[6450-01-P]
 

DEPARTMENT OF ENERGY
 

10 CFR Part 431 


[Docket Number EERE–2007–BT-STD–0007] 


RIN 1904–AB70 


Energy Conservation Program: Energy Conservation Standards for Small Electric Motors 

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

ACTION: Final rule. 

SUMMARY: The U.S. Department of Energy (DOE) is adopting energy conservation standards 

for small electric motors. DOE has determined that these standards will result in significant 

conservation of energy, and are technologically feasible and economically justified. 

EFFECTIVE DATE: The effective date of this rule is [INSERT DATE 30 DAYS FROM 

DATE OF PUBLICATION]. The standards established in today’s final rule will be applicable 

starting [INSERT DATE 5 YEARS FROM DATE OF PUBLICATION]. 

ADDRESSES: For access to the docket to read background documents, the technical support 

document, transcripts of the public meetings in this proceeding, or comments received, visit the 

U.S. Department of Energy, Resource Room of the Building Technologies Program, 950 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

L’Enfant Plaza, SW., 6th Floor, Washington, DC 20024, (202) 586–2945, between 9 a.m. and 4 


p.m., Monday through Friday, except Federal holidays. Please call Ms. Brenda Edwards at the 

above telephone number for additional information regarding visiting the Resource Room. (Note: 

DOE’s Freedom of Information Reading Room no longer houses rulemaking materials.) You 

may also obtain copies of certain previous rulemaking documents in this proceeding (i.e., 

framework document, notice of public meeting and availability of preliminary technical support 

document, notice of proposed rulemaking, draft analyses, public meeting materials, and related 

test procedure documents from the Office of Energy Efficiency and Renewable Energy’s website 

at 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/small_electric_motors.ht 

ml. 

FOR FURTHER INFORMATION CONTACT: 

Mr. 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, (202) 586–8654, e-mail: Jim.Raba@ee.doe.gov. 

Mr. Michael Kido., U.S. Department of Energy, Office of General Counsel, GC–72, 1000 

Independence Avenue, SW., Washington, DC 20585, (202) 586–8145, e-mail: 

Michael.Kido@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

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EERE-2007-BT-STD-0007 COMMENT 31
I. Summary of the Final Rule and Its Benefits

A. Energy Conservation Standards Levels

B. Benefits and Burdens to Customers of Small Electric Motors

C. Impact on Manufacturers

D. National Benefits

E. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Energy Conservation Standards

2. History of Standards Rulemaking for Small Electric Motors

III. General Discussion

A. Test Procedures

B. Technological Feasibility

1. General

2. Maximum Technologically Feasible Levels

C. Energy Savings

D. Economic Justification

1. Specific Criteria

a. Economic Impact on Motor Customers and Manufacturers

b. Life-Cycle Costs

c. Energy Savings

d. Lessening of Utility or Performance of Equipment

e. Impact of Any Lessening of Competition

f. Need of the Nation to Conserve Energy

g. Other Factors

2. Rebuttable Presumption

IV. Methodology and Discussion of Comments on Methodology

A. Market and Technology Assessment

1. Definition of Small Electric Motor

a. Motor Categories

b. Horsepower Ratings

c. Performance Requirements

d. Motor Enclosures

e. Frame Sizes

f. Insulation Class Systems

g. Service Factors

h. Metric Equivalents and Non-Standard Horsepower and Kilowatt Ratings

i. Summary

2. Product Classes

B. Screening Analysis

C. Engineering Analysis

1. Product Classes Analyzed

2. Baseline Models

a. Baseline Efficiencies

b. Baseline Temperature Rise

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EERE-2007-BT-STD-0007 COMMENT 31
c. Baseline Motor Performance 

3. Higher Efficiency Motor Designs 

a. Electrical Steel 

b. Thermal Analysis 

c. Performance Requirements 

d. Stray Load Loss 

e. Stack Length and Core Diameter 

4. Cost Model 

5. Efficiency Scaling 

6. Cost-Efficiency Results 

D. Markups to Determine Equipment Price 

E. Energy Use Characterization 

1. Applications 

2. Annual Hours of Operation and Motor Loading 

F. Life-Cycle Cost and Payback Period Analysis 

1. Installation Cost 

2. Energy Prices 

3. Energy Price Trend 

4. Maintenance and Repair Costs 

5. Equipment Lifetime 

6. Discount Rates 

7. Space-Constrained Applications and the After-Market 

8. Standard Compliance Date 

G. National Impact Analysis-National Energy Savings and Net Present Value Analysis 

1. General 

2. Shipments 

3. Space Constraints 

4. Base-Case and Standards-Case Efficiency Distributions 

5. Annual Energy Consumption per Unit 

H. Customer Sub-Group Analysis 

I. Manufacturer Impact Analysis 

1. Capital Conversion and Equipment Conversion Costs 

2. Manufacturer Selling Prices 

3. Markup Scenarios 

4. Premium Electrical Steels 

J. Employment Impact Analysis 

K. Utility Impact Analysis 

L. Environmental Assessment 

M. 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. Approach and Key Assumptions 

2. Monetary Values of Non-Carbon Emissions 

V. Discussion of Other Comments 

A. Trial Standard Levels 

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EERE-2007-BT-STD-0007 COMMENT 31
B. Enforcement 

C. Nominal Full-Load Efficiency 

VI. Analytical Results and Conclusions 

A. Trial Standard Levels 

B. Significance of Energy Savings 

C. Economic Justification 

1. Economic Impact on Motor Customers 

a. Life-Cycle Costs and Payback Period 

b. Life-Cycle Cost Sensitivity Calculations 

c. Customer Subgroup Analysis 

d. Rebuttable Presumption Payback 

2. Economic Impact on Manufacturers 

a. Industry Cash-Flow Analysis Results 

b. Impacts on Employment 

c. Impacts on Manufacturing Capacity 

d. Impacts on Subgroups of Manufacturers 

e. Cumulative Regulatory Burden 

3. National Net Present Value and Net National Employment 

4. Impact on Utility or Performance of Equipment 

5. Impact of Any Lessening of Competition 

6. Need of the Nation To Conserve Energy 

7. Other Factors 

D. Conclusion 

VII. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866 

B. Review Under the Regulatory Flexibility Act 

C. Review Under the Paperwork Reduction Act 

D. Review Under the National Environmental Policy Act 

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 

M. Congressional Notification 

VIII. Approval of the Office of the Secretary 

I. Summary of the Final Rule and Its Benefits 

A. Energy Conservation Standards Levels 

The Energy Policy and Conservation Act, as amended (42 U.S.C. 6291 et seq.; EPCA or 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

the Act), directs the U.S. Department of Energy (DOE) to adopt energy conservation standards 


for those small electric motors for which standards would be technologically feasible and 

economically justified, and would result in significant energy savings (42 U.S.C. 6317(b)(1)-(2)). 

The standards in today’s final rule satisfy these requirements and will achieve the maximum 

improvements in energy efficiency that are technologically feasible and economically justified. 

Table I.1 and Table I.2 show these standard levels, which will apply to all small electric motors 

manufactured for sale in the United States, or imported into the United States, starting five years 

after publication of this final rule. 

Table I.1 Standard Levels for Polyphase Small Electric Motor 

Motor Output Power Six Poles Four Poles Two Poles 

0.25 Hp/0.18 kW 67.5 69.5 65.6 

0.33 Hp/0.25 kW 71.4 73.4 69.5 

0.5 Hp/0.37 kW 75.3 78.2 73.4 

0.75 Hp/0.55 kW 81.7 81.1 76.8 

1 Hp/0.75 kW 82.5 83.5 77.0 

1.5 Hp/1.1 kW 83.8 86.5 84.0 

2 Hp/1.5 kW N/A 86.5 85.5 

3 Hp/2.2 kW N/A 86.9 85.5 

*Standard levels are expressed in terms of average full-load efficiency. 


**These efficiencies correspond to a modified Trial Standard Level 4b for polyphase motors. For horsepower/pole 


configurations with efficiency standards higher than the for general purpose electric motors (subtype I), DOE 


reduced the standard level to align with regulations in 10 CFR 431.25. See section VI for further discussion.
 

Table I.2 Standard Levels for Capacitor-Start Induction-Run and Capacitor-Start 

Capacitor-Run Small Electric Motors 

Motor Output Power Six Poles Four Poles Two Poles 

0.25 Hp/0.18 kW 62.2 68.5 66.6 

0.33 Hp/0.25 kW 66.6 72.4 70.5 

0.5 Hp/0.37 kW 76.2 76.2 72.4 

0.75 Hp/0.55 kW 80.2 81.8 76.2 

1 Hp/0.75 kW 81.1 82.6 80.4 

1.5 Hp/1.1 kW N/A 83.8 81.5 

2 Hp/1.5 kW N/A 84.5 82.9 

3 Hp/2.2 kW N/A N/A 84.1 

*Standard levels are expressed in terms of full-load efficiency.
 

**These efficiencies correspond to a modified Trial Standard Level 7 for capacitor-start motors. DOE reduced 


efficiency standards for capacitor-start induction run motors such that they harmonize with adopted capacitor-start 


capacitor-run motor efficiency standards. See section VI for further discussion.
 

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EERE-2007-BT-STD-0007 COMMENT 31
B. Benefits and Burdens to Customers of Small Electric Motors 

Table I.3 presents the implications of today’s standards for consumers of small electric 

motors. The economic impacts of the standards consumers as measured by the average life-cycle 

cost (LCC) savings are positive, even though the standards may increase some initial costs. For 

example, a typical polyphase motor has an average installed price of $517 and average lifetime 

operating costs (discounted) of $751. To meet the amended standards, DOE estimates that the 

average installed price of such equipment will increase by $72, which will be more than offset by 

savings of $100 in average lifetime operating costs (discounted). 

Table I.3 Implications of Standards for Commercial Consumers 

Equipment Class 

Energy 

Conservation 

Standard 

% 

Average 

Installed 

Price* 

$ 

Average 

Installed 

Price 

Increase 

$ 

Average 

Life-Cycle 

Cost 

Savings 

$ 

Median 

Payback 

Period 

Years 

Polyphase, 

1-horsepower, 4-pole 83.5 589 72 28 7.8 

Capacitor-start 

induction-run, 

1⁄2-horsepower, 4-pole 

76.2 996 502 -369 12.4 

Capacitor-start 

capacitor-run, 

3/4 horsepower, 4-pole 

81.8 599 51 24 5.9 

* For a baseline model. 

C. Impact on Manufacturers 

Using a real corporate discount rate of 9.7 percent, which DOE calculated by examining 

the financial statements of motor manufacturers, DOE estimates the industry net present value 

(INPV) of the small electric motor manufacturing industry to be $70 million for polyphase small 

electric motors and $279 million for capacitor-start, or single-phase motors (both figures in 

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EERE-2007-BT-STD-0007 COMMENT 31
2009$). DOE expects the impact of the standards on the INPV of manufacturers of small electric 


motors to range from a increase of 4.8 percent to a loss of 7.8 percent (an increase of $3.4 

million to a loss of $5.4 million) for polyphase motors and an increase of 6.6 percent to a loss of 

12.2 percent (an increase of $32.2 million to a loss of $42.2 million) for single-phase motors. 

Based on DOE’s interviews with the major manufacturers of small electric motors, DOE expects 

minimal plant closings or loss of employment as a result of the standards. 

D. National Benefits 

The standards will provide significant benefits to the Nation. DOE estimates the 

standards will save approximately 2.2 quads (quadrillion (1015) British thermal units (BTU)) of 

energy over 30 years (2015–2045). This is equivalent to about 2.2% of total annual US energy 

consumption. 

By 2045, DOE expects the energy savings from the standards to eliminate the need for 

approximately eight new 250-megawatt (MW) power plants. These energy savings will result in 

cumulative greenhouse gas emission reductions of approximately 112 million tons (Mt) of 

carbon dioxide (CO2), or an amount equal to that produced by approximately 25 million new cars 

in a year. Additionally, the standards will help alleviate air pollution by resulting in 

approximately 81 thousand tons (kt) of nitrogen oxides (NOX) emission reductions and 

approximately 0.49 ton of cumulative mercury (Hg) emission reductions from 2015 through 

2045. The estimated net present monetary values of these emissions reductions is between $385 

and $6,081 million for CO2, (expressed in 2009$). The estimated net present monetary values of 

these emissions reductions are between $13.2 and $63.4 million for NOX (expressed in 2009$) 

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EERE-2007-BT-STD-0007 COMMENT 31
 

and $0.12 and $5.14 million for Hg (expressed in 2009$) at a 7-percent discount rate (discounted 


to 2010). At a 3 percent discount rate, the estimated net present values of these emissions 

reductions are between $17.1 and $175.5 million (2009$) for NOX and $0.22 and $9.66 million 

(2009$) for Hg. 

The national NPV of the standards is $5.3 billion using a seven-percent discount rate and 

$12.5 billion using a three-percent discount rate, cumulative from 2015 to 2045 in 2009$. This is 

the estimated total value of future savings minus the estimated increased equipment costs, 

discounted to the year 2009. 

The benefits and costs of today’s rule can also be expressed in terms of annualized 

(2009$) values from 2015–2045. Estimates of annualized values are shown in Table I.4. The 

annualized monetary values are the sum of the annualized national economic value of operating 

savings benefits (energy, maintenance and repair), expressed in 2009$, plus the monetary value 

of the benefits of CO2 emission reductions, otherwise known as the Social Cost of Carbon (SCC), 

calculated using the average value derived using a 3% discount rate (equivalent to $21.40 per 

metric ton of CO2 emitted in 2010, in 2007$). This value is a central value from a recent 

interagency process. The monetary benefits of cumulative emissions reductions are reported in 

2009$ so that they can be compared with the other costs and benefits in the same dollar units. 

The derivation of this value is discussed in section IV.M. Although comparing the value of 

operating savings to the value of CO2 reductions provides a valuable perspective, please note the 

following: 1) The national operating savings are domestic U.S. consumer monetary savings 

found in market transactions while the value of CO2 reductions is based on a global value. Also, 

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EERE-2007-BT-STD-0007 COMMENT 31
note that the central value is only one of four SCC developed by the interagency workgroup. 


Other marginal SCC values for 2010 are $4.70, $35.10, and $64.90 per metric ton (2007$ for 

emissions in 2010), which reflect different discount rates and, for the highest value, the 

possibility of higher-than-expected impacts further out in the tails of the SCC distribution. 2) The 

assessments of operating savings and CO2 savings are performed with different computer 

models, leading to different time frames for analysis. The national operating cost savings is 

measured for the lifetime of small electric motors shipped in the 31-year period 2015–2045. The 

value of CO2, on the other hand, reflects the present value of all future climate related impacts 

due to emitting a ton of carbon dioxide in that year, out to 2300. 

Using a 7-percent discount rate for the annualized cost analysis, the combined cost of the 

standards proposed in today’s proposed rule for small electric motors is $263.9 million per year 

in increased equipment and installation costs, while the annualized benefits are $855.1 million 

per year in reduced equipment operating costs, $115.6 million in CO2 reductions, $3.89 million 

in reduced NOx emissions, and $0.30 million in reduced Hg emissions, for a net benefit of 

$711.0 million per year. Using a 3-percent discount rate, the cost of the standards proposed in 

today’s rule is $263.7 million per year in increased equipment and installation costs, while the 

benefits of today’s standards are $989.5 million per year in reduced operating costs, $115.6 

million in CO2 reductions, $5.58 million in reduced NOx emissions, and $0.29 million in reduced 

Hg emissions, for a net benefit of $847.3 million per year. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

Table I.4 Annualized Benefits and Costs for Small Electric Motors
 

Category 

Primary 

Estimate 

(AEO 

Reference 

Case) 

Low 

Estimate 

(Low 

Energy 

Price 

Case) 

High 

Estimate 

(High 

Energy 

Price 

Case) 

Units 

Year 

Dollars 

Disc. 

Rate 

Period 

Covered 

Benefits 

Energy 

Annualized 

Monetized 

(millions$/year) 

855.1 831.8 870.3 2009 7% 31 

989.5 964.8 1000.5 2009 3% 31 

Annualized 

Quantified 

2.29 CO2 

(Mt) 

2.29 CO2 

(Mt) 

2.29 CO2 

(Mt) NA 7% 31 

1.55 NOx 

(kt) 

1.55 NOx 

(kt) 

1.55 NOx 

(kt) NA 7% 31 

0.017 Hg 

(t) 

0.017 Hg 

(t) 

0.017 Hg 

(t) NA 7% 31 

3.13 CO2 

(Mt) 

3.13 CO2 

(Mt) 

3.13 CO2 

(Mt) NA 3% 31 

2.22 NOx 

(kt) 

2.22 NOx 

(kt) 

2.22 NOx 

(kt) NA 3% 31 

0.017 Hg 

(t) 

0.017 Hg 

(t) 

0.017 Hg 

(t) NA 3% 31 

CO2 Monetized 

Value (at 

$4.7/Metric Ton, 

millions$/year)* 

31.5 31.5 31.5 2009 5% 31 

CO2 Monetized 

Value (at 

$21.4/Metric Ton, 

millions$/year)* 

115.6 115.6 115.6 2009 3% 31 

CO2 Monetized 

Value (at 

$35.1/Metric Ton, 

millions$/year)* 

179.2 179.2 179.2 2009 2.5% 31 

CO2 Monetized 

Value (at 

$64.9/Metric Ton, 

millions$/year)* 

352.5 352.5 352.5 2009 3% 31 

NOx Monetized 

Value (at 

$2,437/Metric Ton, 

millions$/year) 

3.89 3.89 3.89 2009 7% 31 

5.58 5.58 5.58 2009 3% 31 

Hg Monetized 

Value (at $17 

million/Metric Ton, 

millions$/year) 

0.3 0.3 0.3 2009 7% 31 

0.29 0.29 0.29 2009 3% 31 

Total Monetary 

Benefits 

(millions$/year)** 

890.8 – 

1211.8 

867.5 – 

1188.5 

906.0 – 

1227.0 2009 7% 

Range 31 

974.9 951.6 990.1 2009 7% 31 

1111.0 1086.3 1121.9 2009 3% 31 

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EERE-2007-BT-STD-0007 COMMENT 31
 

1026.9 – 

1347.9 

1002.2 – 

1323.2 

1037.8 – 

1358.8 2009 3% 

Range 31 

Costs 

Annualized 

Monetized 

(millions$/year) 

263.9 263.9 263.9 2009 7% 31 

263.7 263.7 263.7 2009 3% 31 

Net Benefits/Costs 

Annualized 

Monetized, 

including CO2 

Benefits 

(million$/year)** 

626.9 – 

947.9 

603.6 – 

924.6 

642.1 – 

963.1 2009 7% 

Range 31 

711.0 687.7 726.2 2009 7% 31 

847.3 822.6 858.3 2009 3% 31 

763.2 – 

1084.3 

738.5 – 

1059.6 

774.2 – 

1095.2 2009 3% 

Range 31 

* These values represent global values (in 2007$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.7, $21.4, and $35.1 per ton are the averages of SCC distributions calculated using 5%, 

3%, and 2.5% discount rates, respectively. The value of $64.9 per ton represents the 95th percentile of the SCC 

distribution calculated using a 3% discount rate. See section IV.M for details. 

** Total Monetary Benefits for both the 3% and 7% cases utilize the central estimate of social cost of CO2 emissions 

calculated at a 3% discount rate (averaged across three IAMs), which is equal to $21.4/ton in 2010 (in 2007$). The 

rows labeled as “7% Range” and “3% Range” calculate consumer, Hg, and NOx cases with the labeled discount rate 

but add these values to the full range of CO2 values with the $4.7/ton value at the low end, and the $64.9/ton value at 

the high end. 

E. Conclusion 

DOE has concluded that the benefits (energy savings, consumer LCC savings, national 

NPV increases, and emissions reductions) to the Nation of today’s standards for small electric 

motors outweigh their costs (loss of manufacturer INPV and consumer LCC increases for some 

users of small electric motors). DOE has also concluded that these standards are technologically 

feasible and economically justified, and will result in significant energy savings. Small electric 

motors that are commercially available or working prototypes use or have used the technologies 

needed to meet the new standard levels. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

II. Introduction 

A. Authority 

Title III of EPCA sets forth a variety of provisions designed to improve energy 

efficiency. Part A of Title III (42 U.S.C. 6291–6309) provides for the Energy Conservation 

Program for Consumer Products Other than Automobiles. Part A-1 of Title III (42 U.S.C. 6311– 

6317) establishes a similar program for “Certain Industrial Equipment,” which includes small 

electric motors, the subject of this rulemaking.1

 DOE publishes today’s final rule pursuant to Part 

A-1 of Title III, which provides for test procedures, labeling, and energy conservation standards 

for small electric motors and certain other equipment, and authorizes DOE to require information 

and reports from manufacturers. The test procedures DOE recently adopted for small electric 

motors, 74 FR 32059 (July 7, 2009), appear at Title 10, Code of Federal Regulations (CFR), 

sections 431.443, 431.444, and 431.445. 

The Act defines “small electric motor” as follows: 

[A] NEMA [National Electrical Manufacturers Association] general purpose alternating 

current single-speed induction motor, built in a two-digit frame number series in 

accordance with NEMA Standards Publication MG1-1987. 

(42 U.S.C. 6311(13)(G)) EPCA requires DOE to prescribe energy conservation standards for 

those small electric motors for which DOE: (1) has determined that standards would be 

technologically feasible and economically justified and would result in significant energy 

1

 These two parts were titled Parts B and C in EPCA, but were codified as Parts A and A–1 in the United 

States Code for editorial reasons. 

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EERE-2007-BT-STD-0007 COMMENT 31
savings, and (2) has prescribed test procedures. (42 U.S.C. 6317(b)) However, pursuant to 


section 346(b)(3) of EPCA (42 U.S.C. 6317(b)(3)), no standard prescribed for small electric 

motors shall apply to any such motor that is a component of a covered product under section 

322(a) of EPCA (42 U.S.C. 6292(a)), or of covered equipment under section 340 (42 U.S.C. 

6311). 

Additionally, EPCA requires DOE, in establishing standards for small electric motors, to 

consider whether the standards themselves will result in a significant conservation of energy, are 

technologically feasible, and are cost effective as described in 42 U.S.C. 6295(o)(2)(B)(i). (42 

U.S.C. 6316(a)) These criteria, along with requirements that any standards be economically 

justified, are largely incorporated into 42 U.S.C. 6295(o), which sets forth the criteria for 

prescribing standards for “covered products,” i.e., consumer products as defined in EPCA. (42 

U.S.C. 6291(1) and (2)) Under 42 U.S.C. 6316(a), portions of 42 U.S.C. 6295, including 

subsection (o), also apply when DOE promulgates standards for certain specified commercial 

and industrial equipment – “covered equipment” as defined in EPCA (42 U.S.C. 6311(1)) – 

including small electric motors. (EPCA states that the term “equipment” shall be substituted for 

“product” in applying the consumer product-related provisions of EPCA to commercial and 

industrial equipment. (42 U.S.C. 6316(a)(3)) 

Therefore, as indicated above, DOE analyzed whether today’s standards for small electric 

motors will achieve the maximum improvement in energy efficiency that is technologically 

feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Additionally, DOE examined 

whether each of today’s standards for this equipment is economically justified, after receiving 

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EERE-2007-BT-STD-0007 COMMENT 31
 

comments on the proposed standards, by determining whether the benefits of the standard exceed 


its burdens by considering, to the greatest extent practicable, the following seven factors that are 

set forth in 42 U.S.C. 6295(o)(2)(B)(i): 

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

equipment subject to the standard; 

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

equipment in the type (or class) compared to any increase in the price, initial charges, or 

maintenance expenses for the covered equipment 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 equipment 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 [of Energy] considers relevant. 

In developing today’s energy conservation standards, DOE also has applied certain other 

provisions of 42 U.S.C. 6295 as it is required to do. First, DOE would not prescribe a standard 

for small electric motors if interested persons established by a preponderance of the evidence that 

the standard is likely to result in the unavailability in the United States of any type (or class) of 

this product with performance characteristics, features, sizes, capacities, and volume that are 

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EERE-2007-BT-STD-0007 COMMENT 31
substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4)) 


Second, DOE has applied 42 U.S.C. 6295(o)(2)(B)(iii), which 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.” 

Third, in setting standards for a type or class of equipment that has two or more 

subcategories, DOE specifies a different standard level than that which applies generally to such 

type or class of equipment “for any group of covered products which have the same function or 

intended use, if . . . products within such group—(A) consume a different kind of energy from 

that consumed by other covered products within such type (or class); or (B) have a capacity or 

other performance-related feature which other products within such type (or class) do not have 

and such feature justifies a higher or lower standard” than applies or will apply to the other 

products. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies 

such a different standard for a group of products, DOE considers such factors as the utility to the 

consumer of such a feature and other factors DOE deems appropriate. Any rule prescribing such 

a standard must include an explanation of the basis on which DOE establishes such higher or 

lower level. (42 U.S.C. 6295(q)(2)) 

Federal energy efficiency requirements for equipment covered under EPCA generally 

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EERE-2007-BT-STD-0007 COMMENT 31
 

supersede State laws or regulations concerning energy conservation testing, labeling, and 

standards. (42 U.S.C. 6297(a)–(c) and 42 U.S.C. 6316(a)) DOE can, however, grant waivers of 

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

provisions of section 327(d) of the Act. (42 U.S.C. 6297(d) and 42 U.S.C. 6316(a)) 

B. Background 

1. Current Energy Conservation Standards 

As indicated above, at present there are no national energy conservation standards for 

small electric motors. 

2. History of Standards Rulemaking for Small Electric Motors 

To determine the small electric motors for which energy conservation standards would be 

technologically feasible and economically justified, and would result in significant energy 

savings, DOE first concluded that the EPCA definition of “small electric motor” covers only 

those motors that meet the definition’s frame-size requirements, and that are either three-phase, 

non-servo motors (referred to below as polyphase motors) or single-phase, capacitor-start 

motors, including both capacitor-start, induction run (CSIR) and capacitor-start, capacitor-run 

(CSCR) motors. 71 FR 38799, 38800-01 (July 10, 2006). In June 2006, DOE issued a report in 

which it analyzed and estimated the likely range of energy savings and economic benefits that 

would result from standards for these motors.2

 The report did not address motors that are a 

component of a covered product or equipment, consistent with 42 U.S.C. 6317. After receiving 

comments on the report, DOE performed further analysis to determine whether standards are 

2 http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/small_motors_tsd.pdf 

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EERE-2007-BT-STD-0007 COMMENT 31
 

warranted for small electric motors and then issued the following determination on June 27, 


2006: 

Based on its analysis of the information now available, the Department [of Energy] has 

determined that energy conservation standards for certain small electric motors appear to 

be technologically feasible and economically justified, and are likely to result in 

significant energy savings. Consequently, the Department [of Energy] will initiate the 

development of energy efficiency test procedures and standards for certain small electric 

motors. 71 FR 38807. 

Thereafter, in 2007, DOE initiated this rulemaking by issuing and seeking public 

comment on the “Energy Conservation Standards Rulemaking Framework Document for Small 

Electric Motors,” which described the approaches DOE anticipated using to develop energy 

conservation standards for small electric motors and the issues to be resolved in the rulemaking. 

See 72 FR 44990 (August 10, 2007). This document is also available on the aforementioned 

DOE website. On September 13, 2007, DOE held a public meeting to present the contents of the 

framework document, describe the analyses DOE planned to conduct during the rulemaking, 

obtain public comment on these subjects, and facilitate the public’s involvement in the 

rulemaking. Manufacturers, trade associations, electric utilities, environmental advocates, 

regulators, and other interested parties provided comments at this meeting, and submitted written 

comments, on the Framework Document. They addressed a range of issues. 

On December 19, 2008, after having considered these comments, gathering additional 

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EERE-2007-BT-STD-0007 COMMENT 31
 

information, and performing preliminary analyses as to standards for small electric motors, DOE 


announced an informal public meeting and the availability on its website of a preliminary 

technical support document (preliminary TSD). 73 FR 79723 (December 30, 2008). The 

preliminary TSD discussed the comments DOE had received in this rulemaking and described 

the actions DOE had taken, the analytical framework DOE was using, and the content and results 

of DOE’s preliminary analyses. Id. at 79724-25. DOE’s preliminary analyses were largely based 

on comments received from industry; including those focusing on what constitutes a small 

electric motors and corresponding shipment estimates. DOE convened the public meeting to 

discuss, and receive comments on, these subjects, DOE’s proposed product classes, potential 

standard levels that DOE might consider, and other issues participants believed were relevant to 

the rulemaking. Id. at 79723, 79725. DOE also invited written comments on all of these matters. 

The public meeting took place on January 30, 2009. Eighteen interested parties participated, and 

ten submitted written comments during the comment period. 

On November 24, 2009, DOE published a notice of proposed rulemaking (NOPR) to 

establish small electric motor energy conservation standards. 74 FR 61410. Shortly after, DOE 

also published on its website the complete technical support document (TSD) for the proposed 

rule, which incorporated the completed analyses DOE conducted and technical documentation 

for each analysis. These analyses were developed using, in part, NEMA-supplied data. The 

TSD included the LCC spreadsheet, the national impact analysis spreadsheet, and the 

manufacturer impact analysis (MIA) spreadsheet—all of which are available at 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/small_electric_motors.ht 

ml. The energy efficiency standards DOE proposed in the NOPR were as follows: 

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EERE-2007-BT-STD-0007 COMMENT 31
Table II.1 Proposed Standard Levels for Polyphase Small Electric Motors 


Motor Output Power Six Poles Four Poles Two Poles 

0.25 Hp/0.18 kW 77.4 72.7 69.8 

0.33 Hp/0.25 kW 79.1 75.6 73.7 

0.5 Hp/0.37 kW 81.1 80.1 76.0 

0.75 Hp/0.55 kW 84.0 83.5 81.6 

1 Hp/0.75 kW 84.2 85.2 83.6 

1.5 Hp/1.1 kW 85.2 87.1 86.6 

2 Hp/1.5 kW 89.2 88.0 88.2 

>3 Hp/2.2 kW 90.8 90.0 90.5 

*Standard levels are expressed in terms of full-load efficiency.
 

**These efficiencies corresponded to NOPR Trial Standard Level 5 for polyphase motors.
 

Table II.2 Proposed Standard Levels for Capacitor-Start Induction-Run Small Electric 

Motors 

Motor Output Power Six Poles Four Poles Two Poles 

0.25 Hp/0.18 kW 65.4 69.8 71.4 

0.33 Hp/0.25 kW 70.7 72.8 74.2 

0.5 Hp/0.37 kW 77.0 77.0 76.3 

0.75 Hp/0.55 kW 81.0 80.9 78.1 

1 Hp/0.75 kW 84.1 82.8 80.0 

1.5 Hp/1.1 kW 87.7 85.5 82.2 

2 Hp/1.5 kW 89.8 86.5 85.0 

>3 Hp/2.2 kW 92.2 88.9 85.6 

*Standard levels are expressed in terms of full-load efficiency.
 

**These efficiencies corresponded to NOPR Trial Standard Level 7 for capacitor-start motors. 


Table II.3 Proposed Standard Levels for Capacitor-Start Capacitor-Run Small Electric 

Motors 

Motor Output Power Six Poles Four Poles Two Poles 

0.25 Hp/0.18 kW 63.9 68.3 70.0 

0.33 Hp/0.25 kW 69.2 71.6 72.9 

0.5 Hp/0.37 kW 75.8 76.0 75.1 

0.75 Hp/0.55 kW 79.9 80.3 77.0 

1 Hp/0.75 kW 83.2 82.0 79.0 

1.5 Hp/1.1 kW 87.0 84.9 81.4 

2 Hp/1.5 kW 89.1 86.1 84.2 

>3 Hp/2.2 kW 91.7 88.5 84.9 

*Standard levels are expressed in terms of full-load efficiency. 


**These efficiencies corresponded to NOPR Trial Standard Level 7 for capacitor-start motors. 


In the NOPR, DOE also identified issues on which it was particularly interested in 

receiving the comments and views of interested parties. DOE requested comment on the 

proposed energy efficiency levels for polyphase and single-phase motors, product classes, 

covered insulation class systems, its selection of baseline models, markups used in the 

engineering analysis, design option and limitations used in the engineering analysis, the approach 

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EERE-2007-BT-STD-0007 COMMENT 31
 

to scaling the results of the engineering analysis, the proposed definition of nominal efficiency,
 

the manufacturer impact analysis scenarios, capital investment costs used, market interaction 

between CSIR and CSCR motors, market response to standards, behavior of customers with 

space constraints, the combined effect of certain market assumptions, the appropriateness of 

other discount rates besides seven and three percent to discount future emissions, and the 

anticipated environmental impacts. The NOPR also included additional background information 

on the history of this rulemaking. 74 FR 61416-17. 

DOE held a public meeting in Washington, DC on December 17, 2009, to hear oral 

comments on, and solicit information relevant to, the proposed rule. DOE has also received 

written comments and information in response to the NOPR. 

III. General Discussion 

A. Test Procedures 

On July 7, 2009, DOE published a final rule that incorporated by reference Institute of 

Electrical and Electronics Engineers, Inc. (IEEE) Standard 112–2004 (Test Method A and Test 

Method B), IEEE Standard 114–2001, and Canadian Standards Association Standard C747–94 

as the DOE test procedures to measure energy efficiency small electric motors. 74 FR 32059. 

In addition to incorporating by reference the above industry standard test procedures, the 

small electric motors test procedure final rule also codified the statutory definition for the term 

“small electric motor;” clarified the definition of the term “basic model”; and the relationship of 

the term to certain product classes and compliance certification reporting requirements; and 

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EERE-2007-BT-STD-0007 COMMENT 31
codified the ability of manufacturers to use an alternative efficiency determination method 


(AEDM) to reduce testing burden when certifying their equipment as compliant but maintaining 

efficiency measurement accuracy and ensuring compliance with potential future energy 

conservation standards. The test procedure notice also discussed matters of laboratory 

accreditation, compliance certification, and enforcement of energy conservation standards for 

small electric motors. 

DOE notes that complete certification and enforcement provisions for small electric 

motors have not yet been developed. DOE intends to propose such provisions in a separate test 

procedure supplementary NOPR, at which time DOE will invite comments on how small electric 

motor efficiency standards can be effectively enforced. Section V.B of this final rule summarizes 

comments received in response to the NOPR that will be further addressed in the test procedure 

supplemental NOPR. 

B. Technological Feasibility 

1. General 

As stated above, any standards that DOE establishes for small electric motors must be 

technologically feasible. (42 U.S.C. 6295(o)(2)(A); 42 U.S.C. 6316(a)) DOE considers a design 

option to be technologically feasible if it is in use by the respective industry or if research has 

progressed to the development of a working prototype. “Technologies incorporated in 

commercially available equipment or in working prototypes will be considered technologically 

feasible.” 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i). This final rule considers 

the same design options as those evaluated in the NOPR. (See chapter 5 of the TSD.) All the 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

evaluated technologies have been used (or are being used) in commercially available products or 

working prototypes. Therefore, DOE has determined that all of the efficiency levels evaluated in 

this notice are technologically feasible. 

2. Maximum Technologically Feasible Levels 

As required by EPCA, (42 U.S.C. 6295(p)(1) and 42 U.S.C. 6316(a)), in developing the 

NOPR, DOE identified the efficiency levels that would achieve the maximum improvements in 

energy efficiency that are technologically feasible (max-tech levels) for small electric motors. 74 

FR 61418. Table III.1 lists the max-tech levels that DOE determined for this rulemaking. DOE 

identified these levels as part of the engineering analysis (chapter 5 of the TSD), using the most 

efficient design parameters that lead to the highest full-load efficiencies for small electric motors. 

Table III.1 Max-Tech Efficiency Levels for Representative Product classes* 

Motor Category Poles Horsepower Efficiency 

% 

Polyphase 4 1 87.7 

CSIR 4 0.5 77.6 

CSCR 4 0.75 87.5 *

 These max-tech efficiency levels are only for the representative product classes described in section IV.C.2. Maxtech efficiency levels for the remaining product classes are determined using the scaling methodology outlined in 

section IV.C.5 

DOE developed maximum technologically feasible efficiencies by creating motor designs 

for each product class analyzed, which use all the viable design options that DOE considered. 

The efficiency levels shown in Table III.1 correspond to designs that use a maximum increase in 

stack length, a copper rotor design, a premium electrical steel (Hiperco 50), a maximum slot-fill 

percentage (65-percent), a change in run-capacitor rating (CSCR motors only), and an optimized 

end ring design. All of the design options used to create these max-tech motors remain in the 

analysis and are options that DOE considers technologically feasible. 

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EERE-2007-BT-STD-0007 COMMENT 31
C. Energy Savings
 

DOE forecasted energy savings in its national energy savings (NES) analysis, through the 

use of an NES spreadsheet tool, as discussed in the NOPR. 74 FR 61418, 61440–42, 61470-72. 

One of the criteria that govern DOE’s adoption of standards for small electric motors is 

that the standard must result in “significant” energy savings. (42 U.S.C. 6317(b)) While the term 

“significant” is not defined by EPCA, a D.C. Circuit indicated that Congress intended 

“significant” energy savings to be savings that were not “genuinely trivial.” Natural Resources 

Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985) The energy savings for 

the standard levels DOE is adopting today are non-trivial, and therefore DOE considers them 

“significant” as required by 42 U.S.C. 6317. 

D. Economic Justification 

1. Specific Criteria 

The following section discusses how DOE has addressed each of the seven factors that it 

uses to determine if energy conservation standards are economically justified. 

a. Economic Impact on Motor Customers and Manufacturers 

DOE considered the economic impact of today’s new standards on purchasers and 

manufacturers of small electric motors. For purchasers of small electric motors, DOE measured 

the economic impact as the change in installed cost and life-cycle operating costs, i.e., the LCC. 

(See section IV.F of this preamble, and chapter 12 of the TSD.) DOE investigated the impacts on 

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EERE-2007-BT-STD-0007 COMMENT 31
manufacturers through the manufacturer impact analysis (MIA). (See sections IV.I and VI.C.2 of 


this preamble and chapter 13 of the TSD.) The economic impact on purchasers and 

manufacturers is discussed in detail in the NOPR. 74 FR 61418-19, 61436-40, 61442-46, and 

61454-70. 

b. Life-Cycle Costs 

DOE considered life-cycle costs of small electric motors, as discussed in the NOPR. 74 

FR 61436–40, 61442, 61454–64. In considering these costs, DOE calculated the sum of the 

purchase price and the operating expense—discounted over the lifetime of the equipment—to 

estimate the range in LCC savings that small motors purchasers would expect to achieve due to 

the standards. 

c. Energy Savings 

Although significant conservation of energy is a separate statutory requirement for 

imposing an energy conservation standard, EPCA also 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) and 42 U.S.C. 

6316(a)) As in the NOPR (74 FR 61440–42, 61470–72), for today’s final rule, DOE used the 

NES spreadsheet results in its consideration of total projected energy savings that are directly 

attributable to the standard levels DOE considered. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

d. Lessening of Utility or Performance of Equipment
 

In selecting today’s standard levels, DOE avoided selection of standards that lessen the 

utility or performance of the equipment under consideration in this rulemaking. (See 42 U.S.C. 

6295(o)(2)(B)(i)(IV) and 42 U.S.C. 6316(a)) 74 FR 61419, 61476. The efficiency levels DOE 

considered maintain both motor performance and power factor in order to preserve consumer 

utility. DOE considered end-user size constraints by developing designs with size increase 

restrictions (limited to a 20-percent increase in stack length), as well as designs with less 

stringent constraints (100-percent increase in stack length). The designs adhering to the 20­

percent increase in stack length maintain all aspects of consumer utility and were created for all 

efficiency levels, but these designs may become very expensive at higher efficiency levels when 

compared with DOE’s other designs. 

e. Impact of Any Lessening of Competition 

DOE considered any lessening of competition that is likely to result from standards. As 

discussed in the NOPR, 74 FR 61419, 61476, and as required under EPCA, DOE requested that 

the Attorney General transmit to the Secretary a written determination of the impact, if any, of 

any lessening of competition likely to result from the standards proposed in the NOPR, 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) and 42 U.S.C. 6316(a)) 

To assist the Attorney General in making such a determination, DOE provided the 

Department of Justice (DOJ) with copies of the November 24, 2009 proposed rule and the NOPR 

TSD for review. The Attorney General’s response is discussed in IV.F.7 below, and is reprinted 

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EERE-2007-BT-STD-0007 COMMENT 31
 

at the end of this rule. DOJ concluded that TSL 5 for polyphase small electric motors and TSL 7 

for single-phase small electric motors are likely to affect the replacement market for certain 

applications. DOJ requested that DOE consider this potential impact and, as warranted, allow 

exemptions from the proposed standard levels the manufacture and marketing of certain 

replacement small electric motors. 

f. Need of the Nation to Conserve Energy 

In considering standards for small electric motors, the Secretary must consider the need 

of the Nation to conserve energy. (42 U.S.C. 6295(o)(2)(B)(i)(VI) and 42 U.S.C. 6316(a)) The 

Secretary recognizes that energy conservation benefits the Nation in several important ways. The 

non-monetary benefits of the standard are likely to be reflected in improvements to the security 

and reliability of the Nation’s energy system. Today’s standard will also result in environmental 

benefits. As discussed in the NOPR, 74 FR 61419, 61447–61453, 61476–61484, and in section 

VI.C.6 of this final rule, DOE considered these factors in adopting today’s standards. 

g. Other Factors 

The Secretary of Energy, in determining whether a standard is economically justified, 

considers any other factors that the Secretary of Energy deems relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(VII) and 42 U.S.C. 6316(a)) In adopting today’s standards, the Secretary 

considered the following: (1) harmonization of standards for small electric motors with existing 

standards under EPCA for medium-sized polyphase general purpose motors; (2) the impact, on 

consumers who need to use CSIR motors, and on the prices for such motors at potential standard 

levels; and (3) the potential for standards to reduce reactive power demand and thereby lower 

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EERE-2007-BT-STD-0007 COMMENT 31
 

costs for supplying electricity3

. 74 FR 61419-20, 61484. These issues are addressed in section 

VI.C.7 below. 

2. Rebuttable Presumption 

Section 325(o)(2)(B)(iii) of EPCA states that there is a rebuttable presumption that an 

energy conservation standard is economically justified if the increased installed cost for a 

product that meets the standard is less than three times the value of the first-year energy savings 

resulting from the standard, as calculated under the applicable DOE test procedure. (42 U.S.C. 

6295(o)(2)(B)(iii) and 42 U.S.C. 6316(a)) DOE’s LCC and payback period (PBP) analyses 

generate values that calculate the PBP of potential energy conservation standards. The 

calculation includes, but is not limited to, the three-year PBP contemplated under the rebuttable 

presumption test just described. However, DOE routinely conducts a full economic analysis that 

considers the full range of impacts, including those to the customer, manufacturer, Nation, and 

environment, as required under 42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(a). The results of 

this analysis serve as the basis for DOE to evaluate definitively the economic justification for a 

potential standard level (thereby supporting or rebutting any presumption of economic 

justification). 

IV. Methodology and Discussion of Comments on Methodology 

DOE used several analytical tools that it developed previously and adapted for use in this 

3

 In an alternating current power system, the reactive power is the root mean square (RMS) voltage multiplied by the 

RMS current, multiplied by the sine of the phase difference between the voltage and the current. Reactive power 

occurs when the inductance or capacitance of the load shifts the phase of the voltage relative to the phase of the 

current. While reactive power does not consume energy, it can increase losses and costs for the electricity 

distribution system. Motors tend to create reactive power because the windings in the motor coils have high 

inductance. 

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EERE-2007-BT-STD-0007 COMMENT 31
rulemaking. One is a spreadsheet that calculates LCC and PBP. Another tool calculates national 


energy savings and national NPV that would result from the adoption of energy conservation 

standards. DOE also used the Government Regulatory Impact Model (GRIM), along with other 

data obtained from interviews with manufacturers, in its MIA to determine the impacts of 

standards on manufacturers. Finally, DOE developed an approach using the National Energy 

Modeling System (NEMS) to estimate impacts of standards for small electric motors on electric 

utilities and the environment. The NOPR discusses each of these analytical tools in detail, 74 FR 

61420, 61436–53, as does the TSD. 

As a basis for this final rule, DOE has continued to use the spreadsheets and approaches 

explained in the NOPR. DOE used the same general methodology as applied in the NOPR, but 

revised some of the assumptions and inputs for the final rule in response to public comments. 

DOE also added new analysis based on the comments it received from interested parties. The 

following paragraphs address these revisions. 

A. Market and Technology Assessment 

When beginning an energy conservation standards rulemaking, 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, product classes, manufacturers, quantities, and types of equipment 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

sold and offered for sale; retail market trends; and regulatory and non-regulatory programs. See
 

chapter 3 of the TSD for further discussion of the market and technology assessment. 

1. Definition of Small Electric Motor 

EPCA defines a small electric motor as "a NEMA general purpose alternating current 

single-speed induction motor, built in a two-digit frame number series in accordance with 

NEMA Standards Publication MG1-1987." 42 U.S.C. 6311(13)(G). NEMA Standards 

Publication MG1-1987 is an industry guidance document that addresses, among other things, 

various aspects related to small and medium electric motors. As denoted in the title, this version 

of MG1 was prepared in 1987, more than 20 years before the date of today’s final rule. NEMA 

has since published updated versions of this document, the latest of which was released in 2006. 

Of particular significance is the difference in what was considered in 1987 a general purpose, 

alternating current motor (only open construction motors) compared to what NEMA currently 

considers a general purpose alternating current motor (both open and enclosed construction 

motors).4 

DOE explained its view in the NOPR as to how it currently reads 42 U.S.C. 6311(13)(G). 

74 FR 61421. DOE indicated that the statute refers to MG1-1987 for purposes of ascertaining 

what constitutes a small electric motor. The agency explained and articulated certain 

assumptions in the NOPR regarding the scope of categories of motors, frame sizes, performance 

4

 An open motor is constructed with ventilating openings that permit external cooling air to pass over and around the 

windings of the motor. An enclosed motor is constructed to prevent the free exchange of air between the inside and 

outside of the housing. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

characteristics, insulation systems, and motor enclosures that it examined within the proposed 


scope of this rulemaking. 

DOE received several comments criticizing the scope of DOE’s coverage in its analyses. 

Manufacturers indicated that DOE’s scope was too broad because, in their view, many of the 

motors DOE examined in ascertaining the energy savings potential for small electric motors, 

were not small electric motors under MG1-1987. For example, Emerson commented that in 

order for standards to be enforceable, DOE should adhere strictly to MG1-1987 in defining 

scope. (Emerson, No. 28 at p. 2) NEMA made similar comments echoing the same concern and 

argued that DOE’s analysis should have been limited to the performance characteristics 

contained in MG1-1987. (See, e.g., NEMA, No. 8 at pp. 2-5) 

In contrast, Earthjustice and UL both commented that DOE was unnecessarily 

constraining itself by adhering to NEMA MG1-1987. See Earthjustice, Public Meeting 

Transcript, No. 20.4 at pp. 49-50; UL, Public Meeting Transcript, No. 20.4 at pp. 89-90. UL 

asserted that DOE’s scope would create a negligible impact on the market, which has been 

shifting from the motors covered under the NOPR to other motor types (such as electronically 

commutated motors). (UL, Public Meeting Transcript, No. 20.4 at p. 182, UL, No. 21 at pp. 2) 

Earthjustice advised DOE that it should expand the scope of the rulemaking to include any 

“covered equipment” that it finds are justified. (Earthjustice, No. 22 at pp. 1-3) It had also noted 

during the preliminary analysis public meeting, that DOE could adopt a different reading of the 

definition by applying the phrase MG1-1987 only to the two digit frame number series 

requirement. Earthjustice, Public Meeting Transcript, at 47-49 (January 30, 2009). 

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EERE-2007-BT-STD-0007 COMMENT 31
 

After careful consideration of all of the comments, DOE believes that its scope of 

coverage in this final rule is appropriate. As such, DOE is declining to revise its scope of 

coverage for this equipment within this rulemaking. While DOE is continuing to adhere to the 

approach proposed in its NOPR and accompanying TSD, DOE may revisit this issue in the future 

and re-examine its interpretation of the small electric motor definition in 42 U.S.C. 6311(13)(G). 

