture, Install, and Service: If mass production of a 

technology in commercial equipment and reliable installation and servicing of 

the technology could be achieved on the scale necessary to serve the relevant 

market at the time of the effective date of the standard, then DOE will 

consider that technology practicable to manufacture, install, and service.

• Adverse Impacts on Equipment Utility or Equipment Availability: DOE will 

not further consider a technology if DOE determines it will have a significant 

adverse impact on the utility of the equipment to significant subgroups of 

customers. DOE will also not further consider a technology that will result in 

the unavailability of any covered equipment type with performance 

characteristics (including reliability), features, sizes, capacities, and volumes 

that are substantially the same as equipment generally available in the United 

States at the time.

• Adverse Impacts on Health or Safety: DOE will not further consider a 

technology if DOE determines that the technology will have significant 

adverse impacts on health or safety.

Table IV.7Table IV.7 below presents a general summary of the methods that a 

manufacturer may use to reduce losses in electric motors. The approaches presented in 

this table refer either to specific technologies (e.g., aluminum versus copper die-cast rotor 

cages, different grades of electrical steel) or physical changes to the motor geometries 
105

(e.g., cross-sectional area of rotor conductor bars, additional stack height). For additional 

details on the screening analysis, please refer to chapter 4 of the preliminary TSD. 

Table IV.7 Summary List of Options from Technology Assessment

Type of Loss to Reduce Technology Option

Stator I2R Losses

Increase cross-sectional area of copper in stator slots

Decrease the length of coil extensions

Rotor I2R Losses

Use a die-cast copper rotor cage

Increase cross-sectional area of rotor conductor bars

Increase cross-sectional area of end rings

Core Losses

Use electrical steel laminations with lower losses (watts/lb)

Use thinner steel laminations 

Increase stack length (i.e., add electrical steel laminations) 

Friction and Windage 

Losses

Optimize bearing and lubrication selection

Improve cooling system design

Stray-Load Losses

Reduce skew on rotor cage

Improve rotor bar insulation

1. Technology Options Not Screened Out of the Analysis

The technology options in this section are options that passed the screening 

criteria of the analysis. DOE considers the technology options in this section to be viable 

means of improving the efficiency of electric motors. In NEMA’s view, DOE’s screening 

analysis lacked sufficient supporting information regarding whether a particular 

technology is included or screened out of the analysis. NEMA agreed that it is necessary 

to look at new technologies, but added that DOE did not provide adequate supporting 

information in its analysis and the group asserted that commenters were left without 

adequate material upon which to base comments in support of or in opposition to 
106

statements made in the preliminary TSD. NEMA suggested that a form clearly 

identifying the issues pertinent to the topic be provided for each option analyzed. NEMA 

stated that providing these forms for each technology option would supply adequate 

material on which commenters can develop public comments. (NEMA, No. 54 at p. 45) 

Additionally, when discussing the seven criteria that DOE must consider in its analysis, 

NEMA expressed that there are more criteria that should be considered. NEMA stated 

that DOE must consider 4(d)(7) of 10 CFR part 430, subpart C, appendix A which lists 

under sections 4.(d)(7)(viii) impacts of non-regulatory approaches and (ix) new 

information relating to the factors used for screening design options. (NEMA, No. 54 at 

p. 13)

Regarding NEMA’s request for a form for each technology option considered, 

today’s NOPR provides detailed information about each technology option considered 

and DOE is requesting comment on each option. DOE understands NEMA’s concerns 

about the technology options not screened out of the DOE analysis. With the exception of 

copper rotor motors, DOE understands that each technology option that it has not 

screened out is a design option that a manufacturer would consider in each motor 

designed and built. DOE recognizes that manufacturers design their motors to balance a 

number of competing factors that all inter-relate with each other, including performance, 

reliability, and energy efficiency. Because the options DOE has identified can be 

modified to improve efficiency while maintaining performance, it is DOE’s tentative 

view that at least some significant level of energy efficiency improvement is possible 

with each technology option not screened out by DOE.
107

Furthermore, DOE notes that it did not explicitly use each of the technology 

options that passed the screening criteria in the engineering analysis. As discussed in 

section IV.C, DOE’s engineering analysis was a mixture of two approaches that DOE 

routinely uses in its engineering analysis methodology: the reverse-engineering approach 

(in which DOE has no control over the design parameters) and the efficiency-level 

approach (in which DOE tried to achieve a certain level of efficiency, rather than 

applying specific design options). This hybrid of methods did not allow for DOE to fully 

control which design parameters were ultimately used for each representative unit in the 

analysis. Without the ability to apply specific design options, DOE could not include 

every option that was not screened out of the analysis. Finally, DOE appreciates NEMA’s 

comments regarding Appendix A to Subpart U of part 430. DOE has considered all 

comments related to the two factors identified by NEMA in its rule.

In addition, DOE notes that its analysis neither assumes nor requires 

manufacturers to use identical technology for all motor types, horsepower ratings, or 

equipment classes. In other words, DOE’s standards are technology-neutral and permit 

manufacturers design flexibility. 

a. Copper Die-Cast Rotors

Aluminum is the most common material used today to create die-cast rotor bars 

for electric motors. Some manufacturers that focus on producing high-efficiency designs 

have started to offer electric motors with die-cast rotor bars made of copper. Copper 
108

offers better performance than aluminum because it has better electrical conductivity (i.e., 

a lower electrical resistance). However, because copper also has a higher melting point 

than aluminum, the casting process becomes more difficult and is likely to increase both 

production time and cost.

NEMA commented that performance is a relative term, and that the NEMA MG 

1-2011 standard specifies performance characteristics and specifications for various types 

of motors. NEMA added that tradeoffs among various performance characteristics related 

to the conductivity of copper are required when designing a NEMA Design B electric 

motor that is in full conformance with the NEMA MG 1-2011 standards. NEMA 

commented that DOE did not address all aspects of motor performance specified in the 

NEMA MG 1-2011 standard, especially some of the performance requirements related to 

the choice of conductive material in the rotor. (NEMA, No. 54 at p. 46)

DOE acknowledges that using copper in rotors may require different design 

approaches and considerations. In its own modeling and testing of copper rotor motors, 

DOE ensured that performance parameters stayed within MG 1-2011 limits (i.e., met 

NEMA Design B criteria). DOE seeks comment on any particular aspects of copper rotor 

design, especially those on parameters widely viewed as challenging to meet, and 

requests explanation of why such parameters are especially challenging when using 

copper.
109

The Advocates (NEEA, NPCC, ACEEE, ASAP, Earthjustice, and ASE) disagreed

with DOE’s tentative decision during the preliminary analysis phase to include copper 

die-cast rotors. It urged DOE to exclude this option in order to avoid analyzing a 

technology that is not ready for use across all motor types, configurations, and 

horsepower ratings that DOE would cover as part of its rulemaking. (Advocates, No. 56 

at pp. 3-4)

On a related note, NEMA commented that DOE has not publicly established what 

determines a “mass quantity.” NEMA elaborated that a “mass quantity” should mean the

ability to be produced in significant volume for the entire industry. NEMA commented 

that DOE screened out certain electrical steels because they could not be produced in 

significant volume for the entire industry, and this same logic should apply to copper 

rotor technology. (NEMA, No. 54 at p. 24) 

DOE did not screen out copper as a die-cast rotor conductor material because 

copper die-cast rotors passed the four screening criteria. Because copper is in commercial 

use today, DOE concluded that this material is technologically feasible and practicable to 

manufacture, install, and service. Additionally, manufacturers are already producing such 

equipment, which suggests that such equipment can be safely produced in mass 

quantities. For example, Siemens produces copper rotor motors for 1-20 hp and SEWEurodrive manufactures a full line of motors from 1-30 hp. In addition, DOE notes that 

its analysis neither assumes nor requires manufacturers to use identical technology for all 

motor types, horsepower ratings, or equipment classes.
110

DOE received considerable feedback concerning copper rotor technology. 

Consequently, DOE has organized those comments into sections below as they pertain to 

the four screening criteria. 

As part of its analysis, DOE intends to ensure that utility, which includes frame 

size considerations, is maintained. Increased shipping costs are also taken into account in 

the national impact analysis (NIA) and the life-cycle cost (LCC) analysis portions of 

DOE’s analytical procedures.

Technological Feasibility

NEMA commented that the use of a technology in a limited subclass of electric 

motors does not imply that the technology can be applied to every equipment class 

covered in this rulemaking. NEMA is not aware of any available complete product line of 

NEMA Design A, B, or C copper die-cast rotor electric motors manufactured in the 

United States, and stated that further investigation is required to prove this technology is 

valid for an entire range of designs. (NEMA, No. 54 at pp. 2, 48, 49) NEMA was able to 

find two manufacturers currently producing copper rotor motors in a total of only 33 out 

of over 600 equipment classes covered in this rulemaking.36

 36 The equipment classes NEMA found included NEMA Design A motors from 1 to 30 hp, 4-pole 

configurations, and NEMA Design B motors from 1.5 to 20 hp in a 2-pole configuration, 1 to 20 hp in a 4-

pole configuration, and 1 hp and 3 – 10 hp in a 6-pole configuration. All motor configurations NEMA 

mentioned were enclosed frame motors.

NEMA and Baldor added 

that none of those motors are produced in the United States, and only about half of those 
111

ratings met NEMA Design B performance requirements. (NEMA, No. 54 at pp. 48, 49; 

Baldor, Public Meeting Transcript, No. 60 at pp. 109, 110)

NEMA commented that the die-casting process for copper rotors can increase 

core or stray load losses in the motor, and this is a problem with copper die-casting that 

has not been solved in all rotor sizes. (NEMA, No. 54 at p. 46)

NEMA cited recently conducted U.S. Army studies involving die-cast copper 

rotor motors. It explained that the first study evaluated the advantages of a die-cast 

copper rotor versus an aluminum rotor. The study also attempted to optimize the process 

and estimate manufacturing costs for die-cast copper rotors. NEMA commented that the 

results of the study showed that the die-cast copper rotor motor was unable to stay within 

the NEMA Design B locked-rotor current limits, and that efficiency increased by less 

than one full NEMA band over the comparable NEMA Design B aluminum cast-copper 

rotor motor. The study reported that continued investment in cast copper rotor motor 

technology development is needed to improve design optimization methods, improve the 

casting process, and to investigate utilization of cast copper in larger motor sizes. NEMA 

commented that the number of die-cast copper rotors manufactured in the study was 

insufficient to make any determination that die-casting could be performed on a high and 

consistent quality basis necessary for general production. (NEMA, No. 54 at p. 50, 51)

NEMA also described a different U.S. Army study where a 75-hp aluminum rotor 

motor driving a pump was to be replaced with a 75-hp copper rotor motor. NEMA 
112

explained that in the study the die-cast copper rotor motor’s optimization study indicated 

the motor would have a one NEMA band increase in efficiency over the aluminum diecast rotor motor it was replacing. However, once built, the 75-hp die-cast copper rotor 

motor had an actual efficiency of more than 1 NEMA band below the aluminum die-cast 

rotor motor, with core and stray load losses of the physical motor being higher than the 

computer model had predicted. NEMA concluded that neither study was successful in 

demonstrating that copper rotor die-casting technology is possible or feasible in its 

current state in the U.S., and that continued investment in die-cast copper rotor 

technology development is necessary to improve the copper die-casting process and 

reduce stray load losses. (NEMA, No. 54 at pp. 51-53)

BBF, a consulting company working on behalf of the Copper Development 

Association (CDA), commented that test data of multiple die-cast copper rotor motors 

resulted in an average tested efficiency above the motors’ nameplate efficiency, whereas 

the test results from a similar model aluminum rotor motor tested below its nameplate 

efficiency. In its view, these results fall within the allowable variances prescribed by 

NEMA with respect to measuring electric motor energy efficiency and demonstrate the 

higher energy efficiency potential of die-cast copper rotor motors. (BBF, No. 51 at p. 3) 

NEMA summarized that it is not aware of any prototypes or commercially 

available products that have demonstrated the technical feasibility of utilizing die-cast 

copper rotors sufficient to cover all equipment classes covered in this rulemaking. NEMA 

disagreed with DOE’s conclusion that die-cast copper rotors successfully passed the 
113

screening criteria for technological feasibility relative to the class of all covered electric 

motors, including the 75-hp copper rotor motor which DOE used as a representative unit

in the engineering analysis. NEMA added that DOE has not provided any evidence that 

die-casting copper can successfully be applied to all electric motors covered in this 

rulemaking by December 19, 2015. NEMA added that the recent studies conducted by 

the United States Army noted above showed that, in the U.S. at present or in any 

foreseeable future time, this technology is not currently feasible over the range of motor 

ratings regulated under this rulemaking. (NEMA, No. 54 at pp. 3, 53, 56; NEMA, Public 

Meeting Transcript, No. 60 at p. 111)

The CDA disagreed with NEMA, and stated that die-cast copper rotor motors are 

a feasible technology because manufacturers have already successfully entered the copper 

rotor motor market. The CDA added that a range of development issues have been 

overcome, again suggesting that it is technologically feasible, but copper die-cast rotors 

require redesign and optimization to take advantage of copper’s different electrical 

properties compared to aluminum, and many motor manufacturers have undertaken this 

redesign and optimization to take advantage of the properties of copper. (BBF, No. 51 at 

p. 3) The CDA agreed, however, that current manufacturing capacity would be unable to 

produce motors on the scale of five million units yearly. (CDA, Public Meeting 

Transcript, No. 60 at p. 119) 

DOE acknowledges that the industry is not equipped to produce all motors with 

copper rotors, but has estimated the costs of both capital and product development 
114

through interviews with manufacturers of motors and included these costs in its 

engineering analysis. DOE welcomes comment on the methodology, and on the resulting 

motor prices. As noted earlier, EPCA, as amended, does not require manufacturers to use 

identical technology for all motor types, horsepower ratings, or equipment classes.

DOE recognizes that assessing the technological feasibility of high-horsepower 

copper die-cast rotors is made more complex by the fact that manufacturers do not offer 

them commercially. That could be for a variety of reasons, among them:

1. Large copper die-cast rotors are physically impossible to construct;

2. They are possible to construct, but impossible to construct to required 

specifications;

3. They are possible to construct to required specifications, but would 

require manufacturing capital investment to do so and be so costly that 

few (if any) consumers would choose them.

Some exploratory research suggests that different organizations have developed 

and used copper rotors in high-horsepower traction (i.e., vehicle propulsion) motors. For 

example, Tesla Motors powers its Roadster37 and Model S38 vehicles with copper 

induction motors generating 30039 or more peak horsepower and Oshkosh die-cast copper 

rotor induction motors rated at 140 peak hp.

40

 37

Remy International, Inc. (Remy) also 

builds high-horsepower copper motors that are claimed to exceed 300 horsepower at 

http://www.teslamotors.com/roadster/technology/motor 38 http://www.teslamotors.com/models/specs 39 http://www.teslamotors.com/roadster/specs 40 See http://www.coppermotor.com/wp-content/uploads/2012/04/casestudy_army-truck.pdf
115

600V.41 DOE seeks comment on these, and on other high-horsepower motors that use 

copper rotors.

DOE recognizes that these motors are designed for a different purpose than most 

motors in the current scope of this rulemaking. Their existence suggests that copper has 

been successfully used at high power levels in an application where efficiency is critical 

and casts doubt on the idea that copper die-cast rotors can be screened out with certainty.

Another reason to be cautious about screening out copper die-cast rotors comes 

from an analogous product: distribution transformers. DOE conducted a recent 

rulemaking on distribution transformers,42 which (as with motors) have two sets of 

conductors that surround electrical steel to transfer power. Although distribution 

transformers do not rotate, many of the ways that they lose energy (e.g., conductor losses) 

are the same as electric motors. They also face constraints (as motors do) on performance 

aspects unrelated to efficiency; inrush current and overall volume are two examples. At 

current prices, copper is generally not viewed as economical for most efficiency levels 

but, if properly designed, copper windings almost always result in smaller, cooler, and 

more efficient transformers. 

In general, copper may improve efficiency relative to aluminum because it carries 

an inherently higher level of electrical conductivity. Several organizations have 

 41 http://www.remyinc.com/docs/hybrid/REM-12_HVH410_DataSht.pdf 42 Available at: http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0048-0762
116

conducted research and built prototype43 motors that use materials even more conductive 

than copper, such as “superconductive” materials that have no conductive losses to 

achieve even greater electric motor efficiency. While DOE is not considering the use of 

these more conductive materials at this time, DOE notes their existence for purposes of 

demonstrating the potential advantages of using materials that lower conductive losses.

While recognizing that motors are not transformers, the parallels that can be 

drawn leave DOE hesitant to screen out copper die-cast rotors on the basis of 

technological feasibility. Relative to the above list of possible reasons for their absence 

from the high-horsepower market, DOE’s analysis does not conclude copper die-cast 

rotors are either: (1) physically impossible to construct or (2) possible to construct, but 

impossible to construct to required specifications. 

Regarding DOE’s projections that the annual sales of electric motors, as defined 

by EISA 2007 will have grown to 5,089,000 units by 2015, including over 24,000 

possible motor configurations, NEMA commented that only a single manufacturer is 

currently producing die-cast copper rotor motors, and in a very limited range. In its view, 

without sufficient data and analysis to support DOE’s conclusion that “mass production” 

of die-cast copper rotors is possible, NEMA asserts that this technology would not pass 

the screening criterion of practicability to manufacture, install, and service. It argues that, 

based on the limited advances of the technology from 1995 to present day in the United 

Practicability to Manufacture, Install, and Service

 43 See General Atomics marine propulsion motor at: http://www.ga.com/electric-drive-motors
117

States, this technology is unlikely to be mature enough by the compliance date for this 

rulemaking to meet the required production of over 5 million motors in the U.S., even if 

all manufacturing were shifted overseas. (NEMA, No. 54 at pp. 3, 47, 53, 54, 56; NEMA, 

Public Meeting Transcript, No. 60 at p. 114) NEMA noted that mandating this 

technology may also have the indirect effect of establishing a monopoly market in the 

U.S. for those manufacturers who can produce copper rotor motors, or to push production 

jobs overseas and penalize motor manufacturers that do not have the capability to 

produce copper rotor motors. (NEMA, No. 54 at p. 24)

DOE recognizes the importance of maintaining a competitive market. However, 

because there are at least two domestic manufacturers of motors with copper rotors and 

because several more are manufacturing internationally, DOE believes the opportunity 

for price manipulation is limited. Furthermore, DOE has seen no evidence to suggest that 

a monopoly would be likely to occur. DOE requests comment and further information 

that would demonstrate the likelihood of a future monopoly. 

BBF and the CDA commented that there are copper die-casting facilities in the 

U.S. – specifically in Colorado and Ohio – as well as in Mexico. They added that die-cast 

rotor motors have been produced for North American service since 2005, and some of 

these motors meet NEMA Design B requirements. The CDA and BBF added that 

multiple high-volume manufacturers in Europe and Asia have produced tens of thousands 

of die-cast copper rotor motors that satisfy the NEMA-specified performance 

requirements that meet or exceed the NEMA Premium levels. These motors have been 
118

sold to North American users. (BBF, No. 51 at pp. 2, 3) DOE was able to purchase and 

tear down a 5-hp copper rotor motor from an Asian manufacturer that performed at 

DOE’s max-tech efficiency level, as well as the performance requirements for NEMA 

Design B. 

SEW Eurodrive stated that it offers only three models of cast-copper rotor motors 

and cited the expenses and difficulty of casting copper rotors as the reason why it does 

not offer more die-cast copper rotor motor models. (SEWE, Public Meeting Transcript, 

No. 60 at p. 121) The company did not elaborate why it manufactures die-cast copper 

rotor motors in the configurations it offers for sale.

Based on these comments, DOE does not believe it has grounds to screen out 

copper die-cast rotors on the basis of practicability to manufacture, install, and service. 

The available facts indicate that manufacturers are already producing smaller motors with 

die-cast copper rotors, leaving the question of whether larger motors are being 

manufactured with die-cast copper rotors. DOE recognizes that as technology scales 

upward in size, it can require different equipment and processes. Nonetheless, Tesla’s44

and Remy’s45 300+ horsepower motors with copper rotors cast doubt on the assertion that 

copper is impracticable in this size range. 

DOE understands that full-scale deployment of copper would likely require 

considerable capital investment (see detailed discussion in SectionIV.J.2.a) and that such 

 44 http://www.teslamotors.com/roadster/technology/motor 45 http://www.remyinc.com/docs/hybrid/REM-12_HVH410_DataSht.pdf
119

investment could increase the production cost of large copper rotor motors considerably. 

DOE believes that its current engineering analysis reflects this likelihood, and welcomes 

comment on this issue.

NEMA commented that DOE failed to address the adverse impacts on equipment 

utility or availability caused by die-cast copper rotors. It asserted that the process for 

manufacturing die-cast copper rotors is underdeveloped, and energy conservation 

standards based on this technology, and implemented in 2015, would result in product 

unavailability of over 99 percent of the electric motors that would be impacted if DOE 

were to set a standard that would require the use of die-cast copper. NEMA reiterated that 

there is no justification as to how motors that are not available today, made from a 

technology that is not practiced in the U.S. today, will become available within three 

years, especially when taking into account the time needed for prototyping, testing, and 

AEDM certification. (NEMA, No. 54 at pp. 3, 47, 48, 54, 55, 56; NEMA, Public Meeting 

Transcript, No. 60 at pp. 114, 115)

Adverse Impacts on Equipment Utility or Equipment Availability

NEMA also commented that it is difficult for die-cast copper rotor motors to stay 

under the maximum locked-rotor current limit for NEMA Design B motors. If this 

technology were adopted, in its view, many current NEMA Design B motors would 

become NEMA Design A motors. This would reduce the utility of a motor, because a 

NEMA Design A motor is not a direct drop-in place replacement for a NEMA Design B 

motor. (NEMA, No. 54 at p. 3) 
120

DOE agrees that, in some cases, redesigning product lines to use copper would

entail substantial cost. DOE’s engineering analysis reflects its estimates of these costs 

and discusses them in detail in section IV.C. DOE was able to model copper rotor motors 

adhering to the specifications of NEMA Design B46, including the reduced (relative to 

Design A) locked-rotor current.

Finally, based on DOE’s own shipments analysis (see TSD Chapter 9) and 

estimates of worldwide annual copper production,47 DOE estimates that .01-.02% of 

worldwide copper supply would be required to use copper rotors for every single motor 

within DOE’s scope of coverage. At the present, DOE does not believe there is sufficient 

evidence to screen copper die-cast rotors from the analysis on the basis of adverse 

impacts to equipment utility or availability.

NEMA commented that the preliminary TSD does not sufficiently explain how 

DOE concluded that mandating performance levels that would require copper rotor diecasting would not have an adverse impact on health or safety, with the implication being 

on occupational health and safety. NEMA commented that the preliminary TSD 

mentioned potential impacts on the health or safety caused by the higher melting point of 

copper, but DOE did not elaborate on what these potential impacts were. NEMA 

Adverse Impacts on Health or Safety

 46 The parameters DOE believed to present the largest risk of rendering a motor noncompliant with NEMA 

MG 1-2011 standards were those related to NEMA design letter, which were adhered to in DOE’s 

modeling efforts. 

47 http://minerals.usgs.gov/minerals/pubs/commodity/copper/mcs-2012-coppe.pdf
121

disagreed with DOE’s conclusion not to screen out die-cast copper rotor technology on 

the premise that handling molten copper is similar to handling molten aluminum. NEMA 

noted that copper has a pouring temperature of 2100 degrees Fahrenheit and a 150 

percent higher casting pressure than aluminum, and that, combined, these two 

characteristics would increase the severity of any potential accidents. NEMA mentions an 

incident involving the two U.S. Army die-cast copper rotor studies previously mentioned, 

which resulted in injuries during the die-casting of aluminum48 [sic] cage rotors and 

caused the only U.S. manufacturer of copper die-casting equipment to withdraw that 

equipment from the market. NEMA added that the equipment currently remains 

unavailable for purchase. (NEMA, No. 54 at pp. 10, 55, 56; NEMA, Public Meeting 

Transcript, No. 60 at p. 115) NEMA added that, especially regarding die-casting copper 

on larger motor sizes, DOE cannot justifiably claim that there are no adverse impacts on 

health or safety until they conduct a thorough investigation or feasibility study regarding 

this topic. (NEMA, No. 54 at p. 3)

However, BBF also commented that copper die-cast rotors can be safely 

manufactured, as one major manufacturer indicated that they have had no worker injuries 

in volume production over multiple years. (BBF, No. 51 at p. 3)

BBF commented that, with the extensive capabilities of copper die-cast rotors and 

commercial availability of copper die-cast rotors with efficiencies higher than NEMA 

MG 1-2011 Table 12-12 efficiencies, DOE should include in its evaluations copper die-

 48 From the context of NEMA’s comment, DOE believes the use of the word “aluminum” was a 

typographical error and that NEMA had intended this passage to use the word “copper” instead.
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cast rotor motors. BBF also added that they strongly disagree with the NEMA 

representatives’ contrary verbal suggestions towards copper rotor motor technology 

presented during the public meeting. (BBF, No. 51 at p. 4)

DOE is aware of the higher melting point of copper (1084 degrees Celsius versus 

660 degrees Celsius for aluminum) and the potential impacts this may have on the health 

or safety of plant workers. However, DOE does not believe at this time that this potential 

impact is sufficiently adverse to screen out copper as a die cast material for rotor 

conductors. The process for die casting copper rotors involves risks similar to those of die 

casting aluminum. DOE believes that manufacturers who die-cast metal at 660 Celsius or 

1085 Celsius (the respective temperatures required for aluminum and copper) would need 

to observe strict protocols to operate safely. DOE understands that many plants already 

work with molten aluminum die casting processes and believes that similar processes 

could be adopted for copper. DOE has not received any supporting data about the 

increased risks associated with copper die casting, and could not locate any studies 

suggesting that the die-casting of copper inherently represented incrementally more risks 

to worker safety and health. DOE notes that several OSHA standards relate to the safety 

of “Nonferrous Die-Castings, Except Aluminum,” of which die-cast copper is part. DOE 

seeks comment on any adverse safety or health impacts and on these OSHA standards49, 

and on any other specific information document the safety of die-casting for both copper 

and aluminum.

 49 For a list, see: 

http://www.osha.gov/pls/imis/citedstandard.sic?p_esize=&p_state=FEFederal&p_sic=3364
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b. Increase the Cross-Sectional Area of Copper in the Stator Slots

Increasing the slot fill by either adding windings or changing the gauge of wire 

used in the stator winding can also increase motor efficiency. Motor design engineers can 

achieve this by manipulating the wire gauges to allow for a greater total cross-sectional 

area of wire to be incorporated into the stator slots. This could mean either an increase or 

decrease in wire gauge, depending on the dimensions of the stator slots and insulation 

thicknesses. As with the benefits associated with larger cross-sectional area of rotor 

conductor bars, using more total cross-sectional area in the stator windings decreases the 

winding resistance and associated losses. However, this change could affect the slot fill 

factor of the stator. The stator slot openings must be able to fit the wires so that 

automated machinery or manual labor can pull (or push) the wire into the stator slots. In 

the preliminary analysis, DOE increased the cross-sectional area of copper in the stator 

slots of the representative units by employing a combination of additional windings, 

thinner gauges of copper wire, and larger slots.

In response to the preliminary analysis, NEMA commented that a majority of 

stator windings are manufactured on automated equipment. NEMA and Baldor noted that 

there is a practical limit of 82 percent slot fill for automated winding equipment for 

motors with four or more poles; motors with two poles have a limit of 78 percent. 

(NEMA, No. 54 at p. 58; Baldor, Public Meeting Transcript, No. 60 at p. 146) NEMA 

commented that the values for maximum slot fill for the automated winding models was 

approximately 82 percent and those based on hand winding were 85 percent. NEMA 

noted that this is not a practical change based on a change in conductor size alone 
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because conductors are sized in a larger increment than this difference would suggest. 

Therefore, it would appear that the size of the stator slot in each case was selected to 

purposely result in the corresponding level of slot fill. (NEMA, No. 54 at p. 59) In other 

words, instead of only adjusting the conductor gauge to the slot size, the slot size could 

be adjusted to the conductor gauge.50 (NEMA, No. 54 at p. 59) Baldor added that slot 

fills above 85 percent would be very difficult to do in current production volumes (5 

million motors annually) and noted that this slot fill percentage was based on a DOEpresented software model and has not been proven in a prototype. (Baldor, Public 

Meeting Transcript, No. 60 at pp. 146, 147) NEMA requested that DOE clarify the 

method it used for calculating slot fill to avoid confusion among other interested parties 

who may have used a different calculation method. (NEMA, No. 54 at p. 58) 

DOE calculated the slot fill by measuring the total area of the stator slot and then 

subtracting the cross sectional area for the slot insulation. This method gave DOE a net 

area of the slot available to house copper winding. DOE then identified the slot with the 

most windings and found the cross sectional area of the insulated copper wires to get the 

total copper cross sectional area per slot. DOE then divided the total copper cross 

sectional area by the total slot area to derive the slot fill. DOE’s estimated slot fills for its 

teardowns and software models are all provided in chapter 5 of the TSD. 

NEMA commented that several of DOE’s designs presented maximum values of 

slot fill at 85 percent, whereas the closest automated winding slot fill was 82-percent. 

 50 In practice, of course, a manufacturer may opt to do either or both.
125

NEMA questioned the significant benefit DOE projected in designing the stator slot such 

that a hand winding would be required to gain a 3-percent change in slot fill. In NEMA’s 

view, the change in core loss that might result from increasing the stator slot area by 3 

percent would not be significant enough to warrant hand-winding the stator. (NEMA, No. 

54 at p. 59) DOE notes that the software designs exhibiting these changes in slot fill 

were used when switching from aluminum to a copper rotor design. Therefore, changing 

slot geometries impacted the design’s slot fill and the slot fill changes resulted from 

different motor designs. Consequently, a 3 percent increase in slot fill does not imply that 

this change was made to increase the efficiency of another design, but could have been 

made to change other performance criteria of the motor, such as locked-rotor current. 

In the preliminary analysis, DOE indicated that motor design engineers can adjust 

slot fill by changing the gauge of wire used in fractions of half a gauge. NEMA 

commented that it did not understand DOE’s statement, and indicated that manufacturers 

limit the number of gauges used at any particular manufacturing plant, and few of those 

gauges are “fractions of a half a gauge.” NEMA added that manufacturers may use 

multiple wire gauges in a particular winding, but DOE’s examples in chapter 5 gave no 

indication that any sizes other than a single conductor size was used in each winding. 

(NEMA, No. 54 at pp. 58, 59) DOE clarifies that all the modeled motors utilized standard 

AWG wire sizes, either whole- or half- gauge sizes (i.e., 18 or 18 1⁄2). DOE clarifies that 

the statement of “fractions of a half gauge” referred to sizes in between a whole gauge 

(i.e. 18 1⁄2 of a gauge is a fraction of 18 gauge wire). DOE did not end up using fractions 
126

consisting of a half gauge of wire sizes to conduct its modeling, but did indicate that this 

was a design option used by the motor industry. 

NEMA also commented that it is not uncommon for a manufacturer to use the 

same stator lamination design for all horsepower ratings built in the same NEMA MG 1-

2011 Standard frame series. NEMA indicated that a high slot fill may require hand 

winding for one of the ratings and automated winding for the other rating, and that a good 

design practice for stator laminations will take into consideration more than just one 

motor rating to determine the best design for all ratings in that frame series. (NEMA, No. 

54 at p. 59)

NEMA and Baldor questioned DOE’s decision not to screen out hand-wound 

stators, and both parties commented that moving to hand-wound technology would be a 

reversal of the trend to automate manufacturing practices whenever possible. (NEMA, 

No. 54 at p. 59; Baldor, Public Meeting Transcript, No. 60 at pp. 122, 123) NEMA noted 

that none of the teardown motors in DOE’s analysis appeared to use hand winding 

technology. (NEMA, No. 54 at p. 59) 

While NEMA agrees that hand winding cannot be ruled out on the grounds of 

technological feasibility, it does believe that hand winding would not be practicable to 

use in mass production. A NEMA member survey indicated that hand winding can take 

up to 25 times longer than machine winding. NEMA added that the manpower required 

to replace automated winding would require an increase in manpower in excess of 20 
127

times the number of automated machines. (NEMA, No. 54 at p. 60) NEMA and Baldor 

commented that moving to an energy conservation level based on hand-wound 

technology would not be achievable on the scale necessary to serve the relevant market at 

the time of the effective date of the standard. (NEMA, No. 54 at p. 60; Baldor, Public 

Meeting Transcript, No. 60 at p. 123) NEMA added that it would not be aware if such an 

expansion of the infrastructure would be required until after any amended or new 

standards are announced. (NEMA, No. 54 at p. 60) DOE is aware of the extra time 

involved with hand winding and has attempted to incorporate this time into efficiency 

levels (ELs) that it believes would require hand winding. DOE reiterates that should the 

increase in infrastructure, manpower, or motor cost increase beyond a reasonable means, 

then ELs utilizing this technology will be screened out during the downstream analysis.

NEMA also expressed concern that standards based on hand winding would shift 

U.S. manufacturing jobs to locations outside of the U.S. which have lower labor rates, 

and Nidec added that most U.S. manufacturers are currently globally positioned to move 

labor-intensive work into low-cost labor countries if energy conservation requirements 

force them to do so. (Nidec, Public Meeting Transcript, No. 60 at p. 124) DOE intends to 

fully capture this impact during the manufacturer impact analysis (MIA) portion of 

DOE’s analysis. Please see section IV.J for a discussion of the manufacturer impact 

analysis. 

NEMA also commented that hand-wound technology would have an adverse 

impact on product utility or product availability, saying that the infrastructure would not 
128

be in place in sufficient time to support the hand winding of all of the stators, and there 

will be an adverse impact on the availability of various ratings of electric motors at the 

time of effective standards. (NEMA, No. 54 at p. 60)

NEMA commented that hand winding would have adverse impacts on worker 

health or safety, as both hand winding and hand insertion of stator coils require 

operations performed by hand with repetitive motions, and such hand winding of stators 

also involves the moving and lifting of various stator and winding components, which 

may be of substantial size in larger horsepower rated electric motors. NEMA added that 

any increase in personnel performing the repetitive tasks required by hand winding can 

have an adverse effect on the overall health and safety record of any facility. (NEMA, 

No. 54 at p. 60; NEMA, Public Meeting Transcript, No. 60 at p. 123) 

DOE disagrees with NEMA’s assertion concerning the adverse impacts on health 

or safety, and notes that hand winding is currently practiced by industry. Furthermore, 

DOE is not aware of any data or studies suggesting hand-winding leads to negative health 

consequences. DOE acknowledges that, were hand-winding to become widespread, 

manufacturers would need to hire more workers to perform hand-winding to maintain 

person-winding-hour equivalence, and has accounted for the added costs of hand-winding 

in its engineering analysis. DOE requests comment on its cost estimates for hand-wound 

motors, as well as on the matter of hand-winding in general and on studies suggesting 

negative health impacts in particular. 
129

NEMA summarized its concerns, saying that hand winding is not a viable 

technology option, especially for a slot fill increase of less than 5 percent. NEMA 

believes that the engineering analysis should not be based on stator slot fill levels which 

require hand winding, which are generally slot fills above 78 percent for 2-pole motor 

and 82 percent for 4-, 6-, and 8-pole motors. (NEMA, No. 54 at p. 60)

DOE acknowledges that the industry is moving towards increased automation. 

However, hand winding is currently practiced by manufacturers, making it a viable 

option for DOE to consider as part of its engineering analysis. Considering the four 

screening criteria for this technology option, DOE did not screen out the possibility of 

changing gauges of copper wire in the stator as a means of improving efficiency. Motor 

design engineers adjust this option by using different wire gauges when manufacturing an

electric motor to achieve desired performance and efficiency targets. Because this design 

technique is in commercial use today, DOE considers this technology option both 

technologically feasible and practicable to manufacture, install, and service. DOE is not 

aware of any adverse impacts on consumer utility, reliability, health, or safety associated 

with changing the wire gauges in the stator to obtain increased efficiency. Should the 

technology option prove to not be economical on a scale necessary to supply the entire 

industry, then this technology option would be likely not be selected for in the analysis, 

either in the LCC or MIA.
130

DOE seeks comment generally on the process of increasing the cross-section of 

copper in the stator, and in particular on the costs and reliability of the hand winding 

process.

2. Technology Options Screened Out of the Analysis

DOE developed an initial list of design options from the technologies identified in 

the technology assessment. DOE reviewed the list to determine if the design options are 

practicable to manufacture, install, and service; would adversely affect equipment utility 

or equipment availability; or would have adverse impacts on health and safety. In the 

engineering analysis, DOE did not consider any of those options that failed to satisfy one 

or more of the screening criterion. The design options screened out are summarized in 

Table IV.8. 

Table IV.8 Design Options Screened Out of the Analysis

Design Option Excluded Eliminating Screening Criterion

Plastic Bonded Iron Powder (PBIP) Technological Feasibility

Amorphous Steels Technological Feasibility

NEMA agreed with DOE in that plastic bonded iron powder has not been proven 

to be a technologically feasible method of construction of stator and rotor cores in 

induction motors. (NEMA, No. 54 at p. 64) NEMA also agreed that amorphous metal 

laminations are not a type of material that lends itself to use in electric motors in the 

foreseeable future. However, NEMA expressed concern that this technology was only 

screened out on the basis of technological feasibility because it had not been used in a 

prototype. (NEMA, No. 54 at p. 63) 
131

Baldor and NPCC also agreed with DOE’s decision to exclude PBIP and 

amorphous steels from the engineering analysis. (Baldor, Public Meeting Transcript, No. 

60 at p. 108; Advocates, No. 56 at p. 3)

DOE is continuing to screen out both of these technology options from further 

consideration in the engineering analysis. Additionally, DOE understands the concerns 

expressed by NEMA regarding technological feasibility, but DOE maintains that if a 

working prototype exists, which implies that the motor has performance characteristics 

consistent with other motors using a different technology, then that technology would be 

deemed technologically feasible. However, that fact would not necessarily mean that a 

technology option would pass all three of the remaining screening criteria.

Chapter 4 of this preliminary TSD discusses each of these screened out design 

options in more detail, as well as the design options that DOE considered in the electric 

motor engineering analysis.

C.

The engineering analysis develops cost-efficiency relationships for the equipment 

that are the subject of a rulemaking by estimating manufacturer costs of achieving 

increased efficiency levels. DOE uses manufacturing costs to determine retail prices for 

use in the LCC analysis and MIA. In general, the engineering analysis estimates the 

efficiency improvement potential of individual design options or combinations of design 

Engineering Analysis
132

options that pass the four criteria in the screening analysis. The engineering analysis also 

determines the maximum technologically feasible energy efficiency level.

When DOE proposes to adopt a new or amended standard for a type or class of 

covered product, it must determine the maximum improvement in energy efficiency or 

maximum reduction in energy use that is technologically feasible for such product. (42 

U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the 

maximum technologically feasible (“max-tech”) improvements in energy efficiency for 

electric motors, using the design parameters for the most efficient products available on 

the market or in working prototypes. (See chapter 5 of the NOPR TSD.) The max-tech 

levels that DOE determined for this rulemaking are described in IV.C.3 of this proposed 

rule.

In general, DOE can use three methodologies to generate the manufacturing costs 

needed for the engineering analysis. These methods are: 

1) the design-option approach – reporting the incremental costs of adding design 

options to a baseline model;

2) the efficiency-level approach – reporting relative costs of achieving 

improvements in energy efficiency; and

3) the reverse engineering or cost assessment approach – involving a "bottoms 

up" manufacturing cost assessment based on a detailed bill of materials 

derived from electric motor teardowns.
133

1. Engineering Analysis Methodology

DOE’s analysis for the electric motor rulemaking is based on a combination of the 

efficiency-level approach and the reverse engineering approach. Primarily, DOE elected 

to derive its production costs by tearing down electric motors and recording detailed 

information regarding individual components and designs. DOE used the costs derived 

from the engineering teardowns and the corresponding nameplate nominal efficiency of 

the torn down motors to report the relative costs of achieving improvements in energy 

efficiency. DOE derived material prices from current, publicly available data as well as 

input from subject matter experts and manufacturers. For most representative units 

analyzed, DOE was not able to test and teardown a max-tech unit because such units are 

generally cost-prohibitive and are not readily available. Therefore, DOE supplemented 

the results of its test and teardown analysis with software modeling.

