Department of Energy

Washington, DC 20585

May 8, 1997

othy Feldman

Vice President, Government Relations

National Electrical Manufacturers Association

1300 North 17th Street. Suite 1847

Rosslyn, VA 22209

This Office has received your March 4, 1997, letter regarding manufacturers' compliance with the

energy conservation standards for certain electric motors covered by the Energy Policy and

Conservation Act of 1975, as amended (EPCA), Public Law 94-163, and your request the

Department of Energy issue a written enforcement policy statement based upon the guidelines

included in your letter.

Your letter asserts that one through 200 horespower general purpose polyphase electric motors

are produced with numerous performance variables to meet a variety of customer performance

criteria, and that the statute does not clearly delineate what motors are covered and what are not.

Consequently, manufacturers are concerned about identifying what motors in particular are

covered under the statutory definition of "electric motor," and thereby would be required to

comply with certain standards and test procedures prescribed by EPCA by October 1997, and

what motors are "definite purpose" or "special purpose ." and thereby not covered.

In response to your request, the attached draft enforcement policy has been prepared. We expect

to make some modifications to this draft. It is the Department's intention to publish an

enforcement policy statement in the Federal Register. I believe the draft policy meets the needs

you describe in you March 4 letter. The Department would appreciate receiving comments from

NEMA and its Motor and Generator Energy Management Task Force on the draft enforcement

policy by May 19, 1997, in order that we can issue the final guidelines in the Federal Reg ter as

quickly as possible.

I hope this satisfactorily addresses your concerns. If you have any questions concerning this

matter, please contact me at (202) 586-9127.

Sincerely,

/46e

Mi hael J. McCabe. Director

Office of Codes and Standards

Office of Building Technology,

State and Community Programs

Attachment

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U.S. Department of Energy , Office of Energy Efficiency and Renewable Energy:

Enforcement Policy for Electric Motors

Covered Under the Energy Policy and Conservation Act of 1975

The Energy Policy and Conservation Act of 1975, as amended (EPCA), Public Law 94-163,

establishes energy efficiency standards and test procedures for certain commercial and industrial

electric motors manufactured (alone or as a component of another piece of equipment) after

October 24, 1997, or in the case of an electric motor which requires listing or certification by a

nationally recognized safety testing laboratory after October 24, 1999. EPCA also directs the

Department of Energy (DOE or Department) to implement the test procedure provisions, and to

require efficiency labeling of motors and certification that covered motors comply with the

standards.

Section 340(13)(A) of EPCA defines the term "electric motor" as "any motor which is a general

purpose T-frame, single-speed, foot-mounting, polyphase squirrel-cage induction motor of the

National Electrical Manufacturers Association, Design A and B, continuous rated, operating on

230/460 volts and constant 60 Hertz line power as defined in NEMA Standards Publication MGl1987." Sections 340(13)(B) and (C) of EPCA also define the terms "definite purpose motor" and

"special purpose motor," respectively, for which there are no efficiency standards prescribed in the

statute.

The DOE proposed rule (61 FR 60440, November 27, 1996) clarifies the statutory definition of

the term, "electric motor," to mean a machine which converts electrical power into rotational

mechanical power and which: 1) includes but is not limited to motors with explosion-proof

construction'; 2) is rated for continuous duty operation, or is rated duty type S-i (IEC); 3)

contains a squirrel-cage or cage (IEC) rotor; 4) has foot-mounting, including foot-mounting with

flanges or detachable feet; 5) is built in accordance with NEMA T-frame dimensions, or IEC

metric equivalents (IEC); 6) has performance in accordance with NEMA Design A or B

characteristics, or equivalent designs such as IEC Design N (IEC); and 7) operates on polyphase

alternating current 60-Hertz sinusoidal power, and is (i) rated 230 volts or 460 volts, or both,

including any motor that is rated at multi-voltages that include 230 volts or 460 volts, or (ii) can

'EPCA expressly authorizes a two-year extension of the effective date for efficiency standards for "motors which

require listing or certification by a nationally recognized safety testing laboratory." EPCA section 342(b )(1). This

applies, for example , to explosion-proof motors which are otherwise general purpose motors.

