small_electric_motors_st To: Antonio Bouza@Exchange

d rulemaking cc:

Sent by: Antonio Bouza Subject: Notice of public meeting and availability of the Framework Document

for small electric motors

08/14/2007 07:53 AM

0 Federal Record Not a Federal Record

User Filed as : Not Categorized in ERMS

To all Small Electric Motors stakeholders:

The Department of Energy is writing to inform you that the Notice of public meeting and

availability of the Framework Document for small electric motors was published recently in

the Federal Register. Please find the file attached below with a copy of the framework

document for your review.

The Department will be updating its website and posting these files soon:

http://www.ecre.enerRv.Rov/buildin2s/a

s.html

ppliance standards/commercial/small electric motor

The purpose of this document is to describe the procedural and analytical approaches DOE

anticipates using to evaluate energy conservation standards for small electric motors. This

document is intended to inform stakeholders of the process DOE will follow for the

standards rulemaking for these motors and to encourage and facilitate stakeholder input

during the rulemaking. This document is merely the starting point for developing standards

and is not a definitive statement with respect to any issue to be determined in the rulemaking.

Stakeholders are invited to comment on the Department's framework document, and to

attend a public meeting at the Department of Energy in Washington DC from 9:00am to

5:00pm on September 13th, 2007. At the public meeting, all statements will be recorded and

transcribed, and will become part of the official record of the standards rulemaking. Any

person requesting to speak at the public meeting should submit such request along with a

signed original and an electronic copy of statements to be given at the meeting before 4:00

p.m., Thursday, August 30, 2007. Written comments are welcome, especially following the

public meeting, and should be submitted by Friday, September 28, 2007.

Stakeholders may submit comments, identified by docket number

EERE-2007-BT-STD-0007 and/or Regulatory Identifier Number (RIN) 1904-AB70, by any

of the following methods:

o Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for

submitting comments.

o E-mail: small_electric_motors_std.rulemaking@ee.doe.gov. Include docket number

EERE-2007-BT-STD-0007 and/or RIN 1904-AB70 in the subject line of the message.

o Mail: Ms. Brenda Edwards-Jones, U.S. Department of Energy, Building Technologies

Program, Mailstop EE-2J, Framework Document for Small Electric Motors, docket number

EERE-2007-BT-STD-0007 COMMENT 01.3
EERE-2007-BT-STD-0007 and/or RIN 1904-AB70, 1000 Independence Avenue, SW,

Washington, DC 20585-0121 . Please submit one signed paper original.

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

Building Technologies Program, Room 1J-018, 1000 Independence Avenue, SW,

Washington, DC 20585-0121. Telephone: (202) 586-2945 . Please submit one signed paper

original.

We appreciate your thorough review of the material and look forward to your participation at

the public meeting and your comments on the Rulemaking Framework Document for Small

Electric Motors.

Sincerely,

Antonio Bouza

Building Technologies Program

U.S. Department of Energy

1000 Independence Avenue, SW

Washington DC 20585-0121

phone: 202. 586.4563

antonio.bouza@ee.doe.gov

SM_Framework Document.pdf 72 FR 44990 - Small Motors Framework Doc Meeting.pdf

EERE-2007-BT-STD-0007 COMMENT 01.3
44990 Federal Register /Vol. 72, No. 154 /Friday, August 10, 2007 /Proposed Rules

Dated at Rockville, Maryland, this 27th day

of July, 2007.

For the Nuclear Regulatory Commission.

Luis A. Reyes,

Executive Director for Operations.

[FR Doc. E7-15554 Filed 8-9-07; 8:45 am]

BILLING CODE 7590-01-P

DEPARTMENT OF ENERGY

Office of Energy Efficiency and

Renewable Energy

10 CFR Part 431

[Docket No. EERE-2007-BT-STD-0007]

RIN 1904-AB70

Energy Efficiency Program for Certain

Commercial and Industrial Equipment:

Public Meeting and Availability of the

Framework Document for Small

Electric Motors

AGENCY: Office of Energy Efficiency and

Renewable Energy, Department of

Energy.

ACTION : Notice of public meeting and

availability of the Framework

Document.

SUMMARY: The Department of Energy

(DOE or Department) is initiating the

rulemaking process to adopt new energy

conservation standards for small electric

motors. Accordingly, the Department

will hold an informal public meeting to

discuss and receive comments on issues

it will address in this rulemaking

proceeding. The Department also

encourages written comments on these

subjects. To inform stakeholders and

facilitate this process, DOE has prepared

a Framework Document, which is

available at: http://www.eere.

energy.gov/buildings/applian cestandards/.

DATES : The Department will hold a

public meeting on Thursday, September

13, 2007 from 9 a.m. to 5 p.m. at DOE

headquarters in Washington, DC. Any

person requesting to speak at the public

meeting should submit such request

along with a signed original and an

electronic copy of statements to be given

at the meeting before 4 p.m., Thursday,

August 30, 2007. Written comments are

welcome, especially following the

public meeting, and should be

submitted by Friday, September 28,

2007.

ADDRESSES : The public meeting will be

held at the U.S. Department of Energy,

Forrestal Building, Room 1E-245, 1000

Independence Avenue, SW.,

Washington, DC 20585-0121. (Please

note that foreign nationals participating

in the public meeting are subject to

advance security screening procedures.

If a foreign national wishes to

participate in the workshop, please

inform DOE of this fact as soon as

possible by contacting Ms. Brenda

Edwards-Jones at (202) 586-2945, so

that the necessary procedures can be

completed.)

Stakeholders may submit comments,

identified by docket number EERE2007-BT-STD-0007 and/or Regulatory

Identifier Number (RIN) 1904-AB70, by

any of the following methods:

® Federal eRulemaking Portal: http://

www.regulations.gov. Follow the

instructions for submitting comments.

o E-mail: small-electric-motorsstd.rulemaking@ee.doe.gov. Include

docket number EERE-2007-BT-STD0007 and/or RIN 1904-AB70 in the

subject line of the message.

o Mail: Ms. Brenda Edwards-Jones,

U.S. Department of Energy, Building

Technologies Program, Mailstop EE-2J,

Framework Document for Small Electric

Motors, docket number EERE-2007-BTSTD-0007 and/or RIN 1904-AB70, 1000

Independence Avenue, SW.,

Washington, DC 20585-0121. Please

submit one signed paper original.

o Hand Delivery/Courier: Ms. Brenda

Edwards-Jones, U.S. Department of

Energy, Building Technologies Program,

Room 1J-018, 1000 Independence

Avenue, SW., Washington, DC 20585-

0121. Telephone: (202) 586-2945.

Please submit one signed paper original.

Instructions: All submissions received

must include the agency name and

docket number or RIN for this

rulemaking.

Docket: For access to the docket to

read background documents, a copy of

the transcript of the public meeting, or

comments received, go to the U.S.

Department of Energy, Forrestal

Building, Room 1J-018 (Resource Room

of the Building Technologies Program),

1000 Independence Avenue, SW.,

Washington, DC 20585-0121, (202) 586-

9127, between 9 a.m. and 4 p.m.,

Monday through Friday, except Federal

holidays. Please call Ms. Brenda

Edwards-Jones at the above telephone

number for additional information

regarding visiting the Resource Room.

FOR FURTHER INFORMATION CONTACT:

Antonio M. Bouza, U.S. Department of

Energy, Office of Energy Efficiency and

Renewable Energy, Building

Technologies, EE-2J, 1000

Independence Avenue, SW.,

Washington, DC 20585-0121, (202) 586-

586-4563. E-mail:

Antonio.Bouza@ee.doe.gov; Francine

Pinto, Esq., or Eric Stas, Esq., U.S.

Department of Energy, Office of the

General Counsel, GC-72, 1000

Independence Avenue, SW.,

Washington, DC 20585-0121, (202) 586-

9507. E-mail:

Francine.Pinto@hq.doe.gov or

Eric. Stas@h q. d oe.gov.

SUPPLEMENTARY INFORMATION: The

Energy Policy and Conservation Act

(EPCA) of 1975 (42 U.S.C. 6291-6309)

established an energy conservation

program for major household

appliances. The National Energy

Conservation Policy Act of 1978

(NECPA) amended EPCA to add Part C

of Title III (42 U.S.C. 6311-6317), which

established an energy conservation

program for certain industrial

equipment. The Energy Policy Act of

1992 (EPACT), Public Law 102-486,

also amended EPCA, and included

amendments that expanded Title III to

include certain types of commercial

equipment, including small electric

motors. Specifically, EPACT amended

section 346 of EPCA (42 U.S.C. 6317) to

provide that the Secretary of Energy

prescribe testing requirements and

energy conservation standards for those

small electric motors for which the

Secretary determines that standards

"would be technologically feasible and

economically justified, and would result

in significant energy savings." (42

U.S.C. 6317(b)(1))

On July 10, 2006, the Secretary of

Energy made a positive determination

with respect to testing requirements and

energy conservation standards for small

electric motors. 71 FR 38799. As a result

of DOE's determination analysis, the

Secretary determined preliminarily that

standards for small electric motors

would be "technologically feasible and

economically justified, and would result

in significant energy savings." DOE will

determine whether and at what level to

promulgate energy conservation

standards for small electric motors

based on in-depth consideration, with

public participation, of the technical

feasibility, economic justification, and

energy savings of potential standards

levels in the context of prescribing new

or amended standards pursuant to

section 325(o) and (p) of EPCA (42

U.S.C. 6295(o), (p)).

To begin the required rulemaking

process, the Department prepared a

Framework Document to present the

issues and explain the analyses and

process it anticipates using to set energy

conservation standards for small electric

motors. The focus of the public meeting

will be to discuss the analyses and

issues identified in various sections of

the Framework Document. During the

Department's presentation to

EERE-2007-BT-STD-0007 COMMENT 01.3
Federal Register /Vol. 72, No. 154 /Friday, August 10, 2007 /Proposed Rules

stakeholders, the Department will

discuss each item listed in the

Framework Document as an issue for

comment. The Department will also

make a brief presentation on the

rulemaking process for these products.

The Department encourages those who

wish to participate in the public

meeting to obtain the Framework

Document and be prepared to discuss its

contents. However, public meeting

participants need not limit their

discussions to the topics in the

Framework Document. A copy of the

draft Framework Document is available

at: http://www.eere.energy.gov/

buildings/appliance_standards/. The

Department is also interested in

receiving views concerning other

relevant issues that participants believe

would affect energy conservation

standards for these products. The

Department also welcomes all interested

parties, whether or not they participate

in the public meeting, to submit in

writing by Friday, September 28, 2007,

comments and information on the

matters addressed in the Framework

Document and on other matters relevant

to consideration of standards for these

small electric motors.

The public meeting will be conducted

in an informal, facilitated, conference

style. There shall be no discussion of

proprietary information, costs or prices,

market shares, or other commercial

matters regulated by the U.S. antitrust

laws. A court reporter will be present to

prepare a transcript of the meeting.

After the public meeting and the

expiration of the period for submission

of written statements, the Department

will begin conducting the analyses as

discussed at the public meeting and

reviewing the comments received.

Anyone who would like to participate

in the public meeting, receive meeting

materials, or be added to the DOE

mailing list to receive future notices and

information regarding small electric

motors, should contact Ms. Brenda

Edwards-Jones at (202) 586-2945.

Issued in Washington, DC, on August 3,

2007.

Alexander A. Karsner,

Assistant Secretary, Energy Efficiency and

Renewable Energy.

[FR Doc. E7-15692 Filed 8-9-07; 8:45 am]

BILLING CODE 6450-01-P

DEPARTMENT OF LABOR

Employee Benefits Security

Administration

29 CFR Part 2560

RIN 1210-AB23

Amendments to Civil Penalties Under

ERISA Section 502(c)(7)

AGENCY: Employee Benefits Security

Administration, Labor.

ACTION: Proposed rule.

SUMMARY: This proposed rule is a

companion to the Department of Labor/

Employee Benefits Security

Administration's (Department) direct

final rule (published today in the "Rules

and Regulations" section of the Federal

Register) amending the Department's

civil penalty regulation under section

502(c)(7) of the Employee Retirement

Income Security Act of 1974 (ERISA or

the Act) to reflect recent amendments to

section 502(c)(7) by the Pension

Protection Act of 2006. These

amendments authorize the Secretary of

Labor to assess civil penalties not to

exceed $100 per day for each violation

of section 101(m) of ERISA. Section

101(m) of ERISA requires plan

administrators of individual account

plans to notify participants and

beneficiaries of their right to sell the

company stock in their accounts and

reinvest the proceeds into other

investments available under the plan.

The Department is publishing these

amendments as a direct final rule

without prior proposal because the

Department views them as highly

technical and anticipates no significant

adverse comment. The Department has

explained its reasons in the preamble to

the direct final rule. If the Department

receives no significant adverse comment

during the comment period, no further

action on this proposed rule will be

taken. However, if the Department

receives significant adverse comment,

the Department will withdraw the direct

final rule and it will not take effect. In

that case, the Department will address

all public comments in a subsequent

final rule based on this proposed rule.

The Department will not institute a

second comment period on this rule.

Any parties interested in commenting

must do so during this comment period.

DATES : Comments must be received on

or before September 10, 2007.