Any such re-examination would be performed within the context of the rulemaking process and 

offer an opportunity for public comment. 

a. Motor Categories 

The motor categories examined by DOE are tied in part to the terminology and 

performance requirements in NEMA MG1-1987. These requirements were established for (1) 

general-purpose alternating-current motors, (2) single-speed induction motors, and (3) the 

NEMA system for designating (two-digit) frame sizes. Single-speed induction motors, as 

delineated and described in MG1-1987, fall into five categories: split-phase, shaded-pole, 

capacitor-start (both CSIR and CSCR), permanent-split capacitor (PSC), and polyphase. Of 

these five motor categories, DOE determined for purposes of this rulemaking that only CSIR, 

CSCR, and polyphase motors are able to meet performance requirements in NEMA MG1 and are 

widely considered general purpose alternating current motors, as shown by the listings found in 

manufacturers’ catalogs. Therefore, in the NOPR DOE proposed to only cover those three motor 

categories. 

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EERE-2007-BT-STD-0007 COMMENT 31
Underwriters Laboratories stated that they believe DOE should cover the split-phase, 

shaded-pole, and PSC motor categories because they are much more common in the current 

market. (Underwriters Laboratories, No. 21 at p. 2) It is DOE's understanding that the motors 

suggested for coverage by UL do not meet the requirements for a NEMA general purpose motors 

and, consequently, are outside the scope of this rulemaking despite being more common. As a 

result, DOE continues to maintain that CSIR, CSCR, and polyphase motors are the only motor 

categories that are general purpose motors for purposes of this rulemaking. 

b. Horsepower Ratings 

In DOE’s preliminary and NOPR analyses on small electric motors, DOE presented a 

range of horsepower ratings from 1⁄4-horsepower up to 3-horsepower. The range of horsepower 

ratings was the same for all three motor categories covered: CSIR, CSCR, and polyphase motors 

as well as all three pole configurations: two, four, and six. This range of horsepower ratings was 

consistent with what DOE believed to be the range of ratings where manufacturers build NEMA 

general purpose motors in a two-digit frame number series. 

In response to the NOPR, NEMA and Baldor commented that the horsepower range for 

the products classes DOE proposed was incorrect. Baldor stated that horsepower ratings higher 

than 1⁄2-horsepower for six-pole motors, 3⁄4-horsepower for four-pole motors, and 1-horsepower 

for two-pole motors are not standard ratings for small electric motors as defined in NEMA MG1, 

in particular, as listed in Table 10-1 of MG1-1987. Therefore, NEMA and Baldor stated that 

motors with such ratings are not NEMA general purpose motors and should be excluded from 

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EERE-2007-BT-STD-0007 COMMENT 31
DOE’s scope of coverage. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 38-41; NEMA, 


No. 24 at pp. 1-5, 7) 

DOE understands that NEMA MG1-1987 does not provide ratings for small motors of 

the identified higher horsepower ratings. However, DOE does not believe this precludes certain 

higher horsepower ratings built in a two-digit NEMA frame consistent with NEMA MG1-1987 

from coverage. In addition, upon review of NEMA manufacturer product catalogs, DOE noted 

that two-digit frame size motors of higher horsepower ratings are commonly marketed as general 

purpose. DOE also observed from NEMA shipment data provided to DOE for the determination 

analysis that when NEMA surveyed its members and requested shipments of general purpose 

motors built in a two-digit frame number series, responding manufacturers provided shipments 

data in horsepower ratings exceeding those listed in the comments above. Although NEMA 

argued that these motors do not fall within this rulemaking, NEMA did not deny that these 

motors are considered general purpose motors. Thus, DOE believes that even though NEMA 

MG1-1987 does not provide standard ratings for higher horsepower small electric motors, many 

of these motors are considered NEMA general purpose motors that could be considered for 

coverage by DOE. 

DOE notes that there is precedent for clarifying the scope of coverage of these motors. 

At industry’s request during the test procedure rulemaking for small electric motors, DOE 

clarified the small electric motor definition to incorporate metric-equivalent motors that are built 

in accordance with the International Electrotechnical Commission’s requirements. See Baldor, 

Public Meeting Transcript, No. 8 at p. 75; NEMA, No. 12 at p. 2. This expansion of the small 

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EERE-2007-BT-STD-0007 COMMENT 31
electric motor definition, which was added to ensure that DOE provided adequate coverage over 


small electric motors generally, was incorporated into 10 CFR 431.442. See also 74 FR 32061­

62 and 32072. 

While DOE believes that many of the horsepower ratings recommended for exclusion by 

NEMA and Baldor could be included in the definition of small electric motors, upon examining 

manufacturer catalogs, DOE found that motors did not exist for some horsepower ratings/pole 

configuration combinations included in NOPR. Specifically, DOE found that no open 

construction, two-digit frame size motors have horsepower ratings greater than 3-horsepower. In 

addition, DOE found no small electric polyphase motors built with a 2- or 3-horsepower rating 

and a six-pole configuration. DOE also found that small electric single-phase motors (CSIR and 

CSCR) do not exist with a 11⁄2 -horsepower rating or higher for six-poles or a 3-horsepower 

rating for four-poles. As there is no evidence that these motors, if manufactured, would be 

considered general purpose motors, and because DOE lacks data on which to base energy 

conservation standards for these motors, DOE is not including them in the scope of this 

rulemaking. Today’s final rule reflects this decision as no standards are being adopted in those 

product classes. Table IV.1 presents the horsepower ratings for which DOE believes no small 

electric motors are currently commercially available. 

Table IV.1 Horsepower Ratings For Which No Motors Exist 

Motor Category Two-Pole Four-Pole Six-Pole 

Polyphase > 2 Hp 

Single-Phase > 3 Hp > 1.5 Hp 

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EERE-2007-BT-STD-0007 COMMENT 31
c. Performance Requirements 


NEMA defines several performance requirements, including breakdown torque, locked 

rotor torque, and locked rotor current that motors must meet in order to be considered generalpurpose. Because DOE’s assessment of the small electric motors market (through analysis of 

commercially-available products sold) indicates that the vast majority of motors meet the 

previously listed requirements, DOE believes that a motor must meet these performance 

characteristics as a condition for coverage. 

PG&E commented that a loophole exists in the rulemaking since the current definition of 

a small general purpose motor is so narrow with respect to design and performance 

characteristics. (PG&E, Public Meeting Transcript, No. 20.4 at pp. 259-60) PG&E added that 

DOE’s reliance on MG1-1987 provides another loophole where NEMA could update its 

standards such that manufacturers could still make a NEMA general purpose motor that is not 

covered under today’s rulemaking. (PG&E, Public Meeting Transcript, No. 20.4 at pp. 260-61) 

NEEA/NPCC agreed with PG&E that a manufacturer could easily circumvent any standards 

whose coverage was based around NEMA performance requirements, by simply constructing the 

motor such that it slightly deviates from NEMA requirements, but still provides similar utility to 

the consumer. (NEEA/NPCC, No. 27, pp. 2-3) Baldor stated that the tables of performance 

requirements in NEMA MG1 are designed to let customers know how motors will perform from 

manufacturer to manufacturer and they have been established for many years and there would be 

no reason to change them. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 266-67) 

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EERE-2007-BT-STD-0007 COMMENT 31
 DOE understands the concerns expressed by PG&E, but agrees with Baldor that 

considering that the relevant performance requirements in NEMA MG1 have not changed 

substantially in over 20 years, these performance standards are unlikely to change should NEMA 

develop a new version of MG1. DOE believes that to do so would constitute a major change to 

the industry and performance characteristics that customers have been accustomed to over the 

years. Therefore, DOE believes that small electric motors must meet certain requirements in 

NEMA MG1-1987 shown in Table IV.6. For those combinations of horsepower rating and pole 

configuration that do not have performance requirements for two-digit frame sizes, DOE has no 

performance requirements. Instead, DOE will cover only those motors widely considered 

general purpose and marketed as such in manufacturer catalogs. 

d. Motor Enclosures 

In the NOPR, DOE stated that in ascertaining what constitutes a small electric motor, 

only the 1987 version of MG1 applies within the context of the statutory definition. Under that 

interpretation, DOE stated that only open construction motors were considered covered products. 

DOE is continuing to adhere to this approach. 

As DOE’s proposed scope did not extend beyond open motors as covered products, 

Baldor and NEMA commented that the revision to 10 CFR Part 431 proposed in the NOPR 

should clearly mention that the table of efficiency values for section 431.446 applies only to 

open motors. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 47-48, NEMA, No. 24 at p. 5) 

To clarify the application of the new efficiency values, DOE is modifying the efficiency 

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EERE-2007-BT-STD-0007 COMMENT 31
 

standards tables in section 431.446 from today’s final rule to include the words, “open motors” 


in the headings. 

e. Frame Sizes 

As for the frame sizes of motors that are covered by DOE standards for small electric 

motors, EPCA defines a small electric motor, in relevant part, as a motor “built in a two-digit 

frame number series in accordance with NEMA Standards Publication MG1–1987.” (42 U.S.C. 

6311(13)(G)) MG1–1987 establishes a system for designating motor frames that consisting of a 

series of numbers in combination with letters that correspond to a specific size. The 1987 version 

of MG1 designates three two-digit frame series: 42, 48, and 56. These frame series have 

standard dimensions and tolerances necessary for mounting and interchangeability that are 

specified in sections MG1–11.31 and MG1–11.34. 

DOE understands that manufacturers produce motors in other two-digit frame sizes, 

namely a 66 frame size. The 66 frame size is used for definite-purpose or special-purpose motors 

and not used in general-purpose applications and are not covered under the EPCA definition of 

“small electric motor.” In the NOPR, DOE stated that it was unaware of any other motors with 

two-digit frame sizes that are built in accordance with NEMA MG1-1987. Should such frame 

sizes appear on the market, DOE will consider evaluating whether to include that equipment. 

For the NOPR, DOE received no comments regarding this issue and as a result, is maintaining its 

stance on this topic for this final rule. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

f. Insulation Class Systems
 

Because DOE’s interpretation of the statutory definition of a small electric motor is 

largely influenced by what NEMA defines as a general-purpose alternating-current motor under 

MG1-1987, DOE has taken into account the criteria that comprise a general purpose motor. 

Among these criteria are the applicable insulation classes. NEMA MG1-1987 paragraph 1-1.05, 

provides that a general-purpose motor must incorporate a “Class A insulation system with a 

temperature rise as specified in MG 1-12.42 for small motors or Class B insulation system with a 

temperature rise as specified in MG 1-12.43 for medium motors.” 

In NEMA MG1-1987, paragraphs 1.66 and 12.42.1 define four insulation class systems: 

Class A, Class B, Class F, and Class H. They are divided into classes based on the thermal 

endurance and each system has a different temperature rise5

 that the insulating material must be 

able to withstand without degradation. The temperature rise requirement for Class A systems is 

the lowest of the four systems defined in NEMA MG1-1987, which means that all other 

insulation classes meet Class A requirements. Because all insulation class systems meet the 

Class A requirements, DOE proposed to cover motors that incorporate any of the other insulation 

class systems in the NOPR. A joint comment submitted by Pacific Gas and Electric Company 

(PG&E), Southern California Edison (SCE), Southern California Gas Company (SCGC), and 

San Diego Gas and Electric Company (SDGE) supported DOE’s decision to include insulation 

Classes B, F, and H in addition to Class A. (Joint Comment, No. 23 at p. 2) NEMA and Baldor 

commented that although it is prudent to cover insulation class systems other than Class A, in 

order for a motor to be considered covered it must adhere to the temperature rise limits required 

5

 Temperature rise refers to the increase in temperature over the ambient temperature of the motor when operated at 

service factor load. NEMA MG1 provides maximum temperature rises (as measured on the windings of the motor) 

for each insulation class system. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

of Class A motors by NEMA MG1. For example, if a motor contains a Class B insulation 


system, but the temperature rise exceeds the threshold for Class A insulation systems, the 

commenters stated that that motor should be excluded from coverage. (Baldor, Public Meeting 

Transcript, No. 20.4 at pp. 25-26; Baldor, No. 15 at p. 3-4, NEMA, No. 24 at pp. 5-7) 

DOE disagrees with Baldor and NEMA’s assessment regarding temperature rise and in 

today’s final rule maintains that the scope of coverage includes motors with any insulation class 

system Class A or higher, regardless of whether a motor meets the Class A temperature rise 

requirements. First, DOE notes that NEMA MG1 does not require small motors to meet the 

temperature rise for a Class A insulation system. Rather, it only requires that the motor 

incorporates an insulation system that meets Class A requirements, which DOE has determined 

could be Class A, B, F, or H. 

Second, DOE believes that it is unreasonable to apply a more stringent temperature rise 

requirement on motors with higher insulation class systems. These motors often incorporate the 

higher insulation class systems in order to protect the motors from degradation at high 

temperatures. As a result, the accompanying temperature rise, which serves as a marker of how 

much heat a particular insulation class can withstand to prevent the motor from damage, will 

generally increase as a higher grade of insulation is used. Baldor's suggestion that a lower 

temperature rise (70o C) must be used for each higher grade of insulation that offers protection at 

higher temperatures is one that DOE declines to adopt. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

Furthermore, according to NEMA Standards publication MG1-1987, paragraph 10.39.1, 


although insulation class system designation is a required marking on the nameplate of small 

electric motors, temperature rise is not. If DOE were to limit scope based on the temperature rise 

requirements of Class A systems, DOE would have no way of determining whether motors of 

insulation class systems greater than Class A meet the required temperature rise and are therefore 

subject to energy conservation standards. As only 2 percent of small electric motor models sold 

are labeled with Class A insulation systems, 98 percent of small electric models would have 

unknown temperature rises (relative to Class A requirements). DOE believes that including all 

insulation classes and temperature rises satisfies the statutory definition and avoids creating an 

unenforceable standard for a large number of motors that do not list temperature rise. 

g. Service Factors 

Some CSIR, CSCR, and polyphase motors may fail to meet the NEMA definition of 

general purpose alternating current motor because they do not meet NEMA service factor 

requirements. See, e.g. NEMA MG1-1987 Table 12–2. Service factor is a measure of the 

overload capacity at which a motor can operate without thermal damage, while operating 

normally within the correct voltage tolerances. The rated horsepower multiplied by the service 

factor determines that overload capacity. For example, a 1-horsepower motor with a 1.25 service 

factor can operate at 1.25 horsepower (1-horsepower x 1.25 service factor). For the NOPR, DOE 

concluded that motors that fail to meet service factor requirements in MG1-12.47 of MG1-1987 

(now 12.51.1 of MG1-2006) are not “small electric motors” as EPCA uses that term. Receiving 

no comments to the contrary, DOE maintains that position in today’s final rule and energy 

efficiency standards do not apply to them. 

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EERE-2007-BT-STD-0007 COMMENT 31
h. Metric Equivalents and Non-Standard Horsepower and Kilowatt Ratings 

DOE’s interpretation of a small electric motor is largely based on the construction and 

rating system in NEMA MG1-1987. (42 U.S.C. 6311(13)(G)) This system uses English units of 

measurement and power output ratings in horsepower. In contrast, general-purpose electric 

motors manufactured outside the United States and Canada are defined and described with 

reference to the International Electrotechnical Commission (IEC) Standard 60034–1 series, 

“Rotating electrical machines,” which employs terminology and criteria different from those in 

EPCA. The performance attributes of these IEC motors are rated pursuant to IEC Standard 

60034–1 Part 1: “Rating and performance,” which uses metric units of measurement and 

construction standards different from MG1, and a rating system based on power output in 

kilowatts instead of power output in horsepower. The Institute of Electrical and Electronics 

Engineers (IEEE) Standard 112 recognizes this difference in the market and defines the 

relationship between horsepower and kilowatts. Furthermore, in 10 CFR 431.12, DOE defined 

“electric motor” in terms of both NEMA and IEC equivalents even though EPCA’s 

corresponding definition and standards were articulated in terms of MG1 criteria and English 

units of measurement. 64 FR 54114 (October 5, 1999) The test procedure final rule adopted a 

definition for small electric motor that explicitly indicated that IEC equivalent motors are 

considered small electric motors. 10 CFR 431.442. 74 FR 32062, 72. 

In the NOPR, DOE addressed how IEC metric or kilowatt-equivalent motors can perform 

identical functions as NEMA small electric motors and provide comparable rotational 

mechanical power to the same machines or equipment. Moreover, IEC metric or kilowatt42
 

EERE-2007-BT-STD-0007 COMMENT 31
equivalent motors can generally be interchangeable with covered small electric motors. 

Consistent with the codified definition of “small electric motor in 10 CFR 431.442, DOE 

interpreted EPCA to apply the term “small electric motor” to any motor that is identical or 

equivalent to a motor constructed and rated in accordance with NEMA MG1, which includes 

IEC metric motors. DOE also proposed that motors with non-standard kilowatt and horsepower 

ratings would be required to meet small electric motor energy conservation standards. 74 FR 

61422. 

A joint comment submitted by PG&E, SCE, SCGC, and SDGE indicated support for 

DOE’s decision to include IEC-rated motors in today’s rulemaking. (Joint Comment, No. 23 at 

p. 2) NEMA and Baldor commented that, even though they agreed with DOE’s approach in the 

NOPR, they believed that given the statutory definition’s dependence on MG1-1987 (and the 

ratings contained in that standard) more justification is needed to include non-standard metric or 

English-rated motors in its scope of coverage. (Public Meeting Transcript, No. 20.4 at pp. 288­

89; NEMA, No. 24 at pp. 24-25) 

DOE appreciates these comments and in this final rule maintains its position regarding 

the inclusion of non-standard IEC metric and English-rated motors. Though NEMA MG1 does 

not provide ratings for these non-standard motors, DOE recognizes that they can perform 

identical functions as those NEMA motors with standard horsepower ratings. Therefore, as DOE 

did within the context of its codified definition of the term “small electric motor” found in 10 

CFR 431.442 to include IEC metric-equivalent motors, DOE believes that non-standard 

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EERE-2007-BT-STD-0007 COMMENT 31
horsepower and kilowatt rated motors should be considered NEMA general purpose and 


included in the scope of coverage of this rulemaking. 

i. Summary 

During the public meeting, Baldor and NEMA commented that DOE did not include the 

definition of NEMA general purpose motor in 10 CFR 431.442, and suggested that DOE include 

the definition for clarity and completeness. (Baldor, Public Meeting Transcript, No. 20.4 at p. 

46; NEMA, No. 24 at p. 5) A.O. Smith also requested clarification of the term “small electric 

motor,” and suggested that the definition align with NEMA established guidelines. (A.O. Smith, 

No. 26 at p. 2) 

DOE has discussed the covered motor categories, horsepower ratings, motor enclosures, 

frame sizes, insulation class systems, service factors, and metric equivalents. As discussed in 

section IV.A.1.b, because DOE has found several horsepower/pole configurations for which 

small electric motors are not commercially available, DOE has made slight modifications in the 

range of horsepower ratings for which it is adopting standards in this final rule. The motors 

covered by today’s rule include polyphase motors from 1⁄4- to 3-horsepower for motors equipped 

with two poles, 1⁄4- to 3-horsepower for motors with four poles, and 1⁄4- to 11⁄2-horsepower for 

motors with six pole motors as long as they are built in a two-digit frame number series and with 

an open construction; the CSIR and CSCR motors covered by today’s rule include motors from 

1⁄4- to 3-horsepower motors equipped with two poles, 1⁄4- to 2-horsepower for motors with four 

poles, and 1⁄4- to 1-horesepower for motors with six poles as long as they are built in a two-digit 

frame number series and with an open construction. A motor will not be excluded because of its 

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EERE-2007-BT-STD-0007 COMMENT 31
insulation class system or its temperature rise. However, it will be excluded if it fails to meet 


NEMA general purpose service factor requirements. Any metric-equivalent motor or motor with 

a non-standard horsepower or kilowatt rating that has performance characteristics and 

construction equivalent to those listed above is also a covered product and must meet the energy 

efficiency standards of this rulemaking. Although today's final rule DOE does not codify a 

definition for “NEMA general purpose motor”, DOE will consider proposing a definition for this 

term in the electric motor test procedure supplemental NOPR. 

2. Product Classes 

When evaluating and establishing energy conservation standards, DOE generally divides 

covered equipment into classes by the type of energy used, capacity, or other performancerelated features that affect efficiency. (42 U.S.C. 6295(q)) DOE routinely establishes different 

energy conservation standards for different product classes based on these criteria. 

At the NOPR public meeting, DOE presented its rationale for creating 72 product classes. 

The 72 product classes were based on combinations of three different characteristics: motor 

category, number of poles, and horsepower. As these motor characteristics change, so does the 

utility and efficiency of the small electric motor. 

The motor category divides the small electric motors market into three major groups: 

CSIR, CSCR, and polyphase. For each motor category, DOE divided the product classes by all 

combinations of eight different horsepower ratings (i.e., 1⁄4 to > 3) and three different pole 

configurations (i.e., 2, 4, and 6). A change in motor category can constitute a change in the type 

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EERE-2007-BT-STD-0007 COMMENT 31
of power used, three-phase power for polyphase motors versus single-phase power for capacitor-


start motors. Alternatively, it might be a change in consumer utility that affects efficiency. The 

addition of a run-capacitor on a CSCR motors can make the motor more efficient as well as 

constitute dimensional changes as the run-capacitor is usually mounted externally on the 

housing. Horsepower rating is directly related to a motor’s capacity, and its pole configuration is 

directly related to the theoretical maximum speed at which a motor can operate. For the NOPR, 

DOE received no comments contrary to disaggregating product classes with these characteristics, 

but did receive other comments regarding product classes. 

Consistent with their comments on scope (discussed in section IV.A.1), NEMA and 

Baldor stated that certain combinations of horsepower and speed (or pole-configuration) ratings 

should be excluded from DOE’s product classes because, in their view, they are not small 

electric motors within the context of MG1-1987. Specifically, they stated that motors with 

horsepower ratings greater than 1-horsepower for two-pole motors, greater than 3⁄4-horsepower 

for four-pole motors, and greater than 1⁄2-horsepower for six-pole motors do not meet the 

statutory definition. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 39-41; NEMA, No. 24 

at pp. 3-4) As discussed in section IV.A.1, DOE examined the statutory definition of small 

electric motor and disagrees that the aforementioned horsepower and speed ratings are not 

covered under this rulemaking. Therefore, in this final rule DOE is maintaining coverage of 

combinations of horsepower and pole configurations higher than those recommended by NEMA 

and Baldor. However, as discussed in section IV.A.1.b, DOE is not adopting standards for 

motors which are not currently commercially available. Accordingly, DOE has removed these 

proposed product classes in the final rule, resulting in 62 total product classes. 

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NEMA and Baldor also commented that DOE should include frame size among the 

characteristics that define a product class. They stated that smaller frame size motors will not be 

able to achieve as high an energy efficiency rating as the larger frame sized motors, thus 

warranting separate product classes. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 43-44, 

NEMA, No. 24 at pp. 4-5, 23) 

DOE acknowledges that motors built with smaller dimensions, namely core diameters, 

may not be able to achieve the same efficiency as a motor with larger dimensions. The smaller 

diameter limits the amount of active material that is used to reduce motor losses and therefore 

limits the maximum efficiency rating possible as well. However, frame size, which relates to the 

frame housing and not the core diameter, is a measurement of height from the bottom of the 

mounting feet to the center of the shaft of the motor. Frame size does not always correlate to the 

core diameter of the motor and amount active material. For example, DOE found that some 

motors with larger frame sizes have core diameters equivalent to those motors built in smaller 

frame sizes, which means that these motors have an efficiency potential equivalent to that of a 

motor in a smaller frame size. Consequently, frame size alone does not necessarily change the 

efficiency of a small electric motor. 

Additionally, NEMA MG1 does not differentiate breakdown torque, locked-rotor torque, 

and locked-rotor current requirements for small general-purpose motors by frame size. DOE 

believes that if performance requirements other than efficiency for small motors are not different 

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EERE-2007-BT-STD-0007 COMMENT 31
 

for different frame sizes, there is no need or precedent for DOE to differentiate efficiency
 

standards for small electric motors based on frame size. 

However, as stated earlier, DOE recognizes that core diameter affects efficiency. If DOE 

were to set a standard based on an analysis of a motor of larger core diameter, it could potentially 

be eliminating from market smaller core diameter motors. However, because core diameter is 

not a standardized dimension across all small electric motors, DOE has chosen to address this 

issue in the engineering analysis. As discussed in section IV.C DOE based its representative unit 

and scaling analyses on what it perceived as the greatest dimensionally constrained motors on the 

market for each product class. By doing this, DOE ensures that all existing consumer utility in 

the marketplace of smaller core diameter motors is maintained with energy conservation 

standards. 

Chapter 3 of the TSD accompanying today's notice provides additional detail on the 

product classes defined for the standards proposed in this final rule and Table IV.2 through Table 

IV.4 below enumerate these product classes. For the final rule, DOE considers 62 product 

classes. 

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EERE-2007-BT-STD-0007 COMMENT 31
Table IV.2 Product classes for Polyphase Motors with an Open Construction 


Motor Horsepower/Standard 

Kilowatt Equivalent Six Poles Four Poles Two Poles 

1/4 hp/0.18 kW PC # 1 PC # 2 PC # 3 

1/3 hp/0.25 kW PC # 4 PC # 5 PC # 6 

1/2 hp/0.37 kW PC # 7 PC # 8 PC # 9 

3/4 hp/0.55 kW PC # 10 PC # 11 PC # 12 

1 hp/0.75 kW PC # 13 PC # 14 PC # 15 

11⁄2 hp/1.1 kW PC # 16 PC # 17 PC # 18 

2 hp/1.5 kW - PC # 19 PC # 20 

 3 hp/2.2 kW - PC # 21 PC # 22 

Table IV.3 Product classes for Capacitor-Start Induction-Run Motors with an Open 

Construction 

Motor Horsepower/Standard 

Kilowatt Equivalent Six Poles Four Poles Two Poles 

1/4 hp/0.18 kW PC #23 PC # 24 PC # 25 

1/3 hp/0.25 kW PC #26 PC #27 PC #28 

1/2 hp/0.37 kW PC #29 PC # 30 PC # 31 

3/4 hp/0.55 kW PC #32 PC # 33 PC # 34 

1 hp/0.75 kW PC #35 PC # 36 PC # 37 

11⁄2 hp/1.1 kW - PC #38 PC # 39 

2 hp/1.5 kW - PC #40 PC # 41 

3 hp/2.2 kW - - PC #42 

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Table IV.4 Product classes for Capacitor-Start Capacitor-Run Motors with an Open 

Construction 

Motor Horsepower/Standard 

Kilowatt Equivalent Six Poles Four Poles Two Poles 

1/4 hp/0.18 kW PC #43 PC #44 PC #45 

1/3 hp/0.25 kW PC #46 PC #47 PC #48 

1/2 hp/0.37 kW PC #49 PC #50 PC #51 

3/4 hp/0.55 kW PC #52 PC #53 PC #54 

1 hp/0.75 kW PC #55 PC #56 PC #57 

11⁄2 hp/1.1 kW - PC #58 PC #59 

2 hp/1.5 kW - PC #60 PC #61 

3 hp/2.2 kW - - PC #62 

B. Screening Analysis 

The purpose of the screening analysis is to evaluate the technology options identified as 

having the potential to improve the efficiency of equipment, to determine which technologies to 

consider further and which to screen out. DOE consulted with industry, technical experts, and 

other interested parties to develop a list of technologies for consideration. DOE then applied the 

following four screening criteria to determine which design options are suitable for further 

consideration in a standards rulemaking: 

1. Technological feasibility. DOE considers technologies incorporated in commercial 

products or in working prototypes to be technologically feasible. 

2. Practicability to manufacture, install, and service. If mass production and reliable 

installation and servicing of a technology in commercial products could be achieved on the scale 

necessary to serve the relevant market at the time the standard comes into effect, then DOE 

considers that technology practicable to manufacture, install, and service. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

3. Adverse impacts on product utility or product availability. If DOE determines a 

technology would have a significant adverse impact on the utility of the product to significant 

subgroups of consumers, or would result in the unavailability of any covered product type with 

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

are substantially the same as products generally available in the United States at the time, it will 

not consider this technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider this technology further. 

See 10 CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b). 

DOE identified the following technology options that could improve the efficiency of 

small electric motors: utilizing a copper die-cast rotor, reducing skew on the rotor stack (i.e. 

straightening the rotor conductor bars), increasing the cross-sectional area of rotor conductor 

bars, increasing the end ring size, changing the copper wire gauge used in the stator, 

manipulating the stator slot size, changing capacitor ratings, decreasing the air gap between the 

rotor and stator, improving the grades of electrical steel, using thinner steel laminations, 

annealing steel laminations, adding stack length, using high efficiency steel lamination materials, 

using plastic bonded iron powder (PBIP), installing better ball bearings and lubricant, and 

installing a more efficient cooling system. For a description of how each of these technology 

options improves small electric motor efficiency see TSD chapter 3. For the NOPR, DOE 

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EERE-2007-BT-STD-0007 COMMENT 31
 

screened out two of these technology options: PBIP and decreasing the air gap below .0125 


inch. DOE received no comments regarding these two technology options and therefore 

maintains its exclusion of these technology options in today’s final rule. However, DOE did 

receive comments concerning the availability of premium electrical steels (such as Hiperco) and 

copper rotors, two design options that it did not screen out in the NOPR. Please see section IV.I 

for a discussion of those issues. 

DOE believes that all of the efficiency levels discussed in today’s notice are 

technologically feasible. The technologies that DOE examined have been used (or are being 

used) in commercially available equipment or working prototypes. These technologies all 

incorporate materials and components that are commercially available in today’s supply markets 

for the motors that are the subject of this final rule. 

C. Engineering Analysis 

The engineering analysis develops cost-efficiency relationships to show the 

manufacturing costs of achieving increased energy efficiency. As discussed in the NOPR, to 

conduct the engineering analysis, DOE used a combined design-option and efficiency level 

approach in which it employed a motor design software technical expert to develop motor 

designs at several efficiency levels for each analyzed product class. Based on these simulated 

designs and manufacturer and component supplier data, DOE calculated manufacturing costs and 

selling prices associated with each efficiency level. DOE decided on this approach after 

receiving insufficient response to its request for the manufacturer data needed to execute an 

efficiency-level approach for the preliminary analyses. The design-option approach allowed 

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DOE to make its engineering analysis methodologies, assumptions, and results publicly available 

in the NOPR, thereby permitting all interested parties the opportunity to review and comment on 

this information. The design options considered in the engineering analysis include: copper diecast rotor, reduced skew on the rotor stack, increased cross-sectional area of rotor conductor 

bars, increase end-ring size, changing the gauge of copper wire in the stator, manipulating stator 

slot size, decreased air gap between rotor and stator to .0125 inch, improved grades of electrical 

steel, use thinner steel laminations, annealed steel laminations, increased stack height, modified 

capacitors ratings, improved ball bearings and lubricant, and more efficient cooling systems. 

Chapter 5 of the TSD contains a detailed description of the engineering analysis methodology 

and chapter 3 of the TSD contains a detailed description of how the design options listed above 

increase motor efficiency. 

1. Product Classes Analyzed 

As discussed in section IV.A.2of this notice, DOE is establishing a total of 62 product 

classes for small electric motors, based on the motor category (polyphase, CSIR, or CSCR), 

horsepower rating, and pole configuration. DOE carefully selected certain product classes to 

analyze, and then scaled its analytical findings for those representative product classes to other 

product classes that were not directly analyzed. Further discussion of DOE’s scaling 

methodology is presented in section IV.C.5 

For the NOPR, DOE analyzed three representative product classes: (1) 1-horsepower, 

four-pole, polyphase motor, (2) 1⁄2-horsepower, four-pole, CSIR motors, and (3) 3⁄4-horsepower, 

four-pole, CSCR motor. By choosing these three product classes, DOE ensured that each motor 

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EERE-2007-BT-STD-0007 COMMENT 31
category (polyphase, CSIR, and CSCR) was represented. DOE achieved this by selecting
 

horsepower ratings for each motor category that are commonly available from most 

manufacturers, thus increasing the quantity of available data on which to base the analysis. 

Finally, DOE chose four-pole motors for each motor category, consistent with NEMA-provided 

shipments data (see TSD chapter 9), which indicated that these motors had the highest shipment 

volume in 2007. See TSD chapter 5 for additional detail on the product classes analyzed. 

In response to the NOPR, Baldor and NEMA commented that the product class selected 

for polyphase motors was inappropriate. They asserted that according to NEMA’s standard 

ratings in MG1-1987, a 1-horsepower, four-pole, polyphase motor would not be considered a 

small motor or NEMA general purpose small motor, and therefore falls out of the scope of this 

rulemaking. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 62-63; NEMA, No. 24 at p. 7) 

However, as discussed in section IV.A.1, DOE disagrees with Baldor and NEMA’s interpretation 

of scope, and in this final rule, DOE is including small electric motors with horsepower ratings 

ranging from 1⁄4- to 3-horsepower and pole configurations of two, four, and six poles. In 

consideration of this scope, DOE believes that the representative product classes selected in the 

NOPR engineering analysis are appropriate and is continuing to use these same representative 

product classes in today’s final rule. 

2. Baseline Models 

The engineering analysis DOE conducted calculates the incremental costs for equipment 

with efficiency levels above the baseline in each product class analyzed. For the NOPR analysis, 

DOE established the baseline motor efficiency and design for the three representative product 

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EERE-2007-BT-STD-0007 COMMENT 31
classes by purchasing what it believed to be the lowest efficiency motors on the market for each 


of these classes. To select these baseline motors, DOE interviewed manufacturers and used 

catalog data on motor efficiency and physical dimensions. DOE recognizes that motors with 

smaller core diameters, may be unable to achieve efficiencies as high as those with larger core 

diameters. In order to preserve the availability of these smaller core diameter motors, DOE 

selected baselines which it believed represented the most dimensionally constrained, in terms of 

core diameter, and least efficient motors currently available on the market. 

After purchasing the three baseline small electric motors, DOE tested the motors 

according to the appropriate IEEE test procedures (as dictated by DOE’s small electric motor test 

procedure discussed in section III.A). After performing the appropriate test procedures, DOE 

then tore down each baseline motor to obtain internal dimensions, copper wire gauges, steel 

grade, and any other pertinent design information. Those parameters and tests were then used as 

inputs into the design software, allowing DOE to model the motor and calibrate its software to 

the tested efficiencies. All subsequent higher-efficiency motor designs employed the design 

options discussed earlier to model incremental improvements in efficiency and increases in cost 

over the baseline. 

a. Baseline Efficiencies 

At the NOPR public meeting, DOE received several comments regarding the validity of 

the baseline motor efficiencies used in the engineering analysis. Emerson Motor Company 

pointed out that it is common to see a spread in efficiencies within a population of motors of a 

particular design. Emerson questioned if an analysis was conducted to determine if the baseline 

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EERE-2007-BT-STD-0007 COMMENT 31
 

polyphase motor chosen and tested had an efficiency value that was at the high-end, low-end, or
 

near the average compared to the population of motors of that model type. (Emerson, Public 

Meeting Transcript, No. 20.4 at pp. 73-75) Similarly, Baldor and NEMA noted that the baseline 

polyphase motor’s tested efficiency (77 percent) varied significantly from the catalog efficiency 

(74 percent). They commented that using 77 percent as the efficiency of the baseline motor in the 

engineering analysis assumed that a single tested value of efficiency is equal to the true 

arithmetic mean of the full-load efficiencies of the population of motors. They argued that given 

the distribution of efficiencies commonly seen across a population of motors, due in part to 

factors such as manufacturing variability, this would be an inappropriate assumption. In 

addition, they also cited the electric motor compliance provisions (in 10 CFR 431.17) for 

support. These provisions state that the lowest full-load efficiency in a sample can differ from 

the nominal full load efficiency by as much as 15 percent due to variations in losses attributable 

to variability in manufacturing and testing facilities. Baldor and NEMA asserted that similar 

conditions should be expected for small motors. Baldor and NEMA recommended that absent 

any other data, DOE should use the manufacturer-rated catalog efficiency of the polyphase motor 

(74 percent) as the baseline efficiency. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 120­

121, 125; NEMA, No. 24 at p. 11, 13) 

DOE agrees that it is possible that one tested efficiency value does not represent the 

average efficiency over a population of motors. Inconsistencies in motor laminations and 

processing during manufacturing can result in motors of a single design having a distribution of 

efficiencies, most commonly seen as variability in core and stray load losses. However, as 

manufacturers were not required to report its catalog efficiencies for these motors based on the 

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EERE-2007-BT-STD-0007 COMMENT 31
results of the DOE test procedures, DOE does not agree with NEMA’s assertion that catalog 

efficiencies should be used as the baseline efficiencies. 

In consideration of the comments received, DOE conducted additional testing to validate 

the polyphase baseline efficiency. DOE tested five additional polyphase motors (for a total of six 

tests, exceeding the minimum five required by the DOE sampling requirements for electric 

motors in 10 CFR 431.17) of the same baseline model, purchased from five separate warehouses 

in order to ensure the maximum variability in production. DOE then used the average of the six 

tests as the baseline efficiency for the polyphase motor. For the single-phase baseline motors, 

because the tested values did not deviate significantly from the catalog efficiency values and as 

DOE did not receive specific comments opposing these values, DOE used the single-tested 

efficiency values as the baseline efficiencies. 

Because DOE modified the efficiencies of the baseline designs relative to that which was 

calculated in the motor design software, DOE felt it necessary to evaluate whether the 

efficiencies of the higher efficiency designs modeled in the software would also change. As 

stated earlier, DOE calibrated its software model to the NOPR tested efficiencies of the baseline 

models, and all subsequent higher efficiency motor designs were generated as incremental 

efficiency gains and cost increases over this baseline design. Thus, a change in the baseline 

efficiency would likely affect the efficiencies of the other motor designs. Therefore, for this 

final rule, DOE shifted the baseline modeled efficiencies to match the tested values described 

above. Similarly, subsequent, more efficient designs were shifted by the same percentage 

change in losses as the baseline shifts. For example, the baseline polyphase model in the design 

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EERE-2007-BT-STD-0007 COMMENT 31
 

software predicted an efficiency of 77.7 percent. This value was decreased to the average tested 

efficiency value of 75.3 percent, constituting an increase in motor losses of roughly 14 percent. 

The modeled efficiencies of the more efficient designs were then shifted down in efficiency by a 

14 percent increase in motor losses as well. 

Table IV.5 Efficiency Values of Baseline Models 

 Polyphase 

1 hp, 4 pole 

CSIR 

1⁄2 hp, 4 pole 

CSCR 

3⁄4 hp, 4 pole 

Catalog Rated Efficiency (%) 74.0 59.0 72.0 

Software Modeled Efficiency (%) 77.7 57.9 70.7 

Baseline/Tested Efficiency (%) 75.36

 57.97 71.47 

Shift in Losses from Modeled Values (%) 14 0 -3 

In the NOPR, DOE stated that an accredited laboratory performed IEEE Standard 112 

Test Methods A and B and IEEE Standard 114 to find efficiency data for its baseline models. 

However, at the public meeting on December 17, 2009, Baldor commented that according to 

NEMA and the National Voluntary Laboratory Accreditation Program Handbook 150-10, 

accreditation is based on motor testing in accordance with IEEE Standard 112 Test Method B 

only, and that it does not currently cover testing in accordance with IEEE Standard 112 Method 

A or IEEE Standard 114. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 114-115) 

Therefore, Baldor suggested that DOE’s statement about motor tests was misleading because no 

accreditation exists for two of the three listed methods. DOE clarifies its previous statement to 

say that a laboratory accredited to perform IEEE Standard 112 Test Method B performed the 

tests. 

6

 This efficiency represents the average of tests conducted on six separate units of the same model number. 

7

 These values were incorrectly presented in the NOPR as 57.7 and 71.0 for CSIR and CSCR, respectively. These 

values presented in the NOPR represent the NOPR modeled efficiencies. 74 FR 61427. 

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b. Baseline Temperature Rise 


NEMA MG1 defines several temperature rise requirements for general purpose 

alternating current single-speed induction motors. In the NOPR TSD, DOE reported the 

modeled temperature rise characteristics of the baseline motors selected in the engineering 

analysis. In response to those values, Baldor reasoned that because the reported temperature rises 

(78o C for the polyphase motor and 86o C for the CSIR motor at full load) would far exceed the 

NEMA temperature rise limit of 70o C at service factor load, for a Class A motor, the selected 

baseline motors were inappropriate selections. (Baldor, Public Meeting Transcript, No. 20.4 at 

pp. 27-30) After receiving Baldor’s comments, DOE reviewed the data from thermal tests 

conducted on the purchased baseline motors and found that the winding temperature tests 

indicated that all three baseline motors in fact meet NEMA temperature rise requirements for 

Class A insulation systems. See chapter 5 of the TSD for the tested temperature rise data for 

each baseline motor. However, because the modeled temperature rises in the design software 

were inconsistent with these tests, DOE revised the operating temperature inputs to the design 

software to agree with the tested temperature rise data. This change in operating temperature 

results in slight changes in the baseline modeled efficiencies. Namely as operating temperature 

decreases, motor efficiency generally increases. Though these motors meet temperature rise 

requirements for Class A insulation systems, DOE emphasizes again, that its scope of coverage 

is not bound to those motors with temperature rises of less than Class A requirements, but rather 

motors that contain insulation class systems rated A or higher. 

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c. Baseline Motor Performance 


In the NOPR TSD, DOE presented the modeled performance characteristics for the 

baseline motors selected. Baldor and NEMA both commented that none of the baseline motors 

meet all of the general purpose performance characteristics for locked-rotor torque, locked-rotor 

current, and breakdown torque as defined in NEMA MG1-1987. They argued that these motors 

cannot be considered small electric motors (under the statutory definition) and therefore, should 

have never been chosen as baseline motors. For polyphase motors, they cited comparisons to 

performance characteristics in NEMA MG1-1987 intended for “medium” motors. (Baldor, 

Public Meeting Transcript, No. 20.4 at pp. 64-67; NEMA, No. 24 at pp. 7-8) The NEEA/NPCC 

disagreed and stated that because the performance of the motors selected by DOE were 

representative of products on the market, they were appropriate baseline models. (NEEA/NPCC, 

No. 27 at pp. 8-9) 

DOE examined the performance characteristics of the three baseline motors, and 

determined that they meet all small electric motor performance requirements of NEMA MG1. 

Thus, DOE believes that they are appropriate baseline motors and are representative of covered 

small electric motors on the market. Table IV.6 below presents references to NEMA MG1-1987 

sections containing performance characteristics that DOE believes are relevant to single-phase 

and polyphase small electric motors. 

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Table IV.6 NEMA MG1-1987 Performance Requirements Relevant to General Purpose 

Small Motors 

 Single Phase Polyphase 

Breakdown Torque 12.32.1 12.37 

Locked Rotor Current 12.33.2 None* 

Locked Rotor Torque 12.32.2 None 

* Because NEMA MG1-1987 section 12.35 is labeled as applying to only medium motors, DOE does not believe 

there are polyphase locked rotor current requirements for small motors. However, NEMA commented at the 

preliminary analysis stage that it is common industry practice to use the limits for Design B medium motors for 

small motors. (NEMA. No. 13, p. 6) 

DOE notes that in the NOPR TSD, DOE presented these performance characteristics at 

full load, steady state operating temperature. When extrapolated down to an ambient 

temperature of 25o C, the temperature at which NEMA specifies that breakdown torque 

requirements must be met, all baseline motors meet the necessary small motor performance 

requirements in MG1. A direct comparison of those values, as requested by Baldor (Baldor, No. 

25 at p. 2; Baldor, Public Meeting Transcript, No. 20.4 at p. 66) is available in TSD chapter 5. 

3. Higher Efficiency Motor Designs 

After establishing baseline models, DOE next used the motor design software to 

incorporate design options (generated in the market and technology assessment and screening 

analysis) to increase motor efficiency. In response to the NOPR engineering analysis, DOE 

received several comments that addressed issues regarding the application of the design options 

in the engineering analysis and the validity of the results outputted from the design software. 

In general, manufacturers questioned whether DOE adequately verified that its design 

software accurately predicts motor efficiency. NEMA and Baldor stated that DOE seemingly 

used an AEDM to generate motor designs and scaled efficiencies for other product classes 

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EERE-2007-BT-STD-0007 COMMENT 31
without meeting DOE’s own substantiation requirements of an AEDM. Emerson stated that in 


order for manufacturers to use an AEDM for compliance and certification with energy 

conservation standards, DOE requires that the AEDM must be applied to 5 basic models of small 

electric motors, and it be shown to accurately predict motor efficiency under real-world testing. 

Collectively, this constitutes a total of 25 tests manufacturers must complete in order to verify 

their design software. (Emerson, Public Meeting Transcript, No. 20.4 at p. 105) Baldor and 

NEMA contended that DOE must be held to these same verification standards if it uses an 

AEDM in establishing energy conservation standards. (Baldor, Public Meeting Transcript, No. 

20.4 at pp. 118-24, 145-146; NEMA, No. 24 at p. 11-12) 

NEEA/NPCC disagreed with these comments, stating that requirements of certification 

and compliance with federal efficiency regulations are wholly unrelated and inapplicable to 

DOE’s analysis methodology. The motor design software used in the engineering analysis was 

simply being used to create motor models for analysis, not as an alternative compliance tool. 

Thus, DOE is under no obligation to meet the verification standards of an AEDM. NEEA/NPCC 

stated that based on the description of the design software, the technical qualifications of the 

consultants, and the motor testing and teardowns conducted to verify the accuracy of software 

tools, it has satisfied with DOE’s engineering analysis methodology. (NEEA/NPCC, No. 27 at 

pp 6-7). 

DOE agrees with NEEA/NPCC that substantiation of an AEDM is a concept intended for 

certifying compliance with energy efficiency standards. It is a tool for manufacturers to use to 

help ensure that equipment they manufacture comply with the standards that DOE sets. It is not 

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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. 

Moreover, on the bases of the baseline motor efficiency verification process which 

included physical teardowns for numerous small motors, DOE has confidence in the software 

program it has selected and believes it to be appropriate to analyze efficiency levels for small 

electric motors.8

 Though the supporting data for these tests are based on confidential 

manufacturer data, the performances of these motors verify the software predictions. 

In addition, as discussed in the NOPR, to the extent that it was feasible, DOE 

substantiated the resulting cost-efficiency curves by testing and tearing down higher efficiency 

motors. In response to that NOPR discussion, NEMA asserted that as seen in Table 12.1 and 

Table 12.2 in appendix 5A of the NOPR, DOE did not compare the test results to the calculated 

results for the representative product classes. (NEMA, No. 24 at p. 24) DOE wishes to clarify 

that Table 12.1 and Table 12.2 in appendix 5A of the NOPR TSD contained test results for 

motors that were used as part of DOE’s scaling methodology. The results of the cost-efficiency 

curve validation testing for representative product classes are shown in Figure 4.1 through Figure 

4.3 of appendix 5A of the NOPR and final rule TSDs. 

8

 DOE notes that the software used for its analysis has been employed by numerous motor manufacturers to develop 

designs that have then been used to produce lines of motors, including capacitor-start and polyphase motors. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

a. Electrical Steel
 

In the NOPR engineering analysis, DOE modeled the use improved grades of electrical 

steel and thinner laminations to achieve higher motor efficiency. In response to that analysis 

Baldor and NEMA commented that because DOE’s design software bases loss calculations on 

Epstein core loss values, they believe DOE’s modeled efficiencies using improved steel types 

may overestimate the actual achievable efficiency for a particular motor design. Baldor cited its 

experience with building and testing multiple motors using various steel types, stating that it has 

never been shown that the core loss in a motor with round laminations and rotating flux field is 

directly related to the results of Epstein testing. (Baldor, Public Meeting Transcript, No. 20.4 at 

pp. 276-80, Baldor, No. 25 at pp. 5-7; NEMA, No. 24 at pp. 23-24) As a result, Baldor asserted 

that DOE should not rely on steel manufacturer core loss data unless it is able to produce an 

actual motor to verify its design assumptions. (Baldor, Public Meeting Transcript, No. 20.4 at p. 