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be operated on 230 volts or 460 volts, or both.2 Notwithstanding the aforementioned points of

clarification in the proposed rule, motor manufacturers have asserted there is still much

uncertainty as to whether motors with certain modifications are covered under the statute.

The Department understands that many modifications can be made to the generic " electric motor"

as defined in EPCA, and that there is some concern among motor manufacturers as to precisely

which motors, having such modifications, are covered under the statute, and whether

manufacturers will be able to comply with the statute by October 24, 1997. Consequently, motor

manufacturers have requested that the Department provide guidance as to which modifications of

electric motors are "general purpose," "definite purpose," and "special purpose" under EPCA.

The policy statement that follows is based upon recommendations from motor manufacturers and

energy efficiency advocates, and provides such guidance.

General Guidelines

EPCA specifies minimum nominal full-load energy efficiency standards for 1 to 200 horsepower

electric motors, and, to measure compliance with those standards, prescribes the test procedures

of the National Electrical Manufacturers Association (NEMA) Standard MGl and Institute of

Electrical and Electronics Engineers (IEEE) Standard 112. Labeling and certification

requirements will become effective only after DOE has promulgated a final rule prescribing such

requirements.. In DOE's view, as stated in Assistant Secretary Ervin's letter of May 9, 1996, to

NEMA's Malcolm O'Hagan, until DOE's regulations become effective, manufacturers can

establish that their motors comply with EPCA requirements if they use competent and reliable

procedures or methods, that give reasonable assurance of such compliance. So long as these

criteria are met, manufacturers could conduct required testing in their own laboratories or in

independent laboratories, and could employ alternative correlation methods (in lieu of actual

testing) for some motors. Manufacturers could also establish their compliance with EPCA

requirements through use of third party certification or verification programs such as those

recognized by Natural Resources Canada.

Motors with features or characteristics that do not meet the statutory definition of "electric

motor" are not covered and are, therefore, not required to meet EPCA requirements. Examples

include motors without feet or without provisions for feet, and variable speed motors operated on

-Terms followedty the parenthetical "IEC" are referred to in the International Electrotechnical Commission Standard

34-1. Other terms in this definition, if not defined in the proposed Code of Federal Regulations Title 10 Part 431.2, shall

be construed with reference to NEMA Standards Publication MG 1-1987.

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a variable frequency power supply.

Multispeed motors and variable speed motors, such as inverter duty motors, are not covered

equipment, based on their intrinsic design for use at variable speeds. However, NEMA Design A

or B motors that meet all other criteria under the definitions in EPCA for covered equipment, and

can be used with an inverter in variable speed applications as an additional feature,-still are

covered equipment under EPCA. In other words, being suitable for use on an inverter by itself

does not exempt it from EPCA requirements.

Motors designed for use on a particular type of application which are in a frame size that is one or

more frame series larger than the frame size assigned to that rating by sections 1.2 and 1.3 of

NEMA Standards Publication MG 13-1984 (R1990), "Frame Assignments for Alternating Current

Integral-Horsepower Induction Motors," in the Department's view, are. not usable in most general

purpose applications, due to the physical size increase associated with a frame series change. A

frame series is defined as the first two digits of the frame size designation. For example, 324T and

326T are both in the same frame series, while 364T is in the next larger frame series. Hence, in

the Department's view, a motor that is of a larger frame series than normally assigned to that

standard rating of motor is not covered by EPCA. A larger size motor within the same frame

series is covered.

Motors built in a frame series or size smaller than that assigned by MG 13-1984 (R1990) are

considered usable in most general purpose applications due to the simple modifications that can be

made to fit a smaller motor in place of a motor with a frame size according to NEMA MG 13.

Constructing a motor, that is typically in a T-frame series, in a smaller size below the T-frame

series does not exempt that motor.