ADDRESSES : To facilitate the receipt and

processing of comments, the

Department encourages interested

persons to submit their comments

electronically by e-mail to e44991

ORl@dol.gov, or by using the Federal

eRulemaking portal at

www.regulations.gov (follow

instructions for submission of

comments). Persons submitting

comments electronically are encouraged

not to submit paper copies. Persons

interested in submitting comments on

paper should send or deliver their

comments (at least three copies) to the

Office of Regulations and

Interpretations, Employee Benefits

Security Administration, Room N-5669,

U.S. Department of Labor, 200

Constitution Avenue, NW., Washington,

DC 20210, Attn: 502(c)(7) Civil Penalty.

Comments received will be posted

without change, including any personal

information provided, to

www.regulations.gov and http://

www.dol.gov/ebsa, and also available for

public inspection at the Public

Disclosure Room, Employee Benefits

Security Administration, Room N-1513,

U.S. Department of Labor, 200

Constitution Avenue, NW., Washington,

DC.

FOR FURTHER INFORMATION CONTACT:

Stephanie L. Ward, Office of

Regulations and Interpretations,

Employee Benefits Security

Administration, (202) 693-8500. This is

not a toll-free number.

SUPPLEMENTARY INFORMATION : As noted

above, in the "Rules and Regulations"

section of today's Federal Register, the

direct final rule being published makes

technical changes to the Department's

existing civil penalty regulation at 29

CFR 2560.502c-7 for violations of

section 101(i) of ERISA, relating to

blackout notices, in order to conform

the regulation to section 502(c)(7) of

ERISA, as amended by the Pension

Protection Act of 2006, Public Law 109-

280, 120 Stat. 780, for violations of

section 101(m) of ERISA, relating to

diversification rights. The provisions

proposed here are those contained in

the direct final rule. Please refer to the

preamble and regulatory text of the

direct final rule for further information

and the actual text of the revisions.

Additionally, all information regarding

Statutory and Executive Orders for this

proposed rule can be found in the

Supplementary Information section of

the direct final rule.

Signed at Washington, DC, this 3rd day of

August, 2007.

Bradford P. Campbell,

Acting Assistant Secretary, Employee Benefits

Security Administration, Department of

Labor.

[FR Doc. E7-15568 Filed 8-9-07; 8:45 am]

BILLING CODE 4510-29-P

EERE-2007-BT-STD-0007 COMMENT 01.3
Energy Conservation Standards

le a °ng Framework Document for

Small Electric Motors

U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

July 30, 2007

EERE-2007-BT-STD-0007 COMMENT 01.3
TABLE OF CONTENTS

1 INTRODUCTION .................................................................................................................. 1

1.1 The Appliances and Commercial Equipment Standards Program .................................. 1

1.2 Overview of Definition and Sub-categories of Covered Small Electric Motors ............ 2

1.2.1 Single-phase Small Electric Motors ........................................................................ 3

1.2.2 Polyphase Small Electric Motors ............................................................................ 4

1.3 Overview of the Rulemaking Process ............................................................................. 4

1.3.1 Test Procedures ....................................................................................................... 5

1.3.2 Rulemaking Process and Stakeholder Participation ............................................... 5

1.4 Advance Notice of Proposed Rulemaking ...................................................................... 6

1.5 Notice of Proposed Rulemaking ..................................................................................... 8

1.6 Final Rule ........................................................................................................................ 8

2 OVERVIEW OF ANALYSES FOR RULEMAKING ........................................................... 9

3 MARKET AND TECHNOLOGY ASSESSMENT ............................................................. 11

3.1 Market Assessment ....................................................................................................... 11

3.2 Equipment Classes ........................................................................................................ 12

3.3 Technology Assessment ................................................................................................ 12

3.4 Baseline Models ............................................................................................................ 14

4 SCREENING ANALYSIS ................................................................................................... 14

5 ENGINEERING ANALYSIS ............................................................................................... 15

5.1 Engineering Analysis Overview ................................................................................... 16

5.2 Engineering Analysis Approach ................................................................................... 17

5.3 Manufacturer Prices ...................................................................................................... 18

5.4 Proprietary Designs ....................................................................................................... 18

5.5 Outside Regulatory Changes Affecting the Engineering Analysis ............................... 18

6 ENERGY USE AND END-USE LOAD CHARACTERIZATION .................................... 19

7 MARKUPS FOR EQUIPMENT PRICE DETERMINATION ............................................ 20

8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS .......................................... 21

8.1 Energy Prices ................................................................................................................ 21

8.2 Life-Cycle Cost Discount Rates .................................................................................... 22

8.3 Maintenance, Repair, and Installation Costs ................................................................. 22

8.4 Motor Lifetimes ............................................................................................................ 23

9 SHIPMENTS ANALYSIS .................................................................................................... 23

9.1 Base Case Forecast ....................................................................................................... 23

9.2 Accounting Methodology ............................................................................................. 24

9.3 Standards Impacts on Motor Shipments ....................................................................... 24

10 NATIONAL IMPACT ANALYSIS ..................................................................................... 25

10.1 Inputs to Forecasts ........................................................................................................ 25

10.2 Calculation of National Energy Savings ...........................................................

10.3 Net Present Value ......................................................................................................... 26

11 LIFE-CYCLE COST SUBGROUP ANALYSIS ................................................................. 26

12 MANUFACTURER IMPACT ANALYSIS ......................................................................... 27

12.1 Sources of Information for the Manufacturer Impact Analysis .................................... 27

12.2 Industry Cash Flow Analysis ........................................................................................ 28

i

EERE-2007-BT-STD-0007 COMMENT 01.3
12.3 Manufacturer Subgroup Analysis ................................................................................. 28

12.4 Competitive Impacts Analysis ...................................................................................... 29

12.5 Cumulative Regulatory Burden .................................................................................... 29

13 UTILITY IMPACT ANALYSIS .......................................................................................... 30

14 EMPLOYMENT IMPACT ANALYSIS .............................................................................. 30

15 ENVIRONMENTAL ASSESSMENT ................................................................................. 31

16 REGULATORY IMPACT ANALYSIS ............................................................................... 33

APPENDIX A - ENERGY POLICY AND CONSERVATION ACT DIRECTIVES

REGARDING SMALL MOTORS ............................................................................................... 34

APPENDIX B - SUMMARY OF ITEMS FOR STAKEHOLDER COMMENT ....................... 36

LIST OF FIGURES

Figure 1 Flow Diagram of Analyses Conducted for an Energy Conservation Standard

Rulemaking ................................................................................................................................... 10

ii

EERE-2007-BT-STD-0007 COMMENT 01.3
LIST OF ACRONYMS

AEO Annual Energy Outlook

ANOPR advance notice of proposed rulemaking

BT Building Technologies Program

CAIR Clean Air Interstate Rule

CFR Code of Federal Regulations

CSCR capacitor-start, capacitor-run

CSIR capacitor-start, induction-run

CSL candidate standard level

DOE U.S. Department of Energy

DOJ U.S. Department of Justice

EERE Office of Energy Efficiency and Renewable Energy

EIA Energy Information Administration

EPCA Energy Policy and Conservation Act

FR Federal Register

GRIM Government Regulatory Impact Model

Hz hertz

IEEE Institute of Electrical and Electronics Engineers, Inc.

IMBUILD Impact of Building Energy Efficiency Programs (spreadsheet model)

IMPLAN Impact Analysis for Planning (national input-output model)

LCC life-cycle cost

NEMA National Electrical Manufacturers Association

NEMS National Energy Modeling System

NES national energy savings

NOPR notice of proposed rulemaking

NOX nitrogen oxides

NPV net present value

OMB Office of Management and Budget

PSC permanent-split capacitor

R&D research and development

RPM revolutions per minute

SG&A selling, general, and administrative costs

SO2 sulfur dioxide

TSD technical support document

TSL trial standard level

U.S.C. United States Code

iii

EERE-2007-BT-STD-0007 COMMENT 01.3
Rulemaking Framework Document for all Electric Motors

1 INTRODUCTION

The U.S. Department of Energy (DOE) Appliances and Commercial Equipment

Standards Program, within the Office of Energy Efficiency and Renewable Energy (EERE)'s

Building Technologies Program (BT), develops and promulgates test procedures and energy

conservation standards for consumer appliances and commercial equipment . A DOE report

submitted to Congress on January 31, 2006, identifies the rulemakings DOE has scheduled for

completion by June 2011 and explains many of the techniques DOE will be applying during the

rulemaking process to meet this schedule.

The purpose of this document is to describe the procedural and analytical approaches

DOE anticipates using to evaluate energy conservation standards for small electric motors (see

section 1 . 1 below for a discussion of the statutory authority for this rulemaking ). This document

is intended to inform stakeholders of the process DOE will follow for the standards rulemaking

for these motors and to encourage and facilitate stakeholder input during the rulemaking. This

document is merely the starting point for developing standards and is not a definitive statement

with respect to any issue to be determined in the rulemaking.

Section 1 provides an overview of the rulemaking process. Sections 2 through 16 discuss

analyses DOE intends to conduct to fulfill the statutory requirements and guidance for this

standards rulemaking . As an initial matter, it should be noted that the category "small electric

motors" includes several distinct types of motors. DOE will conduct separate analyses for each

small electric motor type to determine whether amended energy conservation standards are

technologically feasible, economically justified , and would result in significant conservation of

energy. In other words, for each of the small electric motor types examined in this rulemaking,

DOE will perform a separate set of analyses, including an engineering analysis, a life-cycle cost

(LCC) and payback period analysis, a national impact analysis, and a manufacturer impact

analysis.

DOE will maintain information regarding this rulemaking on its website at:

http://www.eere.energy.gov/buildings/appliance standards/.

While DOE invites stakeholder comment on all aspects of the material presented in this

document, several specific issues on which DOE seeks comment are set out in comment

boxes like this one. DOE uses these comment boxes to highlight issues and ask specific

questions on the approaches DOE is proposing to follow to conduct the analyses required for

the standards rulemaking.

1.1 The Appliances and C ommercial Equipment Standards Program

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163, (42 U.S.C.

6291-6309) established an energy conservation program for major household appliances. The

National Energy Conservation Policy Act of 1978, Pub. L. 95-619, amended EPCA to add Part C

1

EERE-2007-BT-STD-0007 COMMENT 01.3
of Title III (42 U.S.C. 6311-6317), which established an energy conservation program for certain

industrial equipment. The Energy Policy Act of 1992 (EPACT), Pub. L. 102-486, also amended

EPCA, and included amendments that expanded Title III to include certain types of commercial

equipment, including small electric motors. Specifically , it amended section 346 of EPCA (42

U.S.C. 6317) to provide that the Secretary of Energy (the Secretary) prescribe testing

requirements and energy conservation standards for those small electric motors for which the

Secretary determines that standards "would be technologically feasible and economically

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

On July 10, 2006, the Secretary made a positive determination with respect to testing

requirements and energy conservation standards for small electric motors. 71 FR 38799. As a

result of DOE's determination analysis, the Secretary determined "preliminarily" that standards

for small electric motors would be "technologically feasible and economically justified, and

would result in significant energy savings." Id at 38807. DOE will determine whether and at

what level to promulgate energy conservation standards for small electric motors based on indepth consideration, with public participation, of the technical feasibility, economic justification,

and energy savings of potential standards levels in the context for prescribing new or amended

standards established by EPCA section 325(o),(p) (42 U.S.C. 6295 (o),(p)). This document

describes how DOE proposes to conduct the in-depth analysis for this rulemaking process.

1.2 Overview of Definition and Sub-categories of Covered Small Electric Motors

Section 340(13)(F) of EPCA (42 U.S.C. 6311(13)(F)) provides the following definition

for small electric motor: "The term `small electric motor' means 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." In NEMA Standards Publication MG1-1987, which is entitled "Motors and Generators,"

the two-digit frame series encompasses NEMA frame sizes 42, 48 , and 56, and motors with

horsepower ratings ranging from 1/4 to 3 horsepower. These motors operate at 60 hertz (Hz) and

have either a single-phase or a polyphase electrical design.

Section 346(b)(3) of EPCA (42 U.S.C. 6317(b)(3)) specifies that a standard prescribed

for small electric motors shall not apply to any small electric 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). Such products and equipment include residential air

conditioners and heat pumps, furnaces, refrigerators and freezers , clothes washers and dryers,

commercial packaged air-conditioning and heating equipment, and commercial refrigeration

equipment. Accordingly, this rulemaking does not address small electric motors incorporated in

residential and commercial products specifically excluded by statute.

Item I DOE welcomes comment on additional covered products that contain small

motors or other factors that would affect the scope of the small electric motors

rulemaking.

2

EERE-2007-BT-STD-0007 COMMENT 01.3
As background, the following two subsections provide some detail on the single-phase

and polyphase small electric motors covered under this rulemaking.

1.2.1 Single-phase Small Electric Motors

Single-phase small electric motors are commonly found in products and appliances

including pumps, fans, and power tools. NEMA classifies single-phase electric motors

according to motor size, using a two-digit frame size classification system. Small motors range

in capacity from 1/4 horsepower to one horsepower and are available in two-, four -, or six-pole

configurations, with the four-pole configuration being the most common . The basic principal of

operation of a single -phase, squirrel-cage, induction motor utilizes a rotating magnetic field

produced through equal and opposite rotor torque components . While the electromagnetic

torque acting on the rotor of a polyphase motor is relatively smooth and free from pulsating

disturbances, this is not the case in the single-phase motor. For single -phase motors, the torque

may pulsate from zero to a maximum value at twice the power-line frequency-e.g., 120 Hz. In

most applications, torque pulsations are of little consequence , as the inertia of the small electric

motor and the driven load act to smooth out the pulsations.