When developing its engineering analysis for electric motors, DOE divided 

covered equipment into equipment class groups. As discussed, there are four electric 

motor equipment class groups: NEMA Design A and B motors (ECG 1), NEMA Design 

C motors (ECG 2), fire pump electric motors (ECG 3), and brake motors (ECG 4). The 

motors within these ECGs are further divided into equipment classes based on poleconfiguration, enclosure type, and horsepower rating. For DOE’s rulemaking, there are 

580 equipment classes.
134

2. Representative Units

Due to the high number of equipment classes for electric motors, DOE selected 

and analyzed only a few representative units from each ECG and based its overall 

analysis for all equipment classes within that ECG on those representative units. During 

the NOPR analysis, DOE selected three units to represent ECG 1 and two units to 

represent ECG 2. DOE based the analysis of ECG 3 on the representative units for ECG 1 

because of the low shipment volume and run time of fire pump electric motors. DOE also 

based the analysis of ECG 4 on the analysis of ECG 1 because the vast majority of brake 

motors are NEMA Design B motors. When selecting representative units for each ECG, 

DOE considered NEMA design type, horsepower rating, pole-configuration, and 

enclosure.
135

a. Electric Motor Design Type

For ECG 1, which includes all NEMA Design A and B motors that are not fire 

pump or brake motors, DOE only selected NEMA Design B motors as representative 

units to analyze in the preliminary analysis engineering analysis. DOE chose NEMA 

Design B motors because NEMA Design B motors have slightly more stringent 

performance requirements, namely their locked-rotor current has a maximum allowable 

level for a given rating. Consequently, NEMA Design B motors are slightly more 

restricted in terms of their maximum efficiency levels. Therefore, by analyzing a NEMA 

Design B motor, DOE could ensure technological feasibility for all designs covered in 

ECG 1. Additionally, NEMA Design B units have much higher shipment volumes than 

NEMA Design A motors because most motor driven equipment is designed (and UL 

listed) to run with NEMA Design B motors. 

NEMA agreed with DOE’s decision to base any amended or new standards for 

ECG 1 motors on NEMA Design B motor types because consumers generally prefer 

NEMA Design B motors due to the fact that locked-rotor current is constrained to 

established industry standards in these motors, making it easier to select suitable motorstarting devices. NEMA pointed out that, on the other hand, the use of a NEMA Design 

A motor may require the purchaser of the motor to expend a significant amount of time 

and expense in selecting suitable motor-starting devices to operate the motor in an 

appropriate and safe manner. NEMA elaborated that it is important to base the analysis 

on NEMA Design B motors in order to minimize any disruption to consumers based on 

their preference for NEMA Design B. (NEMA, No. 54 at p. 64) DOE appreciates 
136

NEMA’s feedback. For its NOPR engineering analysis, DOE has continued to select 

NEMA Design B motors as its representative units in ECG 1.

As mentioned for ECG 2, DOE selected two representative units to analyze. 

Because NEMA Design C is the only NEMA design type covered by this ECG, DOE 

only selected NEMA Design C motors as its representative units.

For ECG 3, which consists of fire pump electric motors, DOE based its 

engineering analysis on the NEMA Design B units analyzed for ECG 1 in the preliminary 

analysis. As noted, in order to be in compliance with section 9.5 of National Fire 

Protection Association (NFPA) "Standard for the Installation of Stationary Pumps for 

Fire Protection” Standard 20-2010, which is a requirement for a motor to meet DOE’s 

current definition of a fire pump electric motor, the motor must comply with NEMA 

Design B (or IEC Design N) requirements.

51 Although DOE understands that fire pump 

electric motors have additional performance requirements, DOE believed that analysis of 

the ECG 1 motors would serve as a sufficient approximation for the cost-efficiency 

relationship for fire pump electric motors. The design differences between a NEMA 

Design B motor (or IEC-equivalent) and fire pump electric motor are small and unlikely 

to greatly affect incremental cost behavior. 

 51 With the exception of having a thermal shutoff switch, which could prevent a fire pump motor from 

performing its duty in hot conditions, NFPA 20 also excludes several motor types not considered in this 

rulemaking from the NEMA Design B requirement. They are direct current, high-voltage (over 600 V), 

large-horsepower (over 500 hp), single-phase, universal-type, and wound-rotor motors,
137

NEMA disagreed with DOE’s assertion that fire pump electric motors are required 

to meet NEMA Design B standards, and commented that, as defined in 10 CFR 431.12, 

fire pump electric motors are not limited to NEMA Design B performance standards. 

NEMA requested that DOE clarify DOE’s statement in the preliminary analysis that 

currently, efficiency standards have only been established for fire pump electric motors 

that are NEMA Design B. (NEMA, No. 54 at p. 25) NEMA also commented that the 

additional performance requirements for fire pump electric motors (e.g., the ability to 

withstand stall conditions for longer periods of time) mean they are usually designed with 

lower locked-rotor current limits. Therefore, NEMA stated that fire pump electric motors 

may have a maximum efficiency potential slightly lower than typical, general purpose 

NEMA Design B motors. (NEMA, No. 54 at pp. 24-25, 40, 64, 70; NEMA, Public 

Meeting Transcript, No. 60 at pp. 135, 136) NEMA added that they support DOE’s 

decision to analyze fire pump motors in a separate equipment class group because of the

short run time of fire pump electric motors. (NEMA, No. 54 at p. 71)

Regarding DOE’s fire pump electric motor definition, as detailed in the final 

electric motors test procedure, DOE intends its fire pump electric motor definition to 

cover both NEMA Design B motors and IEC-equivalents that meet the requirements of 

section 9.5 of NFPA 20. See 77 FR 26617-18. As stated in the final electric motors test 

procedure, DOE agrees with stakeholders that IEC-equivalent motors should be included 

within the scope of the definition of ‘‘fire pump electric motor,’’ although NFPA 20 does 

not explicitly recognize the use of IEC motors with fire pumps. 77 FR 26617. DOE 

realizes that section 9.5 of NFPA 20 specifically requires that fire pump motors shall be 
138

marked as complying with NEMA Design B. The fire pump electric motor definition that 

DOE created focuses on ensuring that compliance with the energy efficiency

requirements are applied in a consistent manner. DOE believes that there are IEC motors 

that can be used in fire pump applications that meet both NEMA Design B and IEC 

Design N criteria, as well as NEMA MG1 service factors. DOE’s definition encompasses

both NEMA Design B motors and IEC-equivalents. To the extent that there is any 

ambiguity as to how DOE would apply this definition, in DOE’s view, any Design B or 

IEC-equivalent motor that otherwise satisfies the relevant NFPA requirements would 

meet the fire pump electric motor definition in 10 CFR 431.12. To the extent that there is 

confusion regarding this view, DOE invites comments on this issue, along with any data

demonstrating whether any IEC-equivalent motors are listed for fire pump service either 

under the NFPA 20 or another relevant industry standard. 

Regarding NEMA’s other fire pump electric motor comment, DOE agrees that 

some fire pump electric motors may not be required to meet the NEMA Design B 

performance requirements (or IEC-equivalent comments). However, those motors that 

are not required to meet the NEMA Design B performance requirements are directcurrent motors, motors with high voltages (i.e., greater than 600 V), motors with high 

horsepower ratings (i.e., greater than 500 horsepower), single-phase motors, universaltype motors, or wound-rotor motors. Any motor with such attributes would not meet the 

nine motor characteristics that define the scope of electric motors covered in this 

rulemaking. Additionally, any fire pump electric motor that is not rated for continuous 

duty is not, and would not be, covered by the scope of today’s rulemaking. Therefore, 
139

DOE clarifies that any fire pump electric motor currently subject to, or potentially subject 

to, energy conservation standards as a result of this rulemaking, would have to meet the 

NEMA Design B (or IEC-equivalent) performance requirements. As indicated above, 

DOE seeks comment on whether its current regulatory definition requires further 

clarification.

Additionally, DOE understands NEMA’s comments regarding the potential 

limitations of fire pump electric motors. However, DOE believes that its approximation, 

by using the NEMA Design B electric motors from ECG 1 is sufficient, at this time. In 

DOE’s preliminary analysis, DOE found that all efficiency levels analyzed for fire pump 

electric motors resulted in negative life-cycle cost savings for consumers and a negative 

net present values for the Nation. This was the result of extremely low operating hours 

and therefore, limited energy cost savings potential. DOE notes that there are minimal 

shipments and no efficiency levels are likely to be deemed economically justifiable.

Additionally, DOE understands that fire pump motors are similar in both 

performance and architecture to NEMA Design B motors, the chief difference being the 

absence of thermal cutoff capability that would render a fire pump motor unable to 

perform its function in a hot environment. For compliance purposes, however, the 

distinction is less important. DOE welcomes comment on the similarity between fire 

pump and NEMA Design B motors.
140

Equipment class group 4, consisting of brake motors, is also based on ECG 1 

because DOE is only aware of brake motors being built to NEMA Design B 

specifications. Furthermore, DOE understands that there is no fundamental difference in 

design between brake and non-brake electric motors, other than the presence of the brake. 

Therefore, the same design options could be used on both sets of electric motors and both 

motor types are likely to exhibit similar cost versus efficiency relationships. 

For the final rule, DOE may consider combining ECGs 1 and 4 again, as was done 

for the preliminary analysis, but such a decision depends, in part, on the outcome of its 

concurrent electric motors test procedure rulemaking. Currently, DOE believes that its 

proposed approach to testing brake motors will mitigate the impact of the brake 

component’s contributions to motor losses such that the demonstrated efficiency would 

be the same as if the motor had been tested with the brake completely removed 

(essentially making it no different from the motors covered by ECG 1). (See 78 FR 

38467) With this approach, a separate ECG would not be necessary.
141

b. Horsepower Rating

Horsepower rating is an important equipment class setting criterion. When DOE 

selected its preliminary analysis representative units, DOE chose those horsepower 

ratings that constitute a high volume of shipments in the market and provide a wide range 

upon which DOE could reasonably base a scaling methodology. For NEMA Design B 

motors, for example, DOE chose 5-, 30-, and 75-horsepower-rated electric motors to 

analyze as representative units. DOE selected the 5-horsepower rating because these 

motors have the highest shipment volume of all motors. DOE selected the 30-horsepower 

rating as an intermediary between the small and large frame number series electric 

motors. Finally, DOE selected a 75-horsepower unit because there is minimal variation in 

efficiency for motors with horsepower ratings above 75-horsepower. Based on this fact,

DOE determined it was unnecessary to analyze a higher horsepower motor. Additionally, 

as horsepower levels increase, shipments typically decrease. Therefore, DOE believed 

there would be minimal gains to its analysis had it examined a higher horsepower 

representative unit. 

During the public meeting, Baldor commented that the representative units should 

have been selected based on energy consumption and not shipment numbers. Baldor 

indicated that using this approach, the 10-horspower motor would have been designated 

as a representative unit rather than the 5-horsepower motors. (Baldor, Public Meeting 

Transcript, No. 58 at p. 132, 133) NEMA reiterated Baldor’s stance in its submitted 

comments, saying that the 5-horsepower motor would not appear to be the only choice 

for the representative unit. (NEMA, No. 54 at p. 65) NEMA and Baldor also commented 
142

that there are motors built in frame series larger than the standard 75-horsepower frame 

series and DOE should select a motor built in the largest NEMA MG 1 frame series as a 

representative unit. (NEMA, No. 54 at p. 65; Baldor, Public Meeting Transcript, No. 60 

at p. 133) NEMA added that efficiency ratings start to level off once horsepower ratings 

exceed 150-horsepower, not above 75-horsepower. Therefore, they argued that selecting 

a horsepower rating above 150-horsepower would have been a better indicator if the 

perceived increase in efficiency calculated for lower horsepower ratings would be 

achievable by larger horsepower ranges. (NEMA, No. 54 at pp. 27, 65) Baldor reiterated 

this comment in the preliminary analysis public meeting. (Baldor, Public Meeting 

Transcript, No. 60 at pp. 133-134)

While DOE agrees with NEMA that the 5-horsepower electric motor was not the 

only choice for the representative unit, it selected the 5-horsepower motor for multiple 

reasons. The 5-horsepower unit had the highest percentage of shipments for all covered 

electric motors, which ensured that there would be multiple efficiency levels from 

multiple manufacturers available for comparison during the teardown analysis. In 

addition, because DOE later employed scaling, it attempted to find a frame series and Ddimension52

 52 “D” dimension is the length from the centerline of the shaft to the mounting feet of the motor, and 

impacts how large the motor’s laminations can be, impacting the achievable efficiency of the motor. “D” 

dimensions are designated in NEMA MG 1-2011 Section 4.2.1, Table 4-2.

that could serve as a strong basis from which to scale to a relatively small set 

of unanalyzed frame series. The standard NEMA MG 1−2011 frame series for the 5-

horsepower enclosed motor was a midpoint between the standard frame series for 1 

horsepower and 10-horsepower motors, which was the group of ratings covered by the 5-
143

horsepower representative unit. A larger representative unit would have meant a larger 

range of frame series on which to apply the scaling methodology.

As to DOE’s selection of the 75-horsepower representative unit as a maximum, 

DOE understands that the 75-horsepower motor is not built in the largest NEMA MG

1−2011 frame series covered, but maintains that its selection is appropriate for this 

analysis. As stated previously, efficiency changes slowly when approaching the highest 

horsepower ratings, and choosing a higher horsepower rating would not have provided 

any appreciable improvement over the data DOE already developed for its analysis. DOE 

has found minimal variation in efficiency for motors above 75-horsepower. Because the 

change in efficiency diminishes with increasing horsepower, one may achieve a similar 

level of analytical accuracy with fewer data points at higher horsepower. Stated inversely, 

one needs more data points to accurately characterize a curve where it has a greater rate 

of change, such as lower horsepower. Finally, DOE notes that its scaling methodology 

mirrors the scaling methodology used in NEMA’s MG 1-2011 tables of efficiencies, 

including the rate of change in efficiency with horsepower.

DOE also notes that section 13 of NEMA MG 1-2011 does not standardize frame 

series for NEMA Design B motors at the highest horsepower levels covered in today’s 

proposal. Therefore, motors with the highest capacity have variability in their frame 

series. This added flexibility would give manufacturers more options to improve the 

efficiency of their largest motors covered by this rulemaking. Although altering the frame 

size of a motor may be costly, DOE believes that its selection of a 75-hp representative 
144

unit for higher horsepower motors is appropriate for scaling higher horsepower efficiency 

levels and the efficiency levels examined are technologically feasible for the largest 

capacity motors.

For NEMA Design C electric motors, DOE again selected the 5-horsepower rating 

because of its prevalence. In addition, DOE selected a 50-horsepower rating as an 

incrementally higher representative unit. DOE only selected two horsepower ratings for 

these electric motors because of their low shipment volumes. For more information on 

how DOE selected these horsepower ratings see chapter 5 of the TSD.

In submitted comments, NEMA expressed confusion over DOE’s selection of the 

50-horsepower representative unit for the NEMA Design C equipment class group. 

NEMA stated that the NEMA T-frame size for such a rating is 326T, which is three 

NEMA T-frame number series below the largest frame number series of 440. NEMA 

requested that DOE clarify why it limited its NEMA Design C representative unit to such 

a low value in its engineering analysis. (NEMA, No. 54 at p. 66) Finally, NEMA 

commented that the 2011 shipment data that DOE used to select its representative units 

was not broken down by NEMA design type. NEMA believed that using such data to 

select representative units for ECGs 1 and 2 was not appropriate and requested 

clarification. (NEMA, No. 54 at p. 66) 

As with ECG 1, DOE selected representative units that fell in the middle of the 

range of ratings covered in this rulemaking and not necessarily the largest frame size 
145

covered in the rulemaking. Furthermore, as discussed earlier, NEMA Design C motors 

are produced in a smaller range of horsepower ratings than NEMA Design B motors (1 to 

200 rather than 1 to 500). With this smaller horsepower range, a correspondingly smaller 

range of representative units is needed. Therefore, DOE selected a slightly lower rating as 

its maximum for ECG 2. As for the shipments data used to select the 5-hp representative 

unit, DOE acknowledges that it did not separate the data by design type, and has revised 

the text for the NOPR’s TSD to add clarity. However, DOE still maintains that the 

prevalence of 5-hp units make it an appropriate selection as a representative unit.

c. Pole-Configuration

Pole-configuration is another important equipment class setting criterion that 

DOE had to consider when selecting its representative units. For the preliminary analysis, 

DOE selected 4-pole motors for all of its representative units. DOE chose 4-pole motors 

because they represent the highest shipment volume of motors compared to other pole 

configurations. DOE chose not to alternate between pole configurations for its 

representative units because it wanted to keep as many design characteristics constant as 

possible. By doing so, it would allow DOE to more accurately identify how design 

changes affect efficiency across horsepower ratings. Additionally, DOE believed that the 

horsepower rating-versus-efficiency relationship is the most important (rather than poleconfiguration and enclosure type-versus-efficiency) because there are significantly more 

horsepower ratings to consider. 
146

NEMA noted that efficiency gains based on a 4-pole configuration do not confirm 

that those same gains are achievable in other pole configurations, and there is no 

foundation for scaling across different pole configurations. NEMA added that it is 

necessary to know how designs change with respect to pole-configuration, and analyzing 

samples of one pole configuration limits the ability to make decisions based on other 

pole-configurations. NEMA commented that designs significantly vary across poleconfigurations, especially regarding torque characteristics. (NEMA, No. 54 at pp. 26, 66-

67) NEMA also stated that the purpose of the engineering analysis is not necessarily to 

determine the “reasons for efficiency improvements,” but to determine if efficiency can 

be improved in accordance with meeting the requirements of being technologically 

feasible and economically justified per 42 U.S.C. 6295(o)(A) and (B). (NEMA, No. 54 at 

p. 26) Baldor also commented on scaling across pole configurations, saying that the rotor 

diameter grows as the pole number increases, which may cause higher losses in 2-pole 

motors compared to other pole configurations covered in this rulemaking. (Baldor, Public 

Meeting Transcript, No. 60 at pp. 130, 131)

As mentioned earlier, DOE is assessing energy conservation standards for 580 

equipment classes. Analyzing each of the classes individually is not feasible, which 

requires DOE to select representative units on which to base its analysis. DOE 

understands that different pole-configurations have different design constraints. 

Originally, DOE selected only 4-pole motors to analyze because they were the most 

common, allowing DOE to most accurately characterize motor behavior at the pole 

configuration consuming the majority of motor energy. Additionally, by holding pole-
147

configuration constant across its representative units, DOE would be able to develop a 

baseline from which to scale. By maintaining this baseline and holding all other variables 

constant, DOE is able to modify the horsepower of the various representative units and 

isolate which efficiency effects are due to size.

As discussed in section IV.C.8, DOE has used the simpler of two scaling 

approaches presented in the preliminary analysis because both methods had similar 

results. This simpler approach does not require DOE to develop a relationship for 4-pole 

motors from which to scale. Furthermore, DOE notes that the scaling approach it selected 

mirrors the scaling laid out in NEMA’s MG 1-2011 tables, in which at least a subset of 

the motors industry has already presented a possible relationship between efficiency and 

pole count. DOE has continued to analyze 4-pole electric motors because they are the 

most common and DOE believes that all of the efficiency levels it has developed are 

technologically feasible.

d. Enclosure Type

The final equipment class setting criterion that DOE considered when selecting its 

representative units was enclosure type. For the preliminary analysis, DOE elected to 

analyze electric motors with enclosed designs rather than open designs for all of its 

representative units. DOE selected enclosed motors because, as with pole-configurations, 

these motors have higher shipments than open motors. Again, DOE did not alternate 

between the two design possibilities for its representative units because it sought to keep 
148

design characteristics as constant as possible in an attempt to more accurately identify the 

reasons for efficiency improvements.

NEMA commented that DOE’s analysis did not consider the significance of 

enclosure type as it relates to efficiency, and that the NEMA MG 1 frame designations 

for open frame motors are often in a smaller frame series than an enclosed-frame motor 

of the same horsepower rating. NEMA and Baldor commented that there is generally a 

lower efficiency level designated for open-frame motors, and that there is no direct 

scaling relationship between the efficiency standards for open motors relative to enclosed 

frame motors in the scope of this rulemaking. (NEMA, No. 54 at p. 68; Baldor, Public 

Meeting Transcript, No. 60 at p. 131) Baldor recommended that DOE analyze motors of 

different enclosures in order to understand the difference between achievable efficiency 

levels in open and enclosed electric motors. (Baldor, Public Meeting Transcript, No. 60 at 

pp. 131-132) NEMA commented that the engineering analysis should be supported by the 

testing and analysis of both open and enclosed frame motors. (NEMA, No. 54 at p. 68) 

Finally, NEMA commented that by not selecting representative units with different 

enclosure types, DOE fails to meet the statutory requirement that any prescribed amended 

or new efficiency standards are in fact technically feasible, practical to manufacture, and 

have no adverse impacts on product utility or product availability. (NEMA, No. 54 at pp. 

68-69)

DOE acknowledges the comments from interested parties regarding enclosure 

type and its selection of representative units. The final equipment class setting criterion 
149

that DOE had to consider when selecting its representative units was enclosure type. For 

the preliminary analysis, DOE analyzed only electric motors with totally enclosed, fancooled (TEFC) designs rather than open designs for all of its representative units. DOE 

selected TEFC motors because, as with pole configurations, DOE wanted as many design 

characteristics to remain constant as possible. DOE believed that such an approach would 

allow it to more accurately pinpoint the factors that affect efficiency. While DOE only 

analyzed one enclosure type, it notes that its scaling follows NEMA’s efficiency tables

(Table 12-11 and Table 12-12), which already map how efficiency changes with

enclosure type. Finally, TEFC electric motors represented more than three times the 

shipment volume of open motors. DOE chose ELs that correspond to the tables of 

standards published in NEMA’s MG 1-2011 and to efficiency bands derived from those 

tables, preserving the relationship between NEMA’s standards for open and enclosed 

motors.

In the preliminary analysis, DOE stated that, given the same frame size, open 

motors are more efficient than enclosed motors. NEMA commented that DOE should not 

compare open and enclosed motors in the same frame size because NEMA MG 1 

specifies larger frame sizes and a higher service factor for enclosed motors of a given 

rating than it does for open motors. NEMA added that TEFC motors have a fan which 

adds to the friction and windage losses, and even with this fan the TEFC motors can have 

higher efficiencies than open frame motors of the same horsepower and pole 

configuration. (NEMA, No. 54 at p. 41) DOE appreciates the clarification and has altered 

its discussion in chapter 3 of the TSD. 
150

3. Efficiency Levels Analyzed

After selecting its representative units for each electric motor equipment class 

group, DOE examined the impacts on the cost of improving the efficiency of each of the 

representative units to evaluate the impact and assess the viability of potential energy 

conservation standards. As described in the technology assessment and screening 

analysis, there are numerous design options available for improving efficiency and each 

incremental improvement increases the electric motor efficiency along a continuum. The 

engineering analysis develops cost estimates for several efficiency levels (ELs)53 along 

that continuum.

ELs are often based on: (1) efficiencies available in the market; (2) voluntary 

specifications or mandatory standards that cause manufacturers to develop equipment at 

particular efficiency levels; and (3) the max-tech level.

Currently, there are two energy conservation standard levels that apply to various 

types of electric motors. In ECG 1, some motors currently must meet efficiency standards 

that correspond to NEMA MG 1−2011 Table 12-11 (i.e., EPACT 1992 levels54

 53 For the purposes of the NOPR analysis, the term “efficiency level” (EL) is equivalent to that of 

Candidate Standard Level (CSL) in the preliminary analysis. 

), others 

must meet efficiency standards that correspond to NEMA MG 1−2011 Table 12-12 (i.e., 

NEMA Premium levels), and some are not currently required to meet any energy 

conservation standard levels. Because DOE cannot establish energy conservation 

54 EPACT 1992 only established efficiency standards for motors up to and including 200 hp. Eventually, 

NEMA MG 1-2011 added a table, 20-A, which functioned as an extension of Table 12-11. So, although 

EPACT 1992 is a slight misnomer, DOE is using it to refer to those ELs that were based on Table 12-11.
151

standards that are less efficient than current standards (i.e., the “anti-backsliding” 

provision at 42 U.S.C. 6295(o)(1) as applied via 42 U.S.C. 6316(a)) but ECG 1 includes 

both currently regulated and unregulated electric motors, DOE’s analysis assumed the 

respective EPACT 1992 or NEMA Premium standard as the baseline for ELs 1 and 2. For 

ECG 1, DOE established an EL that corresponded to each of these levels, with EL 0 as 

the baseline (i.e., the lowest efficiency level available for unregulated motors and EPACT 

1992 or NEMA Premium, as applicable, for currently regulated motors), EL 1 as 

equivalent to EPACT 1992 levels (or NEMA Premium, as applicable, for currently 

regulated motors), and EL 2 as equivalent to NEMA Premium levels. Additionally, DOE 

analyzed two ELs above EL 2. One of these levels was the max-tech level, denoted as EL 

4 and one was an incremental level that approximated a best-in-market efficiency level 

(EL 3). For all equipment classes within ECG 1, EL 3 was a one “band” increase in 

NEMA nominal efficiency relative to NEMA Premium and EL 4 was a two “band” 

increase.55

 55 Because motor efficiency varies from unit to unit, even within a specific model, NEMA has established a 

list of standardized efficiency values that manufacturers use when labeling their motors. Each incremental 

step, or “band,” constitutes a 10 percent change in motor losses. NEMA MG 1-2011 Table 12-10 contains 

the list of NEMA nominal efficiencies.

 For ECG 3 and 4, DOE used the same ELs with one exception for ECG 3. 

Because fire pump electric motors are required to meet EPACT 1992 efficiency levels 

and those are the only motors in that equipment class group, EPACT 1992 levels were 

used as the baseline efficiency level, which means that fire pump electric motors have 

one fewer EL than ECGs 1 and 4 for purposes of DOE’s analysis. Following the 

preliminary analysis, DOE adjusted one max-tech Design B representative unit level (5 

hp) after receiving additional data. This allowed this unit to be based more on physical 
152

models for the NOPR analysis, thereby reducing exposure to modeling errors. Table IV.9

and Table IV.10 show the ELs for ECGs 1, 3, and 4. 

Table IV.9 Efficiency Levels for Equipment Class Groups 1 and 4

Representative 

Unit

EL 0

(Baseline)

EL 1

(EPACT 1992)

EL 2

(NEMA 

Premium)

EL 3

(Best-inMarket*)

EL 4

(Max-Tech)

5 hp 

(ECG 1 and 4) 82.5% 87.5% 89.5% 90.2% 91.0%

30 hp 

(ECG 1 and 4) 89.5% 92.4% 93.6% 94.1% 94.5%

75 hp 

(ECG 1 only**) 93.0% 94.1% 95.4% 95.8% 96.2%

* Best-in-market represents the best or near best efficiency level at which current manufacturers are 

producing electric motors. Although these efficiencies represent the best-in-market values found for the 

representative units, but when efficiency was scaled to the remaining equipment classes, the scaled 

efficiency was sometimes above and sometimes below the best-in-market value for a particular rating. 

**ECG 4 does not have a 75-horsepower representative unit because DOE was unable to find brake motors 

built with such a high horsepower rating. The maximum horsepower rating for ECG 4 is 30-horsepower.

Table IV.10 Efficiency Levels for Equipment Class Group 3

Representative Unit EL 0

(EPACT 1992)

EL 1

(NEMA 

Premium)

EL 2

(Best-inMarket*)

EL 3

(Max-Tech)

5 hp 87.5% 89.5% 90.2% 91.0%

30 hp 92.4% 93.6% 94.1% 94.5%

75 hp 94.1% 95.4% 95.8% 96.2%

For ECG 2, DOE took a similar approach in developing its ELs as it did for ECG 

1, but with two primary differences. First, when DOE examined catalog data, it found 

that no NEMA Design C electric motors had efficiencies below EPACT 1992 levels, 

which is the current standard for all covered NEMA Design C electric motors. For DOE’s 

representative units, it also found no catalog listings above the required EPACT 1992 

levels. Additionally, when DOE’s subject matter expert modeled NEMA Design C 

motors, the model would only generate designs at NEMA Premium levels and one 
153

incremental level above that while maintaining proper performance standards. Therefore, 

ECG 2 only contains three ELs: EPACT 1992 (EL 0), NEMA Premium (EL 1), and a 

max-tech level (EL 2).

These ELs differed slightly from the CSLs presented in the preliminary analysis 

for ECG2. In the preliminary analysis, a CSL for the 50 hp unit existed between two 

industry standard levels in order to provide greater resolution in selection of a standard 

(NEMA MG-1 Table 12-11 and Table 12-12). For the NOPR analysis, this level was 

removed so that the ELs analyzed would align with Tables 12-11 and 12-12. For the 5 hp 

rep unit, DOE also removed one preliminary analysis CSL, which was intended to 

represent the “best in market” level in the preliminary analysis. After further market 

research, DOE found that few Design C motors are offered above the baseline, and those 

that were mainly met the NEMA premium level, without going higher in efficiency. It 

determined that for the NOPR analysis, the previously designated “max in market” level 

was not applicable. The ELs analyzed for ECG2 in the NOPR are shown in Table IV.11.

Table IV.11 Efficiency Levels for Equipment Class Group 2

Representative Unit EL 1

(EPACT 1992)

EL 2

(NEMA Premium)

EL 3

(Max-Tech)

5 hp 87.5% 89.5% 91.0%

50 hp 92.4% 93.6% 94.5%

In response to its preliminary analysis, DOE received multiple comments 

regarding CSLs. NEMA and Baldor expressed confusion over the fact that the CSLs for 

ECG 2 do not align with the CSLs from ECG 1, and requested that DOE line up CSLs 

across different ECGs in an effort to avoid confusion when discussing the CSLs. 
154

(NEMA, No. 54 at p. 73; Baldor, Public Meeting Transcript, No. 60 at pp. 171, 172) 

DOE understands NEMA’s concerns regarding the nomenclature of its ELs, however, it 

has maintained its approach for the NOPR analysis. DOE examines each ECG 

independently, and because different motor types have different baselines, the EL 

numbers do not always align.

NEMA also asked if the baseline CSL developed for ECG 1, which was 

developed based on an analysis of vertical, hollow-shaft motors, included losses related 

to testing those motors with thrust bearings. NEMA inquired because, at the time of its 

comment, DOE had not yet published the test procedure NOPR, indicating how these 

motor types might be tested. (NEMA, No. 54 at pp. 71-72, 77) 

DOE clarifies that the vertical hollow-shaft motors purchased and used to 

determine the baseline efficiency level for ECG 1 contained bearings capable of 

horizontal operation. Therefore, DOE tested these motors in a horizontal configuration 

without any modifications to the bearings. Additionally, when tested, solid-shafts were 

welded inside the hollow-shaft to permit the motor to be attached to a dynamometer for 

testing. These modifications are in line with the proposals for vertical hollow shaft 

motors as described in DOE’s electric motors test procedure NOPR. 78 FR 38456 (June 

26, 2013).

During the preliminary analysis public meeting, NEMA noted that the CSL 5 

software-modeled efficiency was 96.4 percent and should have been assigned a NEMA 

nominal efficiency level of 96.2 percent rather than 96.5. (NEMA, No. 54 at p. 80) 
155

NEMA and Baldor added that CSL 5 should not be included in any engineering analysis 

because of the infeasibility of cast-copper rotors, and that CSL 4 is the proper max-tech 

level when CSL 5 is eliminated from consideration. (NEMA, No. 54 at p. 73; Baldor, 

Public Meeting Transcript, No. 60 at p. 171) The Efficiency Advocates also expressed 

concern about some of the CSLs analyzed by DOE and questioned the viability of CSL 3. 

The Efficiency Advocates noted that some of the CSL 3 designs were at the very limits of 

critical motor performance parameters, such as locked-rotor torque and current. The 

Efficiency Advocates added that DOE has not tested motors that perform at the levels 

that would be required by CSL 3, 4, and 5. Without having done so, DOE cannot verify 

the predicted performance of its representative units. (NPCC, No. 56 at pp. 4, 5)

As discussed, DOE has removed EL 5 from consideration in the NOPR analysis,

but it has not eliminated the use of copper-die cast rotor technology (see I.A.1). With 

regards to the comments from the Efficiency Advocates, DOE notes that EL 3 for ECG 1 

is based on teardown data from commercially available motors, as it was for the 

preliminary analysis. Additionally, for the NOPR, DOE has tested a unit at EL 4 for one 

of its representative units. Furthermore, DOE has found many instances of electric motors 

being sold and marketed one or two NEMA bands of efficiency above NEMA Premium, 

which suggests that manufacturers have extended technological performance where they 

perceived market demand for higher efficiencies. In other words, DOE has seen no 

evidence suggesting that the absence of products on the market at any given EL implies 

that such products could not be developed, were there sufficient demand. DOE contends 

that all of the ELs analyzed in its engineering analysis are viable because equipment is 
156

currently commercially available at such levels56 and, to the extent possible, has been 

included in DOE’s analysis. DOE welcomes comment on the limits of technology, 

especially as it varies by equipment class.

Additionally, NEMA and Baldor commented on the design options analyzed for 

the various CSLs. NEMA and Baldor stressed that not using a common design option 

across all CSLs may result in a reduction of available product. (NEMA, No. 54 at pp. 3, 

27, 73; Baldor, Public Meeting Transcript, No. 60 at pp. 169-171, 176-178) NEMA 

indicated that it is a standard practice of manufacturers to minimize the number of types 

of electrical steel used at a manufacturing facility and that typically a single type of 

electrical steel may be used for all electric motors manufactured at the facility. NEMA 

added that DOE should account for this situation when performing engineering analyses 

such that a common type of electrical steel is used for the different NEMA design types 

covered by a common CSL. (NEMA, No. 54 at p. 62) NEMA added that although 

NEMA Design C motors constitute less than 1 percent of total motor shipments, the 

electrical steel and die-cast rotor material used for manufacturing NEMA Design C 

electric motors is taken from the same inventory as used for NEMA Design B electric 

motors. Therefore, they contended that DOE should select the same material types for 

NEMA Design C motors as it does for NEMA Design B motors. (NEMA, No. 54 at p. 

65, 74) Finally, NEMA stated that it did not understand why DOE used different steels 

and rotor conductors for CSLs 4 and 5 in some of the ECG 1 representative units but not 

 56 DOE understands that this is not true for every equipment classes covered by this rulemaking, but has not 

seen evidence to suggest that the absence of equipment in any particular classes is not due to lack of market 

demand instead of technological limitations.
157

in others. (NEMA, No. 54 at pp. 3, 72; Baldor, Public Meeting Transcript, No. 60 at p. 

120)

As noted earlier, DOE has restructured its ELs for the NOPR analysis. One 

consequence of this restructuring is that DOE no longer mixes rotor casting technologies 

for a given EL. However, DOE does not limit the number of electrical steels used at a 

given EL to one. DOE understands that manufacturers try to limit the number of 

electrical steels at a given manufacturing facility, but most manufacturers have more than 

one manufacturing facility. Therefore, manufacturers could produce motors with multiple 

grades of electrical steel. Additionally, DOE believes that this approach is in line with 

current industry practice. For its analysis, DOE obtained multiple units for teardowns 

from the same manufacturer. After a steel analysis was conducted on its teardowns, DOE 

found that one manufacturer utilized multiple grades of steel, both across ELs within a 

representative unit and across representative units within an EL. Finally, DOE believes 

that the restructuring of the ELs should also address concerns over the technology 

differences between preliminary analysis ELs 4 and 5 because in the NOPR analysis 

there is no EL 5. DOE has updated chapter 5 of the TSD to include as pertinent design 

data.

During the preliminary analysis public meeting, ACEEE commented that new 

energy conservation levels would have to be raised by at least two NEMA bands because 

an increase of only one NEMA band is not statistically significant. (ACEEE, Public 

Meeting Transcript, No. 60 at p. 168) DOE disagrees with this assessment. Although the 
158

unit-to-unit efficiency of a specific electric motor design may vary by multiple NEMA 

bands of efficiency, an increase in the required efficiency level by one band would be 

significant. If efficiency standards are raised by one NEMA band, there is no evidence to 

suggest that manufacturing practices would change such that the distribution of unit-tounit efficiencies for a given motor design would change. Therefore, if the required 

efficiency standard were changed by one band of efficiency, one would assume that the 

entire population of motors of a given design would shift by one band of efficiency as 

manufacturers begin to produce motors around a higher mean value.

Finally, NEMA commented that another important factor for defining CSLs is the 

ability for CSLs to provide efficiency values to be used in the scaling process and that it 

is important that the relative difference between the efficiency values for CSLs is selected 

such that the relativity is maintained across all of the representative units if it is to be 

applied by scaling to all electric motors included in an ECG. In other words, NEMA 

argues that CSLs must be chosen carefully to correspond with similar technologies and 

materials across the range of scaling (i.e., the entire equipment class) and that they should 

not be chosen to merely to align with NEMA’s own tables and efficiency bands. (NEMA, 

No. 54 at p. 73) Responding to this concern, for each EL above the established NEMA 

Premium levels, DOE has incremented efficiency by one nominal band for all equipment 

classes. This equates to, roughly, a 10 percent decrease in motor losses for all equipment

classes for each jump in EL. 
159

4. Test and Teardowns

Whenever possible, DOE attempted to base its engineering analysis on actual 

electric motors being produced and sold in the market today. First, DOE identified 

electric motors in manufacturer catalogs that represented a range of efficiencies 

corresponding to the ELs discussed in the previous sections. Next, DOE had the electric 

motors shipped to a certified testing laboratory where each was tested in accordance with 

IEEE Standard 112 (Test Method B) to verify its nameplate-rated efficiency. After 

testing, DOE derived production and material costs by having a professional motor 

laboratory57 disassemble and inventory the purchased electric motors. For ECG 1, DOE 

obtained tear-down results for all of the 5-horsepower ELs and all of the 30- and 75-

horsepower ELs except the max-tech levels. For ECG 2, DOE obtained tear-down results

only for the baseline EL, which corresponds to EPACT 1992 efficiency levels. 

These tear-downs provided DOE with the necessary data to construct a bill of 

materials (BOM), which, along with a standardized cost model and markup structure, 

DOE could use to estimate a manufacturer selling price (MSP). DOE paired the MSP 

derived from the tear-down with the corresponding nameplate nominal efficiency to 

report the relative costs of achieving improvements in energy efficiency. DOE’s 

estimates of material prices came from a combination of current, publicly available data, 

manufacturer feedback, and conversations with its subject matter experts. DOE 

supplemented the findings from its tests and tear-downs through: (1) a review of data 

 57 The Center for Electromechanics at the University of Texas at Austin, a 140,000 sq. ft. lab with 40 years 

of operating experience, performed the teardowns, which were overseen by Dr. Angelo Gattozzi, an electric 

motor expert with previous industry experience. DOE also used Advanced Energy Corporation of North 

Carolina to perform some of the teardowns.
160

collected from manufacturers about prices, efficiencies, and other features of various 

models of electric motors, and (2) interviews with manufacturers about the techniques 

and associated costs used to improve efficiency. 

As discussed earlier, DOE’s engineering analysis documents the design changes 

and associated costs when improving electric motor efficiency from the baseline level up 

to a max-tech level. This includes considering improved electrical steel for the stator and 

rotor, interchanging aluminum and copper rotor bar material, increasing stack length, and 

any other applicable design options remaining after the screening analysis. As each of 

these design options are added, the manufacturer’s cost increases and the electric motor’s 

efficiency improves. DOE received multiple comments regarding its test and tear-down 

analysis.

NEMA commented that the cost for manufacturing an electric motor can increase 

as the efficiency level is increased even when the material and technology is not changed. 

It added that an increase in core length, without any change in the material used, will 

result in a higher cost not only due to the increase in the amount of steel, but also due to 

the increase in the amount of wire for the stator winding and aluminum for the rotor core. 

(NEMA, No. 54 at p. 74) Notwithstanding, DOE believes that it has accurately captured 

such changes. When each electric motor was torn down, components such as electrical 

steel and copper wiring were weighed. Therefore, any increase in stack length would 

result in increased costs associated with the increased amount of electrical steel and 

copper wiring.
161

NEMA also commented that the best known value of efficiency for a tested and 

torn down motor is the tested efficiency and the accuracy of this value improves as 

sample size increases. Because DOE only used a sample size of one, NEMA 

recommended that DOE should increase its sample size to something more statistically 

significant. (NEMA, No. 54 at p. 75) NEMA also referred to the small electric motors 

rulemaking and said that a sufficient sample size for testing was proven to be necessary. 

(NEMA, No. 54 a p. 27) NEMA also commented that Appendix A to Subpart U 

designates the appropriate sample size to support the conclusion that the name-plated 

efficiency of a motor is correctly stated. (NEMA, No. 54 at p. 79) NEMA and Baldor 

added that Appendix A to Subpart U requires the determination of a standard deviation 

from the sample, and it is not possible to determine a standard deviation when testing a 

sample of one motor, which was the sample size of DOE’s motor testing. (NEMA, No. 

54 at p. 79; Baldor, Public Meeting Transcript, No. 60 at p. 154)

DOE agrees that an increased sample size would improve the value of efficiency 

used in its analysis, but only if DOE were using an average full-load efficiency value, as 

it did for the small electric motors rulemaking engineering analysis, which did not have 

the benefit of NEMA-developed nominal efficiency values. For today’s analysis, DOE 

did not use the tested efficiency value and believes that to do so would be erroneous 

precisely because it only tested and tore down one unit for a given representative unit and 

EL. Rather than using an average efficiency of a sample of multiple units that is likely to 

change with each additional motor tested, DOE elected to use the nameplate NEMA 
162

nominal efficiency given. DOE understands that this value, short of testing data, is the 

most accurate value to use to describe a statistically valid population of motors of a given 

design; that is, in part, why manufacturers use NEMA nominal efficiencies on their 

motors’ nameplates. 