277) NEEA/NPCC encouraged DOE to investigate the claims made by Baldor at the public 

meeting and revise the engineering analysis if necessary. (NEEA/NPCC, No. 27 at pp. 9-10) 

DOE recognizes that in analyzing motor performance, calculated core losses based on 

Epstein tests may deviate from actual core losses in the motor.9

 This is primarily due to the 

harmonic effects created by the distortion of the flux density waveform. When motor core losses 

are modeled or measured at solely the fundamental frequency, it is possible that additional losses 

due to these harmonics may not be accounted for, which may yield an overall underestimation of 

losses. While DOE acknowledges that this phenomenon exists, DOE also believes it has 

accounted for this effect in its analysis. 

9

 Epstein tests are performed by steel manufacturers to determine expected core loss values in electrical steel. The 

results of these tests are usually provided by steel manufacturers and are used by motor design engineers to predict 

motor performance. 

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As Baldor suggests, one way to ensure that a software model is calibrated correctly to 

account for effects such as these is to build prototype motors and examine their performance 

characteristics. Though DOE did not perform such an exercise specifically for this rulemaking, 

the design software DOE employed for this analysis has been used in the past to design many 

small motors, whose performance characteristics compare favorably with the model predictions. 

Baldor did not provide any additional data from which DOE could refine its analysis or perform 

sensitivity analyses, even though it stated the values of core loss used in DOE’s software model 

were inaccurate. 

DOE believes that the variances between Epstein losses and actual motor losses are not 

an issue for its engineering analysis. It is DOE’s understanding that the Epstein core loss data 

begin to vary significantly from actual motor core losses when various components of the core 

steel are driven into magnetic saturation. Magnetic saturation is when the amplitude of the 

magnetic field excitation is large enough to force the flux density (of the magnetic field) into the 

nonlinear region of the B-H curve. At this point the harmonic components of the 

electromagnetic field increase.10 As these harmonic components increase, motor efficiency may 

be adversely affected and predicted core losses from the Epstein tests will deviate from actual 

core losses seen in the motor. In order to assess the degree to which these harmonic effects may 

impact the efficiency of motors analyzed in the engineering analysis, DOE examined the 

magnetic flux densities at full-load for each motor design. By using steel manufacturer-provided 

magnetization curves, DOE first determined the saturation point for each of the lamination types. 

10 Yamazaki, Katsumi; Watanabe, Yuta. “Stray Load Loss Calculation of Induction Motors Using Electromagnetic 

Field Analysis.” IEEJ Transactions on Industry Applications, Volume 128, Issue 1, pp. 56-63. 

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DOE then evaluated each of its motor designs to determine whether it operates near magnetic
 

saturation. The results of this analysis indicated that only two motor designs, the CSIR baseline 

design and the polyphase efficiency level (EL) 1 design, operate close to the point of magnetic 

saturation at full load. Based on these results, DOE believes that for all other motor designs, 

reliance on the Epstein core loss data is appropriate to model motor efficiency. 

DOE recognizes that for motors designs operating near the point of magnetic saturation 

(i.e., CSIR baseline and polyphase EL 1 designs), the modeled efficiency might deviate from a 

tested efficiency if a prototype were built. With regards to the CSIR baseline design, DOE notes 

that, as discussed in section IV.C.2.a, the efficiency associated with that design was based on a 

tested efficiency, rather than a modeled efficiency. Therefore, the baseline efficiency for the 

CSIR motor should adequately account for any harmonic core loss effects. For the polyphase EL 

1 design, DOE recognizes that there may be significant uncertainty in its modeled efficiency. 

However, as discussed in section VI DOE has found that an efficiency level higher than EL 1 is 

technologically feasible and economically justified based on the net benefits to the nation and 

individual consumers. Therefore, DOE’s standards-setting decisions in this final rule are not 

dependent on any uncertainties associated with the polyphase EL1 motor design. Please refer to 

TSD chapter 5 for additional information regarding the steels used in DOE engineering analysis, 

their respective saturation levels, and the flux densities of the designs using those steels. 

Baldor also questioned the validity of using several higher efficiency steel types in small 

motors, citing an AK steel publication. Baldor commented that several of the lamination types 

modeled, namely 24M19 and 29M15, are not recommended for use in motors with less than a 

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EERE-2007-BT-STD-0007 COMMENT 31
 

100 horsepower rating. (Baldor, No. 25 at p. 7) DOE has reviewed the referenced AK Steel 

publication11 and disagrees with Baldor’s assertion. The AK Steel publication does not suggest 

that 24M19 and 29M15 steels should not be used in motors with less than a 100 horsepower 

rating; rather it only indicates that small electric motors currently on the market do not typically 

use these steel grades. In addition, DOE has not received any comments explaining why these 

lamination types, commonly used in medium motors, would not be applicable to small electric 

motors. Therefore, in this final rule, DOE continues to use higher efficiency steel grades and 

thinner laminations in the engineering analysis. 

b. Thermal Analysis 

NEMA and Baldor also questioned whether a thermal analysis was conducted for the 

higher efficiency motors modeled, stating the importance of verifying the thermal viability of 

motor designs. (NEMA, No. 24 at pp. 6-7, Baldor, Public Meeting Transcript, No. 20.4 at pp. 

28-29) Emerson commented that the NOPR analysis disregarded MG1 performance 

requirements, including operating temperatures, potentially cause conflicts with the National 

Electrical Code. (Emerson, No. 28, p. 2) In response to these comments, DOE has refined its 

thermal analysis methodology to ensure that it is accurately modeling motor efficiency and that 

all motor designs evaluated are thermally viable. As mentioned in section IV.C.2.b, to establish 

the baseline motors’ operating temperatures, DOE conducted tests in accordance with the 

relevant IEEE test procedures and monitored the temperature rises of the motors. DOE was then 

able to calculate a thermal resistance for each of the baseline motors. The thermal resistance of 

each subsequent design was modified to reflect the improved thermal transfer of the more 

11 AK Steel Product Data Bulletin. Nonoriented Electrical Steels. 

http://www.aksteel.com/pdf/markets_products/electrical/Non_Oriented_Bulletin.pdf. 

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efficient design. As each higher efficiency design was modeled, DOE calculated a new 


temperature rise. These calculations indicate that as motor efficiency increases (through an 

increase in the amount of active material and decrease in I2

R losses12), the temperature rise of the 

motor continually decreases. For this reason, DOE believes that all higher efficiency motor 

designs analyzed in the engineering analysis have lower temperature rises than their respective 

baseline motors and are thermally viable. See TSD chapter 5 for additional information regarding 

the actual temperature rises calculated for each of DOE’s designs. 

c. Performance Requirements 

As discussed in section IV.C.2.c, NEMA, through its MG1 publication, lays out a number 

of performance requirements (breakdown torque, locked rotor torque, and locked rotor current) 

that motors must meet in order to be considered “general purpose.” In response to the small 

electric motor designs presented in the NOPR, manufacturers commented that some of DOE’s 

more efficient designs do not meet certain performance requirements. Emerson added that many 

of the design changes that would be necessary to meet these requirements, such as increasing 

resistance at locked rotor or increasing the number of turns of the stator coils, could actually 

decrease efficiency. (Baldor, No. 25 at p. 4; Baldor, Public Meeting Transcript, No. 20.4 at pp. 

67, 86-87; Baldor, No. 25 at pp. 1-3; Emerson, Public Meeting Transcript, No. 20. 4 at pp. 192­

93; Emerson, No. 28, p. 1) Emerson also noted that the costs for the designs might increase 

when the motors are adjusted to meet these performance characteristics. (Emerson, Public 

Meeting Transcript, No. 73) In light of these comments, DOE revisited its engineering designs 

and found that when new performance values were calculated at operating temperatures of 25oC 

12 I2

R losses refer to resistive losses, stemming from current flow through the copper windings in the stator and 

conductor bars in the rotor and manifest as waste heat which adversely affects the efficiency of a motor. 

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(as was done for the baseline designs), the vast majority of motors met applicable NEMA 


standards. For the motors that did not meet breakdown torque, locked rotor torque, or locked 

rotor current requirements (as presented in TSD Chapter 5), DOE revised these designs such that 

they adhered to all performance requirements. DOE notes that in some cases, as predicted by 

manufacturers, the design revisions led to increases in costs to maintain the same level of 

efficiency. See Chapter 5 of the TSD for further details on the performance characteristics of 

motor designs analyzed in the engineering analysis and comparisons to NEMA performance 

requirements. 

Baldor also noted that many small electric motors are rated in a broad voltage range 

(208V to 230V) and asserted (without clarifying) that the NEMA standard specifies these motors 

must be able to meet NEMA performance requirements over the entire voltage range. Baldor 

questioned whether DOE’s proposed efficiency levels are achievable when motors are operated 

across this entire voltage range (specifically at 208V). (Baldor, Public Meeting Transcript, No. 

20.4 at pp. 271-72) As indicated by Emerson (Emerson, Public Meeting Transcript, No. 20.4 at 

pp. 273-74), it is DOE’s understanding the 208V rating constitutes an unusual service condition. 

Thus, DOE’s engineering analysis was based on motor operation at 230V. 

DOE notes that although the NEMA standard may require that certain performance 

characteristics (such as breakdown torque) be met through the entire rated voltage range, there is 

no such requirement for federal efficiency standards. In fact, DOE’s test procedures for small 

electric motors, IEEE 112 (Section 6.1) and IEEE 114 (Section 8.2.1) state that efficiency shall 

be determined at the rated voltage, without specifying which voltage shall be used in cases where 

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motors are rated with broad voltages or dual voltages. DOE understands that it is at the 


manufacturer’s discretion under which single voltage condition to test its motor. Because the 

test procedure outputs an efficiency value at a single input voltage, DOE did not conduct an 

additional analysis at 208V. 

Baldor and NEMA stated that MG1 has additional requirements for small electric motors 

such as voltage unbalance, variation from rated speed, occasional excess current, stall time, 

overspeed, and sound quality. (Baldor, No. 25 at p. 3; NEMA, No. 24 at p. 9) In examining the 

variation from rated speed requirements, DOE notes that these are only applicable to medium 

motors, and thus not relevant to DOE’s small electric motor designs. With regard to the other 

specifications, DOE believes that because it purchased the baseline motors from NEMA 

manufacturers, it is reasonable to assume that the motors meet NEMA MG1 requirements. 

In addition DOE has evaluated each of its motor designs and believes for the following 

reasons that because the baseline motors likely meet all specifications, then the higher efficiency 

motors are expected to meet them as well. Specifically, whether a motor is able to meet voltage 

unbalance, excess current, and stall time requirements is often related to whether a motor 

overheats at those specified conditions. As the I2R losses in higher efficiency motors modeled 

are generally lower than that of the baseline motors (thus, resulting in a lower temperature rise), 

DOE believes that overheating effects will not be exacerbated with higher efficiency. 

For the overspeed requirement, DOE understands that there are several mechanical 

failure modes that may cause the motor to be unable to withstand speeds above the rated speed. 

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Two primary reasons are the failure of the motor bearings and the potential for the motor shaft to 


bend, causing the rotor and stator to contact. In addition, DOE understands this issue to be more 

problematic for medium motors (with larger inertia) than small motors. Finally, for sound 

quality, decreased current and magnetic flux densities in higher efficiency motors will likely 

cause the magnitude of the torque pulsations of the motor to decrease during running conditions, 

reducing noise. The added mass of higher efficiency motors also serves as a dampener to reduce 

motor vibrations and noise. Given all of these reasons, DOE believes that all motor designs 

analyzed in the engineering analysis meet the additional performance requirements identified by 

the commenters. 

DOE also received comments at the public meeting regarding the power factor associated 

with its designs. Baldor commented that during the preliminary analysis stage of the rulemaking 

some parties preferred that the power factor levels be above 85 percent, but that DOE’s analyses 

utilized a power factor around 71 to 73 percent for polyphase motors. (Baldor, Public Meeting 

Transcript, No. 20.4 at pp. 275-76) As discussed in the NOPR, DOE understands that sacrificing 

power factor to obtain gains in efficiency is counterproductive because of the negative effects on 

line efficiency. 74 FR 61429 For this reason, DOE maintained or increased the power factor of 

the baseline motor for each more efficient design. While power factor is generally considered 

when evaluating the potential benefits related to a particular efficiency level, it is not a design 

option that necessarily improves the energy efficiency of small electric motors. Increasing 

power factor could yield results that reduce the energy efficiency of individual units or impose 

higher costs without an increase in energy efficiency. For this reason, DOE opted not to require 

its designs to have an 85 percent power factor in its design analysis. 

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d. Stray Load Loss 

In the NOPR, DOE presented values of stray load loss that were modeled in the design 

software for the baseline and higher efficiency motor designs. The polyphase designs had a 

value of 2.4 percent for stray load loss, while the CSIR and CSCR designs had a value of 1.8 

percent. In response to the NOPR, DOE received several comments regarding the stray load loss 

values used in its designs. Baldor commented that in the absence of a tested stray load loss 

value, the IEEE Standard 112 Test Method A (which is referenced as the DOE test procedure for 

polyphase motors of 1-horsepower of lower) indicates that a value of 1.8 percent should be used. 

As a result, Baldor questioned the source of DOE's polyphase motor stray load loss value. 

Baldor was concerned that DOE actually performed IEEE Standard 112 Test Method B, which 

calculates stray load loss but may yield a different tested efficiency value than Test Method A. In 

Baldor's view, using Test Method B could potentially skew the analysis. (Baldor, Public 

Meeting Transcript, No. 20.4 at pp. 280-82; NEMA, No. at pp. 23-24) 

Baldor and NEMA also questioned why the stray load loss value of 1.8 percent was used 

for the single-phase motors when the IEEE Standard 114 test procedure calls for a measurement 

of stray load losses. (Baldor, Public Meeting Transcript, No. 20.4 at p. 282; NEMA, No. 24 at p. 

24) They were concerned that DOE did not follow the IEEE Standard 114 test procedure for the 

single-phase motors since the stray load loss value used did not appear to be a measured value. 

(Baldor, Public Meeting Transcript, No. 20.4 at p. 286) Advanced Energy supported DOE’s 

assumptions, commenting that even though IEEE Standard 114 calls for a separation of losses, it 

also allows an assumed stray load loss value of 1.8 percent when a measured value cannot be 

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determined. (Advanced Energy, Public Meeting Transcript, No. 20.4 at pp. 285-87) 

NEEA/NPCC also commented that DOE’s stray load loss assumptions were appropriate. 

(NEEA/NPCC, No. 27 at p. 10) 

To clarify, DOE tested the polyphase baseline motor according to both the IEEE Standard 

112 Method A and Method B test procedures. While Method A is the appropriate DOE test 

procedure for a 1-horsepower, four-pole small electric motor, Method B determines efficiency by 

segregating motor losses. When DOE compared the results of Method A and Method B, it found 

that there was no material difference between the resulting tested efficiencies for this particular 

motor. Therefore, DOE assumed that it would be most accurate to model the stray load losses 

determined by IEEE Standard 112 Method B (i.e. 2.4 percent) rather than an assumed value (i.e. 

1.8 percent). 

The two baseline single-phase motors were tested according to IEEE Standard 114. As 

stated by Advanced Energy, the IEEE Standard 114 test procedure provides that if stray load loss 

is not measured, then the value of stray load loss at rated load may be assumed to be 1.8 percent 

of the rated load, consistent with DOE’s assumption for CSCR and CSIR motors. DOE 

recognizes that losses can be segregated using the IEEE Standard 114 test procedure and 

therefore also calculated the stray load losses for the baseline motors. The results of these tests 

showed that the stray load losses for the CSIR and CSCR baseline motors were 1.8 percent and 

1.7 percent. Given the similarity to IEEE Standard 114 assumed value and NEMA’s previous 

recommendation to use this value, DOE believes that the use 1.8 percent stray load loss for the 

single-phase motors was appropriate and has used it again for today’s final rule. 

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Additionally, NEMA and Baldor questioned DOE’s decision to maintain a constant stray 

load loss across its designs within a representative product class, stating that it would be unlikely 

that the use of thinner electrical steels in a longer core length would have resulted in the same 

level of stray load loss as in the baseline design. (NEMA, No. 24 at p. 24; Baldor, Public 

Meeting Transcript, No. 20.4 at pp. 281-83) In response, DOE affirms that its assumptions of 

stray load loss for higher efficiency motor designs are appropriate. DOE recognizes that several 

factors, such as manufacturing process and harmonic effects, may affect the quantity of stray 

load loss for a particular motor. However, as discussed earlier, DOE has determined that the 

majority of motor designs evaluated operate below the point of magnetic saturation, thus 

reducing the impact of harmonic effects. Additionally, DOE understands that it is common 

practice for motor design engineers to assume a value of stray load loss either based on 

experience or as recommended by IEEE test procedures when creating new, potentially more 

efficient, motor designs. Finally, DOE also notes that both the polyphase and single-phase IEEE 

test procedures provide precedent for the assumption of constant stray load losses across several 

motor designs. 

e. Stack Length and Core Diameter 

In the NOPR, DOE considered an increase in stack length as a viable option for 

increasing motor efficiency. DOE recognized, however, that limitations for certain motor 

applications exist because an increase in stack length may cause the motor to exceed the space 

constraints of the application into which it would reside. Thus, DOE followed a suggestion made 

by NEMA during the preliminary analysis stage and limited the stack length increases for space74
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

constrained applications to no more than a 20 percent increase over the baseline motor. (NEMA, 


No. 13, at p. 4) For applications that DOE considered non-space constrained, the stack length of 

the motor was allowed to increase by up to 100 percent of the stack length of the baseline motor 

(i.e. it could double). 

In response to the NOPR analysis, several interested parties commented on DOE’s 

assumptions of space constraints and stack length increases. WEG questioned if the 20 percent 

increase in stack length for space constrained applications is an appropriate tolerance. (WEG, 

Public Meeting Transcript, No. 20.4 at p. 83) A.O. Smith commented that doubling the stack 

length in non-space constrained applications will be somewhat impractical for customers’ 

applications. (A.O. Smith, Public Meeting Transcript, No. 20.4 at p. 81). 

In response to the manufacturers’ comments, DOE maintains that the 20 percent increase 

in stack length for space-constrained applications that was used in the NOPR is still an 

acceptable tolerance. DOE notes that NEMA reiterated its support for this design constraint in 

its comments responding to the NOPR, by citing its recommendation from the preliminary 

analysis. (NEMA, No. 24 at p. 9) Regarding doubling the stack length of the motor, DOE also 

believes this is an appropriate tolerance for non-space constrained applications. When DOE 

solicited engineering cost-efficiency curves from manufacturers for the preliminary analysis, all 

participating manufacturers suggested that increasing stack height would be one of the first 

design options used to achieve greater efficiencies because of the relative cost of this design 

option versus a change in steel type lamination. In designs provided by all of these 

manufacturers, stack increases of well over 100 percent relative to the baseline were used to 

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EERE-2007-BT-STD-0007 COMMENT 31
achieve target efficiency levels that DOE provided to manufacturers. Accordingly, DOE 


believes that for those applications that are non-space constrained, a stack increase of 100 

percent is an appropriate and even a likely design option that manufacturers could employ. DOE 

accounts for the costs associated with increasing a motor’s stack length in markups analysis (see 

section IV.D). 

Emerson also commented that the NOPR efficiency levels would require several motors 

to increase in frame size. (Emerson, No. 28 at p.1) However, DOE disagrees with Emerson’s 

comments and notes that for all higher efficiency designs developed in the engineering analysis, 

core diameter was held constant to the baseline value. As only an increase in core diameter 

would force a frame size increase, DOE believes that all efficiency levels analyzed can be 

achieved without increasing frame size. 

4. Cost Model 

For the NOPR engineering analysis, DOE estimated the manufacturing production cost 

(MPC) of small electric motors by using outputs of the design software to generate a complete 

bill of materials. The bill of materials was marked up to account for scrap, overhead (which 

includes depreciation) and associated non-production costs such as interest payments, research 

and development, and sales and general administration. To account for the increased depreciation 

of equipment associated with manufacturing a copper rotor, DOE used separate overhead 

markups for motor designs using copper and aluminum rotors. The software output also 

included an estimate of labor time associated with each step of motor construction. DOE 

multiplied these estimates by a fully burdened labor rate to obtain an estimate of labor costs. 

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DOE estimated input costs by using an inflation-adjusted 5-year average of prices for 

each of the input commodities: steel laminations, copper wiring, and aluminum and copper for 

rotor die-casting. This method for calculating costs is consistent with past rulemakings where 

material costs were a significant part of manufacturers’ costs. In calculating the 5-year average 

prices for these commodities, DOE adjusted historical prices to 2008 terms using the historical 

Producer Price Index (PPI) for that commodity’s industry. For this final rule, DOE updated 

material prices using the PPI to reflect 2009$. After calculating the MPC, DOE applied a 1.45 

manufacturer markup to arrive at the MSP. 

Emerson commented that it was concerned that DOE had not appropriately accounted for 

the significant costs associated with implementing the technology to manufacture motors with 

copper die-cast rotors in the engineering analysis. (Emerson, Public Meeting Transcript, No. 

20.4 at p. 94) DOE recognizes that there are additional costs associated with implementing 

copper die-cast rotors and has incorporated higher depreciation costs in the Engineering Analysis 

for designs requiring this technology. 

With regard to the accounting of higher depreciation for equipment used to manufacture 

copper die-cast rotors, NEEA/NPCC supported DOE’s approach to using different overhead 

markups for designs with copper rotors and those with aluminum rotors. (NEEA/NPCC, No. 27 

at p. 9) NEMA commented that since motor manufacturers typically standardize its production 

process for a product line, the higher overhead attributable to the application of advanced 

technologies will be applied over all production unless the manufacturer exits that portion of the 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

market. (NEMA, No. 24 at p. 9) As all comments supported the use of higher markups when 


manufacturing copper rotors, DOE maintained this approach in the engineering analysis for the 

final rule. See section IV.C.4 for further details. 

5. Efficiency Scaling 

For the NOPR, in order to scale efficiency levels from the representative product classes 

to the other product classes, DOE used data on commercially-available motors to investigate how 

changing horsepower or pole configuration affects efficiency, DOE evaluated product lines of 

different manufacturers separately. In developing these efficiency relationships, DOE 

considered only motors of the most restrictive frame size for a given product class to ensure that 

the most dimensionally-constrained motors on the market would be able to meet all efficiency 

levels derived. DOE then converted these efficiency relationships across product class into 

motor loss relationships. DOE applied these relationships (as a percentage change in motor 

losses) to each efficiency level analyzed for the representative product classes, ultimately 

deriving corresponding efficiency levels for product classes not directly analyzed in the 

engineering analysis. DOE repeated this analysis for each manufacturer’s product line for which 

sufficient data were available. Finally, DOE averaged the results based on each of the 

manufacturer’s product lines to obtain aggregated scaled efficiency levels for all product classes. 

DOE received several comments on the results and methodology of the proposed scaling 

analysis. While NEAA/NPCC supported DOE’s scaling methodology (NEEA/NPCC, No. 27 at 

p. 9), Baldor stated that the scaling presented is likely not accurate because of the difficulty in 

predicting efficiencies when changing frame sizes, horsepower, and pole configurations. 

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Instead, Baldor commented that DOE should create a motor design for each non-representative 


product class to verify the scaled efficiencies. (Baldor, Public Meeting Transcript, No. 20.4 at p. 

97; Baldor, No. 25 at p. 8) WEG also commented that the scaling should take into account not 

only the change in efficiency associated with altering horsepower or pole configuration, but also 

the drop in efficiency associated with moving from a 56-frame to a 48–frame, and potentially a 

smaller core diameter. (WEG, Public Meeting Transcript, No. 20.4 at p. 220) 

In addition, with regard to the polyphase motor scaling, several manufacturers pointed to 

the efficiencies at high horsepower ratings as evidence that DOE scaling was flawed. 

Specifically, they remarked that although the proposed level for the representative polyphase 

product class harmonized with medium motor NEMA Premium efficiency standards, the 3­

horsepower, six-pole polyphase motor had a scaled efficiency greater than the NEMA Premium 

level.13 They also noted that because the comparable medium motor for that product class is 

built in a 213 T-frame (larger than a 56-frame), it may be unreasonable to require a 56-frame 

motor to have a higher efficiency. (A.O. Smith, No. 26 at p. 2; Baldor, No. 25 at p. 8; Baldor, 

Public Meeting Transcript, No. 20.4 at pp. 100-101, 212-213; Regal-Beloit, Public Meeting 

Transcript, No. 20.4 at pp.105) 

DOE agrees that the efficiency behavior at high horsepower ratings for polyphase motors 

indicated a lack of accuracy in the NOPR scaling, and has revised its analysis for the final rule. 

Baldor’s recommendation to generate motor designs to validate scaling essentially constitutes 

developing an additional engineering analysis for every product class, which is atypical for DOE 

13 NEMA Premium refers to efficiency levels for three-digit frame series medium electric motors developed by 

NEMA to identify high efficiency motors. Congress subsequently adopted those levels for medium electric motors. 

See EISA 2007, Sec. 313(b). 

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EERE-2007-BT-STD-0007 COMMENT 31
rulemakings and unnecessary because it defeats the purpose of using a scaling methodology. In
 

addition, DOE notes that in its comments on the preliminary analysis, NEMA recommended that 

DOE utilize product literature to derive efficiency levels for product classes not directly analyzed 

in the engineering analysis, which was a significant reason why DOE maintained a scaling 

approach based partially on publicly available data. (NEMA, No. 13, at p. 10) Thus, DOE 

believes scaling is an appropriate approach to developing efficiency levels. As interested parties 

did not recommend a new methodology for scaling, DOE based it revised scaling on the same 

general methodology (establishing relationships in efficiency across horsepower ratings and pole 

configurations), but utilized additional sources of data to refine its inputs. 

One new source of data DOE utilized was the NEMA recommended standard levels for 

polyphase, CSIR, and CSCR motors built in small frames (42- and 48-frames) and in 56-frames. 

These recommended standard levels included efficiencies for motors with horsepower ratings 

less than and equal to 1-horsepower and with two-, four-, or six-pole configurations. (NEMA, 

No. 24 at p. 1) DOE first examined this data to see how it compared to the efficiency data of 

motors currently on the market. DOE noted that the efficiency relationships that NEMA 

presented between product classes were comparable to the market data that DOE had collected 

for the NOPR. For this reason, DOE concludes that NEMA’s recommended standard levels can 

be used to establish appropriate efficiency (or loss) relationships for lower horsepower 

polyphase, CSIR, and CSCR motors. 

For the high horsepower (greater than or equal to 1-horsepower) polyphase motors, DOE 

utilized the relationships found in the NEMA Premium standards for electric motors. As seen in 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

Table IV.7, the majority of the NEMA Premium standards between 1- and 3-horsepower are 


based on motors with a frame size in the 140T series, which has the same foot to shaft dimension 

as the 56-frame motor. Therefore, for these 140T series product classes, DOE used NEMA 

Premium efficiencies to develop relationships across horsepower ratings and poles. DOE did not 

use the efficiency relationships found from NEMA Premium classes associated with larger frame 

sizes (182T). For these horsepower/pole configurations, DOE did not have sufficient efficiency 

data to determine appropriate scaling relationships. Thus, though efficiency generally increases 

with horsepower, in order to ensure that all efficiency levels are technologically feasible, DOE 

decided that the 3-horsepower, four-pole motor and 11⁄2-horsepower, two pole motor would have 

the same minimum efficiency standards as the 2-horsepower, four-pole motor and 1-horsepower, 

two-pole motor, respectively. 

Table IV.7 Frame Sizes Associated with NEMA Premium Standards 

Motor Horsepower/Standard 

Kilowatt Equivalent Six Poles Four Poles Two Poles 

1 hp/0.75 kW 56 143T 145T 

11⁄2 hp/1.1 kW 143T 145T 182T 

2 hp/1.5 kW 145T 145T 

3 hp/2.2 kW 145T 182T 

In the absence of any standardized efficiency levels above 1-horsepower for CSIR motors 

(such as those provided in the NEMA Premium table for polyphase motors), DOE continued to 

use market efficiency data. Since this approach, when used in the NOPR, resulted in some 

aberrations (abnormally high efficiencies) for high horsepower polyphase motors, DOE modified 

its methodology slightly for the final rule to result in more appropriate scaling relationships. As 

stated earlier, for the NOPR, because some manufacturers showed larger increases in efficiency 

with increasing horsepower than others, DOE averaged data from several manufacturer product 

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lines to create efficiency relationships. However, for this final rule, to ensure the technological 


feasibility of all scaled efficiency levels, instead of averaging data from all manufacturers, DOE 

selected the product line which resulted in the most achievable efficiency levels. 

As mentioned in the NOPR, DOE was unable to locate sufficient market data for CSCR 

motors. However, DOE data indicate that CSCR motors exhibit scaling relationships similar to 

CSIR motors. For these reasons, DOE decided to continue utilizing CSIR market data to 

characterize the efficiency (or loss) relationships present in the CSCR market at high horsepower 

ratings. 

Next, DOE addressed changes in physical dimensions of motors across horsepower 

ratings and pole configurations. As discussed earlier, DOE recognizes that core diameter affects 

the amount of active material that is used to reduce motor losses, thus impacting efficiency. If 

DOE were to set a standard based on an analysis of a motor of larger core diameter, it could 

potentially eliminate smaller core diameter motors from the market. Therefore, after establishing 

the efficiency relationships (by using the NEMA recommended levels, the NEMA Premium 

levels, and market data), DOE accounted for the fact that for some horsepower/pole 

configurations, 48-frame size motors are commercially available, while for others, only 56-frame 

size motors are commercially available. 

As stated by WEG at the NOPR public meeting, a reduction in frame size (or core 

diameter) should accompanied by a reduction in efficiency. To determine the appropriate 

efficiency reduction of shifting from a motor with a core diameter representative of a 56-frame to 

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a core diameter representative of a 48-frame, DOE again utilized the NEMA recommended 

efficiencies. From these efficiency values, DOE noted that according to NEMA a shift in frame 

size constitutes approximately a 20 percent change in losses. DOE applied this 20 percent 

reduction in losses to product classes for which 42 frame or 48-frame motors are commercially 

available. DOE intends for its loss scaling analysis to reflect motors in the smallest commercially 

available frame size for each product class. 

After deriving efficiency relationships accounting for changes in horsepower, pole 

configuration, and core diameter, DOE then applied these relationships (as a percentage change 

in motor losses) to each efficiency level of the representative product classes, ultimately deriving 

corresponding efficiency levels for the non-representative product classes. 

6. Cost-Efficiency Results 

The results of the engineering analysis are reported as cost-efficiency data (or “curves”) 

in the form of MSP (in dollars) versus full-load efficiency (in percentage). These data form the 

basis for subsequent analyses in the final rule. As discussed in the NOPR, DOE developed two 

curves for each product class analyzed, one for the space-constrained set of designs restricted by 

a 20-percent increase in stack height and one for the non-space constrained set of designs 

restricted by a 100-percent increase in stack height relative to the baseline. 

NEMA recommended efficiency levels for small electric motors that it believed would be 

technologically feasible to implement by 2015. NEMA presented six separate sets of efficiency 

levels, one for 56-frame size motors in each of the three motor categories and one for 42- and 48­

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frame size motors in each of the three motor categories. (NEMA, No. 24 at p. 1) When DOE 


revised its engineering analysis, it ensured that each of its representative units had an efficiency 

level that corresponded to one of those sets of standards. For CSIR motors, NEMA proposed an 

efficiency value of 72.0 percent for a 48-frame size, four-pole 1⁄2-horsepower motor. This 

proposal roughly corresponds to DOE’s efficiency level 4 for CSIR motors. For CSCR motors 

NEMA proposed an efficiency value of 80.0 percent for a 56-frame size, four-pole, 3⁄4- 

horsepower motor. This proposal corresponds to DOE’s efficiency level 2 for CSCR motors. 

For polyphase motors, NEMA did not present an efficiency value for the four-pole, 1­

horsepower product class. In light of this, DOE utilized its scaling model to identify the 

projected efficiency for the four-pole, 1-horsepower product class according to NEMA’s 

recommendations for the 42- and 48-frame size motors. DOE used the 42/48-frame size 

proposed levels to apply to its representative product class because the core diameter of its 

baseline model is representative of 48-frame size motors. DOE projects this efficiency value to 

be approximately 82.6 percent for the representative polyphase motor. As this efficiency lies 

between the designs analyzed for EL 4 and EL5, DOE created an additional efficiency level at 

82.6 percent, denoted EL 4b. DOE developed a new space constrained and non-space 

constrained design at this efficiency level that adhered to all of DOE’s design limitations. 

Table IV.8 through Table IV.10 show the efficiency value and manufacturer selling price 

data for each EL examined in the final rule. 

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Table IV.8 Efficiency and Manufacturer Selling Price Data for Polyphase Motor 


Efficiency Level Efficiency (%) 

(Design 1/Design 2)* 

Manufacturer Selling Price 

($) 

(Design 1/Design 2)* 

Baseline 75.3 98.54 

EL 1 77.3 104.83 

EL 2 78.8 108.17 

EL 3 80.5 114.24 

EL 4 81.1 118.54 

EL 4b 83.5 / 83.5 135.62 / 134.04 

EL 5 85.3 / 85.2 230.92 / 153.92 

EL 6 86.2 / 86.3 237.70 / 186.37 

EL 7 (Max-tech) 87.7 / 87.8 1,766.06 / 326.18 

*Design 1 denotes the space-constrained design, and Design 2 denotes the non-space-constrained design. If only one 

value is listed, then the space-constrained design is the same as the non-space-constrained design. 

Table IV.9 Efficiency and Manufacturer Selling Price Data for Capacitor-Start, InductionRun Motor 

Efficiency Level Efficiency (%) 

(Design 1/Design 2)* 

Manufacturer Selling Price 

($) 

(Design 1/Design 2)* 

Baseline 57.9 91.24 

EL 1 61.1 95.43 

EL 2 63.5 98.45 

EL 3 65.7 99.58 

EL 4 70.6 / 70.5 114.31 / 106.99 

EL 5 71.8 / 71.8 117.07 / 118.00 

EL 6 73.1 / 73.3 182.09 / 132.22 

EL 7 (Max-tech) 77.6 / 77.7 1,200.98 / 151.25 

*Design 1 denotes the space-constrained design, and Design 2 denotes the non-space-constrained design. If only one 

value is listed, then the space-constrained design is the same as the non-space-constrained design. 

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Table IV.10 Efficiency and Manufacturer Selling Price Data for Capacitor-Start, 

Capacitor-Run Motor 

Efficiency Level Efficiency (%) 

(Design 1/Design 2)* 

Manufacturer Selling Price 

($) 

(Design 1/Design 2)* 

Baseline 71.4 111.72 

EL 1 75.1 117.13 

EL 2 79.5 / 79.5 137.20 / 129.88 

EL 3 81.7 / 81.8 142.63 / 135.56 

EL 4 82.8 / 82.8 146.44 / 142.76 

EL 5 84.1 / 84.0 154.55 / 151.91 

EL 6 84.8 / 84.6 236.98 / 158.25 

EL 7 86.8 / 86.7 244.03 / 175.75 

EL 8 (Max-tech) 88.1 / 87.9 1,771.47 / 327.69 

*Design 1 denotes the space-constrained design, and design 2 denotes the non-space-constrained design. If only one 

value is listed, then the space-constrained design is the same as the non-space-constrained design. 

D. Markups to Determine Equipment Price 

To calculate the equipment prices faced by small electric motor purchasers, DOE 

multiplied the manufacturing costs developed from the engineering analysis by the supply chain 

markups it developed (along with sales taxes). In the NOPR, DOE explained how it developed 

the distribution channel markups used. 74 FR 61434. 

DOE did not receive comments on these markups; however, in written comments, NEMA 

and DOJ commented that some original equipment manufacturers (OEMs) could incur additional 

design costs to redesign their products to accommodate the increased size of more efficient 

motor designs. (NEMA, No. 24 at p.19 and DOJ No. 29 at p. 2) DOE recognizes that motors 

produced following the introduction of the standards described in this rule will likely be different 

in size and shape from motors produced today. In particular, the designs produced in DOE’s 

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engineering analysis exhibit longer stack length to increase efficiency. DOE also projects that the 

standards may result in significant increases in market share for CSCR motors (which have an 

extra external capacitor). DOE understands that these changes may result in the need for some 

OEMs who incorporate these motors to redesign their products. Nationally, about 2.5% of U.S. 

gross domestic product is spent on research and development (R&D; National Science Board. 

2010. Science and Engineering Indicators 2010. Arlington, VA: National Science Foundation 

(NSB 10-01)). DOE estimates that R&D by equipment OEMs, including the design of new 

products, generally represents approximately 2 percent of company revenue. This percentage is 

slightly less than the national average to account for high technology companies that generally 

spend a much larger fraction of revenue on R&D than OEMs of equipment that incorporate small 

motors. DOE accounted for the additional costs to redesign products and incorporate differentlyshaped motors by adding 2% to the OEM markup, increasing the baseline OEM markup from 

1.37 to 1.39 and the incremental OEM markup from 1.27 to 1.29 for OEMs without a distributor, 

and 1.33 to 1.35 for OEMs that purchase motors through distributors. 

DOE used these markups, along with sales taxes, installation costs, and manufacturer 

selling prices (MSPs) developed in the engineering analysis, to arrive at the final installed 

equipment prices for baseline and higher efficiency small electric motors. As explained in the 

NOPR (74 FR 61434), DOE defined three distribution channels for small electric motors to 

describe how the equipment passes from the manufacturer to the customer. DOE retained the 

same distribution channel market shares described in the NOPR. 

Table IV.11 summarizes for each of the three identified distribution channels the baseline 

and incremental markups at each stage and the overall markups, including sales taxes. Weighting 

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the markups in each channel by its share of shipments yields an average overall baseline markup 

of 2.52 and an average overall incremental markup of 1.86. DOE used these markups for all 

three types of motors. 

Table IV.11 Summary of Small Electric Motor Distribution Channel Markups 

Direct to OEMs 

65% 

Via Distributors to OEMs 

30% 

Via Distributors to 

End-Users 

5% 

Baseline Incremental Baseline Incremental Baseline Incremental 

Wholesale 

Distributor - ­ 1.28 1.10 1.28 1.10 

OEM 1.39 1.29 1.39 1.35 

Retail and PostOEM 

Distributor 

1.43 1.18 1.43 1.18 1.44 1.18 

Contractor or 

Installer 1.10 1.10 1.10 1.10 1.10 1.10 

Sales Tax 1.0684 1.0684 1.0684 

Overall 2.34 1.79 2.99 2.06 2.17 1.53 

Using these markups, DOE generated motor end-user prices for each efficiency level it 

considered, assuming that each level represents a new minimum efficiency standard. Because it 

generated a range of price estimates, DOE describes prices within a range of uncertainty. 

Chapter 7 of the TSD provides additional detail on the markups analysis. 

E. Energy Use Characterization 

The energy use characterization estimates the annual energy consumption of small 

electric motors. This estimate is used in the subsequent LCC and PBP analyses (chapter 8 of the 

TSD) and National Impacts Analysis (NIA) (chapter 11 of the TSD). DOE determined the annual 

energy consumption of small electric motors by multiplying the energy use while in operation by 

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the annual hours of operation. The energy use in operation is a function of the motor loading and 

the losses resulting from motor operation, based on the motor designs characterized in the 

engineering analysis. DOE’s motor designs are also characterized by their power factor, which 

allows DOE to estimate the reactive power requirements of each analyzed motor. 

1. Applications 

DOE’s shipments analysis indicates that small electric motors are used in five application 

categories: pumps; fans and blowers; air compressors; conveyors and material handling; and 

general industrial or miscellaneous applications. Motor energy use depends on application 

because different applications have different annual hours of operation and different average 

motor loading. 

In the NOPR, DOE presented the results of an analysis of motor shipments into the five 

application categories. Table IV.12 shows the distribution of motor shipments by application 

presented in the NOPR. 

Table IV.12 Distribution of Motors by Application and Motor Type 

Motor Application 

Polyphase 

(%) 

CSIR 

(%) 

CSCR 

(%) 

Reference Case 

Air and gas compressors 17.3 14.9 14.9 

Conveyors & Packaging Equipment 13.3 11.9 11.9 

General industrial machinery 11.3 12.5 12.5 

Indus. and comm. fans and blowers 7.3 6.9 6.9 

Pumps and pumping equipment 50.7 53.7 53.7 

Service industry 0.0 0.0 0.0 

Total 100.0 100.0 100.0 

Sensitivity (NEMA Survey) 

Air and gas compressors 45 22 45 

Conveyors & Packaging Equipment 5 2 2 

General industrial machinery 7 1 1 

Indus. and comm. fans and blowers 23 51 29 

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Pumps and pumping equipment 15 13 12 

Service industry 5 11 11 

Total 100.0 100.0 100.0 

In written comments, NEMA submitted the results of a survey of their OEM customers 

for motors which NEMA considers to be covered products. (NEMA, No. 24 at pp. 19 to 21) The 

survey reports distributions by application and owner type, estimates of annual hours of 

operation, and the fraction of motors that are space-constrained. NEMA also provided 

information on a sixth application not included in DOE’s NOPR, service industry motors. The 

distribution by application and motor type provided by NEMA is also shown in Table IV.13. 

DOE has concerns about the accuracy of the results of this survey. It is not clear which 

OEMs were contacted for the survey, how many responded, how representative the respondents 

are of the small motor market, and what specific questions were asked. It is also not clear that the 

survey results represent an accurate picture of the entire US market for small motors, or how all 

OEMs will respond to today’s rule. In contrast, the distributions by motor application that DOE 

used in the NOPR were based on analysis conducted in the early stages of the rulemaking, 

supplemented by a review of U.S. Census and U.S. Customs data regarding production and 

imports of motors and equipment containing motors. For these reasons, DOE retained its 

assumptions regarding the distribution of motors by application and sector; however, DOE did 

run a sensitivity case that reflects the results of the NEMA survey. This sensitivity is discussed 

in Section VI, and the detailed results are presented in the TSD. 

Table IV.13 shows the distributions of motors by sector within each application used in 

the NOPR, as well as the results provided by the NEMA survey. 

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Table IV.13 Distribution of Motors by Application and Sector 


Application 

Sector 

Total 

(%) 

Industrial 

(%) 

Commercial 

(%) 

Agricultural 

(%) 

Residential 

(%) 

Reference Case 

Air and gas compressors 40 40 10 10 100 

Conveyors & Packaging Equipment 40 50 10 0 100 

General industrial machinery 50 40 10 0 100 

Indus. and comm. fans and blowers 50 50 0 0 100 

Pumps and pumping equipment 40 35 20 5 100 

Service industry 0 0 0 0 N/A 

Sensitivity (NEMA Survey) 

Air and gas compressors 0 15 15 70 100 

Conveyors & Packaging Equipment 65 35 0 0 100 

General industrial machinery 80 20 0 0 100 

Indus. and comm. fans and blowers 20 80 0 0 100 

Pumps and pumping equipment 10 40 20 30 100 

Service industry 10 80 0 10 100 

2. Annual Hours of Operation and Motor Loading 

In the NOPR, and in today’s final rule, DOE characterized the motor loading and annual 

hours of operation with distributions for each analyzed motor application. DOE’s estimates of 

the average motor loading in each application are unchanged from the NOPR to today’s final 

rule. Table IV.14 shows the average loading in each application. DOE assumed that the motor 

loading distribution took the form of a normal distribution, centered on the average value, with a 

standard deviation equal to one fifth of the average loading. Details on these calculations are 

provided in chapter 6 of the TSD. 

Table IV.14 Average Motor Loading By Application 

Application 

Average 

Loading 

(%) 

Air and gas compressors 85 

Conveyors & Packaging Equipment 50 

General industrial machinery 70 

Indus. and comm. fans and blowers 80 

Pumps and pumping equipment 65 

Service industry 70 

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In the NOPR, DOE assumed distributions of the annual hours of operation in each 

application with means and medians as shown in Table IV.15. At the December 17, 2009 public 

meeting, Emerson commented that the average hours of operation within each application 

assumed by DOE are too high (Emerson, Public Meeting Transcript No. 20.4 at pp. 197-99). 

According to Emerson, the distribution of hours of operation that DOE assumed for each 

application, detailed in the TSD, is a highly skewed distribution in which the mean and median 

can be significantly different. As a result of its survey of OEMs, NEMA reported lower hours of 

operation only for compressors, and reported that service industry motors run 1000 hours per 

year on average, with a median of 400 hours. However, by including in the table in their written 

comments the operating hour assumptions DOE used in the NOPR for the other applications, 

NEMA appears to accept DOE’s assumptions of hours of operation for conveyors, general 

industrial machinery, fans and blowers, and pumps. The mean and median hours of operation in 

each application in the reference and sensitivity case are shown in Table IV.15. 

Table IV.15 Median and Mean Annual Hours of Operation and Fraction that Run All the 

Time, by Motor Application 

Application 

Annual Hours of Operation Fraction of motors 

that run all the time 

(%) Median Mean 

Reference Case 

Air and gas compressors 375 600 0 

Conveyors & Packaging Equipment 2000 3000 8 

General industrial machinery 1200 2000 4 

Indus. and comm. fans and blowers 2825 4500 40 

Pumps and pumping equipment 1850 3000 12 

Service industry NA NA NA 

Sensitivity (NEMA Survey) 

Air and gas compressors 100 200 0 

Conveyors & Packaging Equipment 2000 3000 0 

General industrial machinery 1200 2000 4 

Indus. and comm. fans and blowers 2825 4500 10 

Pumps and pumping equipment 1850 3000 12 

Service industry 400 1000 2 

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F. Life-Cycle Cost and Payback Period Analysis 

In response to the requirements of section 325(o)(2)(B)(i) of the Act, DOE conducted 

LCC and PBP analyses to evaluate the economic impacts of possible amended energy 

conservation standards on small electric motor customers. This section of the notice describes 

these analyses. DOE conducted the analysis using a spreadsheet model developed in Microsoft 

(MS) Excel for Windows 2003. 

The LCC is the total consumer expense over the life of the equipment, including purchase 

and installation expense and operating costs (energy expenditures, repair costs, and maintenance 

costs). The PBP is the number of years it would take for the consumer to recover the increased 

costs of a higher-efficiency equipment through energy savings. To calculate the LCC, DOE 

discounted future operating costs to the time of purchase and summed them over the lifetime of 

the equipment. DOE measured the change in LCC and the change in PBP associated with a given 

efficiency level relative to a base case forecast of equipment efficiency. The base case forecast 

reflects the market in the absence of amended mandatory energy conservation standards. As part 

of the LCC and PBP analyses, DOE developed data that it used to establish equipment prices, 

installation costs, annual energy consumption, energy and water prices, maintenance and repair 

costs, equipment lifetime, and discount rates. 

Table IV.16 summarizes the approaches and data DOE used to derive the inputs to the 

LCC and PBP calculations for the NOPR. For today’s final rule, DOE did not introduce changes 

to the LCC and PBP analyses methodology described in the NOPR, but incorporated changes to 

the inputs to the analysis to account for updates to the engineering analysis and energy price 

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trends and to analyze the sensitivity of the results using the survey data NEMA provided. 

Chapter 8 of the TSD contains detailed discussion of the methodology utilized for the LCC and 

PBP analyses as well as the inputs developed for the analyses. 

Table IV.16 Summary of Inputs and Key Assumptions in the Life-Cycle Cost and Payback 

Period Analyses 

Inputs NOPR Changes for the 

Final Rule 

Affecting Installed Costs 

Equipment Price Derived by multiplying manufacturer cost by 

manufacturer, distributor and OEM markups, 

and sales tax. 

No change. 

Installation Cost Based on data from RSMeans. No change. 

Affecting Operating Costs 

Annual Energy 

Use 

Derived by multiplying hours of operation by 

losses, accounting for motor loading. 

Reactive power demand calculated from 

power factor. 

No change in 

operating hours in 

the reference case; 

changes to 

operating hours of 

compressors in the 

sensitivity cases. 

Losses, loading 

and reactive power 

changed slightly, 

as a result of the 

updated 

engineering 

analysis. 

Energy Prices Electricity: Distribution of values for each 

sector, updated using EIA’s 2007 Form 861 

data.. 

No change. 

Energy Price 

Trends 

Energy: Reference Case forecast updated 

with EIA’s AEO 2009 April Release. HighPrice and Low-Price forecasts updated with 

EIA’s AEO 2009 March Release. Carbon Cap 

and Trade case from Lieberman-Warner. 