The basic construction of the single-phase induction motor includes a fixed housing on

the outside (called a "stator") and a rotating armature on the inside (called a "rotor"). Both the

stator and the rotor generate opposing magnetic fields, which forces the rotor to spin, enabling

the motor to perform work. In order to generate the magnetic fields, the stator and rotor are each

constructed of wire wrapped around a stack of electromagnetic-grade steel laminations. As

alternating current is applied to the windings, the magnetic fields change direction, causing a

push-pull force on the rotor relative to the stator, causing the rotor to spin.' The stator

laminations contain a series of slots for the wire windings which are commonly either aluminum

or copper wire. Two sets of windings are provided, at a 90-degree phase difference. The "main"

or "run" winding operates directly from line current, and it stays energized as long as the motor

is running.

Single-phase motors are categorized according to the way the "start and run,"

"secondary," or "auxiliary" winding is used for starting the motor and then running it at normal

speed. Widely-used single-phase motor categories include: (1) split-phase motors; (2) capacitorstart, induction-run (CSIR) motors; (3) permanent-split capacitor (PSC) motors; and (4)

capacitor-start, capacitor-run (CSCR) motors. Split-phase and CSIR small motors both use the

secondary winding for starting only, although the capacitor-start version provides higher starting

torque. The secondary winding uses a much smaller diameter wire energized for a limited time

without overheating and automatically disconnects after startup by a centrifugal switch. In PSC

and CSCR small motors, the secondary winding continues operating when the motor is running.

The capacitor in series with this winding shifts the phase of the input voltage approximately 90

degrees, so the two windings together create a rotating magnetic field. The benefits achieved by

PSC and CSCR small motors are the suppression of torque pulsations and the improved use of

' The "squirrel-cage" rotor has a series of aluminum bars cast lengthwise into the rotor laminations. These bars are

connected with rings located at each end of the stack. Absent the laminated steel core, the assembly of bars and end

rings have the appearance of a squirrel cage, hence the industry nomenclature for this type of construction.

3

EERE-2007-BT-STD-0007 COMMENT 01.3
both the windings and the iron in the motor. These benefits increase the efficiency and the

power factor of the small motor, but at an added cost associated with the capacitor.

1.2.2 Polyphase Small Electric Motors

Polyphase motors in a two-digit NEMA frame size range from 1/4 horsepower to three

horsepower, although the majority are one horsepower or less. Such motors are available in

pole, four-pole, or six-pole configurations, with the four-pole configuration being the most

common. The typical polyphase induction motor employs a wound stator and a squirrel-cage

rotor. Opposing and attracting magnetic forces acting between the stator and rotor of the motor

cause the rotor to spin and produce torque. The stator consists of a hollow cylindrical core

formed by a stack of thin steel laminations . Insulated copper windings are assembled into slots

formed around the inner circumference of the stator steel laminations. The stator winding carries

current through one slot and then back though a companion slot located approximately one pole

pitch distant from the first. For a two-pole motor, the pole pitch is half the circle, while for fouror six-pole machines it is one quarter or one-sixth of the circle , respectively.

The rotor unit consists of a laminated steel core mounted on a steel shaft. Like the stator,

the rotor core also has windings set into slots , but these are wrapped around its outer

circumference (to be closer to the windings of the stator). Moreover, in the squirrel-cage rotor

configuration, the rotor windings consist of solid conductor bars that are interconnected at either

end with solid-conductor end rings.

When the stator windings are energized by a polyphase electrical source, a radiallydirected magnetic flux is established in the "air gap" between the rotor and the stator. This flux

rotates at a speed determined by the electrical frequency and number of poles given by the statorwinding configuration. For example , with 60-Hz excitation and a two-pole (or one-pole-pair)

winding, the flux rotates at a so-called "synchronous " speed of 60 revolutions per second or

3,600 revolutions per minute (rpm). When the driven equipment, such as a pump , fan blade, or

compressor cylinder, exerts torque on the motor , a difference arises between the synchronous

speed and the actual speed of the motor , which is termed "slip." Thus, the fully loaded speed is

slightly less than the synchronous motor speed . The flux produced by the energized stator

windings envelops the rotor cage bars and, due to its motion, induces current to flow in these

conductors. The interaction of the alternating stator flux and the rotor bar currents develops the

motor's drive torque.

Important characteristics of the polyphase squirrel -cage induction motor are simplicity,

ruggedness, and inherently high starting torque (without the start-assisting devices required for

single-phase motors).

1.3 Overview of the Rulemaking Process

As discussed in Section 1.1 above, DOE is required to develop both test procedures and

energy conservation standards for small electric motors . Test procedures are used by

manufacturers to evaluate compliance with standards.

4

EERE-2007-BT-STD-0007 COMMENT 01.3
1.3.1 Test Procedures

In parallel with the rulemaking on energy conservation standards, DOE is undertaking a

test procedure rulemaking for small electric motors. Currently, DOE does not have a test

procedure for small electric motors, but DOE is developing one in a separate rulemaking

proceeding concurrent with this one so that manufacturers can test for compliance.

Test procedures may incorporate by reference portions of test procedures and definitional

information from relevant sources, such as those developed by the Institute of Electrical and

Electronics Engineers, Inc. (IEEE), NEMA, CSA International, and the International

Electrotechnical Commission. Particular test procedures of interest for polyphase motors include

Method B of the IEEE Standard 112, "IEEE Standard Test Procedure for Polyphase Induction

Motors and Generators," and Method 1 of Canadian Standards Association (CSA) Standard

C390, "Energy Efficiency Test Methods for Three -Phase Induction Motors." For single-phase

motors, IEEE Standard 114, "IEEE Standard Test Procedure for Single -Phase Induction Motors,"

is an existing test procedure that may be a starting point for the test procedure rulemaking.

Item 2 DOE welcomes comment on any additional test procedures that should be

considered or comments about the test procedures listed.

1.3.2 Rulemaking Process and Stakeholder Participation

When DOE evaluates new or amended standards for "covered products " under EPCA, it

must ensure that prior to promulgation, any such standard results in significant energy savings

and achieves the maximum improvement in energy efficiency (or water efficiency) that is

technologically feasible and economically justified. In determining whether a standard is

economically justified, DOE considers to the greatest extent practicable, the following seven

factors:

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

products subject to such standard;

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

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

charges for, or maintenance expenses of the covered products which are likely to result

from the imposition of the standard;

(3) The total projected amount of energy (or as applicable , water) savings likely to result

directly from the imposition of the standard;

(4) Any lessening of the utility or the performance of the covered products likely to result

from the imposition of the standard;

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

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

(6) The need for national energy and water conservation; and

(7) Other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i))

5

EERE-2007-BT-STD-0007 COMMENT 01.3
Additional statutory requirements for prescribing new or amended standards are set forth in 42

U.S.C. 6295(o)(1)-(2)(A), (2)(B)(ii)-(iii), and (3)-(5).

The process for developing efficiency standards involves analysis, public notice, and

consultation with interested parties. Such parties (collectively referred to as "stakeholders")

generally include manufacturers, consumers, energy conservation and environmental advocates,

State and Federal agencies, and any other groups or individuals with an interest in energy

conservation standards and test procedures. DOE considers stakeholder participation to be a

very important part of the rulemaking process. Accordingly, DOE actively encourages the

participation and interaction of all stakeholders, during the comment period provided at each

stage of the rulemaking. The broad array of stakeholders who routinely provide comments

promotes a balanced discussion of critical information required to conduct the standards

rulemaking, beginning with public comment on the Framework Document.

In conducting the test procedure rulemakings and the energy (and water) conservation

standards rulemakings, DOE involves stakeholders through a variety of means, including formal

public notifications (i.e., Federal Register notices) and public meetings. As discussed in further

detail below, the standards rulemaking process involves three major public notices, which are

published in the Federal Register:

Advance notice of proposed rulemaking (ANOPR, see section 1.4). The ANOPR is

designed to publicly vet the models and tools that DOE will use in the rulemaking, and to

facilitate public participation before the proposed rule stage. Candidate standard levels,

which span the range of efficiencies from baseline products to the most efficient

technology, are the basis for demonstrating the functionality of the models and tools.

® Notice of proposed rulemaking (NOPR, see section 1.5). The NOPR presents: a

discussion of comments received in response to the ANOPR; the analysis of the impacts

of standards on consumers, manufacturers, and the nation; DOE's weighting of the

impacts; and the proposed standard levels for public comment.

Final rule (see section 1.6). The final rule presents a discussion of comments received in

response to the NOPR, the revised analysis of the impacts of standards, DOE's weighting

of the impacts, and the standard levels DOE is adopting. The final rule also establishes

the effective date of the standards.

1.4 Advance Notice of Proposed Rulemaking

As part of its initial rulemaking activity, DOE typically conducts a Screening Analysis in

which equipment technology options are identified and subjected to a preliminary determination

of whether DOE will retain that option for detailed analysis or eliminate it from further

consideration. This process includes a market and technology assessment (see section 3) and a

screening analysis (see section 4). DOE applies four screening criteria in the Screening Analysis

to determine which technology options to eliminate from further consideration. These four

criteria are: (1) technological feasibility; (2) practicability to manufacture, install, and service;

(3) adverse impacts on product or equipment utility or availability; and (4) adverse impacts on

6

EERE-2007-BT-STD-0007 COMMENT 01.3
health or safety. Technologies that pass through the screening analysis are referred to as "design

options" in the engineering analysis.

These activities include consultations with stakeholders and independent technical

experts who can assist with identifying the key issues and design options that DOE will consider

in the rulemaking. DOE intends this Framework Document, the public meeting following its

publication, and the opportunity for comment on this Framework Document to initiate dialogue

with stakeholders, and to provide an opportunity for comment and input into the structure and

analytical approach proposed for this energy conservation standards rulemaking.

During the ANOPR stage of the rulemaking, in addition to the market and technology

assessment and screening analysis discussed above, DOE also conducts other principal analyses,

including: (1) the engineering analysis (see section 5); (2) the consumer life-cycle cost (LCC)

and payback period analysis see section 8); (3) the national impact analysis, which considers

national energy savings (NES) and consumer net present value (NPV) (see section 10); and (4) a

preliminary manufacturer impact analysis (see section 12). DOE will present the results of these

analyses in the ANOPR Federal Register notice.

Discussion of various candidate standard levels (efficiency levels) in the ANOPR will

facilitate stakeholder review of the spreadsheet models that underpin the analyses. DOE will

use stakeholder comments to refine the models for the next stage of the rulemaking analyses,

where DOE will propose specific efficiency levels for adoption. In the ANOPR,_ DOE generally

selects efficiency levels or design options for consideration that span the full range of

technologically achievable efficiencies. Relative to a baseline market (see section 3.4 for a

discussion of the baseline market), the range of levels DOE analyzes typically includes:

o The highest energy efficiency level or lowest energy consumption level that is

technologically feasible (the "max tech" level);

o The level with the lowest LCC; and

o Levels that incorporate noteworthy technologies or fill in large gaps between other

efficiency levels considered.

DOE will make the spreadsheet tools and results from the ANOPR analyses available on

its website for review and will consider comments on them after the publication of the ANOPR.2

When it publishes the ANOPR, DOE also will make available a technical support document

(TSD) containing the details of all the analyses performed to date. Following publication of the

ANOPR, DOE will provide a 75-day public comment period and hold one public meeting. At

this point, DOE will encourage stakeholders, to the extent possible, to develop joint

recommendations for standard levels.

2 All materials associated with the Small Motors determination analysis, test procedure and energy conservation

standard are available on DOE's website:

http://www. eere. energy. gov/buildings/appliance-standards/commercial/small_electric_motors.html

7

EERE-2007-BT-STD-0007 COMMENT 01.3
1.5 Notice of Proposed Rule aking

In developing the NOPR, DOE will first review and consider all the comments it received

after the publication of the ANOPR. This process may result in revisions or refinements to the

ANOPR analyses, including the engineering and LCC analyses. DOE also will conduct

additional economic and environmental impact analyses at this stage of the rulemaking. These

analyses generally include a consumer LCC subgroup analysis (see section 11), a complete

manufacturer impact analysis (see section 12), a utility impact analysis (see section 13), an

employment impact analysis (see section 14), an environmental assessment (see section 15), and

a regulatory impact analysis (see section 16).

The NOPR analytical process ends with the selection of proposed standard levels (if any)

that DOE will publish in the NOPR. DOE selects these proposed standard levels from the trial

standard levels (TSLs) analyzed during the NOPR phase of the rulemaking. The NOPR Federal

Register notice will document the evaluation and selection of the proposed standard levels, along

with a discussion of other TSLs considered but not selected (and the reasons for not selecting

them).

The selection process for proposed efficiency standards generally runs as follows. For

each equipment class, DOE will identify the max-tech efficiency level. If DOE proposes a level

lower than that, it will sequentially explain the reasons for eliminating higher levels, beginning

with the highest level considered. DOE will present the analytical results in the NOPR, with the

details of the analysis provided in an accompanying TSD.

DOE considers many factors in selecting proposed standards, as described above in

section 1.3.2. These factors and criteria are contained in EPCA and take into consideration the

benefits, costs, and impacts of energy conservation standards. To assist in weighing these

various factors, DOE encourages stakeholders to develop joint recommendations for standard

levels. DOE will carefully consider such recommendations in its decision process.

