Vol. 78 Friday, 

No. 235 December 6, 2013 

Part II 

Department of Energy 

10 CFR Part 431 

Energy Conservation Program: Energy Conservation Standards for 

Commercial and Industrial Electric Motors; Proposed Rule 

maindgalligan on DSK5TPTVN1PROD with PROPOSALS

73590 Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 

DEPARTMENT OF ENERGY 

10 CFR Part 431 

[Docket Number EERE–2010–BT–STD– 

0027] 

RIN 1904–AC28 

Energy Conservation Program: Energy 

Conservation Standards for 

Commercial and Industrial Electric 

Motors 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Notice of proposed rulemaking 

(NOPR) and public meeting. 

SUMMARY: The Energy Policy and 

Conservation Act of 1975 (EPCA), as 

amended, prescribes energy 

conservation standards for various 

consumer products and certain 

commercial and industrial equipment, 

including commercial and industrial 

electric motors. EPCA also requires the 

U.S. Department of Energy (DOE) to 

determine whether more-stringent, 

amended standards would be 

technologically feasible and 

economically justified, and would save 

a significant amount of energy. In this 

notice, DOE proposes energy 

conservation standards for a number of 

different groups of electric motors that 

DOE has not previously regulated. For 

those groups of electric motors currently 

regulated, the proposed standards 

would maintain the current energy 

conservation standards for some electric 

motor types and amend the energy 

conservation standards for other electric 

motor types. The document also 

announces a public meeting to receive 

comment on these proposed standards 

and associated analyses and results. 

DATES: DOE will hold a public meeting 

on Wednesday, December 11, 2013, 

from 9 a.m. to 4 p.m., in Washington, 

DC. The meeting will also be broadcast 

as a webinar. See section VII Public 

Participation for webinar registration 

information, participant instructions, 

and information about the capabilities 

available to webinar participants. 

DOE will accept comments, data, and 

information regarding this NOPR before 

and after the public meeting, but no 

later than February 4, 2014. See section 

VII Public Participation for details. 

ADDRESSES: The public meeting will be 

held at the U.S. Department of Energy, 

Forrestal Building, Room 8E–089, 1000 

Independence Avenue SW., 

Washington, DC 20585. To attend, 

please notify Ms. Brenda Edwards at 

(202) 586–2945. Please note that foreign 

nationals visiting DOE Headquarters are 

subject to advance security screening 

procedures. Any foreign national 

wishing to participate in the meeting 

should advise DOE as soon as possible 

by contacting Ms. Edwards to initiate 

the necessary procedures. Please also 

note that those wishing to bring laptops 

into the Forrestal Building will be 

required to obtain a property pass. 

Visitors should avoid bringing laptops, 

or allow an extra 45 minutes. Persons 

can attend the public meeting via 

webinar. For more information, refer to 

the Public Participation section near the 

end of this notice. 

Any comments submitted must 

identify the NOPR for Energy 

Conservation Standards for electric 

motors, and provide docket number 

EE–2010–BT–STD–2027 and/or 

regulatory information number (RIN) 

number 1904–AC28. Comments may be 

submitted using any of the following 

methods: 

1. Federal eRulemaking Portal: 

www.regulations.gov. Follow the 

instructions for submitting comments. 

2. Email: ElecMotors-2010-STD-0027@

ee.doe.gov. Include the docket number 

and/or RIN in the subject line of the 

message. 

3. Mail: Ms. Brenda Edwards, U.S. 

Department of Energy, Building 

Technologies Program, Mailstop EE–2J, 

1000 Independence Avenue SW., 

Washington, DC 20585–0121. If 

possible, please submit all items on a 

CD. It is not necessary to include 

printed copies. 

4. Hand Delivery/Courier: Ms. Brenda 

Edwards, U.S. Department of Energy, 

Building Technologies Program, 950 

L’Enfant Plaza SW., Suite 600, 

Washington, DC 20024. Telephone: 

(202) 586–2945. If possible, please 

submit all items on a CD, in which case 

it is not necessary to include printed 

copies. 

Written comments regarding the 

burden-hour estimates or other aspects 

of the collection-of-information 

requirements contained in this proposed 

rule may be submitted to Office of 

Energy Efficiency and Renewable 

Energy through the methods listed 

above and by email to Chad_S_

Whiteman@omb.eop.gov. 

For detailed instructions on 

submitting comments and additional 

information on the rulemaking process, 

see section VII of this document (Public 

Participation). 

Docket: The docket, which includes 

Federal Register notices, public meeting 

attendee lists and transcripts, 

comments, and other supporting 

documents/materials, is available for 

review at regulations.gov. All 

documents in the docket are listed in 

the regulations.gov index. However, 

some documents listed in the index, 

such as those containing information 

that is exempt from public disclosure, 

may not be publicly available. 

A link to the docket Web page can be 

found at http://www.regulations.gov/

#!docketDetail;D=EERE-2010-BT-STD0027. This Web page will contain a link 

to the docket for this notice on the 

regulations.gov site. The regulations.gov 

Web page will contain simple 

instructions on how to access all 

documents, including public comments, 

in the docket. See section VII for further 

information on how to submit 

comments through 

www.regulations.gov. 

For further information on how to 

submit a comment, review other public 

comments and the docket, or participate 

in the public meeting, contact Ms. 

Brenda Edwards at (202) 586–2945 or by 

email: Brenda.Edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT: 

James Raba, U.S. Department of Energy, 

Office of Energy Efficiency and 

Renewable Energy, Building 

Technologies Program, EE–2J, 1000 

Independence Avenue SW., 

Washington, DC 20585–0121. 

Telephone: (202) 586–8654. Email: 

Jim.Raba@ee.doe.gov. 

Ms. Ami Grace-Tardy, U.S. 

Department of Energy, Office of the 

General Counsel, GC–71, 1000 

Independence Avenue SW., 

Washington, DC 20585–0121. 

Telephone: (202) 586–5709. Email: 

Ami.Grace-Tardy@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Summary of the Proposed Rule 

A. Benefits and Costs to Consumers 

B. Impact on Manufacturers 

C. National Benefits 

II. Introduction 

A. Authority 

B. Background 

1. Current Standards 

2. History of Standards Rulemaking for 

Electric Motors 

3. Process for Setting Energy Conservation 

Standards 

III. General Discussion 

A. Test Procedure 

B. Equipment Classes and Current Scope of 

Coverage 

C. Expanded Scope of Coverage 

D. Technological Feasibility 

1. General 

2. Maximum Technologically Feasible 

Levels 

E. Energy Savings 

1. Determination of Savings 

2. Significance of Savings 

F. Economic Justification 

1. Specific Criteria 

a. Economic Impact on Manufacturers and 

Consumers 

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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 73591 

1For editorial reasons, upon codification in the 

U.S. Code, Parts B and C were redesignated as Parts 

A and A–1, respectively. 

b. Life-Cycle Costs 

c. Energy Savings 

d. Lessening of Utility or Performance 

e. Impact of Any Lessening of Competition 

f. Need for National Energy Conservation 

g. Other Factors 

2. Rebuttable Presumption 

IV. Methodology and Discussion of Related 

Comments 

A. Market and Technology Assessment 

1. Current Scope of Electric Motors Energy 

Conservation Standards 

2. Expanded Scope of Electric Motor 

Energy Conservation Standards 

3. Advanced Electric Motors 

4. Equipment Class Groups and Equipment 

Classes 

a. Electric Motor Design Letter 

b. Fire Pump Electric Motors 

c. Brake Motors 

d. Horsepower Rating 

e. Pole Configuration 

f. Enclosure Type 

g. Other Motor Characteristics 

5. Technology Assessment 

a. Decrease the Length of Coil Extensions 

b. Increase Cross-Sectional Area of Rotor 

Conductor Bars 

c. Increase Cross-Sectional Area of End 

Rings 

d. Increase the Number of Stator Slots 

e. Electrical Steel With Lower Losses 

f. Thinner Steel Laminations 

g. Increase Stack Length 

h. More Efficient Cooling System 

i. Reduce Skew on Conductor Cage 

B. Screening Analysis 

1. Technology Options Not Screened Out 

of the Analysis 

a. Copper Die-Cast Rotors 

b. Increase the Cross-Sectional Area of 

Copper in the Stator Slots 

2. Technology Options Screened Out of the 

Analysis 

C. Engineering Analysis 

1. Engineering Analysis Methodology 

2. Representative Units 

a. Electric Motor Design Type 

b. Horsepower Rating 

c. Pole-Configuration 

d. Enclosure Type 

3. Efficiency Levels Analyzed 

4. Test and Teardowns 

5. Software Modeling 

6. Cost Model 

a. Copper Pricing 

b. Labor Rate and Non-Production Markup 

c. Catalog Prices 

d. Product Development Cost 

7. Engineering Analysis Results 

8. Scaling Methodology 

D. Markups Analysis 

E. Energy Use Analysis 

1. Comments on Operating Hours 

2. Comments on Other Issues 

F. Life-Cycle Cost and Payback Period 

Analysis 

1. Equipment Costs 

2. Installation Costs 

3. Maintenance Costs 

4. Repair Costs 

5. Unit Energy Consumption 

6. Electricity Prices and Electricity Price 

Trends 

7. Lifetime 

8. Discount Rate 

9. Base Case Market Efficiency 

Distributions 

10. Compliance Date 

11. Payback Period Inputs 

12. Rebuttable-Presumption Payback 

Period 

G. Shipments Analysis 

H. National Impact Analysis 

1. Efficiency Trends 

2. National Energy Savings 

3. Equipment Price Forecast 

4. Net Present Value of Customer Benefit 

I. Consumer Subgroup Analysis 

J. Manufacturer Impact Analysis 

1. Overview 

2. GRIM Analysis and Key Inputs 

a. Product and Capital Conversion Costs 

b. Manufacturer Production Costs 

c. Shipment Forecast 

d. Markup Scenarios 

3. Discussion of Comments 

a. Scope of Coverage 

b. Conversion Costs 

c. Enforcement of Standards 

d. Motor Refurbishment 

4. Manufacturer Interviews 

a. Efficiency Levels above NEMA Premium 

b. Increase in Equipment Repairs 

c. Enforcement 

K. Emissions Analysis 

L. Monetizing Carbon Dioxide and Other 

Emissions Impacts 

1. Social Cost of Carbon 

a. Monetizing Carbon Dioxide Emissions 

b. Social Cost of Carbon Values Used in 

Past Regulatory Analyses 

c. Current Approach and Key Assumptions 

2. Valuation of Other Emissions 

Reductions 

M. Utility Impact Analysis 

N. Employment Impact Analysis 

O. Other Comments Received 

V. Analytical Results 

A. Trial Standard Levels 

B. Economic Justification and Energy 

Savings 

1. Economic Impacts on Individual 

Customers 

a. Life-Cycle Cost and Payback Period 

b. Consumer Subgroup Analysis 

c. Rebuttable Presumption Payback 

2. Economic Impacts on Manufacturers 

a. Industry Cash-Flow Analysis Results 

b. Impacts on Employment 

c. Impacts on Manufacturing Capacity 

d. Impacts on Sub-Group of Manufacturers 

e. Cumulative Regulatory Burden 

3. National Impact Analysis 

a. Significance of Energy Savings 

b. Net Present Value of Customer Costs and 

Benefits 

c. Indirect Impacts on Employment 

4. Impact on Utility or Performance 

5. Impact of Any Lessening of Competition 

6. Need of the Nation to Conserve Energy 

7. Summary of National Economic Impacts 

8. Other Factors 

C. Proposed Standards 

1. Benefits and Burdens of Trial Standard 

Levels Considered for Electric Motors 

2. Summary of Benefits and Costs 

(Annualized) of the Proposed Standards 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Orders 12866 

and 13563 

B. Review Under the Regulatory Flexibility 

Act 

1. Description and Estimated Number of 

Small Entities Regulated 

a. Methodology for Estimating the Number 

of Small Entities 

b. Manufacturer Participation 

c. Electric Motor Industry Structure and 

Nature of Competition 

d. Comparison Between Large and Small 

Entities 

2. Description and Estimate of Compliance 

Requirements 

3. Duplication, Overlap, and Conflict with 

Other Rules and Regulations 

4. Significant Alternatives to the Proposed 

Rule 

5. Significant Issues Raised by Public 

Comments 

C. Review Under the Paperwork Reduction 

Act 

D. Review Under the National 

Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates 

Reform Act of 1995 

H. Review Under the Treasury and General 

Government Appropriations Act, 1999 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General 

Government Appropriations Act, 2001 

K. Review Under Executive Order 13211 

L. Review Under the Information Quality 

Bulletin for Peer Review 

VII. Public Participation 

A. Attendance at the Public Meeting 

B. Procedure for Submitting Prepared 

General Statements For Distribution 

C. Conduct of the Public Meeting 

D. Submission of Comments 

E. Issues on Which DOE Seeks Comment 

VIII. Approval of the Office of the Secretary 

1. The authority citation for part 431 

continues to read as follows: 

2. Revise § 431.25 to read as follows: 

I. Summary of the Proposed Rule 

Title III, Part B of the Energy Policy 

and Conservation Act of 1975 (EPCA or 

the Act), Public Law 94–163 (42 U.S.C. 

6291–6309, as codified), established the 

Energy Conservation Program for 

Consumer Products Other Than 

Automobiles. Part C of Title III of EPCA 

(42 U.S.C. 6311–6317) established a 

similar program for ‘‘Certain Industrial 

Equipment,’’ including certain electric 

motors.1 (Within this preamble, DOE 

will use the terms ‘‘electric motors’’ and 

‘‘motors’’ interchangeably.) Pursuant to 

EPCA, any new or amended energy 

conservation standard that DOE may 

prescribe for certain equipment, such as 

electric motors, shall be designed to 

achieve the maximum improvement in 

energy efficiency that DOE determines 

is technologically feasible and 

economically justified. (42 U.S.C. 

6295(o)(2)(A) and 6316(a)). 

Furthermore, any new or amended 

standard must result in a significant 

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2Table 20–B of MG1–2011 provides nominal fullload efficiencies for ratings without nominal fullload efficiencies in Table 12–12 of MG1–2011. 

conservation of energy. (42 U.S.C. 

6295(o)(3)(B) and 6316(a)). 

In accordance with these and other 

statutory provisions discussed in this 

notice, the U.S. Department of Energy 

(DOE) proposes amending the energy 

conservation standards for electric 

motors by applying the standards 

currently in place to a wider scope of 

electric motors for which DOE does not 

currently regulate. In setting these 

standards, DOE is proposing to address 

a number of different groups of electric 

motors that have, to date, not been 

required to satisfy the energy 

conservation standards currently set out 

in 10 CFR part 431. In addition, with the 

exception of fire pump electric motors, 

the proposal would require all currently 

regulated motors to satisfy the efficiency 

levels prescribed in Table 12–12 and 

Table 20–B2 of MG1–2011, published 

by the National Electrical Manufacturers 

Association; fire pump motors would 

continue to meet the current standards 

that apply. All other electric motors that 

DOE is proposing to regulate would also 

need to meet these efficiency levels (i.e. 

Tables 12–12 and 20–B). As a practical 

matter, the many currently regulated 

motors would continue to be required to 

meet the standards that they already 

meet, but certain motors, such as those 

that satisfy the general purpose electric 

motors (subtype II) (‘‘subtype II’’) or that 

are NEMA Design B motors from 201 

through 500 horsepower, would need to 

meet the more stringent levels 

prescribed by MG1–2011 Tables 12–12 

and 20–B. These proposed efficiency 

levels are shown in Table I.1. If adopted, 

the proposed standards would apply to 

all covered motor types listed in Table 

I.1 that are manufactured in, or 

imported into, the United States starting 

on December 19, 2015. DOE may, 

however, depending on the nature of the 

comments it receives, revisit this 

proposed compliance date. 

TABLE I.1—PROPOSED ENERGY CONSERVATION STANDARDS FOR ELECTRIC MOTORS

[Compliance starting December 19, 2015] 

Equipment class 

group Electric motor design type Horsepower rating 

Pole 

configuration Enclosure Proposed TSL 

1 ........................ NEMA Design A & B * ............... 1–500 2, 4, 6, 8 Open .........................................

Enclosed ...................................

2 

2 

2 ........................ NEMA Design C * ...................... 1–200 4, 6, 8 Open .........................................

Enclosed ...................................

2 

2 

3 ........................ Fire Pump * ............................... 1–500 2, 4, 6, 8 Open .........................................

