## 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
AttachmentSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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 on230/460 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.
STAFF DRAFT 1 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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.
STAFF DRAFT 2 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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.

STAFF DRAFT 3 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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 marketplacebecause 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

STAFF DRAFT 4 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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.

STAFF DRAFT 5 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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

STAFF DRAFT 6 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May 8, 1997 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.

STAFF DRAFT . 7 STAFF DRAFTSTAFF DRAFT STAFF DRAFT STAFF DRAFT May S, 1997 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 MotorsNEMA 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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