CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS
 

1.1 PURPOSE OF DOCUMENT ............................................................................................. 1
 

1.2 OVERVIEW OF APPLIANCE STANDARDS ................................................................. 1
 

1.3 OVERVIEW OF SMALL ELECTRIC MOTOR STANDARDS...................................... 2
 

1.4 STRUCTURE OF THE DOCUMENT............................................................................... 4
 

LIST OF TABLES 

Table 1.3.1 Small Electric Motors Analyses................................................................................ 3
 

i 

EERE-2007-BT-STD-0007 COMMENT 33
 

 

 

 

CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF DOCUMENT
 

This Technical Support Document (TSD) provides the analytical approaches, inputs and 

results associated with DOE’s study of energy conservation standards for small electric motors 

during the notice of proposed rulemaking (NOPR) phase. This TSD also serves to provide 

technical detail and is a compendium to the life-cycle cost (LCC) and payback period (PBP), 

national impact analysis (NIA), and manufacturer impact analysis (MIA) spreadsheets that are 

posted on the DOE’s website for the NOPR analyses.1 

1.2	 OVERVIEW OF APPLIANCE STANDARDS 

Part C of title III of the Energy Policy and Conservation Act (EPCA) provides for an 

energy conservation program for certain commercial and industrial equipment. (42 U.S.C. 6311-

6317) In particular, section 346(b) of EPCA states that the Secretary of Energy must 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)) 

Before DOE determines whether to adopt a proposed energy conservation standard, it 

first solicits comments on the proposed standard. DOE designs any new or amended standard to 

achieve the maximum improvement in energy efficiency that is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A), 42 U.S.C. 6313(a)(6)(B)(i) and (b)(3)(A), and 

42 U.S.C. 6317(a)(1) and (c)) To determine whether economic justification exists, DOE must 

review comments on the proposal and determine that the benefits of the proposed standard 

exceed its burdens to the greatest extent practicable, weighing the following seven factors: 

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

subject to the 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, initial 

charges, or maintenance expenses for the covered products likely to result from 

imposition of the standard; 

3. the total projected amount of energy savings likely to result directly from 

imposition of the standard; 

4. any lessening of utility or performance of the covered products likely to result 

from imposition of the standard; 

1 DOE website: 

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

1 

EERE-2007-BT-STD-0007 COMMENT 33
 

5. the impact of any lessening of competition, as determined in writing by the 

Attorney General, likely to result from imposition of the standard; 

6. the need for national energy conservation; and 

7. other factors the Secretary considers relevant. 

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

1.3 OVERVIEW OF SMALL ELECTRIC MOTOR STANDARDS 

On July 10, 2006, the Secretary of Energy issued a determination stating “...the 

Department believes that standards for considered small motors appear economically justified 

based on balanced consideration of the information and analysis available to the Department at 

this time.” 71 FR 38807. DOE defines “considered small motors” as capacitor-start motors, 

including both induction-run and capacitor-run, and non-servo three-phase motors. 

The Secretary’s determination was based partly on analyses conducted by Lawrence 

Berkley National Laboratory (LBNL). In February 2002, LBNL published a report entitled 

Determination Analysis of Energy Conservation Standards for Small Electric Motors, which 

assessed options for setting energy conservation standards. That report was based on 

information from annual sales data, average load data, and research on existing and potential 

small motor efficiencies obtained from several organizations. 

DOE reviewed the comments it received from stakeholders on this draft analysis 

published in 2002 and then prepared its final, positive, determination for small electric motors on 

July 10, 2006. In that notice, DOE indicated that it found energy conservation standards for 

small electric motors appeared to be technologically feasible, economically justified and would 

result in significant energy savings. 71 FR 38799. As a result of this positive determination, 

DOE published an Energy Conservation Standards Rulemaking Framework Document for Small 

Electric Motors in 2007. This document describes the procedural and analytical approaches that 

DOE anticipated that it would use to evaluate the establishment of energy conservation standards 

for small electric motors.2 DOE also published the Notice of Public Meeting and Availability of 

Framework Document.72 FR 44990 (August 10, 2007). 

On September 13, 2007, DOE held a public meeting to discuss the proposed analytical 

framework. The analytical framework presented at the public meeting described different 

analyses, such as life-cycle cost and payback, the methods proposed for conducting them, and 

the relationships among the various analyses. Table 1.3.1 below provides a list of all the 

rulemaking analyses conducted, and at which stage of the rulemaking DOE publishes those 

analyses. 

2

 The document is available at the DOE website: 

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

2 

EERE-2007-BT-STD-0007 COMMENT 33
 

 

 

 

 

 

Table 1.3.1 Small Electric Motors Analyses 

Preliminary Analyses NOPR Final Rule 

Market and technology 

assessment 

Revised preliminary analyses Revised analyses 

Screening analysis Life-cycle cost subgroup 

analysis 

Engineering analysis Manufacturer impact analysis 

Energy use and end-use load 

characterization 

Utility impact analysis 

Markups for equipment price 

determination 

Employment impact analysis 

Life-cycle cost and payback 

period analyses 

Environmental assessment 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer 

impact analysis 

Representatives of small motor manufacturers, a nationally recognized trade association, 

and a prominent energy efficiency advocacy group attended the framework document public 

meeting and indicated their willingness to work with DOE in its analysis of potential energy 

conservation standards. The major items discussed at the public meeting included definitions for 

covered small electric motors and product classes; matters of proprietary designs; ties between 

efficiency improvements and incremental manufacturing costs; baseline and potential efficiency 

levels; base-case trends under different regulatory scenarios; analyses of costs to manufacture 

energy efficient small electric motors and the relationship to selling prices; LCC analyses and 

methods; LCC subgroups that may be more impacted by efficiency standards over other groups; 

motor rating, loading, and operating hours; the impacts of a standard on domestic energy 

supplies; and the scope of an environmental assessment. 