AEO 2010 for the 

reference; ratios 

from AEO 2009 

March release 

used for high and 

low. 

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Repair and 

Maintenance Costs 

Unchanging with efficiency. No change. 

Affecting Present Value of Annual Operating Cost Savings 

Equipment 

Lifetime 

Mean of 7 and 9 years. Lifetime is correlated 

with annual hours of operation. 

No change. 

Discount Rates Approach based on cost of capital of publicly 

traded firms in the sectors that purchase small 

electric motors. Primary data source is 

Damodaran Online.14 

No change. 

Affecting Installed and Operating Costs 

Space Constraints Assumed 20% of motors in OEM applications 

face space constraints 

No change in 

reference case; 

analyzed 62% and 

95% sensitivity 

cases. 

Effective Date of 

New Standard 

2015. No change. 

1. Installation Cost 

Installation costs include labor, overhead, and any miscellaneous materials and parts. For 

the NOPR and today’s final rule, DOE used data from the RS Means Mechanical Cost Data, 

2008 on labor requirements to estimate installation costs for small electric motors. DOE 

estimates that installation costs do not increase with equipment efficiency. 

2. Energy Prices 

For both the NOPR and today’s final rule, DOE developed nationally representative 

distributions of electricity prices for different customer categories (industrial, commercial, and 

residential) from 2007 Energy Information Administration (EIA) Form 861 data, the most recent 

data available. DOE estimates that marginal energy prices for electric motors are close to 

average prices, which vary by customer type and utility. The average prices (in 2009$) for each 

14 Please see the following website for further information: http://pages.stern.nyu.edu/~adamodar/. 

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sector are 7.5 cents for the industrial and agricultural sectors, 10.4 cents for the commercial 


sector, and 11.7 cents for the residential sector. DOE also estimated an average reactive power 

charge of $0.51 per kilovolt-amps reactive (kVAr) per month using survey data provided in 

written comments submitted during the preliminary analysis stage of the rulemaking by Edison 

Electric Institute. The data identified those customers who are subject to a reactive power 

charge. (EEI, No. 14 at p. 6) 

3. Energy Price Trend 

To estimate the trends in electricity prices for the NOPR, DOE used the price forecasts in 

the 2009 Annual Energy Outlook (AEO 2009) April Release.15 To arrive at prices in future 

years, DOE multiplied the average prices described above by the forecast of annual average price 

changes. Because the AEO 2009 forecasts prices only to 2030, DOE followed past guidelines 

provided to the Federal Energy Management Program by EIA and used the average rate of 

change during 2020–2030 to estimate the price trends beyond 2030. For today’s final rule, DOE 

had updated its analysis to use the price forecasts in the AEO 2010 Early Release, which 

includes price forecasts until 2035. DOE used the average rate of change from 2025 to 2035 to 

estimate price trends beyond 2035. 

The spreadsheet tools used to conduct the LCC and PBP analysis allow users to select 

either the AEO’s high-price case or low-price case price forecasts to estimate the sensitivity of 

the LCC and PBP to different energy price forecasts. The AEO 2009 April Release and AEO 

2010 Early Release only provide forecasts for the Reference Case. Therefore, for the NOPR, 

DOE used the AEO 2009 March Release high-price or low-price forecasts directly to estimate 

high-price and low-price trends. For today’s final rule, DOE updated the low-price ad high-price 

15 All AEO publications are available online at: www.eia.doe.gov/oiaf/aeo/ 

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forecasts to be based on the ratio between the AEO 2009 March Release low- or high-price 

forecasts and the AEO 2009 March Release reference case. DOE then applied these ratios to the 

AEO 2010 Early Release reference case to construct its high-price and low-price forecasts. 

4. Maintenance and Repair Costs 

Small electric motors are not usually repaired, because they often outlast the equipment 

in which they are installed. DOE found no evidence that repair or maintenance costs would 

increase with higher motor energy efficiency. In response to the preliminary analysis, no 

interested parties provided any comments or data indicating that maintenance or repair costs are 

likely to change with motor efficiency. Thus, in today’s final rule DOE did not change the repair 

and maintenance costs for motors that are more efficient than baseline products that were 

presented in the NOPR. 

5. Equipment Lifetime 

For the NOPR and today’s final rule, DOE developed motor lifetime distributions for 

each motor application, with a mean of seven years for capacitor-start motors and a mean of nine 

years for polyphase motors. Each distribution incorporates a correlation between the motor 

annual hours of operation and the motor lifetime. Motor lifetime is governed by two Weibull 

distributions. One characterizes the motor lifetime in total operating hours while the other 

characterizes the lifetime in years of use in the application. Motors are retired from service at the 

age when they reach either of these limits. 

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6. Discount Rates 


The discount rate is the rate at which future expenditures are discounted to estimate their 

present value. DOE used the classic economic definition that discount rates are equal to the cost 

of capital. The cost of capital is a combination of debt interest rates and the cost of equity capital 

to the affected firms and industries. For each end-use sector, DOE developed a distribution of 

discount rates. DOE’s methodology and inputs for calculating discount rates is unchanged from 

the NOPR (74 FR 61440), and details are available in chapter 8 of the TSD. In response to the 

NOPR, DOE did not receive any comments regarding customer discount rates. 

7. Space-Constrained Applications and the After-Market 

Comments at the NOPR public meeting (WEG, Emerson, and Regal-Beloit, Public 

Meeting Transcript, No. 20.4 at pp. 184-85, 191-92), and in written comments (NEMA, No. 24 

at p. 19; DOJ, No. 29 at p. 2), expressed concerns regarding the challenges faced by users who 

purchase motors to replace existing motors within their applications. (This market is referred to 

as the “after-market.”) In particular, these customers might face difficulty replacing motors in 

space-constrained applications with new motors of different size. Motors are sold to these 

customers through distributors or OEMs. DOE was unable to obtain data on the size and 

structure of the space-constrained portion of this market. However, DOE’s motor lifetime 

function, which differentiates between motors retired due to mechanical failure and motors 

retired when the application in which they reside is retired, indicates that approximately 25­

percent of small electric motors retire because of mechanical failure. Only users of these motors 

would be participants in the after-market, as other users replace their complete application rather 

than the motor alone. DOE has assumed that 20-percent of motor application are space98
 

EERE-2007-BT-STD-0007 COMMENT 31
constrained, indicating that approximately 5-percent of motors are both space-constrained and 


retire due to mechanical failure – these users would participate in the after-market). 

As discussed above in section IV.E, the NEMA survey reported on the fraction of motors 

purchased by OEMs that face space constraints inside their application. NEMA reported that 62 

percent of the OEMs responding to the survey stated that any increase in size would negatively 

impact their ability to use the motor in their current applications, and that 33-percent stated that 

their applications could accept “only a slight increase” in size; only 5 percent stated that their 

application had few space constraints. 

While DOE appreciates the information provided by NEMA, the agency has concerns 

regarding how well the sample represents total U.S. small motor shipments and possible survey 

response bias. In addition, as part of its written comments, NEMA has proposed alternative 

standards. These alternative standards appear to indicate that if nearly all OEMs face space 

constraints for motors in their products, it would be difficult for motor manufacturers to achieve 

the efficiency level called for in the NEMA standard levels without large cost increases. For 

these reasons, DOE has retained its assumption that 20-percent of the small motors are installed 

in applications that cannot accommodate any size increases. 

OEMs that manufacture applications with space constraints on their motors have several 

options: (1) redesign their application to accommodate a motor with a longer stack and/or a run 

capacitor; (2) purchase a stockpile of motors not covered by today’s rule to install in future 

production of their application; (3) replace a less efficient CSIR motor with a more efficient 

CSCR motor without increasing stack length; or (4) replace their motor with a motor not covered 

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by today’s rule. DOE estimates the likelihood and effect of each of these outcomes in its analysis 


of national impacts, by: increasing the OEM baseline and incremental markups by 2 percent to 

either pay for redesign of their products to accommodate larger motors or purchase a stockpile of 

existing motors of the correct size; applying a model that estimates the migration from CSIR to 

CSCR motors, based on the relative difference in equipment and operating costs of the two types 

of motors and the assumed fraction that are space-constrained; and changing the assumption in 

the reference case regarding the elasticity of demand for small electric motors to a change in 

purchase price (from zero, or inelastic, to -0.25), thereby increasing the number of motors 

expected to migrate to totally enclosed motors not covered by today’s rule. These assumptions 

result in nearly the entire CSIR market migrating to CSCR motors under the proposed standards, 

with net benefits to the average motor customer. 

In response to this comment, DOE analyzed the impact of increasing the spaceconstrained fraction to 62 percent and to 95 percent of all motors in its sensitivity case (the 

additional 2-percent markup is not included in these two scenarios). These results are 

summarized in section VI below. 

Emerson also pointed out that the OEMs whose products have space constraints are 

typically smaller companies that have a hard time re-engineering their product when changes in 

size occur. (Emerson, Public Meeting Transcript, No. 20.4 at pp. 83-85) DOE recognizes that 

smaller OEMs that manufacture products which can not readily be altered to accommodate a 

larger motor may be adversely affected by today’s rule. In analyzing the potential impact of 

today’s standards on customers, DOE evaluated the impact on identifiable groups of end-use 

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motor customers (i.e., subgroups), such as small businesses, that may not be equally affected by
 

a national standard level. The results of the subgroup analysis for small businesses can be found 

in section VI.C.1.b of this notice. 

8. Standard Compliance Date 

The date by which all small electric motor manufacturers must manufacture motors that 

satisfy the new standards announced in today's rule is statutorily-prescribed under EPCA. See 42 

U.S.C. 6317(b). Therefore, the effective date of any new energy conservation standards for these 

products will be February 2015. DOE calculated the LCC for all end users assuming that each 

one would purchase a new piece of equipment in the year the standard takes effect. 

G. National Impact Analysis-National Energy Savings and Net Present Value Analysis 

1. General 

DOE’s National Impact Analysis (NIA) assesses the national energy savings, as well as 

the national Net Present Value (NPV) of total consumer costs and savings, expected to result 

from new standards at specific efficiency levels. DOE applied the NIA spreadsheet to perform 

calculations of energy savings and NPV, using the annual energy consumption and total installed 

cost data from the LCC analysis. DOE forecasted the energy savings, energy cost savings, 

equipment costs, and NPV for each equipment class from 2015 to 2045. The forecasts provide 

annual and cumulative values for all four parameters. In addition, DOE incorporated into its NIA 

spreadsheet the capability to analyze the sensitivity of the results to forecasted energy prices and 

equipment efficiency trends. Table IV.17 summarizes the approach and data DOE used to derive 

the inputs to the NES and NPV analyses for the NOPR. It also summarizes the changes DOE 

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made in this analysis for today’s final rule. These changes are described in the following 

sections, and more details are available in chapter 11 of the final rule TSD. 

Table IV.17 Approach and Data Used to Derive the Inputs to the National Energy Savings 

and NPV Analyses 

Inputs 2009 NOPR Description Changes for the Final 

Rule 

Shipments Annual shipments from Shipments 

Model. Shipments inelastic to changes 

in motor price. Two CSIR-CSCR crosselasticity cases. 

Updated shipments drivers 

to AEO 2010 for reference 

case. Total shipments 

elasticity changed from 0 

to -0.25. Single crosselasticity case in which 

market shares are fixed 

beginning in 2015. 

Space Constraints Assumed 20% of motors in OEM 

applications face space constraints 

No change in reference 

case; analyzed 62% and 

95% sensitivity cases. 

Effective Date of 

Standard 

2015. No change. 

Base-Case Forecasted 

Efficiencies 

Efficiency distribution determined by 

the number of currently-available 

models meeting the efficiency 

requirements of each TSL. 

Efficiency distribution 

updated to reflect changes 

in engineering analysis, 

including the additional 

polyphase motor design 

Standards-Case 

Forecasted 

Efficiencies 

Roll-up scenario. Efficiency distribution 

held constant over forecast period. 

No change. 

Annual Energy 

Consumption per Unit 

Annual weighted-average values as a 

function of efficiency distribution. 

Updated to account for 

correlation between 

average energy use and 

motor age. 

Total Installed Cost 

per Unit 

Annual weighted-average values as a 

function of efficiency distribution. 

No change. 

Energy Cost per Unit Annual weighted-average values a 

function of the annual energy 

consumption per unit and energy prices. 

No change. 

Repair Cost and None. No change. 

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Inputs 2009 NOPR Description Changes for the Final 

Rule 

Maintenance Cost per 

Unit 

Escalation of Energy 

Prices 

Energy Prices: AEO 2009 April 

Release forecasts for the Reference 

Case. AEO 2009 April Release does not 

provide High-Price and Low-Price 

forecasts; used AEO 2009 March 

Release High-Price and Low-Price 

forecasts to estimate high- and lowgrowth price trends. 

Updated to AEO 2010 

Early Release forecasts for 

the Reference Case. HighPrice and Low-Price 

forecasts created using 

ratios of AEO 2009 March 

release High- and LowPrice forecasts to the AEO 

2009 March Reference 

Case. 

Energy Site-to-Source 

Conversion 

Conversion varies yearly and is 

generated by DOE/EIA’s NEMS 

program (a time-series conversion 

factor; includes electric generation, 

transmission, and distribution losses). 

 No change. 

Effect of Standards on 

Energy Prices 

Determined but found not to be 

significant. 

No change. 

Discount Rate 3% and 7% real. No change. 

Present Year Future expenses discounted to year 

2009. 

Future expenses 

discounted to year 2010. 

2. Shipments 

The shipments portion of the NIA spreadsheet is a shipments model based on 

macroeconomic drivers for small electric motor shipments. In the NOPR, DOE estimated that 

shipments to the industrial sector are proportional to the manufacturing output, shipments to the 

commercial sector are proportional to commercial floor-space, and shipments to the residential 

sector are proportional to the number of households. DOE used the AEO 2009 April Release to 

forecast these three drivers. For today’s final rule, DOE has updated the drivers in the reference 

case to the AEO 2010 Early Release. 

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In the NOPR, DOE examined three alternate shipments scenarios. Two of these scenarios 


were based on the AEO 2009 March Release High-Growth and Low-Growth cases, while the 

third was a “falling market share” case, in which forecast shipments remain constant at their 

2008 levels independent of economic growth. The NEEA/NPCC commented that DOE should 

retain the falling market share case because of uncertainties regarding the size of the future 

demand for small motors covered by this rule, as well as the current economic climate. 

NEEA/NPCC added that DOE should give additional weight to this scenario when making its 

policy decision (NEEA, No. 27 at p. 10). These shipments scenarios are presented in Chapter 9 

of the TSD. 

In its analysis for the NOPR, DOE assumed that customers would not respond to 

standards by changing to enclosed motors, due to different ventilation requirements, and 

analyzed two different elasticities to enclosed motors, -0.25 and -0.5, as sensitivities. Several 

comments (Emerson, Public Meeting Transcript, No. 20.4 at pp. 176-77; NEEA/NPCC, No. 27 

at pp. 5-6; NEMA, No. 24 at p. 19), pointed out that if, as a result of standards, openconstruction motors become more expensive than enclosed motors, customers may choose to 

purchase enclosed motors. DOE’s analysis indicates that enclosed small electric motors are, on 

average, 18-percent more expensive than open motors. For today’s final rule, DOE has changed 

its reference scenario to the -0.25 elasticity scenario for both polyphase and capacitor-start 

motors. As a result, DOE estimates that, depending on the TSL selected, up to 12 percent of the 

capacitor-start motor market might migrate to enclosed motors; however, today’s rule would 

result in a reduction of less than 1-percent for the capacitor-start motor market. DOE has retained 

the inelastic and -0.5 elasticity scenarios as sensitivities. 

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For the NOPR, DOE developed a cross-elasticity model to forecast the impact of 


standards on the relative market shares of CSIR and CSCR motors within each combination on 

motor horsepower and number of poles. DOE used this model to develop two reference cases for 

the NIA analysis. One case assumed that the market share shift described by the model would be 

complete by 2015, the date by which manufacturers must comply with the standard, while the 

other case arbitrarily assumed that the transition would begin in 2015 and be complete by 2025. 

At the December 17, 2009, Public Meeting, WEG Electric commented that their engineers had 

examined motor designs necessary to meet the CSIR and CSCR standard levels proposed in the 

NOPR. Their engineers concluded that motors meeting these efficiencies were manufacturable, 

but that the designs would include a run capacitor (making them all CSCR motors) that might 

present another issue for space constrained applications. (WEG, Public Meeting Transcript No. 

20.4 at pp. 185-86) 

When examining the cross-elasticity between CSIR and CSCR motors, DOE built a 

demand-based model that assumed that manufacturers would produce the products demanded by 

the modeled motor customer behavior. This model has significant uncertainty because of the 

difficulty in predicting the extent and timeframe of the market response to standards and an 

absence of data on changes in the small electric motor market. However, in view of WEG’s 

comment, DOE has placed greater emphasis on the influence of decisions made by 

manufacturers on market share. In particular, in cases where DOE’s model predicts that the 

market will result in a complete or nearly complete shift from CSIR to CSCR motors, DOE 

expects that the market share shift will take place prior to the introduction of standards in 2015 

because manufacturers will change their production by that date. Therefore, for today’s final 

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rule, DOE has decided to use the scenario in which the market share shift is complete by 2015 as 


its single reference case for the shipments model. 

NEMA disagreed with DOE’s statement that the standard levels proposed in the NOPR 

would “maintain a supply of both categories of motors (CSIR and CSCR) in the single-phase 

motor market,” especially since DOE was estimating that the purchase price of a CSIR motor 

would increase dramatically over that of the baseline motor. DOE wishes to clarify that the 

NOPR analysis predicted that nearly all, but not the entire, CSIR market would migrate to CSCR 

motors under the proposed standard level, TSL 7. DOE’s elasticity model for capacitor-start 

motors incorporates both elasticity to products not covered by today’s final rule (enclosed 

motors) and cross-elasticity between CSIR and CSCR motors. DOE expects that the openconstruction CSIR motor market will migrate to open CSCR motors, rather than enclosed CSIR 

motors, because enclosed CSIR motors are only less expensive than open CSCR motors in the 

case of relatively inefficient enclosed CSIR motors. 

Chapter 9 of the TSD describes the shipments and elasticity models and their results in 

detail. 

3. Space Constraints 

As discussed above in Section F, DOE retained its assumption that 20-percent of the 

small motors are installed in applications that cannot accommodate any size increases. DOE has 

added 2-percent to the OEM markups in its reference case to account for estimated increases in 

OEM costs to redesign their products to accommodate larger, more efficient motors, or to 

purchase a stockpile of replacement motors of the correct size. In addition, in response to the 

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survey results presented by NEMA, DOE has analyzed the impact of increasing the spaceconstrained fraction from 20 percent to 62 percent and to 95 percent of all motors in a pair of 

sensitivity case (the additional 2 percent markup is not included in these two scenarios). These 

sensitivity cases have little impact on the national impacts for capacitor-start motors because at 

the capacitor-start efficiency levels in today’s rule, DOE estimates that 97 percent of the CSIR 

market will migrate to CSCR motors assuming only 20 percent of the market is spaceconstrained. Therefore, increasing the assumption of the fraction of space-constrained CSIR 

motors to 95-percent only affects the 3-percent of the CSIR market that had not already migrated 

to CSCR motors under DOE’s reference case, and has little effect on the estimates of national 

energy savings. Appendices 9A and 10A of the TSD present the results of this and other 

sensitivity cases in more detail. 

4. Base-Case and Standards-Case Efficiency Distributions 

In its analysis for the NOPR, DOE developed base-case and standards-case efficiency 

distributions based on the distribution of currently available models for which motor catalogs list 

efficiency. In preparing today’s final rule, DOE developed new scaling relationships governing 

the relationship between the efficiency of each product class to the efficiency of the 

representative product class for its motor category. These changes resulted in some motor models 

that met the criteria for one TSL in the NOPR analysis also meeting the criteria for a different 

TSL in the analysis for today’s rule. The resulting base-case efficiency distributions are shown in 

Table IV.18 DOE’s use of a roll-up method to determine the efficiency in the standards-cases is 

unchanged from the NOPR to the final rule analysis. 

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Table IV.18 Base Case Efficiency Market Shares by Motor Type 


Motor 

Type 

Base Case Market Share (%) by Efficiency Level 

Baseline EL 1 EL 2 EL 3 EL 4 EL 4b EL 5 EL 6 EL 7 

Polyphase 54 6 13 7 12 5 3 0 0 

Baseline EL 1 EL 2 EL 3 EL 4 EL 5 EL 6 EL 7 EL 8 

CSIR 40 30 13 15 2 0 0 0 NA 

CSCR 37 33 4 11 11 0 4 0 0 

5. Annual Energy Consumption per Unit 

In the analysis conducted for the NOPR, DOE developed a model for motor lifetime that 

incorporates a correlation between annual hours of motor operation and the lifetime of the motor. 

This correlation was incorporated into the life-cycle cost analysis, which provides average 

energy use values for the NIA. In the analysis developed for today’s final rule, DOE added a 

correction factor related to this correlation to its NIA model. This correction factor accounts for 

the higher removal rate of motors with higher annual energy usage levels when compared to 

motors with lower annual energy usage levels. This relationship is reflected in DOE's lifetime 

model. 

H. Customer Sub-Group Analysis 

For the NOPR and today’s final rule, DOE analyzed the potential effects of small electric 

motor standards on two subgroups: (1) customers with space-constrained applications, and (2) 

small businesses. For customers with space-constrained applications, DOE used the price and 

energy use estimates developed for space-constrained designs from the engineering analysis to 

conduct its life-cycle cost analysis. For small businesses, DOE analyzed the potential impacts of 

standards by conducting the analysis with different discount rates, because small businesses do 

not have the same access to capital as larger businesses. DOE estimated that for businesses 

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purchasing small electric motors, the average discount rate for small companies is 4.2 percent 


higher than the industry average. Due to the higher costs of conducting business, as evidenced by 

their higher discount rates, the benefits of small electric motor standards for small businesses are 

estimated to be slightly lower than for the general population of small electric motor owners. 

More details on the consumer subgroup analysis can be found in chapter 12 of the final 

rule TSD. 

I. Manufacturer Impact Analysis

 DOE conducted a manufacturer impact analysis (MIA) to estimate the financial impact 

of new energy conservation standards on small electric motors manufacturers, and to calculate 

the impact of such standards on domestic manufacturing employment and capacity. 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 this rulemaking. The GRIM inputs are data 

characterizing the industry cost structure, investments, shipments, and revenues. The key output 

is the industry net present value (INPV). Different sets of assumptions (scenarios) produce 

different results. The qualitative part of the MIA addresses factors such as equipment 

characteristics, market and equipment trends, as well as an assessment of the impacts of 

standards on subgroups of manufacturers. DOE outlined its methodology for the MIA in the 

NOPR. 74 FR 61442–46. The complete MIA for the NOPR is presented in chapter 12 of the 

NOPR TSD. 

For today’s final rule, DOE updated the MIA to reflect changes in the outputs of two 

other key DOE analyses, which feed into the GRIM. In the Engineering Analysis, DOE updated 

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manufacturer production costs (MPCs) and inflated them to 2009$ from 2008$ using the 


producer price index (PPI). In the NIA, DOE updated its shipment forecasts and efficiency 

distributions. In turn, DOE updated the GRIM for these new estimates. DOE also inflated its 

capital and equipment conversion costs to 2009$ from 2008$ using the PPI for Motor and 

Generator Manufacturing (North American Industry Classification System (NAICS) 335312). 

Based on these changes, DOE used the GRIM to revise the MIA results from the NOPR. For 

direct employment calculations, DOE revised the GRIM to include the U.S. Census information 

that was revised for 2007. 

The following sections discuss interested parties comments on the NOPR MIA. In 

general, the format is as follows: DOE provides background on an issue that was raised by 

interested parties, summarizes the interested parties’ comment, and discusses whether and how 

DOE modified its analysis in light of the comments. 

1. Capital Conversion and Equipment Conversion Costs 

For the NOPR, DOE estimated capital conversion costs for a typical manufacturer using 

estimates provided by manufacturers and information provided by industry experts. DOE 

estimated the tooling cost for each separate design at each incremental efficiency level. In 

addition to these capital expenditures, DOE also estimated equipment conversion expenses such 

as research and development, testing, and product literature development associated with new 

energy conservation standards. Because DOE did not receive specific feedback from all 

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manufacturers in the industry, DOE then scaled these costs from a typical manufacturer to 


account for the entire industry where appropriate. 

More specifically, DOE estimated the tooling costs for: (1) total number of laminations 

over baseline designs; (2) grade of steel including the use of premium electrical steels; (3) 

increases in stack length; (4) necessary rewiring; (5) replacement of end rings; and (6) rotor 

redesigns to use copper (if applicable). For rotor redesigns to use copper, DOE estimated the 

costs to purchase new presses, new end rings, and additional tooling. For changes to the grade of 

steel, DOE estimated the costs for punch press dyes. For increases in stack length, DOE 

estimated the costs of switching more production equipment to accommodate a higher volume of 

larger sized small electric motors. For necessary rewiring, DOE estimates the cost of crimp tools. 

For replacement of end rings, DOE estimated the tooling changes for different dimensional 

changes to the end rings. For increases in laminations, DOE estimated the purchase of presses 

and tooling for winding machinery. 

In written comments, NEMA stated that the capital conversion costs DOE assumed in the 

NOPR represent only 25- to 30-percent of the capital investments required by manufacturers at 

the proposed level for CSCR and CSIR. Specifically, NEMA argued that DOE did not account 

for progressive lam dies, new winding retooling, and other equipment conversion costs (e.g., 

engineering time, and manufacture and customer agency approvals). (NEMA, No. 24 at p.18) 

Emerson and A.O. Smith added that such investments needed to reach the proposed standards 

could cause manufacturers to exit the small electric motors market. (Emerson, No. 28 at p. 1; 

A.O. Smith, No. 27 at p. 2) 

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As discussed above, in the NOPR and in today’s final rule, DOE accounts for lam dies, 

new winding retooling and other capital investments at the TSLs that require such tooling. DOE 

also notes that equipment conversion costs associated with R&D, testing, and other non-capital 

expenses are included in its equipment conversion costs assumptions. However, in part because 

the proposed TSL did not require copper rotors or premium electric steel for the CSCR or 

polyphase markets, DOE cannot reconcile its investment totals at TSL 7 for CSCR and CSIR 

with the $150 million to $180 million range implied by NEMA’s comment. However, in 

response to other comments, discussed immediately below, DOE has modified its approach to 

calculating the investments required of a typical manufacturer producing space constrained and 

non-space constrained motors. 

In the NOPR, DOE examined the complete tooling requirements necessary for both 

space-constrained and non-space constrained designs. That is, DOE first calculated tooling costs 

assuming shipments were 100-percent space constrained, then calculated tooling costs assuming 

shipments were 100-percent non-space constrained. Next, DOE calculated the overall tooling 

costs by weighting these values by the fraction of shipments dedicated to space-constrained and 

non space-constrained applications as forecast in the shipments model (20-percent and 80­

percent, respectively). 

Emerson and NEMA commented that the proposed TSLs require the use of different 

materials for electrical steel and rotors for different types of motors, which will lead to high 

capital costs. (Emerson, No. 28 at p. 1; NEMA, No. 24 at p. 18). Baldor Electric commented that 

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manufacturers would lose economies of scope at the proposed TSLs because they would not be 

able to standardize along one type of steel for different classes of motors. Combined with the 

high capital costs, particularly for CSIR, this lack of standardization may lead manufacturers to 

choose to exit portions of the market. (Baldor Electric, Public Meeting Transcript, No. 20.4 at 

pp. 246-47; Emerson, Public Meeting Transcript, No. 20.4 at pp. 248) 

For today’s final rule, DOE modified its calculation of investments based on changes to 

the shipments forecasts related to the split between space constrained and non-space constrained 

motors. For many manufacturers, it will not be possible to invest in tooling equipment for space 

constrained and non-space constrained motors in a manner that is proportional to the relative 

market share of the two types of motors. Particularly given the uncertainty with regard to the 

future market demand and the resulting product mix, DOE believes it is more appropriate to look 

at the specific investment needs of a typical manufacturer at each TSL for both space constrained 

and non-space constrained investments for each motor design. For many design options, this 

leads to investments that are additive—not weighted by shipment share—across spaceconstrained and non-space constrained motors. Furthermore, DOE does not assume economies 

of scope in its assumptions regarding capital investments among the three classes of motors. 

That is, DOE assumed investment in each class independently and assumed they were additive 

when appropriate across the classes. To be clear, DOE is not modifying the shipments scenarios 

from the NIA in this scenario. It is modifying the capital investment assumptions to more 

completely capture the business decisions firms will likely have to make. 

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As mentioned in the comments referenced above, the business case for making the large 


capital investments required for certain types of motors becomes less compelling as shipment 

volumes decrease at higher TSLs (including the TSL established in today’s final rule). DOE 

agrees with Emerson and A.O. Smith that some manufacturers are likely to exit this portion of 

their market, as is reflected by the shipments analysis, which shows a dramatic migration away 

from CSIR motors. For space-constrained motors within the CSIR class DOE projects no 

shipments after standards take effect. To capture this dynamic, at certain TSLs DOE calculated 

investments to include those associated with the CSCR line and the CSIR non-space constrained 

line. Without forecasting a significant volume of space-constrained CSIR shipments, it would be 

inappropriate to assume all manufacturers would invest in the premium electrical steel and 

copper technologies required to meet the standard level. For further details of the investments, 

see chapter 12 of the TSD and or section IV.I of today’s notice. 

In written comment, Emerson further argues that the exit of the market by certain 

manufacturers in response to amended standards would reduce competition and domestic 

employment. (Emerson, No. 28 at p. 1) 

As previously discussed, DOE believes that some manufacturers could exit the small 

electric motors market segment covered by this rule in response to amended standards. However, 

it should be noted that covered small electric motors comprise only a small portion of overall 

motor sales for these companies. At the efficiency levels established by this final rule, DOE’s 

analysis and manufacturer interviews indicated that the majority of manufacturers would likely 

remain in the small electric motors market following the implementation of amended standards. 

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Additionally, DOE learned that a number of covered motors are already manufactured overseas 


and that foreign competition continues to make inroads into the covered motors segment. As for 

a potential reduction in domestic employment, DOE’s analysis indicates that even with the 

potential departure by some manufacturers from segments of the small electric motors market, 

overall direct employment will remain relatively constant due to the increased labor content of 

more efficient motors. 

2. Manufacturer Selling Prices 

In the NOPR, DOE calculated weighted manufacturer selling prices (MSPs) based on a 

shipments split of 20-percent space constrained and 80-percent non-space constrained motors. 

However, the shipments analysis in today’s final rule models a mix of space constrained and 

non-space constrained motors that varies by TSL. As such, DOE has updated its MSPs in the 

GRIM using the same shipment weights used in the shipments analysis at each TSL. For further 

information on the shipment analysis, see chapter 9 of the TSD. 

3. Markup Scenarios 

In the NOPR, DOE analyzed two markup scenarios in the MIA: the preservation-ofreturn-on-invested-capital scenario and the preservation-of-operating-profits scenario. These 

scenarios reflected the upper and lower bounds of industry profitability, respectively. In written 

comments, NEMA contended that DOE had inappropriately discounted the likelihood of the 

lower-bound scenario occurring when it stated its belief that design changes necessary for TSL 5 

would not force all manufacturers to significantly redesign all of their polyphase small electric 

motors and production processes. (NEMA, No. 24 at p. 16) 

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In response, DOE first clarifies that it did not and is not assigning probabilities to the 

preservation of operating profit scenario or the preservation of return on invested capital 

scenario. The two markup scenarios are meant to estimate the range of potential impacts. 

Second, in the NOPR, and for this final rule, DOE accounted for equal investments in the GRIM 

under both the lower and upper bound profitability scenarios. Therefore, changes in markup 

assumptions—not changes in investments—drive the profitability difference between the 

scenarios. For example, in this final rule DOE assumes industry wide capital conversion 

investments for TSL 5 of approximately $7.1 million for polyphase small motors in each markup 

scenario. Thus, the likelihood of either scenario occurring with respect to the other is 

independent of the investment level assumed in the GRIM. 

NEMA further argued that in discounting the likelihood of the lower-bound profitability 

scenario, DOE ignored cost increases and equipment investments associated with specialty steels 

and copper rotors necessary for polyphase motors to meet TSL 5. (NEMA, No. 24 at p.16). 

DOE disagrees with NEMA’s suggestion that TSL 5 requires copper rotors and premium 

electrical steels (such as Hiperco) for polyphase motor designs. DOE continues to believe, as 

discussed in the Engineering Analysis, that both space-constrained and non-space constrained 

motors can achieve TSL 5 through the use of additional laminations. As discussed above, DOE 

included the attendant costs of the additional lams, steel-grade lam dies, end ring investment for 

both space constrained and non-space constrained motors, and a crimping tool. No investments 

for copper rotors design were assumed at TSL 5 for polyphase motors. NEMA ostensibly agreed 

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that the proposed TSL did not require copper rotors when it commented that the “proposed 

standards for polyphase and CSCR small electric motors are based on the use of cast aluminum 

rotors.” (NEMA, No. 24 at p. 18) 

Baldor and NEMA stated that the proposed levels of efficiency in the NOPR are based on 

the assumption that manufacturers must use three different types of electrical steel including 

24M19, 29M15, and Hiperco 50. According to NEMA, each type of electrical steel requires 

different methods for processing the rolled steel into laminations acceptable for use in electric 

motors. NEMA further adds that to remain competitive, manufacturers must minimize the 

number of different types of materials and processes used in a manufacturing facility and 

suggested that DOE adopt a standard level that is achievable with the same electrical steel for all 

motor categories. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 246-47; NEMA, No. 24 at 

p.17. 

In the NOPR, DOE predicted that manufacturers would achieve the proposed efficiency 

levels with three types of steels including 24M19, 29M15, and Hiperco 50. During manufacturer 

interviews, DOE requested information on the type of processes needed to achieve each 

efficiency level, as well as the costs associated with each process. In regards to types of steel 

used and the cost of switching from one steel process to another, all interviewed manufacturers 

reported the use of additional lamination dies to accommodate the different thickness of steel. 

Accordingly, DOE included additional lamination dies per manufacturer in its estimates 

whenever a change of steel grade was applicable, as described in chapter 12 of the TSD. The cost 

per die was derived based on manufacturer’s estimates and information provide by industry 

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experts. See chapter 12 of the TSD for additional details on each type of investment at each 


efficiency level including all design options analyzed. DOE acknowledges that manufacturers in 

general, regardless of industry, reduce the number of manufacturing processes to lower costs and 

thus increase margins. For today’s amended standards, DOE does not prescribe designs nor how 

manufacturers achieve each efficiency level. Because DOE accounts for all the relevant costs 

associated with using the various steel types in both the engineering analysis and MIA, it 

believes it accurately captures the potential costs to manufacturers in using different steel grades. 

Therefore, DOE believes that potential burden on manufacturers has been accounted for in 

today’s final rule. 

In response to the NOPR, NEMA commented that manufacturers are not aware of any 

other pathways to achieving the proposed efficiencies for space constrained CSIR motors but the 

ones analyzed in this rulemaking. NEMA argued that because there are no other pathways to 

achieving the proposed efficiencies, DOE is dictating that manufacturers use different electrical 

steels and different materials for the rotor construction in order to meet the proposed efficiencies 

for the three motor types. (NEMA, No. 24 at p.16). 

DOE acknowledges that TSL 7 reflects the max-tech efficiency levels for CSIR; as such, 

DOE estimates manufacturers may have to employ both copper rotors and premium electrical 

steels to achieve that level. In the engineering analysis, which subsequently carries over to the 

MIA, DOE models a pathway for space-constrained and non-space constrained application 

motors with the use of these technologies. However, in setting new standards for small electric 

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motors, as described in today’s notice, DOE selects efficiency levels for each motor category and 


does not prescribe designs. 

4. Premium Electrical Steels 

In response to the NOPR, Regal-Beloit and NEMA argue that DOE proposed an 

efficiency level for motors that would force manufacturers to utilize specific electrical steels that 

are in scarce supply. NEMA further argues that DOE should not establish standards that require 

manufacturers to use materials that are supply constrained. NEMA stated that a market analysis 

for the scarce materials is needed to prove otherwise. (Regal-Beloit, Public Meeting Transcript, 

No. 20.4 at pp. 245-46; NEMA, No. 24 at pp.17-18). Similarly, NEMA asked DOE to consider 

any spillover effects on the supply of steel for medium electric motors. (NEMA, No. 24 at p.18) 

DOE acknowledges the concern that Hiperco may be supply constrained in the short run 

should manufacturers pursue that design option. As such, to investigate these steel concerns, 

DOE contacted Hiperco 50 steel and other premium electrical steel suppliers and used steel 

manufacturer’s annual reports to examine past shipment volumes of premium steels. DOE then 

compared estimated shipments of these steel to volumes that would be necessary for motors if 

should the base case mix of space constrained and non space constrained persist at all TSLs. 

Based on that analysis, DOE estimates that the entire small electric motor industry would need 

approximately 1.3 million pounds of premium steels (such as Hiperco) in 2015 for the level 

established by this rule. For the steel manufacturer that had available annual reports, the 

estimated pounds of premium steels needed by the motor manufacturers constitutes less than one 

percent of total steel shipments for 2008. How much of that volume reflects premium steels is 

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not publically available. However, annual reports for the publicly traded manufacturer of
 

premium steels suggest that shipments of these steels have decreased by close to 20 percent from 

the previous year, suggesting this manufacturer has over capacity and the ability to meet the 

possible increase in demand of premium steels. Given the time lag for the market to prepare for 

the compliance date of the standard and the low volumes of motors that may require premium 

steel, DOE believes that the proposed standard level will not threaten the supply of the steel, 

even if manufacturers decide to pursue this option. DOE's analysis does not forecast shipments 

of motors that require premium steel and, as a result, DOE does not believe that, based on the 

available data, there will be a significant impact (“spillover”) on the medium motor market due 

to higher demand of the material in the small motor market. 

NEMA stated that the proposed efficiency level mandates the use of copper rotor casting 

technology along with aluminum rotor casting technology in the same manufacturing facilities. 

NEMA argued that copper rotor casting technology is in its infancy and is not a fully developed 

process that can be adapted in all present facilities where small electric motors are built. 

Additionally, NEMA and A.O. Smith are concerned that copper rotor casting technology has 

significant safety issues related to the high temperatures needed for the process. According to 

NEMA, manufacturers may be required to use a few outside companies that may not have 

sufficient capacity to meet all of the copper rotor volume required to meet the needs for all of the 

CSIR small electric motors. Additionally, NEMA argues that standards must be based on the use 

of aluminum rotors only. (A.O. Smith, No. 26 at p. 2; NEMA, No. 24 at p. 18). 

DOE acknowledges manufacturers’ concerns related to the processes for die-casting copper 

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rotors. In its analysis, DOE accounted for the increased capital requirements as they would 


likely occur depending on the efficiency level and motor type at issue. As stated in the NOPR, 

the use of copper rotors could lead manufacturers to outsource their die-casting processes, as 

indicated by NEMA in its comments. (74 FR 61467-68). Ultimately, this is a business decision. 

In its engineering analysis for this rulemaking, DOE included a copper rotor design at efficiency 

level 6 or above for polyphase motors, efficiency level 5 or above for CSIR motors, and 

efficiency level 4 or above for CSCR motors. The inclusion of copper rotor designs at each 

efficiency level varies depending on the necessary efficiency and space constraints. However, 

DOE reiterates that different manufacturers will not necessarily employ the same design options 

to make their motors achieve higher efficiency levels where DOE estimates copper rotors may be 

used, with the exception of the max-tech efficiency levels. In fact, for the NOPR and today’s 

final rule, DOE has analyzed motors up to efficiency level 5 for CSIR motors and efficiency 

level 6 for CSCR motors that use an aluminum die-cast rotor. 

J. Employment Impact Analysis 

DOE considers employment impacts in the domestic economy as one factor in selecting a 

proposed standard. Employment impacts include direct and indirect impacts. Direct employment 

impacts are changes in the number of employees for manufacturers of equipment subject to 

standards, their suppliers, and related service firms. The MIA addresses these impacts. 

Indirect employment impacts from standards consist of the net 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 (electricity, gas (including liquefied petroleum gas), 

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and oil); (2) reduced spending on new energy supply by the utility industry; (3) increased 


spending on the purchase price of new equipment; and (4) the effects of those three factors 

throughout the economy. DOE expects the net monetary savings from standards to be redirected 

to other forms of economic activity. DOE also expects these shifts in spending and economic 

activity to affect the demand for labor in the short term, as explained below. 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare employment statistics in different economic sectors, which are 

compiled and published by the Bureau of Labor Statistics (BLS). The 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 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 labor intensive than other sectors. (See Bureau of Economic 

Analysis, Regional Multipliers: A User Handbook for the Regional Input-Output Modeling 

System (RIMS II), Washington, DC, U.S. Department of Commerce, 1992.) Efficiency 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 manufacturing sectors). Thus, 

based on the BLS data alone, DOE believes net national employment will increase due to shifts 

in economic activity resulting from standards for small electric motors. 

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In developing the NOPR, DOE estimated indirect national employment impacts using an 

input/output model of the U.S. economy called Impact of Sector Energy Technologies 

(ImSET).16 ImSET is a special-purpose version of the “U.S. Benchmark National Input-Output” 

(I-O) model designed to estimate the national employment and income effects of energy-saving 

technologies. The ImSET software includes a computer-based I-O model with structural 

coefficients to characterize economic flows among 188 sectors most relevant to industrial, 

commercial, and residential building energy use. For today’s final rule, DOE has made no 

change to its method for estimating employment impacts. For further details, see chapter 15 of 

the final rule TSD. 

K. Utility Impact Analysis 

The utility impact analysis estimates the change in the forecasted power generation 

capacity for the Nation that would be expected to result from adoption of new standards. For the 

NOPR and today’s final rule, DOE calculated this change using the NEMS-BT computer model. 

NEMS-BT models certain policy scenarios such as the effect of reduced energy consumption by 

fuel type. The analysis output provides a forecast for the needed generation capacities at each 

TSL. While DOE was able to use the forecasts from the AEO 2010 Early Release for energy 

prices and macroeconomic indicators, the NEMS-BT model corresponding to this case is not yet 

available. The estimated net benefit of the standard in today’s final rule is the difference between 

the forecasted generation capacities by NEMS-BT and the AEO 2009 April Release Reference 

Case. DOE obtained the energy savings inputs associated with efficiency improvements to small 

electric motors from the NIA. These inputs reflect the effects of both fuel (natural gas) and 

16 More information regarding ImSET is available online at: 

www.pnl.gov/main/publications/external/technical_reports/PNNL-15273.pdf 

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electricity consumption savings. Chapter 14 of the final rule TSD presents results of the utility
 

impact analysis. 

NEEA/NPCC claimed that only a small fraction of the total costs of avoided generation 

are currently counted in any rulemaking. They note that DOE uses the NEMS-BT model to 

calculate the avoided generation facilities produced by a standard and that the cost of 

construction and operation of these plants are rolled into average rates that all electricity 

consumers must pay, not just those purchasing the product in question. As a result, they believe 

that the NPV difference in the value of total electricity sales between the NEMS-BT forecasts 

with and without the standards may serve as a reasonable proxy for the economic value to all 

electricity consumers of the proposed standards. The difference value of total retail electricity 

sales is necessary to capture all of the cost of the avoided generation, since as noted above, users 

of small general purpose motors impacted by the standard will pay only a portion of those cost at 

embedded rates. (NEEA/NPPC, No. 27, p. 7-8) 

DOE investigated the possibility of estimating the impact of specific standard levels on 

electricity prices in its rulemaking for general service fluorescent lamps and incandescent 

reflector lamps. (See U.S. Department of Energy—Office of Energy Efficiency and Renewable 

Energy: Energy Conservation Standards for General Service Fluorescent Lamps and 

Incandescent Reflector Lamps; Proposed Rule, 74 FR 16920, 16978–979 (April 13, 2009).) It 

concluded that caution is warranted in reporting impacts of appliance standards on electricity 

prices due to the complexity of the power industry (including the variety of utility regulation in 

the U.S.) and the relatively small impact of equipment efficiency standards on demand. In 

addition, electricity price reductions cannot be viewed as equivalent to societal benefits because 

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part of the price reductions result from transfers from producers to consumers. The electric 


power industry is a complex mix of fuel suppliers, producers, and distributors. While the 

distribution of electricity is regulated everywhere, its institutional structure varies, and upstream 

components are complex. Because of the difficulty in accurately estimating electricity price 

impacts, and the uncertainty with respect to transfers from producers to consumers, DOE did not 

estimate the value of potentially reduced electricity costs for all consumers associated with 

standards for small electric motors. 

L. Environmental Assessment 

Pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et 

seq.) 42 U.S.C. 6295(o)(2)(B)(i)(VI), DOE prepared a draft environmental assessment (EA) of 

the potential impacts of the standards for small electric motors in today’s final rule, which it has 

included as chapter 15 of the TSD. DOE found that the environmental effects associated with 

the standards for small electric motors were not significant. Therefore, DOE is issuing a Finding 

of No Significant Impact (FONSI), pursuant to NEPA, the regulations of the Council on 

Environmental Quality (40 CFR parts 1500–1508), and DOE’s regulations for compliance with 

NEPA (10 CFR part 1021). The FONSI is available in the docket for this rulemaking. 

In the EA, DOE estimated the reduction in power sector emissions of CO2, NOx, and Hg 

using the NEMS-BT computer model. In the EA, NEMS-BT is run similarly to the AEO NEMS, 

except that small electric motor energy use is reduced by the amount of energy saved (by fuel 

type) due to the TSLs. The inputs of national energy savings come from the NIA analysis; the 

output is the forecasted physical emissions. The estimated net benefit of the standard in today’s 

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final rule is the difference between the forecasted emissions by NEMS-BT at each TSL and the 


AEO 2009 April Early Release Reference Case. NEMS-BT tracks CO2 emissions using a 

detailed module that provides results with broad coverage of all sectors and inclusion of 

interactive effects. 

DOE has determined that sulfur dioxide (SO2) emissions from affected Electric 

Generating Units (EGUs) are subject to nationwide and regional emissions cap and trading 

programs that create uncertainty about the impact of energy conservation standards on SO2 

emissions. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for all affected 

EGUs. SO2 emissions from 28 eastern States and the District of Columbia (D.C.) are also limited 

under the Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005; 

70 FR 25162 (May 12, 2005), which creates an allowance-based trading program that will 

gradually replace the Title IV program in those States and D.C. (The recent legal history 

surrounding CAIR is discussed below.) The attainment of the emissions caps is flexible among 

EGUs and is enforced through the use of emissions allowances and tradable permits. Energy 

conservation standards could lead EGUs to trade allowances and increase SO2 emissions that 

offset some or all SO2 emissions reductions attributable to the standard. DOE is not certain that 

there will be reduced overall SO2 emissions from the standards. The NEMS-BT modeling system 

that DOE uses to forecast emissions reductions currently indicates that no physical reductions in 

power sector emissions would occur for SO2. The above considerations prevent DOE from 

estimating SO2 reductions from standards at this time. 

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Even though DOE is not certain that there will be reduced overall emissions from the 

standard, there may be an economic benefit from reduced demand for SO2 emission allowances. 

Electricity savings from standards decrease the generation of SO2 emissions from power 

production, which can lessen the need to purchase emissions allowance credits, and thereby 

decrease the costs of complying with regulatory caps on emissions. 

Much like SO2 emissions, NOx emissions from 28 eastern States and the District of 

Columbia (D.C.) are limited under the CAIR. Although CAIR has been remanded to EPA by the 

U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), it will remain in effect 

until it is replaced by a rule consistent with the Court’s July 11, 2008, opinion in North Carolina 

v. EPA. 531 F.3d 896 (D.C. Cir. 2008); see also North Carolina v. EPA, 550 F.3d 1176 (D.C. 

Cir. 2008). These court positions were taken into account in the analysis conducted for the 

NOPR and in today’s final rule. Because all States covered by CAIR opted to reduce NOx 

emissions through participation in cap and trade programs for electric generating units, emissions 

from these sources are capped across the CAIR region. 