Enclosed ...................................

2 

2 

4 ........................ Brake Motors * ........................... 1–30 4, 6, 8 Open .........................................

Enclosed ...................................

2 

2 

* Indicates IEC equivalent electric motors are included. 

The following tables (Tables I.2 to I.5) 

detail the various proposed standard 

levels that comprise TSL 2 and that DOE 

would apply to each group of motors. In 

determining where a particular motor 

with a certain horsepower (hp) or 

kilowatt rating would fall within the 

requirements, as in DOE’s current 

regulations, DOE would apply the 

following approach in determining 

which rating would apply for 

compliance purposes: 

(1) A horsepower at or above the 

midpoint between the two consecutive 

horsepowers shall be rounded up to the 

higher of the two horsepowers; 

(2) A horsepower below the midpoint 

between the two consecutive 

horsepowers shall be rounded down to 

the lower of the two horsepowers; or 

(3) A kilowatt rating shall be directly 

converted from kilowatts to horsepower 

using the formula 1 kilowatt = (1/0.746) 

horsepower. The conversion should be 

calculated to three significant decimal 

places, and the resulting horsepower 

shall be rounded in accordance with the 

rules listed in (1) and (2). 

TABLE I.2—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS (EXCLUDING FIRE PUMP ELECTRIC MOTORS, INTEGRAL BRAKE ELECTRIC MOTORS, AND NON-INTEGRAL BRAKE

ELECTRIC MOTORS) 

[Compliance starting December 19, 2015] 

Motor horsepower/standard 

kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................. 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .............. 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ................. 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ................. 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ................. 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .............. 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ............... 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ................ 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ................ 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ............. 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ................ 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7 

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TABLE I.2—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS (EXCLUDING FIRE PUMP ELECTRIC MOTORS, INTEGRAL BRAKE ELECTRIC MOTORS, AND NON-INTEGRAL BRAKE

ELECTRIC MOTORS)—Continued 

[Compliance starting December 19, 2015] 

Motor horsepower/standard 

kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

40/30 ................ 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7 

50/37 ................ 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4 

60/45 ................ 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0 

75/55 ................ 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1 

100/75 .............. 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1 

125/90 .............. 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1 

150/110 ............ 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1 

200/150 ............ 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1 

250/186 ............ 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0 

300/224 ............ 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0 

350/261 ............ 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0 

400/298 ............ 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0 

450/336 ............ 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0 

500/373 ............ 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0 

TABLE I.3—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN C ELECTRIC MOTORS (EXCLUDING

NON-INTEGRAL BRAKE ELECTRIC MOTORS AND INTEGRAL BRAKE ELECTRIC MOTORS) 

[Compliance starting December 19, 2015] 

Motor horsepower/standard kilowatt equivalent 

Nominal full load efficiency (%) 

4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open 

1/.75 ..................................................................... 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .................................................................. 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ..................................................................... 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ..................................................................... 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ..................................................................... 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .................................................................. 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ................................................................... 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 .................................................................... 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 .................................................................... 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ................................................................. 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 .................................................................... 93.6 94.1 93.0 93.6 91.7 91.7 

40/30 .................................................................... 94.1 94.1 94.1 94.1 91.7 91.7 

50/37 .................................................................... 94.5 94.5 94.1 94.1 92.4 92.4 

60/45 .................................................................... 95.0 95.0 94.5 94.5 92.4 93.0 

75/55 .................................................................... 95.4 95.0 94.5 94.5 93.6 94.1 

100/75 .................................................................. 95.4 95.4 95.0 95.0 93.6 94.1 

125/90 .................................................................. 95.4 95.4 95.0 95.0 94.1 94.1 

150/110 ................................................................ 95.8 95.8 95.8 95.4 94.1 94.1 

200/150 ................................................................ 96.2 95.8 95.8 95.4 94.5 94.1 

TABLE I.4—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS

[Compliance starting December 19, 2015] 

Motor horsepower/standard 

kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................. 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0 

1.5/1.1 .............. 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5 

2/1.5 ................. 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5 

3/2.2 ................. 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5 

5/3.7 ................. 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5 

7.5/5.5 .............. 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5 

10/7.5 ............... 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5 

15/11 ................ 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5 

20/15 ................ 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2 

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73594 Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 

TABLE I.4—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS—Continued 

[Compliance starting December 19, 2015] 

Motor horsepower/standard 

kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

25/18.5 ............. 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2 

30/22 ................ 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0 

40/30 ................ 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0 

50/37 ................ 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7 

60/45 ................ 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4 

75/55 ................ 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6 

100/75 .............. 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6 

125/90 .............. 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6 

150/110 ............ 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6 

200/150 ............ 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6 

250/186 ............ 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5 

300/224 ............ 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5 

350/261 ............ 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5 

400/298 ............ 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5 

450/336 ............ 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5 

500/373 ............ 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5 

TABLE I.5—PROPOSED ENERGY CONSERVATION STANDARDS FOR INTEGRAL BRAKE ELECTRIC MOTORS AND NONINTEGRAL BRAKE ELECTRIC MOTORS

[Compliance starting December 19, 2015] 

Motor horsepower/standard kilowatt 

equivalent 

Nominal full load efficiency (%) 

4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open 

1/.75 ......................................................... 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 ...................................................... 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ......................................................... 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ......................................................... 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ......................................................... 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 ...................................................... 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ....................................................... 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ........................................................ 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ........................................................ 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ..................................................... 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ........................................................ 93.6 94.1 93.0 93.6 91.7 91.7 

A. Benefits and Costs to Consumers 

Table I.6 presents DOE’s evaluation of 

the economic impacts of the proposed 

standards on consumers of electric 

motors, as measured by the weighted 

average life-cycle cost (LCC) savings and 

the weighted average median payback 

period. 

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3All monetary values in this section are 

expressed in 2012 dollars and are discounted to 

2013. 4One quad (quadrillion Btu) is the equivalent of 

293.1 billion kilowatt hours (kWh) or 172.3 million 

barrels of oil. 

5Based on U.S. Department of Energy, Energy 

Information Administration, Annual Energy 

Outlook (AEO) 2013 data. 

6A metric ton is equivalent to 1.1 short tons. 

Results for NOX and Hg are presented in short tons. 7 DOE calculates emissions reductions relative to 

the AEO2013 reference case, which generally 

represents current legislation and environmental 

regulations for which implementing regulations 

were available as of December 31, 2012. 

8Technical Update of the Social Cost of Carbon 

for Regulatory Impact Analysis Under Executive 

Order 12866. Interagency Working Group on Social 

Cost of Carbon, United States Government. May 

2013; revised November 2013. http://

www.whitehouse.gov/sites/default/files/omb/assets/

inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf. 

9 DOE is currently investigating valuation of 

avoided Hg and SO2 emissions. 

TABLE I.6—IMPACTS OF PROPOSED

STANDARDS ON CONSUMERS OF

ELECTRIC MOTORS

Weighted 

average 

LCC 

savings * 

(2012$) 

Weighted 

average 

median 

payback 

period * 

(years) 

Equipment Class 

Group 1.

132 ......... 3.3 

Equipment Class 

Group 2.

38 ........... 5.0 

Equipment Class 

Group 3.

N/A ** ...... N/A ** 

Equipment Class 

Group 4.

259 ......... 1.9 

* The results for each equipment class 

group (ECG) are a shipment weighted average of results for the representative units in 

the group. ECG 1: Representative units 1, 2, 

and 3; ECG 2: Representative units 4 and 5; 

ECG 3: Representative units 6, 7, and 8; ECG 

4: Representative units 9 and 10. The weighted average lifetime in each equipment classes 

is 15 years and ranges from 8 to 29 years depending on the motor horsepower and application. 

** For equipment class group 3, the proposed standard level is the same as the baseline; thus, no customers are affected. 

B. Impact on Manufacturers 

The industry net present value (INPV) 

is the sum of the discounted cash flows 

to the industry from the base year 

through the end of the analysis period 

(2013 to 2044). Using a real discount 

rate of 9.1 percent, DOE estimates that 

the industry net present value (INPV) 

for manufacturers of electric motors is 

$3,371.2 million in 2012$. Under the 

proposed standards, DOE expects that 

manufacturers may lose up to 8.4 

percent of their INPV, which 

corresponds to approximately $283.5 

million. Additionally, based on DOE’s 

interviews with the manufacturers of 

electric motors, DOE does not expect 

any plant closings or significant loss of 

employment based on the energy 

conservation standards chosen in 

today’s Notice of Proposed Rulemaking 

(NOPR). 

C. National Benefits and Costs 3

DOE’s analyses indicate that the 

proposed standards would save a 

significant amount of energy. Estimated 

lifetime savings for electric motors 

purchased over the 30-year period that 

begins in the year of compliance with 

new and amended standards (2015– 

2044) would amount to 7.0 quads (fullfuel-cycle energy).4 The annualized 

energy savings (0.23 quads) are 

equivalent to one percent of total U.S. 

industrial primary energy consumption 

in 2011.5

The estimated cumulative net present 

value (NPV) of total consumer costs and 

savings attributed to the proposed 

standards for electric motors ranges 

from $8.7 billion (at a 7-percent 

discount rate) to $23.3 billion (at a 3- 

percent discount rate). This NPV 

expresses the estimated total value of 

future operating-cost savings minus the 

estimated increased equipment costs for 

equipment purchased in 2015–2044. 

In addition, the proposed standards 

would have significant environmental 

benefits. Estimated energy savings 

would result in cumulative emission 

reductions of 396 million metric tons 

(Mt) 6 of carbon dioxide (CO2), 674 

thousand tons of sulfur dioxide (SO2), 

499 thousand tons of nitrogen oxides 

(NOX) and 0.8 tons of mercury (Hg).7

Through 2030, the estimated energy 

savings would result in cumulative 

emissions reductions of 96 Mt of CO2.

The value of the CO2 reductions is 

calculated using a range of values per 

metric ton of CO2 (otherwise known as 

the Social Cost of Carbon (SCC) 

developed by an interagency process).8

The derivation of the SCC values is 

discussed in section IV.M. DOE 

estimates the present monetary value of 

the CO2 emissions reduction is between 

$2.5 and $36.6 billion. DOE also 

estimates the present monetary value of 

the NOX emissions reduction is $0.3 

billion at a 7-percent discount rate and 

$0.6 billion at a 3-percent discount 

rate.9

Table I.7 summarizes the national 

economic costs and benefits expected to 

result from the proposed standards for 

electric motors. 

TABLE I.7—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF ELECTRIC MOTORS ENERGY CONSERVATION

STANDARDS, PRESENT VALUE FOR MOTORS SHIPPED IN 2015–2044 IN BILLION 2012$ 

Category Present value 

billion 2012$ 

Discount rate 

(%) 

Benefits: 

Consumer Operating Cost Savings ...................................................................................................... 14.8 

34.9 

7 

3 

CO2 Reduction Monetized Value ($11.8/t case) * ................................................................................ 2.5 5 

CO2 Reduction Monetized Value ($39.7/t case) * ................................................................................ 11.8 3

CO2 Reduction Monetized Value ($61.2/t case) * ................................................................................ 18.9 2.5 

CO2 Reduction Monetized Value ($117.0/t case) * .............................................................................. 36.6 3 

NOX Reduction Monetized Value (at $2,639/ton) ** ............................................................................. 0.3 

0.6 

7 

3 

Total Benefits † ................................................................................................................................. 26.9 

47.4 

7 

3 

Costs: 

Consumer Incremental Installed Costs ................................................................................................ 6.1 

11.7 

7 

3 

Net Benefits: 

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73596 Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 

10 DOE used a two-step calculation process to 

convert the time-series of costs and benefits into 

annualized values. First, DOE calculated a present 

value in 2013, the year used for discounting the 

NPV of total consumer costs and savings, for the 

time-series of costs and benefits using discount 

rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For 

the latter, DOE used a range of discount rates, as 

shown in Table I.3. From the present value, DOE 

then calculated the fixed annual payment over a 30- 

year period (2015 through 2044) that yields the 

same present value. The fixed annual payment is 

the annualized value. Although DOE calculated 

annualized values, this does not imply that the 

time-series of cost and benefits from which the 

annualized values were determined is a steady 

stream of payments. 

TABLE I.7—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF ELECTRIC MOTORS ENERGY CONSERVATION

STANDARDS, PRESENT VALUE FOR MOTORS SHIPPED IN 2015–2044 IN BILLION 2012$—Continued 

Category Present value 

billion 2012$ 

Discount rate 

(%) 

Including CO2 and NOX Reduction Monetized Value .......................................................................... 20.8 

35.7 

7 

3 

* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile 

SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate 

an escalation factor. 

** The value represents the average of the low and high NOX values used in DOE’s analysis. 

† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to SCC value of $39.7/t in 2015. 

The benefits and costs of today’s 

proposed standards for electric motors, 

sold in years 2015–2044, can also be 

expressed in terms of annualized values. 

The annualized monetary values are the 

sum of (1) the annualized national 

economic value of the benefits from 

operation of the commercial and 

industrial equipment that meet the 

proposed standards (consisting 

primarily of operating cost savings from 

using less energy, minus increases in 

equipment purchase and installation 

costs, which is another way of 

representing consumer NPV), and (2) 

the annualized monetary value of the 

benefits of emission reductions, 

including CO2 emission reductions.10

Although combining the values of 

operating savings and CO2 emission 

reductions provides a useful 

perspective, two issues should be 

considered. First, the national operating 

savings are domestic U.S. consumer 

monetary savings that occur as a result 

of market transactions while the value 

of CO2 reductions is based on a global 

value. Second, the assessments of 

operating cost savings and CO2 savings 

are performed with different methods 

that use different time frames for 

analysis. The national operating cost 

savings is measured over the lifetime of 

electric motors shipped in years 2015– 

2044. The SCC values, on the other 

hand, reflect the present value of some 

future climate-related impacts resulting 

from the emission of one ton of carbon 

dioxide in each year. These impacts 

continue well beyond 2100. 

Estimates of annualized benefits and 

costs of the proposed standards for 

electric motors are shown in Table I.8. 

The results under the primary estimate 

are as follows. Using a 7-percent 

discount rate for benefits and costs other 

than CO2 reduction, for which DOE 

used a 3-percent discount rate along 

with the average SCC series that uses a 

3-percent discount rate, the cost of the 

standards proposed in today’s rule is 

$462 million per year in increased 

equipment costs; while the estimated 

benefits are $1,114 million per year in 

reduced equipment operating costs, 

$586 million in CO2 reductions, and 

$21.5 million in reduced NOX

emissions. In this case, the net benefit 

would amount to $957 million per year. 

Using a 3-percent discount rate for all 

benefits and costs and the average SCC 

series, the estimated cost of the 

standards proposed in today’s rule is 

$577 million per year in increased 

equipment costs; while the estimated 

benefits are $1,730 million per year in 

reduced operating costs, $586 million in 

CO2 reductions, and $31.5 million in 

reduced NOX emissions. In this case, the 

net benefit would amount to 

approximately $1,354 million per year. 

TABLE I.8—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR ELECTRIC

MOTORS, IN MILLION 2012$ 

Discount rate Primary estimate * Low net benefits 

estimate * 

High net benefits 

estimate * 

million 2012$/year 

Benefits: 

Consumer Operating Cost Savings ........................... 7% ..............................

3% ..............................

1,114 

1,730 

924 

1,421 

1,358 

2,134 

CO2 Reduction Monetized Value ($11.8/t case) * ..... 5% .............................. 155 134 179 

CO2 Reduction Monetized Value ($39.7/t case) * ..... 3% .............................. 586 506 679 

CO2 Reduction Monetized Value ($61.2/t case) * ..... 2.5% ........................... 882 762 1022 

CO2 Reduction Monetized Value ($117.0/t case) * ... 3% .............................. 1,811 1,565 2,098 

NOX Reduction Monetized Value (at $2,639/ton) ** .. 7% ..............................

3% ..............................

21.46 

31.48 

18.55 

27.20 

24.68 

36.39 

Total Benefits † ....................................................... 7% plus CO2 range ....

7% ..............................

3% plus CO2 range ....

3% ..............................

1,290 to 2,947 

1,721 

1,916 to 3,572 

2,347 

1,077 to 2,507 

1,449 

1,583 to 3,014 

1,955 

1,562 to 3,481 

2,061 

2,350 to 4,268 

2,849 

Costs: 

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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 73597 

11For editorial reasons, upon codification in the 

U.S. Code, Parts B and C were redesignated as Parts 

A and A–1, respectively. 

