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U.S. Department of Energy 

Commercial and Industrial Pumps Negotiated Rulemaking Working Group 

Meeting Summary—Sixth Meeting 

Forrestal Building, Washington, D.C. 

May 28 - 29, 2014 

Members in Attendance (Day 1) 

Lucas Adin U.S. Department of Energy 

Tom Eckman Northwest Power and Conservation Council (ASRAC Member) 

Robert Barbour TACO, Inc. 

Charles Cappelino ITT Industrial Process 

Greg Case (via web) Pump Design, Development and Diagnostics (Hydraulic Institute) 

Dan Delaney Regal Beloit (alternate for Howard Richardson) 

Gary Fernstrom California IOUs 

Mark Handzel Xylem Corporation 

Brian Henry Patterson Pump 

Joanna Mauer Appliance Standards Awareness Project 

Doug Potts (via web) American Water 

Steve Rosenstock Edison Electric Institute 

Jay Savigny Flowserve Corporation, Industrial Pumps 

Louis Starr Northwest Energy Efficiency Alliance 

Greg Towsley Grundfos USA 

Doug Brookman Facilitator, Public Solutions, Inc. 

Absent Meg Waltner Natural Resources Defense Council 

Additional Attendees 

Ashley Armstrong, Alex Bosenberg, John Cymbalsky, Brian Henry, Al Issapon, Erica Johnson, 

Elizabeth Kohl, Christopher Lau, Brent McManis, Brent McManis, Steve Thompson, Daniel 

Weintraub, Sarah Widder and Alison Williams 

Author’s note 

The transcript for the May 28-29 WG meeting #6 was not made available until after the WG’s final 

meeting #7 on June 17-19. That final meeting resulted in a unanimous agreement on standards levels 

for in-scope pumps. That agreement is detailed in the WG’s Term Sheet that can be found in 

Appendix A of Meeting Summary #7, as well as in the public docket (EERE-2013-BT-NOC-0039). 

Since the regulatory negotiation was successfully concluded prior to writing this summary, the 

following meeting summary will be somewhat abbreviated. 

 

Day 1—Working Group Meeting #6, May 28, 2014 
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Facilitator Doug Brookman called the Working Group (WG) meeting to order and welcomed all 

present at 9:05AM. The WG proceeded with introductions around the room. 

A member started off the meeting describing the significant amount of time and effort the 

manufacturers and their staff had devoted to analysis and “trying to keep up with the changes” with a 

new calculator and between-meeting webinars. He expressed his hope that this meeting would bring a 

lot of clarification on these subjects. 

Following, Lucas Adin detailed intended meeting outcomes compiled by DOE and the consultant 

team: 

 Deliver a term sheet to ASRAC with recommended pump standards 

 Discuss general aspects of the test procedure (not authorized ‘in-scope’ for the WG) 

 Make progress, move toward closure on metrics 

 Provide updated results on the engineering analysis and lifecycle costs 

 Presentation/discussion on shipments data and Manufacturer Impact Analysis—the last of the 

major analytical elements to be considered 

 Discussion on comparisons between EU and DOE ‘C’ values 

 Additional discussion of radially-split vertical pumps 

 The goal for the June meeting: review all information, develop and vote on a term sheet 

 DOE clarified it will do a separate rulemaking, based on work underway and input, on the 

pumps test procedure 

In discussion, members: 

 Asked for a sample term sheet 

 Wanted to assure that tested values for the efficiencies of pumps exceed the calculated values 

 Asked what happened to the questions that emerged following the webinar—DOE said it 

posted the answers on the SharePoint site 

Dan Weintraub began presenting an Engineering Analysis update (p.41). He provided updates to the 

end suction and inline analyses as well as results from the submersible vertical turbines. He also 

provided a small update to the manufacturer selling price (MSP) versus efficiency relationship. He 

featured the following results: 

 The number of models eligible to be polished were reduced (by approximately one half). A 

member questioned the resulting number. 

 Additional capital conversion costs required to change to advanced casting was reduced by 

approximately one half. 