In the 28 eastern States and D.C. where CAIR is in effect, DOE’s forecasts indicate that 

no NOx emissions reductions will occur due to energy conservation standards because of the 

permanent cap. Energy conservation standards have the potential to produce an economic impact 

in the form of lower prices for NOx emissions allowances, if their impact on electricity demand 

is large enough. However, DOE has concluded that the standards in today’s final rule will not 

have such an effect because the estimated reduction in electricity demand in States covered by 

the CAIR cap would be too small to affect allowance prices for NOx under the CAIR. 

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New or amended energy conservation standards would reduce NOx emissions in those 22 

States that are not affected by the CAIR. DOE used the NEMS-BT to forecast emission 

reductions from the small electric motor standards in today’s final rule. 

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. The Clean Air Mercury Rule (CAMR) would have permanently capped 

emissions of mercury from new and existing coal-fired plants in all States beginning in 2010 (70 

FR 28606). However, the CAMR was vacated by the D.C. Circuit in its decision in New Jersey 

v. Environmental Protection Agency, 517 F 3d 574 (D.C. Cir. 2008) Thus, DOE was able to use 

the NEMS-BT model to estimate the changes in Hg emissions resulting from the proposed rule. 

NEMA noted that the TSD for the NOPR provides a qualitative assessment of upstream 

emissions (i.e., emissions from energy losses during coal and natural gas production) in addition 

to quantifying the emissions at power plants. NEMA states that if DOE is making an assessment 

of upstream emissions, it should also account for the emissions related to the construction of 

more efficient small electric motors, such as those related to the mining of additional raw 

materials, processing of the additional materials, transportation of the additional materials, and 

the manufacture of the motor itself. (NEMA, No. 24 at p. 22) 

As noted in the TSD for the NOPR, DOE developed qualitative estimates of affects on 

upstream fuel-cycle emissions because NEMS-BT does a thorough accounting only of emissions 

at the power plant due to downstream energy consumption. In other words, NEMS-BT does not 

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account for upstream emissions. Therefore, the Environmental Assessment for today’s final rule 


reports only power plant emissions. 

When setting performance standards for industrial equipment, EPCA prescribes that an 

energy efficiency standard be a minimum level of energy efficiency or maximum allowable 

energy use. EPCA defines the term "energy use" within this limited context for commercial and 

industrial equipment as being the quantity of energy directly consumed by an article of industrial 

equipment at the point of use. See 42 U.S.C. 6311(4). In ascertaining the appropriate level of 

efficiency, DOE must balance seven criteria to develop a standard that is economically justified 

and technically feasible. While DOE believes that the majority of the energy and other costs 

associated with the manufacturing of more efficient motors are reflected in its analysis, some of 

the costs associated with certain environmental impacts and other externalities are not 

incorporated. Even though DOE estimates and considers the impacts of standards on the energy 

and emissions associated with electricity generation, it does not specifically assess the energy 

and emissions associated with the manufacturing of more efficient motors or the manufacturing 

of the equipment required to produce and supply energy. The main reason for not assessing 

such indirect costs and benefits is the absence of a reliable and comprehensive method of doing 

so. Such an assessment would require accounting for a variety of variables, including the energy 

required to build and service the energy production, generation, and transmission infrastructure 

needed to deliver the energy, as well as accounting for the energy expended to manufacture 

energy-using equipment. 

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M. Monetizing Carbon Dioxide and Other Emissions Impacts
 

As part the development of this final rule, DOE considered the estimated monetary 

benefits likely to result from the reduced emissions of CO2 and other pollutants that are expected 

to result from each of the Trial Standard Levels considered. This section summarizes the basis 

for the estimated monetary values used for each of these emissions and presents the benefits 

estimates considered. 

For today’s final rule, DOE is relying on a new set of values for the social cost of carbon 

SCC that were recently developed by an interagency process. A summary of the basis for these 

new values is provided below, and a more detailed description of the methodologies used is 

provided as an Annex to Chapter 15 of the Technical Support Document. 

1. Social Cost of Carbon 

Under Executive Order 12866, agencies are required, to the extent permitted by law, “to 

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 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. 

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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 increased flood 

risk, and the value of ecosystem services due to climate change. 

As part of the interagency process that developed these 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 economic literatures. In this way, key 

uncertainties and model differences transparently and consistently inform the range of SCC 

estimates used in the rulemaking process. 

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

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

of 2.5, 3, and 5 percent. The fourth value, 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. 

Table IV.19 Social Cost of CO2, 2010 – 2050 (in 2007 dollars) 

Discount 5% 3% 2.5% 3% 

Year Avg Avg Avg 95th 

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 

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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 

a. Monetizing Carbon Dioxide Emissions 

The “social cost of carbon” (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 

increased flood risk, and the value of ecosystem services. Estimates of the social cost of carbon 

are provided in dollars per metric ton of carbon dioxide. 17 

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 

Academies of Science (Hidden Costs of Energy: Unpriced Consequences of Energy Production 

and Use. National Academies Press. 2009) 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. 

17 In this document, DOE presents all values of the SCC as the cost per metric ton of CO2 emissions. Alternatively, 

one could report the SCC as the cost per metric ton of carbon emissions. The multiplier for translating between mass 

of CO2 and the mass of carbon is 3.67 (the molecular weight of CO2 divided by the molecular weight of carbon = 

44/12 = 3.67). 

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Despite the serious limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing carbon dioxide emissions. Under Executive 

Order 12866, agencies are required, to the extent permitted by law, “to 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 

make it possible for agencies to incorporate the social benefits from reducing carbon dioxide 

emissions into cost-benefit analyses of regulatory actions that have small, or “marginal,” impacts 

on cumulative global emissions. Most federal regulatory actions can be expected to have 

marginal impacts on global emissions. 

For such policies, the benefits from reduced (or costs from increased) emissions in any 

future year can be estimated 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 each of these 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 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; we do not attempt to answer that question here. 

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An interagency group convened on a regular basis to consider public comments, explore 


the technical literature in relevant fields, and discuss key inputs and assumptions in order to 

generate SCC estimates. Agencies that actively participated in the interagency process include 

the Environmental Protection Agency, and the Departments of Agriculture, Commerce, Energy, 

Transportation, and Treasury. This process was convened by the Council of Economic Advisers 

and the Office of Management and Budget, with active participation and regular input from the 

Council on Environmental Quality, National Economic Council, Office of Energy and Climate 

Change, and Office of Science and Technology Policy. The main objective of this process was 

to develop a range of SCC values using a defensible set of input assumptions that are grounded 

in the existing literature. In this way, key uncertainties and model differences can more 

transparently and consistently inform the range of SCC estimates used in the rulemaking process. 

The interagency group selected four SCC estimates for use in regulatory analyses. For 

2010, these estimates are $5, $21, $35, and $65 (in 2007 dollars). The first three estimates are 

based on the average SCC across models and socio-economic and emissions scenarios at the 5, 3, 

and 2.5 percent discount rates, respectively. The fourth value is included to represent the higherthan-expected impacts from temperature change further out in the tails of the SCC distribution. 

For this purpose, we use the SCC value for the 95th percentile at a 3 percent discount rate. The 

central value is the average SCC across models at the 3 percent discount rate. For purposes of 

capturing the uncertainties involved in regulatory impact analysis, we emphasize the importance 

and value of considering the full range. These SCC estimates also grow over time. For instance, 

the central value increases to $24 per ton of CO2 in 2015 and $26 per ton of CO2 in 2020. See 

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Appendix A of the Annex to Chapter 15 of the Technical Support Document for the full range of 


annual SCC estimates from 2010 to 2050. 

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. Specifically, we have set a preliminary goal of revisiting the SCC 

values within two years or at such time as substantially updated models become available, and to 

continue to support research in this area. In the meantime, we 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 

To date, 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 Department of Transportation (DOT) used both a “domestic” SCC value of 

$2 per ton of CO2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission reductions 

(in 2007 dollars), increasing both values at 2.4 percent per year. It also included a sensitivity 

analysis at $80 per ton of CO2. 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. 

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton CO2 

(in 2006 dollars) for 2011 emission reductions (with a range of $0-$14 for sensitivity analysis), 

also increasing at 2.4 percent per year. A regulation finalized by DOE in October of 2008 used a 

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domestic SCC range of $0 to $20 per ton CO2 for 2007 emission reductions (in 2007 dollars). In 

addition, EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified 

what it described as “very preliminary” SCC estimates subject to revision. EPA’s global mean 

values were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 

percent, respectively (in 2006 dollars 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 dollars) of $55, $33, $19, $10, and $5 per 

ton of CO2. The $33 and $5 values represented model-weighted means of the published 

estimates produced from the most recently available versions of three integrated assessment 

models—DICE, PAGE, and FUND—at approximately 3 and 5 percent discount rates. The $55 

and $10 values were derived by adjusting the published estimates for uncertainty in the discount 

rate (using factors developed by Newell and Pizer (2003)) at 3 and 5 percent discount rates, 

respectively. The $19 value was chosen as a central value between the $5 and $33 per ton 

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estimates. All of these values were assumed to increase at 3 percent annually to represent 

growth in incremental damages over time as the magnitude of climate change increases. 

These interim values represent the first sustained interagency effort within the U.S. 

government to develop an SCC for use in regulatory analysis. The results of this preliminary 

effort were presented in several proposed and final rules and were offered for public comment in 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2 tailpipe 

emission proposed rules. 

c. Approach and Key Assumptions 

Since the release of the interim values, interagency group reconvened on a regular basis 

to generate improved SCC estimates considered for this final rule. Specifically, the group 

considered public comments and further explored the technical literature in relevant fields. 

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 Academy of Science (2009) 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 agencies participating in the 

interagency process to estimate the SCC. 

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The U.S. Government will periodically review and reconsider estimates of the SCC used 

for cost-benefit analyses to reflect increasing knowledge of the science and economics of climate 

impacts, as well as improvements in modeling. In this context, statements recognizing the 

limitations of the analysis and calling for further research take on exceptional significance. The 

interagency group offers the new SCC values with all due humility about the uncertainties 

embedded in them and with a sincere promise to continue work to improve them. 

In summary, in considering the potential global benefits resulting from reduced CO2 

emissions, DOE used the most recent values identified by the interagency process, adjusted to 

2009$ using the standard GDP deflator values for 2008 and 2009. For each of the four cases 

specified, the values for emissions in 2010 used were approximately $5, $22, $36, and $67 per 

metric ton avoided (values expressed in 2009$). To monetize the CO2 emissions reductions 

expected to result from amended standards for small electric motors in 2015–2045, DOE used 

the values identified in Table A1 of the “Social Cost of Carbon for Regulatory Impact Analysis 

Under Executive Order 12866,” which is reprinted as an Annex to Chapter 15 of the Technical 

Support Document, appropriately escalated to 2009$. 

2. Monetary Values of Non-Carbon Emissions 

As previously stated, DOE’s analysis assumed the presence of nationwide emission caps 

on SO2 and caps on NOx emissions in the 28 States covered by CAIR. In the presence of these 

caps, the NEMS-BT modeling system that DOE used to forecast emissions reduction indicated 

that no physical reductions in power sector emissions would occur (although there remains 

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uncertainty about whether physical reduction of SO2 will occur), but that the standards could put 

slight downward pressure on the prices of emissions allowances in cap-and-trade markets. 

Estimating this effect is very difficult because of factors such as credit banking can change the 

trajectory of prices. From its modeling to date, DOE is unable to estimate a benefit from energy 

conservation standards on the prices of emissions allowances at this time. See the environmental 

assessment in the final rule TSD for further details. 

DOE also investigated the potential monetary benefit of reduced NOx and Hg emissions 

from the TSLs it considered. As noted above, new or amended energy conservation standards 

would reduce NOx emissions in those 22 States that are not affected by CAIR, in addition to the 

reduction in site NOx emissions nationwide. DOE estimated the monetized value of NOx 

emissions reductions resulting from each of the TSLs considered for today’s final rule based on 

environmental damage estimates from the literature. Available estimates suggest a very wide 

range of monetary values for NOx emissions, ranging from $370 per ton to $3,800 per ton of 

NOx from stationary sources, measured in 2001$ (equivalent to a range of $447 to $4,591 per ton 

in 2009$). Refer to the OMB, 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, for additional information. 

For Hg emissions reductions, DOE estimated the national monetized values resulting 

from the TSLs considered for today’s rule based on environmental damage estimates from the 

literature. The impact of mercury emissions from power plants on humans is considered highly 

uncertain. However, DOE identified two estimates of the environmental damage of Hg based on 

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estimates of the adverse impact of childhood exposure to methyl mercury on IQ for American 


children, and subsequent loss of lifetime economic productivity resulting from these IQ losses. 

The high-end estimate of $1.3 billion per year in 2000$ (which works out to $33.7 million per 

ton emitted per year in 2009$) is based on an estimate of the current aggregate cost of the loss of 

IQ in American children that results from exposure to Hg of U.S. power plant origin.18 DOE’s 

low-end estimate of $0.66 million per ton emitted in 2004$ ($0.764 million per ton in 2008$) 

was derived from an evaluation of mercury control that used different methods and assumptions 

from the first study, but was also based on the present value of the lifetime earnings of children 

exposed to Hg.19 

V. Discussion of Other Comments 

Since DOE opened the docket for this rulemaking, it has received more than 20 

comments from a diverse set of parties, including manufacturers and their representatives, States, 

energy conservation advocates, and electric utilities section IV of this preamble discusses 

comments DOE received on the analytical methodologies it has used in this rulemaking. 

Additional comments DOE received in response to the NOPR addressed the information DOE 

used in its analyses, results of and inferences drawn from the analyses, impacts of standards, the 

merits of the different TSLs and standards options DOE considered, other issues affecting 

adoption of standards for small electric motors, and the DOE rulemaking process. DOE 

addresses these comments below. 

18 Trasande, L., et al., “Applying Cost Analyses to Drive Policy that Protects Children,” 1076 Ann. N.Y. Acad. Sci. 

911 (2006). 19 Ted Gayer and Robert Hahn, “Designing Environmental Policy: Lessons from the Regulation of Mercury 

Emissions,” Regulatory Analysis 05–01, AEI-Brookings Joint Center for Regulatory Studies, Washington, DC 

(2004). A version of this paper was published in the Journal of Regulatory Economics in 2006. The estimate was 

derived by back-calculating the annual benefits per ton from the net present value of benefits reported in the 

study. 

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A. Trial Standard Levels 

In selecting the proposed energy conservation standards for both classes of small electric 

motors for consideration in today’s final rule, DOE started by examining the standard levels with 

the highest energy savings, and determined whether those levels were economically justified. If 

DOE found those levels not to be justified, DOE considered TSLs sequentially lower in energy 

savings until it reached the level with the greatest energy savings that was both technologically 

feasible and economically justified. In the NOPR document, DOE proposed TSL 5 for 

polyphase motors and TSL 7 for single-phase motors. 

Emerson commented that while it is in favor of efficiency standards in general, it is not in 

favor of the proposed standards for small electric motors. This is because it diverts a 

manufacturer’s attention and funding away from other energy efficient technologies that it is 

developing, which are actually being used to replace these covered motors. In its written 

comments, Emerson asked that DOE not regulate small electric motors. (Emerson, Public 

Meeting Transcript, No. 20.4 at pp. 267-69; Emerson, No. 28 at p.3) Underwriters Laboratories 

(UL) submitted written comments stating that over the past five years the majority of fractional 

horsepower motors it has seen have been electronically commutated motors (ECM), which reach 

efficiency levels in the high 90 percent range. However, UL continued on to state that DOE 

should not set efficiency levels for the covered motors that reinforce the status quo, but rather 

encourage greater efficiency, which it states the proposed standard levels would not achieve. 

(UL, No. 21 at pp. 1-2) QM Power added that high standards would cause alternative 

technologies to be sold in higher volumes and as a result bring their relative prices down. (QM 

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Power, Public Meeting Transcript, No. 20.4 at pp. 290-91) Finally, a joint comment submitted by
 

PG&E, SCE, SCGC, and SDGE indicated support for the standard levels chosen by DOE in the 

NOPR phase. (Joint Comment, No. 23 at p. 2) 

DOE notes that it is legally required to issue standards for small electric motors and 

reiterates that it selects the standard level with the highest energy savings that is both 

technologically feasible and economically justified. The standards set in today’s final rule 

represent the efficiency level with the greatest energy savings that is both technologically 

feasible and economically justified. While other classes of motors, such as electronically 

commutated motors (ECMs) may offer higher efficiency levels than the levels selected by DOE 

in today’s rulemaking, DOE must consider and evaluate the covered motors when selecting 

efficiency levels. 

NEMA commented that a statement in the NOPR indicated that the proposed polyphase 

standard was closely aligned with the EPACT 1992 efficiency levels. NEMA was confused by 

this statement because the levels proposed in the NOPR were greater than the EPACT 1992 

levels. (NEMA, No. 24 at p. 22) NEMA also stated that the NOPR indicates “TSL 7 

corresponds to the NEMA Premium equivalent efficiency for CSCR motors,” (74 FR 61469) but 

that there is no defined level of NEMA Premium efficiency for any 3⁄4-horsepower, four-pole 

motor. (NEMA, No. 24 at p. 24) 

DOE would like to clarify these statements. In the NOPR, DOE stated “DOE proposes a 

standard for polyphase small motors... that is closely aligned with the EPACT 1992 standard for 

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medium motors.” 74 FR 61419-20. This text should have read that DOE proposed efficiency 

levels (TSL 5) for polyphase small electric motors are closely aligned with the NEMA Premium 

efficiency levels for 1-horsepower, four pole medium electric motors. This statement was 

restated and asserted at other times throughout the NOPR document and DOE regrets any 

confusion it may have caused. 

In this final rule, due to revisions in the baseline efficiencies, modeling of higher 

efficiency motor designs, and scaling analysis, TSL 4b now most closely aligns with NEMA 

Premium efficiency levels (and medium electric motor standards) for motors greater than 1 

horsepower. DOE recognizes the value to manufacturers of having a single efficiency 

requirement for similar models of motors. Because some efficiency values associated with TSL 

4b are slightly higher than the NEMA Premium efficiency requirements, DOE is reducing these 

values to harmonize with NEMA Premium efficiency. DOE does not anticipate that this 

reduction will result in a significant loss of energy savings. For this reason, DOE is 

implementing this change after conducting its analyses and in the final stage of standard-setting. 

For further detail on the polyphase efficiencies analyzed for TSL 4b, see chapter 5 of the TSD. 

DOE also understands that NEMA Premium levels exist neither for any 3⁄4-horsepower, 

four-pole motors nor single-phase. DOE drew this comparison to NEMA Premium because 

manufacturers had recommended, during the preliminary analysis, that DOE examine such a 

standard level for its CSCR motor with the aforementioned ratings, and the manufacturers used 

that terminology when providing their recommendations to DOE. 

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In addition, Regal-Beloit and A.O. Smith commented that a CSCR motor should be able 


to generate a higher efficiency level than a comparable CSIR motor, but pointed out that DOE’s 

NOPR proposed efficiency levels would require CSIR motors to have higher efficiencies than 

corresponding CSCR motors. (Regal-Beloit, Public Meeting Transcript, No. 20.4 at pp. 107-08; 

A.O. Smith, Public Meeting Transcript, No. 20.4 at p. 108) NEMA also questioned the validity 

of DOE’s scaling analysis, citing the fact that the proposed CSIR levels were in fact slightly 

higher than the proposed CSCR levels. (NEMA, No. 24 at pp. 9-10) They added that though 

DOE indicated that the proposed efficiency levels for CSIR and CSCR were the same, they were 

not exactly equivalent. (NEMA, No. 24 at pp. 25-26) 

DOE would like to clarify that it was not alleging that CSCR motors cannot be as 

efficient as CSIR motors. DOE is aware that CSCR motors are inherently more efficient than 

CSIR motors, as indicated by the NOPR and final rule's max-tech efficiency levels for these two 

types of motors. DOE had proposed a standard level where the pairing of efficiency standards 

for both motor categories were approximately equivalent. DOE analyzed several TSLs for 

single-phase motors, some of which result in higher minimum efficiency requirements for CSCR 

motors than CSIR motors. However, as discussed in section VI.D, TSL 7, which adopt levels for 

CSIR and CSCR that are approximately equivalent, has been determined to the level that 

achieves the maximum energy savings, while being technologically feasible and economically 

justified. 

In consideration of the comments received regarding the exact equivalence of the CSIR 

and CSCR levels, DOE believes it appropriate to harmonize the levels of the two categories of 

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motors for the standard selected in today’s final rule. Because the TSL 7 represents the 


maximum technologically feasible level for CSIR motors, DOE has opted to lower these levels 

to equal the CSCR standard levels for TSL 7. DOE does not expect that this shift in CSIR motor 

efficiency will have a significant impact on the comparative economics or energy savings of the 

varying TSLs, and thus will not change the decision of which TSL to adopt. For this reason, 

DOE has decided to apply this efficiency shift at the standard-setting phase of the analyses. For 

further detail on the CSIR efficiencies analyzed for TSL 7, see chapter 5 of the TSD. 

B. Enforcement 

Thus far in the rulemaking process, DOE has not laid out any plans for the enforcement 

of efficiency standards for small electric motors. Typically, efficiency standard rulemakings do 

not outline a plan for enforcement, which occurs independently from the rulemaking process. 

DOE received a number of comments pertaining to the enforcement of today’s final rule 

and what steps DOE will take to enforce these efficiency standards. Regal-Beloit, A.O. Smith, 

and WEG all expressed the concern that some manufacturers, most notably from overseas, may 

not comply with the standards, and they wished to see a plan for how these standards would be 

enforced. (Regal-Beloit, Public Meeting Transcript, No. 20.4 at pp. 182-83; A.O. Smith, No. 26 

at p. 3; WEG, Public Meeting Transcript, No. 20.4 at pp. 261-66) A joint comment submitted by 

PG&E, SCE, SCGC, and SDGE also stressed the importance of developing a plan for 

enforcement. (Joint Comment, No. 23 at p. 2) Emerson agreed with the joint commenters that a 

lack of enforcement would put the domestic manufacturers who comply with today’s standard at 

a disadvantage in the marketplace because they would incur the costs necessary to increase 

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efficiency. (Joint Comment, No. 23 at p. 2; Emerson, No. 28 at p. 2) 


Additionally, DOE received comments offering suggestions for how to improve the 

enforcement of today’s rule. Both Regal-Beloit commented that DOE should require a marking 

on the motor to indicate that it complies with the efficiency standard, such as is done with 

NEMA Premium motors. (Regal-Beloit, Public Meeting Transcript, No. 20.4 at pp. 229-30) 

Regal-Beloit also suggested that DOE perform some sort of audit of the motors on the market to 

ensure compliance with today’s rule. (Regal-Beloit, Public Meeting Transcript, No. 20.4 at p. 

230) Finally, Earthjustice requested that today’s final rule outline a specific date on which DOE 

will layout plans for enforcement of the small electric motors standards. (Earthjustice, Public 

Meeting Transcript, No. 20.4 at pp. 20-21) 

NEMA’s written comment reiterated these concerns about enforcement, and outlined 

several steps DOE should take to ensure proper compliance. First, it recommended that DOE 

expand its present Compliance Certification number system that is used for electric motors to 

include small electric motors. Second, it recommended a means to notify DOE of potential 

violations. Third, it suggested maintaining a website that lists manufacturers and OEMs who 

have submitted compliance certificates. Fourth, it supported penalties for repeat violations of the 

law. Finally, it stressed the importance of securing the appropriate funds for implementing and 

maintaining an enforcement program. (NEMA, No. 24 at pp. 26-27) NEEA and NPCC also 

commented on the importance of appropriating funds for enforcement of today’s standards. 

(NEEA/NPCC, No. 27 at p. 7) 

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Additionally, NEMA’s written comment indicated that DOE must publish the small 

electric motors SNOPR soon in order for manufacturers to have sufficient time to ensure 

compliance with today’s standards. (NEMA, No. 24 at p. 25) 

DOE agrees that the plans for enforcing today’s final rule are very important, and 

appreciates the suggestions provided by manufacturers. While it is uncommon for a standard 

rulemaking to address issues of enforcement, DOE would like to highlight its intention to outline 

concrete steps for enforcing today’s efficiency standards. Given the numerous rulemakings that 

the agency must promulgate pursuant to its court consent decree and statutory requirements, 

DOE plans to issue this supplemental notice as expeditiously as possible to invite comment from 

interested parties and to ensure that the motor industry has sufficient time to adjust to any new 

provisions that DOE proposes. 

C. Nominal Full-Load Efficiency 

As discussed in section IV.C.2 of today’s final rule, it is common in the motor industry to 

observe variation in motor performance for a population of motors of identical designs, including 

tested efficiency. This variation can be due to variations in material quality, manufacturing 

processes, and even testing equipment. NEMA has established the term “nominal full-load 

efficiency” and uses the term for medium electric motors customers with a guaranteed efficiency 

given the variations in motor manufacturing and testing. As the tolerances due to manufacturing 

and testing variations guaranteed by NEMA’s definition of nominal full load efficiency are based 

on test procedures and data for medium electric motors, DOE elected to alter the definition in its 

NOPR and as it pertains to small electric motors. In the NOPR, DOE defined the term nominal 

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full-load efficiency as the arithmetic mean of the full load efficiency of a population of motors of 


duplicate design. 

At the NOPR public meeting, Baldor made several comments regarding DOE’s proposed 

definition for “nominal full-load efficiency” pertaining to small electric motors. First, Baldor 

commented that the proposed definition was too similar to the existing definition for “average 

full-load efficiency,” and that it differed from the definition in NEMA MG-1, which would 

create confusion for users. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 112, 126-27) 

Next, Baldor commented that the proposed definition provided no stipulation for what 

constitutes a population of motors, and suggested that the term be clarified. (Baldor, Public 

Meeting Transcript, No. 20.4 at pp. 112-13) These two comments were reiterated by NEMA in 

its written comments. (NEMA, No. 24 at pp. 10-16) Finally, Baldor commented that the 

proposed definition infers that the arithmetic mean of the full-load efficiencies of the population 

of motors is known and that the nominal full-load efficiency must be specified to be equal to the 

arithmetic mean, which would provide no limit to the number of different values of efficiency 

that might be marked on nameplates. As such, Baldor requested further clarification on the 

determination of any relationship between nominal full-load efficiency and calculated efficiency. 

(Baldor, Public Meeting Transcript, No. 20.4 at pp. 114, 125) 

Additionally, Baldor recommended improvements to DOE’s usage of nominal full-load 

efficiency. Baldor stated that the standard levels set by DOE should follow a pattern similar to 

the one already established in Table 12-6(a), which provides a logical sequence of numbers, and 

is familiar to motor users. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 129-31) Baldor 

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EERE-2007-BT-STD-0007 COMMENT 31
 

also pointed out that DOE is able to use the nominal values in Table 12-6(a) without using the 


minimum values, which are just provided for user information but not for compliance. (Baldor, 

Public Meeting Transcript, No. 20.4 at pp. 142-43) Again, NEMA supported these statements in 

its written comments. (NEMA, No. 24 at p. 14) Finally, Baldor and NEMA stated that DOE 

does not need to establish energy conservation standards in terms of nominal efficiency, but 

rather identify the characteristic of the efficiency value assigned to a motor to which a value in 

the table applies. (Baldor, Public Meeting Transcript, No. 20.4 at pp. 134-35; NEMA, No. 24 at 

pp. 15-16) 

DOE considered all of these comments when it established energy conservation standards 

for small electric motors in today’s final rule. DOE agrees with NEMA and Baldor that its 

energy efficiency standards are not mandated to be in terms of nominal full-load efficiency. 

Instead, DOE believes that nominal efficiency is an issue more related to certifying compliance. 

Therefore, DOE has elected to establish energy conservation standards in terms of average fullload efficiency. DOE will address comments related to nominal efficiency and propose 

provisions for certifying compliance with small electric motor energy efficiency standards in its 

supplemental test procedure NOPR for electric motors. 

VI. Analytical Results and Conclusions 

A.	 Trial Standard Levels 

DOE examined eight TSLs for polyphase small electric motors and eight for capacitorstart small motors. Table VI.1 and Table VI.2 present the TSLs and the corresponding 

efficiencies for the three representative product classes analyzed for today’s final rule. TSL 8 is 

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EERE-2007-BT-STD-0007 COMMENT 31
the max-tech efficiency level for the polyphase motors, and TSL 7 is the max-tech level for the 

capacitor-start motors. 

Table VI.1 Trial Standard Levels for Polyphase Small Electric Motors* 

Polyphase 

Four-pole 1­

horsepower 

% 

TSL 1 77.3 

TSL 2 78.3 

TSL 3 80.5 

TSL 4 81.1 

TSL 4b 83.5 

TSL 5 85.2 

TSL 6 86.2 

TSL 7 87.7 

* Standard levels are expressed in terms of full-load efficiency. 

DOE’s polyphase TSLs represent the increasing efficiency of the range of motors DOE 

modeled in its engineering analysis. DOE incorporated one additional TSL since the NOPR, 

which is the new TSL 4b. This TSL approximately aligns with the efficiency values proposed by 

NEMA in their written comments. 

TSLs 1, 2, and 3 represent incremental improvements in efficiency as a result of 

increasing the stack height and the slot fill percentage. TSL 4 represents the efficiency level 

possible by increasing stack height by 20 percent while maintaining the baseline steel grade and 

an aluminum rotor. TSL 4b approximately aligns with the efficiency levels proposed by NEMA 

in its written comment, and for the representative product class is comparable to the efficiency of 

a three-digit frame series medium electric motor that meets the efficiency requirements of EPCA. 

TSL 5 represents the highest efficiency value for a space-constrained design before switching to 

a copper rotor. TSL 6 represents a level at which DOE has reached the 20 percent limit of 

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EERE-2007-BT-STD-0007 COMMENT 31
increased stack height, increased grades of steel and included a copper die-cast rotor. Also, TSL
 

6 is comparable to the efficiency standard of a three-digit frame series medium electric motor 

that meets the NEMA Premium level, which Congress has set as an energy conservation standard 

for medium motors through section 313(b) of EISA 2007. At TSL 7, the max-tech efficiency 

level, for the restricted designs DOE has reached the design limit using the maximum increase in 

stack height of 20 percent and increased grades of steel. At this level, DOE has also implemented 

a premium steel type (Hiperco 50), a copper die-cast rotor, a maximum slot fill percentage of 

nearly 65 percent. For the lesser space-constrained design, DOE has decreased the stack height 

from the design used at TSL 6. This design incorporates a copper rotor while reaching the 

design limitation maximum slot fill percentage. 

Table VI.2 Trial Standard Levels for Capacitor-Start Small Electric Motors* 

Capacitor-Start, 

Induction-Run 

4-pole 0.50 horsepower 

motors 

(%) 

Capacitor-Start, 

Capacitor-Run 

4-pole 0.75 horsepower 

motors 

(%) 

TSL 1 70.5 (EL 4) 79.5 (EL 2) 

TSL 2 70.5 (EL 4) 81.7 (EL 3) 

TSL 3 71.8 (EL 5) 81.7 (EL 3) 

TSL 4 73.1 (EL 6) 82.8 (EL 4) 

TSL 5 73.1 (EL 6) 81.7 (EL 3) 

TSL 6 77.6 (EL 7) 87.9 (EL 8) 

TSL 7 77.6 (EL 7) 81.7 (EL 3) 

TSL 8 77.6 (EL 7) 86.7 (EL 7) 

* Standard levels are expressed in terms of full-load efficiency. 

Each TSL for capacitor-start small motors consists of a combination of efficiency levels 

for induction-run and capacitor-run motors. CSIR and CSCR motors are used in similar 

applications and generally can be used interchangeably provided the applications are not bound 

by strict space constraints and will allow the presence of a second capacitor housing of the 

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EERE-2007-BT-STD-0007 COMMENT 31
 

motor. DOE believes that the standards set by today’s rule will impact the relative market share
 

of CSIR and CSCR motors for general-purpose single-phase applications by changing the 

upfront cost of motors as well as their estimated losses. Section IV.G of this final rule and 

chapter 9 of the TSD describe DOE’s model of this market dynamic. 

DOE developed seven possible efficiency levels for CSIR motors and eight possible 

efficiency levels for CSCR motors. Rather than present all possible combinations of these 

efficiency levels, DOE chose a representative set of 8 TSLs that span the range from low energy 

savings to the maximum national energy savings. Because of the interaction between the CSIR 

and CSCR market share, there is no simple relationship between the combination of efficiency 

levels and the resulting energy savings. DOE’s capacitor-start cross-elasticity model was used to 

evaluate the impacts of each TSL on motor shipments in each product class. The model predicts 

that TSLs 1 through 5 result in relatively minor changes in product class market shares, while 

TSLs 6, 7, and 8 result in more significant changes. Uncertainties in the cross-elasticity model, 

and in the timescale of market share response to standards, lead to greater uncertainty in the 

national impacts of TSLs 6, 7, and 8, than with TSLs 1 through 5. A summary of results for all 

combinations of CSIR and CSCR efficiency levels is presented in chapter 10 of the TSD. 

TSL 1 is a combination consisting of the fourth efficiency level analyzed for CSIR 

motors and the second efficiency level for CSCR motors. This TSL uses similar engineering 

design options for both CSIR and CSCR motors and corresponds to an efficiency level roughly 

equivalent to the standards levels recommend for 42/48-frame-size CSIR motors and 56-frame 

size CSCR motors by NEMA. TSL 2 increases the efficiency level of the CSCR motor to the 

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EERE-2007-BT-STD-0007 COMMENT 31
third efficiency level, which corresponds to the minimum life-cycle cost. The efficiency level for 

the CSIR motor remains the same as in TSL 1. TSL 3 raises the CSIR efficiency level, which 

DOE's model meets by implementing a copper die-cast rotor, increasing slot fill, and reaching 

the 20 percent limit on increased stack height, or by doubling the original stack height and 

increasing slot fill. However, the CSCR efficiency level remains at the minimum LCC. 

TSLs 4 and 5 both show the same efficiency level for CSIR motors, but different 

efficiency levels for CSCR motors. To obtain the efficiency level for CSIR motors, DOE had to 

use either a copper rotor in combination with a thinner and higher grade of steel and a stack 

increase of 20 percent, or only a higher grade of steel with a stack exceeding a 20-percent 

increase but no longer than a 100-percent increase. The 82.2-percent efficiency level for CSCR 

motors in TSL 5 corresponds again to the same design and efficiency level for TSL 2 and 3. To 

achieve the 83.2-percent efficiency level for CSCR motors in TSL 4, DOE created designs with a 

20-percent increase in stack height and a higher grade of steel or used a copper rotor with a stack 

height above a 20-percent increase. TSL 4 represents the combination of the highest CSIR and 

CSCR levels that have more customers who benefit than customers who do not according to 

DOE’s LCC analysis. TSL 5 increases energy savings relative to TSL 4 because DOE anticipates 

there will be a greater CSCR market share, and the CSCR efficiency level again corresponds 

with the minimum LCC. 

TSL 6 represents max-tech efficiency levels for CSIR and CSCR motors, as determined 

by DOE’s engineering analysis; at this level CSCR motors are very expensive relative to CSIR 

motors, and DOE forecasts a nearly complete market shift to CSIR motors. TSLs 7 and 8 

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EERE-2007-BT-STD-0007 COMMENT 31
represent cases in which CSIR motors are, on average, very expensive relative to CSCR motors 


as a result of standards, and DOE forecasts near–to-complete market shifts to CSCR motors in 

both of its reference scenarios. Because CSCR motors are more efficient at these levels, national 

energy savings are increased beyond that of the max-tech efficiency level, TSL 6. TSL 7 pairs 

the max-tech efficiency requirements for CSIR motors with the minimum LCC efficiency level 

for CSCR motors, while TSL 8 pairs max-tech CSIR efficiency requirements with the secondhighest CSCR motor efficiency level that DOE analyzed. The ordering of TSLs 5, 6, 7, and 8, 

with respect to energy savings is robust in the face of uncertainties in the inputs to, and the 

parameters of, DOE’s cross-elasticity model. 

B. Significance of Energy Savings 

To estimate the energy savings through year 2045 from potential standards, DOE 

compared the energy consumption attributable to small electric motors under the base case (no 

new standards) to energy consumption attributable to this equipment under each standards case 

(each TSL that DOE has considered). Table VI.3 and Table VI.4 show DOE’s national energy 

savings estimates, which are based on the AEO 2010 Early Release, for each TSL for polyphase 

and capacitor-start small electric motors, respectively. Chapter 10 of the TSD describes these 

estimates in more detail. DOE reports both undiscounted and discounted values of energy 

savings. Discounted energy savings represent a policy perspective where energy savings farther 

in the future are less significant than energy savings closer to the present. 

Estimating the energy savings due to revised and new energy efficiency standards 

required DOE to compare the energy consumption of small electric motors under the base case to 

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EERE-2007-BT-STD-0007 COMMENT 31
energy consumption of these products under the trial standard levels. As described in section 


IV.G DOE used scaling relations for energy use and equipment price to extend its average 

energy use and price for representative product classes (analyzed in the LCC analysis) to all 

product classes, and then developed shipment-weighted sums to estimate the national energy 

savings. As described in section IV.G, DOE conducted separate national impact analyses for 

polyphase and capacitor-start (single-phase) motors. Efficiency standards for CSIR and CSCR 

motors are reflected in the capacitor-start energy savings and NPV results, which account for the 

interchangeability of CSIR and CSCR motors in many applications. 

Table VI.3 and Table VI.4 show the forecasted national energy savings through year 

2045 at each of the TSLs. The tables also show the magnitude of the energy savings if the 

savings are discounted at rates of seven and three percent. The energy savings (undiscounted) 

from implementing standards for polyphase small electric motors range from 0.05 to 0.37 quad 

and the savings for capacitor-start small electric motors range from 1.18 to 2.33 quads. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

Table VI.3 Summary of Cumulative National Energy Savings for Polyphase Small Electric 

Motors (Energy Savings between 2015 and 2045) 

Trial Standard Level 

National Energy Savings (quads) 

Not Discounted Discounted at 3% 

Discounted at 

7% 

1 0.05 0.03 0.01 

2 0.09 0.05 0.02 

3 0.17 0.09 0.04 

4 0.19 0.10 0.05 

4b 0.29 0.15 0.07 

5 0.34 0.18 0.09 

6 0.37 0.19 0.09 

7 0.37 0.20 0.09 

Table VI.4 Summary of Cumulative National Energy Savings for Capacitor-Start Small 

Electric Motors (Energy Savings between 2015 and 2045) 

Trial Standard Level 

National Energy Savings 

quads 

Not Discounted Discounted at 3% Discounted at 7% 

1 1.18 0.63 0.31 

2 1.19 0.64 0.31 

3 1.36 0.73 0.36 

4 1.47 0.79 0.39 

5 1.47 0.79 0.39 

6 1.61 0.87 0.43 

7 1.91 1.03 0.51 

8 2.33 1.25 0.62 

DOE conducted a wide range of sensitivity analyses, including scenarios demonstrating 

the effects of variation in shipments, response of customers to higher motor prices, the cost of 

electricity due to a carbon cap and trade regime, reactive power costs, and (for capacitor-start 

motors) the dynamics of CSIR/CSCR consumer choice. These scenarios show a range of 

possible outcomes from projected energy conservation standards, and illustrate the sensitivity of 

these results to different input and modeling assumptions. In general, however, they do not 

dramatically change the relationship between results at one TSL with those at another TSL and 

the relative economic savings and energy savings of different TSLs remain roughly the same. 

The estimated overall magnitude of savings, however, can change substantially, which can be 

due to a change in the estimated total number of small electric motors in use. Details of each 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

scenario are available in chapter 10 of the TSD and its appendices, along with the national 

energy savings estimated for each scenario. 

Customers currently appear to favor CSIR motors over CSCR motors, even if their initial 

costs and losses are almost identical. DOE’s market-share model includes an “unfamiliarity cost” 

parameter that attempts to account for this observed behavior. For the shipments sensitivity 

analysis, DOE analyzed the total energy savings from capacitor-start motors when this 

unfamiliarity cost is significantly lower (high CSCR model) or higher (low CSCR model) than 

DOE’s reference case. These scenarios can have a significant impact on the relative energy 

savings in different TSLs. Table VI.5 shows the results for the national energy savings (through 

year 2045) in these scenarios. 

Table VI.5 Undiscounted Cumulative National Energy Savings for Capacitor-Start Small 

Electric Motors Under Different CSIR/CSCR Market Share Scenarios (Energy savings 

between years 2015 and 2045) 

Trial Standard Level 

National Energy Savings 

quads 

Low CSCR 

Scenario 

Reference 

Scenario 

High CSCR 

Scenario 

1 1.17 1.18 1.30 

2 1.17 1.19 1.38 

3 1.34 1.36 1.52 

4 1.43 1.47 1.67 

5 1.43 1.47 1.65 

6 1.61 1.61 1.62 

7 1.87 1.91 1.92 

8 2.17 2.33 2.37 

C. Economic Justification 

In examining the potential for energy savings for small electric motors, DOE analyzed 

whether standards would be economically justified. As part of this examination, a variety of 

elements were examined. These elements are based on the various criteria specified in EPCA. 

See generally, 42 U.S.C. 6295. 

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EERE-2007-BT-STD-0007 COMMENT 31
1. Economic Impact on Motor Customers 

DOE analyzed the economic impacts on small electric motor customers by looking at the 

effects standards would have on the LCC, PBP, and on various subgroups. DOE also examined 

the effects of the rebuttable presumption payback period set out in 42 U.S.C. 6295. All of these 

analyses are discussed below. 

a. Life-Cycle Costs and Payback Period 

Customers of equipment affected by new or amended standards usually experience higher 

purchase prices and lower operating costs. Generally, these impacts are best captured by changes 

in life-cycle costs. Therefore, DOE calculated the LCC and PBP for the standards levels 

considered in this proceeding. DOE’s LCC and PBP analyses provided five key outputs for each 

TSL, which are reported in Table VI.6 through Table VI.8 below. The first three outputs are the 

proportion of small motor purchases where the purchase of a design that complies with the TSL 

would create a net life-cycle cost, no impact, or a net life-cycle savings for the consumer. The 

fourth output is the average net life-cycle savings from the purchase of a complying design. 

Finally, the fifth output is the average PBP for the consumer purchase of a design that 

complies with the TSL. The PBP is the number of years it would take for the customer to 

recover, as a result of energy savings, the increased costs of higher-efficiency equipment, based 

on the operating cost savings from the first year of ownership. The payback period is an 

economic benefit-cost measure that uses benefits and costs without discounting. DOE’s PBP 

analysis and its analysis under the rebuttable presumption test both address the payback period 

for a standard. DOE based its estimates of the average PBPs for small electric motors on energy 

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EERE-2007-BT-STD-0007 COMMENT 31
consumption under conditions of actual use of these motors and also analyzed the amount of 


energy consumption for purposes of the rebuttable presumption calculations using the conditions 

prescribed by the DOE test procedure. See 42 U.S.C. 6295(o)(2)(B)(iii). Moreover, as discussed 

above, while DOE examined the rebuttable-presumption criteria (see TSD section VI.C.1.d), it 

determined today’s standard levels to be economically justified through a more detailed analysis 

of the economic impacts of increased efficiency pursuant to section 325(o)(2)(B)(i) of EPCA. 

(42 U.S.C. 6295(o)(2)(B)(i)) Detailed information on the LCC and PBP analyses can be found in 

TSD Chapter 8. 

DOE analyzed the life-cycle cost for three representative motors, as shown in Table VI.6 

through Table VI.8. A Monte Carlo simulation was performed to incorporate uncertainty and 

variability into the analysis. A random sample of 10,000 motors was drawn from the 

distributions of current national shipments by motor type, application, owner type, operating 

hours, and other inputs, using Crystal Ball, a commercially available software program. The 

model calculated the LCC and PBP for equipment at each efficiency level for each of the 10,000 

motors sampled. For a 1-horsepower polyphase motor, customers experience net LCC savings, 

on average, through efficiency level 4b. Efficiency level 3 has the minimum average life-cycle 

cost. For a 1⁄2-horsepower CSIR motor, customers experience net LCC savings, on average, 

through efficiency level 6. CSIR efficiency level 4 has the minimum average life-cycle cost. For 

a 3⁄4-horsepower CSCR motor, customers experience net LCC savings, on average, through 

efficiency level 5. CSCR efficiency level 3 has the greatest average life-cycle cost savings. The 

average payback periods in the tables are substantially longer than the median payback periods 

because a fraction of customers run their motors very few hours per year. This results in 

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EERE-2007-BT-STD-0007 COMMENT 31
 

extraordinarily long payback periods for this fraction of customers and results in average 

payback periods that far exceed the median payback period. DOE believes that the median 

payback period represents the anticipated experience of the typical customer more accurately 

than the average payback period. 

Table VI.6 Polyphase Small Electric Motors: Life-Cycle Cost and Payback Period Results 

for a One Horsepower Motor 

Energy 

Efficiency 

Level 

Efficiency 

% 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

LifeCycle 

Cost 

$ 

Average 

Savings 

$ 

Customers with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 74.0 517 1,892 130 1,268 

1 76.1 530 1,729 127 1,261 8 46.8 53.2 21.8 7.1 

2 77.7 537 1,686 123 1,249 19 41.3 58.7 17.8 5.8 

3 79.4 549 1,630 119 1,237 31 40.6 59.4 17.7 5.6 

4 80.1 558 1,615 118 1,240 29 45.1 54.9 20.4 6.5 

4b 82.6 589 1,540 113 1,240 28 51.2 48.8 24.8 7.8 

5 84.4 655 1,508 110 1,291 -23 65.8 34.3 41.5 12.4 

6 85.3 711 1,488 109 1,339 -71 77.4 22.6 54.2 16.9 

7 87.0 1,477 1,462 107 2,095 -827 96.8 3.2 243.0 51.1 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

Table VI.7 Capacitor-Start Induction-Run Motors: Life-Cycle Cost and Payback Period 

Results for a One-Half Horsepower Motor 

Energy 

Efficiency 

Level 

Efficiency 

% 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

LifeCycle 

Cost 

$ 

Average 

Savings 

$ 

Customers with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 59.0 494 1,250 91 915 

1 62.2 502 1,170 85 896 19 27 73 8.6 2.7 

2 64.5 508 1,116 81 884 31 28 72 8.8 2.8 

3 66.7 511 1,064 77 869 46 24 76 7.5 2.3 

4 71.5 529 976 71 857 58 32 68 10.5 3.2 

5 72.7 549 951 69 868 47 42 58 15.1 4.7 

6 74.0 593 920 67 902 13 55 45 24.9 7.2 

7 78.4 996 860 63 1,285 -369 66 34 108.2 12.4 

Table VI.8 Capacitor-Start Capacitor-Run Motors: Life-Cycle Cost and Payback Period 

Results for a Three-Quarter Horsepower Motor 

Energy 

Efficiency 

Level 

Efficiency 

% 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

LifeCycle 

Cost 

$ 

Average 

Savings 

$ 

Customers with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 72.0 548 1,425 104 1,026 

1 75.7 559 1,360 99 1,014 12 36 64 13.4 4.3 

2 80.0 587 1,250 91 1,005 21 46 54 18.5 5.8 

3 82.2 599 1,205 88 1,002 24 48 52 19.1 5.9 

4 83.2 612 1,214 88 1,015 11 55 45 24.4 7.8 

5 84.5 630 1,201 88 1,029 -3 62 38 29.5 9.4 

6 85.2 670 1,179 86 1,062 -36 70 30 40.3 11.8 

7 87.1 697 1,146 84 1,078 -52 75 25 43.5 13.1 

8 88.4 1,485 1,115 81 1,856 -830 99 1 250.0 49.0 

DOE analyzed the average life-cycle cost for a shipment-weighted distribution of product 

classes, as shown in Table VI.9, Table VI.10 and Table VI.11. The results in these tables account 

161 

EERE-2007-BT-STD-0007 COMMENT 31
 

for motors of different horsepower and pole configuration from the three representative motors 

shown in Table VI.6 through Table VI.8. 

