Appliance Standards and Rulemaking Federal Advisory Committee

Commercial and Industrial Pumps Working Group

Interim Report

June 4, 2014

Background

On June 27, 2013, members of the Appliance Standards and Rulemaking Federal Advisory 

Committee (ASRAC) voted unanimously to form a working group to negotiate a proposed 

regulation setting energy efficiency standards for Commercial and Industrial Pumps. 

A notice of intent to form the Pumps WG was published in the Federal Register on November 

12, 2013. DOE received 19 nominations for membership. Of the 19 nominations, 16 were 

selected to serve as members, including one member from ASRAC, and one DOE representative 

(see Appendix A). The Pumps WG held its first two-day meeting at the U.S. Department of 

Energy’s headquarters in Washington, DC on December 18-19, 2013. This is the first time that 

the pumps industry would be subject to energy efficiency regulation. 

Getting Started

During the working group’s first meeting, members discussed:

• Modifications to the draft Working Group Ground Rules and voted unanimously to adopt 

them, including a consensus definition: no more than two votes against a proposal to 

adopt

• DOE’s preliminary thinking on the definition of pump and potential scope 

• Scheduling issues—how the potential scope of the negotiation would fit/correspond to 

the proposed WG schedule. The WG established seven additional two-day meeting 

dates. 

Over the course of the next three 2-day meetings (January 30 – 31; March 4 - 5; and March 26 –

27, 2014) the WG focused on the definition of covered product, defining the scope of 

negotiations and determining a metric for pump efficiency.

Definition of Covered Product

Regarding the definition of covered product, the WG voted (15 yes/1 no on 3/4/14) to define 

‘pump’ as follows: “a device that moves liquids (which may include entrained gases, free solids, 

and totally dissolved solids) by physical or mechanical action and includes a bare pump and, if 

included by the manufacturer, the mechanical equipment, driver, and controls.” The WG also 

separately defined (15 yes/1 absent on 3/4/14) ‘bare pump,’ ‘mechanical equipment,’ ‘driver,’ 

and ‘controls.’

While the definition of the covered product includes pumps driven by non-electric drivers, the 

WG voted (unanimous on 3/26/14) that in this rulemaking, the metric will not include nonelectric drivers. Instead, pumps with non-electric drivers will be subject to standards for bare 

pumps.
In-Scope Pumps

The WG voted by consensus (15 yes/1 abstain on 3/26/14) that the scope of this rulemaking be 

limited to the following pump types: 

• End suction frame mounted/own bearings (ESFM/OH0, OH1)

• End suction close coupled (ESCC/OH7)

• Inline (IL/OH3, OH4, OH5)

• Radial split (multistage) vertical (RS-V/VS8)

• Vertical turbine submersible (VT-S/VS0)

The scope is consistent with that originally proposed by HI. The HI scope is also consistent with 

the European regulatory regime included in ‘Lot 11’. 

Parameters for Standards

The WG adopted by consensus (15 yes/1 absent on 3/4/14) parameters for this rulemaking, 

which were a slightly modified version of the manufacturers’ caucus proposal:

• Full impeller diameter

• 1-200 Horsepower (shaft power at BEP) 

• 25 gallons/minute and greater (at BEP)

• 459 feet of head maximum (at BEP)

• Design temperature range from -10 to 120 degrees C

• Pumps designed for nominal 3600 or 1800 rpm driver speeds

• 6 inch or smaller bowl diameter (VT-S/HI VSO)

Excluded Pumps

The discussion on parameters was accompanied by detailed discussion on the potential scope of 

negotiations, specifically the pump types that should be excluded. Of particular interest was 

limiting the scope to pumps designed for use in pumping clean water. Over the span of the three 

meetings, the WG ultimately decided to exclude (by various votes: unanimous on 1/31/14, 14 

yes/2 absent on 3/4/14, and unanimous on 3/26/14) the following pump types that might 

otherwise meet the definition of an in-scope pump type (i.e. ESCC, ESFM, etc.):

• Wastewater, sump, slurry, solids handling

• API 610 pumps

• ASME/ISO chemical process pumps

• Fire pumps (which meet NFPA 20, UL listed or FM approved)

• Self-priming pumps

• Prime-assisted pumps

• Nuclear pumps

• Navy pumps

• Sanitary pumps

By limiting the scope of this rulemaking to the five pump types previously identified as in-scope, 

the WG determined (by various votes: unanimous on 1/31/14, 15 yes/1 abstain on 3/26/14) that 

various other pump types that may have been previously considered as part of this rulemaking 

would be excluded:
• Positive displacement

• Axial/mixed flow 

• Double suction

• Multistage axially split

• Multistage radial split-horizontal

• Multistage radial split vertical immersible

• Vertical turbine (non-submersible)

Finally, the WG voted (15 yes/1 abstain on 3/26/14) to hold circulators and dedicated-purpose 

pool pumps for a second negotiation, for which they planned to make a recommendation to 

ASRAC.