Furthermore, when DOE conducts its tear-downs, the bill of materials generated 

is most representative of the tested value of efficiency, not necessarily the NEMA 

nominal value. However, DOE believes that the variance from unit-to-unit, in terms of 

materials, is likely to be insignificant because manufacturers have an incentive to produce 

equipment with consistent performance (i.e., characteristics other than efficiency) as 

possible. Changes in the tested efficiency are likely to occur because of variations in 

production that motor manufacturers have less control over (e.g., the quality of the 

electrical steel). DOE does not believe that the amount of material (in particular,

electrical steel, copper wiring, and die-cast material) from unit-to-unit for a given design 

is likely to change significantly, if at all, because manufacturers have much greater 

control of those production variables. Therefore, additional tests and tear-downs are 

unlikely to change the MSP estimated for a given motor design and DOE believes that its 

sample size of one is appropriate.

In the preliminary engineering analysis, DOE replaced a tear-down result with a 

software model for CSL 2 of its 30-horsepower representative unit because it believed 

that it had inadvertently tested and torn down a motor with an efficiency equivalent to 

CSL 3. DOE noted that it removed the tear-down because there was conflicting efficiency 
163

information on the website, in the catalog, and on the physical nameplate. Subsequently, 

NEMA and Baldor commented that the 30-horsepower, CSL 2 motor should not have 

been replaced with a software-modeled motor, stating that the test result was statistically 

viable. (NEMA, No. 54 at pp. 76-79; Baldor, Public Meeting Transcript, No. 60 at pp. 

150-155) NEMA and Baldor also asserted that DOE had placed emphasis on the use of 

purchased motors in its analysis only when the tested value of efficiency was less than or 

not significantly greater than the marked value of NEMA efficiency. (NEMA, No. 54 at 

p. 80; Baldor, Public Meeting Transcript, No. 60 at pp. 156, 157)

DOE understands that the test result may have been viable for either of the 

efficiency ratings that the manufacturer had assigned. Given the uncertainty, however, 

DOE elected to replace the motor. DOE did not discard the unit simply because it tested 

significantly above its nameplate efficiency. Rather, the motor was listed with different 

values of efficiency depending upon the source and when torn down, the resulting MSP 

was higher than the MSP for the next CSL. These facts suggested that the calculated 

results were erroneous because it is unlikely (based on available data) that it would be 

cheaper to build a more efficient motor than a less efficient one of comparable 

specifications. If DOE had included these data in its analysis, it would likely have 

resulted in a projection that even higher CSLs would be economically justified. The 

combination of these factors resulted in DOE eliminating that motor from the analysis. 

For its updated NOPR engineering analysis, DOE has tested and torn down a new 30-

horsepower motor to describe CSL 2. As stated previously, DOE always prefers to base 

its analysis using motors purchased in the market when possible.
164

NEMA commented that the disproportionate variation in frame weights between 

the CSLs suggests that the CSLs of some representative units were not of similar 

construction. (NEMA, No. 54 at p. 78) When selecting motors for tear-down, DOE 

selected motors with increasing efficiencies. These motors may not have used the same 

frame material. For example, the CSL 0 for the 30-horsepower representative units was 

made out of cast aluminum, but CSL 1 unit used cast iron. This material change accounts 

for the large difference in frame weight. 

During the preliminary analysis public meeting, Nidec requested clarification for 

the increase in stator copper weight for the 75-horsepower, ECG 1 representative unit 

between CSL 2 and CSL 3 since the reported slot fills were the same and the motors had 

similar stack lengths. (Nidec, Public Meeting Transcript, No. 60 at pp. 164, 165) After 

DOE’s tear-down lab determined that the torn-down motors were machine-wound a 

precise measurement of the slot fill was not taken. Although the actual measurement of 

slot fill has no bearing on the estimates of the MSP, because the actual copper weights 

were measured and not calculated, DOE did ask its lab to provide actual measurements of 

slot fill on any subsequent tear-downs and has included the data in chapter 5 of the TSD.

5. Software Modeling

In the preliminary analysis, DOE worked with technical experts to develop certain 

CSLs, in particular, the max-tech efficiency levels for each representative unit analyzed. 
165

DOE retained an electric motors subject matter expert (SME)58 with design experience 

and software, who prepared a set of designs with increasing efficiency. The SME also 

checked his designs against tear-down data and calibrated his software using the relevant 

test results. As new designs were created, DOE’s SME ensured that the critical 

performance characteristics that define a NEMA design letter, such as locked-rotor 

torque, breakdown torque, pull-up torque and locked-rotor currents were maintained. For 

a given representative unit, DOE ensured that the modeled electric motors met the same 

set of torque and locked-rotor current requirements as the purchased electric motors. This 

was done to ensure that the utility of the baseline unit was maintained as efficiency 

improved. Additionally, DOE limited its modeled stack length increases based on 

teardown data and maximum “C” dimensions found in manufacturer’s catalogs.59

In response to the preliminary analysis, Baldor and NEMA requested clarification 

on how DOE compared its software modeled results to the electric motors that it had 

tested and torn down. (NEMA, No. 54 at p. 74; Baldor, Public Meeting Transcript, No. 

60 at p.148) NEMA requested that more details regarding that comparison and the name 

of the software program used to be included in an updated technical support document. 

(NEMA, No. 54 at p. 12) Per the request of NEMA and Baldor, DOE has provided 

comparisons of software estimates and tested efficiencies in appendix 5C of the TSD. 

 58 Dr. Howard Jordan, Ph.D, an electric motor design expert with over 40 years of industry experience, 

served as DOE’s subject matter expert.

59 The “C” dimension of an electric motor is the length of the electric motor from the end of the shaft to the 

end of the opposite side’s fan cover guard. Essentially, the “C” dimension is the overall length of an 

electric motor including its shaft extension.
166

Additionally, the software program that DOE used for its analysis is a proprietary

software program called VICA60.

NEMA expressed concern over efficiency standards based on the software 

platform DOE used and stated that DOE should build working prototypes of its software 

modeled motors to prove the designs work. (NEMA, No. 54 at pp. 24-25 and 74-75) 

Baldor reiterated this point in verbal comments and suggested that this was particularly 

important for CSLs with copper rotor designs given their concerns with copper rotor 

motors. (NEMA, No. 54 at pp. 76-77; Baldor Public Meeting Transcript, No. 60 at pp. 

160, 161) During the preliminary analysis, DOE approached motor laboratories in an 

attempt to prototype its software models. DOE was unable to identify a laboratory that 

could prototype its software modeled motors in a manner that would exactly replicate the 

designs produced (i.e., they could not die-cast copper). Consequently, at this time, DOE 

has not built a prototype of its software models. However, DOE was able to procure a 5-

horsepower NEMA Design B die-cast copper rotor motor with an efficiency two NEMA 

bands above the NEMA Premium level. Therefore, DOE elected to use this design to 

represent the max-tech EL for the 5-horsepower representative unit in equipment class 

group 1, rather than the software-modeled design used in the preliminary analysis. DOE’s 

SME used information gained from testing and tearing down this motor to help 

corroborate the software modeling.

 60 VICA stands for “Veinott Interactive Computer Aid”
167

In the preliminary analysis, DOE indicated that its software modeling expert made 

changes to his software designs based on data collected during the motor teardowns. 

NEMA commented on this and asked why DOE’s software modeling expert made 

changes to some of his designs based on teardown data. (NEMA, No. 54 at p. 75) DOE 

clarifies that the software program was updated using additional teardown data (e.g., 

more accurate dimensions and material types) to maintain as many consistencies in 

design as possible. For example, DOE’s software modeling expert used lamination 

diameters measured during the teardowns as limits for the software models. 

In submitted comments, NEMA noted that the NEMA nominal efficiency for the 

software-modeled motors was derived by selecting the value that was lower than the 

calculated efficiency. NEMA questioned this approach and added that assigning a value 

of NEMA nominal efficiency based on a calculated value of efficiency requires more 

knowledge than merely selecting the closest NEMA nominal value that is lower than the 

calculated value. (NEMA, No. 54 at p. 76) DOE notes that it selected the closest NEMA 

nominal efficiency that is less than or equal to the predicted efficiency of the software for 

multiple reasons. First, DOE wanted to maintain the use of nominal efficiency values to 

remain consistent with past electric motor efficiency standards. Second, DOE chose a 

value below its software estimate because this method would provide a more 

conservative approach. DOE believes its approach was appropriate given the various 

concerns raised with copper rotor motor technologies.
168

During the preliminary analysis public meeting, Regal-Beloit commented that 

calibration of the software-modeled motors is extremely important. Regal-Beloit added 

that the calibration of select models is very important due to the amount of interpolation 

that DOE is basing on these models. (Regal-Beloit, Public Meeting Transcript, No. 60 at 

p. 159-160) Alluding to copper rotor motors, NEMA commented on DOE’s software 

modeling, claiming that verifying the accuracy of a software program with respect to 

performance obtained from testing purchased motors does not verify the accuracy of the 

software program when it is used for a technology which has not been verified by tests. 

(NEMA, No. 54 at p. 76; Baldor, Public Meeting Transcript, No. 60 at p. 160, 161) DOE 

appreciates these comments and, as stated, has conducted calibration of its software 

program using data obtained from motor teardowns. DOE has provided comparisons of 

software estimates and tested efficiencies for both aluminum and copper rotor motors in 

appendix 5C of the TSD. 

NEMA commented that the preliminary TSD did not show that the software 

platform DOE used had been substantiated as being sufficiently accurate for motors 

incorporating existing and new technologies. (NEMA, No. 54 at p. 12) NEMA asserted 

that it is necessary to substantiate the software platform used for modeling as an alternate 

efficiency determination method (AEDM) such that the calculated efficiencies can be 

verified as accurate for the types of technologies included in a motor design. NEMA 

urged that DOE substantiate the software platform used by its SME as an AEDM. 

(NEMA, No. 54 at p. 76) Baldor added that DOE expects manufacturers to prototype five 

motors to certify a program, but DOE has not designed and built any of the motors 
169

designed in its own program. (Baldor, Public Meeting Transcript, No. 60 at p. 162) Nidec 

commented during the public meeting, asking if the software modeling suite DOE used 

has gone through the same scrutiny that manufacturers are subject to when they must 

submit their 25 samples to correlate their estimated computer data with actual testing 

data. (Nidec, Public Meeting Transcript, No. 60 at p. 147)

DOE understands the comments received regarding its software program, but 

maintains that substantiation of an AEDM is a concept intended for certifying compliance 

with energy efficiency standards. It is a tool that manufacturers use to help ensure that the 

equipment they manufacture comply with a Federal standard (which is the 

manufacturers’ duty). It is not a tool for assessing whether a particular energy efficiency 

level under consideration by DOE satisfies the EPCA criteria. Accordingly, the use of the 

AEDM in the manner suggested by industry would not be relevant for the purposes of 

this engineering analysis, which is geared toward DOE’s standards rulemaking.

NEMA also commented that to properly determine the impact of increased 

efficiency on motor utility, DOE must recognize the consequences of how motor 

performance, including parameters such as acceleration, safe stall time, overspeed, 

service factor, thermal performance, and in-rush current will be affected by more 

stringent energy conservation standards. NEMA also specifically referred to performance 

characteristics found in NEMA MG 1 sections 12.44, 12.45, 12.48, 12.49, 12.53, 12.54, 

and 12.56. (NEMA, No. 54 at pp. 5, 77) NEMA added that the narrow margin between 

the NEMA MG 1-2011 limits for locked-rotor current and the calculated locked-rotor
170

current for some of the software-modeled designs in the preliminary analysis suggest that 

there will be problems with these motors meeting the NEMA MG 1 limits if they were 

prototyped. (NEMA, No. 54 at p. 77) Finally, NEMA indicated that two of the DOE 

software-modeled motors in the preliminary analysis, representing the 75-horsepower 

CSLs 4 and 5 for ECG 1, had torque ratings twice that of a U.S. Army 75-horsepower 

electric motor software model, and suggested that the software models used in DOE’s 

analysis are not accurate in modeling copper rotor motor performance. (NEMA, No. 54 at 

p. 77)

DOE has carefully considered NEMA’s comments in its updated NOPR analysis. 

As noted, DOE has eliminated designs from its preliminary analysis because of concerns 

regarding the feasibility of those efficiency levels. Regarding the additional performance 

parameters, DOE agrees that these characteristics must be maintained when improving an 

electric motor’s efficiency. However, the performance parameters DOE believed to 

present the largest risk of rendering a motor noncompliant with NEMA MG 1-2011 

standards were those related to NEMA design letter, which were adhered to in DOE’s 

modeling efforts. Based on comparisons of motor teardowns and software estimates, 

DOE has no reason at this time to believe that its modeled designs would violate the 

additional performance parameters mentioned by NEMA. 

DOE believes that its subject matter expert, who has been designing electric 

motors for several decades, is well qualified to understand the design tradeoffs that must 

be considered. Although the SME’s primary task was to design a more efficient motor 
171

using various technologies, it was of critical importance that the designs be feasible. Even 

though DOE was unable to prototype its modeled designs, DOE has conducted 

comparisons of software estimates and tested efficiencies for both aluminum and copper 

rotor motors and believes this corroborates the modeled designs. Based on this work and 

its total analysis, which included input from its SME, DOE believes it developed a 

sufficiently robust set of technically feasible efficiency levels for its engineering analysis. 

NEMA asked how DOE intended to take into consideration motor utility as motor 

size increases. (NEMA, No. 54 at pp. 23, 24) During the preliminary analysis public 

meeting, Baldor asked if the higher CSLs would fit into existing frame sizes, or if those

motors would have to be redesigned to allow for the increased stack length. Baldor added 

that if the frame size increases, the motor may no longer fit current applications, which 

would cause additional burden for end-users or original equipment manufacturers. 

(Baldor, Public Meeting Transcript, No. 60 at p. 164, 245) Baldor added that IEC frame 

motors are more constrained in terms of size and space than NEMA frame motors, and it 

is more difficult to increase the efficiency on IEC frame motors without changing frame 

size designations, which would lead to space constraint issues. (Baldor and ABB, Public 

Meeting Transcript, No. 60 at pp. 245, 246) Flolo Corporation also commented on motor 

length during the public meeting, insisting that it is important that DOE recognize the 

difference in “C” dimension that any new energy conservation standard would mandate, 

as increasing the “C” dimension will make it difficult for a motor to fit into its originally 

intended machine. (Flolo, Public Meeting Transcript, No. 60 at pp. 243, 244) The 

Efficiency Advocates also commented on motor length, indicating that DOE should be 
172

aware of absolute motor length limits when considering increased stack length, and that 

these changes could greatly increase the installed cost of many of the higher CSLs, 

impacting field and original equipment manufacturer (OEM) installation. (Advocates, 

No. 56 at p. 4)

In the preliminary TSD, DOE stipulated that any increase in stack length would fit 

into the existing frame designation for that particular motor rating. DOE noted that the 

frame designation does not limit frame length, but rather frame diameter. DOE also 

understands that manufacturers have fixed-length frames that they use when 

manufacturing motors. In addition to generating per unit costs associated with 

redesigning motors with new frames at all ELs above the NEMA Premium levels (see 

IV.C.6), DOE sought to maintain motor length by limiting how much it would modify 

stack dimensions to improve efficiency. First, the software models created by DOE used 

lamination diameters observed during teardowns, which ensured that the softwaremodeled designs would fit into existing frame designations. However, for some designs 

DOE increased the number of laminations (i.e., length of the stack of laminations, or 

stack length) beyond the stack lengths observed during the motor teardowns in order to 

achieve the desired efficiency gains.

DOE limited the amount by which it would increase the stack length of its 

software-modeled electric motors in order to preserve the motor’s utility. The maximum 

stack lengths used in the software-modeled ELs were determined by first analyzing the 

stack lengths and “C” dimensions of torn-down electric motors. Then, DOE analyzed the 
173

“C” dimensions of various electric motors in the marketplace conforming to the same 

design constraints as the representative units (same horsepower rating, NEMA frame 

size, enclosure type, and pole configuration). For each representative unit, DOE found the 

largest “C” dimension currently available on the marketplace and estimated a maximum 

stack length based on the stack length to “C” dimension ratios of motors it tore down. 

The resulting product was the value that DOE chose to use as the maximum stack length 

considered in its software modeled designs, although DOE notes that it did not always 

model a motor with that maximum stack length. In most instances, the SME was able to 

achieve the desired improvement in efficiency with a stack length shorter than DOE’s 

estimated maximum. Table IV.12 shows the estimated maximum stack length, the 

maximum stack length found during tear-downs, and the maximum stack length modeled 

for a given representative unit. DOE welcomes additional comments on software 

modeling in general, and on specific data that could be used to calibrate its software 

designs. 

Table IV.12 Maximum Stack Length Data

Representative Unit Estimated Maximum 

Stack Length

Maximum Stack 

Length of a Torn 

Down Motor

Maximum Stack 

Length Modeled

30 Horsepower

Design B 8.87 in. 8.02 in. (EL 2) 7.00 in.

75 Horsepower

Design B 13.06 in. 11.33 in. (EL 3) 12.00 in.

5 Horsepower

Design C 5.80 in. 4.75 in. (EL 0) 5.32 in.

50 Horsepower

Design C 9.55 in. 8.67 in. (EL 0) 9.55 in.
174

6. Cost Model

When developing manufacturer selling prices (MSPs) for the motor designs 

obtained from DOE’s tear-downs and software models, DOE used a consistent approach 

to generate a more accurate approximation of the costs necessary to improve electric 

motor efficiency. DOE derived the manufacturer’s selling price for each design in the 

engineering analysis by considering the full range of production and non-production 

costs. The full production cost is a combination of direct labor, direct materials, and 

overhead. The overhead contributing to full production cost includes indirect labor, 

indirect material, maintenance, depreciation, taxes, and insurance related to company 

assets. Non-production cost includes the cost of selling, general and administrative items 

(market research, advertising, sales representatives, logistics), research and development 

(R&D), interest payments, warranty and risk provisions, shipping, and profit factor. 

Because profit factor is included in the non-production cost, the sum of production and 

non-production costs is an estimate of the MSP. DOE utilized various markups to arrive 

at the total cost for each component of the electric motor and these markups are detailed 

in chapter 5 of the TSD.

a. Copper Pricing

DOE conducted the engineering analysis using material prices based on 

manufacturer feedback, industry experts, and publicly available data. In the preliminary 

analysis, most material prices were based on 2011 prices, with the exception of cast 

copper and copper wire pricing, which were based on a five-year (2007-2011) average 

price. 
175

DOE received comments regarding its copper price development. NPCC 

supported DOE’s decision to use a five-year price average for copper materials and 

suggested that this method should be used whenever a commodity price shows a pattern 

of irregular spikes or valleys. (Advocates, No. 56 at p. 4) Conversely, the Industrial 

Energy Consumers of America (IECA) stated that material costs for high efficiency 

motors are very volatile and cannot be reliably projected from a simple five-year average, 

as DOE did with copper prices during the preliminary analysis. IECA added that as a 

result of using a five-year average, the high efficiency motor material costs may be 

highly underestimated in DOE’s engineering analysis, and IECA suggested that a range 

of material costs rather than averages could better inform a range of life-cycle costs and 

payback periods for each CSL. (IECA, No. 52 at p. 3) 

Based on these comments, DOE has slightly modified its approach. First, DOE 

added updated data for 2012 pricing. Second, rather than a five-year average, DOE 

changed to a three-year average price for copper materials. DOE made this modification 

based on feedback received during manufacturer interviews. By reducing to a three-year 

average, DOE eliminated data from 2008 and 2009, which manufacturers believed were 

unrepresentative data points due to the recession. Data from those two years had the 

effect of depressing the five-year average calculated.
176

b. Labor Rate and Non-Production Markup

In the preliminary analysis, DOE looked at the percentage of electric motors 

imported into the U.S. and the percentage of electric motors built domestically and based 

the balance of foreign and domestic labor rates on these percentages. During the 

preliminary analysis public meeting, Nidec commented that the labor rate DOE used in 

its analysis seems high if that number is weighted towards offshore labor. Nidec also 

agreed with DOE’s smaller markup on the lower-horsepower motors, but commented that 

the overall markups DOE used seem to be high. (Nidec, Public Meeting Transcript, No. 

60 at p. 184) WEG added to these comments, indicating that they believed DOE was 

adequately addressing the cost structure variations among the different motor 

manufacturers. Additionally, WEG believed that basing a labor rate on both foreign and 

domestic labor rates increases accuracy of the analysis, but warned that DOE should be 

careful not encourage production moving outside the United States. (WEG, Public 

Meeting Transcript, No. 60 at pp. 184-186)

At this time, DOE has elected to keep the same labor rates and markups as were 

used in the preliminary analysis. DOE is basing this decision on additional feedback 

received during interviews with manufacturers and the absence of any alternative labor 

rate or markups to apply.

Finally, DOE is aware of potential cost increases caused by increased slot fill, 

including the transition to hand-wound stators in motors requiring higher slot fills. In the 

preliminary analysis, DOE assigned a higher labor hour to any tear-down motor which it 
177

determined to be hand-wound. NEMA commented that DOE did not assign a handwound labor-hour assumption to any of the tear-down motors, and requested clarification 

about whether there were instances of hand winding in these motors. (NEMA, No. 54 at 

p. 23) DOE found that none of the tear-down motors were hand-wound, and therefore no 

hand-winding labor-hour amounts were assigned. This has been clarified in the NOPR 

analysis. Additionally, DOE has assumed that all of its max-tech software models require 

hand-winding, which is reflected in its increased labor time assumptions for those motors.

For additional details please see chapter 5 of the TSD.

In response to DOE’s request for comment on the possibility of higher labor costs 

for lower-volume electric motors, NEMA indicated that plants with few manufacturing 

setup changes, because they may focus on standard motor designs with no special motors, 

have the ability to produce more motors per employee, and that this is the case with many 

offshore companies that build designs for import to the U.S. (NEMA, No. 54 at pp. 27, 

28) For other companies that cater to OEMs that require special designs and small lot 

production, setup changes eat into the capacity of these plants, particularly in the 56/140T 

through 250T frame series where there is high volume. A plant where the lot (i.e., batch) 

size per order is smaller has less impact from setup.

DOE acknowledges that lower-volume products will often realize higher per unit 

costs, and believes this reality is common to most or all manufacturing processes in 

general. Because DOE’s analysis focuses on the differential impacts on cost due to 

standards, and because DOE has no evidence to suggest a significant market shift to 
178

lower production volume in a post-standards scenario, DOE expects that the relative mix 

of high- and low- volume production would be preserved. Indeed, because DOE is 

proposing to expand scope of coverage and bring many previously-excluded motor types 

to NEMA Premium levels, DOE sees the possibility that standardization may increase 

and average production volume may, in fact, rise.61 DOE welcomes additional comment 

on how standards may cause average production run volume to rise or fall, and how labor 

costs may vary as a result.

c. Catalog Prices

NEMA also requested that DOE publish the purchase price for its torn down 

motors, so that they could be compared to the MSPs DOE derived from its motor teardowns. (NEMA, No. 54 at p. 27; Baldor, Public Meeting Transcript, No. 60 at pp. 181, 

182) At this time, DOE is electing not to include the purchase price for its torn down 

motors. DOE believes that such information is not relevant and could lead to erroneous 

conclusions. Some of the purchased motors were more expensive to purchase based on 

certain features that do not affect efficiency, which could skew the price curves 

incorrectly and indicate incorrect trends. For these reasons, in the engineering analysis, 

DOE develops its own cost model so that a consistent cost structure can be applied to 

similar equipment. The details of this model are available in appendix 5A. Because DOE 

purchased electric motors that were built by different manufacturers and sold by different 

distributors, who all have different costs structures, DOE does not believe that such a 

comparison is a meaningful evaluation.

 61 Labor costs may rise starkly at max-tech levels, where hand-winding is employed in order to maximize 

slot fill. DOE’s engineering analysis reflects this fact.
179

d. Product Development Cost

In response to the preliminary analysis, NEMA commented that DOE presumes 

that the incremental cost between motors of different designs and different technologies 

is based solely on the difference in material costs and markups. NEMA also commented 

that there is a higher cost of manufacturing a die-cast copper rotor compared to an 

aluminum die-cast rotor motor that is not captured in material costs. (NEMA, No. 54 at p. 

12, 74) During the preliminary analysis public meeting, ACEEE commented that the 

Motor Coalition has concerns about CSL 3 for ECG 1, stating that DOE’s analysis may 

not have captured the full cost of an industry-transition to that efficiency level. (ACEEE, 

Public Meeting Transcript, No. 60 at p. 20)

DOE has made some additions to its cost model for the NOPR analysis based on 

NEMA’s comments. However, DOE clarifies that its cost model for the preliminary 

analysis did include an incremental markup used to account for higher production costs 

associated with manufacturing copper die-cast rotors. Although DOE used this 

incremental markup in the preliminary analysis, after conducting manufacturer interviews 

for the NOPR analysis, it believed that additional costs were warranted for the examined 

ELs that exceeded the NEMA Premium level. NEMA commented that the manufacturer 

production costs (MPCs) and subsequent LCCs must take into account the large 

additional conversion costs, since manufacturers would likely attempt to recover the costs 

of meeting a higher efficiency standard. (NEMA, No. 54 at p. 4) Therefore, DOE 
180

developed a per-unit adder62 for the MPCs intended to capture one-time increased 

product development and capital conversion costs that would likely result if an efficiency 

level above NEMA Premium were established. 

DOE’s per-unit adder reflects the additional cost passed along to the consumer by 

manufacturers attempting to recover the costs incurred from having to redevelop their 

equipment lines as a result of higher energy conservation standards. The conversion costs 

incurred by manufacturers include capital investment (e.g., new tooling and machinery), 

equipment development (e.g., reengineering each motor design offered), plus testing and 

compliance certification costs.

The conversion cost adder was only applied to ELs above NEMA Premium based 

on manufacturer feedback. Most manufacturers now offer NEMA Premium motors for a 

significant portion of their equipment lines as a result of EISA 2007, which required 

manufacturers to meet this level. Many manufacturers also offer certain ratings with 

efficiency levels higher than NEMA Premium. However, DOE is not aware of any 

manufacturer with a complete line of motors above NEMA Premium. Consequently, 

DOE believes that energy conservation standards above NEMA Premium would result in 

manufacturers incurring significant conversion costs to bring offerings of electric motors 

up to the higher standard.

 62 The “per-unit adder” discussed in this section refers to a fixed adder for each motor that varies based on 

horsepower and NEMA design letter. Each representative unit has their own unique “per-unit adder” that is 

fixed for the analysis. 
181

DOE developed the various conversion costs from data collected during 

manufacturer interviews that were conducted for the Manufacturer Impact Analysis 

(MIA). For more information on the MIA, see TSD chapter 12. DOE used the 

manufacturer-supplied data to estimate industry-wide capital conversion costs and 

product conversion costs for each EL above NEMA Premium. DOE then assumed that 

manufacturers would mark up their motors to recover the total conversion costs over a 

seven year period. By dividing industry-wide conversion costs by seven years of 

expected industry-wide revenue, DOE obtained a percentage estimate of how much each 

motor would be marked up by manufacturers. The conversion costs as a percentage of 7-

year revenue that DOE derived for each NEMA band above NEMA premium are shown 

below. Details on these calculations are shown in Chapter 5 of the TSD. 

Table IV.13 Product Conversion Costs as a Percentage of 7-Year Revenue

NEMA Bands Above NEMA Premium Conversion Costs as a Percentage of 7 Year 

Revenue 

1 4.1%

2 6.5%

The percentage markup was then applied to the full production cost (direct 

material + direct labor + overhead) at the NEMA Premium levels to derive the per unit 

adder for levels above NEMA Premium (see Table IV.14).

Table IV.14 Product Conversion Costs for Efficiency Levels above NEMA 

Premium.

Representative 

Unit

Per Unit Adder for 

1 Band Above NEMA 

Premium

Per Unit Adder for 

2 Bands Above NEMA 

Premium

5 HP, Design B $11.06 $17.36

30 HP, Design B $32.89 $51.61

75 HP, Design B $66.18 $103.86

5 HP, Design C $10.68 $16.75
182

50 HP, Design C $60.59 $95.08

7. Engineering Analysis Results

The results of the engineering analysis are reported as cost versus efficiency data 

in the form of MSP (in dollars) versus nominal full-load efficiency (in percentage). These 

data form the basis for subsequent analyses in today’s NOPR. Table IV.15 through Table 

IV.19 show the results of DOE’s updated NOPR engineering analysis.

Results for Equipment Class Group 1 (NEMA Design A and B Electric Motors)

Table IV.15 Manufacturer Selling Price and Efficiency for 5-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline) 82.5 330

EL 1 (EPACT 1992) 87.5 341

EL 2 (NEMA Premium) 89.5 367

EL 3 (Best-in-Market) 90.2 402

EL 4 (Max-Tech) 91.0 670

Table IV.16 Manufacturer Selling Price and Efficiency for 30-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline) 89.5 848

EL 1 (EPACT 1992) 92.4 1,085

EL 2 (NEMA Premium) 93.6 1,156

EL 3 (Best-in-Market) 94.1 1,295

EL 4 (Max-Tech) 94.5 2,056
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Table IV.17 Manufacturer Selling Price and Efficiency for 75-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline) 93.0 1,891

EL 1 (EPACT 1992) 94.1 2,048

EL 2 (NEMA Premium) 95.4 2,327

EL 3 (Best-in-Market) 95.8 2,776

EL 4 (Max-Tech) 96.2 3,620

Results for Equipment Class Group 2 (NEMA Design C Electric Motors)

Table IV.18 Manufacturer Selling Price and Efficiency for 5-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline/EPACT 1992) 87.5 331

EL 1 (NEMA Premium) 89.5 355

EL 2 (Max-Tech) 91.0 621

Table IV.19 Manufacturer Selling Price and Efficiency for 50-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline/EPACT 1992) 93.0 1,537

EL 1 (NEMA Premium) 94.5 2,130

EL 2 (Max-Tech) 95.0 2,586

Results for Equipment Class Group 3 (Fire Pump Electric Motors)

Table IV.20 Manufacturer Selling Price and Efficiency for 5-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline/EPACT 1992) 87.5 341

EL 1 (NEMA Premium) 89.5 367

EL 2 (Best-in-Market) 90.2 402

EL 3 (Max-Tech) 91.0 670
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Table IV.21 Manufacturer Selling Price and Efficiency for 30-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline/EPACT 1992) 92.4 1,085

EL 1 (NEMA Premium) 93.6 1,156

EL 2 (Best-in-Market) 94.1 1,295

EL 3 (Max-Tech) 94.5 2,056

Table IV.22 Manufacturer Selling Price and Efficiency for 75-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline/EPACT 1992) 94.1 2,048

EL 1 (NEMA Premium) 95.4 2,327

EL 2 (Best-in-Market) 95.8 2,776

EL 3 (Max-Tech) 96.2 3,620

Results for Equipment Class Group 4 (Brake Electric Motors)

Table IV.23 Manufacturer Selling Price and Efficiency for 5-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline) 82.5 330

EL 1 (EPACT 1992) 87.5 341

EL 2 (NEMA Premium) 89.5 367

EL 3 (Best-in-Market) 90.2 402

EL 4 (Max-Tech) 91.0 670

Table IV.24 Manufacturer Selling Price and Efficiency for 30-Horsepower 

Representative Unit

Efficiency Level Efficiency (%) Manufacturer Selling Price ($)

EL 0 (Baseline) 89.5 848

EL 1 (EPACT 1992) 92.4 1,085

EL 2 (NEMA Premium) 93.6 1,156

EL 3 (Best-in-Market) 94.1 1,295

EL 4 (Max-Tech) 94.5 2,056
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8. Scaling Methodology

Once DOE has identified cost-efficiency relationships for its representative units, 

it must appropriately scale the efficiencies analyzed for its representative units to those 

equipment classes not directly analyzed. DOE recognizes that scaling motor efficiencies 

is a complicated proposition that has the potential to result in efficiency standards that are 

not evenly stringent across all equipment classes. However, between DOE’s four ECGs, 

there are 580 combinations of horsepower rating, pole configuration, and enclosure. 

Within these combinations there are a large number of standardized frame number series. 

Given the sizable number of frame number series and equipment classes, DOE cannot 

feasibly analyze all of these variants, hence, the need for scaling. Scaling across 

horsepower ratings, pole configurations, enclosures, and frame number series is a 

necessity. For the preliminary analysis, DOE considered two methods to scaling, one that 

develops a set of power law equations based on the relationships found in the EPACT 

1992 and NEMA Premium tables of efficiency in NEMA Standard Publication MG 1,

and one based on the incremental improvement of motor losses. As discussed in the 

preliminary analysis, DOE did not find a large discrepancy between the results of the two 

approaches and, therefore, used the simpler, incremental improvement of motor losses 

approach in its NOPR analysis.

As discussed in IV.C.3, some of the ELs analyzed by DOE were based on existing 

efficiency standards (i.e., EPACT 1992 and NEMA Premium). Additionally, the baseline 

EL is based on the lowest efficiency levels found for each horsepower rating, pole 

configuration, and enclosure type observed in motor catalog data. Therefore, DOE only 
186

required the use of scaling when developing the two ELs above NEMA Premium (only 

one EL above NEMA Premium for ECG 2).

For the higher ELs in ECG 1, DOE’s scaling approach relies on NEMA MG 1-

2011 Table 12-10 of nominal efficiencies and the relative improvement in motor losses of 

the representative units. As has been discussed, each incremental improvement in NEMA 

nominal efficiency (or NEMA band) corresponds to roughly a 10 percent reduction in 

motor losses. After ELs 3 and 4 were developed for each representative unit, DOE 

applied the same reduction in motor losses (or the same number of NEMA band 

improvements) to various segments of the market based on its representative units. DOE 

assigned a segment of the electric motors market, based on horsepower ratings, to each 

representative unit analyzed. DOE’s assignments of these segments of the markets were 

in part based on the standardized NEMA frame number series that NEMA MG 1-2011 

assigns to horsepower and pole combinations. In the end, EL 3 corresponded to a one 

band improvement relative to NEMA Premium and EL 4 corresponded to a two-band

improvement relative to NEMA Premium. In response to the preliminary analysis, DOE 

received multiple comments regarding scaling. 

NEMA commented that DOE states that scaling is necessary for the national 

impacts analysis, but NEMA contends that the foremost reason for the scaling is that the 

scaling is used to establish the values of any amended or new efficiency standards. 

(NEMA, No. 54 at p. 68) NEMA also expressed its belief that the scaling method used in 

the preliminary analysis does not adequately take into consideration numbers of poles, 
187

stack length, and frame enclosures and that scaling based on changes in efficiency for 

lower horsepower motor models, as interpreted by software, does not accurately reflect 

what is achievable for higher horsepower ratings. (NEMA, No. 54 at p. 5)

During the preliminary analysis public meeting, Baldor commented that because 

some energy conservation levels could not be reached without using a different 

technology option, at least 30 percent of the ratings in an equipment classes could not 

achieve energy conservation levels above CSL 2. Because of this, a scaling method based 

on any particular set of technology is not scalable across all equipment classes. Baldor 

suggested that DOE could use software modeling to check some of the motor 

configurations not directly analyzed. (Baldor, Public Meeting Transcript, No. 60 at pp. 

196, 197, 200)

Nidec commented during the public meeting that scaling has too many variables, 

and that manufacturers do not use scaling because it is not possible. (Nidec, Public 

Meeting Transcript, No. 60 at pp. 198-199) ACEEE added that there is no underlying 

fundamental physical theory associated with the efficiencies listed in NEMA MG 1-2011 

Table 12-11 or Table 12-12. (ACEEE, Public Meeting Transcript, No. 60 at pp. 198-199)

DOE appreciates the comments received regarding scaling; however, it maintains 

that scaling is a tool necessary to analyze the potential effects of energy conservation 

standards above NEMA Premium levels. As stated earlier, DOE is evaluating energy 

conservation standards for 580 equipment classes. DOE acknowledges that analyzing 
188

every one of these classes individually is not feasible, which requires DOE to choose 

representative units on which to base its analysis. DOE agrees with Baldor that the 

primary reason for scaling is to establish efficiency levels for any potential new or 

amended standards for electric motors.

However, DOE notes that its analysis neither assumes nor requires manufacturers 

to use identical technology for all motor types and horsepower ratings. In other words, 

although DOE may choose a certain set of technologies to estimate cost behavior across 

efficiency, DOE’s standards are technology-neutral and permit manufacturers design 

flexibility. DOE clarifies that the national impacts analysis is one of the primary ways in 

which DOE analyses those potential efficiency levels and determines if they would be 

economically justified. As DOE has stated, it is also important that the levels be 

technically feasible. In order to maintain technical feasibility, DOE has maintained the 

scaling approach that it developed for the preliminary analysis. DOE believes that this 

approach, which is as conservative as possible while maintaining the use of NEMA 

nominal efficiencies, accomplishes that. For each incremental EL above the NEMA 

Premium level, DOE has incremented possible efficiency levels by just one band of 

efficiency. Through the use of this conservative approach to scaling, DOE believes that it 

has helped conserve the technological feasibility of each of its ELs to the greatest extent 

practicable.
189

D.

The markups analysis develops appropriate markups in the distribution chain to 

convert the estimates of manufacturer selling price derived in the engineering analysis to 

customer prices. (“Customer” refers to purchasers of the equipment being regulated). In 

the preliminary analysis, DOE determined the distribution channels for electric motors, 

their shares of the market, and the markups associated with the main parties in the 

distribution chain, distributors and contractors. For the NOPR, DOE retained these 

distribution channels. 

Markups Analysis

DOE developed average distributor and contractor markups by examining the 

contractor cost estimates provided by RS Means Electrical Cost Data 2013.63 DOE 

calculates baseline and overall incremental markups based on the equipment markups at 

each step in the distribution chain. The incremental markup relates the change in the 

manufacturer sales price of higher efficiency models (the incremental cost increase) to 

the change in the customer price. Chapter 6 of the NOPR TSD addresses estimating 

markups.

E.

The energy use analysis provides estimates of the annual energy consumption of 

commercial and industrial electric motors at the considered efficiency levels. DOE uses 

these values in the LCC and PBP analyses and in the NIA. DOE developed energy 

consumption estimates for all equipment analyzed in the engineering analysis. 

Energy Use Analysis

 63 RS Means (2013), Electrical Cost Data, 36th Annual Edition, Kingston, MA.
190

The annual energy consumption of an electric motor that has a given nominal fullload efficiency depends on the electric motor’s sector (industry, agriculture, or 

commercial) and application (compressor, fans, pumps, material handling, fire pumps, 

and others), which in turn determine the electric motor’s annual operating hours and load.

To calculate the annual kilowatt-hours (kWh) consumed at each efficiency level 

in each equipment class, DOE used the nominal efficiencies at various loads from the 

engineering analysis, along with estimates of operating hours and electric motor load for 

electric motors in various sectors and applications.

In the preliminary analysis, DOE used statistical information on annual electric 

motor operating hours and load derived from a database of more than 15,000 individual 

motor field assessments obtained through the Washington State University and the New 

York State Energy Research and Development Authority to determine the variation in 

field energy use in the industrial sector. For the agricultural and the commercial sector, 

DOE relied on data found in the literature. 

As part of its NOPR analysis, for the industrial sector, DOE re-examined its initial 

usage profiles and recalculated motor distribution across applications, operating hours, 

and load information based on additional motor field data compiled by the Industrial 

Assessment Center at the University of Oregon, which includes over 20,000 individual 

motor records. For the agricultural sector, DOE revised its average annual operating 
191

hours assumptions based on additional data found in the literature. No changes were 

made to the commercial sector average annual operating hours. 

Chapter 7 of the NOPR TSD describes the energy use analysis.

1. Comments on Operating Hours

Several interested parties commented on the annual operating hours assumptions. 

NEMA and UL commented that fire pumps typically operate when being tested on a 

monthly basis and that the annual operating-hour assumption for fire pump electric 

motors in the industrial sector seemed high but did not provide data to support their 

comment. NEMA agreed with the fire pump electric motor annual operating-hour 

assumptions in the commercial and agricultural sectors. (NEMA, No. 54 at p. 83) (UL, 

No. 46 at p. 1) 

For the NOPR, DOE reviewed the field data for fire pump electric motors used in 

the preliminary analysis and noticed some values were associated with motors driving 

jockey pumps, which are pressure maintenance pumps used to maintain pressure in fire 

sprinkler systems. After filtering out the motors driving jockey pumps, DOE derived an 

average value of annual operating hours similar to the fire pump electric motor annual 

operating hours for the commercial and agricultural sectors. Therefore, DOE revised its 

fire pumps operating hour assumption accordingly. 
192

NEMA submitted data regarding annual operating hour assumptions in the 

industrial sector based on its expert knowledge. These assumptions were lower than those 

used in the preliminary analysis. (NEMA, No. 54 at p. 10) 

As previously mentioned, DOE revised the average operating hours associated 

with applications in the industrial sector (compressor, fans, pump, material handling, and 

others) based on additional individual motor nameplate and field data compiled by the 

Industrial Assessment Center at the University of Oregon.64 The revised average 

operating hour values are generally lower than the estimates from the preliminary 

analysis and differ from what NEMA provided. DOE could not verify the estimates 

provided by NEMA and it is not clear that these estimates represent an accurate picture of 

the entire industrial sector. In contrast, the average operating hours by motor application 

that DOE used in the NOPR were based on an analysis of annual operating hours for over 

35,000 individual motors. DOE notes that it analyzed a sensitivity case that reflects the 

NEMA estimates. 