Table VI.9 Polyphase Motors: Life-Cycle Cost and Payback Period Results for a ShipmentWeighted Product Class Distribution 

Energy 

Efficiency 

Level 

Average 

Efficiency 

% 

Life-Cycle Cost Life-Cycle Cost 

Savings Payback Period 

years

Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

LifeCycle 

Cost 

$ 

Average 

Savings 

$ 

Customers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 78.8 515 1934 139.52 1,323 

1 80.6 528 1883 135.85 1,314 9 44.7 55.3 21.1 6.6 

2 82.0 535 1836 132.45 1,302 22 39.2 60.8 17.2 5.3 

3 83.4 547 1775 128.07 1,287 36 38.7 61.3 17.1 5.2 

4 84.0 556 1759 126.91 1,289 34 42.7 57.3 19.6 6.0 

4b 86.1 587 1678 121.06 1,288 36 49.2 50.8 23.9 7.3 

5 87.6 651 1643 118.52 1,337 -13 63.2 36.8 39.1 11.5 

6 88.4 707 1622 116.99 1,383 -60 74.8 25.2 51.8 15.7 

7 89.7 1,465 1594 114.96 2,131 -808 96.2 3.8 220.4 47.8 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

Table VI.10 Capacitor-Start Induction-Run Motors: Life-Cycle Cost and Payback Period 

Results for a Shipment-Weighted Product Class Distribution 

Energy 

Efficiency 

Level 

Average 

Efficiency 

% 

Life-Cycle Cost Life-Cycle Cost 

Savings Payback Period 

years

Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

LifeCycle 

Cost 

$ 

Average 

Savings 

$ 

Customers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 49.9 496 1265 92.12 920 

1 53.2 504 1182 86.03 900 20 26.9 73.1 8.5 2.5 

2 55.7 510 1125 81.89 888 33 27.7 72.3 8.7 2.6 

3 58.1 513 1071 77.96 871 49 24.0 76.0 7.4 2.2 

4 63.5 531 979 71.28 859 62 30.7 69.3 10.4 3.1 

5 64.8 551 953 69.40 870 51 40.2 59.8 14.9 4.5 

6 66.3 595 920 67.00 903 17 54.1 45.9 24.5 7.0 

7 71.5 1,000 858 62.48 1,287 -367 65.1 34.9 104.4 11.7 

Table VI.11 Capacitor-Start Capacitor-Run Motors: Life-Cycle Cost and Payback Period 

Results for a Shipment-Weighted Product Class Distribution 

Energy 

Efficiency 

Level 

Average 

Efficiency 

% 

Life-Cycle Cost Life-Cycle Cost 

Savings Payback Period 

years

Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

LifeCycle 

Cost 

$ 

Average 

Savings 

$ 

Customers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 73.2 582 2310 167.38 1,349 

1 76.7 594 2208 160.02 1,325 24 29.3 70.7 10.9 3.3 

2 80.9 626 2036 147.55 1,299 50 38.4 61.6 14.9 4.4 

3 83.0 639 1965 142.43 1,289 60 39.7 60.3 15.4 4.6 

4 84.0 653 1979 143.43 1,304 45 46.1 53.9 19.8 5.9 

5 85.2 673 1959 141.96 1,318 32 52.6 47.4 23.9 7.2 

6 85.9 719 1923 139.37 1,351 -1 60.2 39.9 32.5 8.9 

7 87.8 749 1873 135.72 1,364 -15 65.1 35.0 35.1 10.1 

8 89.0 1,629 1824 132.17 2,228 -879 94.7 5.3 200.0 36.4 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

b. Life-Cycle Cost Sensitivity Calculations 


DOE made sensitivity calculations for the case where CSIR motor owners switch to 

CSCR motors. DOE reports the details of the sensitivity calculations in chapter 8 of the TSD 

and the accompanying appendices. Section VI.C.1.a above describes the relationship between 

efficiency levels for the two categories of capacitor-start motors and the TSLs. For TSLs where 

there is a large increase in first cost for CSIR motors and only a moderate increase in price for 

CSCR motors, DOE forecasts that a large fraction of CSIR motor customers will switch to CSCR 

motors. Table VI.12 shows the shipments-weighted average of the LCC for CSIR motors 

including those users that switch to CSCR. The table shows that a negative average LCC is 

forecast for TSL 6, the level at which both CSIR and CSCR motors are at the maximum 

technologically feasible efficiency for space-constrained designs, and at TSL 8, the level with the 

greatest energy savings. 

Table VI.12 Capacitor-Start Induction-Run Motors: Shipment-Weighted Life-Cycle Cost 

and Payback Period Results for a One-Half Horsepower Motor with Switching to CSCR 

Trial 

Standard 

Level 

Life-Cycle Cost Life-Cycle Cost Savings 

Average 

Installed Price 

$ 

Average 

Annual 

Energy Use 

kWh 

Average Annual 

Operating Cost 

$ 

Average LifeCycle Cost 

$ 

Average 

Savings 

$ 

Customers with 

Net 

Cost 

% 

Net 

Benefit 

% 

Baseline 

1 528 969 70.8 854 58 32.5% 67.5% 

2 528 969 70.8 854 58 32.5% 67.5% 

3 547 945 69.0 865 47 41.7% 58.3% 

4 590 913 66.7 897 15 55.0% 45.0% 

5 589 913 66.7 897 15 55.0% 45.0% 

6 994 854 62.4 1,282 -370 66.0% 34.0% 

7 601 863 63.1 891 23 53.7% 46.3% 

8 633 847 61.9 917 -3 60.6% 39.4% 

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EERE-2007-BT-STD-0007 COMMENT 31
Additional sensitivity analyses examined the magnitude by which the estimates varied 


when the results of the NEMA survey of OEMs (motor distributions by application and sector, 

operating hours, and the fraction of motors that are space-constrained in their applications) were 

used. Other sensitivities were conducted by varying inputs such as the cost of electricity, the 

purchase year of the motor, the motor capacity, the number of poles and other inputs and 

assumptions of the analysis. DOE reports the details of all of the sensitivity calculations in 

chapter 8 of the TSD and the accompanying appendices. 

As discussed in section IV.E.1 above, NEMA submitted the results of a survey of their 

OEM customers that install motors covered by today’s rule in their products. The survey reports 

distributions by application and owner type, estimates of annual hours of operation, and the 

fraction of motors that are space-constrained. NEMA also provided information on a sixth 

application not included in DOE’s NOPR, service industry motors. DOE ran a sensitivity 

analysis using the data NEMA provided on motor distributions. Under this sensitivity, LCC 

savings are reduced and payback periods are increased for polyphase and CSCR motor 

customers, while LCC savings are increased and payback periods reduced for CSIR motor 

customers. This is the result of average operating hours of polyphase and CSCR motors being 

reduced by about 30 percent from the DOE reference case, while operating hours of CSIR 

motors are increased by about 10 percent. 

Details on these and other LCC sensitivity cases can be found in TSD appendix 8A. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

c. Customer Subgroup Analysis 


Using the LCC spreadsheet model, DOE estimated the impacts of the TSLs on the 

following customer subgroups: small businesses and customers with space-constrained 

applications. DOE analyzed the small business subgroup because this group has typically had 

less access to capital than larger businesses, which results in higher financing costs and a higher 

discount rate than the industry average. 74 FR 61442, 61459. DOE estimated the LCC and PBP 

for the small business subgroup, as shown in Table VI.13 through Table VI.15. The analysis 

indicates that the small business subgroup is expected to have lower LCC savings and longer 

payback periods than the industry average. 

Chapter 12 of the TSD provides more detailed discussion on the LCC subgroup analysis and 

results. 

Table VI.13 Polyphase Motors: Small Business Customer Subgroup 

Energy 

Efficiency 

Level 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use 

kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

Life-Cycle 

Cost 

$ 

Average 

Life-Cycle 

Cost Savings 

$ 

Consumers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 516 1888 137.84 1,192 

1 529 1838 134.21 1,186 6 51.9 48.1 22.0 6.9 

2 536 1792 130.85 1,177 15 46.1 54.0 18.0 5.6 

3 548 1733 126.54 1,167 25 45.5 54.5 17.9 5.5 

4 556 1718 125.39 1,170 22 49.7 50.3 20.6 6.3 

4b 588 1639 119.63 1,174 18 56.5 43.5 25.1 7.7 

5 652 1604 117.13 1,226 -34 69.6 30.4 41.8 12.2 

6 708 1584 115.60 1,274 -82 80.2 19.9 54.7 16.7 

7 1,460 1557 113.63 2,017 -825 97.4 2.6 243.1 50.2 

166
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

Table VI.14 Capacitor-Start Induction Run Motors: Small Business Customer Subgroup 


Energy 

Efficiency 

Level 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use 

kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

Life-Cycle 

Cost 

$ 

Average 

Life-Cycle 

Cost Savings 

$ 

Consumers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 497 1261 91.33 869 

1 506 1178 85.28 852 16 31.3 68.7 8.5 2.6 

2 512 1121 81.16 842 27 32.4 67.6 8.7 2.7 

3 514 1067 77.25 828 41 28.0 72.0 7.4 2.3 

4 533 976 70.63 819 50 35.8 64.2 10.4 3.2 

5 553 950 68.75 832 37 45.3 54.7 14.9 4.6 

6 597 917 66.37 866 3 58.6 41.4 24.7 7.1 

7 995 855 61.89 1,246 -377 68.5 31.5 108.4 11.9 

Table VI.15 Capacitor-Start Capacitor Run Motors: Small Business Customer Subgroup 


Energy 

Efficiency Level 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use 

kWh 

Average 

Annual 

Operating Cost 

$ 

Average 

Life-Cycle 

Cost 

$ 

Average LifeCycle Cost 

Savings 

$ 

Consumers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

CSCR Baseline 586 2339 169.80 1,273 

1 598 2236 162.36 1,253 20 33.6 66.4 10.8 3.3 

2 630 2062 149.73 1,234 39 43.4 56.6 15.0 4.4 

3 643 1991 144.55 1,226 47 44.7 55.3 15.5 4.6 

4 657 2005 145.59 1,241 32 51.1 48.9 19.7 6.0 

5 678 1985 144.09 1,256 17 58.0 42.0 23.9 7.3 

6 723 1949 141.51 1,290 -17 65.1 34.9 32.8 9.1 

7 754 1898 137.82 1,306 -33 69.7 30.4 35.4 10.2 

8 1,633 1849 134.23 2,171 -898 96.0 4.0 205.3 37.3 

DOE has analyzed customers with space-constrained applications, i.e., customers whose 

motor stack length can increase by no more than 20 percent, because they cannot realize the full 

economic benefit of efficiency improvements in small electric motors. Increasing the stack 

length of small motors is one way to improve their efficiency. But customers with space167
 

EERE-2007-BT-STD-0007 COMMENT 31
constrained applications cannot increase the stack length of the motors they use without being
 

subject to burdens to which other small motor users are not. Furthermore, although small electric 

motors without increased stack length could meet the TSLs DOE has evaluated in this 

rulemaking, such motors use other, more costly design options. Table VI.16 through Table VI.18 

show the mean LCC savings and the mean PBP (in years) for equipment that meets the energy 

conservation standards in today’s final rule for the subgroup of customers with space-constrained 

applications. 

The analysis indicates that the economic benefits of efficiency improvements in small 

electric motors will be lower for customers subject to space constraints than for those who do not 

face such constraints, as well as for the industry average, particularly for motors at the higher 

efficiency levels. For the standard levels promulgated by today’s rule, customers will still realize 

net benefits from space-constrained polyphase and CSCR motors, but not from space-constrained 

CSIR motors. OEMs whose applications have space constraints can replace a less efficient CSIR 

motor with a more efficient CSCR motor without increasing stack length, and still realize net 

benefits, as shown in Table VI.12 above. If these applications cannot accommodate a motor with 

a run capacitor, OEMs can either redesign their application to accommodate a CSCR motor, 

purchase a stockpile of motors not covered by today’s rule to install in future production of their 

application, or replace their motor with a fully enclosed motor not covered by today’s rule. 

Chapter 11 of the TSD explains DOE’s method for conducting the customer subgroup 

analysis and presents the detailed results of that analysis. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

Table VI.16 Polyphase Motors: Space-Constrained Applications Subgroup 


Energy 

Efficiency 

Level 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use 

kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

Life-Cycle 

Cost 

$ 

Average 

Life-Cycle 

Cost 

Savings 

$ 

Consumers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 512 1903 140.60 1,318 

1 524 1853 136.90 1,308 9 45.6 54.4 21.5 6.8 

2 531 1807 133.49 1,296 22 40.2 59.8 17.5 5.5 

3 543 1748 129.13 1,282 36 39.6 60.4 17.4 5.4 

4 552 1732 127.96 1,284 34 43.7 56.3 20.0 6.3 

4b 582 1650 121.98 1,280 37 49.7 50.3 24.2 7.5 

5 756 1610 119.00 1,437 -120 84.8 15.2 71.8 22.3 

6 769 1590 117.55 1,441 -123 84.3 15.7 70.7 22.1 

7 3,548 1543 114.11 4,201 -2,883 100.0 0.0 728.2 226.0 

Table VI.17 Capacitor-Start Induction Run Motors: Space-Constrained Applications 

Customer Subgroup 

Energy 

Efficiency 

Level 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use 

kWh 

Average 

Annual 

Operating 

Cost 

$ 

Average 

Life-Cycle 

Cost 

$ 

Average 

Life-Cycle 

Cost 

Savings 

$ 

Consumers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 494 1274 92.66 923 

1 503 1190 86.56 903 20 26.7 73.3 8.5 2.6 

2 509 1133 82.42 890 33 27.5 72.5 8.8 2.6 

3 511 1079 78.48 873 49 23.6 76.4 7.5 2.2 

4 539 976 71.00 867 56 37.2 62.8 12.9 3.9 

5 544 955 69.45 864 58 38.0 62.0 13.4 4.0 

6 665 925 67.28 976 -53 74.0 26.0 42.3 12.6 

7 2,559 848 61.68 2,843 -1,921 100.0 0.0 418.9 124.7 

169
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

Table VI.18 Capacitor-Start Capacitor Run Motors: Space-Constrained Applications 

Customer Subgroup 

Energy 

Efficiency 

Level 

Life-Cycle Cost Life-Cycle Cost Savings Payback Period 

years Average 

Installed 

Price 

$ 

Average 

Annual 

Energy 

Use 

kWh 

Average 

Annual 

Operating Cost 

$ 

Average 

Life-Cycle 

Cost 

$ 

Average LifeCycle Cost 

Savings 

$ 

Consumers 

with 

Net 

Cost 

% 

Net 

Benefit 

% 

Average Median 

Baseline 579 2313 167.74 1,355 

1 591 2212 160.38 1,331 24 29.2 70.8 10.9 3.3 

2 633 2053 148.85 1,320 35 47.4 52.6 19.0 5.8 

3 645 1998 144.88 1,312 43 47.2 52.8 19.2 5.9 

4 653 1991 144.36 1,316 40 49.3 50.7 21.1 6.5 

5 671 1981 143.61 1,330 26 55.4 44.6 25.3 7.8 

6 839 1914 138.80 1,476 -121 84.3 15.7 60.1 18.4 

7 854 1862 135.02 1,473 -118 82.5 17.5 56.3 17.1 

8 3,992 1815 131.61 4,597 -3,242 100.0 0.0 634.4 193.1 

d. Rebuttable Presumption Payback 

As discussed in section III.D.2, EPCA provides a rebuttable presumption that, in essence, 

an energy conservation standard is economically justified if the increased purchase cost for a 

product that meets the standard is less than three times the value of the first-year energy savings 

resulting from the standard. However, DOE routinely conducts a full economic analysis that 

considers the full range of impacts, including those to the customer, manufacturer, Nation, and 

environment, as required under 42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(e)(1). The results 

of this analysis serve as the basis for DOE to evaluate definitively the economic justification for 

a potential standard level (thereby supporting or rebutting the results of any preliminary 

determination of economic justification). 

For comparison with the more detailed analysis results, DOE calculated a rebuttable 

presumption payback period for each TSL. Table VI.19 and Table VI.20 show the rebuttable 

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EERE-2007-BT-STD-0007 COMMENT 31
presumption payback periods for the representative product classes. No polyphase TSL has a 

rebuttable presumption payback period of less than 3 years. For CSIR and CSCR motors, TSLs 1 

through 3 have rebuttable presumption payback periods of less than 3 years. 

Table VI.19 Rebuttable-Presumption Payback Periods for Representative Polyphase Small 

Electric Motors (1 hp, 4 poles) 

TSL Payback Period 

years 

1 3.3 

2 3.0 

3 3.3 

4 3.8 

4b 4.9 

5 7.9 

6 10.2 

7 45.7 

Table VI.20 Rebuttable-Presumption Payback Periods for Representative Capacitor-Start 

Small Electric Motors 

TSL 

Induction-Run (1/2 hp, 4 poles) Capacitor-Run (3/4 hp 4 poles) 

CSIR Level 

Payback Period 

years CSCR Level 

Payback Period 

years 

1 4 1.7 2 1.5 

2 4 1.7 3 2.7 

3 5 2.5 3 2.7 

4 6 4.1 4 3.3 

5 6 4.1 3 2.7 

6 7 17.7 8 35.5 

7 7 17.7 3 2.7 

8 7 17.7 7 6.0 

2. Economic Impact on Manufacturers 

For the NOPR, DOE used the INPV in the MIA to compare the financial impacts of 

different TSLs on small electric motor manufacturers. 74 FR 61464–69. The INPV is the sum of 

all net cash flows discounted by the industry’s cost of capital (discount rate). DOE used the 

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EERE-2007-BT-STD-0007 COMMENT 31
GRIM to compare the INPV of the base case (no new energy conservation standards) to that of 


each TSL for the small electric motor industry. To evaluate the range of cash-flow impacts on 

this industry, DOE constructed different scenarios using two different assumptions for 

manufacturer markups: (1) The preservation-of-return-on-invested-capital scenario, and (2) the 

preservation-of-operating-profit (absolute dollars) scenario. These two scenarios correspond to 

the range of anticipated market responses, and results in a unique set of cash flows and 

corresponding industry value at each TSL. These steps allowed DOE to compare the potential 

impacts on the industry as a function of TSLs in the GRIM. The difference in INPV between the 

base case and the standards case is an estimate of the economic impacts that implementing that 

standard level would have on the entire industry. For today’s notice, DOE continues to use the 

above methodology and presents the results in the subsequent sections. See chapter 12 of the 

TSD for additional information on MIA methodology and results. 

a. Industry Cash-Flow Analysis Results 

Using the two different markup scenarios, DOE estimated the impact of new standards for 

small electric motors on the INPV of the small electric motors manufacturing industry. The 

impact consists of the difference between the INPV in the base case and the INPV in the 

standards case. INPV is the primary metric used in the MIA, and represents one measure of the 

fair value of the industry in today’s dollars. DOE calculated the INPV by summing all of the 

annual net cash flows, discounted at the small electric motor industry’s cost of capital or discount 

rate. 

To assess the lower end of the range of potential impacts for the small electric motor 

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EERE-2007-BT-STD-0007 COMMENT 31
industry, DOE considered a scenario where a manufacturer’s percentage return on working 

capital and capital invested in fixed assets (net plant, property, and equipment), the year after the 

new energy conservation standards become effective, is the same as in the base case. This 

scenario is called the preservation-of-return-on-invested-capital scenario. To assess the higher 

end of the range of potential impacts for the small electric motor industry, DOE considered a 

scenario in which the absolute dollar amount of the industry’s base-case operating profit 

(earnings before interest and taxes) remains the same and does not increase in the year after 

implementation of the standards. This scenario is called the preservation-of-operating-profit 

(absolute dollars) scenario. For both markup scenarios, DOE considered the same reference 

shipment scenario found in the NIA. Table VI.21 through Table VI.24 show the range of changes 

in INPV that DOE estimates could result from the TSLs DOE considered for this final rule. The 

results present the impacts of energy conservation standards for polyphase small electric motors 

separately and combine the impacts for CSIR and CSCR small electric motors. The tables also 

present the equipment conversion costs and capital conversion costs that the industry would 

incur at each TSL. 

173
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

Table VI.21 Manufacturer Impact Analysis for Polyphase Small Electric Motors 

(Preservation of Return on Invested Capital Markup Scenario) 

 Units Base 

Case 

Trial Standard Level 

1 2 3 4 4b 5 6 7 

INPV 2009$ 

millions 70 69 70 71 70 73 82 88 165 

Change in 

INPV 

2009$ 

millions - (0.19) 0.34 0.98 0.57 3.37 12.62 18.54 95.27 

% - (0.27) 0.49 1.41 0.82 4.84 18.15 26.65 136.95 

Equipment 

Conversion 

Costs 

2009$ 

millions - 1.9 1.9 1.9 3.8 3.8 3.8 5.8 7.7 

Capital 

Conversion 

Costs 

2009$ 

millions - 0.4 0.7 0.7 0.9 1.9 7.1 10.7 37.3 

Total 

Investment 

Required 

2009$ 

millions - 2.3 2.6 2.7 4.7 5.7 10.9 16.5 45.0 

174
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

Table VI.22 Manufacturer Impact Analysis for Polyphase Small Electric Motors 

(Preservation of Operating Profit Markup Scenario) 

 Units Base 

Case 

Trial Standard Level 

1 2 3 4 4b 5 6 7 

INPV 2009$ 

millions 70 68 68 67 66 64 58 52 0 

Change in 

INPV 

2009$ 

millions - (1.49) (1.86) (2.26) (3.58) (5.43) (11.80) (17.51) (69.47) 

% - (2.15) (2.67) (3.25) (5.15) (7.80) (16.96) (25.16) (99.85) 

Equipment 

Conversion 

Costs 

2009$ 

millions - 1.9 1.9 1.9 3.8 3.8 3.8 5.8 7.7 

Capital 

Conversion 

Costs 

2009$ 

millions - 0.4 0.7 0.7 0.9 1.9 7.1 10.7 37.3 

Total 

Investment 

Required 

2009$ 

millions - 2.3 2.6 2.7 4.7 5.7 10.9 16.5 45.0 

Table VI.23 Manufacturer Impact Analysis for CSIR and CSCR Small Electric Motors 

(Preservation of Return on Invested Capital Markup Scenario) 

 Units Base 

Case 

Trial Standard Level 

1 2 3 4 5 6 7 8 

INPV 2009$ 

millions 279 287 289 295 311 308 466 297 325 

Change in 

INPV 

2009$ 

millions - 8.40 9.46 16.27 32.15 28.48 186.60 18.40 46.35 

% - 3.01 3.39 5.83 11.52 10.20 66.87 6.59 16.61 

Equipment 

Conversion 

Costs 

2009$ 

millions - 16.7 16.7 24.9 25.3 24.9 33.7 24.9 25.3 

Capital 

Conversion 

Costs 

2009$ 

millions - 9.4 10.5 16.5 21.7 18.3 79.9 20.7 29.0 

Total 

Investment 

Required 

2009$ 

millions - 26.1 27.2 41.4 47.0 43.2 113.6 45.5 54.3 

175
 

EERE-2007-BT-STD-0007 COMMENT 31
 

Table VI.24 Manufacturer Impact Analysis for CSIR and CSCR Small Electric Motors 

(Preservation of Operating Profit Markup Scenario) 

 Units Base 

Case 

Trial Standard Level 

1 2 3 4 5 6 7 8 

INPV 2009$ 

millions 279 259 258 247 236 239 127 245 226 

Change in 

INPV 

2009$ 

millions - (19.99) (20.79) (32.42) (43.15) (40.09) (152.05) (34.05) (52.58) 

% - (7.16) (7.45) (11.62) (15.46) (14.37) (54.49) (12.20) (18.84) 

Equipment 

Conversion 

Costs 

2009$ 

millions - 16.7 16.7 24.9 25.3 24.9 33.7 24.9 25.3 

Capital 

Conversion 

Costs 

2009$ 

millions - 9.4 10.5 16.5 21.7 18.3 79.9 20.7 29.0 

Total 

Investment 

Required 

2009$ 

millions - 26.1 27.2 41.4 47.0 43.2 113.6 45.5 54.3 

Polyphase Small Electric Motors 

DOE estimated the impacts on INPV at TSL 1 to range from $0.19 million to -$1.49 

million, or a change in INPV of -0.27 percent to -2.15 percent. At this level, industry cash flow 

decreases by approximately 13.3 percent, to $4.84 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 1 represents an 

efficiency increase of 2 percent over the baseline for polyphase motors. The majority of 

manufacturers have motors that meet this efficiency level. All manufacturers that were 

interviewed stated that their existing motor designs allow for simple modifications that would 

require minor capital and equipment conversion costs to reach TSL 1. A possible modification 

analyzed in the engineering analysis is a roughly 7 percent increase in the number of laminations 

within both space-constrained and non space-constrained motors. Manufacturers indicated that 

modifications like increased laminations could be made within existing baseline motor designs 

without significantly altering their size. In addition, these minor design changes will not raise the 

production costs beyond the cost of most motors sold today, resulting in minimal impacts on 

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EERE-2007-BT-STD-0007 COMMENT 31
industry value. 

DOE estimated the impacts in INPV at TSL 2 to range from $0.34 million to -$1.86 

million, or a change in INPV of 0.49 percent to 2.67 percent. At this level, industry cash flow 

decreases by approximately 15.6 percent, to $4.71 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 2 represents an 

efficiency increase of 4 percent over the baseline for polyphase motors. Similar to TSL 1, at TSL 

2 manufacturers stated that their existing motor designs allow for simple modifications that 

would entail only minor capital and equipment conversion costs. A possible modification 

analyzed in the engineering analysis increases the number of laminations by approximately 15 

percent from the baseline within both space-constrained and non spaced-constrained motors. 

Manufacturers indicated that these modifications could be made within baseline motor designs 

without significantly changing their size. At TSL 2, the production costs of standards compliant 

motors do not increase enough to significantly affect INPV. 

At TSL 3, DOE estimated the impacts in INPV to range from $0.98 million to -$2.26 

million, or a change in INPV of 1.41 percent to -3.25 percent. At this level, industry cash flow 

decreases by approximately 16.4 percent, to $4.67 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 3 represents an 

efficiency increase of 6 percent over the baseline for polyphase motors. Similar to TSL 1 and 

TSL 2, at TSL 3 manufacturers stated that their existing motor designs would still allow for 

simple modifications that would not require significant capital and equipment conversion costs. 

In the engineering analysis, standards compliant motors that meet the efficiency requirements at 

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EERE-2007-BT-STD-0007 COMMENT 31
TSL 3 have 17-percent increase in the number of laminations compared to the baseline design
 

within both space-constrained and non spaced-constrained motors. These changes do not result 

in significant impacts on INPV. 

At TSL 4, DOE estimated the impacts in INPV to range from $0.57 million to -$3.58 

million, or a change in INPV of 0.82 percent to -5.15 percent. At this level, industry cash flow 

decreases by approximately 27.7 percent, to $4.03 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 4 represents an 

efficiency increase of 7 percent over the baseline for polyphase motors. Most manufacturers that 

were interviewed are able to reach this level without significant redesigns. At TSL 4, a possible 

design pathway for manufacturers could be to increase the number of laminations by 

approximately 20 percent over the baseline designs within space-constrained and non spaceconstrained motors. 

At TSL 4b, DOE estimated the impacts in INPV to range from $3.37 million to -$5.43 

million, or a change in INPV of 4.84 percent to -7.80 percent. At this level, industry cash flow 

decreases by approximately 36.0 percent, to $3.57 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 4b represents an 

efficiency increase of 8-percent over the baseline for polyphase motors. Most manufacturers that 

were interviewed are able to reach this level without significant redesigns. A possible redesign 

for non space-constrained motors would include increasing the number of laminations by 47 

percent relative to the baseline motor design. For space-constrained motors, redesigns could 

require up to 20 percent more laminations of better grade electrical steel. However, 

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EERE-2007-BT-STD-0007 COMMENT 31
manufacturers reported that efficiency levels similar to TSL 4b would be the highest achievable 


before required efficiencies could significantly change motor designs and production equipment. 

However, setting a level higher than TSL 4b may require significant motor size changes. 

At TSL 5, DOE estimated the impacts in INPV to range from $12.62 million to -$11.80 

million, or a change in INPV of 18.15 percent to -16.96 percent. At this level industry cash flow 

decreases by approximately 77.7 percent, to $1.24 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 5 represents an 

efficiency increase of 10-percent over the baseline for polyphase motors. TSL 5 is equivalent to 

the current NEMA premium level that manufacturers produce for medium-sized electric motors. 

Although some manufacturers reported having existing small electric motors that reach 

TSL 5, the designs necessary are more complex than their cost optimized designs at lower TSLs. 

A possible redesign for non space-constrained motors would include adding up to 49 percent 

more laminations relative to the baseline motor design and improving the grade of steel. For 

space-constrained motors, redesigns could require up to 114 percent more laminations of a 

thinner and higher grade of steel. Manufacturers are concerned that redesigns at TSL 5 could 

increase the size of the motors if they do not currently have motors that reach the NEMA 

premium efficiency levels. A shift to larger motors could be detrimental to sales due to the 

inability of OEMs to use standards- compliant motors as direct replacements in some 

applications. 

According to manufacturers, at TSL 5, the industry would incur significantly higher 

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EERE-2007-BT-STD-0007 COMMENT 31
capital and equipment conversion costs in comparison to the lower efficiency levels analyzed. 


DOE estimates that the capital and equipment conversion costs required to make the redesigns at 

TSL 5 would be approximately four times the amount required to meet TSL 1. At TSL 5 

manufacturers would also be required to shift their entire production of baseline motors to higher 

priced and higher efficiency motors, making their current cost-optimized designs obsolete. These 

higher production costs could have a greater impact on the industry value if operating profit does 

not increase. Manufacturers indicated that setting energy conservation standards at TSL 5 could 

cause some manufacturers to consider exiting the small electric motor market because of the lack 

of resources, potentially unjustifiable investments for a small segment of their business, and the 

possibility of lower revenues if OEMs will not accept large motors. 

At TSL 6, DOE estimated the impacts in INPV to range from $18.54 million to -$17.51 

million, or a change in INPV of 26.65 percent to -25.16 percent. At this level industry cash flow 

decreases by approximately 117.2 percent, to -$0.96 million, compared to the base-case value of 

$5.58 million in the year leading up to the energy conservation standards. TSL 6 represents an 

efficiency increase of 12-percent over the baseline for polyphase motors. Currently, no small 

electric motors are rated above the equivalent to the NEMA premium standard (TSL 5). Possible 

redesigns for space-constrained motors at TSL 6 include the use of copper rotors and a 114­

percent increase in the number of laminations of a thinner and higher grade of steel. These 

changes would cause manufacturers to incur significant capital and equipment conversion costs 

to redesign their space-constrained motors due to the lack of experience in using copper. 

According to manufacturers, copper tooling is significantly costlier and not currently 

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used by any manufacturers for the production of small electric motors. If copper rotor designs are 


required, manufacturers with in-house die-casting capabilities will need completely new 

machinery to process copper. Manufacturers that outsource rotor production would pay higher 

prices for their rotor designs. In both cases, TSL 6 results in significant equipment conversion 

costs to modify current manufacturing processes in addition to redesigning motors to use copper 

in the applications of general purpose small electric motors. Largely due to the significant 

changes to space-constrained motors, DOE estimates that at TSL 6 manufacturers would incur 

close to seven times the total conversion costs required at TSL 1 (a total of approximately $16.5 

million). However, for non space-constrained motors, manufacturers are able to redesign their 

existing motors without the use of copper rotors by using twice the number of laminations that 

are contained in the baseline design. Therefore, for non space-constrained motors the impacts at 

TSL 6 are significantly less because manufacturers can maintain existing manufacturing 

processes without the potentially significant changes associated with copper rotors. At TSL 6 

the impacts for non space-constrained motors are mainly due to higher motor costs and the 

possible decrease in profitability if manufacturers are unable to fully pass through their higher 

production costs. 

At TSL 7, DOE estimated the impacts in INPV to range from $95.27 million to -$69.47 

million, or a change in INPV of 136.95 percent to -99.85 percent. At this level industry cash flow 

decreases by approximately 342.4 percent, to -$13.52 million, compared to the base-case value 

of $5.58 million in the year leading up to the energy conservation standards. TSL 7 represents an 

efficiency increase of 14-percent over the baseline for polyphase motors. 

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Currently, the market does not have any motors that reach TSL 7. At TSL 7, space-


constrained motor designs may require the use of copper rotors and premium electrical steels, 

such as the Hiperco steel used in DOE’s design. There is some uncertainty about the magnitude 

of the impacts on the industry of using Hiperco steel. Manufacturers were unsure about the 

required conversion costs to reach TSL 7 because of the unproven properties and applicability of 

the technology in the general purpose motors covered by this rulemaking. 

Significant R&D for both manufacturing processes and motor redesigns would be 

necessary to understand the applications of premium steels to general purpose small electric 

motors. According to manufacturers, requiring this technology could cause some competitors to 

exit the small electric motor market. If manufacturers’ concerns of having to use both copper 

rotors and new steels materialize, manufacturers could be significantly impacted. For non spaceconstrained motors, DOE estimates that manufacturers would require the use of copper rotors but 

not premium steels. If manufacturers are required to redesign non-spaced constrained motors 

with copper, the total conversion costs for the industry increases greatly because all motors 

require substantially different production equipment. Finally, the production costs of motors that 

meet TSL 7 could be up to 18 times higher than the production costs of baseline motors. The cost 

to manufacture standards-compliant motors could have a significant impact on the industry if 

operating profit does not increase with production costs. 

Capacitor-Start, Induction Run and Capacitor-Start, Capacitor-Run Small Electric Motors 

At TSL 1, DOE estimated the impacts in INPV to range from $8.4 million to -$19.99 

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million, or a change in INPV of 3.01 percent to -7.16 percent. At this level, industry cash flow 

decreases by approximately 41.3 percent, to $13.13 million, compared to the base-case value of 

$22.38 million in the year leading up to the energy conservation standards. TSL 1 represents an 

efficiency increase of 19-percent over the baseline for CSIR motors and 10-percent over the 

baseline for CSCR motors. At TSL 1 for CSIR motors, DOE estimates manufacturers would 

need to increase the number of laminations for space-constrained motors by approximately 33 

percent and use a thinner and higher grade of steel. For non space-constrained CSIR motors, 

manufacturers could increase laminations by approximately 61 percent with the use of a better 

grade of electric steel. For space-constrained CSCR motors, manufacturers could increase 

laminations by ten percent and use a higher grade of steel. For non space-constrained CSCR 

motors, manufacturers could increase laminations by approximately 37 percent. For both CSIR 

and CSCR motors, the additional stack length needed to reach TSL 1 is still within the tolerances 

of many manufacturers’ existing motors. DOE estimates that these changes would cause the 

industry to incur capital and equipment conversion costs of approximately $26.1 million to reach 

TSL 1. While TSL 1 would increase production costs, the cost increases are not enough to 

severely affect INPV under the scenarios analyzed. 

At TSL 2, DOE estimated the impacts in INPV to range from $9.46 million to -$20.79 

million, or a change in INPV of 3.39 percent to -7.45 percent. At this level, industry cash flow 

decreases by approximately 43.5 percent, to $12.65 million, compared to the base-case value of 

$22.38 million in the year leading up to the energy conservation standards. TSL 2 represents an 

efficiency increase of 19 percent over the baseline for CSIR motors and 13-percent over the 

baseline for CSCR motors. For CSIR motors, the same changes to meet TSL 1 are necessary for 

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TSL 2. For CSCR motors, TSL 2 represents what manufacturers would consider a NEMA 


Premium equivalent efficiency level. The changes required for CSCR motors could cause 

manufacturers to incur additional capital conversion costs to accommodate the required increase 

in laminations. Imposing standards at TSL 2 would increase production costs for both CSIR and 

CSCR motors, but the cost increases for both types of motors are not enough to severely affect 

INPV. 

At TSL 3, DOE estimated the impacts in INPV to range from $16.27 million to -$32.42 

million, or a change in INPV of 5.83 percent to -11.62 percent. At this level, industry cash flow 

decreases by approximately 66.5 percent, to $7.51 million, compared to the base-case value of 

$22.38 million in the year leading up to the energy conservation standards. TSL 3 represents an 

efficiency increase of 23 percent over the baseline for CSIR motors and 13 percent over the 

baseline for CSCR motors. At TSL 3, space-constrained CSIR motors could require redesigns 

that use copper rotors. Using copper rotors for space-constrained CSIR motors could cause 

manufacturers to incur approximately $41.4 million in capital and equipment conversion costs, 

largely to purchase the equipment necessary to produce these redesigned motors. 

As with polyphase motors, manufacturers reported that copper rotor tooling is 

significantly costlier than traditional aluminum rotor tooling and not currently used by the 

industry for the production of small electric motors. Similarly, in-house die-casting capabilities 

would need completely new machinery to process copper and the alternative of outsourcing rotor 

production would greatly increase material costs. For non space-constrained CSIR motors, 

manufacturers could redesign motors by increasing the number of laminations without the use of 

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copper rotors, resulting in significantly smaller impacts. At TSL 3, the impacts for non space-


constrained motors are mainly due to higher motor material costs and a possible decline in profit 

margins. TSL 3 represents what manufacturers would consider a NEMA Premium equivalent 

efficiency level for CSCR motors. The required efficiencies for space-constrained CSCR motors 

could be met by manufacturers by increasing the number of laminations by 15 percent and using 

higher steel grades. The required efficiencies for non-spaced constrained CSCR motors could be 

met by increasing the number of laminations by 53 percent. Because the redesigns for CSCR 

motors are less substantial, the impacts at TSL 3 are driven largely by the required CSIR 

efficiencies. 

At TSL 4, DOE estimated the impacts in INPV to range from $32.15 million to -$43.15 

million, or a change in INPV of 11.52 percent to -15.46 percent. At this level, industry cash flow 

decreases by approximately 77.5 percent, to $5.02 million, compared to the base-case value of 

$22.38 million in the year leading up to the energy conservation standards. TSL 4 represents an 

efficiency increase of 27 percent over the baseline for CSIR motors and 15 percent over the 

baseline for CSCR motors. TSL 4 currently represents a NEMA premium equivalent level for 

CSIR motors. Possible redesigns for both CSIR and CSCR motors to meet TSL 4 involve both 

increasing the number of laminations as well as using higher grades of steel. 

For space-constrained CSIR motors, redesigns could require the use of copper rotors. 

Because of these redesigns, standards-compliant motors at TSL 4 have significantly higher costs 

than manufacturers’ baseline motors. These changes increase the engineering and capital 

resources that must be employed, especially for CSCR motors. The negative impacts at TSL 4 

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are driven by the conversion costs that potentially require some single-phase motors to use 


copper rotors, and the higher production costs of standards-compliant motors. 

At TSL 5, DOE estimated the impacts in INPV to range from $28.48 million to -$40.09 

million, or a change in INPV of 10.20 percent to -14.37 percent. At this level, industry cash flow 

decreases by approximately 70.2 percent, to $6.66 million, compared to the base-case value of 

$22.38 million in the year leading up to the energy conservation standards. TSL 5 represents an 

efficiency increase of 27 percent over the baseline for CSIR motors and 13 percent over the 

baseline for CSCR motors. TSL 5 represents NEMA premium equivalent efficiency levels for 

both CSIR and CSCR motors. 

At TSL 5, space-constrained CSIR motors could require the use of copper rotors. The 

required efficiencies for non space-constrained CSIR motors could be met by manufacturers by 

increasing the number of laminations by 82 percent and using a higher grade of steel. The 

required efficiencies for space-constrained CSCR motors could be met by manufacturers by 

increasing the number of laminations by 15 percent and using higher steel grades. The required 

efficiencies for non-spaced constrained CSCR motors could be met by increasing the number of 

laminations by 53 percent. 

Although manufacturers reported that meeting TSL 5 is feasible, the production costs of 

motors at TSL 5 increase substantially and require approximately $43.2 million in total capital 

and equipment conversion costs. The negative impacts at TSL 5 are driven by these conversion 

costs that potentially require some CSIR motors to use copper rotors, and the impacts on 

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profitability if the higher production costs of standards-compliant motors cannot be fully passed 

through to customers. 

At TSL 6, DOE estimated the impacts in INPV to range from $186.60 million to ­

$152.05 million, or a change in INPV of 66.87 percent to -54.49 percent. At this level, industry 

cash flow decreases by approximately 205.8 percent, to -$22.67 million, compared to the basecase value of $22.38 million in the year leading up to the energy conservation standards. TSL 6 

represents an efficiency increase of 33 percent over the baseline for CSIR motors and 23 percent 

over the baseline for CSCR motors. 

Currently, the market does not have any CSIR and CSCR motors that reach TSL 6. TSL 6 

represents the max-tech efficiency level for both CSIR and CSCR motors. In addition to the 

possibility of using copper rotors for both CSIR and CSCR motors, at TSL 6, space-constrained 

motor designs could require premium steels, such as Hiperco. There is uncertainty about the 

impact of Hiperco steel on the industry, primarily due to uncertainty about capital conversion 

costs required to use a new type of steel. Significant R&D in manufacturing processes would be 

necessary to understand the applications of these premium steels in general purpose small 

electric motors. Because all space-constrained motors could require copper rotors and premium 

steels and all non-spaced constrained motors could require copper rotors, the capital conversion 

costs are a significant driver of INPV at TSL 6. Finally, the production costs of motors that meet 

TSL 6 can be as high as 13 times the production cost of baseline motors, which impact 

profitability if the higher production costs cannot be fully passed through to OEMs. 

Manufacturers indicated that the potentially large impacts on the industry at TSL 6 could force 

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some manufacturers to exit the small electric motor market because of the lack of resources and 


what could be an unjustifiable investment for a small segment of their total business. 

At TSL 7, DOE estimated the impacts in INPV to range from $18.40 million to -$34.05 

million, or a change in INPV of 6.59 percent to -12.20 percent. At this level, industry cash flow 

decreases by approximately 74.7 percent, to $5.66 million, compared to the base-case value of 

$22.38 million in the year leading up to the energy conservation standards. TSL 7 represents an 

efficiency increase of 33 percent over the baseline for CSIR motors and 13 percent over the 

baseline for CSCR motors. 

TSL 7 corresponds to the NEMA premium equivalent efficiency for CSCR motors. The 

required efficiencies for space-constrained CSCR motors could be met by manufacturers by 

increasing the number of laminations by 15 percent and using higher steel grades. The required 

efficiencies for non space-constrained CSCR motors could be met by increasing the number of 

laminations by 53 percent. Consequently, the industry is not severely impacted by the CSCR 

efficiency requirements at TSL 7 because these design changes could be met with relatively 

minor changes to baseline designs. 

However, there are no CSIR motors currently on the market that reach TSL 7 (the maxtech efficiency level for CSIR). At TSL 7 space-constrained CSIR redesigns could require the 

use of both copper rotors and premium steels while non space-constrained CSIR motors could 

require only copper rotors. Manufacturers continue to have the same concerns about copper 

rotors and premium steels for CSIR motors as with other efficiency levels that may require these 

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technologies. The impacts on INPV from CSIR motors are mainly associated with estimated 


shipments of non-space constrained CSIR motors and how investments exclude premium steels 

in motor redesigns. The INPV impacts for all single-phase motors at TSL 7 are less severe than 

at TSL 6 due to a change in balance of shipments between CSIR and CSCR motors. At TSL 7, 

the possible high cost of CSIR motors would likely cause customers to migrate to CSCR motors. 

In its analysis, DOE assumed that manufacturers would not invest in all the alternative 

technologies for CSIR motors in light of the expected migration to CSCR motors. At TSL 7, the 

industry is impacted (though to a lesser extent than at TSL 6) by the high conversion costs for 

CSIR motors, for which manufacturers must invest even though these are a small portion of total 

shipments after standards. However, because the total volume of single-phase motors does not 

decline with the shift from CSIR to CSCR motors, the higher revenues from standards-compliant 

CSCR motors mitigate redesign costs for CSIR motors. 

At TSL 8, DOE estimated the impacts in INPV to range from $46.35 million to -$52.58 

million, or a change in INPV of 13.07 percent to -16.17 percent. At this level, industry cash flow 

decreases by approximately 92.1 percent, to $1.77 million, compared to the base-case value of 

$22.38 million in the year leading up to the compliance date for the energy conservation 

standards. TSL 8 represents an efficiency increase of 33 percent over the baseline for CSIR 

motors and 20 percent over the baseline for CSCR motors. 

As with TSL 7, CSIR motors are at the max-tech efficiency level at TSL 8. However, the 

impacts on INPV are worse at TSL 7 because the efficiency requirements for CSCR motors 

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increase. At TSL 8, both space-constrained and non space-constrained CSCR motors could 


require the use of copper, which increases the total conversion costs for the industry. 

Manufacturers continue to share the same concerns about the copper and premium steel 

investments for CSCR and CSIR motors as at TSL 6 and TSL 7. Like TSL 7, TSL 8 causes a 

migration of CSIR motors to CSCR motors. DOE assumed that manufacturers would fully incur 

the required conversion costs for CSCR, but partially for CSIR motors, due to the low market 

share of CSIR motors after the energy conservation standards must be met. After these standards 

apply, the shift to CSCR motors increases total industry revenue and helps to mitigate impacts 

related to capital conversion costs necessary for CSIR motors to use alternative technologies. 

b. Impacts on Employment 

As discussed in the NOPR and for today’s final rule, DOE does not believe that standards 

would materially alter the domestic employment levels of the small electric motors industry 

under any of the TSLs considered for today’s final rule. 74 FR 61469. Even if DOE set new 

efficiency levels high enough to cause some manufacturers to exit the small electric motor 

market, the direct employment impact would likely be minimal. Id. Most covered small motors 

are manufactured on shared production lines and in factories that also produce a substantial 

number of other products. If a manufacturer decided to exit the market, these employees would 

likely be used in some other capacity, reducing the number of headcount reductions. These 

manufacturers estimated that no production jobs would be lost due to energy conservation 

standards, but rather the engineering departments could be reduced by up to one engineer per 

dropped product line. 

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The employment impacts calculated by DOE are independent of the employment impacts 


from the broader U.S. economy, which are documented in chapter 15 of the TSD accompanying 

this notice and discussed in section VI.C.3. Based on available data and its analyses, DOE does 

not believe that the effects of today's rule would substantially impact employment levels in the 

small electric motor industry. For further information and results on direct employment see 

chapter 12 of the TSD. 

c. Impacts on Manufacturing Capacity 

As detailed in the NOPR, no change in the fundamental assembly of small electric motors 

would be required by DOE adoption of any of the TSLs considered for today’s rule, and none of 

the TSLs would require replacing or adding to existing facilities to manufacture. 74 FR 61469­

70. For today’s final rule, DOE continues to believe manufacturers can use any available excess 

capacity to mitigate any possible capacity constraint as a result of energy conservation standards. 

In DOE's view, it is more likely that some motors would be discontinued due to lower demand 

after the promulgation of a standard. For further explanation of the impacts on manufacturing 

capacity for small electric motors, see chapter 12 of the TSD. 

d. Impacts on Subgroups of Manufacturers 

For the reasons stated in the NOPR, including its conclusion that no small manufacturers 

produced small electric motors, DOE did not analyze manufacturer subgroups in the small 

electric motor industry. 74 FR 61470. DOE did not receive further information or comment that 

would otherwise change its views. 

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e. Cumulative Regulatory Burden
 

While any one regulation may not impose a significant burden on manufacturers, the combined 

effects of several 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. 

DOE recognizes that each regulation can significantly affect manufacturers’ financial 

operations. Multiple regulations affecting the same manufacturer can reduce manufacturers’ 

profits and may cause manufacturers to exit from the market. DOE did not identify any 

additional DOE regulations that would affect the manufacturers of small electric motors apart 

from the ones discussed in the NOPR. 74 FR 61470. These included other DOE regulations and 

international standards. DOE recognizes that each regulation has the potential to impact 

manufacturers’ financial operations. For further information about the cumulative regulatory 

burden on the small electric motors industry, see chapter 12 of the TSD. 