Based on information available to DOE, an electric motor can be readily modified by installing

contact seals or rubbing seals to prevent ingress of water, dust, oil, and other foreign materials

into the motor. Nevertheless, such motors can still be used in most general purpose applications.

Manufacturers previously believed that motors with contact seals were not covered equipment

under EPCA, in part because the Institute of Electrical and Electronics Engineers Standard 112,

"Test Procedure for Polyphase Induction Motors and Generators," prescribed by EPCA did not

address the appropriate way to test a motor with contact seals installed: new seals are stiff and

take time to "wear-in;" they gradually loosen over the life of the motor; and finally they may need

replacement. Consequently, testing with contact seals installed could be misleading. Also, testing

the same motor twice for efficiency, once with seals and once without seals, would impose a

significant burden on the manufacturer. In the Department's view, the EPCA efficiency standards

apply to such motors, and the statute allows them to be tested for efficiency without contact or

rubbing seals installed.

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NEMA Standards Publication MG1, "Motors and Generators," is incorporated by EPCA, for

definitional purposes. MG1 categorizes electrical modifications to motors according to

performance characteristics that include locked rotor torque, breakdown torque, pull-up torque,

locked,,rotor current, and slip at rated load, and assigns design letters, such as NEMA Design A,

B, C, D, or E, to identify various combinations of such electrical performance characteristics. The

Department understands that, for example, the locked rotor torque established by MG1 for a

Design A or B motor is a minimum performance value that carries with it a range of performance

values up to, but does not include, the minimum locked rotor torque established for a Design C or

D motor. In the Department's view, a Design A or B motor can have electrical modifications that

affect torque and still be covered by EPCA. A motor that meets the torque values of Design C or

D is not covered.

Electric Motors as Components in Other Equipment

The Department understands that motor manufacturers are facing situations where customers that

are original equipment manufacturers use electric motors as components in end-use equipment

that requires listing or certification by a nationally recognized safety testing laboratory, but the

motors do not require "listing or certification by a nationally recognized safety testing laboratory."

In some instances, where the end-use equipment does require such listing, the file for listing or

certification specifies the particular motor to be used. Consequently, no substitution could be

made for the motor without review of the new motor and the entire system by the safety testing

laboratory.

A different situation could occur where an electric motor is constructed in a frame series or size

that is smaller (but still standard) than that assigned by NEMA Standards Publication MG 13-

1984 (R1990), sections 1.2 and 1.3, in order to fit into a restricted mounting space that is within

certain end-use equipment that may or may not require listing or certification by a nationally

recognized safety testing laboratory. In such case, the manufacturer of the end use equipment

might need to redesign the equipment containing the mounting space to accommodate the smaller

motor, and in addition. may need to have the system re-listed or re-certified for safety.

The Department is concerned that certain end-user equipment that requires safety listing, safety

certification, or redesign for reasons of safety, could become unavailable in the marketplace

because an electric motor specifically identified in the safety listing, safety certification, or safetyredesign document, is covered by EPCA and must be redesigned by the manufacturer so that it

complies with EPCA standards. The motor manufacturer can request from the Department, prior

to October 24, 1997, a 24-month delay of the Department's enforcement of the energy efficiency

level that applies to such electric motor. In such case, the motor manufacturer should submit to

the Department a request for delay of enforcement with a list of motors, for control purposes, that

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are in this situation. The list would identify: 1) the motor manufacturer and the motor by type

and model number; 2) the original equipment manufacturer and the application where the motor is

to be used; 3) the safety listing or safety certification organization and the listing or certification

file or document number, if applicable; the reason for needing a delay of enforcement; and 5) the

name, address, and telephone number of the person to contact for further information. The

request shall be signed by a responsible official of the requesting company.