IECA commented that the database of plant assessments is based on surveys 

conducted between 2005 and 2011 and there is no explanation of the effects of the 

recession on these surveys. (IECA, No. 52 at p. 2) DOE could not estimate the impact of 

the recession on the average operating hour values derived from the database of field 

 64 Strategic Energy Group (January, 2008), Northwest Industrial Motor Database Summary from Regional 

Technical Forum. http://rtf.nwcouncil.org/subcommittees/osumotor/Default.htm This database provides 

information on motors collected by the Industrial Assessment Center (IAC) at Oregon State University 

(OSU). The database includes more than 22,000 records, each with detailed motor application and field 

usage data.
193

assessment from the Washington State University and the New York State Energy 

Research and Development Authority, as the year of the assessment was not specified for 

all of the entries. The additional data from the Industrial Assessment Center cover a 

longer time period (1987-2007). Thus, DOE believes that its estimates of operating hours 

are not unduly affected by lower industrial activity during the recession.

2. Comments on Other Issues

In response to DOE’s energy use discussion from the preliminary analysis, 

NEMA commented that NEMA Design C motors are not typically found in pump 

applications. (NEMA, No. 54 at p. 83) For NEMA Design C motors, DOE re-examined 

its distribution by application and agrees with NEMA that NEMA Design C motors are 

not typically found in pump applications. These motors are characterized by high torque 

and generally found in compressors and other applications such as conveyors. Consistent 

with this review, DOE adjusted its analyses.

NEMA commented that the curve fit for the polynomial equations modeling the 

load versus losses relationships for NEMA Design B motors did not seem to represent the 

test data accurately. (NEMA, No. 54 at p. 81) 

For each representative unit, DOE based its energy use calculation on nominal 

values of efficiency. DOE obtained data on part load losses from test data developed in 

the engineering analysis and fitted these data to derive load versus losses relationships in 

the form of a third degree polynomial equation. The representative units showed tested 
194

efficiencies which were not equal to the nominal efficiencies and DOE adjusted the 

coefficients of the polynomial equations to match the full load losses expected at nominal 

efficiency. The adjusted equation, therefore, calculates losses for a motor with full load 

efficiency equal to the full load nominal efficiency. For the NOPR, DOE followed the 

same approach and revised the polynomial equations to reflect the NOPR engineering 

outputs.

NEMA commented that the installation of a more efficient motor in variable 

torque applications could lead to less energy savings than anticipated. Because a more 

efficient motor usually has less slip65 than a less efficient one does, this attribute can 

result in a higher operating speed and a potential overloading of the motor. NEMA 

recommended that DOE include the consequence of a more efficient motor operating at 

an increased speed in any determination of energy savings. (NEMA, No. 54 at p. 28)

DOE acknowledges that the arithmetic cubic relation between speed and power 

requirement in many variable torque applications can affect the benefits gained by using 

efficient electric motors, which have a lower slip. DOE agrees that it is possible to 

quantify this impact for one individual motor. However, DOE was not able to extend this 

analysis to the national level. DOE does not have robust data related to the overall share 

of motors that would be negatively impacted by higher speeds in order to incorporate this 

effect in the main analysis. Further, in the engineering analysis, DOE could not extend 

the synchronous speed information from the representative units to the full range of 

 65 The slip is the difference between the synchronous speed of the magnetic field (as defined by the number 

of poles), and the actual rotating speed of the motor shaft.
195

electric motor configurations. Instead, DOE developed assumptions66 and estimated the 

effects of higher operating speeds as a sensitivity analysis in the LCC spreadsheet. For 

the representative units analyzed in the LCC analysis, the LCC spreadsheet allows one to 

consider this effect as a sensitivity analysis according to a scenario described in appendix 

7-A of the NOPR TSD. 

IECA commented that estimates of regional shares of motors should be based on 

current inventories of motors rather than sector-specific indicators and that the data from 

the 2006 Manufacturer Energy Consumption Survey (MECS) is outdated. (IECA, No. 52 

at p. 2) DOE did not find any information regarding motor inventory and instead used 

indirect indicators to derive motor distribution. For the NOPR, DOE updated its regional 

shares of motors based on industrial electricity consumption by region from AEO 2013.

F.

For each representative unit analyzed in the engineering analysis, DOE conducts 

LCC and PBP analyses to evaluate the economic impacts on individual customers of 

potential energy conservation standards for electric motors. The LCC is the total 

customer expense over the life of the motor, consisting of equipment and installation 

costs plus operating costs over the lifetime of the equipment (expenses for energy use, 

maintenance and repair). DOE discounts future operating costs to the time of purchase 

Life-Cycle Cost and Payback Period Analysis

 66 DOE assumed that 60 percent of pumps, fans and compressor applications are variable torque 

applications. Of these 60 percent, DOE assumed that all fans and a majority (70 percent) of compressors 

and pumps would be negatively impacted by higher operating speeds; and that 30 percent of compressors 

and pumps would not be negatively impacted from higher operating speeds as their time of use would 

decrease as the flow increases with the speed (e.g. a pump filling a reservoir).
196

using customer discount rates. The PBP is the estimated amount of time (in years) it takes 

customers to recover the increased total installed cost (including equipment and 

installation costs) of a more efficient type of equipment through lower operating costs. 

DOE calculates the PBP by dividing the change in total installed cost (normally higher) 

due to a standard by the change in annual operating cost (normally lower) which results 

from the standard.

For any given efficiency level, DOE measures the PBP and the change in LCC 

relative to an estimate of the base-case efficiency levels. The base-case estimate reflects 

the market in the absence of new or amended energy conservation standards, including 

the market for equipment that exceeds the current energy conservation standards.

For each representative unit, DOE calculated the LCC and PBP for a distribution 

of individual electric motors across a range of operating conditions. DOE used Monte 

Carlo simulations to model the distributions of inputs. The Monte Carlo process 

statistically captures input variability and distribution without testing all possible input 

combinations. Therefore, while some atypical situations may not be captured in the 

analysis, DOE believes the analysis captures an adequate range of situations in which 

electric motors operate.

The following sections contain brief discussions of comments on the inputs and key 

assumptions of DOE’s LCC and PBP analysis and explain how DOE took these 

comments into consideration.
197

1. Equipment Costs

In the LCC and PBP analysis, the equipment costs faced by electric motor 

purchasers are derived from the MSPs estimated in the engineering analysis and the 

overall markups estimated in the markups analysis.

To forecast a price trend for the preliminary analysis, DOE derived an inflationadjusted index of the producer price index (PPI) for integral horsepower motors and 

generators manufacturing from 1969 to 2011. These data show a long-term decline from 

1985 to 2003, and then a steep increase since then. DOE also examined a forecast based 

on the “chained price index—industrial equipment” that was forecasted for AEO2012 out 

to 2040. This index is the most disaggregated category that includes electric motors. 

These data show a short-term increase from 2011 to 2015, and then a steep decrease since 

then. DOE believes that there is considerable uncertainty as to whether the recent trend 

has peaked, and would be followed by a return to the previous long-term declining trend, 

or whether the recent trend represents the beginning of a long-term rising trend due to 

global demand for electric motors and rising commodity costs for key motor components. 

Given the uncertainty, DOE chose to use constant prices (2010 levels) for both its LCC 

and PBP analysis and the NIA. For the NIA, DOE also analyzed the sensitivity of results 

to alternative electric motor price forecasts. 

DOE did not receive comments on the trend it used for electric motor prices, and 

it retained the approach used in the preliminary analysis for the NOPR.
198

2. Installation Costs 

In the preliminary analysis, the engineering analysis showed that for some 

representative units, increased efficiency led to increased stack length. However, the 

electric motor frame remained in the same NEMA frame size requirements as the 

baseline electric motor, and the motor’s “C” dimension remained fairly constant across 

efficiency levels. In addition, electric motor installation cost data from RS Means 

Electrical Cost Data 2013 showed a variation in installation costs by horsepower (for 

three-phase electric motors), but not by efficiency. Therefore, in the preliminary analysis, 

DOE assumed there is no variation in installation costs between a baseline efficiency 

electric motor and a higher efficiency electric motor.

Two interested parties commented that DOE might have to consider increased 

installation costs related to larger diameter motors in comparison to baseline motors. (CA 

IOUs, No. 57 at p. 2; NEMA, No. 54 at p. 83) NEMA added that the size of a motor may 

need to be increased to provide the necessary material to obtain higher levels of energy 

efficiency, such as CSL 3 examined for Design B electric motors. (NEMA, No. 54 at p. 

83) 

DOE’s engineering data show that the motor’s “C” dimension remained fairly 

constant across efficiency levels. For equipment class Group 1, the stack length of higher 

efficiency motors (EL 3 and above) did not show significant increases in size in 

comparison to NEMA Premium level motors (EL 2). In addition, the frame size remained 
199

the same and the “C” dimension data did not significantly vary. Therefore, for the NOPR, 

DOE retained the same approach as in the preliminary analysis and did not incorporate 

changes in installation costs for electric motors that are more efficient than baseline 

equipment.

NEMA stated that when a user replaces a baseline NEMA Design B motor with a 

higher efficiency NEMA Design A motor, the user might experience additional 

installation costs compared to replacing the motor with a baseline NEMA Design B 

motor due to, for example, potential needs for new motor controller or motor protection 

devices. (NEMA, No. 54 at p. 29) In the engineering analysis, for equipment class Group 

1, all representative units selected were NEMA Design B motors and the NEMA Design 

B requirements are maintained across all efficiency levels. Therefore, DOE did not 

account for additional installation costs related to the replacement of NEMA Design B 

motors with NEMA Design A motors.

3. Maintenance Costs

In the preliminary analysis, DOE did not find data indicating a variation in 

maintenance costs between a baseline efficiency and higher efficiency electric motor. 

According to data from Vaughen’s Price Publishing Company,67

 67 Vaughen’s (2011, 2013), Vaughen’s Motor & Pump Repair Price Guide, 2011, 2013 Edition. 

which publishes an 

industry reference guide on motor repair pricing, the price of replacing bearings, which is 

the most common maintenance practice, is the same at all efficiency levels. Therefore, 

DOE did not consider maintenance costs for electric motors. DOE did not receive 

 http://www.vaughens.com/
200

comments on this issue and retained the approach used for the preliminary analysis for 

the NOPR.

4. Repair Costs

In the preliminary analysis, DOE accounted for the differences in repair costs of a 

higher efficiency motor compared to a baseline efficiency motor and defined a repair as 

including a rewind and reconditioning. Based on data from Vaughen’s, DOE derived a 

model to estimate repair costs by horsepower, enclosure and pole, for each EL. 

The Electrical Apparatus Service Association (EASA), which represents the 

electric motor repair service sector, noted that DOE should clarify the definition of repair 

as including rewinding and reconditioning. (EASA, No. 47 at p. 1) DOE agrees with this 

suggestion and has modified its terminology in chapter 7 of the NOPR TSD.

One interested party, Flolo Corporation, noted that since the 1990's, increased 

windings protection has led to longer repair cycles and the repair frequency values used 

in the preliminary analysis were too low. (Pub. Mtg. Tr., No. 58 at p. 234)

For the preliminary analysis, DOE estimated that NEMA Design A, B and C 

electric motors were repaired on average after 32,000 hours of operation based on data 

for the industrial sector. This estimate reflected a situation where electric motors from 1 

to 20-horsepower, with an average lifetime of 5 years, are not repaired; motors from 25-

to 75-horsepower, with an average lifetime of 10 years, are repaired at half their lifetime; 
201

and motors from 100- to 500-horsepower, with an average lifetime of 15 years, are 

repaired at a third of their lifetime. In the NOPR analysis, DOE retained a similar 

approach for the industrial and commercial sectors. For the agricultural sector, DOE did 

not find sufficient data to distinguish by horsepower range and assumed that motors are 

repaired on average at half of their lifetime. With the revised NOPR mechanical lifetime 

and operating hour estimates, the repair frequency in hours increased to 48,600 hours in 

the industrial sector compared to DOE’s earlier estimate of 32,000 hours. 

5. Unit Energy Consumption

The NOPR analysis uses the same approach for determining unit energy 

consumptions (UECs) as the preliminary analysis. The UEC was determined for each 

application and sector based on estimated load points and annual operating hours. For the 

NOPR, DOE refined the average annual operating hours, average load, and shares of 

motors by application and sector. 

In the preliminary analysis, DOE assumed that one-third of repairs are done 

following industry recommended practice as defined by EASA. (EASA Standard AR100-

2010, Recommended Practice for the Repair of Rotating Electrical Apparatus) and do not 

impact the efficiency of the electric motor (i.e., no degradation of efficiency after repair). 

DOE assumed that two-thirds of repairs do not follow good practice and that a slight 

decrease in efficiency occurs when the electric motor is repaired. DOE assumed the 

efficiency decreases by 1 percent in the case of electric motors of less than 40 

horsepower, and by 0.5 percent in the case of larger electric motors. 
202

NEMA and EASA asked DOE to clarify its assumption regarding the share of 

repairs performed following industry recommended practices. (NEMA, No. 54 at p. 29) 

(EASA, No. 47 at p. 1) For the NOPR, DOE reviewed data from the U.S. Economic 

Census68 and EASA69 and estimated that the majority of motor repair shops are EASA 

members and follow industry recommended practices. DOE revised its assumption for 

the NOPR analysis and estimated that 90 percent of repairs are done following industry 

recommended practice and would not impact the efficiency of the motor (i.e. no 

degradation of efficiency after repair). 

NEMA also requested clarification on whether the LCC is based on site energy or 

full fuel cycle energy. (NEMA, No. 54 at p. 31) In the LCC, DOE considers site energy 

use only.

6. Electricity Prices and Electricity Price Trends

In the preliminary analysis, DOE derived sector-specific weighted average 

electricity prices for four different U.S. Bureau of the Census (Census) regions 

(Northeast, Midwest, South, and West) using data from the Energy Information 

Administration (EIA Form 861). For each utility in a region, DOE used the average 

industrial or commercial price, and then weighted the price by the number of customers 

in each sector for each utility. 

 68 U.S. Economic Census 1997 and 2007 data on the number of motor repair establishments (based on 

NAICS 811, 811310, and SIC 7694) 

69 Members of EASA available at: http://www.easa.com/ 
203

For each representative motor, DOE assigned electricity prices using a Monte 

Carlo approach that incorporated weightings based on the estimated share of electric 

motors in each region. The regional shares were derived based on indicators specific to 

each sector (e.g., commercial floor space from the Commercial Building Energy 

Consumption Survey for the commercial sector70) and assumed to remain constant over 

time. To estimate future trends in energy prices, DOE used projections from the EIA’s 

Annual Energy Outlook 2011 (AEO 2011). The NOPR retains the same approach for 

determining electricity prices, and used AEO 2013 to project electricity price trends.

IECA commented that the sector specific average electricity prices do not account 

for differences across census regions where industrial activity is concentrated. (IECA, 

No. 52 at p. 2) As noted above, the industrial electricity price for each region is a 

weighted average based on the number of industrial customers of each utility. Thus, the 

prices reasonably account for concentration of industrial activity.

7. Lifetime 

In the preliminary analysis, DOE estimated the mechanical lifetime of electric 

motors in hours (i.e., the total number of hours an electric motor operates throughout its 

lifetime), depending on its horsepower size. DOE then developed Weibull distributions of 

mechanical lifetimes. The lifetime in years for a sampled electric motor was then 

calculated by dividing the sampled mechanical lifetime by the sampled annual operating 

hours of the electric motor. This model produces a negative correlation between annual 

 70 U.S. Department of Energy Information Administration (2003), Commercial Buildings Energy 

Consumption Survey, http://www.eia.gov/consumption/commercial/data/2003/pdf/a4.pdf 
204

hours of operation and electric motor lifetime: electric motors operated many hours per 

year are likely to be retired sooner than electric motors that are used for only a few 

hundred hours per year. DOE considered that electric motors of less than 75-hp are most 

likely to be embedded in a piece of equipment (i.e., an application). For such 

applications, DOE developed Weibull distributions of application lifetimes expressed in 

years and compared the sampled motor mechanical lifetime (in years) with the sampled 

application lifetime. DOE assumed that the electric motor would be retired at the earlier 

of the two ages. For the NOPR analysis, DOE retained the same approach and revised 

some of the lifetime assumptions based on additional information collected.

NEMA and WEG commented that the mechanical lifetime of agricultural motors 

should be lower than in the commercial or industrial sectors due to lower levels of 

maintenance performed in the field and the lighter duty steel frame constructions of these 

motors. (Pub. Mtg. Tr., No. 58 at p. 253) The NOPR analysis estimates that the average 

motor lifetime (across all sizes) for the agricultural sector to be 20 years.71 This revised 

estimate translates into average mechanical lifetimes between 24,000 and 30,000 hours 

depending on the horsepower range, which is lower than in the industrial sector. 

For the NOPR, DOE collected sector-specific mechanical motor lifetime 

information where available and revised the lifetime assumptions where appropriate. For 

the industrial sector, DOE estimated average mechanical lifetimes of 5, 15, and 20 years, 

depending on the horsepower range (the values correspond to 43,800, 87,600, and 

 71 Gallaher, M., Delhotal, K., & Petrusa, J. (2009). Estimating the potential CO2 mitigation from 

agricultural energy efficiency in the United States. Energy Efficiency, 2 (2):207-220.
205

131,400 hours respectively). These values are higher than those used in the preliminary 

analysis.

8. Discount Rate

The discount rate is the rate at which future expenditures are discounted to 

estimate their present value. The cost of capital commonly is used to estimate the present 

value of cash flows to be derived from a typical company project or investment. Most 

companies use both debt and equity capital to fund investments, so the cost of capital is 

the weighted-average cost to the firm of equity and debt financing. DOE uses the capital 

asset pricing model (CAPM) to calculate the equity capital component, and financial data 

sources to calculate the cost of debt financing.

For the NOPR, DOE estimated a statistical distribution of industrial and 

commercial customer discount rates by calculating the average cost of capital for the 

different types of electric motor owners (e.g., chemical industry, food processing, and 

paper industry). For the agricultural sector, DOE assumed similar discount rates as in 

industry. More details regarding DOE’s estimates of motor customer discount rates are 

provided in chapter 8 of the NOPR TSD.

9. Base Case Market Efficiency Distributions

For the LCC analysis, DOE analyzed the considered motor efficiency levels 

relative to a base case (i.e., the case without new or amended energy efficiency 

standards). This requires an estimate of the distribution of product efficiencies in the base 
206

case (i.e., what consumers would have purchased in the compliance year in the absence 

of new standards). DOE refers to this distribution of product energy efficiencies as the 

base case efficiency distribution. 

Data on motor sales by efficiency are not available. In the preliminary analysis, 

DOE used the number of models meeting the requirements of each efficiency level from 

six major manufacturers and one distributor’s catalog data to develop the base-case 

efficiency distributions. The distribution is estimated separately for each equipment class 

group and horsepower range and was assumed constant and equal to 2012 throughout the 

analysis period (2015- 2044).

For the NOPR, DOE retained the same approach to estimate the base case 

efficiency distribution in 2012, but it updated the base case efficiency distributions to 

account for the NOPR engineering analysis (revised ELs) and for the update in the scope 

of electric motors considered in the analysis. Beyond 2012, DOE assumed the efficiency 

distributions for equipment class group 1 and 4 vary over time based on historical data72

 72 Robert Boteler, USA Motor Update 2009, Energy Efficient Motor Driven Systems Conference 

(EEMODS) 2009.

for the market penetration of NEMA Premium motors within the market for integral 

alternating current induction motors. The assumed trend is shown in chapter 10 of the 

NOPR TSD. For equipment class group 2 and 3, which represent a very minor share of 

the market (less than 0.2 percent), DOE believes the overall trend in efficiency 

improvement for the total integral AC induction motors may not be representative, so 
207

DOE kept the base case efficiency distributions in the compliance year equal to 2012 

levels. 

Two interested parties commented on the base case efficiency distributions. 

Regal-Beloit stated that the share of 1- to 5-horsepower motors in equipment class 1 at 

CSL 0 in the base case distribution was too low by at least one percentage point. (Pub. 

Mtg. Tr., No. 58 at p. 263) NEMA requested clarifications on how DOE derived its base 

case efficiency distributions and commented that it would expect CSL 0 to represent 60 

percent of total units shipped when considering the expanded scope as proposed by 

NEMA. (NEMA, No. 54 at p. 84) Neither stakeholder, however, provided supporting 

data. 

As mentioned previously, DOE developed the 2012 base case efficiency 

distributions based on catalog information on the number of models meeting the 

requirements of each efficiency level. For the NOPR, DOE retained the same 

methodology and revised the catalog information to account for the addition of brake 

motors and NEMA 56-frame size enclosed electric motors in the analysis. DOE has no 

data to assess the stakeholders’ input on the base case efficiency distributions. 

10. Compliance Date

Any amended standard for electric motors shall apply to electric motors 

manufactured on or after a date which is five years after the effective date of the previous 

amendment. (42 U.S.C. 6313(b)(4)) In this case, the effective date of the previous 
208

amendment (established by EISA in 2007) is December 19, 2010, and the compliance 

date of any amended energy conservation standards for electric motors would be 

December 19, 2015. In light of the proposal’s attempt to establish amended or new 

standards for currently regulated and unregulated electric motor types, DOE has chosen 

to retain the same compliance date for both the amended and new energy conservation 

standards to simplify the requirements and to avoid any potential confusion from 

manufacturers. The final rule for this rulemaking is scheduled to be published in early 

2014. DOE calculated the LCC and PBP for all end-users as if each would purchase a 

new piece of equipment in the year that compliance is required. As DOE notes elsewhere, 

DOE is interested in comments regarding the feasibility of achieving compliance with 

this proposed date. 

11. Payback Period Inputs

The payback period is the amount of time it takes the consumer to recover the 

additional installed cost of more efficient equipment, compared to baseline equipment, 

through energy cost savings. Payback periods are expressed in years. Payback periods 

that exceed the life of the product mean that the increased total installed cost is not 

recovered in reduced operating expenses.

The inputs to the PBP calculation are the total installed cost of the product to the 

customer for each efficiency level and the average annual operating expenditures for each 

efficiency level. The PBP calculation uses the same inputs as the LCC analysis, except 

that discount rates are not needed.
209

12. Rebuttable-Presumption Payback Period

EPCA establishes a rebuttable presumption that a standard is economically 

justified if the Secretary finds that the additional cost to the consumer of purchasing a 

product complying with an energy conservation standard level will be less than three 

times the value of the energy (and, as applicable, water) savings during the first year that 

the consumer will receive as a result of the standard, as calculated under the test 

procedure in place for that standard. (42 U.S.C. 6295(o)(2)(B)(iii)) For each considered 

efficiency level, DOE determines the value of the first year’s energy savings by 

calculating the quantity of those savings in accordance with the applicable DOE test 

procedure, and multiplying that amount by the average energy price forecast for the year 

in which compliance with the new or amended standards would be required.

G.

DOE uses projections of product shipments to calculate the national impacts of 

standards on energy use, NPV, and future manufacturer cash flows. DOE develops 

shipment projections based on historical data and an analysis of key market drivers for 

each product. 

Shipments Analysis

To populate the model with current data, DOE used data from a market research 

report,73

 73 IMS Research (February 2012), The World Market for Low Voltage Motors, 2012 Edition, 

confidential inputs from manufacturers, trade associations, and other interested 

 Austin
210

parties’ responses to the Request for Information (RFI) published in the Federal Register. 

76 FR 17577 (March 30, 2011). DOE then used estimates of market distributions to 

redistribute the shipments across pole configurations, horsepower, and enclosures within 

each electric motor equipment class and also by sector. 

DOE’s shipments projection assumes that electric motor sales are driven by 

machinery production growth for equipment including motors. DOE estimated that 

growth rates for total motor shipments correlate to growth rates in fixed investment in 

equipment and structures including motors, which is provided by the U.S. Bureau of 

Economic Analysis (BEA).74 Projections of real gross domestic product (GDP) from 

AEO 2013 for 2015–2040 were used to project fixed investments in the equipment and 

structures including motors. The current market distributions are maintained over the 

forecast period.

For the NOPR, with the expanded scope by horsepower, DOE estimates total 

shipments in scope were 5.43 million units in 2011. This estimate represents an increase 

compared to the shipments estimated in the preliminary analysis because of the inclusion 

of integral brake motors and of NEMA integral enclosed 56-frame motors. 

For the preliminary analysis, DOE collected data on historical series of shipment 

quantities and value for the 1990-2003 period, but concluded that the data were not 

 74 Bureau of Economic Analysis (March 01, 2012), Private Fixed Investment in Equipment and Software 

by Type and Private Fixed Investment in Structures by Type. 

http://www.bea.gov/iTable/iTable.cfm?ReqID=12&step=1
211

sufficient to estimate motor price elasticity.75 Consequently, DOE assumed zero price 

elasticity for all efficiency standards cases and did not estimate any impact of potential 

standards levels on shipments. DOE requested stakeholder recommendations on data 

sources to help better estimate the impacts of increased efficiency levels on shipments.

The Motor Coalition commented that higher equipment costs required to achieve 

efficiency levels above CSL 2 (NEMA Premium) would encourage the refurbishment of 

existing motors rather than their replacement by new, more efficient motors, leading to 

reduced cost effective energy savings at CSL 3. (Motor Coalition, No. 35 at p. 7)

DOE acknowledges that increased electric motor prices could affect the “repair 

versus replace” decision, leading to the increased longevity of existing electric motors 

and a decrease in shipments of newly-manufactured energy-efficient electric motors. 

Considering the minimal cost increase between EL 2 and EL 3 in the preliminary analysis 

(approximately 3 percent for representative unit 1), DOE does not believe it is reasonable 

to consider non-zero price elasticity when calculating the standards-case shipments for 

levels above EL 2 and zero price elasticity when calculating shipments for the standards 

case at EL 2 of the preliminary analysis. For the above reasons, DOE retained its 

shipments projections, which do not incorporate price elasticities, for the NOPR. 

However, DOE also performed a sensitivity analysis that demonstrates the impact of 

 75 Business Trend Analysts, The Motor and Generator Industry, 2002; U.S. Census Bureau (November 

2004), Motors and Generators – 2003.MA335H(03)-1. 

http://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/index.html; and U.S. 

Census Bureau (August 2003), Motors and Generators – 2002.MA335H(02)-1. 

http://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/ma335h02.xls
212

possible price elasticities on projected shipments and the NIA results. See TSD appendix 

10-C for more details and results.

NEMA commented that shipments of imported motors might decrease if higher 

efficiency levels are mandated. (NEMA, No. 54 at p. 29) NEMA, however, provided no 

data in support of its view. DOE has reviewed shipments information from market 

reports, the U.S. Census, as well as market information provided by the Motor Coalition 

and has been unable to obtain any data to assess the potential reduction in quantity of 

imported motors due to standards and whether this would impact the total number of 

motors shipped in the U.S.76 DOE’s shipments projection assumes that electric motor 

sales are driven by machinery production growth for equipment including motors without 

distinction between imported and domestic motors. 

H.

The NIA assesses the national energy savings (NES) and the national NPV of 

total customer costs and savings that would be expected to result from new and amended 

standards at specific efficiency levels.

National Impact Analysis

To make the analysis more accessible and transparent to all interested parties, 

DOE used an MS Excel spreadsheet model to calculate the energy savings and the 

 76 IMS Research (February 2012), The World Market for Low Voltage Motors, 2012 Edition, Austin; 

Business Trend Analysts, The Motor and Generator Industry, 2002; U.S. Census Bureau (November 2004), 

Motors and Generators – 2003.MA335H(03)-1. 

http://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/index.html; and U.S. 

Census Bureau (August 2003), Motors and Generators – 2002.MA335H(02)-1. 

http://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/ma335h02.xls
213

national customer costs and savings from each TSL.77 DOE used the NIA spreadsheet to 

calculate the NES and NPV, based on the annual energy consumption and total installed 

cost data from the energy use analysis and the LCC analysis. DOE forecasted the lifetime 

energy savings, energy cost savings, equipment costs, and NPV of customer benefits for 

each product class for equipment sold from 2015 through 2044. In addition, DOE 

analyzed scenarios that used inputs from the AEO 2013 Low Economic Growth and High 

Economic Growth cases. These cases have higher and lower energy price trends 

compared to the reference case. 

DOE evaluated the impacts of potential new and amended standards for electric 

motors by comparing base-case projections with standards-case projections. The basecase projections characterize energy use and customer costs for each equipment class in 

the absence of new and amended energy conservation standards. DOE compared these 

projections with projections characterizing the market for each equipment class if DOE 

were to adopt new or amended standards at specific energy efficiency levels (i.e., the 

standards cases) for that class.

Table IV.25 summarizes all the major preliminary analysis inputs to the NIA and 

whether those inputs were revised for the NOPR. 

 77 DOE understands that MS Excel is the most widely used spreadsheet calculation tool in the United States 

and there is general familiarity with its basic features. Thus, DOE’s use of MS Excel as the basis for the 

spreadsheet models provides interested parties with access to the models within a familiar context. In 

addition, the TSD and other documentation that DOE provides during the rulemaking help explain the 

models and how to use them, and interested parties can review DOE’s analyses by changing various input 

quantities within the spreadsheet.
214

Table IV.25 Inputs for the National Impact Analysis

Input Preliminary Analysis Description Changes for NOPR

Shipments Annual shipments from shipments 

model.

No change.

Compliance date of 

standard

Modeled used January 1, 2015 December 19, 2015 (modeled as 

January 1, 2016)

Equipment Classes Three separate equipment class groups 

for NEMA Design A and B motors, 

NEMA Design C motors, and Fire 

Electric Pump Motors

Added one equipment class group 

for brake motors.

Base case 

efficiencies

Constant efficiency from 2015 through 

2044. 

No change for Equipment Class 2 

and 3. Added a trend for the 

efficiency distribution of 

equipment class groups 1 and 4.

Standards case 

efficiencies

Constant efficiency at the specified 

standard level from 2015 to 2044.

No change.

Annual energy 

consumption per 

unit

Average unit energy use data are 

calculated for each horsepower rating 

and equipment class based on inputs 

from the Energy use analysis.

No change.

Total installed cost 

per unit

Based on the MSP and weight data from 

the engineering, and then scaled for 

different hp and enclosure categories.

No change.

Electricity expense 

per unit

Annual energy use for each equipment 

class is multiplied by the corresponding 

average energy price.

No change.

Escalation of 

electricity prices

AEO 2011 forecasts (to 2035) and Updated to AEO 2013

extrapolation for 2044 and beyond.

Electricity site-tosource conversionA time series conversion factor; includes 

electric generation, transmission, and 

distribution losses. 

No change

Discount rates 3% and 7% real. No change.

Present year 2012. 2013.

1. Efficiency Trends

In the preliminary analysis, DOE did not include any change in base case 

efficiency in its shipments and national energy savings models. As explained in section 

IV.F, for equipment class groups 1 and 4, for the NOPR, DOE presumed that the 

efficiency distributions in the base case change over time. The projected share of 1 to 5 
215

horsepower NEMA Premium motors (EL 2) for equipment class group 1 grows from 36.6 

percent to 45.5 percent over the analysis period, and for equipment class group 4, it 

grows from 30.0 percent to 38.9 percent. For equipment class group 2 and 3, DOE 

assumed that the efficiency remains constant from 2015 to 2044.

In the standards cases, equipment with efficiency below the standard levels “roll 

up” to the standard level in the compliance year. Thereafter, for equipment class groups 1 

and 4, DOE assumed that the level immediately above the standard would show a similar 

increase in market penetration as the NEMA Premium motors in the base case.

The presumed efficiency trends in the base case and standards cases are described 

in chapter 10 of the NOPR TSD.

2. National Energy Savings

For each year in the forecast period, DOE calculates the lifetime national energy 

savings for each standard level by multiplying the shipments of electric motors affected 

by the energy conservation standards by the per-unit lifetime annual energy savings. 

Cumulative energy savings are the sum of the NES for all motors shipped during the 

analysis period, 2015–2044.

DOE estimated energy consumption and savings based on site energy and 

converted the electricity consumption and savings to primary energy using annual 
216

conversion factors derived from the AEO 2013 version of the NEMS. Cumulative energy 

savings are the sum of the NES for each year over the timeframe of the analysis.

DOE has historically presented NES in terms of primary energy savings. In 

response to the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle 

Measurement Approaches to Energy Efficiency Standards” appointed by the National 

Academy of Science, DOE announced its intention to use full-fuel-cycle (FFC) measures 

of energy use and greenhouse gas and other emissions in the national impact analyses and 

emissions analyses included in future energy conservation standards rulemakings. 76 FR 

51281 (August 18, 2011). While DOE stated in that notice that it intended to use the 

Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) 

model to conduct the analysis, it also said it would review alternative methods, including 

the use of EIA’s National Energy Modeling System (NEMS). After evaluating both 

models and the approaches discussed in the August 18, 2011 notice, DOE published a 

statement of amended policy in the Federal Register in which DOE explained its 

determination that NEMS is a more appropriate tool for this specific use. 77 FR 49701 

(August 17, 2012). Therefore, DOE is using NEMS to conduct FFC analyses. The 

approach used for today’s NOPR, and the FFC multipliers that were applied, are 

described in appendix 10-C of the TSD.

3. Equipment Price Forecast

As noted in section IV.F.2, DOE assumed no change in electric motor prices over 

the 2015−2044 period. In addition, DOE conducted a sensitivity analysis using 
217

alternative price trends. DOE developed one forecast in which prices decline after 2011, 

and one in which prices rise. These price trends, and the NPV results from the associated 

sensitivity cases, are described in appendix 10-B of the NOPR TSD.

4. Net Present Value of Customer Benefit 

The inputs for determining the NPV of the total costs and benefits experienced by 

consumers of considered equipment are: (1) total annual installed cost; (2) total annual 

savings in operating costs; and (3) a discount factor. DOE calculates the lifetime net 

savings for motors shipped each year as the difference between the base case and each 

standards case in total lifetime savings in lifetime operating costs and total lifetime 

increases in installed costs. DOE calculates lifetime operating cost savings over the life of 

each motor shipped during the forecast period.

In calculating the NPV, DOE multiplies the net savings in future years by a 

discount factor to determine their present value. DOE estimates the NPV using both a 3-

percent and a 7-percent real discount rate, in accordance with guidance provided by the 

Office of Management and Budget (OMB) to Federal agencies on the development of 

regulatory analysis.78

 78 OMB Circular A-4, section E (Sept. 17, 2003). 

The discount rates for the determination of NPV are in contrast to 

the discount rates used in the LCC analysis, which are designed to reflect a consumer’s 

perspective. The 7-percent real value is an estimate of the average before-tax rate of 

return to private capital in the U.S. economy. The 3-percent real value represents the 

http://www.whitehouse.gov/omb/circulars_a004_a-4. 
218

“social rate of time preference,” which is the rate at which society discounts future 

consumption flows to their present value.

I.

In analyzing the potential impacts of new or amended standards, DOE evaluates 

impacts on identifiable groups (i.e., subgroups) of customers that may be 

disproportionately affected by a national standard. For the NOPR, DOE evaluated 

impacts on various subgroups using the LCC spreadsheet model.

Consumer Subgroup Analysis 

The customer subgroup analysis is discussed in detail in chapter 11 of the TSD.

J.

1. Overview

Manufacturer Impact Analysis

DOE conducted an MIA for electric motors to estimate the financial impact of 

proposed new and amended energy conservation standards on manufacturers of covered 

electric motors. The MIA has both quantitative and qualitative aspects. The quantitative 

part of the MIA primarily relies on the GRIM, an industry cash flow model customized 

for electric motors covered in this rulemaking. The key GRIM inputs are data on the 

industry cost structure, equipment costs, shipments, and assumptions about markups and 

conversion expenditures. The key MIA output is INPV. DOE used the GRIM to calculate 

cash flows using standard accounting principles and to compare changes in INPV 

between a base case and various TSLs (the standards case). The difference in INPV 

between the base and standards cases represents the financial impact of new and amended 
219

standards on manufacturers of covered electric motors. Different sets of assumptions 

(scenarios) produce different INPV results. The qualitative part of the MIA addresses 

factors such as manufacturing capacity; characteristics of, and impacts on, any particular 

sub-group of manufacturers; and impacts on competition.

DOE conducted the MIA for this rulemaking in three phases. In the first phase 

DOE prepared an industry characterization based on the market and technology 

assessment, preliminary manufacturer interviews, and publicly available information. In 

the second phase, DOE estimated industry cash flows in the GRIM using industry 

financial parameters derived in the first phase and the shipment scenario used in the NIA. 

In the third phase, DOE conducted structured, detailed interviews with a variety of 

manufacturers that represent more than 75-percent of domestic electric motors sales 

covered by this rulemaking. During these interviews, DOE discussed engineering, 

manufacturing, procurement, and financial topics specific to each company, and obtained 

each manufacturer’s view of the electric motor industry as a whole. The interviews 

provided valuable information that DOE used to evaluate the impacts of new and 

amended standards on manufacturers’ cash flows, manufacturing capacities, and 

employment levels. See section IV.J.4 of this NOPR for a description of the key issues 

manufacturers raised during the interviews.

During the third phase, DOE also used the results of the industry characterization 

analysis in the first phase and feedback from manufacturer interviews to group 

manufacturers that exhibit similar production and cost structure characteristics. DOE 
220

identified one sub-group for a separate impact analysis – small business manufacturers –

using the small business employee threshold published by the Small Business 

Administration (SBA). This threshold includes all employees in a business’ parent 

company and any other subsidiaries. Based on this classification, DOE identified 13 

electric motor manufacturers that qualify as small businesses.

The complete MIA is presented in chapter 12 of the NOPR TSD.

2. GRIM Analysis and Key Inputs

DOE uses the GRIM to quantify the changes in cash flow over time due to a 

standard. These changes in cash flow result in either a higher or lower INPV for the 

standards case compared to the base case, the case where a standard is not set. The GRIM 

analysis uses a standard annual cash flow analysis that incorporates manufacturer costs, 

markups, shipments, and industry financial information as inputs. It then models changes 

in costs, investments, and manufacturer margins that result from new and amended 

energy conservation standards. The GRIM spreadsheet uses the inputs to calculate a 

series of annual cash flows beginning with the base year of the analysis, 2013, and 

continuing to 2044. DOE computes INPVs by summing the stream of annual discounted 

cash flows during this analysis period. DOE used a real discount rate of 9.1 percent for 

electric motor manufacturers. The discount rate estimates were derived from industry 

corporate annual reports to the Securities and Exchange Commission (SEC 10-Ks) and 

then modified according to feedback during manufacturer interviews. Many inputs into 

the GRIM come from the engineering analysis, the NIA, manufacturer interviews, and 
221

other research conducted during the MIA. The major GRIM inputs are described in detail 

in the sections below.

a. Product and Capital Conversion Costs

DOE expects new and amended energy conservation standards to cause 

manufacturers to incur one-time conversion costs to bring their production facilities and 

product designs into compliance with new and amended standards. For the MIA, DOE 

classified these one-time conversion costs into two major groups: (1) product conversion 

costs and (2) capital conversion costs. Product conversion costs are one-time investments 

in research, development, testing, marketing, and other non-capitalized costs necessary to 

make product designs comply with new and amended standards. Capital conversion costs 

are one-time investments in property, plant, and equipment necessary to adapt or change 

existing production facilities such that new product designs can be fabricated and 

assembled.

DOE calculated the product and capital conversion costs using both a top-down 

approach and a bottom-up approach based on feedback from manufacturers during 

manufacturer interviews and manufacturer submitted comments. DOE then adjusted these 

conversion costs if there were any discrepancies in the final costs using the two methods

to arrive at a final product and capital conversion cost estimate for each representative 

unit at each EL.
222

During manufacturer interviews, DOE asked manufacturers for their estimated 

total product and capital conversion costs needed to produce electric motors at specific 

ELs. To arrive at top-down industry wide product and capital conversion cost estimates 

for each representative unit at each EL, DOE calculated a market share weighted average 

value for product and capital conversion costs based on the data submitted during 

interviews and the market share of the interviewed manufacturers.

DOE also calculated bottom-up conversion costs based on manufacturer input on 

the types of costs and the dollar amounts necessary to convert a single electric motor 

frame size to each EL. Some of the types of capital conversion costs manufacturers 

identified were the purchase of lamination die sets, winding machines, frame casts, and 

assembly equipment as well as other retooling costs. The two main types of product 

conversion costs manufacturers shared with DOE during interviews were number of 

engineer hours necessary to re-engineer frames to meet higher efficiency standards and 

the testing and certification costs to comply with higher efficiency standards. DOE then 

took average values (i.e. costs or number of hours) based on the range of responses given 

by manufacturers for each product and capital conversion costs necessary for a 

manufacturer to increase the efficiency of one frame size to a specific EL. DOE 

multiplied the conversion costs associated with manufacturing a single frame size at each 

EL by the number of frames each interviewed manufacturer produces. DOE finally scaled 

this number based on the market share of the manufacturers DOE interviewed, to arrive 

at industry wide bottom-up product and capital conversion cost estimates for each 

representative unit at each EL. The bottom-up conversion costs estimates DOE created 
223

were consistent with the manufacturer top down estimates provided, so DOE used the 

bottom-up conversion cost estimates as the final values for each representative unit in the 

MIA.