3. National Net Present Value and Net National Employment 

The NPV analysis estimates the cumulative benefits or costs to the Nation, 

discounted to 2009$ in the year 2010, of particular standard levels relative to a base case of no 

new standard. In accordance with OMB guidelines on regulatory analysis (OMB Circular A–4, 

section E, September 17, 2003), DOE estimated NPVs using both a 7 percent and 3 percent real 

discount rate. The 7 percent rate is an estimate of the average before tax rate of return to private 

capital in the U.S. economy. This rate reflects the returns to real estate and small business capital 

as well as corporate capital. DOE used this discount rate to approximate the opportunity cost of 

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capital in the private sector, since recent OMB analysis has found the average rate of return to 

capital to be near this rate. DOE also used the 3 percent discount rate to capture the potential 

effects of standards on private consumption (e.g., through higher prices for equipment and 

purchase of reduced amounts of energy). This rate represents the rate at which society discounts 

future consumption flows to their present value. This rate can be approximated by the real rate of 

return on long-term Government debt (e.g., the yield on Treasury notes minus the annual rate of 

change in the Consumer Price Index), which has averaged about 3 percent on a pre-tax basis for 

the last 30 years. 

The NPV was calculated using DOE’s reference shipments forecast, which is based on the 

AEO 2010 Early Release forecast. In this scenario, shipments display an elasticity of -0.25, 

which allows for a market shift to enclosed motors when open motors become more expensive 

than their enclosed equivalents. DOE used its calibrated reference model for the market 

dynamics of CSIR and CSCR motors. DOE’s reference scenario also includes 100 percent of the 

cost or benefit from changes in reactive power charges, which are faced either by electricity 

customers or by utilities (which then include them in electricity rates). Table VI.25 and Table 

VI.26show the estimated NPV at each of the TSLs for polyphase and capacitor-start small 

electric motors. For polyphase motors, the NPV is positive at TSLs 1 through 5 using a 7-percent 

discount rate, and is positive for TSLs 1 through 6 using a 3-percent discount rate. For capacitorstart motors, NPV is positive at all TSLs except TSL 6. The latter TSL corresponds to max-tech 

efficiency levels for both CSIR and CSCR motors, which have high installed costs and negative 

lifecycle cost savings. See TSD Chapter 10 for more detailed NPV results. 

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Across motors, for certain TSLs, DOE estimates there will be a net national savings or 


positive NPV from the standard, even though a majority of motor customers may face life-cycle 

cost increases. Life-cycle cost increases result from the large number of small electric motors 

installed in applications with very low operating hours. The consumers of these motors cannot 

recover the increased equipment costs through decreased electricity costs, thus experiencing lifecycle cost increases. On the other hand, a substantial minority of motors run at nearly all hours of 

the day and thus obtain relatively large savings from the standard. 

Table VI.25 and Table VI.26 show DOE’s estimates of net present value for each TSL 

DOE considered for this final rule. 

Table VI.25 Cumulative Net Present Value for Polyphase Small Electric Motors (Impact 

for Equipment Sold from 2015 to 2045) 

Trial Standard Level 

Net Present Value 

billion 2009$ 

7% Discount Rate 3% Discount Rate 

1 0.10 0.26 

2 0.22 0.55 

3 0.41 1.01 

4 0.42 1.05 

4b 0.54 1.44 

5 0.16 0.77 

6 -0.22 0.06 

7 -6.82 -12.65 

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Table VI.26 Cumulative Net Present Value for Capacitor-Start Small Electric Motors 

(Impact for Equipment Sold from 2015 to 2045) 

Trial Standard Level 

Net Present Value 

billion 2009$ 

7% Discount Rate 3% Discount Rate 

1 3.01 7.03 

2 3.05 7.13 

3 2.83 6.87 

4 1.97 5.35 

5 2.08 5.57 

6 -9.29 -16.23 

7 4.74 11.08 

8 3.03 8.14 

As discussed in section VI.C.1.b above, DOE estimated LCC and payback periods under 

a sensitivity case using data on motor shipments distributions provided by OEMs via a survey 

conducted by NEMA. Under this sensitivity case lifecycle costs increase for polyphase and 

CSCR motor users, but decrease for CSIR motor users. DOE estimates there is a net increase in 

national benefits from the standards promulgated in today’s rule using the new information 

provided by NEMA, with energy savings increasing from 2.20 to 2.68 quads, and NPV 

increasing from $12.52 to $19.75 billion, using a 3 percent discount rate. 

DOE also analyzed the effect of NEMA’s assertion that 95 percent of motors are used in 

space-constrained applications. However, at the capacitor-start efficiency levels in today’s rule, 

DOE estimates that 97 percent of the CSIR market will migrate to CSCR motors assuming only 

20 percent of the market is space-constrained. Therefore, increasing the assumption of the 

fraction of CSIR motors that is space-constrained to 95-percent only affects the 3-percent of the 

CSIR market that had not already migrated to CSCR motors under DOE’s reference case, and 

has little effect on the estimates of national energy savings. 

Chapter 10 of the TSD has details on the national impacts for the reference case, while 

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the national impacts for these sensitivity cases are presented in appendix 10A. 


DOE also estimated for each TSL the indirect employment impact of standards – the 

impact on the economy in general – in addition to considering the direct employment impacts on 

manufacturers of products covered in this rulemaking as discussed in section VI.C.2.b. DOE 

expects the net monetary savings from standards to be redirected to other forms of economic 

activity. DOE also expects these shifts in spending and economic activity to affect the demand 

for labor. As shown in Table VI.27 and Table VI.28, DOE estimates that net indirect 

employment impacts from energy conservation standards for small electric motors would be 

positive but very small relative to total national employment. Specifically, DOE’s analysis 

indicates that the number of jobs that may be generated by 2045 through indirect impacts ranges 

from 47 to 6,300 for the TSLs for polyphase small motors, and from 1,100 to 18,700 for the 

TSLs for capacitor-start small motors. These increases would likely be sufficient to offset fully 

any adverse impacts on employment that might occur in the small electric motors industry. For 

details on the employment impact analysis methods and results, see TSD Chapter 14. 

Table VI.27 Net Increase in National Indirect Employment Under Polyphase Small 

Electric Motor Trial Standards Levels 

Trial Standard 

Level 

2015 

thousands 

2020 

thousands 

2030 

thousands 

2045 

thousands 

1 0.047 0.136 0.222 0.299 

2 0.084 0.254 0.418 0.565 

3 0.151 0.463 0.761 1.030 

4 0.190 0.539 0.874 1.178 

4b 0.356 0.915 1.446 1.942 

5 0.661 1.347 2.016 2.668 

6 0.901 1.679 2.448 3.219 

7 2.349 3.621 4.921 6.343 

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Table VI.28 Net Increase in National Indirect Employment Under Capacitor-Start Small 

Electric Motor Trial Standards Levels 

Trial Standard 

Level 

2015 

thousands 

2020 

thousands 

2030 

thousands 

2045 

thousands 

1 1.113 3.645 5.249 7.062 

2 1.119 3.674 5.293 7.123 

3 1.577 4.512 6.398 8.557 

4 2.287 5.561 7.716 10.236 

5 2.248 5.529 7.686 10.204 

6 8.042 12.159 15.350 19.569 

7 1.776 5.795 8.340 11.216 

8 2.322 9.591 13.880 18.701 

4. Impact on Utility or Performance of Equipment 

As explained in sections III.D.1.d and V.B.4 of the NOPR, users of these motors will not 

face a reduction in small electric motor utility or performance under the levels examined under 

this rulemaking. DOE has not received any additional information suggesting that such a 

reduction would occur. Accordingly, DOE has concluded that no lessening of the utility or 

performance of the small electric motors under consideration in this rulemaking would result 

from adoption of any of the TSLs considered for this final rule. 74 FR 61419, 61476. 

5. Impact of Any Lessening of Competition 

As discussed in the November 2009 NOPR, 74 FR 61419, 61476, and in section III.D.1.e 

of this final rule, DOE considers any lessening of competition that is likely to result from 

standards. The Attorney General determines the impact, if any, of any such lessening of 

competition. 

The DOJ concluded that the standards DOE proposed for small electric motors in the 

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November 2009 NOPR could increase costs for consumers who need to replace either a 


polyphase or capacitor-start small electric motor in existing equipment. This is because 

compliance with these standards may require manufacturers to increase the size of their motors 

such that the larger motors may not fit into existing space-constrained equipment. In turn, 

owners with a broken motor may need to replace the entire piece of equipment or attempt to have 

the motor repaired, which could be costly. DOJ requested that DOE consider this impact, and, as 

warranted, consider exempting from the standard the manufacture and marketing of certain 

replacement small electric motors for a limited period of time. (DOJ, No. 29 at pp. 1-2) DOJ 

does not believe the proposed standard would likely lead to a lessening of competition. 

For its final rule on energy conservations standards for small electric motors, DOE 

considered the issue raised by DOJ. DOE believes it adequately accounts for the impacts on 

those consumers that purchase motors for space-constrained applications by developing motors 

with higher costs for what it estimates as space-constrained. Furthermore, DOE does not believe 

it is necessary to exempt motors manufactured to replace motors in space-constrained 

applications because these motors are not marketed as “for replacement purposes,” enforcing 

such a standard could be problematic. In addition, an exemption for replacement motors would 

also apply to motors in non-space constrained applications potentially significantly reducing 

energy savings of this rule. Lastly, DOE believes that the five-year period before the effective 

date will give customers or OEMs sufficient time to account for any changes to motor sizes or to 

stockpile replacement motors for their applications. 

The Attorney General’s response is reprinted at the end of this rule. 

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6. Need of the Nation To Conserve Energy 

Improving the energy efficiency of small electric motors, where economically justified, 

would likely improve the security of the Nation’s energy system by reducing overall demand for 

energy, thus reducing the Nation’s reliance on foreign sources of energy. Reduced electricity 

demand might also improve the reliability of the electricity system, particularly during peak-load 

periods. As a measure of this reduced demand, DOE expects the energy savings from today’s 

standards to eliminate the need for approximately 2.16 gigawatts (GW) of generating capacity by 

2045 and in 2045, to save an amount of electricity greater than that generated by eight 250 

megawatt power plants. 

Enhanced energy efficiency also produces environmental benefits in the form of reduced 

emissions of air pollutants and greenhouse gases associated with energy production. Table VI.29 

and Table VI.30 provide DOE’s estimate of cumulative CO2, NOX, and Hg emissions reductions 

that would result from the TSLs considered in this rulemaking. The expected energy savings 

from these standards may also reduce the cost of maintaining nationwide emissions standards 

and constraints. In the environmental assessment (EA; chapter 15 of the TSD accompanying this 

notice), DOE reports estimated annual changes in CO2, NOX, and Hg emissions attributable to 

each TSL. The cumulative CO2, NOX, and Hg emissions reductions from polyphase motors 

range up to 23.2 Mt, 16.9 kt, and 0.12 ton, respectively, and up to 121.7 Mt, 88.9 kt, and 0.47 

ton, respectively, from single-phase motors. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

Table VI.29 Polyphase Small Electric Motors: Cumulative CO2 and Other Emissions 

Reductions (Cumulative Reductions for Products Sold from 2015 to 2045) 

Trial Standard 

Level 

Emissions Reductions 

CO2 

Mt 

NOx 

kt 

Hg 

tons 

1 2.3 1.6 0.013 

2 4.6 3.3 0.025 

3 8.3 5.9 0.046 

4 9.3 6.7 0.051 

4b 15.4 11.0 0.085 

5 18.3 13.1 0.101 

6 19.5 13.9 0.108 

7 21.2 15.2 0.117 

Table VI.30 Capacitor-Start Small Electric Motors: Cumulative CO2 and Other Emissions 

Reductions (Cumulative Reductions for Products Sold from 2015 to 2045) 

Trial Standard 

Level 

Emissions Reductions 

CO2 

Mt 

NOx 

kt 

Hg 

tons 

1 62.9 45.1 0.265 

2 63.5 45.5 0.267 

3 71.7 51.4 0.302 

4 80.5 57.7 0.339 

5 81.0 58.1 0.341 

6 88.5 63.5 0.373 

7 96.8 69.5 0.408 

8 111.4 80.0 0.469 

As noted in section IV.L of this final rule, DOE does not report SO2 emissions reductions 

from power plants because DOE is uncertain that an energy conservation standard would affect 

the overall level of U.S. SO2 emissions due to emissions caps. DOE also did not include NOX 

emissions reduction from power plants in states subject to CAIR because an energy conservation 

standard would likely not affect the overall level of NOX emissions in those states due to the 

emissions caps mandated by CAIR. 

In the NOPR, DOE also investigated and considered the potential monetary benefit of 

any reduced CO2, SO2, NOX, and Hg emissions that could result from the TSLs it considered. 74 

FR 61448-53, 61477-84. To estimate the likely monetary benefits of CO2 emission reductions 

200
 

EERE-2007-BT-STD-0007 COMMENT 31
associated with the potential standards, DOE valued the potential global benefits resulting from 


such reductions at the interim values of $5, $10, $20, $34 and $57 per metric ton in 2007 (in 

2008$), and also valued the domestic benefits at approximately $1 per metric ton. 74 FR 61452. 

For today’s final rule DOE has updated its analysis to reflect the outcome of the most recent 

interagency process regarding the social cost of carbon dioxide emissions (SCC). See section 

IV.M for a full discussion. The four values of CO2 emissions reductions resulting from that 

process are $4.70/ton (the average value from a distribution that uses a 5% discount rate), 

$21.40/ton (the average value from a distribution that uses a 3% discount rate), $35.10/ton (the 

average value from a distribution that uses a 2.5% discount rate), and $65/ton (the 95th percentile 

value from a distribution that uses a 3% discount rate). These values are expressed in 2007$ and 

correspond to the value of emission reductions in 2010; the values for later years are higher due 

to increasing damages as the magnitude of climate change increases. Table VI.31 and Table 

VI.32 present the global values of emissions reductions at each TSL. Domestic values are 

calculated as a range from 7% to 23% of the global values, and these results are presented in 

Table VI.33 and Table VI.34. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

 

 

Table VI.31 Estimates of Global Present Value of CO2 Emissions Reductions for the 

Period 2015-2045 Under Polyphase Small Electric Motor Trial Standard Levels at SCCScenario-Consistent Discount Rate 

TSL 

Estimated 

Cumulative 

CO2 

Emission 

Reductions, 

Mt 

Global Value of CO2 Emission Reductions, Million 2009$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount 

rate, 95th 

percentile* 

1 2.3 8 40 68 122 

2 4.6 16 81 138 248 

3 8.3 28 146 248 445 

4 9.3 32 165 280 502 

4b 15.4 52 272 462 828 

5 18.3 62 323 550 986 

6 19.5 66 344 585 1049 

7 21.2 72 375 638 1144 

* Columns are labeled by the discount rate used to calculate the social cost of emissions and whether it is an average 

value or drawn from a different part of the distribution. Values presented in the table are based on escalating 2007$ 

to 2009$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC with 

each year. 

Table VI.32 Estimates of Global Present Value of CO2 Emissions Reductions for the 

Period 2015-2045 Under Capacitor-Start Small Electric Motor Trial Standard Levels at 

SCC-Scenario-Consistent Discount Rate 

TSL 

Estimated 

Cumulative 

CO2 

Emission 

Reductions, 

Mt 

Global Value of CO2 Emission Reductions, Million 2009$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount 

rate, 95th 

percentile* 

1 62.9 216 1118 1900 3410 

2 63.5 218 1129 1918 3444 

3 71.7 246 1275 2167 3890 

4 80.5 277 1432 2432 4367 

5 81.0 278 1441 2448 4394 

6 88.5 304 1574 2674 4801 

7 96.8 333 1722 2926 5253 

8 111.4 383 1982 3368 6046 

* Columns are labeled by the discount rate used to calculate the social cost of emissions and whether it is an average 

value or drawn from a different part of the distribution. Values presented in the table are based on escalating 2007$ 

to 2009$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC with 

each year. 

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EERE-2007-BT-STD-0007 COMMENT 31
Table VI.33 Estimates of Domestic Present Value of CO2 Emissions Reductions for the 

Period 2015-2045 Under Polyphase Small Electric Motor Trial Standard Levels at SCCScenario-Consistent Discount Rate 

TSL 

Domestic Value of CO2 Emission Reductions, Million 2009$ * 

5% discount 

rate, 

average** 

3% discount 

rate, 

average** 

2.5% discount 

rate, average** 

3% discount 

rate, 95th 

percentile** 

1 0.5 – 1.8 2.8 – 9.2 4.8 – 15.7 8.5 – 28.1 

2 1.1 – 3.6 5.7 – 18.7 9.7 – 31.8 17.3 – 57.0 

3 2.0 – 6.4 10.2 – 33.5 17.4 – 57.1 31.1 – 102.3 

4 2.2 – 7.3 11.5 – 37.9 19.6 – 64.4 35.1 – 115.5 

4b 3.7 – 12 19.0 – 62.5 32.3 – 106.3 58.0 – 190.5 

5 4.3 – 14.3 22.6 – 74.4 38.5 – 126.5 69.0 – 226.8 

6 4.6 – 15.2 24.1 – 79.1 41.0 – 134.6 73.4 – 241.2 

7 5.0 – 16.6 26.3 – 86.3 44.7 – 146.7 80.1 – 263.0 

* Domestic values are presented as a range between 7% and 23% of the global values. 

** Columns are labeled by the discount rate used to calculate the social cost of emissions and whether it is an 

average value or drawn from a different part of the distribution. Values presented in the table are based on escalating 

2007$ to 2009$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

with each year. 

Table VI.34 Estimates of Domestic Present Value of CO2 Emissions Reductions for the 

Period 2015-2045 Under Capacitor-Start Small Electric Motor Trial Standard Levels at 

SCC-Scenario-Consistent Discount Rate 

TSL 

Domestic Value of CO2 Emission Reductions, Million 2009$ * 

5% discount 

rate, 

average** 

3% discount 

rate, 

average** 

2.5% discount 

rate, average** 

3% discount 

rate, 95th 

percentile** 

1 15 – 50 78 – 257 133 – 437 239 – 784 

2 15 – 50 79 – 260 134 – 441 241 – 792 

3 17 – 57 89 – 293 152 – 498 272 – 895 

4 19 – 64 100 – 329 170 – 559 306 – 1004 

5 19 – 64 101 – 331 171 – 563 308 – 1011 

6 21 – 70 110 – 362 187 – 615 336 – 1104 

7 23 – 77 121 – 396 205 – 673 368 – 1208 

8 27 – 88 139 – 456 236 – 775 423 – 1391 

* Domestic values are presented as a range between 7% and 23% of the global values. 

** Columns are labeled by the discount rate used to calculate the social cost of emissions and whether it is an 

average value or drawn from a different part of the distribution. Values presented in the table are based on escalating 

2007$ to 2009$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

with each year. 

DOE is well aware that scientific and economic knowledge about the contribution of CO2 

and other GHG emissions to changes in the future global climate and the potential resulting 

203
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

damages to the world economy continues to evolve rapidly. Thus, any value placed in this 


rulemaking on reducing CO2 emissions 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 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 

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 and Hg emissions reductions anticipated to result from amended standards 

for SEMs. The dollar per ton values that DOE used are discussed in section IV.M of this final 

rule. Table VI.35 through Table VI.38 present the estimates calculated using seven percent and 

three percent discount rates, respectively. 

Table VI.35 Estimates of Value of Reductions of NOx and Hg Emissions Under Polyphase 

Small Electric Motor Trial Standard Levels at a Seven Percent Discount Rate 

Polyphase 

TSL 

Cumulative NOx 

Emission 

Reductions, kt 

Value of NOx 

Emission 

Reductions, 

million 2009$ 

Cumulative Hg 

Emission 

Reductions, t 

Value of Hg 

Emission 

Reductions, 

million 2009$ 

1 1.62 0.11 to 1.18 0.013 0.00 to 0.12 

2 3.29 0.23 to 2.39 0.025 0.01 to 0.25 

3 5.91 0.42 to 4.29 0.046 0.01 to 0.45 

4 6.67 0.47 to 4.84 0.051 0.01 to 0.51 

4b 11.00 0.78 to 7.99 0.085 0.02 to 0.84 

5 13.09 0.92 to 9.51 0.101 0.02 to 1.00 

6 13.93 0.98 to 10.11 0.108 0.02 to 1.06 

7 15.19 1.07 to 11.03 0.117 0.03 to 1.16 

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EERE-2007-BT-STD-0007 COMMENT 31
Table VI.36 Estimates of Value of Reductions of NOx and Hg Emissions Under Polyphase 

Small Electric Motor Trial Standard Levels at a Three Percent Discount Rate 

Polyphase

 TSL 

Cumulative NOx 

Emission 

Reductions, kt 

Value of NOx 

Emission 

Reductions, 

million 2009$ 

Cumulative Hg 

Emission 

Reductions, t 

Value of Hg 

Emission 

Reductions, 

million 2009$ 

1 1.62 0.34 to 3.46 0.013 0.01 to 0.24 

2 3.29 0.68 to 7.01 0.025 0.01 to 0.48 

3 5.91 1.22 to 12.59 0.046 0.02 to 0.87 

4 6.67 1.38 to 14.21 0.051 0.02 to 0.98 

4b 11.00 2.28 to 23.45 0.085 0.04 to 1.62 

5 13.09 2.71 to 27.90 0.101 0.04 to 1.93 

6 13.93 2.89 to 29.68 0.108 0.05 to 2.05 

7 15.19 3.15 to 32.37 0.117 0.05 to 2.24 

Table VI.37 Estimates of Value of Reductions of NOx and Hg Emissions Under CapacitorStart Small Electric Motor Trial Standard Levels at a Seven Percent Discount Rate 

CapacitorStart TSL 

Cumulative NOx 

Emission 

Reductions, kt 

Value of NOx 

Emission 

Reductions, 

million 2009$ 

Cumulative Hg 

Emission 

Reductions, t 

Value of Hg 

Emission 

Reductions, 

million 2009$ 

1 45.10 3.50 to 35.97 0.265 0.06 to 2.79 

2 45.54 3.53 to 36.23 0.267 0.06 to 2.82 

3 51.44 3.99 to 41.03 0.302 0.07 to 3.18 

4 57.74 4.48 to 46.05 0.339 0.08 to 3.57 

5 58.11 4.51 to 46.34 0.341 0.08 to 3.60 

6 63.48 4.93 to 50.63 0.373 0.09 to 3.93 

7 69.47 5.39 to 55.40 0.408 0.10 to 4.30 

8 79.95 6.20 to 63.76 0.469 0.11 to 4.95 

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EERE-2007-BT-STD-0007 COMMENT 31
Table VI.38 Estimates of Value of Reductions of NOx and Hg Emissions Under CapacitorStart Small Electric Motor Trial Standard Levels at a Three Percent Discount Rate 

CapacitorStart TSL 

Cumulative 

NOx Emission 

Reductions (kt) 

Value of NOx 

Emission 

Reductions 

(million 2009$) 

Cumulative Hg 

Emission 

Reductions (t) 

Value of Hg 

Emission 

Reductions 

(million 2009$) 

1 45.10 9.60 to 98.70 0.265 0.12 to 5.22 

2 45.54 9.69 to 99.66 0.267 0.12 to 5.27 

3 51.44 10.95 to 112.58 0.302 0.13 to 5.95 

4 57.74 12.29 to 126.37 0.339 0.15 to 6.68 

5 58.11 12.37 to 127.17 0.341 0.15 to 6.72 

6 63.48 13.52 to 138.94 0.373 0.17 to 7.34 

7 69.47 14.79 to 152.03 0.408 0.18 to 8.04 

8 79.95 17.02 to 174.97 0.469 0.21 to 9.25 

The NPV of the monetized benefits associated with emissions reductions can be viewed 

as a complement to the NPV of the consumer savings calculated for each TSL considered in this 

rulemaking. Table VI.40 through Table VI.43 present the NPV values for small electric motors 

that would result if DOE were to add the estimates of the potential benefits resulting from 

reduced CO2, NOX, and Hg emissions in each of four valuation scenarios to the NPV of 

consumer savings calculated for each TSL considered in this rulemaking, at both a seven percent 

and three percent discount rate. The CO2 values used in the columns of each table correspond 

with the four scenarios for the valuation of CO2 emission reductions presented in section IV.M. 

Table VI.39 shows an example of the calculation of the NPV including benefits from emissions 

reductions for the case of TSL 7 for capacitor-start motors and TSL 4b for polyphase motors. 

Although adding the value of consumer savings to the values of emission reductions 

provides a valuable perspective, the following should be considered: 1) The national consumer 

savings are domestic U.S. consumer monetary savings found in market transactions, while the 

values of emissions reductions are based on estimates of marginal social costs, which, in the case 

of CO2, are based on a global value. 2) The assessments of consumer savings and emission206
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

 

 

 

 

related benefits are performed with different computer models, leading to different time frames 

for analysis. For small electric motors, the present value of national consumer savings is 

measured for the period in which units shipped from 2015 to 2045 continue to operate. However, 

the time frames of the benefits associated with the emission reductions differ. For example, the 

value of CO2 emissions reductions reflects the present value of all future climate-related impacts 

due to emitting a ton of carbon dioxide in that year, out to 2300. 

Table VI.39 Estimate of Adding Net Present Value of Consumer Savings to Present Value 

of Global Monetized Benefits from CO2, NOx, and Hg Emissions Reductions at TSL 7 for 

Capacitor-Start Motors and TSL 4b for Polyphase Motors (2015-2045) 

Category Present Value 

billion 2009$ Discount Rate 

Benefits 

Operating Cost Savings 7.6 7% 

17.1 3% 

CO2 Monetized Value 

(at $4.7/Metric Ton)* 0.38 5% 

CO2 Monetized Value 

(at $21.4/Metric Ton)* 1.99 3% 

CO2 Monetized Value

 (at $35.1/Metric Ton)* 3.39 2.5% 

CO2 Monetized Value 

(at $64.9/Metric Ton)* 6.08 3% 

NOx Monetized Value 

(at $2,437/Metric Ton) 

0.03 7% 

0.10 3% 

Hg Monetized Value 

(at $17 million/Metric Ton) 

0.003 7% 

0.005 3% 

Total Monetary Benefits ** 

9.7 7% 

19.2 3% 

Costs 

Total Monetary Costs 2.4 7% 

4.5 3% 

Net Benefits/Costs 

Including CO2, NOx, and Hg** 7.3 7% 

14.6 3% 

* These values represent global values (in 2007$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.7, $21.4, and $35.1 per ton are the averages of SCC distributions calculated using 5%, 

3%, and 2.5% discount rates, respectively. The value of $64.9 per ton represents the 95th percentile of the SCC 

207 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

distribution calculated using a 3% discount rate. See section IV.M for details. 


** Total Monetary Benefits for both the 3% and 7% cases utilize the central estimate of social cost of CO2 emissions
 

calculated at a 3% discount rate (averaged across three IAMs), which is equal to $21.4/ton in 2010 (in 2007$). 


Table VI.40 Estimates of Adding Net Present Value of Consumer Savings (at 7% Discount 

Rate) to Net Present Value of Low, Central, and High-End Global Monetized Benefits from 

CO2, NOx, and Hg Emissions Reductions at All Trial Standard Levels for Polyphase Small 

Electric Motors (2015-2045) 

TSL 

Consumer NPV at 7% Discount Rate added with: 

CO2 Value of 

$4.7/metric ton 

CO2* and Low 

Values for NOx 

and Hg** 

billion 2009$ 

CO2 Value of 

$21.4/metric ton 

CO2* and Medium 

Values for NOx and 

Hg*** 

billion 2009$ 

CO2 Value of 

$35.1/metric ton 

CO2* and Medium 

Values for NOx 

and Hg*** 

billion 2009$ 

CO2 Value of 

$64.9/metric ton 

CO2* and High 

Values for NOx 

and Hg**** 

billion 2009$ 

1 0.11 0.14 0.17 0.22 

2 0.24 0.30 0.36 0.47 

3 0.44 0.56 0.66 0.86 

4 0.45 0.59 0.70 0.93 

4b 0.59 0.82 1.01 1.38 

5 0.22 0.49 0.72 1.16 

6 (0.15) 0.13 0.37 0.84 

7 (6.75) (6.44) (6.18) (5.66) 

* These label values per ton represent the global negative externalities of CO2 in 2010, in 2007$. Their present 


values have been calculated with scenario-consistent discount rates. See section IV.M for a full discussion of the 


derivation of these values.
 

** Low Values correspond to $447 per ton of NOx emissions and $0.764 million per ton of Hg emissions. 


*** Medium Values correspond to $2,519 per ton of NOx emissions and $17.2 million per ton of Hg emissions. 


**** High Values correspond to $4,591 per ton of NOx emissions and $33.7 million per ton of Hg emissions.
 

Table VI.41 Estimates of Adding Net Present Value of Consumer Savings (at 3% Discount 

Rate) to Net Present Value of Low, Central, and High-End Global Monetized Benefits from 

CO2, NOx, and Hg Emissions Reductions at All Trial Standard Levels for Polyphase Small 

Electric Motors (2015-2045) 

TSL 

Consumer NPV at 3% Discount Rate added with: 

CO2 Value of 

$4.7/metric ton 

CO2* and Low 

Values for NOx 

and Hg** 

billion 2009$ 

CO2 Value of 

$21.4/metric ton 

CO2* and Medium 

Values for NOx and 

Hg*** 

billion 2009$ 

CO2 Value of 

$35.1/metric ton 

CO2* and Medium 

Values for NOx 

and Hg*** 

billion 2009$ 

CO2 Value of 

$64.9/metric ton 

CO2* and High 

Values for NOx 

and Hg**** 

billion 2009$ 

1 0.27 0.30 0.33 0.39 

208
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

2 0.57 0.64 0.69 0.81 

3 1.04 1.16 1.27 1.47 

4 1.08 1.22 1.34 1.57 

4b 1.49 1.73 1.92 2.29 

5 0.83 1.11 1.34 1.79 

6 0.13 0.42 0.66 1.14 

7 (12.57) (12.26) (11.99) (11.47) 

* These label values per ton represent the global negative externalities of CO2 in 2010, in 2007$. Their present 


values have been calculated with scenario-consistent discount rates. See section IV.M for a full discussion of the 


derivation of these values.
 

** Low Values correspond to $447 per ton of NOx emissions and $0.764 million per ton of Hg emissions. 


*** Medium Values correspond to $2,519 per ton of NOx emissions and $17.2 million per ton of Hg emissions. 


**** High Values correspond to $4,591 per ton of NOx emissions and $33.7 million per ton of Hg emissions.
 

Table VI.42 Estimates of Adding Net Present Value of Consumer Savings (at 7% Discount 

Rate) to Net Present Value of Low, Central, and High-End Global Monetized Benefits from 

CO2, NOx, and Hg Emissions Reductions at All Trial Standard Levels for Capacitor-Start 

Small Electric Motors (2015-2045) 

TSL 

Consumer NPV at 7% Discount Rate added with: 

CO2 Value of 

$4.7/metric ton 

CO2* and Low 

Values for NOx 

and Hg** 

billion 2009$ 

CO2 Value of 

$21.4/metric ton 

CO2* and Medium 

Values for NOx and 

Hg*** 

billion 2009$ 

CO2 Value of 

$35.1/metric ton 

CO2* and Medium 

Values for NOx 

and Hg*** 

billion 2009$ 

CO2 Value of 

$64.9/metric ton 

CO2* and High 

Values for NOx 

and Hg**** 

billion 2009$ 

1 3.23 4.15 4.93 6.46 

2 3.27 4.20 4.99 6.53 

3 3.08 4.13 5.02 6.76 

4 2.25 3.43 4.43 6.39 

5 2.36 3.55 4.56 6.52 

6 (8.98) (7.69) (6.59) (4.43) 

7 5.08 6.50 7.70 10.05 

8 3.42 5.05 6.44 9.14 

Table VI.43 Estimates of Adding Net Present Value of Consumer Savings (at 3% Discount 

Rate) to Net Present Value of Low, Central, and High-End Global Monetized Benefits from 

CO2, NOx, and Hg Emissions Reductions at All Trial Standard Levels for Capacitor-Start 

Small Electric Motors (2015-2045) 

TSL Consumer NPV at 3% Discount Rate added with: 

209
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

CO2 Value of 

$4.7/metric ton 

CO2* and Low 

Values for NOx 

and Hg** 

billion 2009$ 

CO2 Value of 

$21.4/metric ton 

CO2* and Medium 

Values for NOx and 

Hg*** 

billion 2009$ 

CO2 Value of 

$35.1/metric ton 

CO2* and Medium 

Values for NOx 

and Hg*** 

billion 2009$ 

CO2 Value of 

$64.9/metric ton 

CO2* and High 

Values for NOx 

and Hg**** 

billion 2009$ 

1 7.26 8.21 8.99 10.54 

2 7.36 8.32 9.11 10.68 

3 7.13 8.21 9.10 10.88 

4 5.64 6.85 7.86 9.85 

5 5.86 7.08 8.09 10.10 

6 (15.91) (14.58) (13.48) (11.28) 

7 11.43 12.89 14.09 16.49 

8 8.54 10.22 11.61 14.37 

* These label values per ton represent the global negative externalities of CO2 in 2010, in 2007$. Their present 


values have been calculated with scenario-consistent discount rates. See section IV.M for a full discussion of the 


derivation of these values.
 

** Low Values correspond to $447 per ton of NOx emissions and $0.764 million per ton of Hg emissions. 


*** Medium Values correspond to $2,519 per ton of NOx emissions and $17.2 million per ton of Hg emissions. 


**** High Values correspond to $4,591 per ton of NOx emissions and $33.7 million per ton of Hg emissions.
 

7. Other Factors 

In developing today’s standards, the Secretary took into consideration the following 

additional factors: (1) harmonization of standards for small electric motors with existing 

standards under EPCA for medium-sized polyphase general purpose motors; (2) the impact, on 

consumers who need to use CSIR motors, of substantially higher prices for such motors caused 

by some potential standard levels; and (3) the potential for standards to reduce reactive power, 

and thereby cause lower costs for supplying electricity. 

D. Conclusion 

EPCA contains criteria for prescribing new or amended energy conservation standards. 

DOE must prescribe standards only for those small electric motors for which DOE: 1) has 

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EERE-2007-BT-STD-0007 COMMENT 31
 

determined that standards would be technologically feasible and economically justified and 


would result in significant energy savings, and 2) has prescribed test procedures. (42 U.S.C. 

6295(o)(2)(B), 6316(a), and 6317(b)) Moreover, any standards for this equipment must 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)) In determining whether a 

standard is economically justified, DOE must determine whether the benefits of the standard 

exceed its burdens when considering the seven factors discussed in section III.D.1. (42 U.S.C. 

6295(o)(2)(B)(i) and 6316(a)) 

In evaluating standards for small electric motors, DOE analyzed polyphase and capacitorstart motors independently of one another, and considered eight TSLs for polyphase equipment 

and eight TSLs for capacitor-start equipment. For reasons explained in the NOPR, DOE 

combined CSCR and CSIR motors into a single set of TSLs for capacitor-start motors, with each 

TSL being a combination of CSIR and CSCR efficiency levels. 74 FR 61484. 

In selecting today’s energy conservation standards for small electric motors, DOE started 

by examining the TSL with the highest energy savings, and determined whether that TSL was 

economically justified. Upon finding a TSL not to be justified, DOE considered sequentially 

lower TSLs until it identified the highest level that was economically justified. (Such level would 

necessarily also be technologically feasible and result in a significant conservation of energy 

because all of the TSLs considered for this final rule meet those criteria.) DOE notes that for 

polyphase small electric motors, the TSL with the highest energy savings is also the max-tech 

efficiency level, but, as explained in the NOPR, the same is not true for capacitor-start motors. 

211
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

74 FR 61484. 


. 

Table VI.44 and Table VI.45 summarize the results of DOE’s quantitative analysis, based 

on the assumptions and methodology discussed above, of each TSL DOE considered for this 

rule. They will aid the reader in the discussion of costs and benefits of each TSL. In some cases, 

the tables present a range of results. The range of values reported for industry impacts represents 

the results for the two markup scenarios – preservation-of-return-on-invested-capital and 

preservation-of-operating-profit (absolute dollars) – that DOE used to estimate manufacturer 

impacts. 

In addition to the quantitative results, DOE also considers other burdens and benefits that 

affect economic justification. These include pending standards for medium motors as a result of 

EISA 2007. 

1. Polyphase Small Electric Motors 

Table VI.44 presents a summary of the quantitative analysis results for each TSL for 

polyphase small electric motors. 

212
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

 

 

 

 

 

Table VI.44 Summary of Polyphase Small Electric Motors Analytical Results* 


Criteria Trial Standard Level 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 4b TSL 5 TSL 6 TSL 7 

Primary Energy Savings (quads) 0.05 0.09 0.17 0.19 0.29 0.34 0.37 0.37 

 @ 7% Discount Rate 0.01 0.02 0.04 0.05 0.07 0.09 0.09 0.09 

 @ 3% Discount Rate 0.03 0.05 0.09 0.10 0.15 0.18 0.19 0.20 

Generation Capacity Reduction (GW) 0.05 0.09 0.16 0.19 0.31 0.36 0.39 0.42 

NPV (2009$ billions) 

 @ 7% discount

 @ 3% discount 

0.10 

0.26 

0.22 

0.55 

0.41 

1.01 

0.42 

1.05 

0.54 

1.44 

0.16 

0.77 

(0.22) 

(0.06) 

(6.82) 

(12.65) 

Industry Impacts (0.19)­ 0.34­ 0.98­ 0.57­ 3.37­ 12.62­ 18.54­ 95.27­

 Change in INPV (2009$ millions) (1.49) (1.86) (2.26) (3.58) (5.43) (11.80) (17.51) (69.47) 

 Change in INPV (%) (0.27)­ 0.49­ 1.41­ 0.82­ 4.84­ 18.15­ 26.65­ 136.95­

(2.15) (2.67) (3.25) (5.15) (7.80) (16.96) (25.16) (99.85) 

Cumulative Emission Reduction

 CO2 (Mt) 2.3 4.6 8.3 9.3 15.4 18.3 19.5 21.2 

 Value of CO2 reductions (2009$ 8–122 16–248 28–445 32–502 52–828 62–986 66-1049 72-1144 

millions)**

 NOX (kt) 1.6 3.3 5.9 6.7 11.0 13.1 13.9 15.2 

 Value of NOX reductions at 7% 0.11 – 0.23 – 0.42 – 0.47 – 0.78 – 0.92 – 0.98 – 1.07 – 

discount rate (2009$ millions) 1.18 2.39 4.29 4.84 7.99 9.51 10.11 11.03 

 Value of NOX reductions at 3% 0.34 – 0.68 – 1.22 – 1.38 – 2.28 – 2.71 – 2.89 – 3.15 – 

discount rate (2009$ millions) 3.46 7.01 12.59 14.21 23.45 27.90 29.68 32.37 

 Hg (t) 0.013 0.025 0.046 0.051 0.085 0.101 0.108 0.117 

 Value of Hg reductions at 7% discount 0.00 – 0.01 – 0.01 – 0.01 – 0.02 – 0.02 – 0.02 – 0.03 – 

rate (2009$ millions) 0.12 0.25 0.45 0.51 0.84 1.00 1.06 1.16 

 Value of Hg reductions at 3% discount 0.01 – 0.01 – 0.02 – 0.02 – 0.04 – 0.04 – 0.05 – 0.05 – 

rate (2009$ millions) 0.24 0.48 0.87 0.98 1.62 1.93 2.05 2.24 

Life-cycle Cost of Rep. Product Class

 Customers with increase in LCC (%) 46.8 41.3 40.6 45.1 51.2 65.8 77.4 96.8 

 Customers with savings in LCC (%) 53.2 58.7 59.4 54.9 48.8 34.3 22.6 3.2 

 Mean LCC (2009$) 1,261 1,249 1,237 1,240 1,240 1,291 1,339 2,095 

 Mean LCC Savings (2009$) 

Life-cycle Cost of all Product Classes, 

Weighted by Shipments 

8 19 31 29 28 (23) (71) (827) 

 Customers with increase in LCC (%) 44.7 39.2 38.7 42.7 49.2 63.2 74.8 96.2 

 Customers with savings in LCC (%) 55.3 69.8 61.3 57.3 50.8 36.8 25.2 3.8 

 Mean LCC (2009$) 1,314 1,302 1,287 1,289 1,288 1,337 1,383 2,131 

 Mean LCC Savings (2009$) 9 22 36 34 36 (13) (60) (808) 

Payback Period (years) 

 Average

 Median 

21.1 

6.7 

17.3 

5.4 

17.2 

5.3 

19.8 

6.2 

24.1 

7.4 

40.2 

11.7 

52.6 

16.1 

234.6 

48.7 

Employment Impact 

 Indirect Impacts (2045) (jobs, ‘000) 0.30 0.57 1.03 1.18 1.94 2.67 3.22 6.34 

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the amount 


indicated. 


** Range of global values for the SCC of emissions reductions, representing a range of scenarios as described in
 

section IV.M and summarized in Table VI.31, with discount rates ranging from 2.5% to 5%. 


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EERE-2007-BT-STD-0007 COMMENT 31
First, DOE considered TSL 7, the most efficient level for polyphase small electric 

motors. TSL 7 would save an estimated 0.37 quad of energy through 2045, an amount DOE 

considers significant. Discounted at seven percent, the projected energy savings through 2045 

would be 0.09 quad. For the Nation as a whole, DOE projects that TSL 7 would result in a net 

decrease of $6.82 billion in NPV, using a discount rate of seven percent. The emissions 

reductions at TSL 7 are 21.2 Mt of CO2, up to 15.2 kt of NOx, and up to 0.117 ton of Hg. These 

reductions have a value of up to $1,144 million for CO2 (using the 95th percentile value at a 3 

percent discount rate), and a value of up to $11.0 million for NOx, and $1.16 million for Hg at a 

discount rate of seven percent. At the central value for the social cost of carbon, the estimated 

monetized benefit of CO2 emissions reductions is $375 million at a discount rate of three percent. 

DOE also estimates that at TSL 7, total electric generating capacity in 2030 will decrease 

compared to the base case by 0.42 GW. 

At TSL 7, DOE projects that the average polyphase small electric motor customer 

purchasing equipment in 2015 will experience an increase in LCC of $827 compared to the 

baseline. DOE estimates the fraction of customers experiencing LCC increases will be 96.8 

percent. The median PBP for the average polyphase small electric motor customer at TSL 7, 48.7 

years, is projected to be substantially longer than the mean lifetime of the equipment. When all 

polyphase product classes are considered and weighted by shipments, DOE estimates that small 

electric motor customers experience slightly lower increases in LCC of $808. 

The projected change in industry value ranges from a decrease of $69.5 million to an 

increase of $95.3 million. The impacts are driven primarily by the assumptions regarding the 

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EERE-2007-BT-STD-0007 COMMENT 31
ability to pass on larger increases in MPCs to the customer. At TSL 7, DOE recognizes the risk 


of very large negative impacts if manufacturers’ expectations about reduced profit margins are 

realized. In particular, if the high end of the range of impacts is reached as DOE expects, TSL 7 

could result in a net loss of 99.9 percent in INPV to the polyphase small motor industry. DOE 

believes manufacturers would likely have a more difficult time maintaining current gross margin 

levels with larger increases in manufacturing production costs, as standards increase the need for 

capital conversion costs, equipment retooling, and increased research and development spending. 

Specifically, at this TSL, the majority of manufacturers would need to significantly redesign all 

of their polyphase small electric motors. 

After carefully considering the analysis and weighing the benefits and burdens of TSL 7, 

the Secretary has reached the following conclusion: At TSL 7, the benefits of energy savings, 

emissions reductions (both in physical reductions and the monetized value of those reductions), 

would be outweighed by the economic burden of a net cost to the Nation (over 30 years), the 

economic burden to customers (as indicated by the large increase in life-cycle cost) and the 

potentially large reduction in INPV for manufacturers resulting from large conversion costs and 

reduced gross margins. Consequently, the Secretary has concluded that trial standard level 7 is 

not economically justified. 

DOE then considered TSL 6, which would likely save an estimated 0.37 quad of energy 

through 2045, an amount DOE considers significant. Discounted at seven percent, the projected 

energy savings through 2045 would be 0.09 quad. For the Nation as a whole, DOE projects that 

TSL 6 would result in a net decrease of $220 million in NPV, using a discount rate of seven 

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EERE-2007-BT-STD-0007 COMMENT 31
percent. The estimated emissions reductions at TSL 6 are 19.5 Mt of CO2, up to 13.9 kt of NOx, 

and up to 0.108 ton of Hg. These reductions have a value of up to $1,049 million for CO2 (using 

the 95th percentile value at a 3 percent discount rate), and a value of up to $10.1 million for NOx, 

and $1.06 million for Hg, at a discount rate of seven percent. At the central value for the social 

cost of carbon, the estimated monetized benefit of CO2 emissions reductions is $344 million at a 

discount rate of three percent. Total electric generating capacity in 2030 is estimated to decrease 

compared to the base case by 0.39 GW under TSL 6. 

At TSL 6, DOE projects that the average polyphase small electric motor customer 

purchasing equipment in 2015 will experience an increase in LCC of $71 compared to the 

baseline. DOE estimates the fraction of customers experiencing LCC increases will be seven 

percent. The median PBP for the average polyphase small electric motor customer at TSL 6, 16.1 

years, is projected to be substantially longer than the mean lifetime of the equipment. When all 

polyphase product classes are considered and weighted by shipments, DOE estimates that small 

electric motor customers experience slightly lower increases in LCC of $60. 

The projected change in industry value ranges from a decrease of $17.5 million to an 

increase of $18.5 million. The impacts are driven primarily by the assumptions regarding the 

ability to pass on larger increases in MPCs to the customer. At TSL 6, DOE recognizes the risk 

of very large negative impacts if manufacturers’ expectations about reduced profit margins are 

realized. In particular, if the high end of the range of impacts is reached as DOE expects, TSL 6 

could result in a net loss of 25.2 percent in INPV to the polyphase small motor industry. DOE 

believes manufacturers would likely have a more difficult time maintaining current gross margin 

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EERE-2007-BT-STD-0007 COMMENT 31
levels with larger increases in manufacturing production costs, as standards increase the need for 

capital conversion costs, equipment retooling, and increased research and development spending. 

Specifically, at this TSL, the majority of manufacturers would need to significantly redesign all 

of their polyphase small electric motors. 

After carefully considering the analysis and weighing the benefits and burdens of TSL 6, 

the Secretary has reached the following conclusion: at TSL 6, the benefits of energy savings, 

emissions reductions (both in physical reductions and the monetized value of those reductions), 

would be outweighed by the economic burden of a net cost to the Nation (over 30 years), the 

economic burden to consumers (as indicated by the increased life-cycle cost), and the potential 

reduction in INPV for manufacturers resulting from large conversion costs and reduced gross 

margins. Consequently, the Secretary has concluded that trial standard level 6 is not 

economically justified. 

DOE then considered TSL 5, which provides for polyphase small electric motors the 

maximum efficiency level that the analysis showed to have positive NPV for the Nation. TSL 5 

would likely save an estimated 0.34 quad of energy through 2045, an amount DOE considers 

significant. Discounted at seven percent, the projected energy savings through 2045 would be 

0.09 quad. For the Nation as a whole, DOE projects that TSL 5 would result in a net increase of 

$160 million in NPV, using a discount rate of seven percent. The estimated emissions reductions 

at TSL 5 are 18.3 Mt of CO2, up to 13.1 kt of NOx, and up to 0.101 ton of Hg. These reductions 

have a value of up to $986 million for CO2 (using the 95th percentile value at a 3 percent discount 

rate), and a value of up to $9.5 million for NOx, and $1.0 million for Hg, at a discount rate of 

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EERE-2007-BT-STD-0007 COMMENT 31
seven percent. At the central value for the social cost of carbon, the estimated benefit of CO2 

emissions reductions is $323 million at a discount rate of three percent. Total electric generating 

capacity in 2030 is estimated to decrease compared to the base case by 0.36 GW under TSL 5. 

At TSL 5, DOE projects that the average polyphase small electric motor customer 

purchasing the equipment in 2015 will experience an increase in LCC of $23 compared to the 

baseline representative unit for analysis (1 hp, 4 pole polyphase motor). This corresponds to 

approximately a 1.8 percent increase in average LCC. Based on this analysis, DOE estimates 

that approximately 66 percent of customers would experience LCC increases and that the median 

PBP would be 11.7 years, which is longer than the mean lifetime of the equipment. However, in 

consideration of the relatively small percentage increase in LCC at TSL 5, DOE examined 

sensitivity analyses to assess the likelihood of consumers in fact experiencing significant LCC 

increases. These included calculating a shipment-weighted LCC savings. 