 Hydraulic redesign cost decreased by 15% 

 Updated model numbers based on new data 

 The cost of redesign per unit was adjusted to decrease linearly from PER 40 to PER10 

 Described how added precision caused the model numbers to change from month to month 

 Reconsidered and refined the estimated population of ‘failing’ pumps 

 Confirmed that the efficiency levels displayed are independent of the C value—C values and 

their correspondence to efficiency levels will be determined by the WG 

 Described that the presented efficiency levels were illustrative, that they could be easily 

changed/scaled to meet the WG’s inquiry and the analysis could be quickly completed 
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 Described how the preceding revisions had a very minor impact on the overall results 

 Confirmed that “the only design option on the table is hydraulic redesign.” 

Moving on, Dan described changes to two additional pump types: 

 Confirmed “not much change” in the analysis for vertical turbine submersible pumps 

 Described radial split vertical pumps as a global platform, with the same pumps sold in both 

the U.S. and in Europe. Europe is in the process of phasing out anything below MEI 40 

 Concluded by describing how the analysis depicts price differences based on pump efficiency 

differences. 

A member restated Dan’s conclusion: “so to really simplify this....you’re not going to see a (price) 

premium as a pump manufacturer if you fall anywhere between 21% and the 90% level?” 

Returning from the mid-morning break a manufacturer questioned the decision that the WG’s scope 

would not include deliberations on the test procedure. He asked if the WG could insert a one-line 

statement in the term sheet recommending the use of the HI test procedure. Lucas Adin clarified that 

the completed term sheet would be sent to ASRAC for consideration. Then ASRAC would make its 

recommendation to DOE. He continued that DOE’s consultant had participated in the development of 

the HI test procedure. A member contributed that one concern was the ‘extended product’ part of the 

test metric. Lucas continued that establishing a sub-working group was possible and confirmed that, 

regardless, a test procedure NOPR would be required. Sarah Widder contributed that time had been 

allocated in Day 2 to discuss key metric issues, as they related to the test method such as load points, 

weights and the general architecture. Another member restated his desire to have a statement 

endorsing the HI test method in the term sheet. 

A manufacturer questioned the statement that the metric was going to be based on the ‘bare pump’ 

only. Sarah Widder responded that “a given pump can be rated as a bare pump plus a default motor, a 

pump plus a more efficient motor that it’s sold with, or a pump plus a more efficient motor and 

controls. And that will be reflected in the rating, but the standard will be set....only looking at 

improvements to pump efficiency.” Another manufacturer described the concern that introducing “the 

motor and the drive and taking set efficiency values....are leading to false calculations that we would 

be unable to emulate on a test standard if we were doing wire-to-water efficiency testing.” 

Next, Alison Williams presented updates to the Life-Cycle Cost (LCC) Analysis. She described the 

fundamental purposes of the LCC, the shipments model and National Impact Analysis (NIA) (p.120). 

She described the following revisions in a detailed presentation: 

 Changed the distribution channel weightings, raising the pump OEM to distributor to 

contractor to end user from 17% to 70%, which resulted in a change in the mark up and 

incremental mark up. 

 Revised load profile estimates based on manufacturer’s comments (with very little resulting 

impact), which changed the operating hours distributions 

 Restated that the analysis shows that “the energy savings dwarfed the costs in almost all 

situations” 

 Revised the lifetime estimates for vertical turbine submersible and other pump types 

 Adjusted average mechanical life hours estimates 

 Clarified that repair could mean a full range improvements to an installed pumps 
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 Showed different sector weights for vertical turbine submersible pumps 

Alison moved on to the results, describing two scenarios: one where no costs are passed on to 

consumers and another where full costs are passed on to consumers. She concluded that “the current 

market structure for pricing is the same in the base case and the standards case. So not surprisingly in 

this case, the average LCC savings are positive for everything because the delta increase cost is very 

small (p.149).” She continued describing the payback period as being low (for this lower bound 

scenario). 

Alison began to describe the second, full-cost recovery scenario. Responding to a member’s question, 

she stated that the full cost recovery is over the full analysis period—30 years, which at a discount rate 

of 11.8% is approximately 10-11 years. Chris Lau clarified the two scenarios are meant to bound the 

mark ups. A member questioned the results of the upper-bound calculation (16%). 