TABLE I.8—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR ELECTRIC

MOTORS, IN MILLION 2012$—Continued 

Discount rate Primary estimate * Low net benefits 

estimate * 

High net benefits 

estimate * 

Incremental Installed Costs ....................................... 7% ..............................

3% ..............................

462 

577 

492 

601 

447 

569 

Net Benefits: 

Total † ......................................................................... 7% plus CO2 range ....

7% ..............................

3% plus CO2 range ....

3% ..............................

585 to 2,016 

957 

982 to 2,413 

1,354 

1,115 to 3,033 

1,614 

1,781 to 3,700 

2,280 

1,353 to 3,438 

1,887 

1,957 to 4,043 

2,492 

* This table presents the annualized costs and benefits associated with electric motors shipped in 2015–2044. These results include benefits to 

consumers which accrue after 2044 from the equipment purchased in years 2015–2044. Costs incurred by manufacturers, some of which may 

be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The Primary, 

Low Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy Outlook (AEO) 2013 Reference 

case, Low Estimate, and High Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected equipment 

price in the Primary Estimate, a declining rate for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1. 

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile 

SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate 

an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount 

rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled 

discount rate, and those values are added to the full range of CO2 values. 

DOE has tentatively concluded that 

the proposed standards represent the 

maximum improvement in energy 

efficiency that is technologically 

feasible and economically justified, and 

would result in the significant 

conservation of energy. DOE further 

notes that equipment achieving these 

standard levels are already 

commercially available for most 

equipment classes covered by today’s 

proposal. Based on the analyses 

described above, DOE has tentatively 

concluded that the benefits of the 

proposed standards to the Nation 

(energy savings, positive NPV of 

consumer benefits, consumer LCC 

savings, and emission reductions) 

would outweigh the burdens (loss of 

INPV for manufacturers and LCC 

increases for some consumers). 

DOE also considered more-stringent 

energy efficiency levels as trial standard 

levels, and is still considering them in 

this rulemaking. However, DOE has 

tentatively concluded that the potential 

burdens of the more-stringent energy 

efficiency levels would outweigh the 

projected benefits. Depending on the 

comments that DOE receives in 

response to this notice and related 

information collected and analyzed 

during the course of this rulemaking, 

DOE may adopt energy efficiency levels 

presented in this notice that are either 

higher or lower than the proposed 

standards, or some combination of 

level(s) that incorporate the proposed 

standards in part. 

II. Introduction 

The following section briefly 

discusses the statutory authority 

underlying today’s proposed rule, as 

well as some relevant historical 

background related to the establishment 

of standards for electric motors. 

A. Authority 

Title III, Part B of the Energy Policy 

and Conservation Act of 1975 (EPCA or 

the Act), Public Law 94–163, as 

amended (42 U.S.C. 6291–6309) 

established the ‘‘Energy Conservation 

Program for Consumer Products Other 

Than Automobiles.’’ Part C of Title III of 

EPCA (42 U.S.C. 6311–6317) established 

a similar program for ‘‘Certain Industrial 

Equipment,’’ including electric 

motors.11 The Energy Policy Act of 1992 

(EPACT 1992) (Pub. L. 102–486) 

amended EPCA by establishing energy 

conservation standards and test 

procedures for certain commercial and 

industrial electric motors (in context, 

‘‘motors’’) manufactured (alone or as a 

component of another piece of 

equipment) after October 24, 1997. In 

December 2007, Congress passed into 

law the Energy Independence and 

Security Act of 2007 (EISA 2007) (Pub. 

L. 110–140). Section 313(b)(1) of EISA 

2007 updated the energy conservation 

standards for those electric motors 

already covered by EPCA and 

established energy conservation 

standards for a larger scope of motors 

not previously covered by standards. (42 

U.S.C. 6313(b)(2)) EPCA directs the 

Secretary of Energy to publish a final 

rule no later than 24 months after the 

effective date of the previous final rule 

to determine whether to amend the 

standards already in effect. Any such 

amendment shall apply to electric 

motors manufactured after a date which 

is five years after either: (1) The 

effective date of the previous 

amendment or (2) if the previous final 

rule did not amend the standards, the 

earliest date by which a previous 

amendment could have been effective. 

(42 U.S.C. 6313(b)(4)(B)) 

DOE is issuing today’s proposal 

pursuant to Part C of Title III, which 

establishes an energy conservation 

program for covered equipment that 

consists essentially of four parts: (1) 

Testing; (2) labeling; (3) the 

establishment of Federal energy 

conservation standards; and (4) 

certification and enforcement 

procedures. For those electric motors for 

which Congress established standards, 

or for which DOE amends or establishes 

standards, the DOE test procedure must 

be the prescribed procedures that 

currently appear at 10 CFR part 431 that 

apply to electric motors. The test 

procedure is subject to review and 

revision by the Secretary in accordance 

with certain criteria and conditions. 

(See 42 U.S.C. 6314(a)) 

Section 343(a)(5)(B)–(C) of EPCA, 42 

U.S.C. 6314(a)(5)(B)–(C), provides in 

part that if the NEMA- and IEEEdeveloped test procedures are amended, 

DOE shall so amend the test procedures 

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73598 Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 

under 10 CFR part 431, unless the 

Secretary determines, by rule, that the 

amended industry procedures would 

not meet the requirements for test 

procedures to produce results that 

reflect energy efficiency, energy use, 

and estimated operating costs of the 

tested motor, or, would be unduly 

burdensome to conduct. (42 U.S.C. 

6314(a)(2)–(3), (a)(5)(B)) As newer 

versions of the NEMA and IEEE test 

procedures for electric motors were 

developed, DOE updated 10 CFR part 

431 to reflect these changes. 

Manufacturers of covered equipment 

must use the prescribed DOE test 

procedure as the basis for certifying to 

DOE that their equipment complies with 

the applicable energy conservation 

standards adopted under EPCA and 

when making representations to the 

public regarding the energy use or 

efficiency of such equipment. (42 U.S.C. 

6314(d)) Similarly, DOE must use these 

test procedures to determine whether 

the equipment comply with standards 

adopted pursuant to EPCA. Id. 

DOE must follow specific statutory 

criteria for prescribing new and 

amended standards for covered 

equipment. In the case of electric 

motors, the criteria set out in relevant 

subsections of 42 U.S.C. 6295, which 

normally applies to standards related to 

consumer products, also apply to the 

setting of energy conservation standards 

for motors via 42 U.S.C. 6316(a). As 

indicated above, new and amended 

standards must be designed to achieve 

the maximum improvement in energy 

efficiency that is technologically 

feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A) and 6316(a)) 

Furthermore, DOE may not adopt any 

standard that would not result in the 

significant conservation of energy. (42 

U.S.C. 6295(o)(3) and 6316(a)) 

Moreover, DOE may not prescribe a 

standard: (1) For certain equipment, 

including electric motors, if no test 

procedure has been established for the 

product, or (2) if DOE determines by 

rule that the proposed standard is not 

technologically feasible or economically 

justified. (42 U.S.C. 6295(o)(3)(A)– 

6316(a)) In deciding whether a proposed 

standard is economically justified, DOE 

must determine whether the benefits of 

the standard exceed its burdens. (42 

U.S.C. 6295(o)(2)(B)(i) and 6316(a)) DOE 

must make this determination after 

receiving comments on the proposed 

standard, and by considering, to the 

greatest extent practicable, the following 

seven factors: 

1. The economic impact of the 

standard on manufacturers and 

consumers of the 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 that 

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 of 

Energy (Secretary) considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII) and 

6316(a)) 

EPCA, as codified, also contains what 

is known as an ‘‘anti-backsliding’’ 

provision, which prevents the Secretary 

from prescribing any new or amended 

standards that either increase the 

maximum allowable energy use or 

decrease the minimum required energy 

efficiency of a covered product. (42 

U.S.C. 6295(o)(1) and 6316(a)) Also, the 

Secretary may not prescribe an amended 

or new standard if interested persons 

have established by a preponderance of 

the evidence that the standard is likely 

to result in the unavailability in the 

United States of any covered product 

type (or class) of performance 

characteristics (including reliability), 

features, sizes, capacities, and volumes 

that are substantially the same as those 

generally available in the United States. 

(42 U.S.C. 6295(o)(4) and 6316(a)) 

Further, EPCA, as codified, 

establishes a rebuttable presumption 

that a standard is economically justified 

if the Secretary finds that the additional 

cost to the consumer of purchasing a 

product complying with an energy 

conservation standard level will be less 

than three times the value of the energy 

savings during the first year that the 

consumer will receive as a result of the 

standard, as calculated under the 

applicable test procedure. (42 U.S.C. 

6295(o)(2)(B)(iii) and 6316(a)) 

Additionally, 42 U.S.C. 6295(q)(1), as 

applied to covered equipment via 42 

U.S.C. 6316(a), specifies requirements 

when promulgating a standard for a type 

or class of covered product that has two 

or more subcategories. DOE must 

specify a different standard level than 

that which applies generally to such 

type or class of equipment for any group 

of covered equipment that have the 

same function or intended use if DOE 

determines that equipment within such 

group: (A) Consume a different kind of 

energy from that consumed by other 

covered equipment within such type (or 

class); or (B) have a capacity or other 

performance-related feature which other 

equipment within such type (or class) 

do not have and such feature justifies a 

higher or lower standard. (42 U.S.C. 

6294(q)(1) and 6316(a)). In determining 

whether a performance-related feature 

justifies a different standard for a group 

of products, DOE must consider such 

factors as the utility to the consumer of 

the feature and other factors DOE deems 

appropriate. Id. Any rule prescribing 

such a standard must include an 

explanation of the basis on which such 

higher or lower level was established. 

(42 U.S.C. 6295(q)(2) and 6316(a)) 

Federal energy conservation 

requirements generally supersede State 

laws or regulations concerning energy 

conservation testing, labeling, and 

standards. (42 U.S.C. 6297(a)–(c) and 

6316(a)) DOE may, however, grant 

waivers of Federal preemption for 

particular State laws or regulations, in 

accordance with the procedures and 

other provisions set forth under 42 

U.S.C. 6297(d)). 

B. Background 

1. Current Standards 

An electric motor is a device that 

converts electrical power into rotational 

mechanical power. The outside 

structure of the motor is called the 

frame, which houses a rotor (the 

spinning part of the motor) and the 

stator (the stationary part that creates a 

magnetic field to drive the rotor). 

Although many different technologies 

exist, DOE’s rulemaking is concerned 

with squirrel-cage induction motors, 

which represent the majority of electric 

motor energy use. In squirrel-cage 

induction motors, the stator drives the 

rotor by inducing an electric current in 

the squirrel-cage, which then reacts 

with the rotating magnetic field to 

propel the rotor in the same way a 

person can repel one handheld magnet 

with another. The squirrel-cage used in 

the rotor of induction motors consists of 

longitudinal conductive bars (rotor bars) 

connected at both ends by rings (end 

rings) forming a cage-like shape. Among 

other design parameters, motors can 

vary in horsepower, number of ‘‘poles’’ 

(which determines how quickly the 

motor rotates), and torque 

characteristics. Most motors have 

‘‘open’’ frames that allow cooling 

airflow through the motor body, though 

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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 73599 

12The members of the Motor Coalition include: 

National Electrical Manufacturers Association, 

American Council for an Energy-Efficient Economy, 

Appliance Standards Awareness Project, Alliance to 

Save Energy, Earthjustice, Natural Resources 

Defense Council, Northwest Energy Efficiency 

Alliance, Northeast Energy Efficiency Partnerships, 

and Northwest Power and Conservation Council. 

13 DOE’s proposal differs from that of the Motor 

Coalition in that DOE’s proposal covers brake 

motors and does not set separate standards for Uframe motors. It also seeks supplemental 

information regarding certain 56-frame motors. See 

section IV.A.2 for details. 

some have enclosed frames that offer 

added protection from foreign 

substances and bodies. DOE regulates 

various motor types from between 1 and 

500 horsepower, with 2, 4, 6, and 8 

poles, and with both open and enclosed 

frames. 

EPACT 1992 amended EPCA by 

establishing energy conservation 

standards and test procedures for 

certain commercial and industrial 

electric motors manufactured either 

alone or as a component of another 

piece of equipment after October 24, 

1997. Section 313 of EISA 2007 

amended EPCA by: (1) Striking the 

definition of ‘‘electric motor’’ provided 

under EPACT 1992, (2) setting forth 

definitions for ‘‘general purpose electric 

motor (subtype I)’’ and ‘‘general purpose 

electric motor (subtype II),’’ and (3) 

prescribing energy conservation 

standards for ‘‘general purpose electric 

motors (subtype I),’’ ‘‘general purpose 

electric motors (subtype II), ‘‘fire pump 

electric motors,’’ and ‘‘NEMA Design B 

general purpose electric motors’’ with a 

power rating of more than 200 

horsepower but not greater than 500 

horsepower. (42 U.S.C. 6311(13), 

6313(b)). The current standards for these 

motors, which are reproduced in the 

proposed regulatory text at the end of 

this notice, are divided into four tables 

that prescribe specific efficiency levels 

for each of those groups of motors. 

2. History of Standards Rulemaking for 

Electric Motors 

On October 5, 1999, DOE published in 

the Federal Register, a final rule to 

implement the EPACT 1992 electric 

motor requirements. 64 FR 54114. In 

response to EISA 2007, on March 23, 

2009, DOE updated, among other things, 

the corresponding electric motor 

regulations at 10 CFR part 431 with the 

new definitions and energy 

conservation standards. 74 FR 12058. 

On December 22, 2008, DOE proposed 

to update the test procedures under 10 

CFR part 431 both for electric motors 

and small electric motors. 73 FR 78220. 

DOE finalized key provisions related to 

small electric motor testing in a 2009 

final rule at 74 FR 32059 (July 7, 2009), 

and further updated the test procedures 

for electric motors and small electric 

motors at 77 FR 26608 (May 4, 2012). 

The May 2012 final rule primarily 

focused on updating various definitions 

and incorporations by reference related 

to the current test procedure. In that 

rule, DOE promulgated a regulatory 

definition of ‘‘electric motor’’ to account 

for EISA 2007’s removal of the previous 

statutory definition of ‘‘electric motor.’’ 

DOE also clarified definitions related to 

those motors that EISA 2007 laid out as 

part of EPCA’s statutory framework, 

including motor types that DOE had not 

previously regulated. See generally, id. 

at 26613–26619. DOE published a new 

proposed test procedure rulemaking on 

June 26, 2013, that proposes to further 

refine some existing electric motor 

definitions and add certain definitions 

and test procedure preparatory steps to 

address a wider variety of electric motor 

types than are currently regulated. 78 

FR 38456. 

Regarding the compliance date that 

would apply to the requirements of 

today’s proposed rule, EPCA directs the 

Secretary of Energy to publish a final 

rule no later than 24 months after the 

effective date of the previous final rule 

to determine whether to amend the 

standards in effect for such equipment. 

Any such amendment shall apply to 

electric motors manufactured after a 

date which is five years after: (i) The 

effective date of the previous 

amendment; or (ii) if the previous final 

rule did not amend the standards, the 

earliest date by which a previous 

amendment could have been effective. 

(42 U.S.C. 6313(b)(4)) 

As described previously, EISA 2007 

constitutes the most recent amendment 

to EPCA and energy conservation 

standards for electric motors. Because 

these amendments required compliance 

on December 19, 2010, DOE had 

indicated during the course of public 

meetings held in advance of today’s 

proposal that motors manufactured after 

December 19, 2015, would need to 

comply with any applicable new 

standards that DOE may set as part of 

this rulemaking. Today’s proposed 

standards would apply to motors 

manufactured starting on December 19, 

2015. As noted in detail later in this 

notice, however, DOE is interested in 

receiving comments on the ability of 

manufacturers to meet this deadline. 

DOE received numerous comments 

from interested parties who provided 

significant input to DOE in response to 

the framework document and 

preliminary analysis that the agency had 

issued. See 75 FR 59657 (Sept. 28, 2010) 

(framework document notice of 

availability) and 77 FR 43015 (July 23, 

2012) (preliminary analysis notice of 

availability). During the framework 

document comment period for this 

rulemaking, several interested parties 

urged DOE to consider including 

additional motor types currently 

without energy conservation standards 

in DOE’s analyses and establishing 

standards for such motor types. In the 

commenters’ view, this approach would 

more effectively increase energy savings 

than setting more stringent standards for 

currently regulated electric motors. In 

response, DOE published a Request for 

Information (RFI) seeking public 

comments from interested parties 

regarding establishment of energy 

conservation standards for several types 

of definite and special purpose motors 

for which EISA 2007 did not provide 

energy conservation standards. 76 FR 

17577 (March 30, 2011). DOE received 

comments responding to the RFI 

advocating that DOE regulate many of 

the electric motors discussed in the RFI, 

as well as many additional motor types. 