The purpose of the request and the list is for control purposes, to advise the Department as to

which motors are used in equipment that is listed for safety and would otherwise have to comply

with the statute. As long as the manufacturer submits its request and list of covered motors, the

manufacturer can assume the motors on such a list would be viewed by the Department as subject

to conditions where delay is proper. The fact that a motor is on the list does not establish delay,

but is subject to conditions where delay is proper. Only motors on such a list would be viewed by

the Department as subject for delay. The fact a manufacturer submits a list does not, however,

bar DOE from' determining that a motor was improperly listed. The Department will be free to

make further inquiries of the manufacturers to be sure motors on the list are included in safety

tested equipment. The manufacturer would assume, generally, that there would be not delay of

enforcement for a motor not on such a list.

In the Department's view, where safety or redesign that actually precludes availability of certain

equipment becomes the overriding issue, the requesting process would mitigate an undue hardship

by allowing original equipment manufacturers time to modify their equipment to accept the

covered motor, and to have such equipment re-listed or re-certified.

A motor specified in a safety listing or certification could be in either Category I or Category II,

discussed below. Because more time, up to 24 months is contemplated for compliance by

Category II motors, the Department believes any safety listing issues concerning such motors can

be addressed during that time period. Hence, the foregoing guidance would not apply to

Category II motors. In addition, a safety listing or certification for a piece of equipment can

specify that a motor with certain characteristics, or with specific "component recognition," must

be included in such equipment. In these situations, the safety listing or certification does not

require a specific motor, and these situations also are not covered by the foregoing guidance.

Using the guidelines, the attached matrix provides examples that illustrate whether many common

features or motor variations fall within the motors covered by EPCA. Because manufacturers

produce many basic models that have many variations , the Department does not represent that the

matrix is all-inclusive , rather it is a set of examples demonstrating how the definitions and

guidelines would be applied to various motor types . By extension of these examples, any motor

currently in production, or to be designed in the future, can be classified.

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Category I - For " electric motors " (manufactured alone or as a component of another piece

of equipment) in Category I, EPCA efficiency standards and test procedures will be

enforced beginning on October 25, 1997.

The Department understands that some motors are essentially modifications of generic general

purpose motors. Modifications could consist, for example, of minor changes such as the addition

of temperature sensors or a heater, or changes in exterior features such as motor housing. Such

motors can still be used for most general purpose applications, and the modifications have little or

no effect on motor performance. Nor do the modifications affect energy efficiency. DOE does

not believe that the modifications justify excluding. these motors from meeting statutory energy

efficiency levels, or that Congress intended to exclude them from coverage.

Category II - For certain motors that are " definite purpose " according to present industry

practice, but that can be used in most general purpose applications, EPCA efficiency

standards and test procedures will be enforced beginning no later than October 25, 1999.

Section 340(13)(B) of EPCA defines the term "definite purpose motor" as "any motor designed in

standard ratings with standard operating characteristics or standard mechanical construction for

use under service conditions other than usual or for use on a particular type of application and

which cannot be used in most general purpose applications. " [Emphasis added.]

As with motors in Category I, motors in Category II are essentially modifications of generic

general purpose motors. Generally, however, the modifications contained in these motors are

more extensive and complex than the modifications in Category I motors. These Category II

motors had been considered "definite purpose" in common industry parlance, but are covered

equipment under EPCA because they can be used in most general purpose applications.

According to statements provided during the January 15, 1997, Public Hearing, Tr. pgs. 238-239,

the industry only recently became aware that such motors are covered under EPCA. Although the

statutory definition adopted in 1992 contained the definition of "definite purpose," the

Department recognizes its delay in issuing regulations that embody this definition probably

contributed to industry's delay in recognizing that these motors are covered.

The Department understands that motors with horsepower ratings that fall between the

horsepower ratings in section 342(b)(1) of EPCA. thermally protected motors, and motors with

roller bearings until recently, were viewed by most manufacturers as definite purpose motors,

consistent with the industry definition that did not contain the clause "which cannot be used in

most general purpose applications." During the period prior and subsequent to the hearing,

discussions among manufacturers resulted in a new understanding that such motors are general

purpose under EPCA, since they can be used in most general purpose applications. The

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Department believes that each of these types of motors requires a substantial amount of time for

redesign and testing in order to convert to motors that meet the efficiency standards in the statute.