Moving on to the average LCC savings, Alison described the results: almost all the pumps in different 

horsepower bins resulted in positive LCC savings, while a few did not (p.166). Manufacturers 

restated, again, their inability to pass on price increases due to pump redesign. Comments and 

discussion continued on DOE’s 30 year analysis period and the manufacturers’ ability to recover 

costs. Alison clarified that some of the confusion was that the 30 year analysis period is not really 

applicable to the LCC—it is applicable to the MIA and NIA. The MIA will describe how the 

manufacturers are affected over the 30 year period. 

Alison returned to presenting the results of the full-cost recovery scenario—the worst case for 

consumers. She noted some variability, “but overall across most of the equipment classes, there’s still 

more consumers benefitting than there are being burdened.” She also showed the payback period 

analysis results (p.183). The WG broke for lunch. 

At the lunch break DOE distributed the detailed power point presentation slides that were presented in 

the morning session. Returning from lunch the manufacturer’s caucus spokesperson Mark Handzel 

described how the caucus had reviewed the material at lunch and needed more time to consider the 

content, especially when considering sensitive issues such as pricing and cost recovery (p.188). A 

manufacturer asked if there was a way the industry could learn from DOE’s previous experience. 

John Cymbalsky responded that DOE does this analysis in all its rulemakings. The information 

gathered and analyzed results in lower and upper bounds representing cost recovery that will be 

presented in the MIA. Several members added comments based on their experience with standards 

setting and the unique features of the pumps industry (p.194). 

Alison Williams began presenting the shipments analysis, summarizing “national net present value is 

basically positive for everything across-the-board.” She continued saying the shipments analysis 

feeds into the national impact analysis and the manufacturer impact analysis. And, the shipments 

model projects shipments over the 30 year analysis period, starting with historical data for each 

equipment category. What followed was a detailed discussion on a range of shipments issues: 

speculation on numbers and types of pumps and the impact of imports (p.205). 

Alison continued, describing an analytic method that the team ultimately rejected, using AEO 

projections of investment to predict shipments, based on the experience of the motors rulemaking. 
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Instead, she relied on historical census data, taking current shipments data and projecting the 

shipments forward using various AEO trends such as commercial floor space and the value of 

manufacturing shipments. This analysis resulted in shipments projections growing from 420,000 in 

2019 to approximately 700,000 in 2048. Members noted the inherent difficulty in projecting 30 years 

out. Alison also noted that the team was using the same shipments forecast in the base case as in the 

standards case. 

Alison began presenting the NIA (p. 217). The NIA estimates the national energy savings from new 

energy conservation standards and the national net present values (NPV) for the nation as a whole. 

The method is to take the unit lifetime energy savings multiplied by projected shipments and 

accumulating this over the 30 year analysis period. For the NPV, the team looks at the difference 

each year between energy bill savings and increased equipment expenditures. The national energy 

savings is the difference between the base case energy consumption in each year and the standards 

case energy consumption in each year—the difference is the national energy savings. Continuing she 

described the use of Trial Standard Levels (TSLs) and how they corresponded to the PER that the WG 

had been using. 

In discussion, members questioned: 

 The sector weightings 

 Total installed cost estimates as pumps are pushed to higher efficiency levels 

 Changes to the electricity conversion factors 

After the afternoon break, Chris Lau began presenting the MIA (p. 235). The purpose of the MIA is 

to assess the impacts of different efficiency standards levels on manufacturers, utilizing a cash flow 

model. The analysis considers the manufacturer’s production costs, the shipments forecasts, financial 

parameters and markups to derive the manufacturers selling price (MSP). Continuing, he described 

the inputs: industry shipments and industry pricing that give you revenue; subtract cost of capital and 

operating costs and the result is an estimate of operating profit. Then the team utilized a discounted 

cash flow model (GRIM), modeling a lower bound scenario and an upper bound scenario. The 

industry’s capital conversion costs to meet a new efficiency standard are spread over the four year 

period to the effective date. Responding to a question, Chris described that the analysis assumes the 

MPCs would not change as the standard increased—however there would be conversion costs and 

those conversion costs would drive price increases. Detailed discussion on the implications for 

conversion costs, imports and shipments ensued. The team concluded by saying that, while iterations 

or tweaks could be made, all the rulemaking analyses had now been presented (p. 257). 