When DOE publishes the NOPR, it will provide the Department of Justice (DOJ) with

copies of the NOPR and TSD, in order to solicit feedback on the impact of the proposed standard

levels on competition in the motors industry. DOJ will review these standard levels in light of

any lessening of competition that is likely to result from the imposition of standards. (See 42

U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the NOPR will be followed by a 75-day

public comment period that includes one public meeting.

L6 Final Rule

After the publication of the NOPR, DOE will consider public comments it receives on the

proposal and accompanying analyses. On the basis of the public comments, DOE will review

the engineering and economic impact analyses and proposed standards and consider

modifications where necessary. Before the final rule is issued, DOE also will consider DOJ

comments on the NOPR relating to the impacts of the proposed standard levels on competition,

to determine whether changes to these standard levels are needed.

8

EERE-2007-BT-STD-0007 COMMENT 01.3
The standards rulemaking will conclude with the publication of the final rule. DOE will

select the final standard level based on the complete record of the standards rulemaking. The

final rule will promulgate the final standard level and the effective date and explain the basis for

their selection. The final rule will be accompanied by a final TSD.

2 OVERVIEW OF ANALYSES FOR RULEMAKING

The purpose of the analyses conducted in support of the standards rulemaking is to ensure

that DOE selects energy conservation standards that achieve the maximum improvement in

energy efficiency that is technologically feasible and economically justified, and will result in

significant energy savings. Economic justification includes the consideration of economic

impacts on domestic manufacturers and consumers, national benefits including environmental

impacts, issues of consumer utility, and impacts from any lessening of competition. DOE

expects the selection of such standards to achieve the maximum energy savings that are

economically justified without imposing excessive financial burden on any particular party.

This section offers an overview of the DOE analytical methodology for standard setting

and discusses the major components of the analyses DOE will conduct. DOE will ensure a

consistent approach to its analyses throughout the rulemaking by considering each analysis as a

part of the overall standards-setting framework.

Figure 1 summarizes the analytical components of the standards-setting process. The

"analyses" are presented in the center column. Each analysis has a set of "key inputs," which are

data and information required for the analysis. "Approaches" are the methods that DOE will use

to obtain key inputs, which may vary depending on the information in question. For example,

some key inputs exist in public databases; DOE will collect other information from stakeholders

or experts with special knowledge, and DOE will develop yet other information independently in

support of this rulemaking. The results of each analysis are "key outputs," which feed directly

into the rulemaking. Arrows indicate the flow of information between the various analyses.

9

EERE-2007-BT-STD-0007 COMMENT 01.3
I

Approaches

Characterize Industy

Key Iitl,u

• Identify Firms/Equipment

• Historical Shipments

Market Segmentation

• Analysis of market Uata • Non-Hegulatory Programs

Analysis of Equipment Data Equipment Prototypes

Efficiency-Level Approach

Design Option Approach Manufacturing Cost

• Analysis of Energy and

Water Use Data

Define Distribution :hannels

Economic Census Data

Analysis

Retail Price Collection and

vrtarysis

Accounting Approach

Backcast and Forecast

Market Saturation

at

esfiuier oy/Peduonennc

Energy and

Water Use

rx Markups for

Product Price

Determination

Energy and Water Prices

Installaion Costs

• Mainterance & Repair Co

Engineering Analysis

_:'Design BrergyMfater Use

Anual Energy Use (UEC)

• Annual Water Use (UWC)

r

'R

sr

Energy-Efficiency

Levels

Key Ouf.,pu^z

Equipment Classes

• TechnoloGy Options

Design Options

a-

- Cost-Cfficrency Relationship

Installation

Cogs

Motu[ Costs I

Life-Cycle Cost and

Payback Period

Analysis

Energyefisiency Levels i

t

Shipments

Analysis

Energy Price Forecasts

She-to-Souroe Factors

Manufacturer Prices

Arera^e Costs

Advance Ho ice o Props o Rulesnt5 it t (AHOPE'.

Manufactu r Inteofews

GRIM Analysis

NBuIS-BT

IMBUILD

NBulS-BT

Stakeholder Comments

Demographics

• Manufacturer Prices

Average Costs

Manufacturer Financial Data:

• Utility toed FdUOm

National Energy Savings

• National Energy Savings

r • National Equipment Costs

• National Operating Costs

• Emicsion Rsoo

• National Energy Savings

• Non-Regulatory

Atemalives

Candidate

Standard

Levels

• UEC & UWC

Energy &

Water Prices

National Impact

Analysis

Repair Costs

Life-Cycle Costs

Payback 3edods

National tnergy Savings

Net Present ttelues

• Conversion Capital Expenditures

• Direct Employment Impacts Preliminary

Manufacturer Impact

Analysis

Reprise ANOPR

Analyses

k

Life-Cycle Cost

Sub-Group Analysis

Manufacturer Impact

Analysis

Utility Impact

Analysis

I Employment Impact

Analysis

Environmental

Assessment

Regulatory Impact

Analysis

-SLs

Trial Standard Levels (rSLs)

• life-Cycle Costs

• Payback aeriods

Industry Cash Flow

Sub-Group Cash-Flow

Direct Brploymertt Impacts

Competitive Impacts

• Cumulative Regulatory Burden

Dilcet 6np1oynurt

Impacts

• Utility Impacts

t :!r

National Employment Impacts

Emission Estimates

_I • National Energy Savings

! • Net Present Values

Hotico of Prop o' ed Rutsrrtaki n j (I1QPtt)

Department of Justise Review;

• Stakeholder Comments Revise Analyses • Revised Results

Fin, Rtarl>t

Figure 1 Flow Diagram of Analyses Conducted for an Energy Conservation Standard

Rulemaldng

.nalyse

arket and Technology

Assess nit

Equipment Class Technology ]ptions

Screening Analysis

Design Options

ail Prices

10

EERE-2007-BT-STD-0007 COMMENT 01.3
3 MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the'manufacturers

of small, single-phase, capacitor-start electric motors (both induction-run and capacitor-run) and

small, polyphase electric motors, and specifics about the performance attributes of these motors.

DOE will use this assessment throughout the rulemaking. However, the assessment is

particularly important at the outset for developing equipment classes and for identifying

technology options that improve the efficiency of small electric motors.

3.1 Market Assessment

DOE will qualitatively and quantitatively characterize the structure of the markets for

small, single-phase, capacitor-start electric motors (both induction-run and capacitor-run) and

small, polyphase electric motors. In the market assessment, DOE will characterize the

manufacturers, estimate market shares and trends, and address regulatory and non-regulatory

initiatives intended to improve the efficiency or reduce the energy consumption of covered

motors.

This market assessment will establish the context for this rulemaking, and it will serve as

a resource to guide the analyses that follow. For example, DOE may use historical shipments

and prices as an indicator of future shipments and prices. Similarly, DOE plans to use market

structure data for the manufacturer impact analysis.

DOE recognizes that there may be limited public information on national shipments,

manufacturing costs, channels of distribution, and manufacturers' market shares of small electric

motors. These types of data would be extremely valuable for conducting analyses to determine if

energy conservation standards are economically justified and will result in significant energy

savings. Therefore, DOE encourages stakeholders to submit any available data that pertains to

these areas of interest and that would improve DOE's understanding of the small electric motors

market. This data may be provided under a confidentiality agreement with DOE's contractor

responsible for this part of the rulemaking analysis, Navigant Consulting, Inc. As in other

rulemakings, Navigant Consulting regularly works with confidential data from manufacturers

and other organizations, preparing aggregated results for DOE's analysis that do not divulge

sensitive raw data, but that enable other stakeholders to review and comment on the aggregated

dataset. Alternatively, stakeholders may submit confidential data to DOE, indicating in writing

which data should remain confidential. In order to prevent public disclosure of the data due to

actions taken by a third party, stakeholders providing confidential information to DOE must

submit that data according to 10 CFR 1004.11.

Item 3 DOE welcomes input on shipments, manufacturing costs, distribution

channels, and estimates of market shares for the small electric motors covered in this

rulemaking. For DOE to be able to use the data to conduct energy savings calculations,

a degree ofdisaggregation (e.g., equipment class, frame size, and horsepower) is

desirable.

11

EERE-2007-BT-STD-0007 COMMENT 01.3
DOE is developing a database of commonly available equipment based on the most

recent manufacturer catalogues from motor manufacturers. This model database enables DOE to

understand what is available in the market and to compare available equipment to statutory

definitions. DOE will use the resulting knowledge about equipment availability to evaluate how

the market may respond to various standard levels (e.g., consumers substituting motors that are

not subject to regulation), as well as performance attributes of the various commerciallyavailable motor technologies.

3.2 Equipment Classes

When necessary, DOE divides covered equipment into classes by: (a) the type of energy

used; (b) the capacity of the equipment; or (c) any other performance-related feature that justifies

different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) For

the determination analysis on small electric motors, DOE separately analyzed the following

products as separate classes: (i) single-phase, capacitor-start, induction-run motors; (ii) singlephase, capacitor-start, capacitor-run motors; and (iii) polyphase motors. The division was based

on the different sizes and starting torques (and therefore different consumer utilities) of these

small electric motors. DOE seeks comment on the appropriateness of using such divisions for

this rulemaking, as well as any further (i.e., finer) divisions of covered equipment under each of

these three classes.

Item 4 DOE welcomes comment on equipment classes for single-phase, capacitorstart, induction-run electric motors.

Item 5 DOE welcomes comment on equipment classes for single-phase, capacitorstart, capacitor-run electric motors.

Item 6 DOE welcomes comment on equipment classes for polyphase electric motors.

3.3 Technology Assessment

The technology assessment centers on understanding how energy is used by the product

or equipment, and potential changes that would reduce energy consumption. These measures

that improve the energy efficiency of the equipment are called "technology options," and they

are based on existing technologies, as well as prototype designs and concepts. In consultation

with stakeholders, DOE will develop a list of technology options to consider in this rulemaking.

Initially, this list will include all those options that are technologically feasible, including a maxtech design. In the screening analysis, DOE will eliminate from consideration any technology

options that fail to meet one of the four screening criteria: (1) technological feasibility; (2)

practicability to manufacture, install, and service; (3) adverse impacts on product or equipment

utility or availability; and (4) adverse impacts on health or safety (see section 4 for a more

complete discussion).3

s Technology options that pass all the screening criteria are called "design options," and, as such, they are analyzed

in the engineering analysis see section 5).

12

EERE-2007-BT-STD-0007 COMMENT 01.3
DOE is studying technology options that could be employed to improve the efficiency of

the small electric motors covered in this rulemaking . To this end, DOE is reviewing

manufacturer catalogues, recent trade publications, technical journals, and DOE also intends to

consult with technical experts who have worked on small motor designs and applications.

Presently, DOE is aware of a limited set of design options that could improve the efficiency of

these motors. These design options are discussed below.

The following summarizes small motor operation, the mechanisms of energy loss in those

products, and some initial technology options DOE has identified that would be expected to

improve energy efficiency. The application of a motor to do work creates losses that are both

contained within the motor itself and induced in the power distribution system supplying

electricity to the motor. Losses within the motor are referred to as `internal energy losses.'

These losses are caused by electrical conductivity losses (both Eddy currents and hysteresis

losses4), mechanical losses (i.e., frictional and air-resistance losses), and stray losses. All of

these energy losses result in the generation of heat in the motor. Losses are strongly dependent

on motor design and the quality of the materials used and construction of motor components.

The conventional methods for reducing losses include increasing the amount of active material

(e.g., the cross-sectional area of wire conductors), substituting a higher grade of electrical steel

for the magnetic components , improving the mechanical components and design (e.g., winding,

bearings, and fan), and improving the quality control of components and assembly. These

methods may increase either the motor cost or size if no other changes in the motor are made.

In addition to the internal losses discussed above, small motors with low power factors

can induce extra energy losses in the power distribution system that supplies electricity to the

motor. The lower a motor's power factor, the greater the current per watt required to operate the

motor. These increased currents cause additional losses in the power distribution system because

of conductive losses (also called 12R losses).

The precise impacts on small electric motor cost and efficiency will depend on how the

designer makes tradeoffs between added performance from improved materials or design, and

maintenance of the motor performance . The 12R (the expression of heat loss in watts where I is

measured current and R is resistance) of the rotor is one of the main sources of energy loss in the

rotor. Technology options employed that may reduce the 12 R loss in the rotor may increase

electrical conductivity losses in the stator . DOE is aware that there are certain technology

options that have design trade -offs, and can increase losses in some areas while reducing losses

in other areas.

4 Hysteresis losses are caused by the magnetic lag or reluctance of the core molecules to reorient themselves with the

60 Hz alternating magnetic field applied by the primary winding. Eddy current losses are actual currents induced in

the core by the magnetic field, in the same manner that the field induces current in the secondary winding.

However, these currents cannot leave the core and simply circulate within each lamination, eventually becoming

heat. In both instances, hysteresis and eddy current losses create heat in the core material.

13

EERE-2007-BT-STD-0007 COMMENT 01.3
Item 7 DOE welcomes comment on the preliminary design options identified in this

section. DOE welcomes comment on whether there are other technology options that it

should also consider.