In written comments and during manufacturer interviews, electric motor 

manufacturers stated there would be very large product and capital conversion costs 

associated with ELs above NEMA Premium, especially for any ELs that require 

manufacturers to switch to die-cast copper rotors. Manufacturers addressed the 

difficulties associated with using copper die-cast rotors and the uncertainty of a standard 

that requires manufacturers to produce electric motors on a commercial level for all 

horsepower ranges using this technology. NEMA stated that switching to die-cast copper 

rotors would cost each manufacturer approximately $80 million in retooling costs and 

approximately $68 million to redesign, test and certify electric motors at these ELs. 

(NEMA, No. 54 at p. 11) NEMA stated that significant conversion costs associated with 

any EL above NEMA Premium exist even if die-cast copper rotors are not used. Several 

manufacturers during interviews and in comments stated they would need to devote 

significant engineering time to redesign their entire production line to comply with ELs 

that are just one NEMA band higher than NEMA Premium. NEMA also stated that 

testing and certifying electric motors to ELs above NEMA Premium would be a 

significant cost to each manufacturer, since each manufacturer could have thousands or 

hundreds of thousands of unique electric motor specifications they would need to certify. 

(NEMA, No. 54 at p.4) DOE took these submitted comments into account when 
224

developing the industry product and capital conversion costs. The final product and 

capital conversion cost estimates were in the range of estimates submitted by NEMA.

See chapter 12 of the TSD for a complete description of DOE’s assumptions for 

the product and capital conversion costs.

b. Manufacturer Production Costs

Manufacturing a more efficient electric motor is typically more expensive than 

manufacturing a baseline product due to the use of more costly materials and 

components. The higher MPCs for these more efficient equipment can affect the revenue, 

gross margin, and cash flows of electric motor manufacturers.

DOE developed the MPCs for the representative units at each EL analyzed in one 

of two ways: (1) DOE purchased, tested and then tore down a motor to create a bill of 

materials (BOM) for the motor; and (2) DOE created a BOM based on a computer 

software model for a specific motor that complies with the associated efficiency level. 

This second approach was used when DOE was unable to find and purchase a motor that 

matched the efficiency criteria for a specific representative unit. Once DOE created a 

BOM for a specific motor, either by tear downs or software modeling, DOE then 

estimated the labor hours and the associated scrap and overhead costs necessary to 

produce a motor with that BOM. DOE was then able to create an aggregated MPC based 

on the material costs from the BOM and the associated scrap costs, the labor costs based 

on an average labor rate and the labor hours necessary to manufacture the motor, and the 
225

overhead costs, including depreciation, based on a markup applied to the material, labor, 

and scrap costs based on the materials used.

DOE created a BOM from tear downs for 15 of the 21 analyzed representative 

unit ELs and applied these BOM data to create ELs for certain representative units.: The 

representative unit ELs based on tear downs include: all five ELs for the Design B, 5-

horsepower representative unit; the baseline and ELs 1, 2, and 3 for the Design B, 30-

horsepower and 75-horsepower representative units; and the baseline for the Design C, 5-

horsepower and 50-horsepower representative units. DOE created a BOM based on a 

computer software model for the remaining six analyzed representative unit ELs: EL 4 

for the Design B, 30-horsepower and 75-horsepower representative units; and ELs 1 and 

2 for the Design C, 5-horsepower and 50-horsepower representative units.

Due to the very large product and capital conversion costs manufacturers would 

face if standards forced manufacturers to produce motors above NEMA Premium ELs, 

DOE decided to include the product and capital conversion costs as a portion of the 

MPCs for all ELs above NEMA Premium. DOE applied a per unit adder, which was a 

flat percentage of the MPC at NEMA Premium, for all MPCs above NEMA Premium. 

For a complete description of MPCs and the inclusion of manufacturer conversion costs 

into the MPC see the engineering analysis discussion in section IV.C of this NOPR.
226

c. Shipment Forecast

INPV, the key GRIM output, depends on industry revenue, which in turn, depends 

on the quantity and prices of electric motors shipped in each year of the analysis period. 

Industry revenue calculations require forecasts of: (1) total annual shipment volume; (2) 

the distribution of shipments across analyzed representative units (because prices vary by 

representative unit); and, (3) the distribution of shipments across efficiencies (because 

prices vary with efficiency).

In the NIA, DOE estimated the total number of electric motor shipments by year 

for the analysis period. The NIA projects electric motor shipments to generally increase 

over time. This is consistent with the estimates manufacturers revealed to DOE during 

manufacturer interviews. The NIA then estimated the percentage of shipments assigned 

to each ECG. DOE further estimated the percentage of shipments by horsepower rating, 

pole configuration, and enclosure type within each ECG. For the NIA, the shipment 

distribution across ECG and the shipment distribution across horsepower rating, pole 

configuration, and enclosure type do not change on a percentage basis over time. Nor 

does the shipment distribution across ECGs or across horsepower rating, pole 

configuration, and enclosure type change on a percentage basis due to an energy 

conservation standard (e.g. the number of shipments of Design C, 1 horsepower, 4 pole, 

open motor are the same in the base case as in the standards case). Finally, the NIA 

estimated a distribution of shipments across ELs (an efficiency distribution), for each 

horsepower range within each ECG. As described in further detail below, the efficiency 

distributions for ECG 1 and ECG 4 motors become more energy efficient over time in the 
227

base case, while the efficiency distributions for ECG 2 and ECG 3 do not change on a 

percentage basis over time (i.e., for ECG 2 and ECG 3 motors, the efficiency 

distributions at the beginning of the analysis period are the same as the efficiency 

distributions at the end of the analysis period). DOE also assumed the total volume of 

shipments does not decrease due to energy conservation standards, so total shipments are 

the same in the base case as in the standards case.

For the NIA, DOE modeled a “shift” shipment scenario for ECG 1 and ECG 4 

motors and a “roll-up” shipment scenario for ECG 2 and ECG 3 motors. In the standards 

case of the “shift” shipment scenario, shipments continue to become more efficient after a 

standard is set – in this case, immediately after the standards go into effect, all shipments 

below the selected TSL are brought up to meet that TSL. However, motors at or above 

the selected TSL migrate to even higher efficiency levels and continue to do so over time. 

In contrast, in the standards case of the “roll-up” shipment scenario, when a TSL is 

selected to become the new energy conservation standard, all shipments that fall below 

that selected TSL roll-up to the selected TSL. Therefore, the shipments that are at or 

above the selected TSL remain unchanged in the standards case of the “roll-up” shipment 

scenario compared to the base case. For the “roll-up” shipment scenario, the only 

difference in the efficiency distribution between the standards case and the base case is 

that in the standards case all shipments falling below the selected TSL in the base case 

are now at the selected TSL in the standards case.
228

While the shipments from the NIA are broken out into a total number of motor 

shipments for each ECG, horsepower rating, pole configuration, and enclosure type, the 

MIA consolidates the number of motor shipments into the representative units for each 

ECG. For example, the Design B, 5-horsepower, 4-pole, enclosed motor was the 

representative unit for all Design A and B motors between 1 and 10-horsepower 

regardless of the number of poles or enclosure type. So in the MIA DOE treated all ECG 

1 (Design A and B) motor shipments between 1 and 10-horsepower as shipments of the 

Design B, 5-horsepower representative unit; all ECG 1 motor shipments between 15- and 

50-horsepower as shipments of the Design B, 30-horsepower representative unit; and all 

ECG 1 motor shipments between 60- and 500-horsepower as shipments of the Design B, 

75-horsepower representative unit. For ECG 2 (Design C) motors, ECG 3 (fire pump) 

motors, and ECG 4 (brake) motors the MIA consolidated shipments in a similar manner, 

treating all shipments in the representative units’ horsepower range as shipments of that 

representative unit.

See the shipment analysis, chapter 9, of this NOPR TSD for additional details.

d. Markup Scenarios

As discussed in the MPC section above, the MPCs for the representative units are 

the factory costs of electric motor manufacturers; these costs include material, direct 

labor, overhead, depreciation, and any extraordinary conversion cost recovery. The MSP 

is the price received by electric motor manufacturers from their direct customer, typically 

either an OEM or a distributor. The MSP is not the cost the end-user pays for the electric 
229

motor since there are typically multiple sales along the distribution chain and various 

markups applied to each sale. The MSP equals the MPC multiplied by the manufacturer 

markup. The manufacturer markup covers all the electric motor manufacturer’s nonproduction costs (i.e., selling, general and administrative expenses (SG&A), normal 

R&D, and interest, etc.) and profit. Total industry revenue for electric motor 

manufacturers equals the MSPs at each EL for each representative unit multiplied by the 

number of shipments at that EL.

Modifying these manufacturer markups in the standards case yields a different set 

of impacts on manufacturers than in the base case. For the MIA, DOE modeled three 

standards case markup scenarios to represent the uncertainty regarding the potential 

impacts on prices and profitability for manufacturers following the implementation of 

new and amended energy conservation standards: (1) a flat markup scenario, (2) a 

preservation of operating profit scenario, and (3) a two-tiered markup scenario. These 

scenarios lead to different markup values, which, when applied to the inputted MPCs, 

result in varying revenue and cash flow impacts on manufacturers.

The flat markup scenario assumed that the cost of goods sold for each product is 

marked up by a flat percentage to cover SG&A expenses, R&D expenses, interest 

expenses, and profit. There were two values used for the flat markup, a 1.37 markup for 

high volume representative units and a 1.45 markup for low volume representative units. 

The 1.37 markup was used for the Design B, 5-horsepower representative unit; the 

Design C, 5-horsepower representative unit; the fire pump, 5-horsepower representative 
230

unit; and the brake, 5-horsepower representative unit The 1.45 markup is used for the 

Design B, 30-horsepower and 75-horsepower representative units; the Design C, 50 

horsepower representative unit; the fire pump, 30-horsepower and 75-horsepower 

representative units; and the brake, 30-horsepower and 75-horsepower representative 

units. This scenario represents the upper bound of industry profitability in the standards 

case because manufacturers are able to fully pass through additional costs due to 

standards to their customers. To derive the flat markup percentages, DOE examined the 

SEC 10-Ks of publicly traded electric motor manufacturers to estimate the industry 

average gross margin percentage. DOE then used that estimate along with the flat 

manufacturer markups used in the small electric motors rulemaking at 75 FR 10874 

(March 9, 2010), since several of the small electric motor manufacturers are also

manufacturers of electric motors covered in this rulemaking, to create a final estimate of 

the flat markups used for electric motors covered in this rulemaking.

DOE included an alternative markup scenario, the preservation of operating profit 

markup, because manufacturers stated that they do not expect to be able to markup the 

full cost of production given the highly competitive market, in the standards case. The 

preservation of operating profit markup scenario assumes that manufacturers are able to 

maintain only the base case total operating profit in absolute dollars in the standards case, 

despite higher product costs and investment. The base case total operating profit is 

derived from marking up the cost of goods sold for each product by the flat markup

described above. In the standards case for the preservation of operating profit markup 

scenario, DOE adjusted the manufacturer markups in the GRIM at each TSL to yield 
231

approximately the same earnings before interest and taxes in the standards case in the 

year after the compliance date of the new and amended standards as in the base case. 

Under this scenario, while manufacturers are not able to yield additional operating profit 

from higher production costs and the investments that are required to comply with new 

and amended energy conservation standards, they are able to maintain the same operating 

profit in the standards case that was earned in the base case.

DOE modeled a third profitability scenario, a two-tiered markup scenario. During 

interviews, several manufacturers stated they offer two tiers of motor lines that are 

differentiated, in part, by efficiency level. For example, several manufacturers offer 

Design B motors that meet, and in some cases exceed, NEMA Premium levels. Motors 

that exceed these levels typically command higher prices over NEMA Premium level 

motors at identical horsepower levels. These manufacturers suggested that the premium 

currently earned by the higher efficiency tiers would erode as new and amended 

standards are set at higher efficiency levels, which would harm profitability. To model 

this effect, DOE used information from manufacturers to estimate the higher and lower 

markups for electric motors under a two-tier pricing strategy in the base case. In the 

standards case, DOE modeled the situation in which product efficiencies offered by a 

manufacturer are altered due to standards. This change reduces the markup of higher 

efficiency equipment as they become the new baseline caused by the energy conservation 

standard. The change in markup is based on manufacturer statements made during 

interviews and on DOE’s understanding of industry pricing.
232

The preservation of operating profit and two-tiered markup scenarios represent 

the lower bound of industry profitability in the standards case because manufacturers are 

not able to fully pass through the additional costs due to standards, as manufacturers are 

able to do in the flat markup scenario. Therefore, manufacturers earn less revenue in the 

preservation of operating profit and two-tiered markup scenarios than they do in the flat 

markup scenario.

3. Discussion of Comments

During the August 2012 preliminary analysis public meeting, interested parties 

commented on the assumptions and results of the preliminary analysis TSD. Oral and 

written comments addressed several topics, including the scope of coverage, conversion 

costs, enforcement of standards, and the potential increase in the motor refurbishment 

market. DOE addresses these comments below.

a. Scope of Coverage

SEW-Eurodrive expressed concern about establishing energy conservation 

standards for integral gearmotors. SEW-Eurodrive stated that manufacturers would have 

to review and ensure the compatibility between the motor and the gearbox for all new 

integral gearmotor designs. Setting standards for these motors, in its view, may cause 

manufacturers to review potentially millions of motor-gear box combinations. SEWEurodrive also stated that since integral gearmotors comprise a system whose overall 

efficiency is limited by the low efficiency of the mating gearing, an increase in the 

efficiency of the motor alone would have a very small effect on the overall system 
233

efficiency. (SEW-Eurodrive, No. 53 at p. 3) DOE believes that these integral gearmotors 

can be tested by removing the gearbox and simply testing the partial motor in accordance 

with the partial motor test procedure proposed at 78 FR 38455 (June 26, 2013). This 

approach would allow integral gearmotor motor manufacturers to test and certify the 

electric motors and not every combination of electric motor and gearbox.

b. Conversion Costs

NEMA made a few comments regarding the potential difficulties and costs 

associated with increasing energy conservation standards to efficiency levels above 

NEMA Premium. First, NEMA stated that DOE should consider the current difficulties 

that manufacturers from IEC countries are having when meeting the efficiency levels 

under NEMA MG 1 Table 12-12. NEMA stated these manufacturers already face 

difficulties due to the limits of an electric motor frame size and stack length, as these 

limits pose physical constraints to higher efficiency levels. Moreover, such limits to IEC 

frame size and stack length are comparable to what manufacturers of NEMA frame 

motors would face if required efficiency levels were increased above current NEMA 

Premium efficiency levels. (NEMA, No. 54 at p. 84) NEMA did not provide any cost 

data, in engineering time or dollars, that these manufacturers were faced with regarding 

their compliance with NEMA MG 1 Table 12-12 efficiency levels.

NEMA went on to give estimates for the conversion costs associated with 

manufacturers producing motors above NEMA Premium efficiency levels. NEMA stated 

that it would cost each manufacturer approximately $80 million in retooling and $68 
234

million in reengineering, testing and prototyping to switch from currently used materials 

to die-cast copper rotor production. NEMA also stated there are other costs not directly 

related to the die-casting process manufacturers would incur, if standards required copper 

rotor technology. For example, NEMA noted that there are additional costs associated 

with redesigning the rotor and stator to maintain compliance with NEMA MG 1 

performance requirements. NEMA also provided DOE with a few of the major costs 

placed on the manufacturers if energy conservation standards exceeded NEMA Premium 

efficiency levels. NEMA said manufacturers would incur significant costs due to 

retooling slot insulators, automatic winding machines, and progressive lamination 

stamping dies—the last of which can cost between $500,000 and $750,000 per set. 

Manufacturers would also need to reengineer potentially 100,000 to 200,000 

specifications per manufacturer to comply with standards above NEMA Premium levels. 

(NEMA, No. 54 at p. 11)

DOE took these difficulties and costs that could be placed on manufacturers into 

consideration when creating the conversion costs of standards above NEMA Premium 

efficiency levels. DOE also recognizes the magnitude of the conversion costs on the 

industry at efficiency levels above NEMA Premium and this was one of the main reasons 

DOE included a portion of the conversion costs in the MPC for efficiency levels above 

NEMA Premium. DOE believes it is likely that motor manufacturers would attempt to 

recover these large one-time extraordinary conversion costs at standards above NEMA 

Premium through a variable cost increase in the MPCs of electric motors sold by 

manufacturers.
235

c. Enforcement of Standards

NEMA stated that large domestic manufacturers could be adversely impacted by 

higher energy conservation standards if DOE does not strictly enforce those new and 

amended standards, especially on imported machinery with embedded motors. NEMA 

commented that domestic manufacturers are currently competing with imported goods 

containing electric motors that are below current motor standards. This practice puts 

compliant motor manufacturers at a disadvantage because the machinery containing a 

non-compliant motor is often sold at a lower cost than machinery with a compliant motor. 

(NEMA, No. 54 at p. 11) DOE recognizes the need to enforce any energy conservation 

standard established for motors manufactured alone or as a component of another piece 

of equipment to ensure that all manufacturers are operating on a level playing field and to 

realize the actual reduction in energy consumption from these standards.

d. Motor Refurbishment

NEMA commented that if electric motors had to be redesigned to achieve higher 

energy conservation standards potential new motor customers may be forced to rewind 

older, less efficient motors because the longer or larger frame sizes that could be required 

to satisfy more stringent efficiency standards might not fit as drop-in replacements for 

existing equipment. (NEMA, No. 54 at p. 10) DOE agrees that adopting higher energy 

conservation standards for electric motors may force motor manufacturers to increase the 

length and/or the diameter of the frame. Such increase in motor frame size may cause 

some machinery using electric motors to be incompatible with previous electric motor 
236

designs. DOE requested comment on the quantitative impacts this could have on the 

electric motor and OEM markets but did not receive any quantitative responses regarding 

this issue. DOE is aware this could be a possible issue at the ELs above NEMA Premium, 

but does not consider this to be an issue at ELs that meet or are below NEMA Premium, 

since the majority of the electric motors used in existing equipment should already be at 

NEMA Premium efficiency levels. Therefore, based on data available at this time, DOE 

does not believe that motor refurbishment is likely to act as a barrier to the efficiency 

levels proposed in today’s NOPR.

4. Manufacturer Interviews

DOE conducted additional interviews with manufacturers following the 

preliminary analysis in preparation for the NOPR analysis. In these interviews, DOE 

asked manufacturers to describe their major concerns with this rulemaking. The 

following section describes the key issues identified by manufacturers during these 

interviews.

a. Efficiency Levels above NEMA Premium

During these interviews, several manufacturers were concerned with the 

difficulties associated with increasing motor efficiency levels above NEMA Premium. 

Manufacturers stated that even increasing the efficiency of motors to one band above 

NEMA Premium would require each manufacturer to make a significant capital 

investment to retool their entire production line. It would also require manufacturers to 
237

completely redesign almost every motor configuration offered, which could take several 

years of engineering time.

According to manufacturers, another potential problem with setting standards 

above NEMA Premium is that this would misalign U.S. electric motor standards with 

global motor standards (e.g., IEC motor standards). They noted that over the past few 

decades, there has been an effort to harmonize global motor standards that setting new 

U.S. electric motor standards at a level exceeding the NEMA Premium level would cause 

U.S. electric motor markets to be out of synchronization with the rest of the world’s 

efficiency standards.

Several manufacturers also commented they believe any standard requiring diecasting copper rotors is infeasible. One main concern manufacturers have regarding 

copper is that not only has the price of copper significantly increased over the past 

several years, there has been tremendous volatility in the price as well. Manufacturers 

worry that if standards required manufacturers to use copper rotors, they would be subject 

to this volatile copper market. Manufacturers also noted that motor efficiency standards 

requiring copper rotors for all electric motors would likely increase the price of copper 

due to the increase in demand from the motors industry.

Another key concern that manufacturers have regarding standards that require

using copper rotors is that copper has a much higher melting temperature than aluminum, 

and the pressure required to die-cast copper is much higher than aluminum. They contend 
238

that there is a much greater chance that a significant accident or injury to their employees 

could occur if manufacturers were required to produce copper rotors rather than 

aluminum rotors.

Lastly, several manufacturers stated they would not be able to produce copper 

die-cast rotors in-house and would have to outsource this production. Manufacturers 

stated that if the entire motor industry had to outsource their rotor production as a result 

of standards that required the use of die-cast copper rotors, there would be significant 

supply chain problems in the motor manufacturing process. Manufacturers emphasized 

during interviews that the capacity to produce copper rotors on a large commercial scale 

does not exist and would be very difficult to implement in even a three-year time period.

Overall, manufacturers are very concerned if any electric motor standard required 

motor efficiency levels beyond NEMA Premium, especially if those efficiency levels 

required the use of copper rotor technology. According to manufacturers, efficiency

levels beyond NEMA Premium would require a significant level of investment from all 

electric motor manufacturers and would cause the U.S. to be out of sync with the electric 

motor standards around the world. If standards required the use of copper rotors,

manufacturers would experience further difficulties due to the potential increase in 

copper prices and the volatility of the copper market, as well as the potential safety 

concerns regarding the higher melting temperature of copper than aluminum.
239

b. Increase in Equipment Repairs

Manufacturers have stated that as energy conservation standards increase 

customers are more likely to rewind old, less efficient motors, as opposed to purchasing 

newer more efficient and compliant motors. Therefore, if motor standards significantly 

increase the price of motors, manufacturers believe rewinding older motors might 

become a more attractive option for some customers. These customers would in turn be 

using more energy than if they simply purchased a currently compliant motor, since 

rewound motors typically do not operate at their original efficiency level after being 

rewound. Manufacturers believe that DOE must take the potential consumer rewinding 

decision into account when deciding on an electric motors standard.

c. Enforcement

Manufacturers have stated that one of their biggest concerns with additional 

energy conservation standards is the lack of enforcement of current electric motor 

standards. In general, domestic manufacturers have stated they comply with the current 

electric motor regulations and will continue to comply with any future standards. 

However, these manufacturers believe that there are several foreign motor manufacturers 

that do not comply with the current electric motor regulations and will not comply with 

any future standards if the efficiency standards are increased. This would cause compliant 

manufacturers to be placed at a competitive disadvantage, since complying with any 

increased efficiency standards will be very costly. Some domestic manufacturers believe 

the most cost effective way to reduce energy consumption of electric motors is to more 
240

strictly enforce the existing electric motor standards rather than increase the efficiency 

standards of electric motors.

K.

In the emissions analysis, DOE estimated the reduction in power sector emissions 

of carbon dioxide (CO2), nitrogen oxides (NOx), sulfur dioxide (SO2), and mercury (Hg) 

from potential energy conservation standards for electric motors. In addition, DOE 

estimates emissions impacts in production activities (extracting, processing, and 

transporting fuels) that provide the energy inputs to power plants. These are referred to as 

“upstream” emissions. Together, these emissions account for the full-fuel-cycle (FFC). In 

accordance with DOE’s FFC Statement of Policy (76 FR 51282 (August 18, 2011) as 

amended at 77 FR 49701 (August 17, 2012)), the FFC analysis includes impacts on 

emissions of methane (CH4) and nitrous oxide (N2O, both of which are recognized as 

greenhouse gases. 

Emissions Analysis

DOE conducted the emissions analysis using emissions factors that were derived 

from data in the Energy Information Agency’s (EIA’s) Annual Energy Outlook 2013

(AEO 2013), supplemented by data from other sources. DOE developed separate 

emissions factors for power sector emissions and upstream emissions. The method that 

DOE used to derive emissions factors is described in chapter 13 of the NOPR TSD.

EIA prepares the Annual Energy Outlook using the National Energy Modeling 

System (NEMS). Each annual version of NEMS incorporates the projected impacts of 

existing air quality regulations on emissions. AEO 2013 generally represents current 
241

legislation and environmental regulations, including recent government actions, for 

which implementing regulations were available as of December 31, 2012.

SO2 emissions from affected electric generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs. Title IV of the Clean Air Act 

sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous States and 

the District of Columbia (D.C.). SO2 emissions from 28 eastern states and D.C. were also 

limited under the Clean Air Interstate Rule (CAIR; 70 FR 25162 (May 12, 2005)), which 

created an allowance-based trading program that operates along with the Title IV 

program. CAIR was remanded to the U.S. Environmental Protection Agency (EPA) by 

the U.S. Court of Appeals for the District of Columbia Circuit but it remained in effect. 

See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 

F.3d 896 (D.C. Cir. 2008). On July 6, 2011 EPA issued a replacement for CAIR, the 

Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On August 21, 

2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME Homer City 

Generation, LP v. EPA, No. 11-1302, 2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 

2012). The court ordered EPA to continue administering CAIR. The AEO 2013

emissions factors used for today’s NOPR assumes that CAIR remains a binding 

regulation through 2040.

The attainment of emissions caps is typically flexible among EGUs and is 

enforced through the use of emissions allowances and tradable permits. Under existing 

EPA regulations, any excess SO2 emissions allowances resulting from the lower 
242

electricity demand caused by the adoption of an efficiency standard could be used to 

permit offsetting increases in SO2 emissions by any regulated EGU. In past rulemakings, 

DOE recognized that there was uncertainty about the effects of efficiency standards on 

SO2 emissions covered by the existing cap-and-trade system, but it concluded that 

negligible reductions in power sector SO2 emissions would occur as a result of standards. 

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury 

and Air Toxics Standards (MATS) for power plants, which were announced by EPA on 

December 21, 2011.. 77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA 

established a standard for hydrogen chloride as a surrogate for acid gas hazardous air 

pollutants (HAP), and also established a standard for SO2 (a non-HAP acid gas) as an

alternative equivalent surrogate standard for acid gas HAP. The same controls are used to 

reduce HAP and non-HAP acid gas; thus, SO2 emissions will be reduced as a result of the 

control technologies installed on coal-fired power plants to comply with the MATS 

requirements for acid gas. AEO 2013

Comment [A28]: Change recommended by 

OIRA.

assumes that, in order to continue operating, coal 

plants must have either flue gas desulfurization or dry sorbent injection systems installed 

by 2015. Both technologies, which are used to reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 emissions when 

electricity demand decreases (e.g., as a result of energy efficiency standards). Emissions 

will be far below the cap established by CAIR, so it is unlikely that excess SO2 emissions 

allowances resulting from the lower electricity demand would be needed or used to 

permit offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE 

believes that efficiency standards will reduce SO2 emissions in 2015 and beyond.
243

CAIR established a cap on NOx emissions in 28 eastern States and the District of 

Columbia. Energy conservation standards are expected to have little effect on NOx

emissions in those States covered by CAIR because excess NOx emissions allowances 

resulting from the lower electricity demand could be used to permit offsetting increases 

in NOx emissions. However, standards would be expected to reduce NOx emissions in the 

States not affected by the caps, so DOE estimated NOx emissions reductions from the 

standards considered in today’s NOPR for these States.

The MATS limit mercury emissions from power plants, but they do not include 

emissions caps and, as such, DOE’s energy conservation standards would likely reduce 

Hg emissions. DOE estimated mercury emissions reduction using emissions factors based 

on AEO 2013, which incorporates the MATS. 

NEMA commented that DOE should consider emissions related to all aspects 

involved in the production of higher efficiency motors. (NEMA, No. 54 at p. 31) In 

response, DOE notes that EPCA directs DOE to consider the total projected amount of 

energy, or as applicable, water, savings likely to result directly from the imposition of the 

standard when determining whether a standard is economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)(III) and 6316(a)) DOE interprets this to include energy used in the 

generation, transmission, and distribution of fuels used by appliances or equipment. In 

addition, DOE is using the full-fuel-cycle measure, which includes the energy consumed 

in extracting, processing, and transporting primary fuels. DOE’s current accounting of 

primary energy savings and the full-fuel-cycle measure are directly linked to the energy 
244

used by appliances or equipment. DOE believes that energy used in manufacturing of 

appliances or equipment falls outside the boundaries of “directly” as intended by EPCA. 

Thus, DOE did not consider such energy use and air emissions in the NIA or in the 

emissions analysis.

L.

As part of the development of this proposed rule, DOE considered the estimated 

monetary benefits from the reduced emissions of CO2 and NOX that are expected to result 

from each of the TSLs considered. In order to make this calculation similar to the 

calculation of the NPV of consumer benefit, DOE considered the reduced emissions 

expected to result over the lifetime of equipment shipped in the forecast period for each 

TSL. This section summarizes the basis for the monetary values used for each of these 

emissions and presents the values considered in this rulemaking.

Monetizing Carbon Dioxide and Other Emissions Impacts

For today’s NOPR, DOE is relying on a set of values for the social cost of carbon 

(SCC) that was developed by an interagency process. A summary of the basis for these 

values is provided below, and a more detailed description of the methodologies used is 

provided as an appendix to chapter 14 of the NOPR TSD.

1. Social Cost of Carbon 

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 
245

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of carbon dioxide. A domestic SCC value is meant to 

reflect the value of damages in the United States resulting from a unit change in carbon 

dioxide emissions, while a global SCC value is meant to reflect the value of damages 

worldwide.

Under section 1(b)(6) of Executive Order 12866, “Regulatory Planning and 

Review,” 58 FR 51735 (Oct. 4, 1993), agencies must, to the extent permitted by law, 

assess both the costs and the benefits of the intended regulation and, recognizing that 

some costs and benefits are difficult to quantify, propose or adopt a regulation only upon 

a reasoned determination that the benefits of the intended regulation justify its costs. The 

purpose of the SCC estimates presented here is to allow agencies to incorporate the 

monetized social benefits of reducing CO2 emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global 

emissions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts.

As part of the interagency process that developed the SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

using a defensible set of input assumptions grounded in the existing scientific and 
246

economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process.

a. Monetizing Carbon Dioxide Emissions

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of serious challenges. A recent report from the 

National Research Council points out that any assessment will suffer from uncertainty, 

speculation, and lack of information about: (1) future emissions of greenhouse gases; (2) 

the effects of past and future emissions on the climate system; (3) the impact of changes 

in climate on the physical and biological environment; and (4) the translation of these 

environmental impacts into economic damages. As a result, any effort to quantify and 

monetize the harms associated with climate change will raise serious questions of 

science, economics, and ethics and should be viewed as provisional.

Despite the serious limits of both quantification and monetization, SCC estimates 

can be useful in estimating the social benefits of reducing carbon dioxide emissions. Most 

Federal regulatory actions can be expected to have marginal impacts on global emissions. 

For such policies, the agency can estimate the benefits from reduced emissions in any 

future year by multiplying the change in emissions in that year by the SCC value 

appropriate for that year. The net present value of the benefits can then be calculated by 

multiplying the future benefits by an appropriate discount factor and summing across all 

affected years. This approach assumes that the marginal damages from increased 

emissions are constant for small departures from the baseline emissions path, an 
247

approximation that is reasonable for policies that have effects on emissions that are small 

relative to cumulative global carbon dioxide emissions. For policies that have a large 

(non-marginal) impact on global cumulative emissions, there is a separate question of 

whether the SCC is an appropriate tool for calculating the benefits of reduced emissions. 

This concern is not applicable to this rulemaking, however.

It is important to emphasize that the interagency process is committed to 

updating these estimates as the science and economic understanding of climate change 

and its impacts on society improves over time. In the meantime, the interagency group 

will continue to explore the issues raised by this analysis and consider public comments 

as part of the ongoing interagency process.

b. Social Cost of Carbon Values Used in Past Regulatory Analyses

Economic analyses for Federal regulations have used a wide range of values to 

estimate the benefits associated with reducing carbon dioxide emissions. In the final 

model year 2011 CAFE rule, the U.S. Department of Transportation (DOT) used both a 

“domestic” SCC value of $2 per metric ton of CO2 and a “global” SCC value of $33 per 

metric ton of CO2 for 2007 emission reductions (in 2007$), increasing both values at 2.4 

percent per year. DOT also included a sensitivity analysis at $80 per metric ton of CO2.

79

 79 See Average Fuel Economy Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 

(March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate Average Fuel Economy 

Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-90 (Oct. 2008) (Available at: 

 

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per metric ton 

of CO2 (in 2006$) for 2011 emission reductions (with a range of $0−$14 for sensitivity 

http://www.nhtsa.gov/fuel-economy) (Last accessed December 2012).
248

analysis), also increasing at 2.4 percent per year.80 A regulation for packaged terminal air 

conditioners and packaged terminal heat pumps finalized by DOE in October of 2008 

used a domestic SCC range of $0 to $20 per metric ton CO2 for 2007 emission reductions 

(in 2007$). 73 FR 58772, 58814 (Oct. 7, 2008). In addition, EPA’s 2008 Advance Notice 

of Proposed Rulemaking on Regulating Greenhouse Gas Emissions Under the Clean Air 

Act identified what it described as “very preliminary” SCC estimates subject to revision. 

73 FR 44354 (July 30, 2008). EPA’s global mean values were $68 and $40 per metric ton 

CO2 for discount rates of approximately 2 percent and 3 percent, respectively (in 2006$ 

for 2007 emissions).

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing carbon dioxide emissions. To ensure 

consistency in how benefits are evaluated across agencies, the Administration sought to 

develop a transparent and defensible method, specifically designed for the rulemaking 

process, to quantify avoided climate change damages from reduced CO2 emissions. The 

interagency group did not undertake any original analysis. Instead, it combined SCC 

estimates from the existing literature to use as interim values until a more comprehensive 

analysis could be conducted. The outcome of the preliminary assessment by the 

interagency group was a set of five interim values: global SCC estimates for 2007 (in 

2006$) of $55, $33, $19, $10, and $5 per metric ton of CO2. These interim values 

represented the first sustained interagency effort within the U.S. government to develop 

 80 See Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015, 73 

FR 24352 (May 2, 2008) (Proposed Rule); Draft Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-58 (June 2008) 

(Available at: http://www.nhtsa.gov/fuel-economy) (Last accessed December 2012).
249

an SCC for use in regulatory analysis. The results of this preliminary effort were 

presented in several proposed and final rules.

c. Current Approach and Key Assumptions 

Since the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates. Specifically, the group considered 

public comments and further explored the technical literature in relevant fields. The 

interagency group relied on three integrated assessment models commonly used to 

estimate the SCC: the FUND, DICE, and PAGE models. These models are frequently 

cited in the peer-reviewed literature and were used in the last assessment of the 

Intergovernmental Panel on Climate Change. Each model was given equal weight in the 

SCC values that were developed. 

Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

different approaches to quantifying damages taken by the key modelers in the field. An 

extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

socio-economic parameters and a range of values for the discount rate. All other model 
250

features were left unchanged, relying on the model developers’ best estimates and 

judgments.

In 2010, the interagency group selected four sets of SCC values for use in 

regulatory analyses.81

Table IV.26

Three sets of values are based on the average SCC from three 

integrated assessment models, at discount rates of 2.5 percent, 3 percent, and 5 percent. 

The fourth set, which represents the 95th-percentile SCC estimate across all three models 

at a 3-percent discount rate, is included to represent higher-than-expected impacts from 

climate change further out in the tails of the SCC distribution. The values grow in real 

terms over time. Additionally, the interagency group determined that a range of values 

from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although preference is given to consideration of the global benefits of 

reducing CO2 emissions. presents the values in the 2010 interagency group 

report, which is reproduced in appendix 14-A of the NOPR TSD.

 81 Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United States Government, February 2010. 

http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf.
251

Table IV.26 Annual SCC Values from 2010 Interagency Report, 2010–2050 (in 2007 

dollars per metric ton CO2)

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 4.7 21.4 35.1 64.9

2015 5.7 23.8 38.4 72.8

2020 6.8 26.3 41.7 80.7

2025 8.2 29.6 45.9 90.4

2030 9.7 32.8 50.0 100.0

2035 11.2 36.0 54.2 109.7

2040 12.7 39.2 58.4 119.3

2045 14.2 42.1 61.7 127.8

2050 15.7 44.9 65.0 136.2

The SCC values used for today’s notice were generated using the most recent 

versions of the three integrated assessment models that have been published in the peerreviewed literature.82 Table IV.27shows the updated sets of SCC estimates from the 2013 

interagency update in five-year increments from 2010 to 2050. Appendix 14A of the 

NOPR TSD provides the full set of values. The central value that emerges is the average 

SCC across models at 3-percent discount rate. However, for purposes of capturing the 

uncertainties involved in regulatory impact analysis, the interagency group emphasizes 

the importance of including all four sets of SCC values.

 82 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 

12866. Interagency Working Group on Social Cost of Carbon, United States Government, May 

2013. http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_upd

ate.pdf .. May 2013; revised November 2013.

http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbonfor-regulator-impact-analysis.pdf
252

Table IV.27 Annual SCC Values from 2013 Interagency Update, 2010–2050 (in 2007 

dollars per metric ton CO2)

Year

Discount Rate %

5 3 2.5 3

Average Average Average 95th Percentile

2010 11 3332 5251 9089

2015 1211 3837 5857 109

2020 12 43 6564 129128

2025 14 4847 7069 144143

2030 16 52 7675 159

2035 19 5756 8180 176175

2040 21 6261 8786 192191

2045 24 66 92 206

2050 2726 71 9897 221220

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizes that the existing models are imperfect and incomplete. The National Research 

Council report mentioned above points out that there is tension between the goal of 

producing quantified estimates of the economic damages from an incremental ton of 

carbon and the limits of existing efforts to model these effects. There are a number of 

concerns and problems that should be addressed by the research community, including 

research programs housed in many of the Federal agencies participating in the 

interagency process to estimate the SCC. The interagency group intends to periodically 

review and reconsider those estimates to reflect increasing knowledge of the science and 

economics of climate impacts, as well as improvements in modeling.

Comment [A29]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
253

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions resulting from today’s rule, DOE used the values from the 2013 

interagency report , adjusted to 2012$ using the Gross Domestic Product price deflator. 

For each of the four cases specified, the values used for emissions in 2015 were $12.9, 

$4011.8, $6239.7, $61.2, and $117 per metric ton avoided (values expressed in 2012$). 

DOE derived values after 2050 using the relevant growth rate for the 2040-2050 period in 

the interagency update. 

DOE multiplied the CO2 emissions reduction estimated for each year by the SCC 

value for that year in each of the four cases. To calculate a present value of the stream of 

monetary values, DOE discounted the values in each of the four cases using the specific 

discount rate that had been used to obtain the SCC values in each case.

2. Valuation of Other Emissions Reductions

DOE investigated the potential monetary benefit of reduced NOx emissions from 

the TSLs it considered. As noted above, DOE has taken into account how new or 

amended energy conservation standards would reduce NOx emissions in those 22 states 

not affected by the CAIR. DOE estimated the monetized value of NOx emissions 

reductions resulting from each of the TSLs considered for today’s NOPR based on 

estimates found in the relevant scientific literature. Available estimates suggest a very 

wide range of monetary values per ton of NOx from stationary sources, ranging from 

Comment [A30]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
254

$468 to $4,809 per ton in 2012$).83 In accordance with OMB guidance, 84 DOE 

calculated a range of monetary benefits using each of the economic values for NOX and 

real discount rates of 3-percent and 7-percent. 

DOE is evaluating appropriate monetization of avoided SO2 and Hg emissions in 

energy conservation standards rulemakings. It has not included monetization in the 

current analysis.

M.

The utility impact analysis estimates several effects on the power generation 

industry that would result from the adoption of new or amended energy conservation 

standards. In the utility impact analysis, DOE analyzes the changes in installed electricity

capacity and generation that would result for each trial standard level. The utility impact 

analysis uses a variant of NEMS,

Utility Impact Analysis 

85 which is a public domain, multi-sectored, partial 

equilibrium model of the U.S. energy sector. DOE uses a variant of this model, referred 

to as NEMS-BT,86

 83 For additional information, refer to U.S. Office of Management and Budget, Office of Information and 

Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities, Washington, DC.

to account for selected utility impacts of new or amended energy 

conservation standards. DOE’s analysis consists of a comparison between model results 

84 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 85 For more information on NEMS, refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 

2003, DOE/EIA-0581(2003) (March, 2003). 86 DOE/EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is 

run under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it by the 

name “NEMS-BT” (“BT” is DOE’s Building Technologies Program, under whose aegis this work has been 

performed). 
255

for the most recent AEO Reference Case and for cases in which energy use is 

decremented to reflect the impact of potential standards. The energy savings inputs 

associated with each TSL come from the NIA. Chapter 15 of the NOPR TSD describes 

the utility impact analysis in further detail.

N.

Employment impacts from new or amended energy conservation standards 

include direct and indirect impacts. Direct employment impacts are any changes in the 

number of employees of manufacturers of the equipment subject to standards; the MIA 

addresses those impacts. Indirect employment impacts are changes in national 

employment that occur due to the shift in expenditures and capital investment caused by 

the purchase and operation of more efficient equipment. Indirect employment impacts 

from standards consist of the jobs created or eliminated in the national economy, other 

than in the manufacturing sector being regulated, due to: (1) reduced spending by end 

users on energy; (2) reduced spending on new energy supply by the utility industry; (3) 

increased consumer spending on the purchase of new equipment; and (4) the effects of 

those three factors throughout the economy. 