As discussion continued, members questioned or added: 

 The ability of the industry to execute the necessary changes in the proposed timeframe 

 How to consistently achieve the energy efficiency gains in the marketplace utilizing an 

extended product approach 

 Described how additional motor efficiency standard-setting efforts are underway in Europe, 

including test procedure development 

 Reiterated the desire for the metric and labeling provisions to inform successful utility 

programs 

The discussion continued on practical matters of applying a prospective standard. 
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Next Dan Weintraub began presenting on C values, saying that C values are used to define each 

efficiency level for each equipment class. The analysis team developed PER C values at each 

efficiency level for both the DOE and HI data sets. Dan presented charts which compared the two 

data sets, which were fairly similar. Dan described how they were working on merging the two data 

sets. He reviewed the results for each pump class and summarized some results: 

 End suction close couple, DOE C values are consistently more efficient by an average of half a 

point 

 Frame-mounted are consistently more efficient by 1.1 efficiency points 

 Inline are consistently more efficient by an average of .25 efficiency points 

 For VT-S, it’s flipped, where DOE C values are less efficient by an average of .7 points 

Member questioned the results, for what should be two data sets that are very similar. Dan clarified 

that there was an MEI C value and PER C value and they represent different things (p.305). 

Dan continued on the topic of MEI, presenting an evaluation of the relative efficiency of the US and 

EU populations by comparing the MEI C values from the DOE data set, the HI data set and the EU 

Lot 11 data set. He described the methodology and the following results: generally, the EU is less 

efficient, probably because the EU data is older. Dan continued with a description of differences 

between the DOE and HI data sets. 

Moving on, members began to discuss the general shape/content of prospective proposals to begin 

negotiating. One member identified several factors that are important to the energy efficiency 

advocates caucus: conversion time and resource issues for the industry, harmonization with the EU, 

the tradeoffs between manufacturing impacts and consumer impacts and also the effective date of the 

standard. He questioned whether some phase-in approach was possible. Betsy Kohl responded that 

DOE’s “reading of the statute indicates that we have a five year time lag.” In subsequent comments, 

members indicated that the timing of implementation could be important to the industry. 

Another member, summarizing, reiterated some of the factors listed above and asked about 

enforcement and if that figures into the negotiation. He continued, raising the issue of extended 

product and what the WG would like to do with it. 

The facilitator confirmed that the Day 2 agenda would start with the standards negotiation and then 

proceed to the metrics discussion. The WG adjourned for the day. 

Day 2—Working Group Meeting #6, May 29, 2014 

Attendance: All members present for Day 1 were also present for Day 2 

The facilitator called the meeting to order at 8:05AM. The WG proceeded with introductions around 

the room. The Day 2 Agenda included the following: 

 Member’s questions at the outset 

 A first round in the standard-setting negotiation, and 

 Moving toward closure on metrics 
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Questions 

A member led off, asking about the details on implementation of standard. Lucas Adin responded that 

some of that will need to be addressed in a subsequent rulemaking, but generally DOE sets standard 

levels, creates a test procedure and adopts specific procedures for enforcement. The enforcement 

process for DOE generally relies on upon manufacturer self-certification. For a given product that 

is subject to the standard, each basic model has to be assigned a rating and its compliance with the 

standard has to be certified by the Department. That is the responsibility of the manufacturer. The 

testing can be done by the manufacturer or a test lab, in accordance with the established test 

procedure. 

A manufacturer inquired about the number of pumps tested and sampling. Lucas described that the 

testing of each basic model is typically based on a sample size of two. He indicated that DOE 

would create the test procedure through a rulemaking, subject to normal comment provisions 

including this WG. A member suggested that NEMA might serve as a resource on these questions, 

since they have been responding to regulations for 20 years. Lucas confirmed that DOE would be 

looking for input from the industry as any rulemaking proceeds. 