3.4 Baseline Models

Once DOE establishes equipment classes, it will select baseline models as reference

points against which it can measure changes resulting from potential energy conservation

standards. The baseline model represents the characteristics of common or typical equipment

sold in a given equipment class. Given that no existing energy efficiency standards apply to

small electric motors, DOE will select baseline models that are typical of what is sold in the

market today. Accordingly, DOE has determined that a baseline model should encompass motor

features and performance characteristics such as frame size and type , motor speed (in rpm), and

enclosure type. DOE will not define all the detailed characteristics of the proposed baseline

models until it receives comments from stakeholders and can conduct further analysis.

At a subsequent stage in its analysis, DOE will use the baseline models to conduct the

engineering analysis and the LCC and payback period analyses. To determine energy savings

and changes in manufacturer selling price, DOE will compare each of the more efficient motors

(i.e., motors that incorporate design options to improve efficiency) with the baseline model.

Item 8 DOE welcomes comment on which baseline models should be selected from

the representative equipment classes and why.

Item 9 DOE welcomes comment on the scaling of findings from the representative

equipment classes to other equipment classes that it does not analyze.

4 SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technology options that DOE will

not consider in the rulemaking for small electric motors. Following the process set forth below,

DOE will screen out technology design options based upon the four criteria below.

As an initial matter, DOE will develop a list of design options (developed through its own

research and in consultation with interested parties ) for consideration in the engineering analysis

(see section 5). The identified candidate design options or best available technologies will

encompass all those technologies that may be technologically feasible. Thereafter, DOE will

review each such design option or best available technology in light of the following four

14

EERE-2007-BT-STD-0007 COMMENT 01.3
criteria, as provided in sections 4(a)(4) and 5 (b) of the Process Rule 5 and tailored to the current

rulemaking:

1. Technologicalfeasibility. If DOE determines that a design option is not incorporated in

commercially available motors or in working prototypes, then it will not give further

consideration to that design option.

2. Practicability to manufacture, install, and service. If DOE determines that mass

production or reliable installation and servicing of a design option could not be achieved

on the scale necessary to serve the relevant market by the time of the effective date of the

standard, then it will not give further consideration to that design option.

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

design option to have significant adverse impact on the utility of the motor to significant

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

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

that are substantially the same as motors generally available in the United States at the

time, it will not give further consideration to that design option.

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

significant adverse impacts on health or safety, it will not give further consideration to

that design option.

DOE will fully document its reasons for eliminating any design options during the

screening analysis, and will publish this documentation for stakeholder review and comment as

part of the ANOPR.

Item 10 DOE welcomes comment on how the above four screening criteria might

apply to a technology design option(s) that a stakeholder recommends to DOE.

5 ENGINEERING ANALYSIS

After conducting the screening analysis described above, DOE will perform an

engineering analysis based on the remaining design options that improve motor efficiency. This

section provides an overview of the engineering analysis (section 5 . 1), discusses DOE's

proposed approach (section 5.2), and addresses manufacturer prices (section 5 .3), proprietary

designs (section 5 .4), and regulatory burdens that might affect the engineering analysis

(section 5.5).

5 10 CFR Part 430, Subpart C, Appendix A.

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EERE-2007-BT-STD-0007 COMMENT 01.3
5.1 Engineering Analysis Overview

The purpose of the engineering analysis is to determine the relationship between the

manufacturer's selling price and efficiency for small electric motors. In determining the priceefficiency relationship, DOE will estimate the increase in the manufacturer selling price

associated with technological and design changes that increase the efficiency of small motors

relative to the baseline models. DOE will develop cost estimates for the engineering analysis

(which it will also use in section 12, the manufacturer impact analysis) from detailed data on the

incremental costs of changes in material, labor, and overhead. To start, DOE will develop

separate engineering analyses for each of the baseline models identified in section 3.4. DOE

intends to use commercially-available motor design software to develop its own cost-efficiency

relationships for the small motors analyzed.

DOE seeks input on the methods and approaches used by manufacturers to improve the

efficiency of small motors. In addition, DOE intends to identify the model with the highest

efficiency that is technologically feasible within each equipment class (i.e., the "max-tech"

model). DOE's engineering analysis will document the design changes and costs associated with

improving motor efficiency from the baseline through the max-tech model. This will include

considering improved electrical steel for the stator and rotor, improved electrical conductors, and

so on. As each of these design options are added, the manufacturer's cost generally increases

and the motor's efficiency (and performance) improves.

Item 11 For each equipment class, DOE welcomes stakeholder comment on methods

and approaches employed to improve the efficiency of the motors, including the max tech

model. Detailed information on the motor performance and the incremental

manufacturing costs (e.g., material costs, 6 labor costs, 7 overhead costs8 (excluding

depreciation), building conversion capital expenditures, tooling/equipment conversion

capital expenditures associated with more efficient designs, R&D expenses, and

marketing expenses) would be useful.

6 Direct material costs are the costs of raw materials such as steel, copper, and insulation, and also include scrap

metal that can be traced to final or end equipment. Direct material costs do not include indirect material costs which

are attributed to supplies that may be used in the production process, but are not assigned to final pieces of

equipment (e.g., lubricating oil for production machinery).

7 Labor costs are the earnings of workers who assemble parts into a finished good or operate machines in the

production process. Direct labor includes the fringe benefits of direct laborers such as group health care, as well as

overtime pay. Direct labor does not include indirect labor, which is defined as the earnings of employees who do

not work directly in assembling a piece of equipment-such as supervisors, janitors, stockroom personnel,

inspectors, and forklift operators.

8 Factory overhead excludes depreciation, but includes indirect labor, downtime, set-up costs, indirect material,

expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory overhead does not

include selling, general, and administrative costs (SG&A), R&D, interest, or profit (which DOE accounts for

separately).

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EERE-2007-BT-STD-0007 COMMENT 01.3
5.2 Engineering Analysis Approach

For the engineering analysis, DOE will examine incremental increases in the

manufacturer selling price associated with increases in equipment efficiency. For the ANOPR,

DOE intends to develop a database of small electric motor software designs that offer a range of

efficiencies. DOE will conduct design runs to examine various parameters that increase the

efficiency of the motor. The software would provide design and performance specifications for

motor designs, and generate a detailed bill of materials, from which DOE can calculate a final

manufacturers selling price. An important input to this software includes prices for materials

such as the electrical steel, copper windings, and aluminum rotor bar/end rings. A materials

price analysis will be based on a five-year average of typical costs when these materials are

purchased in volume. DOE will seek materials pricing information from current, publiclyavailable data. DOE may supplement this software analysis through: (1) a review of data

collected from manufacturers on prices, efficiencies, and other features of various models of

small electric motors, and (2) interviews with manufacturers about the techniques and associated

costs used to improve efficiency. In addition, DOE will use the cost data generated by the

engineering analysis in the manufacturer impact analysis (see section 12). If possible, DOE will

then aggregate the cost numbers by weighting each individual data point by company-level sales

volumes for each equipment class.

To be useful in the manufacturer impact analysis, manufacturer cost information should

reflect the variability in baseline models, design strategies, and cost structures that exist among

manufacturers. If necessary, DOE will qualify any aggregated cost-efficiency data. Information

obtained through follow-up with manufacturers will assist this effort. These confidential

interviews will provide a deeper understanding of the various combinations of technologies used

to increase small motor efficiency, as well as their associated manufacturing costs.

DOE will estimate the contribution of the depreciation of conversion capital expenditures

to the incremental overhead. During the interviews with manufacturers, DOE will gather

information about the capital expenditures needed to increase the efficiency of the baseline

models to various efficiency levels (i.e., conversion expenditures by efficiency). DOE will also

gather information about the depreciation method(s) used to expense the conversion

expenditures.

The approach proposed above will enable DOE to characterize the cost-efficiency

relationship for motors across the entire efficiency range. As explained above, DOE will

maintain the confidentiality of proprietary data, while allowing the public to examine the cost

and design assumptions that underlie the cost-efficiency estimates.

Item 12 DOE welcomes commentfrom stakeholders on current prices for materials

used in the construction of small electric motors.

Item 13 DOE welcomes comment on the above -described approach to determining the

relationship between manufacturer selling price and motor efficiency.

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EERE-2007-BT-STD-0007 COMMENT 01.3
Item 14 DOE welcomes comment from stakeholders on which software tool is the best

one to use for its engineering analysis and why.

5.3 Manufacturer Prices

DOE plans to apply markups to convert manufacturer production costs to manufacturer

selling prices. DOE intends to estimate manufacturer markups from publicly-available financial

information (e.g., Securities and Exchange Commission 10-K reports).

Item 15 DOE welcomes comment on the markup approach proposed for developing

estimates of manufacturer selling prices.

5.4 Proprietary Designs

DOE will consider in its engineering and economic analyses all design options that are

commercially available or present in a working prototype, including proprietary designs. DOE

will consider a proprietary design in the subsequent analyses only if it is not a unique path to a

given motor efficiency level. If the proprietary design is the only approach available to achieve a

given efficiency level, then DOE will reject the efficiency level (that can only be achieved by a

proprietary design) from further analysis. Furthermore, DOE is sensitive to manufacturer

concerns regarding proprietary designs and will take appropriate steps to maintain the

confidentiality of any proprietary data that manufacturers submit. This information will provide

input to the competitive impacts assessment and other economic analyses.

Item 16 DOE welcomes comment on whether there are proprietary designs it should

considerfor any ofthe motor types under consideration in this rulemaking and, if so, how

DOE should acquire the cost data necessary for evaluating these designs.

5.5 Outside Regulatory Changes Affecting the Engineering Analysis

In conducting an engineering analysis, DOE takes into consideration the effects of

regulatory changes outside DOE's statutory energy conservation standards rulemaking process

that can impact the manufacturers of the covered equipment . As previously mentioned, section

346(b)(3) of EPCA (42 U.S.C. 6317(b)(3)) specifies that a standard prescribed for small electric

motors shall not apply to any small electric 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). Any additional regulation on products containing small electric motors may alter

DOE's scope of coverage in this rulemaking (e.g., regulation stemming from new legislation).

Some regulatory changes can also affect the efficiency or energy consumption of the small

motors covered under this rulemaking . DOE will attempt to identify all such outside engineering

issues that could impact the engineering analysis. The consideration of these issues is closely

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EERE-2007-BT-STD-0007 COMMENT 01.3
related to the cumulative regulatory burden assessment that DOE will carry out as part of the

manufacturer impact analysis.

Item 17 DOE welcomes comment on whether there are outside issues that DOE should

consider in its analysis of small electric motors.

Item 18 DOE welcomes comment on whether there are small electric motor designs

that are used for general purposes as well as for regulated appliances.

6 ENERGY USE AND END-USE LOAD CHARACTERIZATION

The purpose of the energy-use and end-use load characterization is to identify how

products and equipment are used by consumers, and thereby determine the energy savings

potential of energy efficiency improvements. For small electric motors, the end-use load is the

mechanical work that is performed by the equipment which varies over time and with different

applications. The energy use of the motor equals the end-use load plus any energy losses

associated with motor operation. For the motors in this rulemaking, this analysis will focus on

how end-users install and operate these motors and how motor operation and its associated losses

varies over time with different applications.

DOE intends this analysis, which is an input to the LCC and national impact analyses, to

capture and represent the typical energy consumption in the field. This usage profile will enable

DOE to conduct a calculation to determine the LCC and the payback period of more efficient

motor technologies relative to the baseline motor.

Motor loading is the fraction of motor capacity that is utilized on average. This factor is

important for determining which types of motor designs will deliver a specified efficiency.

Thus, as part of the energy use and end-use load characterization, DOE intends to develop a

model of motor loads, to determine average and peak load levels for the various types of small

electric motors.

DOE seeks to identify and obtain detailed data on the typical applications and end-use

profiles for the motors considered in this rulemaking. If the range of energy use determined for

each motor type is large enough, DOE will conduct a sensitivity analysis to determine how high

and low estimates of energy use might impact the economic feasibility of any amended energy

conservation standards.

Item 19 DOE welcomes recommendations on sources of data that would provide enduse operating profiles for each of the motor types covered under this rulemaking.

Item 20 DOE welcomes comment on whether the end-use operating profiles are

different for each of the motor types covered under this rulemaking, and if so, how.

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EERE-2007-BT-STD-0007 COMMENT 01.3
Item 21 DOE welcomes comment on other engineering issues that could impact the

engineering analysis.

7 MARKUPS FOR EQUIPMENT PRICE DETERMINATION

DOE uses manufacturer-to-consumer markups to convert the manufacturer selling price

estimates from the engineering analysis to consumer prices. The manufacturer-to-consumer

markups are in addition to the markups on production costs that DOE uses to estimate

manufacturer selling price in the engineering analysis described in section 5.3 above. DOE then

uses the consumer (retail) prices calculated from these markups in the LCC and payback period

analysis, and in the national impact analysis. Retail prices are needed for the baseline efficiency

level and all other efficiency levels under consideration. As noted above, DOE will obtain these

retail prices by applying manufacturer-to-consumer markups to manufacturer-selling-price

estimates, and then to validate these markups, DOE will attempt to collect data on existing prices

in the market either by, purchasing large data sets or by downloading data from distributor

internet sites.

However, before it can develop markup information, DOE must first identify distribution

channels (i.e., how a motor is distributed from the manufacturer to the consumer). Once it

establishes proper distribution channels for each of the motor types, DOE will rely on economic

census data from the U.S. Census Bureau, as well as input from the electric motor industry and

motor experts, to develop an understanding of the markups applied as a motor moves from the

manufacturer to the consumer. To the extent possible, DOE also will use collected retail price

data to determine overall manufacturer-to-consumer markups.