Then, on August 15, 2012, a group of 

interested parties (the ‘‘Motor 

Coalition’’ 12) submitted a Petition to 

DOE asking the agency to adopt a 

consensus stakeholder proposal that 

would amend the energy conservation 

standards for electric motors. The Motor 

Coalition’s proposal advocated 

expanding the scope of coverage to a 

broader range of motors than what DOE 

currently regulates and it recommended 

that energy conservation standards for 

all covered electric motors be set at 

levels that are largely equivalent to what 

DOE proposes in today’s NOPR (i.e., 

efficiency levels in NEMA MG1–2011 

Tables 12–12 and 20–B).13

DOE received several comments from 

NEMA regarding the December 19, 

2015, compliance date. First, NEMA 

pointed out that all publications and 

presentations prior to that preliminary 

analysis public meeting on August 21, 

2012, indicated that DOE’s statutory 

deadline for any final rule was 

December 19, 2012, but at the public 

meeting DOE showed a final rule 

completion date as the end of 2013. 

(NEMA, No. 54 at pp. 2, 6–7) NEMA 

questioned the authority by which DOE 

has decided to delay the Final Rule 

beyond the date of December 19, 2012, 

as stipulated in EPCA. (NEMA, No. 54 

at p. 2) 

Second, NEMA commented that 

shortening the time to comply with any 

new standards from three years to two 

years would place additional burdens 

on manufacturers considering all of the 

electric motors types that DOE is 

considering in the preliminary TSD, the 

burdensome candidate standard levels 

that DOE is considering, and the 

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14The Petition is available at: http://

www.regulations.gov/#!documentDetail;D=EERE2010-BT-STD-0027-0035. 

possibility of expanding the scope of 

energy conservation standards. (NEMA, 

No. 54 at pp. 2, 7; NEMA, Public 

Meeting Transcript, No. 60 at p. 30) 

Third, NEMA also noted that when 

EPACT 1992 first added electric motors 

as covered equipment, motor 

manufacturers were allowed five years 

to modify motor designs and certify 

compliance to the new standards. 

(NEMA, No. 54 at p. 7) It further noted 

that NEMA MG 1–1998 subsequently 

introduced NEMA Premium efficiency 

standards, and between 1998 and 2007 

manufacturers voluntarily increased the 

number of NEMA Premium efficiency 

motor models available. (NEMA, No. 54 

at p. 7) NEMA commented that this 

transition period eased the burden of 

satisfying the added stringency of the 

standards set by EISA 2007, which 

allowed three years to update energy 

conservation standards to mandatory 

NEMA Premium levels for certain motor 

ratings. (NEMA, No. 54 at p. 7) NEMA 

added that adhering to the statutory 

deadline for setting any new and 

amended standards would minimize 

any disruption in the electric motor 

market. (NEMA, No. 54 at p. 8) NEMA 

also commented that since the EISA 

2007 standards were enacted, only a 

limited number of motor ratings above 

NEMA Premium have been offered 

because there is not sufficient space 

available in most frame ratings to 

increase the efficiency. (NEMA, No. 54 

at p. 7) NEMA added that any standards 

above NEMA Premium would force 

manufacturers to redesign entire 

product lines and go through the 

process of certification and compliance, 

all of which would be expected to take 

longer than three years. (NEMA, No. 54 

at pp. 7, 8) 

Finally, NEMA also attempted to 

illustrate the difficulty of reaching 

NEMA Premium levels in IEC frame 

motors, noting that a comparison of 

certificates of compliance before and 

after EISA 2007 standards went into 

effect would demonstrate that some 

manufacturers were forced to abandon 

the U.S. electric motor market for some 

period of time before they could update 

their IEC frame motor product line. 

(NEMA, No. 54 at p. 8) NEMA added 

that increasing the efficiency of subtype 

II motors to NEMA Premium efficiency 

and expanding the scope of motors 

subject to energy conservation standards 

(many of which currently have 

efficiency levels below EPACT 1992 

energy conservation levels) will also 

require extensive redesign, and 

manufacturers would be forced to 

comply in only three years. (NEMA, No. 

54 at p. 8) 

During the course of preparing for the 

electric motors energy conservation 

standards rulemaking, information was 

submitted to DOE by NEMA, ASAP, and 

CDA in response to DOE’s RFI and then 

later in the Petition from the Motors 

Coalition 14 that caused DOE to 

reevaluate the scope of electric motors 

it was considering in this rulemaking. 

That Petition, and related supporting 

information, suggested that DOE apply 

the NEMA Premium efficiency levels 

(‘‘NEMA Premium’’) to a much broader 

swath of electric motors than are 

currently regulated by DOE, rather than 

increase the stringency of the standards 

that had only recently come into effect 

(i.e., EISA 2007 standards). As part of its 

routine practice, DOE reviewed the 

information and the merits of the 

Petition. With the potential prospect of 

expanding the types of motors that 

would be regulated by standards, DOE 

recognized the need to amend its test 

procedures to add the necessary testing 

preparatory steps (i.e. test set-up 

procedures) to DOE’s regulations. The 

inclusion of these steps would help 

ensure that manufacturers of these new 

motor types would be performing the 

same steps as are performed when 

testing currently regulated motors. 

The compliance date prescribed by 

statute would require manufacturers to 

begin manufacturing compliant motors 

by December 19, 2015. Accordingly, 

DOE is proposing a December 19, 2015, 

compliance date. DOE, however, 

recognizes that the statute also 

contemplated a three-year lead time for 

manufacturers in order to account for 

the potential logistical and production 

hurdles that manufacturers may face 

when transitioning to the new 

standards. Accordingly, while DOE is 

proposing a December 19, 2015 

compliance deadline, it is also 

interested in comments that detail any 

hurdles with meeting this compliance 

deadline along with the merits of 

receiving the three-year lead-time also 

set out in the statute. 

3. Process for Setting Energy 

Conservation Standards 

Section 325(o) provides criteria for 

prescribing new or amended standards 

which are designed to achieve the 

maximum improvement in energy 

efficiency and for which the Secretary of 

Energy determines are technologically 

feasible and economically justified. 

Consequently, DOE must consider, to 

the greatest extent practicable, the 

following seven factors: (1) The 

economic impact of the standard on the 

manufacturers and consumers of the 

products subject to the standard; (2) the 

savings in operating costs throughout 

the estimated average life of the 

products compared to any increase in 

the prices, initial costs, or maintenance 

expenses for the products that are likely 

to result from the imposition of the 

standard; (3) the total projected amount 

of energy 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 conservation; and (7) other 

factors the Secretary considers relevant. 

(42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) 

Other statutory requirements are set 

forth in 42 U.S.C. 6295(o)(1)–(2)(A), 

(2)(B)(ii)–(iii), and (3)–(4). These criteria 

apply to the setting of standards for 

electric motors through 42 U.S.C. 

6316(a). 

III. General Discussion 

DOE developed today’s proposed rule 

after considering input, including verbal 

and written comments, data, and 

information from interested parties that 

represent a variety of interests. All 

commenters, along with their 

corresponding abbreviations and 

affiliations, are listed in Table III.1 

below. The issues raised by these 

commenters are addressed in the 

discussions that follow. 

TABLE III.1—SUMMARY OF COMMENTERS

Company or organization Abbreviation Affiliation 

Air Movement and Control Association International, Inc.AMCAI ........................ Trade Association. 

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TABLE III.1—SUMMARY OF COMMENTERS—Continued 

Company or organization Abbreviation Affiliation 

Alliance to Save Energy ................................. ASE ............................ Energy Efficiency Advocates. 

American Council for an 

Energy-Efficient Economy. 

ACEEE ....................... Energy Efficiency Advocates. 

Appliance Standards Awareness Project ....... ASAP ......................... Energy Efficiency Advocates. 

Baldor Electric Co. .......................................... Baldor ......................... Manufacturers. 

BBF & Associates ........................................... BBF ............................ Representative for Trade Association.

California Investor Owned Utilities ................. CA IOUs ..................... Utilities. 

Copper Development Association .................. CDA ........................... Trade Association. 

Earthjustice ..................................................... Earthjustice ................ Energy Efficiency Advocates. 

Electric Apparatus Service Association .......... EASA ......................... Trade Association. 

Flolo Corporation ............................................ Flolo ........................... Other. 

Industrial Energy Consumers of America ....... IECA ........................... Trade Association. 

Motor Coalition * .............................................. MC ............................. Energy Efficiency Advocates, Trade Associations, Manufacturers, Utilities. 

National Electrical Manufacturers Association NEMA ......................... Trade Association. 

Northwest Energy Efficiency Alliance ............. NEEA ......................... Energy Efficiency Advocates. 

Northwest Power & Conservation Council ..... NPCC ......................... Utilities. 

SEW-Eurodrive, Inc. ....................................... SEWE ........................ Manufacturer. 

UL LLC ............................................................ UL .............................. Testing Laboratory. 

* The members of the Motor Coalition include: National Electrical Manufacturers Association (NEMA), American Council for an Energy-Efficient 

Economy (ACEEE), Appliance Standards Awareness Project (ASAP), Alliance to Save Energy (ASE), Earthjustice, Natural Resources Defense 

Council (NRDC), Northwest Energy Efficiency Alliance (NEEA), Northeast Energy Efficiency Partnerships (NEEP), and Northwest Power and 

Conservation Council (NPCC). 

Subsequent to DOE’s preliminary 

analysis public meeting, several other 

interested parties submitted comments 

supporting the Petition. Those 

supporters included: BBF and 

Associates, the Air Movement and 

Control Association International, Inc., 

U.S. Senators Lisa Murkowski and Jeff 

Bingaman, the Hydraulic Institute, the 

Arkansas Economic Development and 

Commission-Energy Office, and the 

Power Transmission Distributors 

Association. 

A. Test Procedure 

On June 26, 2013, DOE published a 

notice that proposed to incorporate 

definitions for certain motor types not 

currently subject to energy conservation 

standards (78 FR 38456). The notice also 

proposed to clarify several definitions 

for motor types currently regulated by 

energy conservation standards and 

adding some necessary steps to facilitate 

the testing of certain motor types that 

DOE does not currently require to meet 

standards. During its preliminary 

analysis stage, DOE received comments 

concerning definitions and test 

procedure set-up steps suggested for 

testing motors under an expanded scope 

approach. DOE addressed the comments 

as part of the test procedure NOPR. For 

additional details, see 78 FR 38456 

(June 26, 2013). 

B. Equipment Classes and Current 

Scope of Coverage 

When evaluating and establishing 

energy conservation standards, DOE 

divides covered equipment into 

equipment classes by the type of energy 

used or by capacity or other 

performance-related features that would 

justify a different standard. In making a 

determination whether a performancerelated feature would justify a different 

standard, DOE must consider factors 

such as the utility to the consumer of 

the feature and other factors that DOE 

determines are appropriate. (42 U.S.C. 

6295(q) and 6316(a)) 

Existing energy conservation 

standards cover electric motors that fall 

into four categories based on physical 

design features of the motor. These four 

categories are: General purpose electric 

motors (subtype I), general purpose 

electric motors (subtype II), fire pump 

electric motors, and NEMA Design B 

motors (with a horsepower rating from 

201 through 500). Definitions for each of 

these terms can be found at 10 CFR 

431.12. 

C. Expanded Scope of Coverage 

DOE has the authority to set energy 

conservation standards for a wider range 

of electric motors than those classified 

as general purpose electric motors (e.g., 

definite or special purpose motors). 

EPACT 1992 amended EPCA to include, 

among other things, a definition for the 

term ‘‘electric motor’’—which the 

statute defined as including certain 

‘‘general purpose’’ motors. (42 U.S.C. 

6311(13)(A) (1992)) The amendments 

also defined the terms ‘‘definite purpose 

motors’’ and ‘‘special purpose motor.’’ 

(42 U.S.C. 6311(13)(C) and (D)) (1992)) 

EPACT 1992 initially prescribed energy 

conservation standards for ‘‘electric 

motors’’ (i.e., subtype I general purpose 

electric motors) and explicitly stated 

that these standards did not apply to 

definite purpose or special purpose 

motors. (42 U.S.C. 6313(b)(1) (1992)) 

However, EISA 2007 struck the narrow 

EPACT 1992 definition of ‘‘electric 

motor.’’ With the removal of this 

definition, the term ‘‘electric motor’’ 

became broader in scope. As a result of 

these changes, both definite and special 

purpose motors fell under the broad 

heading of ‘‘electric motors’’ that 

previously only applied to ‘‘general 

purpose’’ motors. While EISA 2007 

prescribed standards for general 

purpose motors, the Act did not apply 

those standards to definite or special 

purpose motors. (42 U.S.C. 6313(b) 

(2012)) 

Although DOE believes that EPCA, as 

amended through EISA 2007, provides 

sufficient statutory authority for the 

regulation of special purpose and 

definite purpose motors as ‘‘electric 

motors,’’ DOE notes it has additional 

authority under section 10 of the 

American Energy Manufacturing 

Technical Corrections Act, Public Law 

112–210, which amended DOE’s 

authority to regulate commercial and 

industrial equipment under section 

340(2)(B) of EPCA to include ‘‘other 

motors,’’ in addition to ‘‘electric 

motors’’. (42 U.S.C. 6311(2)(B)(xiii)). 

Therefore, even if special and definite 

purpose motors were not ‘‘electric 

motors,’’ special and definite purpose 

motors would be considered as ‘‘other 

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15EPCA specifies the types of industrial 

equipment that can be classified as covered in 

addition to the equipment enumerated in 42 U.S.C. 

6311(1). This equipment includes ‘‘other motors’’ 

(to be codified at 42 U.S.C. 6311(2)(B)). Industrial 

equipment must also, without regard to whether 

such equipment is in fact distributed in commerce 

for industrial or commercial use, be of a type that: 

(1) In operation consumes, or is designed to 

consume, energy in operation; (2) to any significant 

extent, is distributed in commerce for industrial or 

commercial use; and (3) is not a covered product 

as defined in 42 U.S.C. 6291(a)(2) of EPCA, other 

than a component of a covered product with respect 

to which there is in effect a determination under 42 

U.S.C. 6312(c). (42 U.S.C. 6311 (2)(A)). Data from 

the 2002 United States Industrial Electric Motor 

Systems Market Opportunities Assessment 

estimated total energy use from industrial motor 

systems to be 747 billion kWh. Based on the 

expansion of industrial activity, it is likely that 

current annual electric motor energy use is higher 

than this figure. Electric motors are distributed in 

commerce for both the industrial and commercial 

sectors. According to data provided by the Motor 

Coalition, the number of electric motors 

manufactured in, or imported into, the United 

States is over five million electric motors annually, 

including special and definite purpose motors. 

Finally, special and definite purpose motors are not 

currently regulated under Title 10 of the Code of 

Federal Regulations, part 430 (10 CFR part 430). 

To classify equipment as covered commercial or 

industrial equipment, the Secretary must also 

determine that classifying the equipment as covered 

equipment is necessary for the purposes of Part A– 

1 of EPCA. The purpose of Part A–1 is to improve 

the efficiency of electric motors, pumps and certain 

other industrial equipment to conserve the energy 

resources of the nation. (42 U.S.C. 6312(a)–(b)) In 

today’s proposal, DOE has tentatively determined 

that the regulation of special and definite purpose 

motors is necessary to carry out the purposes of part 

A–1 of EPCA because regulating these motors will 

promote the conservation of energy supplies. 

Efficiency standards that may result from coverage 

would help to capture some portion of the potential 

for improving the efficiency of special and definite 

purpose motors. 

16The preliminary TSD published in July 2012 is 

available at: http://www.regulations.gov/

#!documentDetail;D=EERE-2010-BT-STD-0027- 

0023. 

motors’’ that EPCA already treats as 

covered industrial equipment.15

Consistent with EISA 2007’s 

reworking of the definition, the 2012 

test procedure final rule broadly defined 

the term ‘‘electric motor.’’ at 10 CFR 

431.12. (77 FR 26608 (May 4, 2012)). 