Initial Proposals 

Mark Handzel, speaking on behalf of the manufacturers, restated some of his member’s concerns 

and limitations and offered PER 15 as proposed standard level (P.30). He continued this level would 

not overburden their engineering departments and would set the bar above the EU’s initial starting 

point. 

Tom Eckman, speaking on behalf of the energy efficiency advocates caucus, responded by offering 

a performance goal proposal. That goal was .25 quads of energy savings. He stated that how the 

WG achieves that could be the subject of lots of discussion. 

In discussion, a member asked if the industry’s capacity to redesign was really the determining 

factor in offering PER 15. Mark indicated there were several factors. Another member asked if RSV pumps could contribute to the goal. Alison said, because it is a global platform and the baseline 

is high, the WG probably won’t get much savings. Other members talked about the benefits and 

burdens of synchronizing with the EU, whose standard for RS-V rises to MEI 40 in 2015. 

Members also discussed the potential of extended product to contribute to the savings (P.56). 

Lucas commented that the potential gain was inherent in the metric and the label as well. Another 

member raised the potential benefits of additional data points—part load values—that would be 

captured in a DOE database. Another member commented that would be useful in structuring utility 

programs. There were different interpretations about whether DOE could or would create such a 

database. Several members endorsed the concept and described the benefits of making the data 

available. A detailed discussion of the potential benefits continued. Another member cautioned 

that not all manufacturers, especially small ones, might have the capacity to offer an extended 

product. 

Next Betsy Kohl provided some additional information on the compliance date issue. Previously 

DOE had said five years was set. Betsy said, after further review, the Department had determined 
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there was no statutory prescription for five years in this case. Continuing, she said that means the 

period could be three years or seven years—the WG could have different compliance dates for 

different product classes. Betsy also confirmed that there were still statutory prohibitions on 

‘tiering’ among the product classes. Alison also clarified that the 2019 compliance date that she 

was showing is actually only three years from the publication of the final rule, which is 2016. 

Members turned to questions on specific slides related to the NIA (P. 95). Alison confirmed the 

results reflect pump efficiency only. And use the same default (premium) motors in the base case 

and the standard case. Questions and discussion continued on the reasons the advocates caucus 

settled on .25 quads as their proposal. A member of that caucus summarized some of their thinking, 

saying that harmonization with the EU and the fact that they were going to MEI 40 in 2015, “we 

kind of saw that as the lowest level we might want to go.” She continued that more discussion was 

needed based on new information (P. 106) 

Metrics (P.107) 

Sarah Widder started with a review of the general architecture of the proposed metric. She restated 

the definition of PER (pump energy rating) and floated new term PEI or pump energy index for 

consideration. This would mean separate terms for separate pieces of information that go into the 

metric—“You have a separate term to refer to that weighted average pump input power and then a 

unique term for the ratioed value, and you can be clear when you are talking about them.” Members 

endorsed the idea of two terms. 

Sarah continued describing loading points of 75%, 100% and 110% of the BEP flow rate for 

constant load application of bare pumps—and equal weighting those points. For variable load 

applications she referenced the earlier discussion, arriving at 25%, 50%, 75% and 100% of BEP 

flow rate of the pump, also equally weighted. Manufacturers spoke in agreement with this general 

construct. 

Alison Williams clarified/restated the three things the WG should vote on are: 

 The general pump energy index as a ratio of the controlled or uncontrolled PER for that 

pump, and the PER max of the uncontrolled minimally compliant pump on the bottom 

 The pump weights, where they are equally weighted, and 

 The load points 

 The detailed discussion continued on the topic of full load losses (P. 127) and motor sizing and, 

finally, part-load motor losses (P. 146). 

A member raised the issue of manufacturer’s published data that may not be accurate. In 

discussion, DOE described that motors had a test method for nominal full load efficiency. A 

member asked who is responsible for assuring pump-motor combination is compliant when the 

pump manufacturer accepts the motor manufacturer’s data. Lucas replied that, while details need to 

be addressed, generally, pump manufacturers are responsible for the pump rating given to DOE. 