This analysis will generate retail prices based on the marked-up manufacturing prices

from the engineering analysis. Because DOE expects to generate a range of price estimates, it

plans to describe new retail prices within a range of uncertainty. If the range of retail prices for

each motor type is large enough, DOE will conduct a sensitivity analysis to determine how high

and low estimates of retail price might impact the economic feasibility of any potential amended

energy conservation standard.

Item 22 DOE welcomes comment on the distribution chain for small electric motors,

the key stakeholders in those distribution chains, the typical markups applied by those

stakeholders, and the overall markup from manufacturer selling price to consumer retail

price.

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EERE-2007-BT-STD-0007 COMMENT 01.3
8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

The effects of increased energy conservation standards on consumers include a change in

operating expense (usually decreased) and a change in purchase price (usually increased). DOE

analyzes the net effect on consumers by calculating the LCC and payback period using the

engineering performance data (section 5), the energy-use and end-use load characterization data

(section 6), and the equipment retail prices (section 7). Inputs to the LCC calculation include the

installed cost to the consumer (purchase price plus installation cost), operating expenses (energy

expenses, and, if applicable, repair costs and maintenance costs), the lifetime of the equipment or

other defined period of analysis, and a discount rate.

For the ANOPR, DOE will conduct the LCC analysis using typical values to reflect

conditions in the field for equipment retail price and life, energy costs, energy usage, and

discount rates. If DOE determines that there is significant variability in any of the above inputs,

it will conduct sensitivity analyses to determine how the LCC and payback period are impacted

by high and low estimates for each of the inputs. For any sensitivity analyses that it conducts,

DOE will account for correlations that may exist between inputs (e.g., energy usage may be

correlated to energy prices). The detailed impact calculation, which DOE will conduct after the

ANOPR, may include an assessment of impacts on subgroups of consumers, as described in

section 11.

Based on the results of the LCC analysis, DOE will select candidate standard levels

(CSLs) for the ANOPR analysis. The range of CSLs typically will include the motor efficiency

level with the lowest LCC, the highest efficiency level that is technologically feasible, and other

intermediate levels DOE has not yet determined.

For the NOPR, DOE will carefully review all of the comments it receives on the ANOPR

LCC analysis, make any necessary revisions to the analysis, and evaluate additional parameters

not included in the ANOPR analysis, if necessary.

For small electric motors, DOE will need to determine input values for several variables.

The following sections discuss the methodologies DOE plans to use to develop energy prices,

discount rates, maintenance/repair/installation costs, and motor lifetimes.

8.1 Energy Prices

For consumers of small electric motors, DOE will survey residential, commercial and

industrial energy tariffs9 as a means for establishing marginal electricity prices. DOE will also

use data from the Commercial Building Energy Consumption Survey10 conducted by the Energy

Information Administration (EIA) to estimate building energy use characteristics that impact

electricity prices. If the tariff survey and EIA data demonstrate a large variability in electricity

prices, DOE will conduct a sensitivity analysis to determine how high and low electricity price

estimates might impact the economic feasibility of any amended energy conservation standards.

9 "Energy tariffs" are the rules for calculating energy bills. DOE contractors maintain a database of hundreds of

tariffs that can be used to calculate incremental energy bill impacts from energy savings. See: http://tariffs.lbl.gov/

10 See: http://www.eia.doe.gov/emeu/cbecs/

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EERE-2007-BT-STD-0007 COMMENT 01.3
DOE will use projections of national average energy prices for residential, commercial and

industrial consumers-principally from EIA's Annual Energy Outlook (AEO) from the most

recent year available-to estimate future energy prices in its LCC analysis

Item 23 DOE welcomes input on the proposed methodology for estimating current and

future electricity prices.

8.2 Life-Cycle Cost Discount Rates

The calculation of consumer LCC requires the use of an appropriate discount rate. For

consumers of small electric motors, DOE will derive the discount rates for commercial and

industrial consumers by estimating the cost of capital of companies that purchase commercial

equipment. The cost of capital is commonly used to estimate the present value of cash flows to

be derived from a typical company project or investment. Most companies use both debt and

equity capital to fund investments, so the cost of capital is the weighted-average cost of equity

and debt financing. This corporate finance approach is referred to as the weighted-average cost

of capital. For instance, the set of commercial or industrial companies purchasing small electric

motors may differ from those who purchase distribution transformers, which would result in

different discount rates being developed for this rulemaking.

DOE will publish the discount rates and associated documentation on the derivation of

these discount rates in the ANOPR. It will invite stakeholders to comment specifically on the

issue of consumer discount rates during the ANOPR comment period.

Item 24 DOE welcomes input on the proposed approaches for estimating discount

rates for consumers of small motors covered under this rulemaking.

8.3 Maintenance, Repair, and Installation Costs

Typically, DOE will take into consideration any expected changes to maintenance, repair,

and installation costs for the equipment covered in a rulemaking. Often, small incremental

changes in equipment efficiency would incur little or no change in repair and maintenance costs

over baseline equipment. For equipment with significant energy efficiency improvements over

the baseline, there may be increased repair and maintenance costs since such equipment is more

likely to incorporate technologies that are not widely available. For motors, DOE expects that

maintenance and repair costs will not change with increased efficiency. DOE invites comment

on how repair costs may change for more efficient motors that may be more expensive than

motors currently in the market. With regard to installation costs, DOE is aware that there is

variability in the costs for commercial and industrial sector small motor installations. However,

DOE does not believe that existing installation practices would necessarily change under an

energy conservation standard, but larger, more efficient motors may be more difficult and

expensive to install in constrained spaces or configurations.

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EERE-2007-BT-STD-0007 COMMENT 01.3
Item 25 DOE welcomes comment on whether and how to develop maintenance, repair,

and installation costs for small electric motors. Specifically DOE invites comment on

how efficiency requirements may affect the ability of motor designs to fit in constrained

spaces and configurations.

8.4 Motor Lifetimes

DOE will use information from catalogues and various literature sources, and input from

manufacturers and other stakeholders, to establish small motor lifetimes for use in the LCC and

subsequent analyses.

Based on consideration of the comments received for the ANOPR, DOE will make

necessary changes to the analysis. These changes will be reflected in the documentation of the

NOPR.

Item 26 DOE welcomes comment on appropriate small motor lifetimes for the small

motor types covered in this rulemaking.

9 SHIPMENTS ANALYSIS

DOE requires shipment forecasts to calculate the national impacts of standards on energy

consumption, NPV, and future manufacturer cash flows. DOE plans to develop shipments

forecasts based on an analysis of key market drivers for the covered motors.

9.1 Base Case Forecast

To evaluate the various impacts of standards, DOE develops a base case forecast against

which to compare forecasts for higher efficiency levels. DOE will design the base case forecast

to depict what will happen to energy consumption and energy costs over time if it does not adopt

energy conservation standards for the motors covered under this rulemaking. In determining the

base case forecast, DOE will consider historical shipments, the mix of motor efficiencies

currently sold in the absence of regulation, and how that mix might change over time . For these

purposes, DOE needs data on historical equipment shipments and the market shares of the

different efficiency levels offered in each equipment class.

DOE seeks data on historical shipments for small , single-phase capacitor-start electric

motors (both induction-run and capacitor -run) and small, polyphase electric motors. DOE is

considering manufacturers and industry organizations as potential sources of such information.

Alternatively, to arrive at this information, DOE is considering purchasing national market

reports or extrapolating historical sales data from the United States Bureau of Census. The

United States Bureau of Census publishes limited information on the quantity and dollar-value of

equipment shipments. However, the Census data does not disaggregate the motors according to

motor type or energy conservation standard equipment class.

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EERE-2007-BT-STD-0007 COMMENT 01.3
DOE hopes to collect shipment data within each equipment class, as well as market share

efficiency data (i.e., data on the distribution of equipment shipments by motor efficiency), if

applicable, for each equipment class. DOE recognizes that this information may be difficult to

collect, and may, therefore, consider other methods to estimate the efficiency distribution in the

market. For instance, if market share efficiency data are not available, DOE may develop, as a

proxy, efficiency distributions based on available models and information from motor experts.

Item 27 DOE welcomes recommendations on sources of data that would provide

information on shipments of small electric motors by different equipment classes and

long-term trends in small electric motor shipments.

9.2 Accounting Methodology

DOE proposes to determine annual shipments in the base case by accounting for new

motor installation, motor replacements due to failure, and motor retrofits. Each of these three

impacts on the accounting methodology is discussed below:

New Construction - the new motors that are installed each year due to equipment

growth in a particular sector. DOE proposes to determine this by using the National

Energy Modeling System (HEMS) growth projections for the commercial and

industrial equipment sectors.

Replacements - the motors that have failed or which are included in equipment that

fails. DOE bases this calculation on equipment sales and retirement rates.

® Retrofits -the motors replacing existing motors during renovation and/or repair of

equipment. This replacement may occur before the original motor has failed.

DOE intends to use an accounting model method to prepare shipment scenarios for the

base case and the standards level cases. The model will keep track of the aging and

replacement of small electric motors given a projection of future motor sales growth.

Item 28 DOE welcomes comment on the accounting methodology described above for

each of the motor types covered in this rulemaking.

9.3 Standards Impacts on Motor Shipments

For each motor type, DOE will develop a set of shipment forecasts for the covered

motors for each set of standards analyzed. It will use these standards case forecasts to evaluate

the impacts of standards on motor shipments. DOE derives standards case forecasts using the

same data sets as base case forecasts. However, because the standards case forecasts take into

account the increase in purchase price and the decrease in operating costs caused by standards,

forecasted shipments typically deviate from the base case. The magnitude of the difference

between the standards case and base case shipment forecasts depends on the estimated purchaseprice-increase, as well as the operating-cost savings from the standard. Because the purchase

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EERE-2007-BT-STD-0007 COMMENT 01.3
price tends to have a larger impact than operating cost on equipment purchase decisions,

standards case forecasts typically do show an elasticity of demand, manifested as a drop in

shipments relative to the base case.

Market-pull programs, such as consumer rebate programs that encourage the purchase of

more efficient small motors and manufacturer tax credits that encourage the production of more

efficient small motors, also affect standards case forecasts. To the extent that such programs

exist, DOE will consider their impact on the forecast of both standards case and base case

shipments.

Item 29 DOE welcomes comment on how any standard for small electric motors might

impact shipments of these motors. DOE also invites information about market-pull

programs that promote the adoption of more efficient motors.

10 NATIONAL IMPACT ANALYSIS

Section 8 discusses methods for estimating the LCC savings and payback period for

individual consumers. This section discusses DOE's assessment of the aggregate impacts of

proposed efficiency standards at the national level. Measures of impact that DOE will report

include future NES from candidate motor standards (i.e., the cumulative incremental energy

savings from a small electric motors efficiency standard relative to a base case of no national

standard over a specified forecast period) and the NPV of total consumer LCC.

10.1 Inputs to Forecasts

Analyzing impacts of Federal energy conservation standards for small electric motors

requires a comparison of projected United States energy consumption with, and without, new

energy conservation standards. The forecasts contain projections of unit energy consumption of

new motors, annual equipment shipments, and the price of purchased equipment. The

derivations of the base case shipments forecasts are discussed in section 9. Approaches to

determine retail prices for equipment are described in section 7, while approaches to determine

unit energy consumption are described in section 6.

10.2 Calculation of National Energy Savings

DOE intends to calculate national energy consumption for each year beginning with the

expected effective date of the standards. It will calculate national electricity consumption for the

base case and each standard level analyzed. DOE plans to perform this calculation through the

use of a spreadsheet model that effectively multiplies annual shipment forecasts by unit energy

savings, thereby accounting for the stock of equipment affected by standards.

In response to comments by stakeholders who asked for a simple, transparent model,

DOE developed IVES spreadsheet models for its standards rulemakings starting in 1996, to

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EERE-2007-BT-STD-0007 COMMENT 01.3
project energy savings and to demonstrate how the growth in efficiency can be accounted for

over time . 11 Although these models are specific to each product , their general framework is

applicable to the entire small motors market. It is DOE's expectation that the NES spreadsheet

model will provide a credible , stand-alone forecast of national energy savings and NPV for small

electric motors.

Item 30 DOE welcomes comment on the NES spreadsheet models itproposes to use

for estimating national impacts of energy conservation standards for small electric.

motors.

10.3 Net Present Value

DOE calculates the national NPV of energy conservation standards in conjunction with

the NES. It calculates annual energy expenditures from annual energy consumption by

incorporating forecasted energy prices, using the shipment and average energy efficiency

forecasts described in section 9. DOE calculates annual equipment expenditures by multiplying

the price per unit by the forecasted shipments. The difference between a base case and a

standards case scenario will likely contribute to an NES offset against increased expenditures on

motors. The difference each year between energy bill savings and increased equipment

expenditures is the net savings (if positive) or net costs (if negative). DOE will discount these

annual values to the present time and sum them to provide a net present value. According to

Office of Management and Budget (OMB) requirements, DOE will conduct two NPV

calculations, one using a real discount rate of three percent and another using a real discount rate

of seven percent (OMB, Circular A-4: Regulatory Analysis. 2003). Based on consideration of

the comments received on the ANOPR, DOE will make any necessary changes to the analysis

and the CSLs.