Employment Impact Analysis

One method for assessing the possible effects on the demand for labor of such 

shifts in economic activity is to compare sector employment statistics developed by the 

Labor Department’s Bureau of Labor Statistics (BLS). BLS regularly publishes its 

estimates of the number of jobs per million dollars of economic activity in different 

sectors of the economy, as well as the jobs created elsewhere in the economy by this 
256

same economic activity. Data from BLS indicate that expenditures in the utility sector 

generally create fewer jobs (both directly and indirectly) than expenditures in other 

sectors of the economy. There are many reasons for these differences, including wage

differences and the fact that the utility sector is more capital-intensive and less laborintensive than other sectors. Energy conservation standards have the effect of reducing 

consumer utility bills. Because reduced consumer expenditures for energy likely lead to 

increased expenditures in other sectors of the economy, the general effect of efficiency 

standards is to shift economic activity from a less labor-intensive sector (i.e., the utility 

sector) to more labor-intensive sectors (e.g., the retail and service sectors). Thus, based 

on the BLS data alone, DOE believes net national employment may increase because of 

shifts in economic activity resulting from new and amended standards.

For the standard levels considered in the NOPR, DOE estimated indirect national 

employment impacts using an input/output model of the U.S. economy called Impact of 

Sector Energy Technologies, Version 3.1.1 (ImSET). ImSET is a special purpose version 

of the “U.S. Benchmark National Input-Output” (I–O) model, which was designed to 

estimate the national employment and income effects of energy-saving technologies. The 

ImSET software includes a computer-based I–O model having structural coefficients that 

characterize economic flows among the 187 sectors. ImSET’s national economic I–O 

structure is based on a 2002 U.S. benchmark table, specially aggregated to the 187 

sectors most relevant to industrial, commercial, and residential building energy use. DOE 

notes that ImSET is not a general equilibrium forecasting model, and understands the 

uncertainties involved in projecting employment impacts, especially changes in the later 
257

years of the analysis. Because ImSET does not incorporate price changes, the 

employment effects predicted by ImSET may over-estimate actual job impacts over the 

long run. For the NOPR, DOE used ImSET only to estimate short-term employment 

impacts.

For more details on the employment impact analysis, see chapter 16 of the NOPR 

TSD.

O.

IECA commented that motor end-users have not participated in DOE’s electric 

motor standards process, and they urge DOE to provide an outreach effort to include 

those who buy motors. (IECA, No. 52 at p. 3) Throughout the rulemaking process, DOE 

makes a considerable effort to understand rulemaking impacts to consumers, most 

specifically in the life-cycle cost analysis. It encourages various interested parties, 

including end-users of electric motors, to attend public meetings and submit comments. 

DOE recognizes the central importance of the consumer perspective, and welcomes 

comment from IECA and any other organizations serving consumer interest, as well as 

from individual consumers, themselves.

Other Comments Received

V. Analytical Results

A. Trial Standard Levels
258

DOE ordinarily considers several Trial Standard Levels (TSLs) in its analytical 

process. TSLs are formed by grouping different Efficiency Levels (ELs), which are 

standard levels for each Equipment Class Grouping (ECG) of motors. DOE analyzed the 

benefits and burdens of the TSLs developed for today’s proposed rule. DOE examined 

four TSLs for electric motors. Table V.1 presents the TSLs analyzed and the 

corresponding efficiency level for each equipment class group. 

The efficiency levels in each TSL can be characterized as follows: TSL 1 

represents each equipment class group moving up one efficiency level from the current 

baseline, with the exception of fire-pump motors, which remain at their baseline level; 

TSL 2 represents NEMA Premium levels for all equipment class groups with the 

exception of fire-pump motors, which remain at the baseline; TSL 3 represents 1 NEMA 

band above NEMA Premium for all groups except fire-pump motors, which move up to 

NEMA Premium; and TSL 4 represents the maximum technologically feasible level (max 

tech) for all equipment class groups.1 Because today’s proposal includes equipment class 

groups containing both currently regulated motors and those proposed to be regulated, at 

certain TSLs, an equipment class group may encompass different standard levels, some 

of which may be above one EL above the baseline. For example, at TSL1, EL1 is being 

proposed for equipment class group 1. However, a large number of motors in equipment 

class group 1 already have to meet EL2. If TSL1 was selected, these motors would 

continue to be required to meet the standards at TSL2, while currently un-regulated 

motors would be regulated to TSL1. 
259

Table V.1 Summary of Proposed TSLs

Equipment 

Class Group

TSL 1 TSL 2 TSL 3 TSL 4

1 EL 1 EL 2 EL 3 EL 4

2 EL 1 EL 1 EL 2 EL 2

3 EL 0 EL 0 EL 1 EL 3

4 EL 1 EL 2 EL 3 EL 4

B.

As discussed in section II.A, EPCA provides seven factors to be evaluated in 

determining whether a potential energy conservation standard is economically justified. 

(42 U.S.C. 6295(o)(2)(B)(i)) The following sections generally discuss how DOE is 

addressing each of those seven factors in this rulemaking. 

Economic Justification and Energy Savings

1. Economic Impacts on Individual Customers

DOE analyzed the economic impacts on electric motor customers by looking at 

the effects standards would have on the LCC and PBP. DOE also examined the rebuttable 

presumption payback periods for each equipment class, and the impacts of potential 

standards on customer subgroups. These analyses are discussed below.

a. Life-Cycle Cost and Payback Period

To evaluate the net economic impact of standards on electric motor customers, 

DOE conducted LCC and PBP analyses for each TSL. In general, higher-efficiency 

equipment would affect customers in two ways: (1) annual operating expense would 

decrease, and (2) purchase price would increase. Section IV.F of this notice discusses the 

inputs DOE used for calculating the LCC and PBP. The LCC and PBP results are 
260

calculated from electric motor cost and efficiency data that are modeled in the 

engineering analysis (section IV.C).

For each representative unit, the key outputs of the LCC analysis are a mean LCC 

savings and a median PBP relative to the base case, as well as the fraction of customers 

for which the LCC will decrease (net benefit), increase (net cost), or exhibit no change 

(no impact) relative to the base-case product forecast. No impacts occur when the basecase efficiency equals or exceeds the efficiency at a given TSL. Table V.2 through Table 

V.5 show the key shipment weighted average of results for the representative units in

each equipment class group.

Table V.2 Summary Life-Cycle Cost and Payback Period Results for Equipment 

Class Group 1

Trial Standard Level* 1 2 3 4

Efficiency Level 1 2 3 4

Customers with Net LCC 

Cost (%)** 0.3 8.4 38.0 84.6 

Customers with Net LCC 

Benefit (%)** 9.7 32.0 40.4 7.6 

Customers with No 

Change in LCC (%)** 90.0 59.6 21.5 7.7

Mean LCC Savings ($) 43 132 68 -417

Median PBP (Years) 1.1 3.3 6.7 29.9 

* The results for equipment class group 1 are the shipment weighted averages of the results for 

representative units 1, 2, and 3.

** Rounding may cause some items to not total 100 percent.

Table V.3 Summary Life-Cycle Cost and Payback Period Results for Equipment 

Class Group 2

Trial Standard Level* 1 2 3 4

Efficiency Level 1 1 2 2

Customers with Net LCC 

Cost (%)** 21.5 21.5 94.7 94.7 

Customers with Net LCC 

Benefit (%)** 68.6 68.6 5.3 5.3 

Customers with No Change 

in LCC (%)** 9.9 9.9 0.0 0.0

Mean LCC Savings ($) 38 38 -285 -285 
261

Median PBP (Years) 5.0 5.0 22.8 22.8 

* The results for equipment class group 2 are the shipment weighted averages of the results for 

representative units 4 and 5.

** Rounding may cause some items to not total 100 percent

Table V.4 Summary Life-Cycle Cost and Payback Period Results for Equipment 

Class Group 3

Trial Standard Level* 1 2 3 4

Efficiency Level 0 0 1 3

Customers with Net LCC 

Cost (%)** 0.0 0.0 81.7 100.0

Customers with Net LCC 

Benefit (%)** 0.0 0.0 0.0 0.0

Customers with No Change 

in LCC (%)** 0.0 0.0 18.3 0.0

Mean LCC Savings ($) N/A*** N/A*** -61 -763 

Median PBP (Years) N/A*** N/A*** 3,299 11,957 

* The results for equipment class group 3 are the shipment weighted averages of the results for 

representative units 6, 7, and 8.

** Rounding may cause some items to not total 100 percent

* **For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected.

Table V.5 Summary Life-Cycle Cost and Payback Period Results for Equipment 

Class Group 4

Trial Standard Level* 1 2 3 4

Efficiency Level 1 2 3 4

Customers with Net LCC 

Cost (%)** 1.0 10.8 33.1 79.6 

Customers with Net LCC 

Benefit (%)** 31.8 60.8 65.8 19.9 

Customers with No Change 

in LCC (%)** 67.3 28.4 1.1 0.3 

Mean LCC Savings ($) 137 259 210 -291 

Median PBP (Years) 1.2 1.9 3.7 16.0 

* The results for equipment class group 4 are the shipment weighted averages of the results for 

representative units 9 and 10.

** Rounding may cause some items to not total 100 percent

b. Consumer Subgroup Analysis

In the customer subgroup analysis, DOE estimated the LCC impacts of the 

electric motor TSLs on various groups of customers. Table V.6 and Table V.7 compare 

the weighted average mean LCC savings and median payback periods for ECG 1 at each 

TSL for different customer subgroups.
262

Chapter 11 of the TSD presents the detailed results of the customer subgroup 

analysis and results for the other equipment class groups.

Table V.6 Summary Life-Cycle Cost Results for Subgroups for Equipment Class 

Group 1: Average LCC savings

EL TSL

Average LCC Savings (2012$)*

Default

Low 

Energy 

Price

Small 

Business

Industrial 

Sector 

Only

Commercial 

Sector Only

Agricultural 

Sector Only

1 1 43 38 37 53 40 16

2 2 132 115 111 169 118 5

3 3 68 46 45 111 53 -103

4 4 -417 -447 -448 -356 -440 -675

* The results for equipment class group 1 are the shipment weighted averages of the results for 

representative units 1, 2, and 3.

Table V.7 Summary Life-Cycle Cost Results for Subgroups for Equipment Class 

Group 1: Median Payback Period

EL TSL

Median Payback Period

(years)*

Default

Low 

Energy 

Price

Small 

Business

Industrial 

Sector 

Only

Commercial 

Sector Only

Agricultural 

Sector Only

1 1 1.1 1.3 1.1 0.8 1.3 3.5 

2 2 3.3 3.7 3.3 2.1 3.9 7.0 

3 3 6.7 7.6 6.7 4.2 7.9 22.7 

4 4 29.9 33.7 29.9 18.8 34.7 123.5 

* The results for equipment class group 1 are the shipment weighted averages of the results for 

representative units 1, 2, and 3.

c. Rebuttable Presumption Payback

As discussed in section IV.F.12, EPCA establishes a rebuttable presumption that 

an energy conservation standard is economically justified if the increased purchase cost 

for equipment that meets the standard is less than three times the value of the first-year 

energy savings resulting from the standard. (42 U.S.C. 6295(o)(2)(B)(iii) and 6316(a)) 

DOE calculated a rebuttable-presumption PBP for each TSL to determine whether DOE 
263

could presume that a standard at that level is economically justified. DOE based the 

calculations on average usage profiles. As a result, DOE calculated a single rebuttablepresumption payback value, and not a distribution of PBPs, for each TSL. Table V.8

shows the rebuttable-presumption PBPs for the considered TSLs. The rebuttable 

presumption is fulfilled in those cases where the PBP is three years or less. However, 

DOE routinely conducts an economic analysis that considers the full range of impacts to 

the customer, manufacturer, Nation, and environment, as required under 42 U.S.C. 

6295(o)(2)(B)(i) as applied to equipment via 42 U.S.C. 6316(a). The results of that 

analysis serve as the basis for DOE to definitively evaluate the economic justification for 

a potential standard level (thereby supporting or rebutting the results of any three-year 

PBP analysis). Section V.C addresses how DOE considered the range of impacts to select 

today’s NOPR.

Table V.8 Rebuttable-Presumption Payback Periods (years) 

Trial Standard Level

1 2 3 4

Equipment Class Group 1* 0.6 0.8 1.2 4.3

Equipment Class Group 2* 1.8 1.8 8.0 8.0

Equipment Class Group 3* 0.0 0.0 900 5,464 

Equipment Class Group 4* 0.6 0.9 1.3 4.5

* The results for each equipment class group (ECG) are a shipment weighted average of results for the 

representative units in the group. ECG 1: Representative units 1, 2, and 3; ECG 2: Representative units 4 

and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units 9 and10.

2. Economic Impacts on Manufacturers

DOE performed an MIA to estimate the impact of new and amended energy 

conservation standards on manufacturers of electric motors. The section below describes 

the expected impacts on manufacturers at each TSL. Chapter 12 of the TSD explains the 

analysis in further detail.
264

The tables below depict the financial impacts (represented by changes in INPV) 

of new and amended energy conservation standards on manufacturers as well as the 

conversion costs that DOE estimates manufacturers would incur at each TSL. DOE 

displays the INPV impacts by TSL for each ECG in accordance with the grouping 

described in detail in section V.A. To evaluate the range of cash flow impacts on the 

electric motor industry, DOE modeled three markup scenarios that correspond to the 

range of anticipated market responses to new and amended standards. Each markup 

scenario results in a unique set of cash flows and corresponding industry value at each 

TSL. All three markup scenarios are presented below. In the following discussion, the 

INPV results refer to the difference in industry value between the base case and the 

standards case that result from the sum of discounted cash flows from the base year 

(2013) through the end of the analysis period. The results also discuss the difference in 

cash flow between the base case and the standards case in the year before the compliance 

date for new and amended energy conservation standards. This figure represents how 

large the required conversion costs are relative to the cash flow generated by the industry 

in the absence of new and amended energy conservation standards. In the engineering 

analysis, DOE enumerates common technology options that achieve the efficiencies for 

each of the representative units within an ECG. For descriptions of these technology 

options and the required efficiencies at each TSL, see section IV.C of today’s notice.
265

a. Industry Cash-Flow Analysis Results

The results below show three INPV tables representing the three markup 

scenarios used for the analysis. The first table reflects the flat markup scenario, which is 

the upper (less severe) bound of impacts. To assess the lower end of the range of 

potential impacts, DOE modeled two potential markup scenarios, a two-tiered markup 

scenario and a preservation of operating profit markup scenario. As discussed in section 

IV.J.2.d, the two-tiered markup scenario assumes manufacturers offer two different tiers 

of markups – one for lower efficiency levels and one for higher efficiency levels. 

Meanwhile the preservation of operating profit markup scenario assumes that in the 

standards case, manufacturers would be able to earn the same operating margin in 

absolute dollars in the standards case as in the base case. In general, the larger the product 

price increases, the less likely manufacturers are able to fully pass through additional 

costs due to standards calculated in the flat markup scenario.

Table V.9, Table V.10, and Table V.11 present the projected results for all electric 

motors under the flat, two-tiered and preservation of operating profit markup scenarios. 

DOE examined all four ECGs (Design A and B motors, Design C motors, fire pump 

motors, and brake motors) together. The INPV results follow in the tables below.
266

Table V.9 Manufacturer Impact Analysis for Electric Motors—Flat Markup 

Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4

INPV (2012$ millions) $3,371.2 $3,378.

7

$3,759.

2

$4,443.

7 $5,241.3

Change in INPV (2012$ millions) - $7.5 $388.0 $1,072.

5 $1,870.1

(%) - 0.2% 11.5% 31.8% 55.5%

Product 

Conversion Costs (2012$ millions) - $6.1 $57.4 $611.7 $620.6

Capital 

Conversion Costs (2012$ millions) - $0.0 $26.4 $220.5 $699.8

Total Conversion 

Costs (2012$ millions) - $6.2 $83.7 $832.3 $1,320.4

Table V.10 Manufacturer Impact Analysis for Electric Motors—Two-Tiered 

Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4

INPV (2012$ millions) $3,371.2 $3,374.

3

$3,087.

6

$2,979.

6 $3,335.7

Change in INPV (2012$ millions) - $3.2 $(283.5

)

$(391.6

) $(35.5)

(%) - 0.1% -8.4% -11.6% -1.1%

Product 

Conversion Costs (2012$ millions) - $6.1 $57.4 $611.7 $620.6

Capital 

Conversion Costs (2012$ millions) - $0.0 $26.4 $220.5 $699.8

Total Conversion 

Costs (2012$ millions) - $6.2 $83.7 $832.3 $1,320.4
267

Table V.11 Manufacturer Impact Analysis for Electric Motors—Preservation of 

Operating Profit Markup Scenario

Units Base 

Case

Trial Standard Level

1 2 3 4

INPV (2012$ millions) $3,371.2 $3,019.

5

$3,089.

7

$2,356.

8 $1,383.1

Change in INPV (2012$ millions) - $(351.7

)

$(281.5

)

$(1,014

.4)

$(1,988.1

)

(%) - -10.4% -8.4% -30.1% -59.0%

Product 

Conversion Costs (2012$ millions) - $6.1 $57.4 $611.7 $620.6

Capital 

Conversion Costs (2012$ millions) - $0.0 $26.4 $220.5 $699.8

Total Conversion 

Costs (2012$ millions) - $6.2 $83.7 $832.3 $1,320.4

TSL 1 represents EL 1 for ECG 1, ECG 2 and ECG 4 motors and baseline for 

ECG 2 motors. At TSL 1, DOE estimates impacts on INPV to range from $7.5 million to 

-$351.7 million, or a change in INPV of 0.2 percent to -10.4 percent. At this proposed 

level, industry free cash flow is estimated to decrease by approximately 1.1 percent to 

$164.9 million, compared to the base case value of $166.7 million in the year leading up 

to the proposed energy conservation standards.

The INPV impacts at TSL 1 range from slightly positive to moderately negative, 

however DOE does not anticipate that manufacturers would lose a significant portion of 

their INPV at this TSL. This is because the vast majority of shipments already meets or 

exceeds the efficiency levels prescribed at TSL 1. DOE estimates that in the year of 

compliance, 90 percent of all electric motor shipments (90 percent of ECG 1, eight 

percent of ECG 2, 100 percent of ECG 3, and 67 percent of ECG 4 shipments) would 

meet the efficiency levels at TSL 1 or higher in the base case. Since ECG 1 shipments 

account for over 97 percent of all electric motor shipments the effects on those motors are 
268

the primary driver for the impacts at this TSL. Only a few ECG 1 shipments not currently 

covered by the existing electric motors rule and a small amount of ECG 2 and ECG 4 

shipments would need to be converted at TSL 1 to meet this efficiency standard.

DOE expects conversion costs to be small compared to the industry value because 

most of the electric motor shipments, on a volume basis, already meet the efficiency 

levels analyzed at this TSL. DOE estimates product conversion costs of $6.1 million due 

to the proposed expanded scope of this rulemaking which includes motors previously not 

covered by the current electric motor energy conservation standards. DOE believes that at 

this TSL, there will be some engineering costs as well as testing and certification costs 

associated with this proposed scope expansion. DOE estimates the capital conversion 

costs to be minimal at TSL 1. This is mainly because almost all manufacturers currently 

produce some motors that are compliant at TSL 1 efficiency levels and it would not be 

much of a capital investment to bring all motor production to this efficiency level.

TSL 2 represents EL 2 for ECG 1 and ECG 4 motors; EL 1 for ECG 2 motors; 

and baseline for ECG 3 motors. At TSL 2, DOE estimates impacts on INPV to range 

from $388 million to -$283.5 million, or a change in INPV of 11.5 percent to -8.4

percent. At this proposed level, industry free cash flow is estimated to decrease by 

approximately 17.2 percent to $138 million, compared to the base case value of $166.7

million in the year leading up to the proposed energy conservation standards.
269

The INPV impacts at TSL 2 range from moderately positive to moderately 

negative. DOE estimates that in the year of compliance, 59 percent of all electric motor 

shipments (60 percent of ECG 1, eight percent of ECG 2, 100 percent of ECG 3, and 30 

percent of ECG 4 shipments) would meet the efficiency levels at TSL 2 or higher in the 

base case. The majority of shipments are currently covered by an electric motors standard 

that requires general purpose Design A and B motors to meet this TSL. Therefore, only 

previously non-covered Design A and B motors and a few ECG 2 and ECG 4 motors 

would have to be converted at TSL 2 to meet this efficiency standard.

DOE expects conversion costs to increase significantly from TSL 1, however,

these conversion costs do not represent a large portion of the base case INPV, since again 

the majority of electric motor shipments already meet the efficiency levels analyzed at 

this TSL. DOE estimates product conversion costs of $57.4 million due to the proposed 

expanded scope of this rulemaking, which includes motors previously not covered by the 

current electric motor energy conservation standards and the inclusion of ECG 2 and 

ECG 4 motors. DOE believes there will be sizable engineering costs as well as testing 

and certification costs at this TSL associated with this proposed scope expansion. DOE 

estimates the capital conversion costs to be approximately $26.4 million at TSL 2. While 

most manufacturers already produce at least some motors that are compliant at TSL 2, 

these manufacturers would likely have to invest in expensive machinery to bring all 

motor production to these efficiency levels.
270

TSL 3 represents EL 3 for ECG 1 and ECG 4 motors, EL 2 for ECG 2 motors and 

EL 1 for ECG 3 motors. At TSL 3, DOE estimates impacts on INPV to range from 

$1,072.5 million to -$1,014.4 million, or a change in INPV of 31.8 percent to -30.1

percent. At this proposed level, industry free cash flow is estimated to decrease by 

approximately 167.5 percent to -$112.5 million, compared to the base case value of 

$166.7 million in the year leading up to the proposed energy conservation standards.

The INPV impacts at TSL 3 range from significantly positive to significantly 

negative. DOE estimates that in the year of compliance, 23 percent of all electric motor 

shipments (24 percent of ECG 1, less than one percent of ECG 2, 19 percent of ECG 3, 

and four percent of ECG 4 shipments) would meet the efficiency levels at TSL 3 or 

higher in the base case. The majority of shipments would need to be converted to meet 

energy conservation standards at this TSL.

DOE expects conversion costs to increase significantly at TSL 3 and become a 

substantial investment for manufacturers. DOE estimates product conversion costs of 

$611.7 million at TSL 3, since most electric motors in the base case do not exceed the 

current motor standards set at NEMA Premium for Design A and B motors, which 

represent EL 2 for ECG 1. DOE believes there would be a massive reengineering effort 

that manufacturers would have to undergo to have all motors meet this TSL. 

Additionally, motor manufacturers would have to increase the efficiency levels for ECG 

2, ECG 3, and ECG 4 motors. DOE estimates the capital conversion costs to be 

approximately $220.5 million at TSL 3. Most manufacturers would have to make 
271

significant investments to their production facilities in order to convert all their motors to 

be compliant at TSL 3.

TSL 4 represents EL 4 for ECG 1 and ECG 4 motors, EL 3 for ECG 3 motors and 

EL 2 for ECG 2 motors. At TSL 4, DOE estimates impacts on INPV to range from 

$1,870.1 million to -$1,988.1 million, or a change in INPV of 55.5 percent to -59.0

percent. At this proposed level, industry free cash flow is estimated to decrease by 

approximately 298.4 percent to -$330.8 million, compared to the base case value of 

$166.7 million in the year leading up to the proposed energy conservation standards.

The INPV impacts at TSL 4 range from significantly positive to significantly 

negative. DOE estimates that in the year of compliance only eight percent of all electric 

motor shipments (nine percent of ECG 1, less than one percent of ECG 2, zero percent of 

ECG 3, and less than one percent of ECG 4 shipments) would meet the efficiency levels 

at TSL 2 or higher in the base case. Almost all shipments would need to be converted to 

meet energy conservation standards at this TSL.

DOE expects conversion costs again to increase significantly from TSL 3 to 

TSL 4. Conversion costs at this TSL now represent a massive investment for electric 

motor manufacturers. DOE estimates product conversion costs of $620.6 million at 

TSL 4, which are the same conversion costs at TSL 3. DOE believes that manufacturers 

would need to completely reengineer almost all electric motors sold as well as test and 

certify those motors. DOE estimates capital conversion costs of $699.8 million at TSL 4. 
272

This is a significant increase in capital conversion costs from TSL 3 since manufacturers 

would need to adopt copper die-casting at this TSL. This technology requires a 

significant level of investment because the majority of the machinery would need to be 

replaced or significantly modified.

b. Impacts on Employment

DOE quantitatively assessed the impact of potential new and amended energy 

conservation standards on direct employment. DOE used the GRIM to estimate the 

domestic labor expenditures and number of domestic production workers in the base case 

and at each TSL from the announcement of any potential new and amended energy 

conservation standards in2013 to the end of the analysis period in 2044. DOE used 

statistical data from the U.S. Census Bureau’s 2011 Annual Survey of Manufacturers 

(ASM), the results of the engineering analysis, and interviews with manufacturers to 

determine the inputs necessary to calculate industry-wide labor expenditures and 

domestic employment levels. Labor expenditures involved with the manufacturing of 

electric motors are a function of the labor intensity of the product, the sales volume, and 

an assumption that wages remain fixed in real terms over time.

In the GRIM, DOE used the labor content of each product and the manufacturing 

production costs to estimate the annual labor expenditures of the industry. DOE used 

Census data and interviews with manufacturers to estimate the portion of the total labor 

expenditures attributable to domestic labor.
273

The production worker estimates in this employment section cover only workers 

up to the line-supervisor level who are directly involved in fabricating and assembling an 

electric motor within a motor facility. Workers performing services that are closely 

associated with production operations, such as material handling with a forklift, are also 

included as production labor. DOE’s estimates account for only production workers who 

manufacture the specific equipment covered by this rulemaking. For example, a worker 

on an electric motor line manufacturing a fractional horsepower motor (i.e. a motor with 

less than one horsepower) would not be included with this estimate of the number of 

electric motor workers, since fractional motors are not covered by this rulemaking.

The employment impacts shown in the tables below represent the potential 

production employment impact resulting from new and amended energy conservation 

standards. The upper bound of the results estimates the maximum change in the number 

of production workers that could occur after compliance with new and amended energy 

conservation standards when assuming that manufacturers continue to produce the same 

scope of covered equipment in the same production facilities. It also assumes that 

domestic production does not shift to lower-labor-cost countries. Because there is a real 

risk of manufacturers evaluating sourcing decisions in response to new and amended 

energy conservation standards, the lower bound of the employment results includes the 

estimated total number of U.S. production workers in the industry who could lose their 

jobs if all existing production were moved outside of the U.S. While the results present a 

range of employment impacts following 2015, the sections below also include qualitative 

discussions of the likelihood of negative employment impacts at the various TSLs. 
274

Finally, the employment impacts shown are independent of the indirect employment 

impacts from the broader U.S. economy, which are documented in chapter 16 of the 

NOPR TSD.

Based on 2011 ASM data and interviews with manufacturers, DOE estimates 

approximately 60 percent of electric motors sold in the U.S. are manufactured 

domestically. Using this assumption, DOE estimates that in the absence of new and 

amended energy conservation standards, there would be approximately 7,237 domestic 

production workers involved in manufacturing all electric motors covered by this 

rulemaking in 2015. The table below shows the range of potential impacts of new and 

amended energy conservation standards for all ECGs on U.S. production workers in the 

electric motor industry. However, because ECG 1 motors comprise more than 97 percent 

of the electric motors covered by this rulemaking, DOE believes that potential changes in 

domestic employment will be driven primarily by the standards that are selected for ECG 

1, Design A and B electric motors.

Table V.12 Potential Changes in the Total Number of All Domestic Electric Motor 

Production Workers in 2015

Base Case Trial Standard Level

1 2 3 4

Total Number of Domestic 

Production Workers in 2015

(without changes in production 

locations)

7,237 7,270 7,420 8,287 15,883

Potential Changes in Domestic 

Production Workers in 2015* 33 - 0 183 -(362)

1,050 -

(3,619)

8,646 -

(7,237)

* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative 

numbers.
275

Most manufacturers agree that any standards that involve expanding the scope of 

equipment required to meet NEMA Premium would not significantly change domestic 

employment levels. At this efficiency level (TSL 2),, manufacturers would not be 

required to make major modifications to their production lines nor would they have to 

undertake new manufacturing processes. A few small business manufacturers who 

primarily make electric motors currently out of the scope of coverage, but whose 

equipment would be covered by new electric motor standards, could be impacted by 

efficiency standards at TSL 2. These impacts, including employment impacts, are 

discussed in section VI.B of today’s NOPR. Overall, DOE believes there would not be a 

significant decrease in domestic employment levels at TSL 2. DOE created a lower 

bound of the potential loss of domestic employment at 362 employees for TSL 2. DOE 

estimated only five percent of the electric motors market is comprised of manufacturers 

that do not currently produce any motors at NEMA Premium efficiency levels. DOE 

estimated that at most five percent of domestic electric motor manufacturing could 

potentially move abroad or exit the market entirely. DOE similarly estimated that all 

electric motor manufacturers produce some electric motors at or above TSL 1 efficiency 

levels. Therefore, DOE does not believe that any potential loss of domestic employment 

would occur at TSL 1.

Manufacturers, however, cautioned that any standard set above NEMA Premium 

would require major changes to production lines, large investments in capital and labor, 

and would result in extensive stranded assets. This is largely because manufacturers 

would have to design and build motors with larger frame sizes and could potentially have 
276

to use copper, rather than aluminum rotors. Several manufacturers pointed out that this 

would require extensive retooling, vast engineering resources, and would ultimately 

result in a more labor-intensive production process. Manufacturers generally agreed that a 

shift toward copper rotors would have uncertain impacts on energy efficiency and would 

cause companies to incur higher labor costs. These factors could cause manufacturers to 

consider moving production offshore to reduce labor costs or they may choose to exit the 

market entirely. Therefore, DOE believes it is more likely that efficiency standards set 

above NEMA Premium could result in a decrease of labor. Accordingly, DOE set the 

lower bound on the potential loss of domestic employment at 50 percent of the existing 

domestic labor market for TSL 3 and 100 percent of the domestic labor market for TSL 4. 

However, these values represent the worst case scenario DOE modeled. Manufacturers 

also stated that larger motor manufacturing (that is for motors above 200 horsepower) 

would be very unlikely to move abroad since the shipping costs associated with those 

motors are very large. Consequently, DOE does not currently believe standards set at 

TSL 3 and TSL 4 would likely result in a large loss of domestic employment.

c. Impacts on Manufacturing Capacity

Most manufacturers agreed that any standard expanding the scope of equipment 

required to meet NEMA Premium would not have a significant impact on manufacturing 

capacity. Manufacturers pointed out, however, that a standard that required them to use 

copper rotors would severely disrupt manufacturing capacity. Most manufacturers 

emphasized they do not currently have the machinery, technology, or engineering 

resources to produce copper rotors in-house. Some manufacturers claim that the few 
277

manufacturers that do have the capability of producing copper rotors are not able to 

produce these motors in volumes sufficient to meet the demands of their customers. For 

manufacturers to either completely redesign their motor production lines or significantly 

expand their fairly limited copper rotor production line would require a massive retooling 

and engineering effort, which could take several years to complete. Most manufacturers 

stated they would have to outsource copper rotor production because they would not be 

able to modify their facilities and production processes to produce copper rotors in-house 

within a three year time period. Most manufacturers agreed that outsourcing rotor die 

casting would constrain capacity by creating a bottleneck in rotor production, as there are 

very few companies that produce copper rotors.

Manufacturers also pointed out that there is substantial uncertainty surrounding 

the global availability and price of copper, which has the potential to constrain capacity. 

Several manufacturers expressed concern that the combination of all of these factors 

would make it difficult to support existing business while redesigning product lines and 

retooling. The need to support existing business would also cause the redesign effort to 

take several years.

In summary, for those TSLs that require copper rotors, DOE believes there is a 

likelihood of capacity constraints in the near term due to fluctuations in the copper 

market and limited copper die casting machinery and expertise. However, for the levels 

proposed in this rule, DOE does not foresee any capacity constraints.
278

d. Impacts on Sub-Group of Manufacturers

Using average cost assumptions to develop an industry cash-flow estimate may 

not be adequate for assessing differential impacts among manufacturer subgroups. Small 

manufacturers, niche equipment manufacturers, and manufacturers exhibiting cost 

structures substantially different from the industry average could be affected 

disproportionately. DOE analyzed the impacts to small businesses in section VI.B and did 

not identify any other adversely impacted electric motor-related subgroups for this 

rulemaking based on the results of the industry characterization.

e. Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of recent or impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. In addition 

to energy conservation standards, other regulations can significantly affect 

manufacturers’ financial operations. Multiple regulations affecting the same 

manufacturer can strain profits and lead companies to abandon product lines or markets 

with lower expected future returns than competing equipment. For these reasons, DOE 

conducts an analysis of cumulative regulatory burden as part of its rulemakings 

pertaining to appliance efficiency.

During previous stages of this rulemaking, DOE identified a number of 

requirements, in addition to new and amended energy conservation standards for electric 
279

motors, that manufacturers will face for equipment they manufacture approximately three 

years prior to and three years after the compliance date of the new and amended 

standards. The following section briefly addresses comments DOE received with respect 

to cumulative regulatory burden and summarizes other key related concerns that 

manufacturers raised during interviews.

Several manufacturers expressed concern about the compliance date of this 

rulemaking to the proximity of the 2015 compliance date for the small electric motors 

rulemaking at 75 FR 10874 (March 9, 2010). Most manufacturers of electric motors 

covered by this rulemaking also produce electric motors that are covered by the small 

electric motors rulemaking. Manufacturers stated that adopting these two regulations in a 

potentially short timeframe could strain R&D and capital expenditure budgets for motor 

manufacturers. Some manufacturers also raised concerns about other existing regulations 

separate from DOE’s energy conservation standards that electric motors must meet: the 

National Fire Protection Association (NFPA) 70, National Electric Code; the NFPA 20, 

Standard for the Installation of Stationary Pumps for Fire Protection; and Occupational 

Safety and Health Administration (OSHA) regulations. DOE discusses these and other 

requirements in chapter 12 of the NOPR TSD. DOE takes into account the cost of 

compliance with other published Federal energy conservation standards in weighing the 

benefits and burdens of today’s proposed rulemaking. In the 2010 small motors final rule, 

DOE estimated that manufacturers may lose up to 11.3 percent of their INPV, which was

approximately $39.5 million, in 2009$. To see the range of impacts DOE estimated for 

the small motors rule, see chapter 12 of the NOPR TSD. DOE does not describe the Comment [A31]: Change recommended by 

OIRA.
280

quantitative impacts of standards that have not yet been finalized because any impacts 

would be highly speculative. DOE also notes that certain standards are optional for 

manufacturers and takes that into account when creating the cumulative regulatory 

burden analysis.

3. National Impact Analysis

a. Significance of Energy Savings

For each TSL, DOE projected energy savings for electric motors purchased in the 

30-year period that begins in the year of compliance with new and amended standards 

(2015–2044). The savings are measured over the entire lifetime of equipment purchased 

in the 30-year period. DOE quantified the energy savings attributable to each TSL as the 

difference in energy consumption between each standards case and the base case. Table 

V.13 presents the estimated primary energy savings for each considered TSL, and Table 

V.14 presents the estimated FFC energy savings for each considered TSL. The approach 

for estimating national energy savings is further described in section IV.H.
281

Table V.13 Cumulative Primary Energy Savings for Electric Motors Trial Standard 

Levels for Units Sold in 2015 –2044

Equipment Class

Trial Standard Level

1 2 3 4

Group 1 

quads

(NEMA Design A and B) 0.82 6.27 9.86 12.64

Group 2

(NEMA Design C) 0.02 0.02 0.03 0.03

Group 3

(Fire Pump Electric Motors) 0.00 0.00 0.00 0.00

Group 4 

(Brake Motors) 0.26 0.58 0.71 0.81

Total All Classes 1.10 6.87 10.60 13.49

Table V.14 Cumulative Full-Fuel-Cycle Energy Savings for Electric Motors Trial 

Standard Levels for Units Sold in 2015 –2044

Equipment Class

Trial Standard Level

1 2 3 4

Group 1 

quads

(NEMA Design A and B) 0.83 6.38 10.02 12.85

Group 2

(NEMA Design C) 0.02 0.02 0.03 0.03

Group 3

(Fire Pump Electric Motors) 0.00 0.00 0.00 0.00

Group 4 

(Brake Motors) 0.26 0.59 0.73 0.83

Total All Classes 1.11 6.98 10.78 13.71

Circular A-4 requires agencies to present analytical results, including separate 

schedules of the monetized benefits and costs that show the type and timing of benefits 

and costs. Circular A-4 also directs agencies to consider the variability of key elements 

underlying the estimates of benefits and costs. For this rulemaking, DOE undertook a 

sensitivity analysis using nine rather than 30 years of equipment shipments. The choice of 

Comment [A32]: Change recommended by 

OIRA.
282

a nine-year period is a proxy for the timeline in EPCA for the review of certain energy 

conservation standards and potential revision of and compliance with such revised 

standards.87

Table V.15

 ThisWe would note that the review timeframe mayestablished in EPCA 

generally does not be statistically relevant with regard tooverlap with the equipment 

lifetime, equipment manufacturing cycles or other factors specific to electric motors. 

Thus, this information is presented for informational purposes only and is not indicative 

of any change in DOE’s analytical methodology. The NES results based on a 9-year 

analytical period are presented in . The impacts are counted over the lifetime 

of electric motors purchased in 2015–2023.

Table V.15 Cumulative National Energy Savings for Electric Motors Trial Standard 

Levels for Units Sold in 2015–2023

Equipment Class

Trial Standard Level

1 2 3 4

Group 1 

quads

(NEMA Design A and B) 0.355 1.440 2.168 2.833

Group 2

(NEMA Design C) 0.004 0.004 0.006 0.006

Group 3

(Fire Pump Electric Motors) 0.000 0.000 0.000 0.000

Group 4 

(Brake Motors) 0.060 0.125 0.152 0.176

Total All Classes 0.420 1,569 2.326 3.015

 87 EPCA requires DOE to review its standards at least once every 6 years, and requires, for certain 

products, a 3-year period after any new standard is promulgated before compliance is required, except that 

in no case may any new standards be required within 6 years of the compliance date of the previous 

standards. While adding a 6-year review to the 3-year compliance period adds up to 9 years, DOE notes 

that it may undertake reviews at any time within the 6 year period and that the 3-year compliance date may 

yield to the 6-year backstop. A 9-year analysis period may not be appropriate given the variability that 

occurs in the timing of standards reviews and the fact that for some consumer products, the compliance 

period is 5 years rather than 3 years.

Comment [A33]: Change recommended by 

OIRA.
283

b. Net Present Value of Customer Costs and Benefits

DOE estimated the cumulative NPV of the total costs and savings for customers 

that would result from the TSLs considered for electric motors. In accordance with 

OMB’s guidelines on regulatory analysis,88 DOE calculated the NPV using both a 7-

percent and a 3-percent real discount rate. The 7-percent rate is an estimate of the average 

before-tax rate of return on private capital in the U.S. economy, and reflects the returns 

on real estate and small business capital as well as corporate capital. This discount rate 

approximates the opportunity cost of capital in the private sector (OMB analysis has 

found the average rate of return on capital to be near this rate). The 3-percent rate reflects 

the potential effects of standards on private consumption (e.g., through higher prices for 

equipment and reduced purchases of energy). This rate represents the rate at which 

society discounts future consumption flows to their present value. It can be approximated 

by the real rate of return on long-term government debt (i.e., yield on United States 

Treasury notes), which has averaged about 3 percent for the past 30 years.

Table V.16 shows the customer NPV results for each TSL considered for electric 

motors. In each case, the impacts cover the lifetime of equipment purchased in 2015–

2044. 

 88 OMB Circular A-4, section E (Sept. 17, 2003). http://www.whitehouse.gov/omb/circulars_a004_a-4. 
284

Table V.16 Net Present Value of Customer Benefits for Electric Motors Trial 

Standard Levels for Units Sold in 2015–2044

Discount 

Rate %

Trial Standard Level

Equipment Class 1 2 3 4

Group 1

billion 2012$

(NEMA Design A and B)

3%

4.5 20.7 1.5 -41.2

Group 2

(NEMA Design C) 0.0 0.0 0.0 0.0

Group 3

(Fire Pump Electric Motors) 0.0 0.0 0.0 0.0

Group 4

(Brake Motors) 1.3 2.5 1.5 -1.2

Total All Classes 5.8 23.3 3.0 -42.4

Group 1

(NEMA Design A and B)

7%

2.2 7.7 -3.7 -29.1

Group 2

(NEMA Design C) 0.0 0.0 0.0 0.0

Group 3

(Fire Pump Electric Motors) 0.0 0.0 0.0 0.0

Group 4

(Brake Motors) 0.5 1.0 0.3 -1.2

Total All Classes 2.7 8.7 -3.4 -30.3

The NPV results based on the afore-mentioned 9-year analytical period are 

presented in Table V.17. The impacts are counted over the lifetime of equipment 

purchased in 2015–2023. As mentioned previously, this information is presented for 

informational purposes only and is not indicative of any change in DOE’s analytical 

methodology or decision criteria. 
285

Table V.17 Net Present Value of Customer Benefits for Electric Motors Trial 

Standard Levels for Units Sold in 2015–2023

Discount 

Rate %

Trial Standard Level

Equipment Class 1 2 3 4

Group 1

billion 2012$

(NEMA Design A and B)

3%

2.253 6.473 2.541 -12.055

Group 2

(NEMA Design C) 0.011 0.011 -0.012 -0.012

Group 3

(Fire Pump Electric 

Motors)

0.000 0.000 -0.001 -0.009

Group 4

(Brake Motors) 0.389 0.706 0.495 -0.372

Total All Classes 2.654 7.190 3.023 -12.448

Group 1

(NEMA Design A and B)

7%

1.344 3.492 -0.102 -12.017

Group 2

(NEMA Design C) 0.005 0.005 -0.016 -0.016

Group 3

(Fire Pump Electric 

Motors)

0.000 0.000 -0.001 -0.007

Group 4

(Brake Motors) 0.225 0.391 0.201 -0.498

Total All Classes 1.574 3.887 0.083 -12.537

c. Indirect Impacts on Employment

DOE expects energy conservation standards for electric motors to reduce energy 

costs for equipment owners, and the resulting net savings to be redirected to other forms 

of economic activity. Those shifts in spending and economic activity could affect the 

demand for labor. As described in section IV.N, DOE used an input/output model of the 

U.S. economy to estimate indirect employment impacts of the TSLs that DOE considered 

in this rulemaking. DOE understands that there are uncertainties involved in projecting 

employment impacts, especially changes in the later years of the analysis. Therefore, 
286

DOE generated results for near-term time frames (2015–2019), where these uncertainties 

are reduced. 