That definition covers ‘‘general 

purpose,’’ ‘‘special purpose’’ and 

‘‘definite purpose’’ electric motors (as 

defined by EPCA). As noted above, 

EPCA did not require either ‘‘special 

purpose’’ or ‘‘definite purpose’’ motor 

types to meet energy conservation 

standards because they were not 

considered ‘‘general purpose’’ under the 

EPCA definition of ‘‘general purpose 

motor’’—a necessary element to meet 

the pre-EISA 2007 ‘‘electric motor’’ 

definition. See 77 FR 26612. Because of 

the restrictive nature of the prior electric 

motor definition, along with the 

restrictive definition of the term 

‘‘industrial equipment,’’ DOE would 

have been unable to set standards for 

such motors without this change. (See 

42 U.S.C. 6311(2)(B) (2006) (limiting the 

scope of equipment covered under 

EPCA)) In view of the changes 

introduced by EISA 2007 and the 

absence of energy conservation 

standards for special purpose and 

definite purpose motors, as noted in 

chapter 2 of DOE’s July 2012 electric 

motors preliminary analysis technical 

support document (TSD),16 it is DOE’s 

view that both of these motors are 

categories of ‘‘electric motors’’ covered 

under EPCA, as currently amended. 

Accordingly, DOE is proposing 

standards for certain definite purpose 

and special purpose motors. To this 

end, DOE is considering setting energy 

conservation standards for those motors 

that exhibit all of the following nine 

characteristics: 

• Is a single-speed, induction motor, 

• Is rated for continuous duty (MG 1) 

operation or for duty type S1 (IEC), 

• Contains a squirrel-cage (MG 1) or 

cage (IEC) rotor, 

• Operates on polyphase alternating 

current 60-hertz sinusoidal line power, 

• Is rated 600 volts or less, 

• Has a 2-, 4-, 6-, or 8-pole 

configuration, 

• Has a three-digit NEMA frame size 

(or IEC metric equivalent) or an 

enclosed 56 NEMA frame size (or IEC 

metric equivalent), 

• Has no more than 500 horsepower, 

but greater than or equal to 1 

horsepower (or kilowatt equivalent), 

and 

• Meets all of the performance 

requirements of a NEMA Design A, B, or 

C electric motor or an IEC design N or 

H electric motor. 

However, motor types that exhibit all 

of the characteristics listed above, but 

that DOE does not believe should be 

subject to energy conservation standards 

at this time because of the current 

absence of a reliable and repeatable 

method to test them for efficiency, 

would be listed as motors that would 

not at this time be subject to energy 

conservation standards. Once a test 

procedure becomes available, DOE may 

consider setting standards for these 

motors at that time. See generally, 78 FR 

38456 (June 26, 2013). DOE requests 

comment on these nine characteristics 

and their appropriateness for outlining 

scope of coverage. 

To facilitate the potential application 

of energy conservation standards to 

special and definite purpose motors, 

DOE proposed to define such motors 

and provide certain preparatory test 

procedure steps. 78 FR 38456 (June 26, 

2013). The definitions under 

consideration would address motors 

currently subject to standards, specific 

motors DOE is considering requiring to 

meet standards, and some motors that 

will continue to not be required to meet 

particular energy conservation 

standards. Some of the clarifying 

definitions, such as the definitions for 

NEMA Design A and C electric motors, 

come from NEMA Standards 

Publication MG 1–2009, ‘‘Motors and 

Generators.’’ DOE understands that 

some of the motors addressed, such as 

partial motors and integral brake 

motors, do not have standard industryaccepted definitions. For such motor 

types, DOE worked with subject-matter 

experts (SMEs), manufacturers, and the 

Motor Coalition to create the working 

definitions that are proposed in the test 

procedure NOPR. (8 FR 38456 (June 26, 

2013). 

D. Technological Feasibility 

1. General 

EPCA requires that any new or 

amended energy conservation standard 

that DOE prescribes shall be designed to 

achieve the maximum improvement in 

energy efficiency that DOE determines 

is technologically feasible. (42 U.S.C. 

6295(o)(2)(A) and 6316(a)). In each 

standards rulemaking, DOE conducts a 

screening analysis based on information 

gathered on all current technology 

options and prototype designs that 

could improve the efficiency of the 

products or equipment that are the 

subject of the rulemaking. As the first 

step in such an analysis, DOE develops 

a list of technology options for 

consideration in consultation with 

manufacturers, design engineers, and 

other interested parties. DOE then 

determines which of those means for 

improving efficiency are technologically 

feasible. 

Where DOE determines that particular 

technology options are technologically 

feasible, it further evaluates each 

technology option in view of the 

following additional screening criteria: 

(1) Practicability to manufacture, install, 

or service; (2) adverse impacts on 

product utility or availability; and (3) 

adverse impacts on health or safety. 

Section IV.B of this notice addresses the 

results of the screening analysis for 

electric motors, particularly the designs 

DOE considered—those it screened out, 

and those that are the basis for the trial 

standard levels (TSLs) in this 

rulemaking. For further details on the 

screening analysis for this rulemaking, 

see chapter 4 of the NOPR TSD. 

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17 In the past DOE, presented energy savings 

results for only the 30-year period that begins in the 

year of compliance. In the calculation of economic 

impacts, however, DOE considered operating cost 

savings measured over the entire lifetime of 

equipment purchased in the 30-year period. DOE 

has chosen to modify its presentation of national 

energy savings to be consistent with the approach 

used for its national economic analysis. 

18 ‘‘Review of Site (Point-of-Use) and Full-FuelCycle Measurement Approaches to DOE/EERE 

Building Appliance Energy-Efficiency Standards,’’ 

(Academy report) was completed in May 2009 and 

included five recommendations. A copy of the 

study can be downloaded at: http://www.nap.edu/ 

catalog.php?record_id=12670. 

19 DOE also presents a sensitivity analysis that 

considers impacts for products shipped in a 9-year 

period. 

2. Maximum Technologically Feasible 

Levels 

When DOE proposes to adopt a new 

or amended standard for a type or class 

of covered product, it must determine 

the maximum improvement in energy 

efficiency or maximum reduction in 

energy use that is technologically 

feasible for such product. (42 U.S.C. 

6295(p)(1)) This requirement also 

applies to DOE proposals to amend the 

standards for electric motors. See 42 

U.S.C. 6316(a). Accordingly, in its 

engineering analysis, DOE determined 

the maximum technologically feasible 

(‘‘max-tech’’) improvements in energy 

efficiency for electric motors, using the 

design parameters for the most efficient 

motors available on the market or in 

working prototypes. (See chapter 5 of 

the NOPR TSD.) The max-tech levels 

that DOE determined for this 

rulemaking are described in section 

IV.C.3 of this proposed rule. 

E. Energy Savings 

1. Determination of Savings 

Section 325(o) of EPCA also provides 

that any new or amended energy 

conservation standard that DOE 

prescribes shall be designed to achieve 

the maximum improvement in energy 

efficiency that DOE determines is 

economically justified. (42 U.S.C. 

6295(o)(2)(A)–(B) and 6316(a)). In 

addition, in determining whether such 

standard is technologically feasible and 

economically justified, DOE may not 

prescribe standards for certain types or 

classes of electric motors if such 

standards would not result in significant 

energy savings. (42 U.S.C. 6295(o)(3)(B) 

and 6316(a)). For each TSL, DOE 

projected energy savings from the 

motors that would be covered under this 

rulemaking and that would be 

purchased in the 30-year period that 

begins in the year of compliance with 

the new and amended standards (2015– 

2044). The savings are measured over 

the entire lifetime of equipment 

purchased in the 30-year period.17 DOE 

quantified the energy savings 

attributable to each TSL as the 

difference in energy consumption 

between each standards case and the 

base case. The base case represents a 

projection of energy consumption in the 

absence of new or amended mandatory 

efficiency standards, and considers 

market forces and policies that affect 

demand for more efficient equipment. 

DOE used its national impact analysis 

(NIA) spreadsheet model to estimate the 

energy savings from new and amended 

standards for the equipment that would 

be subject to this rulemaking. The NIA 

spreadsheet model (described in section 

IV.H of this notice) calculates energy 

savings in site energy, which is the 

energy directly consumed by motors at 

the locations where they are used. For 

electricity, DOE reports national energy 

savings in terms of the savings in the 

energy that is used to generate and 

transmit the site electricity. To calculate 

source energy, DOE derives annual 

conversion factors from the model used 

to prepare the Energy Information 

Administration’s (EIA) Annual Energy 

Outlook (AEO). 

DOE has begun to also estimate fullfuel-cycle energy savings. 76 FR 51282 

(August 18, 2011), as amended at 77 FR 

49701 (August 17, 2012). The full-fuelcycle (FFC) metric includes the energy 

consumed in extracting, processing, and 

transporting primary fuels, and thus 

presents a more complete picture of the 

impacts of energy efficiency standards. 

DOE’s evaluation of FFC savings is 

driven in part by the National Academy 

of Science’s (NAS) report on FFC 

measurement approaches for DOE’s 

Appliance Standards Program.18 The 

NAS report discusses that FFC was 

primarily intended for energy efficiency 

standards rulemakings where multiple 

fuels may be used by a particular 

product. In the case of this rulemaking 

pertaining to electric motors, only a 

single fuel—electricity—is consumed by 

the equipment. DOE’s approach is based 

on the calculation of an FFC multiplier 

for each of the energy types used by 

covered equipment. The methodology 

for estimating FFC does not project how 

fuel markets would respond to this 

particular standard rulemaking. The 

FFC methodology simply estimates how 

much additional energy, and in turn 

how many tons of emissions, may be 

displaced if the estimated fuel were not 

consumed by the equipment covered in 

this rulemaking. It is also important to 

note that inclusion of FFC savings does 

not affect DOE’s choice of proposed 

standards. 

2. Significance of Savings 

As noted above, 42 U.S.C. 

6295(o)(3)(B) prevents DOE from 

adopting a standard for a covered 

product unless such standard would 

result in ‘‘significant’’ energy savings. 

Although the term ‘‘significant’’ is not 

explicitly defined in EPCA, the U.S. 

Court of Appeals, in Natural Resources 

Defense Council v. Herrington, 768 F.2d 

1355, 1373 (D.C. Cir. 1985), indicated 

that Congress intended ‘‘significant’’ 

energy savings in this context to be 

savings that were not ‘‘genuinely 

trivial.’’ DOE believes that the energy 

savings for all of the TSLs considered in 

this rulemaking (presented in section 

V.A) are nontrivial, and, therefore, DOE 

considers them ‘‘significant’’ within the 

meaning of section 325 of EPCA. 

F. Economic Justification 

1. Specific Criteria 

EPCA provides seven factors to be 

evaluated in determining whether a 

potential energy conservation standard 

is economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)) The following sections 

detail how DOE addresses each of those 

factors in this rulemaking. 

a. Economic Impact on Manufacturers 

and Consumers 

In determining the impacts of a new 

or amended standard on manufacturers, 

DOE first uses an annual cash-flow 

approach to determine the quantitative 

impacts. This step includes both a shortterm assessment—based on the cost and 

capital requirements during the period 

between when a regulation is issued and 

when entities must comply with the 

regulation—and a long-term assessment 

over a 30-year period.19 The industrywide impacts analyzed include industry 

net present value (INPV), which values 

the industry on the basis of expected 

future cash flows; cash flows by year; 

changes in revenue and income; and 

other measures of impact, as 

appropriate. Second, DOE analyzes and 

reports the impacts on different types of 

manufacturers, including impacts on 

small manufacturers. Third, DOE 

considers the impact of standards on 

domestic manufacturer employment and 

manufacturing capacity, as well as the 

potential for standards to result in plant 

closures and loss of capital investment. 

Finally, DOE takes into account 

cumulative impacts of various DOE 

regulations and other regulatory 

requirements on manufacturers. 

For individual consumers, measures 

of economic impact include the changes 

in life-cycle cost (LCC) and payback 

period (PBP) associated with new or 

amended standards. The LCC, addressed 

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as ‘‘savings in operating costs’’ at 42 

U.S.C. 6295(o)(2)(B)(i)(II), is one of 

seven factors considered in determining 

the economic justification for a new or 

amended standard and is discussed in 

the following section. For consumers in 

the aggregate, DOE also calculates the 

national net present value of the 

economic impacts applicable to a 

particular rulemaking. 

b. Life-Cycle Costs 

The LCC is the sum of the purchase 

price of a piece of equipment (including 

its installation) and the operating 

expense (including energy, 

maintenance, and repair expenditures) 

discounted over the lifetime of that 

equipment. The LCC savings for the 

considered efficiency levels are 

calculated relative to a base case that 

reflects projected market trends in the 

absence of new or amended standards. 

The LCC analysis requires a variety of 

inputs, such as equipment prices, 

equipment energy consumption, energy 

prices, maintenance and repair costs, 

equipment lifetime, and consumer 

discount rates. For its analysis, DOE 

assumes that consumers, as users of 

electric motors, will purchase the 

considered equipment in the first year 

of compliance with new or amended 

standards. 

To account for uncertainty and 

variability in specific inputs, such as 

equipment lifetime and discount rate, 

DOE uses a distribution of values with 

probabilities attached to each value. 

DOE identifies the percentage of 

consumers estimated to receive LCC 

savings or experience an LCC increase, 

in addition to the average LCC savings 

associated with a particular standard 

level. DOE also evaluates the LCC 

impacts of potential standards on 

identifiable subgroups of consumers 

that may be affected disproportionately 

by a national standard. 

c. Energy Savings 

Although significant conservation of 

energy is a separate statutory 

requirement for imposing an energy 

conservation standard, EPCA requires 

DOE, in determining the economic 

justification of a standard, to consider 

the total projected energy savings that 

are expected to result directly from the 

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

As discussed in section IV.H, DOE uses 

the NIA spreadsheet to project national 

energy savings. 

d. Lessening of Utility or Performance 

In establishing classes of products, 

and in evaluating design options and 

the impact of potential standard levels, 

DOE evaluates standards that would not 

lessen the utility or performance of the 

considered products. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) As noted earlier, the 

substance of this provision applies to 

the equipment at issue in today’s 

proposal as well. DOE has determined 

that the standards proposed in today’s 

notice will not reduce the utility or 

performance of the equipment under 

consideration in this rulemaking. One 

piece of evidence for this claim includes 

the fact that many motors are already 

commonly being sold at the proposed 

levels (NEMA’s ‘‘Premium’’ 

designation). A second piece of 

evidence is that the proposed standards 

closely track the recommendations of 

NEMA, which represents manufacturers 

who understand deeply the design 

compromises entailed in reaching 

higher efficiencies and who would be 

acting against the interest of their 

customers in recommending standards 

that would harm performance or utility. 

e. Impact of Any Lessening of 

Competition 

EPCA directs DOE to consider the 

impact of any lessening of competition, 

as determined in writing by the 

Attorney General, that is likely to result 

from the imposition of a standard. (42 

U.S.C. 6295(o)(2)(B)(i)(V). It also directs 

the Attorney General to determine the 

impact, if any, of any lessening of 

competition likely to result from a 

proposed standard and to transmit such 

determination to the Secretary of Energy 

within 60 days of the publication of a 

proposed rule, together with an analysis 

of the nature and extent of the impact. 

(42 U.S.C. 6295(o)(2)(B)(ii)) DOE will 

transmit a copy of today’s proposed rule 

to the Attorney General with a request 

that the Department of Justice (DOJ) 

provide its determination on this issue. 

DOE will address the Attorney General’s 

determination in the final rule. 

f. Need for National Energy 

Conservation 

The energy savings from the proposed 

standards are likely to provide 

improvements to the security and 

reliability of the Nation’s energy system. 

Reductions in the demand for electricity 

also may result in reduced costs for 

maintaining the reliability of the 

Nation’s electricity system. DOE 

conducts a utility impact analysis to 

estimate how standards may affect the 

Nation’s needed power generation 

capacity. 

The proposed standards also are 

likely to result in environmental 

benefits in the form of reduced 

emissions of air pollutants and 

greenhouse gases associated with energy 

production. DOE reports the emissions 

impacts from today’s standards, and 

from each TSL it considered, in section 

V.B.4 of this notice. DOE also reports 

estimates of the economic value of 

emissions reductions resulting from the 

considered TSLs. 

g. Other Factors 

EPCA allows the Secretary of Energy, 

in determining whether a standard is 

economically justified, to consider any 

other factors that the Secretary deems to 

be relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(VII)) 

2. Rebuttable Presumption 

As set forth in 42 U.S.C. 