As part of information gathering and sharing, DOE prepared and circulated three 

interview guides to small motor manufacturers in 2007 and early 2008 (see preliminary TSD 

appendices 12A, 12B, and 12C). DOE issued these interview guides to small electric motor 

manufacturers with the following objectives: (1) to obtain the manufacturer selling price (MSP) 

versus efficiency curves for the engineering analysis; (2) to obtain market-related information for 

the covered motors, including an estimate of shipments; (3) to assess any preliminary impacts on 

manufacturers that may be associated with higher efficiency designs; and (4) to foster 

cooperation between DOE and these interested parties, who may choose to participate in the 

manufacturer impact analysis following the public meeting comment period. The interview 

guides requested input on (1) the relationship between manufacturing selling price and efficiency 

for four representative units selected by DOE; (2) market data such as distribution channels and 

end-use operating profiles for small motors; (3) preliminary manufacturer’s impacts; and (4) 

national shipment estimates (to be aggregated by the Business Information Service of the 

National Electrical Manufacturers Association). 

3 

EERE-2007-BT-STD-0007 COMMENT 33
 

 

DOE incorporated the information gathered at these meetings in its engineering analysis. 

Following the publication of the preliminary TSD and the public meeting for the preliminary 

analyses on January 31, 2009 DOE held additional meetings with manufacturers as part of the 

consultative process for the manufacturer impact analysis (Chapter 12). During this period, DOE 

received numerous comments regarding the preliminary analyses. 

DOE developed three spreadsheet tools for this rulemaking. The first spreadsheet tool 

calculates LCC and payback periods. The second spreadsheet tool calculates impacts of trial 

standards at various levels on small electric motor shipments, and calculates the NES and NPV at 

various standard levels. The third spreadsheet is for the government regulatory impact model 

(GRIM) used to calculate the INPV for the manufacturer impact analysis. The spreadsheets are 

posted on DOE’s website along with the complete TSD documenting the analysis supporting this 

NOPR. 

1.4 STRUCTURE OF THE DOCUMENT 

This TSD consists of 16 chapters including an environmental assessment and a regulatory 

impact analysis, plus additional appendices. 

Chapter 1 Introduction: Provides an overview of the appliance standards program and how 

it applies to the small electric motors rulemaking, provides a history of DOE’s 

actions to date, and outlines the structure of the TSD. 

Chapter 2 Analytical Framework: Describes the rulemaking process step by step. 

Chapter 3 Market and Technology Assessment: Characterizes the small electric motor 

market and the technologies available for increasing equipment efficiency. 

Chapter 4 Screening Analysis: Discusses the design options identified in chapter 3 that 

improve small motor efficiency, and determines which of these are viable for 

consideration in the engineering analysis. 

Chapter 5 Engineering Analysis: Presents detailed cost and efficiency information for the 

motors that constitute the representative units for analysis. This chapter describes 

DOE’s approach to the engineering analysis for determining manufacturer costs 

and selling prices. 

Chapter 6 Energy Use and End-Use Load Characterization: Discusses the process DOE 

used for generating energy use estimates and end-use load profiles for small 

electric motors. 

Chapter 7 Markups for Equipment Price Determination: Discusses the methods DOE used 

for establishing markups to convert manufacturer selling prices to installed 

customer equipment prices. 

4 

EERE-2007-BT-STD-0007 COMMENT 33
 

Chapter 8 Life-Cycle Cost and Payback Period Analyses: Describes the impact of potential 

candidate standards on consumers of small electric motors. This chapter 

compares the life-cycle cost of small motors and other measures of consumer 

impact with and without trial standard levels. 

Chapter 9 Shipments Analysis: Provides a shipments estimate for 200X and the methods 

DOE used for forecasting shipments with and without new energy conservation 

standards. 

Chapter 10 National Impact Analysis: Describes the national forecast of energy 

consumption, efficiency of new units, and annual equipment sales with and 

without new energy conservation standards. 

Chapter 11 Life-Cycle Cost Subgroup Analysis: Evaluates impacts on any identifiable 

groups or customers who may be disproportionately affected by any proposed 

national energy efficiency standard level. 

Chapter 12 Manufacturer Impact Analysis: Assesses the impacts on small motor 

manufacturers of any proposed energy efficiency standard. 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 products. 

Chapter 13 Utility Impact Analysis: Analyzes the effects of proposed small electric motor 

standard levels on electricity sales. The utility impact analysis compares model 

results for the base case and policy cases in which proposed standards are in 

place. 

Chapter 14 Employment Impact Analysis: Estimates national job creation or elimination 

(direct and indirect effects) resulting from possible standards due to reallocation 

of the associated commercial expenditures for purchasing and operating 

equipment. 

Chapter 15 Environmental Assessment for Small Electric Motors: Discusses the effects of 

energy conservation standards on airborne emissions of electric utilities. 

Chapter 16 Regulatory impact Analysis: Discusses the impact of the present regulatory 

actions and of non-regulatory alternatives to setting energy conservation 

standards. 

5 

EERE-2007-BT-STD-0007 COMMENT 33