11 LIFE-CYCLE COST SUBGROUP ANALYSIS

This section describes how DOE analyzes consumer impacts by dividing consumers into

subgroups and accounting for variations in key inputs to the LCC analysis. A consumer

subgroup comprises a subset of the population that is likely, for one reason or another, to be

affected disproportionately by new or revised energy conservation standards (e.g., small

businesses, ethnic minorities, and low-income or senior consumers). The purpose of a subgroup

analysis is to determine the extent of this disproportional impact. DOE will work with

stakeholders early in the rulemaking process to identify any subgroups for this consideration.

However, it will not analyze the consumer subgroups until the NOPR stage of the analysis.

In comparing potential impacts on the different consumer subgroups , DOE will evaluate

variations in regional electricity prices, variations in usage profiles, and variations in installation

costs that might affect the NPV of an energy conservation standard to certain consumer

subgroups. To the extent possible, DOE may obtain estimates of the variability in each input

' Several examples of NES spreadsheet models from previous rulemakings can be found on DOE's website at

www.eere.energy.gov/buildings/a l pp iance standards/.

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EERE-2007-BT-STD-0007 COMMENT 01.3
factor and consider this variability in its calculation of consumer impacts. It will discuss with

stakeholders the variability in each input factor and likely sources of information.

Item 31 DOE welcomes comment on what, ifany, consumer subgroups are

appropriate in considering standards for small electric motors.

12 MANUFACTURER IMPACT ANALYSIS

DOE announced changes to the manufacturer impact analysis format in a report issued to

Congress on January 31, 2006 (as required by section 141 of the Energy Policy Act of 2005).

This report, entitled "Energy Conservation Standards Activities," (Standards Activities) is

available on the DOE website at:

http://www.eere.energy.gov/buildings/appliance standards/2006 schedule setting.html.

Previously, DOE did not report any manufacturer impact analysis results during the

ANOPR phase; however, under this new format, DOE will collect, evaluate, and report

preliminary information and data in the ANOPR. (See Standards Activities, page 48.) Such

preliminary information includes the anticipated conversion capital expenditures by efficiency

level and the corresponding, anticipated impacts on employment. DOE will invite further input

on these issues during its ANOPR manufacturer interviews.

DOE intends the manufacturer impact analysis to provide an assessment of the potential

impacts of energy conservation standards on manufacturers of small electric motors. DOE

intends to conduct a separate manufacturer impact analysis for each of the motor types covered

under this rulemaking. In addition to financial impacts, a wide range of quantitative and

qualitative effects may occur following adoption of a standard that may require changes to the

manufacturing practices for these motors. DOE will identify these effects through. interviews

with manufacturers and other experts.

12.1 Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described earlier provide important information that DOE will use

as inputs for the manufacturer impact analysis. Such information includes financial parameters

developed in the market assessment (section 3.1), manufacturing costs and prices from the

engineering analysis (sections 5.2 and 5.3), retail price forecasts (section 7), and shipments

forecasts (section 9). DOE will supplement this information with information gathered during

manufacturer interviews. The interview process plays a key role in the manufacturer impact

analysis, because it provides an opportunity for directly affected parties to express their views on

important issues.

To this end, DOE will conduct detailed interviews with manufacturers to gain insight into

the range of potential impacts from standards. During the interviews, DOE will take note of

information on the possible impacts on manufacturing costs, equipment prices, sales, direct

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EERE-2007-BT-STD-0007 COMMENT 01.3
employment, capital assets, and industry competitiveness. Both qualitative and quantitative

information are valuable in terms of this analysis . DOE will schedule interviews well in advance

to provide every opportunity for key individuals to be available to participate.

DOE will ask interview participants to identify all confidential information provided in

writing or orally, and DOE will determine whether the information submitted is entitled to

confidential treatment. It will consider the information gathered , as appropriate, in the energy

conservation standard decision-making process. DOE will also ask participants to identify any

information that they wish to have included in the public record , but that they do not want to

have associated with their interview (thereby identifying that particular manufacturer); DOE will

incorporate this information into the public record, but will report it without attribution.

DOE will collate the interview results and prepare a summary of the major issues and

outcomes. This summary will become part of the technical support document for this

rulemaking.

12.2 Industry Cash Flow Analysis

The industry cash flow analysis will rely primarily on the Government Regulatory Impact

Model (GRIM). DOE uses the GRIM to analyze the financial impacts of new or more stringent

energy conservation standards on the industry that produces the equipment covered by the

standard.

The GRIM analysis uses a number of factors-annual expected revenues, manufacturer

costs such as costs of goods sold, SG&A costs, taxes, and capital expenditures (both ordinary

capital expenditures and those related to standards)-to determine annual cash flows associated

with a new standard, beginning from the announcement of the standard and continuing for

several years after its implementation . DOE compares the results against base case projections

that involve no new standards. The financial impact of new standards is the difference between

the two sets of discounted annual cash flows. Other performance metrics, such as return on

invested capital, are also available from the GRIM.

12.3 Manufacturer Subgroup Analysis

It is possible that the use of average industry cost values will not adequately assess

differential impacts among subgroups of motor manufacturers . DOE recognizes that smaller

manufacturers, niche players, and manufacturers exhibiting a cost structure that differs

significantly from the industry average may be impacted differently by the imposition of

standards. Ideally, DOE would consider the impact on every firm individually . In highly

concentrated industries, this may be possible. In industries having numerous participants,

however, DOE uses the results of the market and technology assessment to group manufacturers

into subgroups, as appropriate . For small motors, DOE does not intend to assess the impacts on

every manufacturer individually and, therefore , is interested in stakeholder feedback about

potential subgroups.

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EERE-2007-BT-STD-0007 COMMENT 01.3
Item 32 DOE welcomes comment on, if appropriate, what potential subgroups of

motor manufacturers DOE should consider in a manufacturer subgroup analysis.

12.4 Competitive Impacts Analysis

EPCA directs DOE to consider any lessening of competition that is likely to result from

an imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney

General to determine in writing the impacts, if any, of any lessening of competition. (42 U.S.C.

6295(o)(2)(B)(ii))

DOE will make a determined effort to gather firm-specific financial information and

impacts, and it will then report the aggregated impact of the standard on manufacturers. The

competitive impacts analysis will focus on assessing the impacts to smaller, yet significant,

manufacturers. DOE will base the assessment on manufacturing cost data and on information

collected from interviews with manufacturers. The manufacturer interviews will focus on

gathering information that would help in assessing asymmetrical cost increases to some

manufacturers, increased proportion of fixed costs potentially increasing business risks, and

potential barriers to market entry (e.g., proprietary technologies). DOE will provide the Attorney

General with a copy of the NOPR for consideration in an evaluation of the impact of standards

on the lessening of competition.

12.5 Cumulative Regulatory Burden

DOE is aware that other regulations may apply to equipment covered under this

rulemaking, as well as to other equipment produced by the same manufacturers of equipment

covered under this rulemaking. Multiple regulations may result in a significant , cumulative

regulatory burden on these manufacturers. DOE will analyze and consider the impact on motor

manufacturers of multiple , equipment-specific regulatory actions.

Regulations that could affect the industry impacted by this rulemaking include:

® Existing energy conservation standards for 1 to 200 horsepower electric motors

established by DOE on October 5, 1999 (64 FR 54114).

® Standards applicable to products that incorporate small motors which are already

regulated, such as residential air conditioners and heat pumps, furnaces, refrigerators

and freezers, clothes washers and dryers, commercial packaged air-conditioning and

heating equipment, and commercial refrigeration equipment.

® Safety or other requirements associated with covered equipment.

Item 33 DOE welcomes comment on what other regulations or pending regulations it

should consider in its examination of cumulative regulatory burden.

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EERE-2007-BT-STD-0007 COMMENT 01.3
13 UTILITY IMPACT ANALYSIS

To estimate the effects of energy conservation standards for small electric motors on the

electric utility industry, DOE plans to use a variant of EIA's NEMS, called NEMS-BT (BT

refers to DOE's Building Technologies Program). NEMS is a large, multi-sectoral partial

equilibrium model of the U.S. energy sector, used primarily for the purpose of preparing the

AEO. NEMS-BT produces a widely-recognized reference case forecast for the United States

through 2030 and is available in the public domain.

The utility impact analysis is a comparison between the NEMS-BT model results for the

base case and standards cases. Outputs of the utility impact analysis usually parallel results that

appear in the latest AEO, with some additions. Typical outputs include forecasts of electricity

generation, sales, price, and avoided capacity. DOE plans to conduct the utility impact analysis

as a scenario departing from the latest AEO reference case. In other words, it will model the

energy savings impacts from energy conservation standards for small motors using NEMS-BT to

generate forecasts that deviate from the AEO reference case. 12

Item 34 DOE welcomes input from stakeholders on its proposed use of NEMS-BT to

conduct the utility impact analysis.

14 EMPLOYMENT IMPACT ANALYSIS

The Process Rule includes employment impacts among the factors for DOE to consider

in selecting a proposed efficiency standard, and it also provides guidance for consideration of the

impact of CSLs on both direct and indirect employment. The Process Rule states a general

presumption against any CSL that would directly cause plant closures or significant loss of

domestic employment, unless specifically identified expected benefits of the standard would

outweigh such adverse effects. (See the Process Rule, 10 CFR Part 430, Subpart C, Appendix A,

sections 4(d)(7)(ii) and (vi), and 5(e)(3)(i)(B).)

DOE estimates the impacts of standards on employment for equipment manufacturers,

relevant service industries, energy suppliers, and the economy in general. Its analysis covers

both direct and indirect employment impacts. Direct employment impacts would result if

standards led to a change in the number of employees at manufacturing plants and related supply

and service firms. Direct impact estimates are covered in the manufacturer impact analysis.

Indirect employment impacts are impacts on the national economy other than in the

manufacturing sector being regulated. Indirect impacts may result both from expenditures

shifting among goods (the substitution effect) and changes in income that lead to a change in

overall expenditure levels (the income effect). DOE defines indirect employment impacts from

standards as net jobs eliminated or created in the general economy as a result of increased

12 Several NEMS-BT models from previous rulemakings can be found on the DOE's website at

www.eere.energy.gov/buildings/appliance standards/.

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EERE-2007-BT-STD-0007 COMMENT 01.3
spending driven by the increased equipment prices and reduced spending on energy. DOE

expects new standards for small electric motors to increase the total installed cost of equipment

(which includes manufacturer selling price, sales taxes, distribution chain markups, and

installation cost). DOE also expects the new standards to decrease energy consumption, and thus

expenditures on energy. Over time, increased total installed cost is paid back through energy

savings. The savings in energy expenditures may be spent on new commercial investment and

other items.

DOE intends to investigate the indirect employment impacts of small electric motor

standards using the Impact of Building Energy Efficiency Programs (IMBUILD) spreadsheet

model.13 DOE's Building Technologies Program office developed IMBUILD, which.is a special

version of the Impact Analysis for Planning (IMPLAN) national input-output model. PLAN

specifically estimates the employment and income effects of building energy technologies. The

IMBUILD model is an economic analysis system that focuses on those sectors most relevant to

buildings and characterizes the interconnections among 35 sectors as national input-output

matrices using data from the Bureau of Labor Statistics. The IMBUILD model estimates

changes in employment, industry output, and wage income in the overall U.S. economy resulting

from changes in expenditures in the various sectors of the economy. Changes in expenditures

due to equipment standards can be introduced into IMBUILD as changes in existing economic

flows. IMBUILD can then estimate the resulting net national impact on jobs by sector.

Although DOE intends to use IMBUILD for its analysis of indirect employment impacts, it

welcomes input on other tools and factors it might consider.

Item 35 DOE welcomes feedback on its proposed approach to assessing national

employment impacts, both direct and indirect.

15 ENVIRONMENTAL ASSESSMENT

The intent of the environmental assessment is to provide emissions results estimates, and

to fulfill requirements to properly quantify and consider the environmental effects of all new

Federal rules. The primary environmental effects of energy conservation standards for small

electric motors are likely to be reduced emissions resulting from reduced electricity

consumption. Accordingly, the environmental assessment for this rulemaking will focus on the

significant pollutants and emissions of electricity-generating power plants. Specifically, the

environmental assessment will consider three pollutants -- sulfur dioxide (SO2), nitrous oxide

(NOX), and mercury (Hg); it will also consider one emission -- carbon dioxide (C02)-

At the NOPR rulemaking stage, for each of the trial standard levels, DOE will calculate

total undiscounted and discounted power plant emissions using NEMS-BT, and will use other

methods to calculate site emissions. The environmental assessment performed in this

13 Several employment analyses using the IMBUILD model from previous rulemakings can be found on the DOE's

website at www.eere.energy.gov/buildings/appliance standards/.

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EERE-2007-BT-STD-0007 COMMENT 01.3
rulemaking will be conducted as an incremental policy impact (i.e., a standard for the product

under evaluation) of the most current AEO forecast, applying the same basic set of assumptions

used in AEO. Also, forecasts conducted with NEMS-BT consider the supply-side and demandside effects on the electric utility industry. Thus, DOE's analysis will account for any factors

affecting the type of electricity generation and, in turn, the type and amount of airborne

emissions generated by the utility industry.

The NEMS-BT model tracks CO2 emissions with a specialized carbon emissions

estimation subroutine, producing reasonably accurate results due to the broad coverage of all

sectors and inclusion of interactive effects. Past experience with carbon results from NEMS

suggests that emissions estimates are somewhat lower than emissions based on simple average

factors. One of the reasons for this divergence is that NEMS tends to predict that conservation

displaces generating capacity in future years. On the whole, NEMS-BT provides carbon

emissions results of reasonable accuracy, at a level consistent with other published Federal

results.