6295(o)(2)(B)(iii), EPCA creates a 

rebuttable presumption that an energy 

conservation standard is economically 

justified if the additional cost to the 

consumer of a product that meets the 

standard is less than three times the 

value of the first year’s energy savings 

resulting from the standard, as 

calculated under the applicable DOE 

test procedure. DOE’s LCC and PBP 

analyses generate values used to 

calculate the effects that proposed 

energy conservation standards would 

have on the payback period for 

consumers. These analyses include, but 

are not limited to, the three-year 

payback period contemplated under the 

rebuttable-presumption test. In addition, 

DOE routinely conducts an economic 

analysis that considers the full range of 

impacts to consumers, manufacturers, 

the Nation, and the environment, as 

required under 42 U.S.C. 

6295(o)(2)(B)(i). The results of this 

analysis serve as the basis for DOE’s 

evaluation of the economic justification 

for a potential standard level (thereby 

supporting or rebutting the results of 

any preliminary determination of 

economic justification). The rebuttable 

presumption payback calculation is 

discussed in section IV.F.12 of this 

proposed rule. 

IV. Methodology and Discussion of 

Related Comments 

DOE used four spreadsheet tools to 

estimate the impact of today’s proposed 

standards. The first spreadsheet 

calculates LCCs and PBPs of potential 

new energy conservation standards. The 

second provides shipments forecasts 

and the third calculates national energy 

savings and net present value impacts of 

potential new energy conservation 

standards. The fourth tool helps assess 

manufacturer impacts, largely through 

use of the Government Regulatory 

Impact Model (GRIM). 

Additionally, DOE estimated the 

impacts of energy conservation 

standards for electric motors on utilities 

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20BT stands for DOE’s Building Technologies 

Program. 21The EIA allows the use of the name ‘‘NEMS’’ 

to describe only an AEO version of the model 

without any modification to code or data. Because 

the present analysis entails some minor code 

modifications and runs the model under various 

policy scenarios that deviate from AEO 

assumptions, the name ‘‘NEMS–BT’’ refers to the 

model as used here. For more information on 

NEMS, refer to The National Energy Modeling 

System: An Overview, DOE/EIA–0581 (98) (Feb. 

1998), available at: http://tonto.eia.doe.gov/

FTPROOT/forecasting/058198.pdf. 

22The efficiency levels found in Table 12–12 are 

the more stringent of the two sets of efficiency 

tables. 

23For the purposes of determining compliance, 

DOE assesses a motors horsepower rating according 

to the provisions of 10 CFR 431.25(e). 

24The Petition is available at: http://

www.regulations.gov/#!documentDetail;D=EERE2010-BT-STD-0027-0035. 

and the environment. DOE used a 

version of EIA’s National Energy 

Modeling System (NEMS) for the utility 

and environmental analyses. The NEMS 

model simulates the energy sector of the 

U.S. economy. EIA uses NEMS to 

prepare its Annual Energy Outlook 

(AEO), a widely known energy forecast 

for the United States. The version of 

NEMS used for appliance standards 

analysis is called NEMS–BT20 and is 

based on the AEO version with minor 

modifications.21 The NEMS–BT model 

offers a sophisticated picture of the 

effect of standards because it accounts 

for the interactions between the various 

energy supply and demand sectors and 

the economy as a whole. 

A. Market and Technology Assessment 

For the market and technology 

assessment, DOE develops information 

that provides an overall picture of the 

market for the equipment concerned, 

including the purpose of the equipment, 

the industry structure, and market 

characteristics. This activity includes 

both quantitative and qualitative 

assessments, based primarily on 

publicly available information. The 

subjects addressed in the market and 

technology assessment for this 

rulemaking include scope of coverage, 

equipment classes, types of equipment 

sold and offered for sale, and technology 

options that could improve the energy 

efficiency of the equipment under 

examination. Chapter 3 of the TSD 

contains additional discussion of the 

market and technology assessment. 

1. Current Scope of Electric Motors 

Energy Conservation Standards 

EISA 2007 amended EPCA to 

prescribe energy conservation standards 

for four categories of electric motors: 

General purpose electric motors 

(subtype I) (hereinafter, ‘‘subtype I’’), 

general purpose electric motors (subtype 

II) (hereinafter, ‘‘subtype II’’), fire pump 

electric motors, and NEMA Design B, 

general purpose electric motors that also 

meet the subtype I or subtype II 

definitions and are rated above 200 

horsepower through 500 horsepower. 

DOE’s most recent test procedure final 

rule added clarity to the definitions for 

each of these motor categories, which 

are now codified at 10 CFR 431.12. 77 

FR 26608. 

Although DOE is not proposing to 

modify these definitions, commenters 

sought additional clarifications. During 

the preliminary analysis public meeting, 

NEMA expressed confusion regarding 

whether IEC frame motors would fall 

under the subtype I or subtype II 

designation, as DOE defined them to be 

related to both definitions. NEMA 

added that because subtype I and 

subtype II electric motors are subject to 

different efficiency standards, 

manufacturers producing IEC frame 

motors are confused as to whether IEC 

frame motors are subject to NEMA MG 

1 Table 12–11 or Table 12–12 efficiency 

standards.22 (NEMA, Public Meeting 

Transcript, No. 60 at pp. 36, 37) 

DOE understands that an IEC frame 

motor could be treated as either a 

subtype I or subtype II motor depending 

on its other characteristics. Having an 

IEC frame alone does not dictate 

whether a motor is a general purpose 

subtype I or subtype II motor; rather, 

other physical characteristics, such as 

equivalency to a NEMA Design A, B, or 

C electric motor, and whether it has 

mounting feet could determine the 

subtype designation and associated 

energy efficiency standard level. All of 

these elements flow directly from the 

statutory changes enacted by EISA 2007. 

(See EISA 2007, sec. 313(a)(3), codified 

at 42 U.S.C. 6311(13)) Currently, electric 

motors are required to meet energy 

conservation standards as follows: 

TABLE IV.1—CURRENT ELECTRIC MOTOR ENERGY CONSERVATION STANDARDS 23

Electric motor category Horsepower range Energy conservation standard level 

General Purpose Electric Motors (Subtype I) ................................................ 1 to 200 (inclusive) ............................ MG 1–2011 Table 12–12. 

General Purpose Electric Motors (Subtype II) ............................................... 1 to 200 (inclusive) ............................ MG 1–2011 Table 12–11. 

NEMA Design B and ......................................................................................

IEC Design N Motors .....................................................................................

201 to 500 (inclusive) ........................ MG 1–2011 Table 12–11. 

Fire Pump Electric Motors .............................................................................. 1 to 500 (inclusive) ............................ MG 1–2011 Table 12–11. 

Additionally, NEMA requested 

clarification on the terminology DOE 

intends to use for NEMA Design B 

motors, namely whether the term is 

‘‘NEMA Design B motor’’ or ‘‘NEMA 

Design B electric motor’’ and what, if 

any, differences there are between the 

two terms. (NEMA, No. 54 at p. 14) DOE 

understands that the terms ‘‘motor’’ and 

‘‘electric motor’’ may refer to a variety 

of machines outside of its regulatory 

context. However, because there are no 

NEMA Design B motors that are not 

electrically-driven, in DOE’s view, the 

potential for ambiguity is minimal. DOE 

clarifies that it is using the term ‘‘NEMA 

Design B motor,’’ as is currently 

codified in 10 CFR 431.12. Additionally, 

DOE does not consider there to be any 

meaningful difference between the two 

terms and notes that all motors 

currently regulated under 10 CFR part 

431, subpart B, are electric motors. 

DOE requests comment on whether 

the proposed standards help resolve the 

potential issue on which it had 

previously issued clarification of 

whether a [IEC] motor may be 

considered to be subject to two 

standards. 

2. Expanded Scope of Electric Motor 

Energy Conservation Standards 

As referenced above, on August 15, 

2012, the Motor Coalition petitioned 

DOE to adopt the Coalition’s consensus 

agreement, which, in part, formed the 

basis for today’s proposal.24 The Motor 

Coalition petitioned DOE to simplify 

coverage to address a broad array of 

electric motors with a few clearly 

identified exceptions. The Motor 

Coalition advocated this approach to 

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simplify manufacturer compliance and 

to help facilitate DOE’s enforcement 

efforts. The Petition highlighted 

potential energy savings that would 

result from expanding the scope of 

covered electric motors. (Motor 

Coalition, No 35 at pp. 1–30) 

Subsequent to DOE’s preliminary 

analysis public meeting, several other 

interested parties submitted comments 

supporting the Petition. Those 

supporters included: BBF and 

Associates, the Air Movement and 

Control Association International, Inc., 

U.S. Senators Lisa Murkowski and Jeff 

Bingaman, the Hydraulic Institute, the 

Arkansas Economic Development and 

Commission-Energy Office, and the 

Power Transmission Distributors 

Association. 

The California Investor Owned 

Utilities (CA IOUs), represented by the 

Pacific Gas and Electric Company 

(PG&E), Southern California Gas 

Company (SCGC), San Diego Gas and 

Electric (SDG&E), and Southern 

California Edison (SCE) commented that 

they supported the Petition’s intent to 

expand the scope of coverage to the vast 

majority of single speed, polyphase, and 

integral horsepower induction motors 

between 1 and 500 horsepower, as well 

as increasing energy conservation 

standards for some covered products. 

(CA IOUs, No. 57 at p. 2) 

The Air Movement and Control 

Association International, Inc. (AMCA 

International) endorsed the Petition. 

AMCA International encouraged DOE to 

adopt the Petition to save energy as soon 

as possible. (AMCA International, No. 

59 at p. 1) 

The CDA and BBF supported DOE’s 

preliminary analysis and the Petition, 

indicating that the Petition sets 

minimum efficiency levels that 

represent a challenge to the industry 

and can have a great impact on U.S. 

energy use. (BBF & Associates, No. 51 at 

pp. 1, 2; CDA, No. 55 at p. 1) BBF also 

urged DOE to investigate energy 

conservation standards for motors over 

500 horsepower because preliminary 

indications suggest that as much as 27 

percent of total motor power consumed 

in the U.S. is from motors over 500 

horsepower, and higher efficiencies can 

provide substantial savings. (BBF, No. 

51 at p. 4) 

EASA supported the Motor 

Coalition’s Petition, asserting that it is 

in the best interests of saving energy, 

U.S. jobs, and the economy overall to 

adopt that Petition’s approach. EASA 

strongly encouraged the DOE to adopt 

the recommendations of the Motor 

Coalition, citing large and economically 

justified energy savings. (EASA, No. 47 

at p. 1) 

ACEEE commented on behalf of the 

Motor Coalition, stating that expanding 

the scope of energy conservation 

standards and only excluding a small 

group of motor types will enhance 

enforcement efforts by the government, 

by simplifying the standards to only 

include explicit exclusions. (ACEEE, 

Public Meeting Transcript, No. 60 at p. 

19) 

After reviewing the Petition, DOE is 

proposing to require electric motor 

types beyond those currently covered 

(and discussed in section IV.A.1) to 

meet energy conservation standards. 

DOE’s proposed expansion is similar to 

the approach recommended by the 

Motor Coalition in its Petition (Motor 

Coalition, No. 35 at pp. 1–3). DOE’s 

proposal would establish energy 

conservation standards for electric 

motors that exhibit all of the 

characteristics listed in Table IV.2, with 

a limited number of exceptions. 

TABLE IV.2—CHARACTERISTICS OF

MOTORS REGULATED UNDER EXPANDED SCOPE OF COVERAGE

Motor characteristic 

Is a single-speed, induction motor, 

Is rated for continuous duty (MG 1) operation 

or for duty type S1 (IEC), 

Contains a squirrel-cage (MG 1) or cage 

(IEC) rotor, 

Operates on polyphase alternating current 

60-hertz sinusoidal power, 

Is rated for 600 volts or less, 

Is built with a 2-, 4-, 6-, or 8-pole configuration, 

Is a NEMA Design A, B, or C motor (or IEC 

Design N or H) 

Is built in a three-digit NEMA frame size or 

an enclosed 56-frame (or any IEC equivalent), and 

Is rated from 1 to 500 horsepower (inclusive). 

In response to its preliminary 

analysis, DOE received several 

comments about the characteristics that 

DOE should use to define the broad 

scope of electric motors potentially 

subject to energy conservation 

standards. First, NEMA suggested that 

DOE define motor types exhibiting the 

nine characteristics listed in Table IV.2. 

(NEMA, No. 54 at p. 32) NEMA also 

requested that DOE clarify the range of 

horsepower ratings included and the 

scope of 56- and IEC-frame motors 

covered. The Energy Advocates (NPCC, 

NEEA, ACEEE, ASAP, Earthjustice, 

ASE) also suggested that DOE include 

IEC-equivalents and NEMA 56-frame 

sizes in the scope of coverage. (NPCC, 

No. 56 at p. 2) 

Additionally, DOE is proposing to 

clarify the design, construction, and 

performance characteristics of covered 

electric motors. Specifically, DOE is 

proposing to clarify that only motors 

rated from 1 to 500 horsepower 

(inclusive), or their IEC equivalents, 

would be covered by the standards 

being proposed in today’s rulemaking. 

Finally, with regard to IEC-frame 

motors, DOE would not cover IEC 

motors on the singular basis of frame 

size, but would consider covering such 

motors when they meet the criteria of 

Table IV.2. In other words, an IEC-frame 

motor would need to satisfy these nine 

criteria for the proposed standards to 

apply. 

In its submitted Petition, the Coalition 

requested that DOE cover all singlespeed, polyphase, 56-frame induction 

motors rated at one horsepower or 

greater that do not meet the regulatory 

definition for ‘‘small electric motor’’ in 

10 CFR part 431, subpart X. This 

definition applies to both single-phase 

and polyphase open-frame general 

purpose AC induction motors built in a 

two-digit frame size. The proposal put 

forth by the Coalition would expand 

energy conservation standards to 

polyphase, enclosed 56-frame motors 

rated at one or more horsepower along 

with polyphase, special and definite 

purpose open 56-frame motors of 

horsepower greater than or equal to one 

that are not covered by DOE’s small 

electric motor regulations. 

Regarding 56-frame motors at 1-hp or 

greater, DOE is proposing standards for 

polyphase, enclosed 56-frame motors 

that are rated at 1-hp or greater. DOE is 

also tentatively proposing TSL 2 for 

polyphase, open 56-frame special and 

definite purpose motors that are rated at 

1-hp or greater as advocated by the 

Motor Coalition. With respect to these 

motors (i.e. 56-frame, open, special and 

definite purpose), DOE seeks additional 

data related to these motors, including, 

but not limited to the following 

categories: Motor efficiency 

distributions; shipment breakdowns 

between horsepower ratings, open and 

enclosed motors, and between general 

and special and definite purpose 

electric motors; and information 

regarding the typical applications that 

use these motors. If this proposal is 

adopted in the final rule, DOE will 

account for a substantial majority of 56- 

frame motors that are not already 

regulated by efficiency standards and 

ensure coverage for all general purpose 

motors along with a substantial number 

of special and definite purpose motors. 

Based on currently available data, 

DOE estimates that approximately 

270,000 polyphase, open 56-frame 

special and definite purpose motors (1- 

hp or greater) were shipped in 2011 and 

at least 70% of these motors have 

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25Shipments for these 56-open frame motors were 

estimated from data provided by the Motor 

Coalition. DOE assumed 56-frame open motors are 

distributed across 2-, 4-, and 6-pole configurations 

and 1 to 5 horsepower ratings. With this 

assumption, DOE used the shipments distributions 

from ECG 1 motors across these motor 

configurations and ratings to establish shipments 

data for open 56-frame motors by motor 

configuration and horsepower rating. Efficiency 

distributions were based on a limited survey of 

electric motor models from six major manufacturer 

catalogs. 

26 DOE used the same NIA model and inputs 

described in section IV.H to estimate these values 

of NES and NPV, but adjusted the shipments and 

efficiency distributions to match the data specific 

to these 56-frame open motors. 

27 DOE notes that general purpose, open 56-frame 

motors are already addressed by the standards for 

small electric motors. 

efficiency levels below NEMA 

Premium.25 In addition, based on this 

data, DOE believes that establishing TSL 

2 for this subset of 56-frame motors 

would result in national energy savings 

of 0.58 quads (full-fuel-cycle) and net 

present value savings of $1.11 billion 

(2012$), with a 7 percent discount 

rate.26 DOE has not merged its data and 

analyses related to this subset of 56- 

frame motors with the other analyses in 

today’s NOPR. As described above, DOE 

seeks additional information that can be 

incorporated into its final analysis. 