Determining a Metric

As the WG voted to define the covered product, a pump, as inclusive of driver and controls, the 

existing industry metrics (i.e., pump efficiency, MEI) were not adequate to represent the energy 

use of a covered product. As a result, the WG spent a significant amount of time in meetings five 

and six (April 29-30, May 28-29) engaged in developing a new metric that includes not only bare 

pump performance, but can also capture performance of motors and controls. It seems that the 

WG is very close to accepting a version of the metric (some members called for a preliminary 

vote of acceptance, but other members wanted more time to test the impacts of the proposal). 

As currently proposed (and largely accepted by a large majority of the WG—an individual or 

two seem to be undecided), the construct of the metric would include a numerator of equally 

weighted average electric input power to the ‘pump’ measured (or calculated) over a specified 

load profile and a denominator of the weighted average electric input power for a minimally 

compliant pump (i.e., the maximum power allowed for a given pump based on an 

uncontrolled/constant load). The load points (and speed for testing at each of those points) used 

in the numerator would be different for bare pumps and pumps with motors (e.g., a constant load 

rating) versus any pump sold into the market in combination with a motor and/or controls (e.g., a 

variable load rating). This construct demonstrates significantly lower power for pumps with 

controls. 

This metric will likely be called the Pump Efficiency Index (PEI). In order to pass the standard, 

the PEI would have to be less than or equal to 1. The manufacturers’ caucus has proposed that 

both constant and variable load ratings would be shown on every pump; but details on standards 

and levels have not yet been determined. The beauty of this construct is that it enables a pump 

consumer to do efficiency comparisons across various pumps and pump/motor/controls

combinations. 

Initial Standard Level Proposals

Also in meetings number five and six, the WG conducted a detailed review/discussion on the:

• Engineering Analysis (noting significant data/analysis gaps and deficiencies that were 

corrected)

• Life Cycle Cost (LCC) Analysis

• Shipments Analysis 
• National Impact Analysis (NIA) and

• Manufacturer Impact Analysis (MIA)

After reviewing all provided results, in meeting #6, the two principal caucuses exchanged, for 

the first time, standard-setting proposals. The manufacturers’ caucus proposed meeting a 

standard of PEI-15, which would set a level which presumes to eliminate 15% of current pumps 

from the market by the compliance date. The caucus leader noted this level is higher than where 

the European Union (EU) set its initial efficiency threshold, which was designed to eliminate 

only 10% of pumps from the market. This resurfaced a consistent theme that had emerged in 

discussion and analysis—at higher efficiency levels, manufacturer impacts are very significant. 

The energy-efficiency advocates caucus responded by setting a performance target for the 

industry. The caucus spokesperson said they would like to achieve .25 quads of cumulative 

national energy savings over the analysis period. This would correspond to PEI-40. It was noted 

that this corresponded to a higher efficiency level than the EU’s new MEI-40 standard, which 

goes into effect on January, 2015 – MEI-40 is roughly equivalent to PEI-25-30.

As the meeting concluded, in response to WG request, the DOE General Counsel’s office 

reported that the compliance date was not a rigid five years after the rule is published, as 

presented earlier. This means the WG could be more flexible and, for example, choose rolling 

compliance dates for different pump types. However, the six-year presumed follow-up window 

remains in effect.

Test Procedure

Members of the WG also expressed an interest in having a detailed consideration/discussion on 

the test procedure. DOE has said it intended to create a pumps test procedure by its normal 

rulemaking methods. HI has just completed its test procedure deliberation and established its 

method for bare pumps. DOE’s effort would expand the test procedure coverage to include 

pump-motor-controls combinations to account for the entire covered product. Some members 

were cautious about taking on new responsibilities given the time that remains (two, three-day 

meetings) and the work load to be completed. After discussion, the WG concluded that it would 

take up the test procedure if time allows. 

Conclusion

With initial proposals on the table and a metric ready for a consensus vote, the WG seems poised 

to complete its task. While moving very deliberately, the WG has nevertheless established an 

effective collaboration. The WG has functional caucuses and effective caucus leadership. While 

nothing is certain in this environment, these features bode well for completion of a term sheet in 

the next two scheduled meetings.

Interim Report prepared by Doug Brookman and Alison Williams

publicsolutions@earthlink.net; 

aawilliams@lbl.gov
Appendix A—Members 

U.S. Department of Energy—ASRAC 

Commercial and Industrial Pumps Negotiated Rulemaking Working Group

Lucas Adin U.S. Department of Energy

Tom Eckman Northwest Power and Conservation Council (ASRAC Member)

Robert Barbour TACO, Inc.

Charles Cappelino ITT Industrial Process

Greg Case Pump Design, Development and Diagnostics

Gary Fernstrom California IOUs

Mark Handzel Xylem Corporation

Albert Huber Patterson Pump Company

Joanna Mauer Appliance Standards Awareness Project

Doug Potts American Water

Charles Powers Flowserve Corporation, Industrial Pumps

Steve Rosenstock Edison Electric Institute

Louis Starr Northwest Energy Efficiency Alliance

Greg Towsley Grundfos USA

Meg Waltner Natural Resources Defense Council