At TSL 5, when accounting for the full-range of horsepowers and pole configurations of 

polyphase motors, the average LCC increase is reduced to $13. This corresponds to 

approximately 63 percent of customers experiencing an increase in LCC, with the remaining 37 

percent, those with greater operating hours, realizing net savings. 

The projected change in industry value ranges from a decrease of $11.8 million to an 

increase of $12.6 million. The impacts are driven primarily by the assumptions regarding the 

ability to pass on larger increases in MPCs to the customer. At TSL 5, DOE recognizes the risk 

of negative impacts if manufacturers’ expectations about reduced profit margins are realized. If 

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EERE-2007-BT-STD-0007 COMMENT 31
the high end of the range of impacts is reached, TSL 5 could result in a net loss of 17.0 percent in 


INPV to the polyphase small motor industry. 

After carefully considering the analysis and weighing the benefits and burdens of TSL 5, 

the Secretary has reached the following conclusion: At TSL 5, the benefits of energy savings 

and emissions reductions (both in physical reductions and the monetized value of those 

reductions) would be outweighed by the economic burden to consumers (as indicated by the 

increased life-cycle cost). Consequently, the Secretary has concluded that trial standard level 5 is 

not economically justified. 

DOE then considered TSL 4b, which is at an efficiency level added to the analysis in 

response to comments presented on the NOPR. TSL 4b would likely save an estimated 0.29 quad 

of energy through 2045, an amount DOE considers significant. Discounted at seven percent, the 

projected energy savings through 2045 would be 0.07 quad. For the Nation as a whole, DOE 

projects that TSL 4b would result in a net increase of $540 million in NPV, using a discount rate 

of seven percent. The estimated emissions reductions at TSL 4b are 15.4 Mt of CO2, up to 11.0 

kt of NOx, and up to 0.085 ton of Hg. These reductions have a value of up to $828 million for 

CO2 (using the 95th percentile value at a 3 percent discount rate), and a value of up to $8.0 

million for NOx, and $0.8 million for Hg, at a discount rate of seven percent. At the central value 

for the social cost of carbon, the estimated benefit of CO2 emissions reductions is $272 million at 

a discount rate of three percent. Total electric generating capacity in 2030 is estimated to 

decrease compared to the base case by 0.31 GW under TSL 4b. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

At TSL 4b, DOE projects that the average polyphase small electric motor customer 


purchasing the equipment in 2015 will experience a reduction in LCC of $28 compared to the 

baseline representative unit for analysis (1 hp, 4 pole polyphase motor). This corresponds to 

approximately a 2.2 percent reduction in average LCC. Based on this analysis, DOE estimates 

that approximately 51 percent of customers would experience LCC increases and that the median 

PBP would be 7.4 years, which is only slightly longer than the mean lifetime of the equipment. 

However, in consideration of the relatively small percentage decrease in LCC at TSL 4b, DOE 

examined sensitivity analyses to assess the likelihood of consumers experiencing significant 

LCC increases. These included calculating a shipment-weighted LCC savings. 

At TSL 4b, when accounting for the full-range of horsepowers and pole configurations of 

polyphase motors, the average LCC savings increase to $36. This corresponds to approximately 

49 percent of customers experiencing an increase in LCC, with the remaining 51 percent 

realizing net savings. 

The projected change in industry value ranges from a decrease of $5.4 million to an 

increase of $3.4 million. The impacts are driven primarily by the assumptions regarding the 

ability to pass on larger increases in MPCs to the customer. At TSL 4b, DOE recognizes the risk 

of negative impacts if manufacturers’ expectations about reduced profit margins are realized. If 

the high end of the range of impacts is reached, TSL 4b could result in a net loss of 7.8 percent in 

INPV to the polyphase small motor industry. 

Trial standard level 4b has other advantages that are not directly economic. This level sets 

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EERE-2007-BT-STD-0007 COMMENT 31
standards for many product classes that are approximately harmonized with the efficiency level 


for medium motors to be implemented in 2010 which requires four-pole, 1-hp polyphase motors 

to be at least 85.5% efficient. Since many--but not all--three digit frame size polyphase motors 

of this size can also be used in two-digit frames with minimal adjustment, DOE believes that 

there is a benefit to harmonizing small polyphase and medium polyphase motor efficiency 

standards in this size range. In particular, DOE does not believe the design changes necessary for 

TSL 4b would force all manufacturers to significantly redesign all of their polyphase small 

electric motors or their production processes. Therefore, DOE believes manufacturers are not at 

a significant risk to experience highly negative impacts. 

After considering the analysis and the benefits and burdens of trial standard level 4b, the 

Secretary has reached the following conclusion: Trial standard level 4b offers the maximum 

improvement in energy efficiency that is technologically feasible and economically justified, and 

will result in significant conservation of energy. The Secretary has reached the conclusion that 

the benefits of energy savings and emissions reductions (both in physical reductions and the 

monetized value of those reductions) outweigh the potential reduction in INPV for manufacturers 

and the economic burden on consumers, which is relatively small on average. Therefore, DOE 

today adopts the energy conservation standards for polyphase small electric motors at trial 

standard level 4b. 

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EERE-2007-BT-STD-0007 COMMENT 31
2. Capacitor-Start Small Electric Motors 

 Table VI.45 presents a summary of the quantitative analysis results for each TSL for 

capacitor-start small electric motors. 

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EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

 

Table VI.45 Summary of Capacitor-Start Small Electric Motors Analytical Results* 


Criteria Trial Standard Level 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 TSL 7 TSL 8 

Primary Energy Savings (quads) 1.18 1.19 1.36 1.47 1.47 1.61 1.91 2.33 

 @ 7% Discount Rate 0.31 0.31 0.36 0.39 0.39 0.43 0.51 0.62 

 @ 3% Discount Rate 0.63 0.64 0.73 0.79 0.79 0.87 1.03 1.25 

Generation Capacity Reduction (GW) 1.21 1.22 1.38 1.54 1.55 1.70 1.86 2.14 

NPV (2009$ billions) 

 @ 7% discount

 @ 3% discount 

3.01 

7.03 

3.05 

7.13 

2.83 

6.87 

1.97 

5.35 

2.08 

5.57 

(9.29) 

(16.23) 

4.74 

11.08 

3.03 

8.14 

Industry Impacts 8.40­ 9.46­ 16.27­ 32.15­ 28.48­ 186.60­ 18.40­ 46.35­

 Change in INPV (2009$ millions) (19.99) (20.79) (32.42) (42.15) (40.09) (152.05) (34.05) (52.58) 

 Change in INPV (%) 3.01­ 3.39­ 5.83­ 11.52­ 10.20­ 66.87­ 6.59­ 16.61­

(7.16) (7.45) (11.62) (15.46) (14.37) (54.49) (12.20) (18.84) 

Cumulative Emission Reduction

 CO2 (Mt) 62.9 63.5 71.7 80.5 81.0 88.5 96.8 111.4 

 Value of CO2 reductions (2009$ 216– 218– 246– 277– 278– 304– 333– 383– 

millions)** 3410 3444 3890 4367 4394 4801 5253 6046 

NOX (kt) 45.1 45.54 51.44 57.74 58.11 63.48 69.47 79.95 

 Value of NOX reductions at 7% 3.5 – 3.5 – 4.0 – 4.5 – 4.5 – 4.9 – 5.4 – 6.2 – 

discount rate (2009$ millions) 36.0 36.2 41.0 46.0 46.3 50.6 55.4 63.8 

 Value of NOX reductions at 3% 9.6 – 9.7 – 11.0 – 12.3 – 12.4 – 13.5 – 14.8 – 17.0 – 

discount rate (2009$ millions) 98.7 100.0 112.6 126.4 127.2 138.9 152.0 175.0 

 Hg (t) 0.265 0.267 0.302 0.339 0.341 0.373 0.408 0.469 

 Value of Hg reductions at 7% discount 0.06 – 0.06 – 0.07 – 0.08 – 0.08 – 0.09 – 0.10 – 0.11 – 

rate (2009$ millions) 2.79 2.82 3.18 3.57 3.60 3.93 4.30 4.95 

 Value of Hg reductions at 3% discount 0.12 – 0.12 – 0.13 – 0.15 – 0.15 – 0.17 – 0.18 – 0.21 – 

rate (2009$ millions) 5.22 5.27 5.95 6.68 6.72 7.34 8.04 9.25 

223
 

EERE-2007-BT-STD-0007 COMMENT 31
 

 

 

 

Life-cycle Cost of Rep. Product Class 

CSIR 

 Customers with increase in LCC (%) 32.0 32.0 41.6 54.9 54.9 65.6 65.6 65.6 

 Customers with savings in LCC (%) 68.0 68.0 58.4 45.1 45.1 34.5 34.5 34.5 

 Mean LCC (2009$) 857 857 868 902 902 1,285 1,285 1,285 

 Mean LCC Savings (2009$) 

CSCR 

58 58 47 13 13 (369) (369) (369) 

 Customers with increase in LCC (%) 46.5 47.8 47.8 54.9 47.8 98.6 47.8 74.7 

 Customers with savings in LCC (%) 53.6 52.2 52.2 45.1 52.2 1.4 52.2 25.3 

 Mean LCC (2009$) 1,005 1,002 1,002 1,015 1,002 1,856 1,002 1,078 

 Mean LCC Savings (2009$) 

CSIR migrating to CSCR weighted 

results*** 

21 24 24 11 24 (830) 24 (52) 

 Customers with increase in LCC (%) 32.5 32.5 41.7 55.0 55.0 66.0 53.7 60.6 

 Customers with savings in LCC (%) 67.5 67.5 58.3 45.0 45.0 34.0 46.3 39.4 

 Mean LCC (2009$) 854 854 865 899 899 1,282 891 917 

 Mean LCC Savings (2009$) 

Life-cycle Cost of all Product Classes, 

Weighted by Shipments 

CSIR 

58 58 47 15 15 (370) 23 (3) 

 Customers with increase in LCC (%) 30.7 30.7 40.2 54.1 54.1 65.1 65.1 65.1 

 Customers with savings in LCC (%) 69.3 69.3 59.8 45.9 45.9 34.9 34.9 34.9 

 Mean LCC (2009$) 859 859 870 903 903 1,287 1,287 1,287 

 Mean LCC Savings (2009$) 

CSCR 

62 62 51 17 17 (367) (367) (367) 

 Customers with increase in LCC (%) 38.4 39.7 39.7 46.1 39.7 94.7 39.7 65.0 

 Customers with savings in LCC (%) 61.6 60.3 60.3 53.9 60.3 5.3 60.3 35.0 

 Mean LCC (2009$) 1,299 1,289 1,289 1,304 1,289 2,228 1,289 1,364 

 Mean LCC Savings (2009$) 50 60 60 45 60 (879) 60 (15) 

Market Share**** - CSIR (%) 99 98 98 96 95 100 3 7 

Payback Period (years) 

CSIR 

 Average 10.5 10.5 15.1 24.9 24.9 108.5 108.5 108.5 

Median 

CSCR 

3.1 3.1 4.5 7.0 7.0 11.9 11.9 11.9 

 Average 14.8 15.3 15.3 19.5 15.3 200.0 15.3 34.8 

Median 4.4 4.5 4.5 5.9 4.5 37.6 4.5 10.0 

Employment Impact 

 Indirect Impacts (2045) (jobs, ‘000) 7.06 7.12 8.56 10.24 10.20 19.57 11.22 18.70 

* Parentheses indicate negative (-) values. For LCCs, a negative value means an increase in LCC by the amount 


indicated. 


** Range of global values for the SCC of emissions reductions, representing a range of scenarios as described in
 

section IV.M and summarized in Table VI.31, with discount rates ranging from 2.5% to 5%. 


*** Shipments-weighted based on market share product switching model. 


**** Base case market share is 95 percent CSIR and 5 percent CSCR. 


First, DOE considered TSL 8, the combination of CSIR and CSCR efficiency levels 


generating the greatest national energy savings. TSL 8 would likely save an estimated 2.33 quads 


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EERE-2007-BT-STD-0007 COMMENT 31
of energy through 2045, an amount DOE considers significant. Discounted at seven percent, the 


projected energy savings through 2045 would be 0.62 quad. For the Nation as a whole, DOE 

projects that TSL 8 would result in a net benefit of $3.03 billion in NPV, using a discount rate of 

seven percent. The estimated emissions reductions at TSL 8 are up to 111.4 Mt of CO2, up to 

80.0 kt of NOx, and up to 0.469 ton of Hg. These reductions have a value of up to $6,046 million 

for CO2 (using the 95th percentile value at a 3 percent discount rate), and a value of up to $63.8 

million for NOx, and $4.95 million for Hg at a discount rate of seven percent. At the central 

value for the social cost of carbon, the estimated benefit of CO2 emissions reductions is $1,982 

million at a discount rate of three percent. DOE also estimates that at TSL 8, total electric 

generating capacity in 2030 will decrease compared to the base case by 2.14 GW. 

At TSL 8, DOE projects that for the average customer, compared to the baseline, the 

LCC of a CSIR and CSCR motor will increase by $369 and $52, respectively. At TSL 8, DOE 

estimates the fraction of customers experiencing LCC increases will be 66 percent for CSIR 

motors and 75 percent for CSCR motors. The median PBP for the average capacitor-start small 

electric motor customers at TSL 8, 11.9 years for CSIR motors and 10.0 years for CSCR motors, 

is projected to be substantially longer than the mean lifetime of the equipment. DOE also 

considered market migration between CSIR and CSCR users and how that would affect the LCC 

of CSIR users at TSL 8. DOE estimates that at this TSL it will be more cost-effective for many 

CSIR consumers to purchase a CSCR motor instead, with only a slight $3 increase in the average 

LCC over that of the baseline CSIR motor. In total, 61 percent of consumers who migrate from a 

CSIR to a CSCR motor will experience LCC increases. 

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EERE-2007-BT-STD-0007 COMMENT 31
DOE also examined LCC savings using a full distribution of motor sizes and speeds. 


Under these conditions, for the average customer, the LCC of a CSIR and CSCR motor will 

increase by $367 and $15, respectively, compared to the baseline. At TSL 8, DOE estimates the 

fraction of customers experiencing LCC increases will be 65 percent for both CSIR and CSCR 

motors. 

The projected change in industry value ranges from a decrease of $52.58 million to an 

increase of $46.35 million. The impacts are driven primarily by the assumptions regarding the 

ability to pass on larger increases in MPCs to the customer as well as the necessary estimated 

investments. At TSL 8, DOE recognizes the risk of negative impacts if manufacturers’ 

expectations about reduced profit margins are realized. In particular, if the high end of the range 

of impacts is reached as DOE expects, TSL 8 could result in a net loss of 18.84 percent in INPV 

to the capacitor-start small motor industry. DOE believes manufacturers would likely have a 

more difficult time maintaining current gross margin levels with larger increases in 

manufacturing production costs, as standards increase the need for capital conversion costs, 

equipment retooling, and increased research and development spending. Specifically, at this 

TSL, the majority of manufacturers would need to significantly redesign all of their capacitorstart small electric motors. 

After carefully considering the analysis and weighing the benefits and burdens of TSL 8, 

the Secretary has reached the following conclusion: At TSL 8, the benefits of energy savings, 

emissions reductions (both in physical reductions and the monetized value of those reductions), 

and the positive net economic savings (over 30 years) would be outweighed by the economic 

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EERE-2007-BT-STD-0007 COMMENT 31
burden on existing CSCR customers and CSIR customers who do not migrate from CSIR to 

CSCR motors (as indicated by the large increase in LCC) and the potentially large reduction in 

INPV for manufacturers resulting from large conversion costs and reduced gross margins. 

Consequently, the Secretary has concluded that trial standard level 8 is not economically 

justified. 

DOE then considered TSL 7, which would likely save an estimated 1.91 quads of energy 

through 2045, an amount DOE considers significant. Discounted at seven percent, the projected 

energy savings through 2045 would be 0.51 quad. For the Nation as a whole, DOE projects that 

TSL 7 would result in a net benefit of $4.74 billion in NPV, using a discount rate of seven 

percent. The estimated emissions reductions at TSL 7 are up to 96.8 Mt of CO2, up to 69.5 kt of 

NOx, and up to 0.408 ton of Hg. These reductions have a value of up to $5,253 million for CO2 

(using the 95th percentile value at a 3 percent discount rate), and a value of up to $55.4 million 

for NOx, and $4.30 million for Hg at a discount rate of seven percent. At the central value for the 

social cost of carbon, the estimated benefit of CO2 emissions reductions is $1,722 million at a 

discount rate of three percent. Total electric generating capacity in 2030 is estimated to decrease 

compared to the base case by 1.86 GW under TSL 7. 

At TSL 7, DOE projects that for the average customer, the LCC of capacitor-start small 

electric motors will increase by $369 for CSIR motors and decrease by $24 for CSCR motors 

compared to the baseline. At TSL 7, DOE estimates the fraction of CSIR customers experiencing 

LCC increases will be 66 percent, but only 48 percent for CSCR motor customers. However, 

DOE believes that at this TSL, which is the max-tech efficiency level for CSIR motors, the 

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relative difference in cost between a CSIR motor and a CSCR motor becomes substantial and 


will have large effects on customers. Rather than buy an expensive CSIR motor, those 

customers whose applications permit them to will purchase a CSCR motor with the same number 

of poles and horsepower ratings. DOE is unsure of the magnitude of the migration of CSIR users 

to CSCR motors, but estimates that customers that purchase a CSCR motor rather than a CSIR 

motor will reduce their LCC by $23 on average, compared to the baseline CSIR motor. On a 

national level, DOE estimates that the market share of CSCR motors could grow from 5 percent 

of all capacitor-start motors to 97 percent once the compliance date for these standards is 

effective. Even though switching from a CSIR to a CSCR motor would result in a reduction in 

LCC on average, DOE estimates that approximately 54 percent of CSIR customers that switch 

would still experience an LCC increase. 

DOE also examined LCC savings with a full distribution of motor sizes and speeds. 

Under these conditions, for the average customer, compared to the baseline, the LCC of a CSIR 

and CSCR motor will increase by $367 and decrease by $60, respectively. DOE also examined 

what fraction of motors would have increases in LCC. At TSL 7, DOE estimates that 65 percent 

of CSIR motor customers who do not switch to CSCR motors, and 40 percent of CSCR motor 

customers, will experience increased LCC. 

The projected change in industry value ranges from a decrease of $34.05 million to an 

increase of $18.40 million. The impacts are driven primarily by the assumptions regarding the 

ability to pass on larger increases in MPCs to the customer as well as the necessary estimated 

investments. At TSL 7, DOE recognizes the risk of negative impacts if manufacturers’ 

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expectations about reduced profit margins are realized. In particular, if the high end of the range 


of impacts is reached as DOE expects, TSL 7 could result in a net loss of 12.20 percent in INPV 

to the capacitor-start small motor industry. At this TSL, the combination of efficiency levels 

could cause a migration from CSIR motors to CSCR motors; however, DOE believes that the 

capital conversion costs, equipment retooling and R&D spending associated with this migration 

would not be severe. 

After carefully considering the analysis and weighing the benefits and burdens of TSL 7, 

the Secretary has reached the following conclusion: Trial standard level 7 offers the maximum 

improvement in energy efficiency that is technologically feasible and economically justified and 

will result in significant conservation of energy. The Secretary has reached the conclusion that 

the benefits of energy savings, emissions reductions (both in physical reductions and the 

monetized value of those reductions), the positive net economic savings to the Nation (over 30 

years) and the harmonization of efficiency requirements between CSIR and CSCR motors would 

outweigh the potential reduction in INPV for manufacturers and the economic burden on those 

CSIR customers who are unable to switch to CSCR motors. Further, benefits from carbon 

dioxide reductions (at a central value calculated using a three percent discount rate) would 

increase NPV by $1,722 million (2009$). These benefits from carbon dioxide emission 

reductions, when considered in conjunction with the consumer savings NPV and other factors 

described above support DOE's tentative conclusion that trial standard level 7 is economically 

justified. Therefore, DOE today adopts the energy conservation standards for capacitor-start 

small electric motors at trial standard level 7. 

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VII. Procedural Issues and Regulatory Review
 

A. Review Under Executive Order 12866 

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 

51735 (October 4, 1993), requires each agency to identify the problem the agency intends to 

address that warrants new agency action (including, where applicable, the failures of private 

markets or public institutions), as well as assess the significance of that problem, to enable 

assessment of whether any new regulation is warranted. EPCA requires DOE to establish 

standards for the small motors covered in today’s rulemaking. In addition, today’s standards also 

address the following: (1) Misplaced incentives, which separate responsibility for selecting 

equipment and for paying their operating costs; and (2) Lack of consumer information and/or 

information processing capability about energy efficiency opportunities. The market for small 

electric motors is dominated by the presence and actions of OEMs, who sell small electric 

motors to end-users as a component of a larger piece of equipment. There is a very large 

diversity of equipment types that use small electric motors and the market for any particular type 

of equipment may be very small. Consumers lack information and choice regarding the motor 

component. OEMs and consumers may be more concerned with other aspects of the application 

system than with selecting the most cost effective motor for the end user. Space constraints may 

also restrict the ability of the consumer to replace the motor with a more efficient model. 

In addition, DOE has determined that today’s regulatory action is a “significant 

regulatory action” under section 3(f)(1) of Executive Order 12866. Accordingly, section 6(a)(3) 

of the Executive Order required that DOE prepare a regulatory impact analysis (RIA) on today’s 

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final rule and that the Office of Information and Regulatory Affairs (OIRA) in the OMB review 


this rule. DOE presented to OIRA for review the final rule and other documents prepared for this 

rulemaking, including the RIA, and has included these documents in the rulemaking record. 

They are available for public review in the Resource Room of DOE’s Building Technologies 

Program, 950 L’Enfant Plaza, SW., Suite 600, Washington, DC 20024, (202) 586-2945, between 

9:00 a.m. and 4:00 p.m., Monday through Friday, except Federal holidays. 

The NOPR contained a summary of the RIA, which evaluated the extent to which major 

alternatives to standards for small electric motors could achieve significant energy savings at 

reasonable cost, as compared to the effectiveness of the proposed rule. 74 FR 61493-96. The 

complete RIA (Regulatory Impact Analysis for Proposed Energy Conservation Standards for 

Small Electric Motors) is contained in the TSD prepared for today’s rule. The RIA consists of: 

(1) a statement of the problem addressed by this regulation and the mandate for government 

action, (2) a description and analysis of the feasible policy alternatives to this regulation, (3) a 

quantitative comparison of the impacts of the alternatives, and (4) the national economic impacts 

of today’s standards. 

The major alternatives DOE analyzed were: (1) no new regulatory action; (2) financial 

incentives, including tax credits and rebates; (3) revisions to voluntary energy efficiency targets; 

and (4) bulk government purchases. DOE evaluated each alternative in terms of its ability to 

achieve significant energy savings at reasonable costs, and compared it to the effectiveness of the 

proposed rule. 

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Table VII.1 Non-Regulatory Alternatives for Small Electric Motors 


Policy Alternatives 

Energy 

Savings 

quads* 

Net Present Value† 

billion $ 

7% Discount Rate 3% Discount Rate 

No New Regulatory Action 0.00 0.00 0.00 

Consumer Rebates at TSL 4b (Polyphase) and 

TSL 3 (Single-Phase) 0.17 0.49 1.13 

Consumer Rebates at TSL 4b (Polyphase) and 

TSL 2 (Single-Phase) 0.27 0.72 1.69 

Consumer Rebates at TSL 4b (Polyphase) and 

TSL 3 (Capacitor-Start Capacitor-Run Only) 0.60 1.76 4.03 

Consumer Tax Credits 0.11 0.35 0.80 

Manufacturer Tax Credits 0.07 0.25 0.56 

Voluntary Efficiency Targets 0.42 0.95 2.29 

Bulk Government Purchases 0.18 0.44 1.04 

Proposed Standards at TSL 4b (Polyphase) and 

TSL 7 (Capacitor-Start) 2.20 5.28 12.52 

* Energy savings are in source quads from 2015 and 2045. 

† Net present value (NPV) is the value of a time series of costs and savings. DOE determined the NPV from 2015 

to 2065 in billions of 2009$. 

The net present value amounts shown in Table VII.1 refer to the NPV for consumers. The 

costs to the government of each policy (such as rebates or tax credits) are not included in the 

costs for the NPV since, on balance, consumers are both paying for (through taxes) and receiving 

the benefits of the payments. For each of the policy alternatives other than standards, Table VII.1 

shows the energy savings and NPV in the case where the CSIR and CSCR market share shift in 

response to the policy prior to 2015, or immediately in 2015 when compliance with the standards 

would be required. The NES and NPV in the case of the proposed standard are shown as a range 

between this scenario and a scenario in which the market shift takes ten years to complete, and 

begins in 2015 . The following paragraphs discuss each of the policy alternatives listed in Table 

VII.1. (For more details see TSD, RIA.) 

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No new regulatory action. The case in which no regulatory action is taken with regard to small 

electric motors constitutes the "base case" (or "No Action") scenario. In this case, between 2015 

and 2045, capacitor-start small electric motors purchased in or after 2015 are expected to 

consume 1.91 quads of primary energy (in the form of losses), while polyphase small electric 

motors purchased in or after 2015 are expected to consume 0.29 quad of primary energy. Since 

this is the base case, energy savings and NPV are zero by definition. 

Rebates. DOE evaluated the possible effect of a rebate consistent with current motor rebate 

practices in the promotion of premium efficiency motors which cover a portion of the 

incremental price difference between equipment meeting baseline efficiency levels and 

equipment meeting improved efficiency requirements. The current average motor rebate for an 

efficient 1-horsepower motor is approximately $25, and DOE scaled this rebate to be 

approximately proportional to the retail price of the motor. DOE evaluated rebates targeting TSL 

4b for polyphase motors, and evaluated several target efficiency levels for capacitor-start motors 

(including TSLs 7, 5, 3, and 2). Existing rebate programs for polyphase motors target three-digit 

frame series motors with efficiencies equivalent to TSL 4b for small polyphase motors. At rebate 

efficiency levels corresponding to TSL 7 and 5 for capacitor-start motors, DOE estimates that 

rebates consistent with current practice would have an insignificant impact on increasing the 

market share of CSIR motors. For this case, meeting the target level requires the purchase of a 

motor with a very high average first cost because for TSL 7, CSIR motors are at the maximum 

technologically feasible efficiency. As a result, rebates targeting TSLs 3 and 2 have larger energy 

savings. TSLs 7, 5, 3, and 2 correspond to the same efficiency level (EL 3) for CSCR motors. 

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For rebate programs targeting TSL 4b for polyphase motors and TSL 3 for capacitor start 


motors, DOE estimates the market share of equipment meeting the energy efficiency levels 

targeted would increase from 0 percent to 0.4 percent for polyphase motors, from 0 percent to 

0.2 percent for capacitor-start, induction-run motors, and from 26.0 to 42.6 percent for capacitorstart, capacitor-run motors. DOE assumed the impact of this policy would be to permanently 

transform the market so that the shipment-weighted efficiency gain seen in the first year of the 

program would be maintained throughout the forecast period. At the estimated participation 

rates, the rebates would provide 0.17 quad of national energy savings and an NPV of $0.49 

billion (at a 7-percent discount rate). 

DOE found that a rebate targeting the efficiency levels corresponding to TSL 2 for 

capacitor-start motors would result in larger energy savings than one targeting the efficiency 

levels of TSL 3, TSL 5 or TSL 7. Such rebates would increase the market share among 

capacitor-start induction-run motors meeting the efficiency level corresponding to TSL 2 from 

2.0 percent to 11.7 percent. Combined with unchanged polyphase motor rebates targeting TSL 

4b, DOE estimates these rebates would provide 0.27 quad of national energy savings and an 

NPV of $0.72 billion (at a 7-percent discount rate). 

DOE also analyzed an alternative rebate program for capacitor-start motors which would 

give rebates of twice the value of the previously-analyzed rebate for CSCR motors which meet 

the requirements of TSL 7 (a $50 rebate for a 1 HP motor, scaled to other product classes), and 

no rebates for CSIR motors. DOE estimates that these rebates would have no effect on the 

efficiency distribution of capacitor-start induction-run motors, and would increase the market 

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share among capacitor-start capacitor-run motors meeting TSL 7 from 26.0 percent to 89.4 


percent. Combined with unchanged polyphase motor rebates at TSL 4b, DOE estimates these 

rebates would provide 0.60 quad of national energy savings and an NPV of $1.76 billion (at a 7­

percent discount rate). 

Although DOE estimates that rebates will provide national benefits, they are much 

smaller than the benefits resulting from national performance standards. Thus, DOE rejected 

rebates as a policy alternative to national performance standards. 

Consumer Tax Credits. If customers were offered a tax credit equivalent to the amount 

mentioned above for rebates, DOE’s research suggests that the number of customers buying a 

small electric motor that would take advantage of the tax credit would be approximately 60 

percent of the number that would take advantage of rebates. Thus, as a result of the tax credit, the 

percentage of customers purchasing the products with efficiencies corresponding to TSL 4b or 

higher for polyphase motors would increase from 8.0 percent to 15.0 percent; the market share of 

capacitor-start motors meeting TSL 3 would increase from 0 percent to 0.1 percent for capacitorstart, induction-run motors, and from 26.0 percent to 36.0 percent for capacitor-start, capacitorrun motors. DOE assumed the impact of this policy would be to permanently transform the 

market so that the shipment-weighted efficiency gain seen in the first year of the program would 

be maintained throughout the forecast period. DOE estimated that tax credits would yield a 

fraction of the benefits that rebates would provide. DOE rejected rebates, as a policy alternative 

to national performance standards, because the benefits that rebates provide are much smaller 

than those resulting from performance standards. Thus, because consumer tax credits provide 

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even smaller benefits than rebates, DOE also rejected consumer tax credits as a policy alternative
 

to national performance standards. 

Manufacturer Tax Credits. DOE believes even smaller benefits would result from availability of 

a manufacturer tax credit program that would effectively result in a lower price to the consumer 

by an amount that covers part of the incremental price difference between products meeting 

baseline efficiency levels and those meeting TSL 4b for polyphase small electric motors and TSL 

3 for capacitor-start small electric motors. Because these tax credits would go to manufacturers 

instead of customers, DOE believes that fewer customers would be aware of this program 

relative to a consumer tax credit program. DOE assumes that 50 percent of the customers who 

would take advantage of consumer tax credits would buy more-efficient products offered through 

a manufacturer tax credit program. Thus, as a result of the manufacturer tax credit, the 

percentage of customers purchasing the more-efficient products would increase from 8.0 percent 

to 11.5 percent (i.e., 50 percent of the impact of consumer tax credits) for polyphase motors, 

from 0 percent to 0.1 percent for capacitor-start, induction-run motors, and from 26.0 percent to 

31.0 percent for capacitor-start, capacitor-run motors. 

DOE assumed the impact of this policy would be to permanently transform the market so 

that the shipment-weighted efficiency gain seen in the first year of the program will be 

maintained throughout the forecast period. DOE estimated that manufacturer tax credits would 

yield a fraction of the benefits that consumer tax credits would provide. DOE rejected consumer 

tax credits as a policy alternative to national performance standards because the benefits that 

consumer tax credits provide are much smaller than those resulting from performance standards. 

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Thus, because manufacturer tax credits provide even smaller benefits than consumer tax credits, 

DOE also rejected manufacturer tax credits as a policy alternative to national performance 

standards. 

Voluntary Energy-Efficiency Targets. There are no current federal or industry marketing efforts 

to increase the use of efficient small electric motors which meet the requirements of TSL 4b for 

polyphase small electric motors or TSL 7 for capacitor-start small electric motors. NEMA and 

the Consortium for Energy Efficiency promote “NEMA Premium” efficient three-digit frame 

series motors, and DOE analyzed this program as a model for the market effects of a similar 

program for small electric motors. DOE evaluated the potential impacts of such a program that 

would encourage purchase of products meeting the trial standard level efficiency levels. DOE 

modeled the voluntary efficiency program based on this scenario and assumed that the resulting 

shipment-weighted efficiency gain would be maintained throughout the forecast period. DOE 

estimated that the enhanced effectiveness of voluntary energy-efficiency targets would provide 

0.42 quad of national energy savings and an NPV of $0.95 billion (at a 7-percent discount rate). 

Although this would provide national benefits, they are much smaller than the benefits resulting 

from national performance standards. Thus, DOE rejected use of voluntary energy-efficiency 

targets as a policy alternative to national performance standards. 

Bulk Government Purchases. Under this policy alternative, the government sector would be 

encouraged to purchase increased amounts of polyphase equipment that meet the efficiency 

levels in trial standard level 4b and capacitor-start equipment that meets the efficiency levels in 

trial standard level 7. Federal, State, and local government agencies could administer such a 

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program. At the Federal level, this would be an enhancement to the existing Federal Energy
 

Management Program (FEMP). DOE modeled this program by assuming an increase in 

installation of equipment meeting the efficiency levels of the target standard levels among the 

commercial and public buildings and operations which are run by government agencies. DOE 

estimated that bulk government purchases would provide 0.18 quad of national energy savings 

and an NPV of $0.44 billion (at a 7-percent discount rate), benefits which are much smaller than 

those estimated for national performance standards. DOE rejected bulk government purchases as 

a policy alternative to national performance standards. 

National Performance Standards. None of the regulatory alternatives DOE examined would save 

as much energy or have an NPV as high as the standards in today’s final rule. Also, several of 

the alternatives would require new enabling legislation, because DOE does not have authority to 

implement those alternatives. Additional detail on the regulatory alternatives is found in the RIA 

chapter in the TSD. 

B. Review Under the Regulatory Flexibility Act 

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an initial 

regulatory flexibility analysis 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. 

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DOE has made its procedures and policies available on the Office of the General Counsel’s 


website, www.gc.doe.gov. 

DOE reviewed today’s final rule under the provisions of the Regulatory Flexibility Act 

and the procedures and policies published on February 19, 2003. A regulatory flexibility analysis 

examines the impact of the rule on small entities and considers alternative ways of reducing 

negative impacts. 

In the context of this rulemaking, “small businesses,” as defined by the Small Business 

Administration (SBA), for the small electric motor manufacturing industry are manufacturing 

enterprises with 1,000 employees or fewer. See 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. DOE 

used this small business definition to determine whether any small entities would be required to 

comply with the rule. (65 FR 30836, 30850 (May 15, 2000), as amended at 65 FR 53533, 53545 

(September 5, 2000) and codified at 13 CFR part 121. The size standards are listed by NAICS 

code and industry description. The manufacturers impacted by this rule are generally classified 

under NAICS 335312, “Motor and Generator Manufacturing,” which sets a threshold of 1,000 

employees or less for an entity in this category to be considered a small business. 

As explained in the NOPR, DOE identified producers of equipment covered by this 

rulemaking, which have manufacturing facilities located within the United States and could be 

considered small entities, by two methods: (1) asking larger manufacturers in MIA interviews to 

identify any competitors they believe may be a small business, and (2) researching NEMA239
 

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identified fractional horsepower motor manufacturers. DOE then looked at publicly-available 


data and contacted manufacturers, as necessary, to determine if they meet the SBA's definition of 

a small manufacturing company. In total, DOE identified 11 companies that could potentially be 

small businesses. During initial review of the 11 companies in its list, DOE either contacted or 

researched each company to determine if it sold covered small electric motors. Based on its 

research, DOE screened out companies that did not offer motors covered by this rulemaking. 

Consequently, DOE estimated that only one out of 11 companies listed were potentially small 

business manufacturers of covered products. DOE then contacted this potential small business 

manufacturer and determined that the company’s equipment would not be covered by this 

proposed rulemaking. Thus, based on its initial screening and subsequent interviews, DOE did 

not identify any company as a small business manufacturer based on SBA’s definition of a small 

business manufacturer for this industry. (74 FR 61410, 61496). For today’ final rule, DOE did 

not identify any additional companies that would be potential small business manufacturer based 

on SBA’s definition of a small business manufacturer for the small electric motor industry. 

DOE reviewed the standard levels considered in today’s final rule under the provisions of 

the Regulatory Flexibility Act and the procedures and policies published on February 19, 2003. 

On the basis of the foregoing, DOE reaffirms the certification. Therefore, DOE has not prepared 

a final regulatory flexibility analysis for this rule. 

C. Review Under the Paperwork Reduction Act 

This rulemaking imposes no new information or record-keeping requirements. 

Accordingly, OMB clearance is not required under the Paperwork Reduction Act. (44 U.S.C. 

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3501, et seq.) 


D. Review Under the National Environmental Policy Act 

DOE prepared an environmental assessment of the impacts of today’s standards which it 

published as chapter 15 within the TSD for the final rule. DOE found the environmental effects 

associated with today’s standard levels for small electric motors to be insignificant. Therefore, 

DOE is issuing a FONSI pursuant to NEPA (42 U.S.C. 4321 et seq.), the regulations of the 

Council on Environmental Quality (40 CFR parts 1500-1508), and DOE’s regulations for 

compliance with NEPA (10 CFR part 1021). The FONSI is available in the docket for this 

rulemaking. 

E. Review Under Executive Order 13132 

DOE reviewed this rule pursuant to Executive Order 13132, “Federalism,” 64 FR 43255 

(August 4, 1999), which imposes certain requirements on agencies formulating and 

implementing policies or regulations that preempt State law or that have federalism implications. 

In accordance with DOE’s statement of policy describing the intergovernmental consultation 

process it will follow in the development of regulations that have federalism implications, 65 FR 

13735 (March 14, 2000), DOE examined the November 2009 proposed rule and determined that 

the rule would not have a substantial direct effect on the States, on the relationship between the 

National Government and the States, or on the distribution of power and responsibilities among 

the various levels of Government. See 74 FR 61497. DOE received no comments on this issue 

in response to the NOPR, and its conclusions on this issue are the same for the final rule as they 

were for the proposed rule. Therefore, DOE has taken no further action in today’s final rule with 

respect to Executive Order 13132. 

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F. Review Under Executive Order 12988 

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, "Civil Justice Reform" (61 FR 4729 

(February 7, 1996)) 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. 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 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, the final regulations meet the relevant standards of Executive Order 

12988. 

G. Review Under the Unfunded Mandates Reform Act of 1995 

As indicated in the NOPR, DOE reviewed the proposed rule under Title II of the 

Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4) (UMRA), which imposes requirements 

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on Federal agencies when their regulatory actions will have certain types of impacts on State, 

local, and Tribal governments and the private sector. See 74 FR 61497. DOE concluded that 

this rule would not contain an intergovernmental mandate, but would likely result in 

expenditures of $100 million or more after 2015 for private sector commercial and industrial 

users of equipment with small electric motors. DOE estimated annualized impacts for the final 

standards using the results of the national impacts analysis. The national impact analysis results 

expressed as annualized values are $961 – $1,146 million in total annualized benefits from the 

final rule, $264 million in annualized costs, and $698 – $882 million in annualized net benefits. 

Details are provided in chapter 10 of the TSD. Therefore, DOE must publish a written statement 

assessing the costs, benefits, and other effects of the rule on the national economy. 

Section 205 of UMRA also requires DOE to identify and consider a reasonable number 

of regulatory alternatives before promulgating a rule for which UMRA requires such a written 

statement. DOE must select from those alternatives the most cost-effective and least burdensome 

alternative that achieves the objectives of the rule, unless DOE publishes an explanation for 

doing otherwise or the selection of such an alternative is inconsistent with law. 

Today’s energy conservation standards for small electric motors would achieve the 

maximum improvement in energy efficiency that DOE has determined to be both technologically 

feasible and economically justified. A discussion of the alternatives considered by DOE is 

presented in the regulatory impact analysis section of the TSD for this rule. Also, Section 202(c) 

of UMRA authorizes an agency to prepare the written statement required by UMRA in 

conjunction with or as part of any other statement or analysis that accompanies the proposed 

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rule. (2 U.S.C. 1532(c)) The TSD, preamble, and regulatory impact analysis for today’s final rule 


contain a full discussion of the rule’s costs, benefits, and other effects on the national economy, 

and therefore satisfy UMRA’s written statement requirement. 

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

DOE determined that, for this rulemaking, it need not prepare a Family Policymaking 

Assessment under Section 654 of the Treasury and General Government Appropriations Act, 

1999 (Pub. L. 105-277). See 74 FR 61497. DOE received no comments concerning Section 654 

in response to the NOPR, and, therefore, has taken no further action in today’s final rule with 

respect to this provision. 

I. Review Under Executive Order 12630 

DOE determined under Executive Order 12630, “Governmental Actions and Interference 

with Constitutionally Protected Property Rights,” 53 FR 8859 (March 18, 1988), that today’s rule 

would not result in any takings that might require compensation under the Fifth Amendment to 

the U.S. Constitution. See 74 FR 61497-98. DOE received no comments concerning Executive 

Order 12630 in response to the NOPR, and, therefore, has taken no further action in today’s final 

rule with respect to this Executive Order. 

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

Section 515 of the Treasury and General Government Appropriations Act, 2001 (44 

U.S.C. 3516, note) provides for agencies to review most disseminations of information to the 

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public under guidelines established by each agency pursuant to general guidelines issued by
 

OMB. OMB’s guidelines were published at 67 FR 8452 (February 22, 2002), and DOE’s 

guidelines were published at 67 FR 62446 (October 7, 2002). DOE has reviewed today’s final 

rule under the OMB and DOE guidelines and has concluded that it is consistent with applicable 

policies in those guidelines. 

K. Review Under Executive Order 13211 

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 the Office of Information and Regulatory Affairs (OIRA) a Statement of 

Energy Effects for any proposed significant energy action. DOE determined that today’s rule, 

which sets energy conservation standards for small electric motors, is not a “significant energy 

action” within the meaning of Executive Order 13211. See 74 FR 61498. Accordingly, DOE did 

not prepare a Statement of Energy Effects on the proposed rule. DOE received no comments on 

this issue in response to the NOPR. As with the proposed rule, DOE has concluded that today’s 

final rule is not a significant energy action within the meaning of Executive Order 13211, and 

has not prepared a Statement of Energy Effects on the final rule. 

L. Review Under the Information Quality Bulletin for Peer Review 

In consultation with the Office of Science and Technology Policy (OSTP), OMB issued 

on December 16, 2004, its “Final Information Quality Bulletin for Peer Review” (the Bulletin). 

70 FR 2664. (January 14, 2005) The Bulletin establishes that certain scientific information shall 

be peer reviewed by qualified specialists before it is disseminated by the Federal government, 

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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. 

As set forth in the NOPR, DOE held formal in-progress peer reviews of the types of 

analyses and processes that DOE has used to develop the energy efficiency standards in today’s 

rule, and issued a report on these peer reviews. The report is available at 

http://www.eere.energy.gov/buildings/appliance_standards/peer_review.html. See 74 FR 61498. 

M. Congressional Notification 

As required by 5 U.S.C. 801, DOE will submit to Congress a report regarding the 

issuance of today’s final rule prior to the effective date set forth at the outset of this notice. The 

report will state that it has been determined that the rule is a “major rule” as defined by 5 U.S.C. 

804(2). DOE also will submit the supporting analyses to the Comptroller General in the U.S. 

Government Accountability Office (GAO) and make them available to each House of Congress. 

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EERE-2007-BT-STD-0007 COMMENT 31
For the reasons stated in the preamble, DOE amends part 431 of chapter II of title 10, of 


the Code of Federal Regulations, to read as set forth below. 

PART 431 - ENERGY EFFICIENCY 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. Section 431.446 is revised to read as follows: 

Energy Conservation Standards 

§431.446 Small electric motors energy conservation standards and their effective 

dates. 

(a) Each small electric motor manufactured (alone or as a component of 

another piece of non-covered equipment) after February 28, 2015, shall have an average 

full load efficiency of not less than the following: 

Motor horsepower/ 

standard kilowatt 

Average full load efficiency 

Polyphase 

Open Motors 

equivalent (number of poles) 

6 4 2 

0.25 / 0.18 67.5 69.5 65.6 

0.33 / 0.25 71.4 73.4 69.5 

0.5 / 0.37 75.3 78.2 73.4 

0.75 / 0.55 81.7 81.1 76.8 

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1 / 0.75 82.5 83.5 77.0 

1.5 / 1.1 83.8 86.5 84.0 

2 / 1.5 N/A 86.5 85.5 

3 / 2.2 N/A 86.9 85.5 

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Average full load efficiency 

Capacitor-Start Capacitor-Run and Capacitor-Start Induction-Run 

Open Motors 

 (number of poles) 

6 4 2 

0.25 / 0.18 62.2 68.5 66.6 

0.33 / 0.25 66.6 72.4 70.5 

0.5 / 0.37 76.2 76.2 72.4 

0.75 / 0.55 80.2 81.8 76.2 

1 / 0.75 81.1 82.6 80.4 

1.5 / 1.1 N/A 83.8 81.5 

2 / 1.5 N/A 84.5 82.9 

3 / 2.2 N/A N/A 84.1 

(b) For purposes of determining the required minimum average 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 efficiency standards in paragraph 

(a) 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 

horsepower ratings shall be rounded up to the higher of the two horsepower ratings; 

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

horsepower ratings shall be rounded down to the lower of the two horsepower ratings; or 

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

using the formula 1 kilowatt = (1/0.746) hp, without calculating beyond three significant 

decimal places, and the resulting horsepower shall be rounded in accordance with 

paragraphs (b)(1) or (b)(2) of this section, whichever applies. 

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APPENDIX 


[The following letter from the Department of Justice will not appear in the Code of 

Federal Regulations.] 

DEPARTMENT OF JUSTICE 

Antitrust Division 

Main Justice Building 

950 Pennsylvania Avenue, NW. 

Washington, DC 20530–0001 

(202) 514–2401/(202) 616–2645(f) 

antitrust.atr@usdoj.gov 

http://www.usdoj.gov/atr 

January 25, 2010 

Robert H. Edwards, Jr. 

Deputy General Counsel for Energy Policy 

Department of Energy 

Washington, D.C. 20585 

Dear Deputy General Counsel Edwards: 

I am responding to your November 19, 2009 letter seeking the views of the 

Attorney General about the potential impact on competition of proposed energy 

conservation standards for small electric motors. Your request was submitted pursuant to 

Section 325(o)(2)(B)(i)(V) of the Energy Policy and Conservation Act, as amended, 

(“EPCA”), 42 U.S.C. § 6295(o)(B)(i)(V), which requires the Attorney General to make a 

determination of the impact of any lessening of competition that is likely to result from 

the imposition of proposed energy conservation standards. The Attorney General’s 

responsibility for responding to requests from other departments about the effect of a 

program on competition has been delegated to the Assistant Attorney General for the 

Antitrust Division in 28 CFR § 0.40(g). 

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 Inconducting its analysis the Antitrust Division examines whether a proposed 

standard may lessen competition, for example, by substantially limiting consumer choice, 

leaving consumers with fewer competitive alternatives, placing certain manufacturers of 

a product at an unjustified competitive disadvantage compared to other manufacturers, or 

by inducing avoidable inefficiencies in production or distribution of particular products. 

We have reviewed the proposed standards contained in the Notice of Proposed 

Rulemaking (“NOPR”)(74 Fed. Reg. 61410) and attended the December 17, 2009 public 

hearing on the proposed standard. 

Based on our review of the record, the proposed standards for small electric 

motors could increase costs for consumers who need to replace small electric motors in 

existing equipment. Proposed Trial Standard Level (TSL) 5 for polyphase small electric 

motors and TSL 7 for all capacitor-start small electric motors apply to motors sold as 

replacements as well as to those built into original equipment. We understand that 

compliance with those standards could require manufacturers to increase the size of their 

motors such that the larger motors will not fit into existing space constrained equipment. 

In such a case, owners of existing equipment with a broken motor would have to either 

replace the entire piece of equipment or attempt to repair the motor. Such equipment 

owners would not have the option of simply replacing the existing small electric motor, 

thus limiting the range of competitive alternatives available to them. This may be quite 

onerous to consumers when the motor is only a small component of the total cost of the 

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item and repairing the motor is difficult or costly. We ask the Department of Energy to 

take this possible impact into account and consider, as is warranted, exempting from the 

proposed standard the manufacture and marketing of certain replacement small electric 

motors for a limited period in time. 

Sincerely,
 

Christine A. Varney,
 

Assistant Attorney General 


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