DOE notes that enclosed 56-frame 

motors with horsepower ratings below 1 

horsepower would not, however, be 

covered as part of today’s proposal. DOE 

is not proposing to cover 56-frame size 

fractional motors because EPCA, as 

amended, establishes energy 

conservation standards for electric 

motors at 1-hp or greater and DOE 

requires the use of different test 

procedures for motors above and below 

1-hp. In particular, DOE’s regulations 

prescribe, consistent with industry 

practice, the use of the Institute of 

Electrical and Electronics Engineers 

(IEEE) Standard 112 (Test Method A) to 

test motors rated below 1-hp, and IEEE 

Standard 112 (Test Method B) to test 

motor rated at or above 1-hp. To ensure 

consistent testing results, DOE requires 

application of the same test procedure 

to all electric motors. Therefore, DOE is 

not proposing to regulate enclosed 56- 

frame size motors rated under 1-hp.27

This tentative decision, however, does 

not foreclose the possibility that DOE 

may regulate the efficiency of these 

motors and may change depending on 

the nature of the feedback provided by 

commenters with respect to this issue. 

DOE requests comment on its tentative 

decision to not address fractional 

horsepower enclosed 56-frame motors 

as part of today’s proposal, along with 

any relevant information and data. 

In view of Table IV.2, Table IV.3 lists 

the various electric motor types that 

would be covered by DOE’s proposed 

approach. Further details and 

definitions for the motor types can be 

found in DOE’s electric motors test 

procedure NOPR, which was published 

on June 26, 2013 (78 FR 38456). 

TABLE IV.3—CURRENTLY UNREGULATED MOTOR TYPES DOE PROPOSES TO COVER

Electric Motor Type 

NEMA Design A from 201 to 500 horsepower. Electric motors with non-standard endshields or flanges. 

Electric motors with moisture resistant windings. Electric motors with non-standard bases. 

Electric motors with sealed windings. Electric motors with special shafts. 

Partial electric motors. Vertical hollow-shaft electric motors. 

Totally enclosed non-ventilated (TENV) electric motors. Electric motors with sleeve bearings. 

Immersible electric motors. Electric motors with thrust bearings. 

Integral brake electric motors. Non-integral brake electric motors. 

In view of DOE’s proposed approach 

described in Table IV.3, DOE is 

proposing to include certain motor 

types that some interested parties have 

suggested that DOE continue to exclude 

from any energy efficiency 

requirements. For example, the Motor 

Coalition would exclude integral brake 

motors from coverage, as DOE once did 

through policy guidance, see 62 FR 

59978 (November 5, 1997), but which 

was subsequently removed. See 77 FR 

26638 (May 4, 2012). (Motor Coalition, 

No. 35 at p. 3) SEW-Eurodrive also 

commented that there are two basic 

types of integral gearmotor: (1) One that 

meets the definition in DOE’s 

preliminary analysis, and (2) another 

having a special shaft or mounting 

configuration. SEW-Eurodrive 

contended that the second type of 

integral gearmotor would require 

replacement of the entire rotor shaft and 

rotor cage to be tested. (SEWE, No. 53, 

p. 3) 

In view of the foregoing, DOE 

continues to believe that consistent and 

repeatable test procedures can be 

prescribed for integral brake motors, 

integral gearmotors, integral partial 

motors, and partial d motors. See 78 FR 

38456 (June 26, 2013). In particular, 

DOE believes that an integral brake 

motor that meets the nine criteria in 

Table IV.2, could be readily tested and 

satisfy the proposed standards. In 

addition, DOE believes that the 

definition for ‘‘partial electric motor’’ 

and ‘‘component set’’ proposed in its 

June test procedure NOPR will clarify 

what types of items would meet these 

definitions, which should help 

manufacturers determine whether the 

equipment they manufacture fall under 

these terms. See 78 FR 38456 (June 26, 

2013). Furthermore, DOE believes that 

the type of integral gearmotor addressed 

by SEW-Eurodrive (i.e., with a special 

shaft or mounting configuration) would 

likely satisfy DOE’s proposed definition 

of component set, because it would 

require more than the addition of end 

shields and a bearing to create an 

operable motor. (Component sets would 

not be required to meet standards under 

today’s proposal) 

ACEEE supported the Motor 

Coalition’s Petition in its approach to 

expand the scope of covered motors to 

comply with the energy efficiency levels 

found in Table 12–12 of NEMA 

Standards Publication MG 1–2011. 

According to ACEEE, such approach 

could be easily accomplished by 

manufacturers and, at the same time, 

allow them to refocus resources on 

designing and building the next 

generation of electric motor. (ACEEE, 

Public Meeting Transcript, No. 60 at pp. 

18, 19) UL agreed with the ACEEE 

approach and suggested that DOE clarify 

the scope of coverage with a statement 

whereby all electric motors are subject 

to standards, except for those 

specifically mentioned as excluded. 

(UL, Public Meeting Transcript, No. 60 

at pp. 60, 61) Finally, the California 

Independently Owned Utilities (CA 

IOUs) submitted similar comments, 

suggesting that DOE expand the scope of 

coverage and explicitly define those 

motor types excluded from standards. 

The CA IOUs stressed that this approach 

would provide clarity both to 

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28For this rulemaking, ‘‘across-the-line start’’ 

indicates the electric motor is run directly on 

polyphase, alternating current (AC) sinusoidal 

power, without any devices or controllers 

manipulating the power signal fed to the motor. 

29At its core, the equipment class concept, which 

is being applied only as a structural tool for 

purposes of this rulemaking, is equivalent to a 

‘‘basic model.’’ See 10 CFR 431.12. The 

fundamental difference between these concepts is 

that a ‘‘basic model’’ pertains to an individual 

manufacturer’s equipment class. Each equipment 

class for a given manufacturer would comprise a 

basic model for that manufacturer. 

compliance and enforcement efforts by 

government agencies and 

manufacturers. (CA IOUs, No. 57 at 

p. 1) 

After considering these comments, 

and further analyzing available relevant 

information, DOE believes that a 

simplified approach to determining 

coverage would help ensure consistency 

to the extent possible when applying the 

proposed standards. Therefore, in 

today’s notice, DOE is proposing that an 

electric motor that meets the nine 

characteristics in Table IV–3 would be 

covered and required to meet the 

applicable energy conservation 

standards, either in NEMA MG 1 Table 

12–11 or 12–12. Additionally, DOE is 

proposing not to set standards at this 

time for the following motors: 

component sets, liquid-cooled motors, 

submersible motors, and definitepurpose inverter-fed motors. DOE is not 

proposing to set standards for these 

motors in light of the substantial 

difficulties and complexities that would 

be involved in testing these motors at 

this time. In addition, DOE is proposing 

not to set standards at this time for airover motors, but intends to address 

these types of motors in a separate 

rulemaking. Definitions for the motor 

types and additional details about these 

issues are addressed at 78 FR 38456 

(June 26, 2013). 

3. Advanced Electric Motors 

In its preliminary analysis, DOE 

addressed various ‘‘advanced electric 

motor,’’ which included those listed in 

Table IV.4. While DOE recognized that 

such motors could offer improved 

efficiency, regulating them would 

represent a significant shift for DOE, 

which has primarily focused on the 

efficiency of polyphase, single-speed 

induction motors. Seeking more 

information, DOE solicited public 

comments about these types of motors 

and how they would be tested for 

energy efficiency. 

TABLE IV.4—ADVANCED ELECTRIC

MOTORS

Motor description 

Inverter drives. 

Permanent magnet motors. 

Electrically commutated motors. 

Switched-reluctance motors. 

DOE received comments about 

advanced motors from various 

interested parties. NEMA asserted that, 

in certain applications, inverter drives, 

permanent-magnet motors, 

electronically commutated motors, and 

switched-reluctance motors, could offer 

improved efficiency. However, NEMA 

also noted that these motors may 

include technologies where standard 

test procedures are still being 

developed, making it unable to 

comment. (NEMA, No. 54 at pp. 18–19) 

DOE understands that a test procedure 

would be necessary before it 

contemplates setting energy 

conservation standards for these types 

of motors. Additionally, during the 

preliminary analysis public meeting, 

ACEEE commented that advanced motor 

designs present the largest opportunity 

for future energy savings within the 

motor marketplace and NEMA member 

manufacturers are already exploring the 

standards-setting process for advanced 

motor designs in the NEMA MG 1 

standards publication. (ACEEE, Public 

Meeting Transcript, No. 60 at p. 19) 

Other interested parties submitted 

comments regarding the efficiency of 

‘‘advanced motor systems’’ and, in 

general, motor-driven systems. Danfoss 

commented that system efficiency 

improvements would provide 

significant energy savings, and cited 

variable frequency drives (VFDs) as an 

example of a way to improve system 

efficiency. VFDs, or inverter drives, are 

external components used in motordriven systems to control motor speed 

and torque by varying motor input 

frequency and voltage Danfoss 

elaborated that VFDs could save 20 to 

30 percent of the energy that typical, 

non-VFD-motors consume and urged 

that DOE consider this approach, 

instead of seeking minimal energy 

conservation improvements in acrossthe-line start polyphase electric 

motors.28 (Danfoss, Public Meeting 

Transcript, No. 60 at pp. 21–23, 174, 

175) UL submitted similar comments 

during the preliminary analysis public 

meeting, indicating that DOE and the 

industry should focus on improving 

system-level efficiency. UL added that if 

a motor is not properly matched to its 

load then the system efficiency could be 

20 or 30 percent less efficient than 

possible. (UL, Public Meeting 

Transcript, No. 60 at pp. 69, 70) BBF 

and the CDA commented that the 

overall evaluation of system efficiency 

is very important, and the evaluation of 

VFDs and the motor system represents 

many major opportunities for improved 

efficiency. (BBF, No. 51, p. 4; CDA, No. 

55, p. 2) 

DOE understands the concerns from 

interested parties regarding advanced 

motor efficiency and its connection with 

the possible regulation of advanced 

electric motors. At this time, however, 

DOE has chosen not to regulate 

advanced motors and knows of no 

established definitions or test 

procedures that could be applied to 

them. Because DOE agrees that 

significant energy savings may be 

possible for some advanced motors, 

DOE plans to keep abreast of changes to 

these technologies and their use within 

industry, and may consider regulating 

them in the future. DOE invites 

comment on the topic of advanced 

motors, including any related 

definitions or test procedures that it 

should consider applying as part of 

today’s rulemaking. 

4. Equipment Class Groups and 

Equipment Classes 

When DOE prescribes or amends an 

energy conservation standard for a type 

(or class) of covered equipment, it 

considers (1) the type of energy used; (2) 

the capacity of the equipment; or (3) any 

other performance-related feature that 

justifies different standard levels, such 

as features affecting consumer utility. 

(42 U.S.C. 6295(q)) Due to the large 

number of characteristics involved in 

electric motor design, DOE has used two 

constructs to help develop its energy 

conservation standards proposals for 

electric motors: ‘‘equipment class 

groups’’ and ‘‘equipment classes.’’ An 

equipment class represents a unique 

combination of motor characteristics for 

which DOE is proposing a specific 

energy conservation standard. There are 

580 potential equipment classes that 

consist of all permutations of electric 

motor design types (i.e., NEMA Design 

A & B, NEMA Design C, fire pump 

electric motor, or brake electric motor), 

standard horsepower ratings (i.e., 

standard ratings from 1 to 500 

horsepower), pole configurations (i.e., 

2-, 4-, 6-, or 8-pole), and enclosure types 

(i.e., open or enclosed). An equipment 

class group is a collection of equipment 

classes that share a common design 

type. For example, given a combination 

of motor design type, horsepower rating, 

pole-configuration, and enclosure type, 

the motor’s design type dictates its 

equipment class group, while the 

combination of the remaining 

characteristics dictates its specific 

equipment class.29

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30The terms ‘‘U-frame’’ and ‘‘T-frame’’ refer to 

lines of frame size dimensions, with a T-frame 

motor having a smaller frame size for the same 

horsepower rating as a comparable U-frame motor. 

In general, ‘‘T’’ frame became the preferred motor 

design around 1964 because it provided more 

horsepower output in a smaller package. 

31See, for example, http://www.overlyhautz.com/ 

adaptomounts1.html. 

In the preliminary analysis, DOE 

divided electric motors into three 

groups based on two main 

characteristics: NEMA (or IEC) design 

letter and whether the motor met the 

definition of a fire pump electric motor. 

For the NOPR, DOE is keeping these 

three groups and adding a fourth 

equipment class group for electric 

motors with brakes (integral and nonintegral). DOE’s four resulting 

equipment class groups are: NEMA 

Design A and B motors (ECG 1), NEMA 

Design C motors (ECG 2), fire pump 

electric motors (ECG 3), and electric 

motors with brakes (ECG 4). Within 

each of these groups, DOE would use 

combinations of other pertinent motor 

characteristics to enumerate individual 

equipment classes. To illustrate the 

differences between the two terms, 

consider the following example. A 

NEMA Design B, 50 horsepower, twopole enclosed electric motor and a 

NEMA Design B, 100 horsepower, sixpole open electric motor would be in 

the same equipment class group (ECG 

1), but each would represent a unique 

equipment class that will ultimately 

have its own efficiency standard. Table 

IV.5 outlines the relationships between 

equipment class groups and the 

characteristics used to define equipment 

classes. 

TABLE IV.5—ELECTRIC MOTOR EQUIPMENT CLASS GROUPS FOR THE NOPR ANALYSIS

Equipment class 

group Electric motor design Horsepower Poles Enclosure 

1 ................................. NEMA Design A & B * .............................................................................. 1–500 2, 4, 6, 8 Open. 

Enclosed. 

2 ................................. NEMA Design C * ..................................................................................... 1–200 4, 6, 8 Open. 

Enclosed. 

3 ................................. Fire Pump * ............................................................................................... 1–500 2, 4, 6, 8 Open. 

Enclosed. 

4 ................................. Brake Motors * .......................................................................................... 1–30 4, 6, 8 Open. 

Enclosed. 

* Including IEC equivalents. 

NEMA submitted multiple comments 

about DOE’s equipment class groups 

and equipment classes. First, NEMA 

argued that such expansive groups 

could make it difficult to properly 

determine efficiency standards, 

particularly given the large expansion of 

scope being contemplated by DOE. 

(NEMA, No. 54 at p. 40) NEMA 

recommended that ‘‘for ‘electric motors’ 

the term ‘equipment class’ be identified 

as those electric motors which are of the 

polyphase squirrel-cage induction 

type.’’ It added that: 

‘‘An ‘equipment class group’ can be 

defined as a particular ‘group’ of such 

‘electric motor’ having a particular set of 

common characteristics, such as NEMA 

Design A and B electric motors or NEMA 

Design C electric motors, or fire pump 

electric motors. Each ‘equipment class group’ 

can be organized according to ‘rating’ where 

‘rating’ is as it is presently defined in 

§ 431.12 [of 10 CFR Part 431]. When 

appropriate, an AEDM [alternative efficiency 

determination method] can then be 

substantiated for the complete ‘equipment 

class’ of polyphase squirrel-cage induction 

electric motors as is permitted and done 

today.’’ 

Additionally, NEMA suggested that 

DOE separate U-frame motors from 

T-frame motors during the analysis 

because any proposed increase in 

efficiency standards for the low volume 

production of U-frame motors would 

likely result in a reduction in the 

availability of U-frame motors, which 

they assert, is not permitted under 42 

U.S.C. 6295(o)(4). (NEMA, No. 54 at pp. 

20, 26) Citing the high cost of 

redesigning these motors relative to the 

potential savings, the Motor Coalition 

predicted manufacturers would exit the 

U-frame market leaving only one or two 

manufacturers. (Motor Coalition, No. 35 

at p. 13) NEMA also stated that the 

demand for this type of motor has been 

declining since the 1960’s and U-frame 

motors have not been included in the 

NEMA MG 1 standard since U-frame 

motors were replaced by T-frame motors 

as the NEMA standard in the 1960s. 

(NEMA, No. 54 at pp. 19, 20) NEMA 

added that the challenge created by 

substituting a U-frame motor with a 

T-frame motor must be accounted for in 

the manufacturer and national impact 

analyses. 