The results suggest that today’s standards are likely to have negligible impact on 

the net demand for labor in the economy. The net change in jobs is so small that it would 

be imperceptible in national labor statistics and might be offset by other, unanticipated 

effects on employment. Chapter 16 of the NOPR TSD presents detailed results.

4. Impact on Utility or Performance

DOE believes that the standards it is proposing today will not lessen the utility or 

performance of electric motors. 

5. Impact of Any Lessening of Competition

DOE has also considered any lessening of competition that is likely to result from 

new and amended standards. The Attorney General determines the impact, if any, of any 

lessening of competition likely to result from a proposed standard, and transmits such 

determination to the Secretary, together with an analysis of the nature and extent of such 

impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii))

To assist the Attorney General in making such determination, DOE will provide 

DOJ with copies of this NOPR and the TSD for review. DOE will consider DOJ’s 

comments on the proposed rule in preparing the final rule, and DOE will publish and 

respond to DOJ’s comments in that document.
287

6. Need of the Nation to Conserve Energy

Enhanced energy efficiency, where economically justified, improves the Nation’s 

energy security, strengthens the economy, and reduces the environmental impacts or 

costs of energy production. Reduced electricity demand due to energy conservation 

standards is also likely to reduce the cost of maintaining the reliability of the electricity 

system, particularly during peak-load periods. As a measure of this reduced demand, 

chapter 15 in the NOPR TSD presents the estimated reduction in generating capacity in 

2044 for the TSLs that DOE considered in this rulemaking.

Energy savings from standards for electric motors could also produce 

environmental benefits in the form of reduced emissions of air pollutants and greenhouse 

gases associated with electricity production. Table V.18 provides DOE’s estimate of 

cumulative emissions reductions projected to result from the TSLs considered in this 

rulemaking. DOE reports annual emissions reductions for each TSL in chapter 13 of the 

NOPR TSD.
288

Table V.18 Cumulative Emissions Reduction Estimated for Electric Motors Trial 

Standard Levels 

Trial Standard Level

1 2 3 4

Primary Energy Emissions

CO2 (million metric tons) 62.4 374.1 576.0 733.3 

NOX (thousand tons) 105.3 669.7 1,034.7 1,315.5 

SO2 (thousand tons) 33.5 196.3 301.9 384.5 

Hg (tons) 0.1 0.8 1.3 1.6 

N2O (thousand tons) 1.2 8.3 12.9 16.4 

CH4 (thousand tons) 7.3 46.3 71.6 91.0 

Upstream Emissions

CO2 (million metric tons) 3.5 22.0 34.0 43.2 

NOX (thousand tons) 0.8 4.7 7.3 9.3 

SO2 (thousand tons) 48.6 303.1 467.8 595.0 

Hg (tons) 0.0 0.0 0.0 0.0 

N2O (thousand tons) 0.0 0.2 0.3 0.4 

CH4 (thousand tons) 294.8 1,841.4 2,841.9 3,614.6 

Total Emissions

CO2 (million metric tons) 65.9 396.1 610.0 776.5 

NOX (thousand tons) 106.0 674.4 1,042.0 1,324.8 

SO2 (thousand tons) 82.1 499.4 769.6 979.5 

Hg (tons) 0.1 0.8 1.3 1.6 

N2O (thousand tons) 1.3 8.5 13.2 16.8 

CH4 (thousand tons) 302.2 1,887.7 2,913.5 3,705.5 

As part of the analysis for this rule, DOE estimated monetary benefits likely to 

result from the reduced emissions of CO2 and NOX that DOE estimated for each of the 

TSLs considered. As discussed in section IV.L, DOE used values for the SCC developed 

by an interagency process. The four sets of SCC values resulting from that process 

(expressed in 2012$) are represented by $12.9/metric ton (the average value from a 

distribution that uses a 5-percent discount rate), $40.8/metric ton (the average value from 

a distribution that uses a 3-percent discount rate), $62.2/metric ton (the average value 
289

from a distribution that uses a 2.5-percent discount rate), and $117.0/metric ton (the 95thpercentile value from a distribution that uses a 3-percent discount rate). These values 

correspond to the value of emission reductions in 2015; the values for later years are 

higher due to increasing damages as the projected magnitude of climate change increases. 

Table V.19 presents the global value of CO2 emissions reductions at each TSL. 

For each of the four cases, DOE calculated a present value of the stream of annual values 

using the same discount rate as was used in the studies upon which the dollar-per-ton 

values are based. DOE calculated domestic values as a range from 7 percent to 23 percent 

of the global values, and these results are presented in chapter 14 of the NOPR TSD.
290

Table V.19 Estimates of Global Present Value of CO2 Emissions Reduction under 

Electric Motors Trial Standard Levels

TSL

SCC Case*

5% discount 

rate, 

average*

3% discount 

rate, average*

2.5% discount 

rate, average*

3% discount 

rate, 95th

percentile*

Primary Energy Emissions

Million 2012$

1 435 433 1,985 961 3,152 113 6,069 040

2 2,380 366 11,293 179 18,090 17,876 34,702 552

3 3,643 622 17,332 159 27,779 452 53,276 047

4 4,649 622 22,093 21,871 35,403 34,985 67,902 609

Upstream Emissions

1 24 111 110 177 174 340 338

2 137 136 657 650 1,054 042 2,021 012

3 210 209 1,010 001 1,623 604 3,110 097

4 268 266 1,287 274 2,066 042 3,959 943

Total Emissions

1 459 457 2,096 071 3,329 287 6,409 378

2 2,517 502 11,949 829 19,144 18,918 36,723 564

3 3,853 831 18,342 159 29,401 056 56,385 143

4 4,917 888 23,379 145 37,468 027 71,861 552

* For each of the four cases, the corresponding SCC value for emissions in 2015 is 

$12.9, $4011.8, $6239.7, $61.2, and $117.0 per metric ton (2012$).

DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other greenhouse gas (GHG) emissions to changes in the future global 

climate and the potential resulting damages to the world economy continues to evolve 

rapidly. Thus, any value placed on reducing CO2 emissions in this rulemaking is subject 

to change. DOE, together with other Federal agencies, will continue to review various 

methodologies for estimating the monetary value of reductions in CO2 and other GHG 

emissions. This ongoing review will consider the comments on this subject that are part 

of the public record for this and other rulemakings, as well as other methodological 

Comment [A34]: Values and footnote updated to 

reflect revised Social Cost of Carbon values 

announced by OIRA on Nov. 1, 2013.
291

assumptions and issues. However, consistent with DOE’s legal obligations, and taking 

into account the uncertainty involved with this particular issue, DOE has included in this 

proposed rule the most recent values and analyses resulting from the ongoing interagency 

review process.

DOE also estimated a range for the cumulative monetary value of the economic 

benefits associated with NOX emissions reductions anticipated to result from new and 

amended standards for electric motors. The low and high dollar-per-ton values that DOE 

used are discussed in section IV.L present the cumulative present values for each TSL 

calculated using seven-percent and three-percent discount rates.

Table V.20 Estimates of Present Value of NOX Emissions Reduction under Electric 

Motors Trial Standard Levels

TSL 3% discount rate 7% discount rate

Power Sector Emissions

Million 2012$

1 49.5 26.4 

2 257.1 120.2 

3 392.2 181.6 

4 501.3 233.2 

Upstream Emissions

1 68.0 33.8 

2 378.4 164.8 

3 579.9 250.3 

4 739.7 320.6 

Total Emissions

1 117.5 60.2 

2 635.4 285.0 

3 972.2 432.0 

4 1,241.0 553.8 
292

7. Summary of National Economic Impacts

The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the customer savings calculated for each TSL 

considered in this rulemaking. Table V.21 presents the NPV values that result from 

adding the estimates of the potential economic benefits resulting from reduced CO2 and 

NOX emissions in each of four valuation scenarios to the NPV of customer savings 

calculated for each TSL considered in this rulemaking, at both a seven-percent and threepercent discount rate. The CO2 values used in the columns of each table correspond to the 

four sets of SCC values discussed above.

Table V.21 Net Present Value of Customer Savings Combined with Net Present 

Value of Monetized Benefits from CO2 and NOX Emissions Reductions 

TSL

Customer NPV at 3% Discount Rate added with:

SCC Case 

$12.911.8/metric 

ton CO2

* and Low 

Value for NOX

**

SCC Case 

$40.839.7/metric 

ton CO2

* and 

Medium Value for 

NOX

**

SCC Case 

$6261.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Case 

$117.0/metric ton 

CO2

* and High Value 

for NOX

**

1

Billion 2012$

6.3 8.0 9.32 12.54

2 25.9 35.97 43.042.8 61.10

3 7.0 22.31 33.30 61.160.9

4 -37.3 -17.818.0 -3.74.1 31.74

TSL

Customer NPV at 7% Discount Rate added with:

SCC Case 

$12.911.8/metric 

ton CO2

* and Low 

Value for NOX

**

SCC Case 

$40.839.7/metric 

ton CO2

* and 

Medium Value for 

NOX

**

SCC Case 

$6261.2/metric ton 

CO2

* and Medium 

Value for NOX

**

SCC Case 

$117.0/metric ton 

CO2

* and High Value 

for NOX

**

1

Billion 2012$

3.2 4.98 6.1 9.2

2 11.2 20.98 28.127.9 45.97

3 0.5 15.42 26.41 53.85

4 -25.3 -6.46 7.73 42.63 * These label values represent the global SCC in 2015, in 2012$. 

** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton, 

and High Value corresponds to $4,809 per ton.

Comment [A35]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
293

Although adding the value of customer savings to the values of emission 

reductions provides a valuable perspective, two issues should be considered. First, the 

national operating cost savings are domestic U.S. customer monetary savings that occur 

as a result of market transactions, while the value of CO2 reductions is based on a global 

value. Second, the assessments of operating cost savings and the SCC are performed with 

different methods that use quite different time frames for analysis. The national operating 

cost savings is measured for the lifetime of equipment shipped in 2015–2044. The SCC 

values, on the other hand, reflect the present value of future climate-related impacts 

resulting from the emission of one metric ton of CO2 in each year. These impacts 

continue well beyond 2100.

8. Other Factors

The Secretary of Energy, in determining whether a standard is economically 

justified, may consider any other factors that the Secretary deems to be relevant. (42 

U.S.C. 6295(o)(2)(B)(i)(VI)) No other factors were considered in this analysis.

C.

When considering proposed standards, the new or amended energy conservation 

standard that DOE adopts for any type (or class) of covered equipment shall be designed 

to achieve the maximum improvement in energy efficiency that the Secretary of Energy 

determines is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A) and 6316(a)) In determining whether a standard is economically justified, 

the Secretary must determine whether the benefits of the standard exceed its burdens to 

Proposed Standards
294

the greatest extent practicable, considering the seven statutory factors discussed 

previously. (42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) The new or amended standard must 

also “result in significant conservation of energy.” (42 U.S.C. 6295(o)(3)(B) and 6316(a))

For today’s NOPR, DOE considered the impacts of standards at each TSL, 

beginning with the max-tech level, to determine whether that level was economically 

justified. Where the max-tech level was not justified, DOE then considered the next most 

efficient level and undertook the same evaluation until it reached the highest efficiency 

level that is technologically feasible, economically justified and saves a significant 

amount of energy. Throughout this process DOE also considered the recommendations 

made by the Motors Coalition and other stakeholders in their submitted comments. For 

more details on the Motors Coalition see Section II.B.2. 

To aid the reader in understanding the benefits and/or burdens of each TSL, tables 

in this section summarize the quantitative analytical results for each TSL, based on the 

assumptions and methodology discussed herein. The efficiency levels contained in each 

TSL are described in section V.A. In addition to the quantitative results presented in the 

tables, DOE also considers other burdens and benefits that affect economic justification. 

These include the impacts on identifiable subgroups of customers who may be 

disproportionately affected by a national standard, and impacts on employment. Section 

V.B.1.b presents the estimated impacts of each TSL for the considered subgroup. DOE 

discusses the impacts on employment in electric motor manufacturing in section V.B.2.b, 

and discusses the indirect employment impacts in section V.B.3.c.
295

1. Benefits and Burdens of Trial Standard Levels Considered for Electric Motors

Table V.22 and Table V.23 summarize the quantitative impacts estimated for each 

TSL for electric motors.

Table V.22 Summary of Analytical Results for Electric Motors: National Impacts

Category TSL 1 TSL 2 TSL 3 TSL 4

National Full-Fuel-Cycle Energy Savings quads

1.1 7.0 10.8 13.7

NPV of Consumer Benefits

3% discount rate

2012$ billion

5.8 23.3 3.0 -42.4

7% discount rate 2.7 8.7 -3.4 -30.3

Cumulative Emissions Reduction (Total FFC Emissions)

CO2 million metric tons 65.9 396.1 610.0 776.5 

SO2 thousand tons 106.0 674.4 1,042.0 1,324.8 

NOX thousand tons 82.1 499.4 769.6 979.5 

Hg tons 0.1 0.8 1.3 1.6 

N2O thousand tons 1.3 8.5 13.2 16.8 

CH4 thousand tons 302.2 1,887.7 2,913.5 3,705.5 

Value of Emissions Reduction (Total FFC Emissions)

CO2 2012$ million 459457 to 

6,409378 * 2,517502 to 36,723564

3,853831 to 

56,385143

4,917888 to 

71,861552

NOX – 3% discount rate 117.5 2012$ million 635.4 972.2 1,241.0 

NOX – 7% discount rate 60.2 2012$ million 285.0 432.0 553.8 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions.

Table V.23 Summary of Analytical Results for Electric Motors: Manufacturer and 

Consumer Impacts

Category TSL 1 TSL 2 TSL 3 TSL 4

Manufacturer Impacts

Industry NPV 2012$ 

million

3,378.7 –

3,019.5

3,759.2 –

3,087.6

4,443.7 –

2,356.8

5,241.3 –

1,383.1

Industry NPV % change 0.2 – (10.4) 11.5 – (8.4) 31.8 – (30.1) 55.5 – (59.0)

Consumer Mean LCC Savings* 

Equipment Class Group 1

2012$

43 132 68 -417

Equipment Class Group 2 38 38 -285 -285

Equipment Class Group 3 N/A** N/A** -61 -763

Comment [A36]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
296

Category TSL 1 TSL 2 TSL 3 TSL 4

Equipment Class Group 4 137 259 210 -291

Consumer Median PBP* years

Equipment Class Group 1 1.1 3.3 6.7 29.9

Equipment Class Group 2 5.0 5.0 22.8 22.8

Equipment Class Group 3 N/A** N/A** 3,299 11,957

Equipment Class Group 4 1.2 1.9 3.7 16.0

Equipment Class Group 1

Net Cost % 0.3 8.4 38.0 84.6

Net Benefit % 9.7 32.0 40.4 7.6

No Impact % 90.0 59.6 21.5 7.7

Equipment Class Group 2

Net Cost % 21.5 21.5 94.7 94.7

Net Benefit % 68.6 68.6 5.3 5.3

No Impact % 9.9 9.9 0.0 0.0

Equipment Class Group 3

Net Cost (%) 0.0 0.0 81.7 100.0

Net Benefit (%) 0.0 0.0 0.0 0.0

No Impact (%) 0.0 0.0 18.3 0.0

Equipment Class Group 4

Net Cost (%) 1.0 10.8 33.1 79.6

Net Benefit (%) 31.8 60.8 65.8 19.9

No Impact (%) 67.3 28.4 1.1 0.3

* * The results for each equipment class group (ECG) are a shipment weighted average of results for the 

representative units in the group. ECG 1: Representative units 1, 2, and 3; ECG 2: Representative units 4 

and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units 9 and10.

* *For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected.

First, DOE considered TSL 4, the most efficient level (max tech), which would 

save an estimated total of 13.7 quads of energy, an amount DOE considers significant. 

TSL 4 has an estimated NPV of customer benefit of -30.3 billion using a 7 percent 

discount rate, and -42.4 billion using a 3 percent discount rate. 

The cumulative emissions reductions at TSL 4 are 776.5 million metric tons of 

CO2, 979.5 thousand tons of NOX, 1,324.8 thousand tons of SO2, and 1.6 tons of Hg. The 
297

estimated monetary value of the CO2 emissions reductions at TSL 4 ranges from 

$4,917888 million to $71,861552 million. 

At TSL 4, the weighted average LCC impact ranges from $-763 for ECG 3 to $-

285 for ECG 2. The weighted average median PBP ranges from 16 years for ECG 4 to 

11,957 years for ECG 3. The weighted average share of customers experiencing a net 

LCC benefit ranges from 0 percent for ECG 3 to 19.9 percent for ECG 4.

At TSL 4, the projected change in INPV ranges from a decrease of $1,988.1 

million to an increase of $1,870.1 million. If the decrease of $1,988.1 million were to 

occur, TSL 4 could result in a net loss of 59 percent in INPV to manufacturers of covered 

electric motors.

In view of the foregoing, DOE concludes that, at TSL 4 for electric motors, the 

benefits of energy savings, emission reductions, and the estimated monetary value of the 

emissions reductions would be outweighed by the potential multi-billion dollar negative 

net economic cost; the economic burden on customers as indicated by the increase in 

customer LCC (negative savings), large PBPs, the large percentage of customers who 

would experience LCC increases; the increase in the cumulative regulatory burden on 

manufacturers; and the capital and engineering costs that could result in a large reduction 

in INPV for manufacturers at TSL 4. Additionally, DOE believes that efficiency 

standards at this level, could result in significant impacts on OEMs due to larger and 

faster motors. Although DOE has not quantified these potential impacts, DOE believes 

Comment [A37]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.

Comment [A38]: Change recommended by 

OIRA.
298

that it is possible that these impacts could be significant and further reduce any potential 

benefits of standards established at this TSL. Consequently, DOE has concluded that TSL 

4 is not economically justified. 

Next, DOE considered TSL 3, which would save an estimated total of 10.6 quads 

of energy, an amount DOE considers significant. TSL 3 has an estimated NPV of 

customer benefit of $-3.4 billion using a 7 percent discount rate, and $3.0 billion using a 

3 percent discount rate.

The cumulative emissions reductions at TSL 3 are 610.0 million metric tons of 

CO2, 769.6 thousand tons of NOX, 1,042.0 thousand tons of SO2, and 1.3 tons of Hg. The 

estimated monetary value of the CO2 emissions reductions at TSL 4 ranges from 

$3,853831 million to $ 56,385143 million. 

At TSL 3, the weighted average LCC impact ranges from $-285 for ECG 2 to 

$210 for ECG 4. The weighted average median PBP ranges from 3.7 years for ECG 4 to 

3,299 years for ECG 3. The share of customers experiencing a net LCC benefit ranges 

from 0 percent for ECG 3 to 65.8 percent for ECG 4.

At TSL 3, the projected change in INPV ranges from a decrease of $1,014,4 

million to an increase of $1,072.5 million. If the decrease of $1,014.4 million were to 

occur, TSL 3 could result in a net loss of 30.1 percent in INPV to manufacturers of 

covered electric motors.

Comment [A39]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
299

In view of the foregoing, DOE concludes that, at TSL 3 for electric motors, the 

benefits of energy savings, positive weighted average customer LCC savings for some 

ECGs, generating capacity reductions, emission reductions, and the estimated monetary 

value of the emissions reductions would be outweighed by the potential negative net 

economic cost; the economic burden on customers as indicated by the increase in 

weighted average LCC for some ECGs (negative savings), large PBPs, the large 

percentage of customers who would experience LCC increases; the increase in the 

cumulative regulatory burden on manufacturers; and the capital and engineering costs 

that could result in a large reduction in INPV for manufacturers at TSL 3. Additionally, 

DOE believes that efficiency standards at this level could result in significant impacts on 

OEMs due to larger and faster motors. Although DOE has not quantified these potential 

impacts, DOE believes that it is possible that these impacts could be significant and 

further reduce any potential benefits of standards established at this TSL. Consequently, 

DOE has concluded that TSL 3 is not economically justified.

Next, DOE considered TSL 2, which would save an estimated total of 7.0 quads 

of energy, an amount DOE considers significant. TSL 32 has an estimated NPV of 

customer benefit of $8.7 billion using a 7 percent discount rate, and $23.3 billion using a 

3 percent discount rate.

The cumulative emissions reductions at TSL 2 are 396.1 million metric tons of 

CO2, 674.4 thousand tons of NOX, 499.4 thousand tons of SO2, and 0.8 tons of Hg. The 

Comment [A40]: Change recommended by 

OIRA.
300

estimated monetary value of the CO2 emissions reductions at TSL 4 ranges from 

$2,517502 million to $36,723564 million. 

At TSL 2, the weighted average LCC impact ranges from no impacts for ECG 3 

to $259 for ECG 4. The weighted average median PBP ranges from 0 years for ECG 3 to 

5 years for ECG 2. The share of customers experiencing a net LCC benefit ranges from 0 

percent for ECG 3 to 68.6 percent for ECG 2. The share of motors already at TSL 2 

efficiency levels varies by equipment class group and by horsepower range (from 0 to 62 

percent). For ECG 1, which represents the most significant share of the market, about 30

percent of motors meet the TSL 2 levels.

At TSL 2, the projected change in INPV ranges from a decrease of $283.5 million 

to an increase of $388 million. If the decrease of $283.5 million were to occur, TSL 2 

could result in a net loss of 8.4 percent in INPV to manufacturers of covered electric 

motors.

After considering the analysis and weighing the benefits and the burdens, DOE 

has tentatively concluded that at TSL 2 for electric motors, the benefits of energy savings, 

positive NPV of customer benefit, positive impacts on consumers (as indicated by 

positive weighted average LCC savings for all ECGs impacted at TSL 2, favorable PBPs, 

and the large percentage of customers who would experience LCC benefits, emission 

reductions, and the estimated monetary value of the emissions reductions would outweigh 

the slight increase in the cumulative regulatory burden on manufacturers and the risk of 

Comment [A41]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.

Comment [A42]: Change recommended by 

OIRA.

Comment [A43]: Change recommended by 

OIRA.

Comment [A44]: Change recommended by 

OIRA.
301

small negative impacts if manufacturers are unable to recoup investments made to meet 

the standard. In particular, the Secretary of Energy has concluded that TSL 2 would save 

a significant amount of energy and is technologically feasible and economically justified. 

In addition, DOE notes that TSL 2 most closely corresponds to the standards that 

were proposed by the Motor Coalition, as described in section II.B.2. Based on the above 

considerations, DOE today proposes to adopt the energy conservation standards for 

electric motors at TSL 2. Table V.24 through Table V.27 present the proposed energy 

conservation standards for electric motors.
302

Table V.24 Proposed Energy Conservation standards for NEMA Design A and 

NEMA Design B Electric Motors (Compliance Starting December 19, 2015)

Motor 

Horsepower

/Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

2 Pole 4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open Enclosed Open

1/.75 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2

20/15 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0

30/22 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7

40/30 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7

50/37 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4

60/45 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0

75/55 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1

100/75 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1

125/90 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1

150/110 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1

200/150 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1

250/186 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0

300/224 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0

350/261 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0

400/298 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0

450/336 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0

500/373 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
303

Table V.25 Proposed Energy Conservation Standards for NEMA Design C Electric 

Motors (Compliance Starting December 19, 2015)

Motor 

Horsepower/ 

Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open

1/.75 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 92.4 93.0 91.7 91.7 89.5 90.2

20/15 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 93.6 93.6 93.0 93.0 90.2 91.0

30/22 93.6 94.1 93.0 93.6 91.7 91.7

40/30 94.1 94.1 94.1 94.1 91.7 91.7

50/37 94.5 94.5 94.1 94.1 92.4 92.4

60/45 95.0 95.0 94.5 94.5 92.4 93.0

75/55 95.4 95.0 94.5 94.5 93.6 94.1

100/75 95.4 95.4 95.0 95.0 93.6 94.1

125/90 95.4 95.4 95.0 95.0 94.1 94.1

150/110 95.8 95.8 95.8 95.4 94.1 94.1

200/150 96.2 95.8 95.8 95.4 94.5 94.1
304

Table V.26 Proposed Energy Conservation Standards for Fire Pump Electric 

Motors (Compliance Starting December 19, 2015)

Motor 

Horsepower

/Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

2 Pole 4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open Enclosed Open

1/.75 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0

1.5/1.1 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5

2/1.5 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5

3/2.2 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5

5/3.7 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5

7.5/5.5 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5

10/7.5 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5

15/11 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5

20/15 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2

25/18.5 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2

30/22 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0

40/30 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0

50/37 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7

60/45 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4

75/55 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6

100/75 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6

125/90 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6

150/110 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6

200/150 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6

250/186 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5

300/224 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5

350/261 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5

400/298 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5

450/336 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5

500/373 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5
305

Table V.27 Proposed Energy Conservation Standards for Brake Motors 

(Compliance Starting December 19, 2015)

Motor 

Horsepower/ 

Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open

1/.75 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 92.4 93.0 91.7 91.7 89.5 90.2

20/15 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 93.6 93.6 93.0 93.0 90.2 91.0

30/22 93.6 94.1 93.0 93.6 91.7 91.7

2. Summary of Benefits and Costs (Annualized) of the Proposed Standards

The benefits and costs of today’s proposed standards, for equipment sold in 2015-

2044, can also be expressed in terms of annualized values. The annualized monetary 

values are the sum of: (1) the annualized national economic value of the benefits from 

consumer operation of equipment that meet the proposed standards (consisting primarily 

of operating cost savings from using less energy, minus increases in equipment purchase 

and installation costs, which is another way of representing consumer NPV), and (2) the 

annualized monetary value of the benefits of emission reductions, including CO2

emission reductions.89

 89 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized 

values. First, DOE calculated a present value in 2013, the year used for discounting the NPV of total 

consumer costs and savings, for the time-series of costs and benefits using discount rates of three and seven 

percent for all costs and benefits except for the value of CO2 reductions. For the latter, DOE used a range of 

discount rates, as shown in Table I.3. From the present value, DOE then calculated the fixed annual 

payment over a 30-year period (2015 through 2044) that yields the same present value. The fixed annual 
306

Although combining the values of operating savings and CO2 emission reductions 

provides a useful perspective, two issues should be considered. First, the national 

operating savings are domestic U.S. consumer monetary savings that occur as a result of 

market transactions while the value of CO2 reductions is based on a global value. Second, 

the assessments of operating cost savings and CO2 savings are performed with different 

methods that use different time frames for analysis. The national operating cost savings is 

measured for the lifetime of electric motors shipped in 2015 –2044. The SCC values, on 

the other hand, reflect the present value of some future climate-related impacts resulting 

from the emission of one ton of carbon dioxide in each year. These impacts continue well 

beyond 2100.

Estimates of annualized benefits and costs of the proposed standards for electric 

motors are shown in Table V.28. The results under the primary estimate are as follows. 

Using a 7-percent discount rate for benefits and costs other than CO2 reduction, for which 

DOE used a 3-percent discount rate along with the average SCC series that uses a 3-

percent discount rate, the cost of the standards proposed in today’s rule is $462 million 

per year in increased equipment costs; while the estimated benefits are $1,114 million per 

year in reduced equipment operating costs, $592586 million in CO2 reductions, and $21.5

million in reduced NOX emissions. In this case, the net benefit would amount to 

$1,265957 million per year. Using a 3-percent discount rate for all benefits and costs and 

 payment is the annualized value. Although DOE calculated annualized values, this does not imply that the 

time-series of cost and benefits from which the annualized values were determined is a steady stream of 

payments.
307

the average SCC series, the estimated cost of the standards proposed in today’s rule is 

$577 million per year in increased equipment costs; while the estimated benefits are 

$1,730 million per year in reduced operating costs, $596586 million in CO2 reductions, 

and $31.5 million in reduced NOX emissions. In this case, the net benefit would amount 

to approximately $1,776354 million per year. Comment [A45]: Values updated to reflect 

revised Social Cost of Carbon values announced by 

OIRA on Nov. 1, 2013.
308

Table V.28 Annualized Benefits and Costs of Proposed Standards for Electric 

Motors

Discount Rate

Primary 

Estimate*

Low Net 

Benefits 

Estimate*

High Net 

Benefits 

Estimate*

million 2012$/year

Benefits

Consumer Operating Cost 

Savings

7% 1,114 924 1,358 

3% 1,730 1,421 2,134 

CO2 Reduction Monetized 

Value ($12.911.8/t case)* 5% 156 155 135 134 180 179

CO2 Reduction Monetized 

Value ($40.839.7/t case)* 3% 592 586 511 506 686 679

CO2 Reduction Monetized 

Value ($6261.2/t case)* 2.5% 892 882 771 762 1,034 1022

CO2 Reduction Monetized 

Value $117.0/t case)* 3% 1,819 811 1,572 565 2,107 098

NOX Reduction Monetized 

Value (at $2,639/ton)**

7% 21.46 18.55 24.68

3% 31.48 27.20 36.39

Total Benefits†

7% plus CO2

range

1,291290 to 

2,954 947

1,077 to 2,514 

507

1,563562 to 

3,490 481

7% 1,727 721 1,454 449 2,068 061

3% plus CO2

range

1,917916 to 

3,580 572

1,583 to 3,020 

014

2,351350 to 

4,277 268

3% plus CO2

range

2,353 347 1,960 955 2,856 849

Costs

Consumer Incremental 

Equipment Costs

7% 462 492 447

3% 577 601 569

Net Benefits

Total†

7% plus CO2

range

82958

5 to 2,492016

5861,11

5 to 2,0233,033

1,116

353 to 

3,043438

7% 1,265957 9621,614 1,621887

3% plus CO2

range

1,340982 to 

3,0032,413

9821,781 to 

2,4193,700

1,782957 to 

3,7094,043

3% 1,776354 1,3592,280 2,287492

Comment [A46]: Values in table updated to 

reflect revised Social Cost of Carbon values 

announced by OIRA on Nov. 1, 2013.

Comment [A47]: Change recommended by 

OIRA.

Comment [A48]: Change recommended by 

OIRA.
309

* This table presents the annualized costs and benefits associated with electric motors shipped in 

2015−2044. These results include benefits to consumers which accrue after 2044 from the equipment 

purchased in years 2015−2044. Costs incurred by manufacturers, some of which may be incurred in 

preparation for the rule, are not directly included, but are indirectly included as part of incremental 

equipment costs. The Primary, Low Benefits, and High Benefits Estimates are in view of projections of 

energy prices from the Annual Energy Outlook (AEO) 2013 Reference case, Low Estimate, and High 

Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected 

equipment price in the Primary Estimate, a decline rate for projected equipment price trends in the Low 

Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits 

Estimate. The methods used to derive projected price trends are explained in section IV.F.1.

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of 

values are based on the average SCC from the three integrated assessment models, at discount rates of 2.5, 

3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all three models 

at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change 

further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The 

SCC time series incorporate an escalation factor. The value for NOX is the average of the low and high 

values used in DOE’s analysis.

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to 

average SCC with 3-percent discount rate. In the rows labeled “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values 

are added to the full range of CO2 values.

VI. Procedural Issues and Regulatory Review

A.

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to 

address, including, where applicable, the failures of private markets or public institutions 

that warrant new agency action, as well as to assess the significance of that problem. The 

problems that today’s standards address are as follows: 

Review Under Executive Orders 12866 and 13563

(1) There is a lack of consumer information and/or information processing capability 

about energy efficiency opportunities in the commercial and industrial equipment 

market.
310

(1) There is asymmetric information (one party to a transaction has more and better 

information than the other) and/or high transactions costs (costs of gathering 

information and effecting exchanges of goods and services).

(2)(1) There are external benefits resulting from improved energy efficiency of 

covered electric motors which are not captured by the users of such equipment. 

These benefits include externalities related to environmental protection and 

energy security that are not reflected in energy prices, such as reduced emissions 

of greenhouse gases. DOE attempts to quantify some of the external benefits 

through use of Social Cost of Carbon values.

In addition, DOE has determined that today’s regulatory action is an 

“economically significant regulatory action” under section 3(f)(1) of Executive Order 

12866. Accordingly, section 6(a)(3) of the Executive Order requires that DOE prepare a 

regulatory impact analysis (RIA) on today’s rule and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) review this 

rule. DOE presented to OIRA for review the draft rule and other documents prepared for 

this rulemaking, including the RIA, and has included these documents in the rulemaking 

record. The assessments prepared pursuant to Executive Order 12866 can be found in the 

technical support document for this rulemaking. 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563 is supplemental to and 

explicitly reaffirms the principles, structures, and definitions governing regulatory review 

established in Executive Order 12866. To the extent permitted by law, agencies are 

Comment [A49]: Change recommended by 

OIRA.
311

required by Executive Order 13563 to: (1) propose or adopt a regulation only upon a 

reasoned determination that its benefits justify its costs (recognizing that some benefits 

and costs are difficult to quantify); (2) tailor regulations to impose the least burden on 

society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in 

choosing among alternative regulatory approaches, those approaches that maximize net 

benefits (including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible. In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include identifying changing future compliance 

costs that might result from technological innovation or anticipated behavioral changes. 

For the reasons stated in the preamble, DOE believes that today’s NOPR is consistent 

with these principles, including the requirement that, to the extent permitted by law, 

benefits justify costs and that net benefits are maximized. 
312

B.

The Regulatory Flexibility Act (5 U.S.C. 601 

Review Under the Regulatory Flexibility Act

et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for 

public comment, unless the agency certifies that the rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. As required by 

Executive Order 13272, “Proper Consideration of Small Entities in Agency Rulemaking,” 

67 FR 53461 (August 16, 2002), DOE published procedures and policies on February 19, 

2003, to ensure that the potential impacts of its rules on small entities are properly 

considered during the rulemaking process. 68 FR 7990 DOE has made its procedures and 

policies available on the Office of the General Counsel’s website 

(http://energy.gov/gc/office-general-counsel).

DOE has prepared an IRFA for this rulemaking, a copy of which DOE will 

transmit to the Chief Counsel for Advocacy of the SBA for review under 5 U.S.C 605(b). 

As presented and discussed below, the IFRA describes potential impacts on electric 

motors manufacturers associated with capital and product conversion costs and discusses 

alternatives that could minimize these impacts.

A statement of the objectives of, and reasons and legal basis for, the proposed rule 

are set forth elsewhere in the preamble and not repeated here.
313

1. Description and Estimated Number of Small Entities Regulated

a. Methodology for Estimating the Number of Small Entities

For manufacturers of electric motors, the Small Business Administration (SBA) 

has set a size threshold, which defines those entities classified as “small businesses” for 

the purposes of the statute. DOE used the SBA’s small business size standards to 

determine whether any small entities would be subject to the requirements of the rule. 

The size standards are listed by North American Industry Classification System (NAICS) 

code and industry description available at: http://www.sba.gov/content/table-smallbusiness-size-standards. Electric motor manufacturing is classified under NAICS 335312, 

“Motor and Generator Manufacturing.” The SBA sets a threshold of 1,000 employees or 

less for an entity to be considered as a small business for this category.

To estimate the number of companies that could be small business manufacturers 

of equipment covered by this rulemaking, DOE conducted a market survey using publicly 

available information. DOE’s research involved industry trade association membership 

directories (including NEMA), information from previous rulemakings, UL qualification 

directories, individual company websites, and market research tools (e.g., Hoover’s 

reports). DOE also asked stakeholders and industry representatives if they were aware of 

any other small manufacturers during manufacturer interviews and DOE public meetings. 

DOE used information from these sources to create a list of companies that potentially 

manufacture electric motors covered by this rulemaking. As necessary, DOE contacted 

companies to determine whether they met the SBA’s definition of a small business 

manufacturer. DOE screened out companies that do not offer equipment covered by this 
314

rulemaking, do not meet the definition of a ‘‘small business,’’ or are foreign owned and 

operated.

DOE initially identified 60 potential manufacturers of electric motors sold in the 

U.S. After reviewing publicly available information DOE contacted 27 of the companies 

that DOE suspected were small business manufacturers to determine whether they met 

the SBA definition of a small business and whether they manufactured the equipment that

would be affected by today’s proposal. Based on these efforts, DOE estimates that there 

are 13 small business manufacturers of electric motors.

b. Manufacturer Participation

DOE contacted the 13 identified small businesses to invite them to take part in a 

small business manufacturer impact analysis interview. Of the electric motor 

manufacturers DOE contacted, 10 responded and three did not. Eight of the 10 

responding manufacturers declined to be interviewed. Therefore, DOE was able to reach 

and discuss potential standards with two of the 13 small business manufacturers. DOE 

also obtained information about small business manufacturers and potential impacts 

while interviewing large manufacturers.

c. Electric Motor Industry Structure and Nature of Competition

Eight major manufacturers supply approximately 90 percent of the market for 

electric motors. None of the major manufacturers of electric motors covered in this 

rulemaking is a small business. DOE estimates that approximately 50 percent of the 
315

market is served by imports. Many of the small businesses that compete in the electric 

motor market produce specialized motors, many of which have not been regulated under 

previous standards. Most of these low-volume manufacturers do not compete directly 

with large manufacturers and tend to occupy niche markets for their equipment. There are 

a few small business manufacturers that produce general purpose motors; however, these 

motors currently meet NEMA Premium efficiency levels, the efficiency levels being 

proposed in today’s notice.

d. Comparison Between Large and Small Entities

For electric motors, small manufacturers differ from large manufacturers in 

several ways that affect the extent to which a manufacturer would be impacted by 

proposed standards. Characteristics of small manufacturers include: lower production 

volumes, fewer engineering resources, less technical expertise, and less access to capital.

Lower production volumes lie at the heart of most small business disadvantages, 

particularly for a small manufacturer that is vertically integrated. A lower-volume 

manufacturer’s conversion costs would need to be spread over fewer units than a larger 

competitor. Thus, unless the small business can differentiate its product in some way that 

earns a price premium, the small business is a ‘price taker’ and experiences a reduction in 

profit per unit relative to the large manufacturer. Therefore, because much of the same 

equipment would need to be purchased by both large and small manufacturers in order to 

produce electric motors at higher TSLs, undifferentiated small manufacturers would face 
316

a greater variable cost penalty because they must depreciate the one-time conversion 

expenditures over fewer units.

Smaller companies are also more likely to have more limited engineering 

resources and they often operate with lower levels of design and manufacturing 

sophistication. Smaller companies typically also have less experience and expertise in 

working with more advanced technologies. Standards that required these technologies 

could strain the engineering resources of these small manufacturers if they chose to 

maintain a vertically integrated business model. Small business electric motor 

manufacturers can also be at a disadvantage due to their lack of purchasing power for 

high performance materials. For example, more expensive low-loss steels are needed to 

meet higher efficiency standards and steel cost grows as a percentage of the overall 

product cost. Small manufacturers who pay higher per pound prices would be 

disproportionately impacted by these prices.

Lastly, small manufacturers typically have less access to capital, which may be 

needed by some to cover the conversion costs associated with new technologies.

2. Description and Estimate of Compliance Requirements

In its market survey, DOE identified three categories of small business electric 

motor manufacturers that may be impacted differently by today’s proposed rule. The first 

group, which includes approximately five of the 13 small businesses, consists of 

manufacturers that produce specialty motors that were not required to meet previous 
317

Federal standards, but would need to do so under the expanded scope of today’s proposed 

rule. DOE believes that this group would likely be the most impacted by expanding the 

scope of equipment required to meet NEMA Premium efficiency levels. The second 

group, which includes approximately five different small businesses, consists of 

manufacturers that produce a small amount of covered equipment and primarily focus on 

other types of motors not covered in this rulemaking, such as single-phase or directcurrent motors. Because generally less than 10 percent of these manufacturers’ revenue 

comes from covered equipment, DOE does not believe new standards will substantially 

impact their business. The third group, which includes approximately three small 

businesses, consists of manufacturers that already offer NEMA Premium general purpose 

and specialty motors. DOE expects these manufacturers to face similar conversion costs 

as large manufacturers, in that they will not experience high capital conversion costs as 

they already have the design and production experience necessary to bring their motors 

up to NEMA Premium efficiency levels. It is likely, however, that some of the specialty 

equipment these manufacturers produce will be included in the expanded scope of this 

proposed rule and is likely to result in these small businesses incurring additional 

certification and testing costs. These manufacturers could also face product development 

costs if they have to redesign any motors that are not currently meeting the NEMA 

Premium level.