Given the recent realization that they are covered, it is not realistic to expect the motors will be

able to comply by October.

Intermediate Horsepower Ratings

The Department understands that a motor with an intermediate horsepower rating, i.e., a

horsepower rating that falls between the horsepower ratings in section 342(b)(1) of EPCA, had

been considered a definite purpose motor in common industry parlance because such motors are

designed as a collaborative effort between the motor manufacturer and the motor user which

results in a unique horsepower rating, such as a 65 horsepower rating for a compressor

application. Nevertheless, such a 65 horsepower motor is covered by EPCA because it can be

used successfully in most general purpose applications. This becomes especially critical when a

motor manufacturer builds its business on intermediate horsepower ratings that still fit under the

definition of electric motor in EPCA because they. can be used in most general purpose

applications. The Department understands that redesigning and testing the efficiency for so many

niche market motors, so that they comply with EPCA standards, would take approximately two

years.

Moreover, in a situation such as that involving compressors, if the compressor manufacturer

cannot change its requirements from the 65 horsepower motor and the motor cannot be readily

replaced, the affected compressors will be unavailable in the marketplace while the required motor

is being redesigned and tested.

Thermally Protected Motors

The Department understands that in order to redesign a thermally protected motor to improve its

efficiency so that it complies with EPCA, various changes in the windings must be made which

will require the thermal protector to be re-selected. Such devices sense the inrush and running

current of the motor, as well as the operating temperature. Any changes to a motor that affect

these characteristics will prevent the protector from operating correctly. When a new protector is

selected, the motor must be tested to verify proper operation of the device in the motor. The

motor manufacturer would test the locked rotor and overload conditions, which could take

several days, and the results may dictate that a second selection is needed with additional testing.

When the manufacturer has finished testing, typically the manufacturer will have a third party

conduct additional testing. This testing may include cycling the motor in a locked-rotor condition

to verify that the protector functions properly. This testing may take days or even weeks to

perform.

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Since it was only recently recognized that these motors are covered by EPCA, in the

Department's view the total testing program makes it impossible for manufacturers to comply

with the EPCA efficiency levels in thermally protected motors by October 1997, especially since

each different motor winding must be tested and motor winding/thermal protector combinations

number in the thousands.

Motors with Roller Bearings

Based on information available to DOE, motors with roller bearings fit within the definition of

electric motor under the statute. However, because the IEEE Standard 112 Test Method B did

not provide measures to test motors with roller bearings installed, manufacturers mistakenly

believed such motors were not covered. Under IEEE 112, a motor with roller bearings could only

be tested for efficiency with the roller bearings removed and standard ball bearings installed as

temporary substitutes. Then on the basis of the energy efficiency information gained from that

test, the manufacturer would need to redesign the motor in order to comply with the statute. In

this situation, the Department understands that testing, redesigning, and retesting many lines of

motors with roller bearings would be difficult and would take significant time to establish

compliance.

Categories III, IV and V - Definite purpose motors, special purpose motors, and equipment

that is not an "electric motor" by definition are not covered by EPCA.

Section 340 (13)(A) of EPCA defines "definite purpose motor" as "any motor designed in

standard ratings with standard operating characteristics or standard mechanical construction for

use under service conditions other than usual, or for use on a particular type of application, and

which cannot be used in most general purpose applications."

Close-coupled Pump Motors

NEMA Standards Publication MG1-1993, with revisions one through three, Part 18, "DefinitePurpose Machines," defines "a face-mounting close-coupled pump motor" as "a medium

alternating-current squirrel-cage induction open or totally enclosed motor, with or without feet,

having a shaft suitable for mounting an impeller and sealing device." Paragraphs MG1 18.601-

18.614 specify its performance, face and shaft mounting dimensions, and frame assignments that

replace the suffix letters T and TS with the suffix letters JM and JP. The Department understands

that such motors are designed in standard ratings with standard operating characteristics for use in

certain close-coupled pumps and pumping applications, and cannot be used in non-pumping

applications, such as, for example, conveyors. Consequently, close-coupled pump motors are

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