NEMS-BT also reports SO2, NOR, and mercury, which DOE has reported in past

analyses. The Clean Air Act Amendments of 1990 set an SO2 emissions cap on all power

generation. The attainment of this target, however, is flexible among generators through the use

of emissions allowances and tradable permits. Although NEMS includes a module for SO2

allowance trading and delivers a forecast of SO2 allowance prices, accurate simulation of SO2

trading implies that the effect of efficiency standards on physical emissions will be zero because

emissions will always be at or near the ceiling. However, there is an SO2 benefit from energy

conservation, in the form of a lower SO2 allowance price. But since the impact of any one

standard on the allowance price is likely small and highly uncertain, DOE does not plan to

monetize the SO2 benefit.

NEMS-BT also has an algorithm for estimating NOR emissions from power generation.

The impact of these emissions, however, will be affected by the Clean Air Interstate Rule

(CAIR), which the EPA issued on March 10, 2005 and finalized on May 12, 2005; CAIR will

permanently cap emissions of NOR in 28 eastern states and the District of Columbia. 70 FR

25162 (May 12, 2005). As with SO2 emissions, a cap on NOR emissions means that equipment

efficiency standards may have little or no physical effect on these emissions. When NOR

emissions are subject to emissions caps, DOE's emissions reduction estimate corresponds to

incremental changes in the prices of emissions allowances in cap-and-trade emissions markets

rather than physical emissions reductions. Therefore, while the emissions cap may mean that

physical emissions reductions will not result from standards, standards could produce an

environmentally-related economic benefit in the form of lower prices for emissions allowance

credits. However, as with SO2 allowance prices, DOE does not plan to monetize this benefit

because the impact on the NOR allowance price from any single energy conservation standard is

likely small and highly uncertain.

Item 36 DOE welcomes feedback on its proposed approach to assessing national

environmental impacts.

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EERE-2007-BT-STD-0007 COMMENT 01.3
16 REGULATORY IMPACT ANALYSIS

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis,

which addresses the potential for non-regulatory approaches to supplant or augment energy

conservation standards to improve the efficiency of small electric motors in the market. The

regulatory impact analysis will consider the likely effects of non-regulatory initiatives on motor

energy use, consumer utility, and life-cycle costs. DOE will take into account the actual impacts

of any existing initiatives to date, but also will consider historical information presented that may

reasonably estimate the impacts that any such initiative might have in the future. It will use the

NES spreadsheet model (as discussed in section 10.2, "Calculation of National Energy Savings")

to calculate the NES and NPV for alternatives to the proposed conservation standards.

If DOE proposes energy conservation standards for certain small electric motors and the

NOPR constitutes a significant regulatory action, DOE would prepare and submit to OMB for

review the assessment of costs and benefits required under section 6(a)(3) of Executive Order

12866, "Regulatory Planning and Review," 58 FR 51735 (October 4, 1993). The Executive

Order requires agencies to identify the specific market failure or other specific problem that is

that basis for agency action, as well as assess the significance of that problem, in order to permit

assessment of whether any new regulation is warranted. (Executive Order 12866, § 1(b)(1)).

DOE's preliminary analysis suggests that accounting for the market value of energy

savings alone (i.e., excluding any possible additional "externality" benefits such as those noted

below) would yield net benefits across a wide array of equipment and circumstances. These

results, if correct, imply the existence of a market failure in the small electric motors market.

DOE requests data on and suggestions for testing the existence and extent of these potential

market failures, in order to complete an assessment in the proposed rule regarding the

significance of these failures and the anticipated net benefits of regulation.

DOE believes that there is a lack of consumer information and/or information processing

capability about energy efficiency opportunities in the small electric motors market. If this is in

fact the case, DOE would expect the energy efficiency for small electric motors to be randomly

distributed across key variables such as energy prices and usage levels. DOE seeks data on the

efficiency levels of existing small electric motors in use by application (e.g., pumps, conveyors,

compressors) and electricity price (and/or geographic region of the country). DOE plans to use

these data to test the extent to which purchasers of this equipment behave as if they are unaware

of the costs associated with their energy consumption.

There are likely to be certain "external" benefits resulting from the improved efficiency

of units that are not captured by the users of such equipment. These include both environmental

and energy security-related externalities that are not already reflected in energy prices such as

reduced emissions of greenhouse gases and reduced use of natural gas and oil for electricity

generation. DOE invites comments on the weight that should be given to these factors in DOE's

determination of the maximum efficiency level at which the total benefits are likely to exceed the

total burdens resulting from a DOE standard.

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EERE-2007-BT-STD-0007 COMMENT 01.3
APPENDIX A - ENERGY POLICY AND CONSERVATION ACT DIRECTIVES

REGARDING SMALL MOTORS

This appendix provides an excerpt from EPCA under which DOE is exerting its authority

under 42 U.S.C. 6317(b) through (f).

Sec. 6317. Energy conservation standards for high-intensity discharge lamps, distribution

transformers, and sall electric motors

(b) Small electric motors

(1) The Secretary shall, within 30 months after October 24, 1992, prescribe testing

requirements for those small electric motors for which the Secretary makes a

determination that energy conservation standards would be technologically feasible and

economically justified, and would result in significant energy savings.

(2) The Secretary shall, within 18 months after the date on which testing requirements are

prescribed by the Secretary pursuant to paragraph (1), prescribe, by rule, energy

conservation standards for those small electric motors for which the Secretary prescribed

testing requirements under paragraph (1).

(3) Any standard prescribed under paragraph (2) shall apply to small electric motors

manufactured 60 months after the date such rule is published or, in the case of small

electric motors which require listing or certification by a nationally recognized testing

laboratory, 84 months after such date. Such standards shall not apply to any small

electric motor which is a component of a covered product under section 6292(a) of this

title or a covered equipment under section 6311 of this title.

(c) Consideration of criteria under other law

In establishing any standard under this section, the Secretary shall take into

consideration the criteria contained in section 6295(n) of this title.

(d) Prescription of labeling requirements by Secretary

The Secretary shall, within six months after the date on which energy conservation

standards are prescribed by the Secretary for high-intensity discharge lamps and

distribution transformers pursuant to subsection (a) (2) of this section and small electric

motors pursuant to subsection (b)(2) of this section, prescribe labeling requirements for

such lamps, transformers, and small electric motors.

(e) Compliance by manufacturers with labeling requirements

Beginning on the date which occurs six months after the date on which a labeling rule is

prescribed for a product under subsection (d) of this section, each manufacturer of a

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EERE-2007-BT-STD-0007 COMMENT 01.3
product to which such a rule applies shall provide a label which meets, and is displayed

in accordance with, the requirements of such rule.

W New covered products; distribution of non-conforming products prohibited; construction

with other law

(1) After the date on which a manufacturer must provide a label for a product pursuant to

subsection (e) of this section--

(A) each such product shall be considered, for purposes of paragraphs (1) and (2) of

section 6302(a) of this title, a new covered product to which a rule under section

6294 of this title applies; and

(B) it shall be unlawful for any manufacturer or private labeler to distribute in

commerce any new productfor which an energy conservation standard is

prescribed under subsection (a)(2) or (b)(2) of this section which is not in

conformity with the applicable energy conservation standard.

(2) For purposes of section 6303(a) of this title, paragraph (1) of this subsection shall be

considered to be a part of section 6302 of this title.

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EERE-2007-BT-STD-0007 COMMENT 01.3
APPENDIX B - SUMMARY OF ITEMS FOR STAKEHOLDER COMMENT

Summary of all items for stakeholder comment contained in the framework document.

Item 1 DOE welcomes comment on additional covered products that contain small motors or

other factors that would affect the scope of the small electric motors rulemaking ........................ 2

Item 2 DOE welcomes comment on any additional test procedures that should be considered

or comments about the test procedures listed.... :............................................................................ 5

Item 3 DOE welcomes input on shipments, manufacturing costs, distribution channels, and

estimates of market shares for the small electric motors covered in this rulemaking. For DOE to

be able to use the data to conduct energy savings calculations, a degree of disaggregation (e.g.,

equipment class, frame size, and horsepower) is desirable .......................................................... 11

Item 4 DOE welcomes comment on equipment classes for single-phase , capacitor-start,

induction-run electric motors ........................................................................................................ 12

Item 5 DOE welcomes comment on equipment classes for single-phase, capacitor-start,

capacitor-run electric motors ........................................................................................................ 12

Item 6 DOE welcomes comment on equipment classes for polyphase electric motors........... 12

Item 7 DOE welcomes comment on the preliminary design options identified in this section.

DOE welcomes comment on whether there are other technology options that it should also

consider ........................................................................................................................................ 14

Item 8 DOE welcomes comment on which baseline models should be selected from the

representative equipment classes and why ................................................................................... 14

Item 9 DOE welcomes comment on the scaling of findings from the representative equipment

classes to other equipment classes that it does not analyze .......................................................... 14

Item 10 DOE welcomes comment on how the above four screening criteria might apply to a

technology design option(s) that a stakeholder recommends to DOE .......................................... 15

-Item 11 For each equipment class, DOE welcomes stakeholder comment on methods and

approaches employed to improve the efficiency of the motors, including the max tech model.

Detailed information on the motor performance and the incremental manufacturing costs (e.g.,

material costs, labor costs, overhead costs (excluding depreciation), building conversion capital

expenditures, tooling/equipment conversion capital expenditures associated with more efficient

designs, R&D expenses, and marketing expenses) would be useful ............................................ 16

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EERE-2007-BT-STD-0007 COMMENT 01.3
Item 12 DOE welcomes comment from stakeholders on current prices for materials used in

the construction of small electric motors ...................................................................................... 17

Item 13 DOE welcomes comment on the above-described approach to determining the

relationship between manufacturer selling price and motor efficiency ........................................ 17

Item 14 DOE welcomes comment from stakeholders on which software tool is the best one

to use for its engineering analysis and why .................................................................................. 18

Item 15 DOE welcomes comment on the markup approach proposed for developing

estimates of manufacturer selling prices ....................................................................................... 18

Item 16 DOE welcomes comment on whether there are proprietary designs it should

consider for any of the motor types under consideration in this rulemaking and, if so, how DOE

should acquire the cost data necessary for evaluating these designs ............................................ 18

Item 17 DOE welcomes comment on whether there are outside issues that DOE should

consider in its analysis of small electric motors ............................................ ............................... 19

Item 18 DOE welcomes comment on whether there are small electric motor designs that are

used for general purposes as well as for regulated appliances ...................................................... 19

Item 19 DOE welcomes recommendations on sources of data that would provide end-use

operating profiles for each of the motor types covered under this rulemaking ............................ 19

Item 20 DOE welcomes comment on whether the end-use operating profiles are different for

each of the motor types covered under this rulemaking , and if so, how ....................................... 19

Item 21 DOE welcomes comment on other engineering issues that could impact the

engineering analysis ................................................................ ...................................................... 20

Item 22 DOE welcomes comment on the distribution chain for small electric motors, the key

stakeholders in those distribution chains, the typical markups applied by those stakeholders, and

the overall markup from manufacturer selling price to consumer retail price .............................. 20

Item 23 DOE welcomes input on the proposed methodology for estimating current and

future electricity prices ..................................................................................................... ............ 22

Item 24 DOE welcomes input on the proposed approaches for estimating discount rates for

consumers of small motors covered under this rulemaking .......................................................... 22

Item 25 DOE welcomes comment on whether and how to develop maintenance , repair, and

installation costs for small electric motors. Specifically DOE invites comment on how efficiency

requirements may affect the ability of motor designs to fit in constrained spaces and

configurations............................................................................................................................... 23

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EERE-2007-BT-STD-0007 COMMENT 01.3
Item 26 DOE welcomes comment on appropriate small motor lifetimes for the small motor

types covered in this rulemaking .................................................................................................. 23

Item 27 DOE welcomes recommendations on sources of data that would provide information

on shipments of small electric motors by different equipment classes and long-term trends in

small electric motor shipments .................................................................................................... 24

Item 28 DOE welcomes comment on the accounting methodology described above for each

of the motor types covered in this rulemaking .............................................................................. 24

Item 29 DOE welcomes comment on how any standard for small electric motors might

impact shipments of these motors. DOE also invites information about market-pull programs

that promote the adoption of more efficient motors ..................................................................... 25

Item 30 DOE welcomes comment on the NES spreadsheet models it proposes to use for

estimating national impacts of energy conservation standards for small electric motors ............. 26

Item 31 DOE welcomes comment on what, if any, consumer subgroups are appropriate in

considering standards for small electric motors ............................................................................ 27

Item 32 DOE welcomes comment on, if appropriate , what potential subgroups of motor

manufacturers DOE should consider in a manufacturer subgroup analysis ................................. 29

Item 33 DOE welcomes comment on what other regulations or pending regulations it should

consider in its examination of cumulative regulatory burden.......................

Item 34 DOE welcomes input from stakeholders on its proposed use of NEMS-BT to

conduct the utility impact analysis .........................................

Item 35 DOE welcomes feedback on its proposed approach to assessing national

employment impacts, both direct and indirect................. 31 .............................................................

Item 36 DOE welcomes feedback on its proposed approach to assessing national

environmental impacts .................................................................................................................. 32

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EERE-2007-BT-STD-0007 COMMENT 01.3