At TSL 2, the level proposed in today’s notice, DOE estimates capital conversion 

costs of $1.88 million and product conversion costs of $3.75 million for a typical small 

manufacturer in the first group (manufacturers that produce specialized motors previously 
318

not covered by Federal standards). Meanwhile, DOE estimates a typical large 

manufacturer would incur capital and product conversion costs of $3.29 million and 

$7.25 million, respectively, at the same TSL. Small manufacturers that predominately 

produce specialty motors would face higher relative capital conversion costs at TSL 2 

than large manufacturers because large manufacturers have been independently pursuing 

higher efficiency motors as a result of the efficiency standards prescribed by EISA 2007 

(10 CFR part 431.25) and consequently have built up more design and production 

experience. Large manufacturers have also been innovating as a result of the small 

electric motors rulemaking at 75 FR 10874 (March 9, 2010), which exempted many of 

the specialized equipment that these small business manufacturers produce. Many large 

manufacturers of general purpose motors offer equipment that was covered by the 2010 

small electric motors rule, as well as equipment that falls under this proposed rule. Small 

manufactures pointed out that this would give large manufacturers an advantage in that 

they already have experience with the technology necessary to redesign their equipment 

and are familiar with the steps they will have to take to upgrade their manufacturing 

equipment and processes. Small manufactures, whose specialized motors were not 

required to meet the standards prescribed by the small electric motors rule and EISA 

2007 have not undergone these processes and, therefore, would have to put more time 

and resources into redesign efforts.

The small businesses whose product lines consist of a high percentage of 

equipment that are not currently required to meet efficiency standards would need to 

make significant capital investments relative to large manufacturers to upgrade their 
319

production lines with equipment necessary to produce NEMA Premium motors. As Table 

VI.1 illustrates, these manufacturers would have to drastically increase their capital 

expenditures to purchase new lamination die sets, and new winding and stacking 

equipment.

Table VI.1 Estimated Capital and Product Conversion Costs as a Percentage of 

Annual Capital Expenditures and R&D Expense

Capital conversion cost as 

a percentage of annual 

capital expenditures

Product conversion 

cost as a percentage of 

annual R&D expense

Total conversion cost 

as a percentage of 

annual revenue

Typical Large 

Manufacturer 14% 31% 2%

Typical Small 

Manufacturer 188% 490% 75%

Table VI.1 also illustrates that small manufacturers whose product lines contain 

many motors that are not currently required to meet Federal standards face high relative 

product conversion costs compared to large manufacturers, despite the lower dollar value. 

In interviews, these small manufacturers expressed concern that they would face a large 

learning curve relative to large manufacturers, due to the fact that many of the equipment 

they produce has not had to meet Federal standards. In its market survey, DOE learned 

that for some manufacturers, the expanded scope of specialized motors that would have 

to meet NEMA Premium could affect nearly half the equipment they offer. They would 

need to hire additional engineers and would have to spend considerable time and 

resources redesigning their equipment and production processes. DOE does not expect 

the small businesses that already manufacture NEMA Premium equipment or those that 

offer very few alternating-current motors to incur these high costs.
320

Manufacturers also expressed concern about testing and certification costs 

associated with new standards. They pointed out that these costs are particularly 

burdensome on small businesses that produce a wide variety of specialized equipment. 

As a result of the wide variety of equipment they produce and their relatively low output, 

small manufacturers are forced to certify multiple small batches of motors, the costs of 

which need to be spread out over far fewer units than large manufacturers.

Small manufacturers that produce equipment not currently required to meet 

efficiency standards also pointed out that they would face significant challenges 

supporting current business while making changes to their production lines. While large 

manufacturers could shift production of certain equipment to different plants or product 

lines while they made updates, small businesses would have limited options. Most of 

these small businesses have only one plant and would have to find a way to continue to 

fulfill customer needs while redesigning production lines and installing new equipment. 

In interviews with DOE, small manufacturers said that it would be difficult to quantify 

the impacts that downtime and the possible need for external support could have on their 

businesses.

3. Duplication, Overlap, and Conflict with Other Rules and Regulations

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being considered today.
321

4. Significant Alternatives to the Proposed Rule

The discussion above analyzes impacts on small businesses that would result from 

the TSL DOE is proposing in today’s notice. Though TSLs lower than the proposed TSL 

are expected to reduce the impacts on small entities, DOE is required by EPCA to 

establish standards that achieve the maximum improvement in energy efficiency that are 

technically feasible and economically justified, and result in a significant conservation of 

energy. Therefore, DOE rejected the lower TSLs.

In addition to the other TSLs being considered, the NOPR TSD includes a 

regulatory impact analysis in chapter 17. For electric motors, this report discusses the 

following policy alternatives: (1) consumer rebates, (2) consumer tax credits, and (3) 

manufacturer tax credits. DOE does not intend to consider these alternatives further 

because they either are not feasible to implement or are not expected to result in energy 

savings as large as those that would be achieved by the standard levels under 

consideration.

DOE continues to seek input from businesses that would be affected by this 

rulemaking and will consider comments received in the development of any final rule.

5. Significant Issues Raised by Public Comments

DOE’s MIA suggests that, while TSL 2 presents greater difficulties for small 

businesses than lower efficiency levels, the business impacts at higher TSLs would be 

greater. DOE expects that most small businesses will generally be able to maintain 
322

profitability at the TSL proposed in today’s rulemaking. It is possible, however, that the 

small manufacturers whose product lines consist of a high percentage of previously 

exempted motors could incur significant costs as a result of this proposed rule, and those 

high costs could endanger their business. DOE’s MIA is based on its interviews of both 

small and large manufacturers, and consideration of small business impacts explicitly 

enters into DOE’s choice of the TSLs proposed in this NOPR.

DOE did not receive any public comments suggesting that small businesses would 

not be able to achieve the efficiency levels at TSL 2.

C.

Manufacturers of electric motors that are currently subject to energy conservation 

standards must certify to DOE that their equipment comply with any applicable energy 

conservation standards. In certifying compliance, manufacturers must test their 

equipment according to the DOE test procedures for electric motors, including any 

amendments adopted for those test procedures. The collection-of-information 

requirement for the certification and recordkeeping is subject to review and approval by 

OMB under the Paperwork Reduction Act (PRA). This requirement has been approved 

by OMB under OMB control number 1910-1400. Public reporting burden for the 

certification is estimated to average 20 hours per response, including the time for 

reviewing instructions, searching existing data sources, gathering and maintaining the 

data needed, and completing and reviewing the collection of information. DOE intends 

to address revised certification requirements for electric motors in a separate rulemaking.

Review Under the Paperwork Reduction Act

Comment [A50]: Change recommended by 

OIRA.

Comment [A51]: Change recommended by 

OIRA.
323

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB Control Number.

D.

Pursuant to the National Environmental Policy Act (NEPA) of 1969, DOE has 

determined that the proposed rule fits within the category of actions included in 

Categorical Exclusion (CX) B5.1 and otherwise meets the requirements for application of 

a CX. See 10 CFR Part 1021, App. B, B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). 

The proposed rule fits within the category of actions because it is a rulemaking that 

establishes energy conservation standards for consumer products or industrial equipment, 

and for which none of the exceptions identified in CX B5.1(b) apply. Therefore, DOE has 

made a CX determination for this rulemaking, and DOE does not need to prepare an 

Environmental Assessment or Environmental Impact Statement for this proposed rule. 

DOE’s CX determination for this proposed rule is available at http://cxnepa.energy.gov/. 

Review Under the National Environmental Policy Act of 1969

E.

Executive Order 13132, “Federalism.” 64 FR 43255 (Aug. 10, 1999) imposes 

certain requirements on Federal agencies formulating and implementing policies or 

regulations that preempt State law or that have Federalism implications. The Executive 

Review Under Executive Order 13132
324

Order requires agencies to examine the constitutional and statutory authority supporting 

any action that would limit the policymaking discretion of the States and to carefully 

assess the necessity for such actions. The Executive Order also requires agencies to have 

an accountable process to ensure meaningful and timely input by State and local officials 

in the development of regulatory policies that have Federalism implications. On March 

14, 2000, DOE published a statement of policy describing the intergovernmental 

consultation process it will follow in the development of such regulations. 65 FR 13735. 

EPCA governs and prescribes Federal preemption of State regulations as to energy 

conservation for the equipment that are the subject of today’s proposed rule. States can 

petition DOE for exemption from such preemption to the extent, and based on criteria, set 

forth in EPCA. (42 U.S.C. 6297) No further action is required by Executive Order 

13132.

F.

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, “Civil Justice Reform,” imposes on 

Federal agencies the general duty to adhere to the following requirements: (1) eliminate 

drafting errors and ambiguity; (2) write regulations to minimize litigation; and (3) 

provide a clear legal standard for affected conduct rather than a general standard and 

promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 

Executive Order 12988 specifically requires that Executive agencies make every 

reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, 

if any; (2) clearly specifies any effect on existing Federal law or regulation; (3) provides 

Review Under Executive Order 12988
325

a clear legal standard for affected conduct while promoting simplification and burden 

reduction; (4) specifies the retroactive effect, if any; (5) adequately defines key terms; 

and (6) addresses other important issues affecting clarity and general draftsmanship under 

any guidelines issued by the Attorney General. Section 3(c) of Executive Order 12988 

requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to 

meet one or more of them. DOE has completed the required review and determined that, 

to the extent permitted by law, this proposed rule meets the relevant standards of 

Executive Order 12988.

G.

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

Federal agency to assess the effects of Federal regulatory actions on State, local, and 

Tribal governments and the private sector. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 

1531). For a proposed regulatory action likely to result in a rule that may cause the 

expenditure by State, local, and Tribal governments, in the aggregate, or by the private 

sector of $100 million or more in any one year (adjusted annually for inflation), section 

202 of UMRA requires a Federal agency to publish a written statement that estimates the 

resulting costs, benefits, and other effects on the national economy. (2 U.S.C. 1532(a),

(b)) The UMRA also requires a Federal agency to develop an effective process to permit 

timely input by elected officers of State, local, and Tribal governments on a proposed 

“significant intergovernmental mandate,” and requires an agency plan for giving notice 

and opportunity for timely input to potentially affected small governments before 

Review Under the Unfunded Mandates Reform Act of 1995
326

establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820. DOE’s policy statement is

also available at http://energy.gov/gc/downloads/unfunded-mandates-reform-actintergovernmental-consultation.

Although today’s proposed rule does not contain a Federal intergovernmental 

mandate, it may require expenditures of $100 million or more on the private sector. 

Specifically, the proposed rule will likely result in a final rule that could require 

expenditures of $100 million or more. Such expenditures may include: (1) investment in 

research and development and in capital expenditures by electric motor manufacturers in 

the years between the final rule and the compliance date for the new standards, and (2) 

incremental additional expenditures by consumers to purchase higher-efficiency electric 

motors, starting at the compliance date for the applicable standard.

Section 202 of UMRA authorizes a Federal agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the proposed 

rule. 2 U.S.C. 1532(c). The content requirements of section 202(b) of UMRA relevant to 

a private sector mandate substantially overlap the economic analysis requirements that 

apply under section 325(o) of EPCA and Executive Order 12866. The 

SUPPLEMENTARY INFORMATION section of the NOPR and the “Regulatory 

Impact Analysis” section of the TSD for this proposed rule respond to those 

requirements. 
327

Under section 205 of UMRA, the Department is obligated to identify and consider 

a reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most cost-effective and least burdensome alternative 

that achieves the objectives of the proposed rule unless DOE publishes an explanation for 

doing otherwise, or the selection of such an alternative is inconsistent with law. As 

required by 42 U.S.C. 6295(d), (f), and (o) and 6316(a), today’s proposed rule would 

establish energy conservation standards for electric motors that are designed to achieve 

the maximum improvement in energy efficiency that DOE has determined to be both 

technologically feasible and economically justified. A full discussion of the alternatives 

considered by DOE is presented in the “Regulatory Impact Analysis” section of the TSD 

for today’s proposed rule.

H.

Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This proposed rule would not have any 

impact on the autonomy or integrity of the family as an institution. Accordingly, DOE 

has concluded that it is not necessary to prepare a Family Policymaking Assessment.

Review Under the Treasury and General Government Appropriations Act, 1999
328

I.

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (Mar. 18, 

1988), that this proposed regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution.

Review Under Executive Order 12630

J.

Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for Federal agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

reviewed today’s NOPR under the OMB and DOE guidelines and has concluded that it is 

consistent with applicable policies in those guidelines.

Review Under the Treasury and General Government Appropriations Act, 2001

K.

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001), requires 

Federal agencies to prepare and submit to OIRA at OMB, a Statement of Energy Effects 

for any proposed significant energy action. A “significant energy action” is defined as 

any action by an agency that promulgates or is expected to lead to promulgation of a final 

rule, and that: (1) is a significant regulatory action under Executive Order 12866, or any 

successor order; and (2) is likely to have a significant adverse effect on the supply, 

Review Under Executive Order 13211
329

distribution, or use of energy, or (3) is designated by the Administrator of OIRA as a 

significant energy action. For any proposed significant energy action, the agency must 

give a detailed statement of any adverse effects on energy supply, distribution, or use 

should the proposal be implemented, and of reasonable alternatives to the action and their 

expected benefits on energy supply, distribution, and use. 

DOE has tentatively concluded that today’s proposed regulatory action, which 

sets forth potential energy conservation standards for commercial and industrial electric 

motors, is not a significant energy action because the proposed standards are not likely to 

have a significant adverse effect on the supply, distribution, or use of energy, nor has it 

been designated as such by the Administrator at OIRA. Accordingly, DOE has not 

prepared a Statement of Energy Effects on the proposed rule.

L.

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology Policy (OSTP), issued its Final Information Quality Bulletin for Peer Review 

(the Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the bulletin is to enhance the quality and credibility of 

the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

defines as scientific information the agency reasonably can determine will have, or does 

Review Under the Information Quality Bulletin for Peer Review 
330

have, a clear and substantial impact on important public policies or private sector 

decisions. 70 FR 2667.

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs and/or projects. The 

“Energy Conservation Standards Rulemaking Peer Review Report” dated February 2007 

has been disseminated and is available at the following Web site: 

www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.

VII. Public Participation

A.

The time, date, and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this notice. If you plan to attend the public 

meeting, please notify Ms. Brenda Edwards at (202) 586-2945 or 

Attendance at the Public Meeting

Brenda.Edwards@ee.doe.gov. As explained in the ADDRESSES section, foreign 

nationals visiting DOE Headquarters are subject to advance security screening 

procedures.
331

In addition, you can attend the public meeting via webinar. Webinar registration 

information, participant instructions, and information about the capabilities available to 

webinar participants will be published on DOE’s website at: [INSERT LINK].

Participants are responsible for ensuring their systems are compatible with the webinar 

software.

B.

Any person who has plans to present a prepared general statement may request 

that copies of his or her statement be made available at the public meeting. Such persons 

may submit requests, along with an advance electronic copy of their statement in PDF 

(preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to the 

appropriate address shown in the ADDRESSES section at the beginning of this notice. 

The request and advance copy of statements must be received at least one week before 

the public meeting and may be emailed, hand-delivered, or sent by mail. DOE prefers to 

receive requests and advance copies via email. Please include a telephone number to 

enable DOE staff to make follow-up contact, if needed.

Procedure for Submitting Prepared General Statements For Distribution

C.

DOE will designate a DOE official to preside at the public meeting and may also 

use a professional facilitator to aid discussion. The meeting will not be a judicial or 

evidentiary-type public hearing, but DOE will conduct it in accordance with section 336 

of EPCA (42 U.S.C. 6306). A court reporter will be present to record the proceedings and 

Conduct of the Public Meeting
332

prepare a transcript. DOE reserves the right to schedule the order of presentations and to 

establish the procedures governing the conduct of the public meeting. After the public 

meeting, interested parties may submit further comments on the proceedings as well as on 

any aspect of the rulemaking until the end of the comment period.

The public meeting will be conducted in an informal, conference style. DOE will 

present summaries of comments received before the public meeting, allow time for 

prepared general statements by participants, and encourage all interested parties to share 

their views on issues affecting this rulemaking. Each participant will be allowed to make 

a general statement (within time limits determined by DOE), before the discussion of 

specific topics. DOE will allow, as time permits, other participants to comment briefly on 

any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to 

clarify their statements briefly and comment on statements made by others. Participants 

should be prepared to answer questions by DOE and by other participants concerning 

these issues. DOE representatives may also ask questions of participants concerning other 

matters relevant to this rulemaking. The official conducting the public meeting will 

accept additional comments or questions from those attending, as time permits. The 

presiding official will announce any further procedural rules or modification of the above 

procedures that may be needed for the proper conduct of the public meeting.
333

A transcript of the public meeting will be included in the docket, which can be 

viewed as described in the Docket section at the beginning of this notice. In addition, any 

person may buy a copy of the transcript from the transcribing reporter.

D.

DOE will accept comments, data, and information regarding this proposed rule 

before or after the public meeting, but no later than the date provided in the DATES 

section at the beginning of this proposed rule. Interested parties may submit comments, 

data, and other information using any of the methods described in the ADDRESSES 

section at the beginning of this notice. 

Submission of Comments

Submitting comments via regulations.gov. The regulations.gov web page will 

require you to provide your name and contact information. Your contact information will 

be viewable to DOE Building Technologies staff only. Your contact information will not 

be publicly viewable except for your first and last names, organization name (if any), and 

submitter representative name (if any). If your comment is not processed properly 

because of technical difficulties, DOE will use this information to contact you. If DOE 

cannot read your comment due to technical difficulties and cannot contact you for 

clarification, DOE may not be able to consider your comment.

However, your contact information will be publicly viewable if you include it in 

the comment itself or in any documents attached to your comment. Any information that 

you do not want to be publicly viewable should not be included in your comment, nor in 
334

any document attached to your comment. Otherwise, persons viewing comments will see 

only first and last names, organization names, correspondence containing comments, and 

any documents submitted with the comments. 

Do not submit to regulations.gov information for which disclosure is restricted by 

statute, such as trade secrets and commercial or financial information (hereinafter 

referred to as Confidential Business Information (CBI)). Comments submitted through 

regulations.gov cannot be claimed as CBI. Comments received through the website will 

waive any CBI claims for the information submitted. For information on submitting CBI, 

see the Confidential Business Information section below.

DOE processes submissions made through regulations.gov before posting. 

Normally, comments will be posted within a few days of being submitted. However, if 

large volumes of comments are being processed simultaneously, your comment may not 

be viewable for up to several weeks. Please keep the comment tracking number that 

regulations.gov provides after you have successfully uploaded your comment. 

Submitting comments via email, hand delivery/courier, or mail. Comments and 

documents submitted via email, hand delivery, or mail also will be posted to 

regulations.gov. If you do not want your personal contact information to be publicly 

viewable, do not include it in your comment or any accompanying documents. Instead, 

provide your contact information in a cover letter. Include your first and last names, 
335

email address, telephone number, and optional mailing address. The cover letter will not 

be publicly viewable as long as it does not include any comments

Include contact information each time you submit comments, data, documents, 

and other information to DOE. If you submit via mail or hand delivery/courier, please 

provide all items on a CD, if feasible. It is not necessary to submit printed copies. No 

facsimiles (faxes) will be accepted.

 

Comments, data, and other information submitted to DOE electronically should 

be provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) 

file format. Provide documents that are not secured, that are written in English, and that 

are free of any defects or viruses. Documents should not contain special characters or any 

form of encryption and, if possible, they should carry the electronic signature of the 

author. 

Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter 

with a list of supporters’ names compiled into one or more PDFs. This reduces comment 

processing and posting time. 

Confidential Business Information. According to 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from 

public disclosure should submit via email, postal mail, or hand delivery/courier two well-
336

marked copies: one copy of the document marked confidential including all the 

information believed to be confidential, and one copy of the document marked nonconfidential with the information believed to be confidential deleted. Submit these 

documents via email or on a CD, if feasible. DOE will make its own determination about 

the confidential status of the information and treat it according to its determination.

Factors of interest to DOE when evaluating requests to treat submitted 

information as confidential include: (1) a description of the items; (2) whether and why 

such items are customarily treated as confidential within the industry; (3) whether the 

information is generally known by or available from other sources; (4) whether the 

information has previously been made available to others without obligation concerning 

its confidentiality; (5) an explanation of the competitive injury to the submitting person 

which would result from public disclosure; (6) when such information might lose its 

confidential character due to the passage of time; and (7) why disclosure of the 

information would be contrary to the public interest.

It is DOE’s policy that all comments may be included in the public docket, 

without change and as received, including any personal information provided in the 

comments (except information deemed to be exempt from public disclosure). 
337

E.

Although DOE welcomes comments on any aspect of this proposal, DOE is 

particularly interested in receiving comments and views of interested parties concerning 

the following issues:

Issues on Which DOE Seeks Comment

1. DOE requests comment on the potential impacts of new and amended 

standards on small electric motor manufacturers, especially regarding 

DOE’s proposed expansion of scope of covered electric motors.

2. DOE requests comment on whether the proposed standards help resolve 

the potential issue on which it had previously issued clarification of 

whether a [IEC] motor may be considered to be subject to two standards.

2.3.DOE seeks comment on any additional sources of data that could be used 

to establish the distribution of electric motors across equipment class 

groups. 

3.4.DOE seeks comment on any additional sources of data that could be used 

to establish the distribution of electric motors across sectors by 

horsepower range and within each equipment class group.

4.5.DOE seeks comment on any additional sources for determining the 

frequency of motor repair depending on equipment class group and sector.

5.6.DOE seeks comment on any additional sources of data on motor lifetime 

that could be used to validate DOE’s estimates of motor mechanical 

lifetime and its method of estimating lifetimes. DOE defines equipment 

lifetime as the lesser of the age at which electric motors are retired from 

service or the equipment in which they are embedded is retired. For the 

Comment [A52]: Change recommended by 

OIRA.
338

NIA, DOE uses motor average lifetime in years derived from motor 

mechanical lifetime in hours (see Chapter 8, Section 8.2.3) and from 

annual operating hours (see Section 10.2.2.2). DOE based expected 

equipment lifetime on discussions with industry experts and developed a 

distribution of typical lifetimes for several categories of electric motors. 

DOE welcomes further input on the average equipment lifetimes for the 

LCC and NIA analyses.

6.7.DOE seeks comment on the estimated base case distribution of product 

efficiencies and on any additional sources of data.

7.8.DOE seeks comments on its decision to use efficiency trends for 

equipment class groups 1 and 4 and constant efficiencies for equipment 

class groups 2 and 3 over the analysis period. Specifically, DOE would 

like comments on additional sources of data on trends in efficiency 

improvement.

8.9.DOE seeks comment on any sources of data that could be used to establish 

the elasticity of electric motor shipments with respect to changes in 

purchase price.

9.10. DOE seeks comment on its scaled values for MSPs. In particular, 

DOE seeks comments on its methodology for scaling MSP data from the 

representative equipment classes to the remaining equipment classes.

10.11. DOE seeks comment on the scaled values for motor weights. In 

particular, DOE seeks comments on its methodology for scaling weight 

Comment [A53]: Change recommended by 

OIRA.
339

data from the representative equipment classes to the remaining equipment 

classes.

11.12. DOE seeks comment on the trial standard levels (TSLs) developed 

for the NOPR. 

12.13. DOE seeks comment on its proposed compliance date of 

December 19, 2015. 

13.14. DOE seeks comment on its decision to analyze brake motors in a 

separate equipment class group.

14.15. DOE seeks comment on its decision to limit standards for brake 

motors to 1-30 hp, and 4, 6, and 8 pole configurations. DOE selected these 

ratings after reviewing manufacturer catalogs and only finding brake 

motors in these configurations. 

15.16. DOE seeks comment on its decision to not screen out copper diecast copper rotor motors. 

16.17. DOE seeks comment on the availability of copper in the market to 

manufacture die-cast copper rotor motors on a “mass quantity” scale. 

17.18. DOE seeks comment on its decision to not screen out hand 

winding in its analysis. 

18.19. DOE seeks comment on its estimation for labor hours for each 

representative unit. 

19.20. DOE seeks comments on the cost to manufacturers to change their 

product lines to meet EL3. 
340

20.21. DOE seeks comments on the cost to manufacturers to change their 

product lines to meet EL4.

21.22. DOE is aware that motors used in fire pump applications may 

carry various definitions, including, but not limited to, NEMA, IEC, and 

NFPA designations. DOE requests comment on its current definition of 

fire pump motors, the suitability of that definition for the United States 

market, and on its advantages or disadvantages relative to other potential 

definitions. 

22.23. In DOE’s view any Design B or IEC-equivalent motor that 

otherwise satisfies the relevant NFPA requirements would meet the fire 

pump electric motor definition in 10 CFR 431.12. To the extent that there 

is confusion regarding this view, DOE invites comments on this issue, 

along with any data demonstrating whether any IEC-equivalent motors are 

listed for fire pump service either under the NFPA 20 or another relevant 

industry standard.

23.24. DOE seeks data on any other subsets of 56-frame motors, 

particularly those motors that are: (1) enclosed general purpose electric 

motors that have a rating of under 1 horsepower and (2) open, special or 

definite purpose (inclusive) electric motors. The types of data that DOE 

seeks include, but are not limited to, the following categories: efficiency 

distribution; shipment breakdown between horsepower ratings, open and 

enclosed motors, and between general and special and definite purpose 

electric motors; and typical applications that use these motors.
341

25. Currently, DOE’s reference case projects that prices for future shipments 

of motors will remain constant. DOE is seeking input on the 

appropriateness of this assumption. 

26. DOE requests comment on whether there are features or attributes of the 

more energy-efficient electric motors that manufacturers would produce to 

meet the standards in this proposed rule that might affect how they would 

be used by consumers. DOE requests comment specifically on how any 

such effects should be weighed in the choice of standards for the electric 

motors for the final rule.

27. For this rulemaking, DOE analyzed the effects of this proposal assuming 

that the electric motors would be available to purchase for 30 years and 

undertook a sensitivity analysis using 9 years rather than 30 years of 

product shipments. The choice of a 30-year period of shipments is 

consistent with the DOE analysis for other products and commercial 

equipment. The choice of a 9-year period is a proxy for the timeline in 

EPCA for the review of certain energy conservation standards and 

potential revision of and compliance with such revised standards. We are 

seeking input, information and data on whether there are ways to further 

refine the analytic timeline.

28. DOE solicits comment on the application of the new SCC values used to 

determine the social benefits of CO2 emissions reductions over the 

rulemaking analysis period. (The rulemaking analysis period covers from 

2015 to 2044 plus the appropriated number of years to account for the 
342

lifetime of the equipment purchased between 2015 and 2044.) In 

particular, the agency solicits comment on the agency’s derivation of SCC 

values after 2050 where the agency applied the average annual growth rate 

of the SCC estimates in 2040−2050 associated with each of the four sets 

of values.

29. DOE solicits comment on whether its proposal presents a sufficiently 

broad scope of regulatory coverage to help ensure that significant energy 

savings would be met or whether further adjustments to the proposed 

scope – whether to exclude certain categories or to include others – are 

necessary.

30. DOE requests comment on the nine characteristics listed in section III.C

and their appropriateness for outlining scope of coverage.

VIII. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of today’s proposed rule.

Comment [A54]: Changes recommended by 

OIRA.
343

List of Subjects in 10 CFR Part 431

Administrative practice and procedure, Confidential business information, Energy 

conservation, Commercial and industrial Equipment, Imports, Intergovernmental 

relations, Reporting and recordkeeping requirements, and Small businesses. 

Issued in Washington, DC, on 

________________________________

David T. Danielson

Assistant Secretary

Energy Efficiency and Renewable Energy
344

For the reasons set forth in the preamble, DOE proposes to amend part 431 of 

chapter II of title 10 of the Code of Federal Regulations, as set forth below: 

PART 431 - ENERGY CONSERVATION PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL EQUIPMENT

1. The authority citation for part 431 continues to read as follows:

Authority: 42 U.S.C. 6291-6317

2. Revise §431.25 to read as follows:

§431.25 Energy conservation standards and effective dates.

(a) Except as provided for fire pump electric motors in paragraph (b) of this section, 

each general purpose electric motor (subtype I) with a power rating of 1 horsepower or 

greater, but not greater than 200 horsepower, including a NEMA Design B or an 

equivalent IEC Design N motor that is a general purpose electric motor (subtype I), 

manufactured (alone or as a component of another piece of equipment) on or after 

December 19, 2010, but before December 19, 2015, shall have a nominal full-load 

efficiency that is not less than the following:

TABLE 1—NOMINAL FULL-LOAD EFFICIENCIES OF GENERAL PURPOSE ELECTRIC 

MOTORS (SUBTYPE I), EXCEPT FIRE PUMP ELECTRIC MOTORS

Motor horsepower/standard kilowatt equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

6 4 2 6 4 2

1/.75 82.5 85.5 77.0 82.5 85.5 77.0

1.5/1.1 86.5 86.5 84.0 87.5 86.5 84.0

2/1.5 87.5 86.5 85.5 88.5 86.5 85.5

3/2.2 88.5 89.5 85.5 89.5 89.5 86.5

5/3.7 89.5 89.5 86.5 89.5 89.5 88.5

7.5/5.5 90.2 91.0 88.5 91.0 91.7 89.5

10/7.5 91.7 91.7 89.5 91.0 91.7 90.2
345

15/11 91.7 93.0 90.2 91.7 92.4 91.0

20/15 92.4 93.0 91.0 91.7 93.0 91.0

25/18.5 93.0 93.6 91.7 93.0 93.6 91.7

30/22 93.6 94.1 91.7 93.0 93.6 91.7

40/30 94.1 94.1 92.4 94.1 94.1 92.4

50/37 94.1 94.5 93.0 94.1 94.5 93.0

60/45 94.5 95.0 93.6 94.5 95.0 93.6

75/55 94.5 95.0 93.6 94.5 95.4 93.6

100/75 95.0 95.4 93.6 95.0 95.4 94.1

125/90 95.0 95.4 94.1 95.0 95.4 95.0

150/110 95.4 95.8 94.1 95.8 95.8 95.0

200/150 95.4 95.8 95.0 95.8 96.2 95.4

(b) Each fire pump electric motor that is a general purpose electric motor (subtype I) 

or general purpose electric motor (subtype II) manufactured (alone or as a component of 

another piece of equipment) on or after December 19, 2010, but before December 19, 

2015, shall have a nominal full-load efficiency that is not less than the following:

TABLE 2—NOMINAL FULL-LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC 

MOTORS

Motor horsepower/standard

kilowatt equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2

1/.75 74.0 80.0 82.5 -- 74.0 80.0 82.5 75.5

1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5

2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0

3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5

5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5

7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5

10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5

15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2
346

20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2

25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0

30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0

40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7

50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4

60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0

75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0

100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6

125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5

150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5

200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4

300/224 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4

350/261 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4

400/298 -- -- 95.4 95.4 -- -- 95.4 95.4

450/336 -- -- 95.8 95.8 -- -- 95.4 95.4

500/373 -- -- 95.8 95.8 -- -- 95.8 95.4

(c) Except as provided for fire pump electric motors in paragraph (b) of this section, 

each general purpose electric motor (subtype II) with a power rating of 1 horsepower or 

greater, but not greater than 200 horsepower, including a NEMA Design B or an 

equivalent IEC Design N motor that is a general purpose electric motor (subtype II), 

manufactured (alone or as a component of another piece of equipment) on or after 

December 19, 2010, but before December 19, 2015, shall have a nominal full-load 

efficiency that is not less than the following:

TABLE 3—NOMINAL FULL-LOAD EFFICIENCIES OF GENERAL PURPOSE ELECTRIC 

MOTORS (SUBTYPE II), EXCEPT FIRE PUMP ELECTRIC MOTORS

Motor horsepower/

standard kilowatt equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2

1/.75 74.0 80.0 82.5 -- 74.0 80.0 82.5 75.5
347

1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5

2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0

3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5

5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5

7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5

10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5

15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2

20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2

25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0

30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0

40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7

50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4

60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0

75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0

100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6

125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5

150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5

200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0

(d) Each NEMA Design B or an equivalent IEC Design N motor that is a general 

purpose electric motor (subtype I) or general purpose electric motor (subtype II), 

excluding fire pump electric motors, with a power rating of more than 200 horsepower, 

but not greater than 500 horsepower, manufactured (alone or as a component of another 

piece of equipment) on or after December 19, 2010, but before December 19, 2015 shall 

have a nominal full-load efficiency that is not less than the following:

TABLE 4—NOMINAL FULL-LOAD EFFICIENCIES OF NEMA DESIGN B GENERAL 

PURPOSE ELECTRIC MOTORS (SUBTYPE I AND II), EXCEPT FIRE PUMP ELECTRIC 

MOTORS

Motor horsepower/

standard kilowatt equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2
348

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4

300/224 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4

350/261 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4

400/298 -- -- 95.4 95.4 -- -- 95.4 95.4

450/336 -- -- 95.8 95.8 -- -- 95.4 95.4

500/373 -- -- 95.8 95.8 -- -- 95.8 95.4

(e) For purposes of determining the required minimum nominal full-load efficiency 

of an electric motor that has a horsepower or kilowatt rating between two horsepower or 

two kilowatt ratings listed in any table of energy conservation standards in paragraphs (a) 

through (d) of this section, each such motor shall be deemed to have a listed horsepower 

or kilowatt rating, determined as follows:

(1) A horsepower at or above the midpoint between the two consecutive 

horsepowers shall be rounded up to the higher of the two horsepowers;

(2) A horsepower below the midpoint between the two consecutive horsepowers 

shall be rounded down to the lower of the two horsepowers; or

(3) A kilowatt rating shall be directly converted from kilowatts to horsepower using 

the formula 1 kilowatt = ( 1⁄0.746) horsepower. The conversion should be calculated to 

three significant decimal places, and the resulting horsepower shall be rounded in 

accordance with paragraph (e)(1) or (e)(2) of this section, whichever applies.

(f) The standards in Table 1 through Table 4 of this section do not apply to definite 

purpose motors, special purpose motors, or those motors exempted by the Secretary.

(g) The standards in Table 5 through Table 8 of this section apply to electric motors 

that satisfy the following criteria:

(1) Are single-speed, induction motors;

(2) Are rated for continuous duty (MG 1) operation or for duty type S1 (IEC);

(3) Contain a squirrel-cage (MG 1) or cage (IEC) rotor;

(4) Operate on polyphase alternating current 60-hertz sinusoidal line power;

(5) Are rated 600 volts or less;

(6) Have a 2-, 4-, 6-, or 8-pole configuration,

(7) Have a three-digit NEMA frame size (or IEC metric equivalent) or an enclosed 

56 NEMA frame size (or IEC metric equivalent),

(8) Are rated no more than 500 horsepower, but greater than or equal to 1 

horsepower (or kilowatt equivalent), and

(9) Meet all of the performance requirements of one of the following motor types: a 

NEMA Design A, B, or C motor or an IEC design N or H motor.
349

(h) Starting on December 19, 2015, each NEMA Design A and NEMA Design B 

motor that is an electric motor meeting the criteria in paragraph (g) of this section 

and with a power rating from 1 horsepower through 500 horsepower, but excluding 

fire pump electric motors, integral-brake electric motors, and non-integral brake 

electric motors, manufactured (alone or as a component of another piece of 

equipment) shall have a nominal full-load efficiency of not less than the following:

TABLE 5 – NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN A AND NEMA

DESIGN B ELECTRIC MOTORS (EXCLUDING FIRE PUMP ELECTRIC MOTORS, INTEGRALBRAKE ELECTRIC MOTORS, AND NON-INTEGRAL BRAKE ELECTRIC MOTORS)

Motor 

Horsepower

/Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

2 Pole 4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open Enclosed Open

1/.75 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2

20/15 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0

30/22 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7

40/30 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7

50/37 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4

60/45 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0

75/55 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1

100/75 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1

125/90 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1

150/110 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1

200/150 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1

250/186 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0

300/224 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0

350/261 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0

400/298 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0

450/336 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0

500/373 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
350

(i) Starting on December 19, 2015, each NEMA Design C electric motor that is an 

electric motor meeting the criteria in paragraph (g) of this section and with a power rating 

from 1 horsepower through 200 horsepower, but excluding non-integral brake electric 

motors and integral brake electric motors, manufactured (alone or as a component of 

another piece of equipment) shall have a nominal full-load efficiency that is not less than 

the following:

TABLE 6 – NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN C ELECTRIC 

MOTORS (EXCLUDING NON-INTEGRAL BRAKE ELECTRIC MOTORS AND INTEGRAL BRAKE 

ELECTRIC MOTORS)

Motor 

Horsepower/ 

Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open

1/.75 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 92.4 93.0 91.7 91.7 89.5 90.2

20/15 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 93.6 93.6 93.0 93.0 90.2 91.0

30/22 93.6 94.1 93.0 93.6 91.7 91.7

40/30 94.1 94.1 94.1 94.1 91.7 91.7

50/37 94.5 94.5 94.1 94.1 92.4 92.4

60/45 95.0 95.0 94.5 94.5 92.4 93.0

75/55 95.4 95.0 94.5 94.5 93.6 94.1

100/75 95.4 95.4 95.0 95.0 93.6 94.1

125/90 95.4 95.4 95.0 95.0 94.1 94.1

150/110 95.8 95.8 95.8 95.4 94.1 94.1

200/150 96.2 95.8 95.8 95.4 94.5 94.1
351

(j) Starting on December 19, 2015, each fire pump electric motor meeting the 

criteria in paragraph (g) of this section and with a power rating of 1 horsepower through 

500 horsepower, manufactured (alone or as a component of another piece of equipment) 

shall have a nominal full-load efficiency that is not less than the following:

TABLE 7 – NOMINAL FULL LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS

Motor 

Horsepower

/Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

2 Pole 4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open Enclosed Open

1/.75 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0

1.5/1.1 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5

2/1.5 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5

3/2.2 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5

5/3.7 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5

7.5/5.5 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5

10/7.5 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5

15/11 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5

20/15 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2

25/18.5 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2

30/22 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0

40/30 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0

50/37 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7

60/45 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4

75/55 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6

100/75 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6

125/90 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6

150/110 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6

200/150 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6

250/186 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5

300/224 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5

350/261 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5

400/298 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5

450/336 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5

500/373 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5
352

(k) Starting on December 19, 2015, each integral brake electric motor and nonintegral brake electric motor meeting the criteria in paragraph (g) and with a power rating 

of 1 horsepower through 30 horsepower, manufactured (alone or as a component of 

another piece of equipment) shall have a nominal full-load efficiency that is not less than 

the following:

TABLE 8 – NOMINAL FULL LOAD EFFICIENCIES OF INTEGRAL BRAKE ELECTRIC 

MOTORS AND NON-INTEGRAL BRAKE ELECTRIC MOTORS

Motor 

Horsepower/ 

Standard 

Kilowatt 

Equivalent

Nominal Full Load Efficiency (%)

4 Pole 6 Pole 8 Pole

Enclosed Open Enclosed Open Enclosed Open

1/.75 85.5 85.5 82.5 82.5 75.5 75.5

1.5/1.1 86.5 86.5 87.5 86.5 78.5 77.0

2/1.5 86.5 86.5 88.5 87.5 84.0 86.5

3/2.2 89.5 89.5 89.5 88.5 85.5 87.5

5/3.7 89.5 89.5 89.5 89.5 86.5 88.5

7.5/5.5 91.7 91.0 91.0 90.2 86.5 89.5

10/7.5 91.7 91.7 91.0 91.7 89.5 90.2

15/11 92.4 93.0 91.7 91.7 89.5 90.2

20/15 93.0 93.0 91.7 92.4 90.2 91.0

25/18.5 93.6 93.6 93.0 93.0 90.2 91.0

30/22 93.6 94.1 93.0 93.6 91.7 91.7

(l) For purposes of determining the required minimum nominal full-load efficiency 

of an electric motor that has a horsepower or kilowatt rating between two horsepower or 

two kilowatt ratings listed in any table of energy conservation standards in paragraphs (h) 

through (k) of this section, each such motor shall be deemed to have a listed horsepower 

or kilowatt rating, determined as follows:

(1) A horsepower at or above the midpoint between the two consecutive 

horsepowers shall be rounded up to the higher of the two horsepowers;

(2) A horsepower below the midpoint between the two consecutive horsepowers 

shall be rounded down to the lower of the two horsepowers; or

(3) A kilowatt rating shall be directly converted from kilowatts to horsepower using 

the formula 1 kilowatt = ( 1

⁄0.746) horsepower. The conversion should be calculated to 

three significant decimal places, and the resulting horsepower shall be rounded in 

accordance with paragraph (l)(1) or (l)(2) of this section, whichever applies.
353

(m) The standards in Table 5 through Table 8 of this section do not apply to the 

following electric motors exempted by the Secretary, or any additional electric motors 

that the Secretary may exempt:

(1) Air-over electric motors;

(2) Component sets of an electric motor;

(3) Liquid-cooled electric motors;

(4) Submersible electric motors; and

(5) Definite-purpose, inverter-fed electric motors.