Members described how the use of alternative efficiency determination method (AEDM)—a 

validated system that shows test data calibrating back to models—could be beneficial. Members 

reiterated that all of this would need to be articulated in the test procedure. In discussion, members 

and the analysis team also confirmed that part-load loss testing is a part of the motors test 

procedure. 
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Sarah continued, giving a very detailed presentation on the primary, or default, calculation option, 

which requires a part-load loss curve to account for the impact of part loading on motor efficiency 

(P. 193). She reviewed a very complicated cubic polynomial equation and explained the major 

equation elements. What followed was a very detailed discussion on the application of this 

calculation option, that referencing other, existing test procedures (P. 214). Sarah raised the issue of 

using a .98 scaling factor. There was additional discussion about the use of a PEI rather than a PER 

value. After some detailed exchanges, a manufacturers’ caucus member stated that they prefer the 

PEI construct. 

After more detailed discussion, Sarah suggested that the WG consider and vote on the load points 

and weighting that had been discussed earlier. She restated the proposal: for uncontrolled pumps 

the PERcl (for constant load application) had load points of 110%, 100% and 75% and equal 

weighting of those three points; for pumps sold with controls, apply a variable load curve using 

flow points of 25%, 50%, 75% and 100% of BEP flow and they would also be equally weighted. 

As the facilitator moved to call for a vote, the manufacturers’ spokesperson asked if the WG could 

delay a vote until the June meeting. 

Interim Report to ASRAC 

DOE thought it would be a good idea to update ASRAC on the WG’s progress at their next meeting 

(June 6). The facilitator had been tasked to write the report. He described that he intended to keep 

it short, to describe the information the WG had discussed and, also what it had agreed upon and 

describe what lies ahead. The facilitator described how he intended to share it with Lucas Adin to 

assure no major gaps. Members asked if they could listen in on the ASRAC meeting—they could. 

A manufacturer asked if it was possible to get a list of deliverables or check list to make sure the 

WG completed its work. Lucas responded that what was needed was for the WG to agree on a 

standard level (or multiple ones) and any other specific recommendations it wishes to make. A 

member described how the manufacturers would definitely want to give consideration to the test 

procedure, if time allowed. Other members weighed in on additional topics for the WG to consider. 

The discussion turned to the June meeting dates and the prospect that the scheduled July meeting 

dates may be shorter or, even, not necessary. There was a question whether the WG should 

formally seek to include examination of the test procedure in its work statement through at request 

to ASRAC. In discussion, the WG decided to do detailed test procedure work as time allowed. This 

prompted a question about whether another webinar would be useful. The manufacturers had 

requested additional information about the financial analyses presented previously. In discussing 

options, Chris Lau offered that he could put together a slide deck that had more complete 

information and make that available. Members clarified that the presentation should be available to 

all to listen in. Lucas suggested that DOE schedule a webinar. The WG established June 4 at 

1:00PM EDT as the proposed webinar time, subject to confirmation from DOE. 

Dan Weintraub began the final presentation of the day on the VT-S and RS-V product classes. 

Since RS-V is global product, the intention was to harmonize with the EU for the C values. He 

proposed taking the MEI C values and shift them (using an average difference translation factor) to 

get as close as possible to the EU in this product class (P.287). Manufacturers requested that Dan 

send his best estimate of the value to them so they could do the analysis. The other issue was 
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vertical turbine submersible pumps. In the EU they only regulated two pole pumps (3600 RPM). 

He described two paths forward: manufacturers can submit data and DOE report back or they can 

utilize the calculator for their own calculations on four pole pumps. Manufacturers said that very 

few (to zero) four pole pumps were sold and they would do the calculations. Dan confirmed that 

implied, and he anticipated, that would result in one set of C values for both equipment classes 

based off a two pole configuration. Alison, following on, suggested that as a consequence the team 

would not do analysis on the VT-S four pole or RSV, since there are no energy savings. 

The facilitator did a brief summary of WG’s accomplishments during the last two days, including: 

 Detailed presentations on LCC, shipments and NIA—completing the major analyses for the 

negotiation 

 A first exchange of standards proposals from the two major caucuses 

 A detailed presentation on metrics 

 Discussion on a report to ASRAC 

 Considered some key issues on the test procedure 

The meeting adjourned at 2:58 PM 

Meeting Summary compiled by Doug Brookman 

July 8, 2014 

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