EISA 2007 prescribed energy 

conservation standards for electric 

motors built with a U-frame, whereas 

previously only electric motors built 

with a T-frame were covered.30

(Compare 42 U.S.C. 6311(13)(A)(1992) 

with 42 U.S.C. 6311(13)(B)(2011)) In 

general, for the same combination of 

horsepower rating and pole 

configuration, an electric motor built in 

a U-frame is built with a larger ‘‘D’’ 

dimension than an electric motor built 

in a T-frame. The ‘‘D’’ dimension is a 

measurement of the distance from the 

centerline of the shaft to the bottom of 

the mounting feet. Consequently, Uframe motors should be able to reach 

efficiencies as high, or higher, than Tframe motors with similar ratings (i.e., 

horsepower, pole-configuration, and 

enclosure) because the larger frame size 

allows for more active materials, such as 

copper wiring and electrical steel, 

which help reduce I2R (i.e., losses 

arising from the resistivity of the 

current-carrying material) and core 

losses (losses that result from magnetic 

field stability changes). Furthermore, 

U-frame motors do not have any unique 

utility relative to comparable T-frame 

motors. In general, a T-frame design 

could replace an equivalent U-frame 

design with minor modification of the 

mounting configuration for the driven 

equipment. By comparison, a U-frame 

design that is equivalent to a T-frame 

design could require substantial 

modification to the mounting 

configuration for the same piece of 

driven equipment because of its larger 

size. DOE’s research indicated that 

manufacturers sell conversion brackets 

for installing T-frame motors into 

applications where a U-frame motor had 

previously been used.31

Regarding NEMA’s contention that 

U-frame motors will become unavailable 

if DOE does not separate these motors 

from T-frame motors when developing 

efficiency standards, DOE understands 

NEMA’s concerns regarding the 

diminishing market size of U-frame 

motors and the potential for them to 

disappear. However, DOE believes that 

such an occurrence would not be the 

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result of an efficiency standard that is 

technologically infeasible for U-frame 

motors, but because U-frame motors 

offer no unique utility relative to 

T-frame motors. Furthermore, DOE 

believes that the proposed standards are 

unlikely to result in the unavailability of 

U-frame motors. Based on catalog data 

from several large electric motor 

manufacturers, DOE observed that 70 

percent of currently available U-frame 

models meet the proposed standard 

(TSL 2). With much of the U-frame 

market already at the proposed 

standard, DOE sees no technical reason 

that U-frame manufacturers would not 

be able to comply with TSL 2. 

DOE also notes that under 42 U.S.C. 

6295(o)(4), EPCA proscribes the 

promulgation of standards that would 

result in the ‘‘unavailability in the 

United States in any covered product 

type (or class) of performance 

characteristics (including reliability), 

features, sizes, capacities, and volumes 

that are substantially the same as those 

generally available in the United States 

at the time of the Secretary’s finding.’’ 

The provision does not require the 

continued protection of particular 

classes or types of product—or in this 

case, electric motors—if the same utility 

continues to be available for the 

consumers who are purchasing the 

given product. Consequently, based on 

available information, DOE has not 

separated U-frame motors into a unique 

equipment class group. DOE welcomes 

any additional data relevant to this 

finding, including data that would 

suggest the need for an alternate 

approach. DOE also requests additional 

information from manufacturers on 

whether covering U-frame motors would 

cause them to be unavailable in the U.S. 

and whether U-frame motors have any 

particular performance characteristics, 

features, sizes, capacities, or volumes. 

Finally, NEMA questioned DOE’s use 

of the term ‘‘equipment class’’ to 

describe a combination of horsepower 

rating, pole configuration, and enclosure 

type instead of using the term ‘‘rating,’’ 

which is defined in 10 CFR 431.12, as 

part of the definition of a ‘‘basic model.’’ 

(NEMA, No. 54 at p. 25) NEMA believes 

that this could cause confusion because 

of proposals regarding certification, 

alternative efficiency determination 

methods (AEDMs), and enforcement in 

a separate rulemaking, which are all 

centered around ‘‘equipment classes.’’ 

(NEMA, No. 54 at p. 25) NEMA stated 

that DOE’s definition in this rulemaking 

has the adverse impact of requiring 

substantiation of an AEDM separately 

for every rating for which it is to be used 

and would constitute a significant 

increase in compliance burden. (NEMA, 

No. 54 at p. 25) DOE understands 

NEMA’s concerns regarding the 

potential of undue compliance burden. 

DOE notes that it has not proposed a 

regulatory definition for the term 

‘‘equipment class.’’ It is merely a 

construct for use in the various analyses 

in today’s rulemaking. The term 

‘‘equipment class’’ as described in this 

rulemaking should not be misconstrued 

as having any regulatory meaning as it 

relates to the definition of ‘‘basic 

model.’’ In today’s rulemaking, DOE is 

continuing to use the terminology as 

described in the preliminary analysis 

and above. DOE intends to address 

NEMA’s concerns regarding the 

potential compliance burden in a 

separate rulemaking that will address 

compliance, certification and 

enforcement-related issues. 

a. Electric Motor Design Letter 

The first criterion that DOE 

considered when disaggregating 

equipment class groups was based on 

the NEMA (and IEC) design letter. The 

NEMA Standards Publication MG 1– 

2011, ‘‘Motors and Generators,’’ defines 

a series of standard electric motor 

designs that are differentiated by 

variations in performance requirements. 

These designs are designated by letter— 

Designs A, B, and C. (See NEMA MG 1– 

2011, paragraph 1.19.1). These designs 

are categorized by performance 

requirements for full-voltage starting 

and developing locked-rotor torque, 

breakdown torque, and locked-rotor 

current, all of which affect an electric 

motor’s utility and efficiency. DOE is 

proposing to regulate the efficiency of 

each of these design types. 

The primary difference between a 

NEMA Design A and NEMA Design B 

electric motor is that they have different 

locked-rotor current requirements. 

NEMA Design B motors must not exceed 

the applicable locked-rotor current level 

specified in NEMA MG 1–2011, 

paragraph 12.35.1. NEMA Design A 

motors, on the other hand, do not have 

a maximum locked-rotor current limit. 

In most applications, NEMA Design B 

motors are generally preferred because 

locked-rotor current is constrained to 

established industry standards, making 

it easier to select suitable motor-starting 

devices. However, certain applications 

have special load torque or inertia 

requirements, which result in a design 

with high locked-rotor current (NEMA 

Design A). When selecting starting 

devices for NEMA Design A motors, 

extra care must be taken in properly 

sizing electrical protective devices to 

avoid nuisance tripping during motor 

startup. The distinction between NEMA 

Design A and NEMA Design B motors is 

important to users who are sensitive to 

high locked-rotor current; however, both 

NEMA Design A and Design B motors 

have identical performance 

requirements in all other metrics, which 

indicates that they offer similar levels 

and types of utility. Given these 

similarities, DOE is proposing to group 

these motors together into a single 

equipment class grouping for the 

purposes of this rulemaking. 

In contrast, DOE believes that the 

different torque requirements for NEMA 

Design C electric motors represent a 

change in utility that can affect 

efficiency performance. NEMA Design C 

motors are characterized by high 

starting torques. Applications that are 

hard to start, such as heavily loaded 

conveyors and rock crushers, require 

this higher starting torque. The 

difference in torque requirements will 

restrict which applications can use 

which NEMA Design types. As a result, 

NEMA Design C motors cannot always 

be replaced with NEMA Design A or B 

motors, or vice versa. Therefore, as in 

the preliminary analysis, DOE has 

analyzed NEMA Design C motors in an 

equipment class group separate from 

NEMA Design A and B motors. 

In chapter two, ‘‘Analytical 

Framework,’’ of the preliminary 

technical support document, DOE noted 

numerous instances where 

manufacturers were marketing electric 

motors rated greater than 200 

horsepower as NEMA Design C motors. 

DOE understands that NEMA MG 1– 

2011 specifies Design C performance 

requirements for motors rated 1–200 hp 

in four-, six-, and eight-pole 

configurations—a motor rated above 200 

hp or using a two-pole configuration 

would not meet the Design C 

specifications. DOE requested public 

comment about whether motors that are 

name-plated as NEMA Design C, but 

that fall outside the ratings for which 

NEMA Design C is defined, can be 

considered to be NEMA Design C 

motors. In its comments, NEMA 

asserted it did not support marking a 

motor as NEMA Design C where no 

standard exists for two-pole designs, or 

four-, six- or eight-pole motors over 200 

horsepower. NEMA recommended that 

any such improperly marked motor be 

examined for determination of its 

proper Design letter relative to the 

applicable standards in NEMA MG 1. 

Furthermore, NEMA recommended that 

DOE not include efficiency standards 

for motors of any design type for which 

NEMA or IEC standards do not exist. 

(NEMA, No. 54 at p. 19) 

DOE understands that without 

established performance standards that 

form the basis for a two-pole NEMA 

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Design C motor or a NEMA Design C 

motor with a horsepower rating above 

200, motors labeled as such would not 

meet the proposed regulatory definition 

for ‘‘NEMA Design C motor.’’ 78 FR 

38456 (June 26, 2013). DOE considers 

motors at these ratings to be improperly 

labeled if they are name-plated as 

NEMA Design C. Mislabeled NEMA 

Design C motors, however, are still 

subject to energy conservation standards 

if they meet the definitions and 

performance standards for a regulated 

motor—e.g. NEMA Design A or B. And 

since these motors either need to meet 

the same efficiency levels or would be 

required by customers to meet specific 

performance criteria expected of a given 

design letter (i.e. Design A, B, or C), 

DOE does not foresee at this time any 

incentive that would encourage a 

manufacturer to identify a Design A or 

B motor as a Design C motor for 

standards compliance purposes. DOE 

understands, however, that NEMA 

Design C motors as a whole constitute 

an extremely small percentage of motor 

shipments—less than two percent of 

shipments—covered by this rulemaking, 

which would appear to create an 

unlikely risk that mislabeling motors as 

NEMA Design C will be used as an 

avenue to circumvent standards. 

Nevertheless, DOE will monitor the 

potential presence of such motors and 

may reconsider standards for them 

provided such practice becomes 

prevalent. 

b. Fire Pump Electric Motors 

In addition to considering the NEMA 

design type when establishing 

equipment class groups, DOE 

considered whether an electric motor is 

a fire pump electric motor. EISA 2007 

prescribed energy conservation 

standards for fire pump electric motors 

(42 U.S.C. 6313(b)(2)(B)) and, 

subsequently, DOE adopted a definition 

for the term ‘‘fire pump electric motor,’’ 

which incorporated portions of National 

Fire Protection Association Standard 

(NFPA) 20, ‘‘Standard for the 

Installation of Stationary Pumps for Fire 

Protection’’ (2010). Pursuant to NFPA 

20, a fire pump electric motor must 

comply with NEMA Design B 

performance standards and must 

continue to run in spite of any risk of 

damage stemming from overheating or 

continuous operation. The additional 

requirements for a fire pump electric 

motor constitutes a change in utility that 

DOE believes could also affect its 

performance and efficiency. Therefore, 

DOE established a separate equipment 

class group for such motors in the 

preliminary analysis to account for the 

special utility offered by these motors. 

In its comments, NEMA agreed with 

DOE’s decision to separate fire pump 

electrical motors as a separate 

equipment class group. (NEMA, No. 54 

at p. 20) Consequently, DOE is 

proposing to continue using a separate 

equipment class group for fire pump 

electric motors. 

c. Brake Motors 

In its NOPR analyses, DOE considered 

whether the term ‘‘electric motor’’ 

should include an integral brake electric 

motor or a non-integral brake electric 

motor (collectively, ‘‘brake motors’’). In 

the test procedure NOPR, DOE proposed 

definitions both for integral and nonintegral brake electric motors. 78 FR 

38456 (June 26, 2013). Both of these 

electric motor types are contained in 

one equipment class group as separate 

from the equipment class groups 

established for NEMA Design A and B 

motors, NEMA Design C motors, and 

fire pump electric motors. 

DOE understands that brake motors 

contain multiple features that can affect 

both utility and efficiency. In most 

applications, electric motors are not 

required to stop immediately. Instead, 

electric motors typically slow down and 

gradually stop after power is removed 

from the motor due to a buildup of 

friction and windage from the internal 

components of the motor. However, 

some applications require electric 

motors to stop quickly. Such motors 

may employ a brake component that, 

when engaged, abruptly slows or stops 

shaft rotation. The brake component 

attaches to one end of the motor and 

surrounds a section of the motor’s shaft. 

During normal operation of the motor, 

the brake is disengaged from the motor’s 

shaft—it neither touches nor interferes 

with the motor’s operation. However, 

under normal operating conditions, the 

brake is drawing power from the electric 

motor’s power source and may also be 

contributing to windage losses, because 

the brake is an additional rotating 

component on the motor’s shaft. When 

power is removed from the electric 

motor (and therefore the brake 

component), the brake component deenergizes and engages the motor shaft, 

quickly slowing or stopping rotation of 

the rotor and shaft components. Because 

of these utility related features that 

affect efficiency, DOE has preliminarily 

established a separate equipment class 

group for electric motors with an 

integral or non-integral brake. 

d. Horsepower Rating 

In its preliminary analysis, DOE 

considered three criteria when 

differentiating equipment classes. The 

first criterion was horsepower, a critical 

performance attribute of an electric 

motor that is directly related to the 

capacity of an electric motor to perform 

useful work and that generally scales 

with efficiency. For example, a 50- 

horsepower electric motor would 

generally be considered more efficient 

than a 10-horsepower electric motor. In 

view of the direct correlation between 

horsepower and efficiency, DOE 

preliminarily used horsepower rating as 

a criterion for distinguishing equipment 

classes in the framework document and 

continued with that approach for the 

preliminary analysis. 

NEMA agreed with DOE’s view that 

horsepower is a performance attribute 

that must be considered when 

evaluating efficiency and urged that this 

long-established and workable concept 

not be abandoned. (NEMA, No. 54 at p. 

40) In today’s proposal, DOE continues 

to use horsepower as an equipment 

class-setting criterion. 

e. Pole Configuration 

The number of poles in an induction 

motor determines the synchronous 

speed (i.e., revolutions per minute) of 

that motor. There is an inverse 

relationship between the number of 

poles and a motor’s speed. As the 

number of poles increases from two to 

four to six to eight, the synchronous 

speed drops from 3,600 to 1,800 to 1,200 

to 900 revolutions per minute, 

respectively. In addition, manufacturer 

comments and independent analysis 

performed on behalf of DOE indicate 

that the number of poles has a direct 

impact on the electric motor’s 

performance and achievable efficiency 

because some pole configurations utilize 

the space inside of an electric motor 

enclosure more efficiently than other 

pole configurations. DOE used the 

number of poles as a means of 

differentiating equipment classes in the 

preliminary analysis. 

In response to the preliminary 

analysis, NEMA agreed that the number 

of poles of an electric motor has impacts 

a motor’s achievable efficiency and 

supported DOE’s decision to take this 

characteristic into consideration. 

(NEMA, No. 54 at p. 41) In today’s 

proposal, DOE continues to use poleconfiguration as an equipment classsetting criterion. 

f. Enclosure Type 

EISA 2007 prescribes separate energy 

conservation standards for open and 

enclosed electric motors. (42 U.S.C. 

6313(b)(1)) Electric motors 

manufactured with open construction 

allow a free interchange of air between 

the electric motor’s interior and exterior. 

Electric motors with enclosed 

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construction have no direct air 

interchange between the motor’s interior 

and exterior (but are not necessarily airtight) and may be equipped with an 

internal fan for cooling (see NEMA MG 

1–2011, paragraph 1.26). Whether an 

electric motor is open or enclosed 

affects its utility; open motors are 

generally not used in harsh operating 

environments, whereas totally enclosed 

electric motors often are. The enclosure 

type also affects an electric motor’s 

ability to dissipate heat, which directly 

affects efficiency. For these reasons, 

DOE used an electric motor’s enclosure 

type (open or enclosed) as an equipment 

class setting criterion in the preliminary 

analysis. 

NEMA acknowledged in its comments 

that the enclosure type is an important 

characteristic that affects the achievable 

efficiency for any particular electric 

motor. NEMA added that it may become 

necessary to consider separate groups 

for various enclosures as DOE continues 

to expand the scope of electric motors 

subject to energy conservation 

standards, but did not make any specific 

suggestions regarding which enclosures 

could be considered separately. (NEMA, 

No. 54 at p. 42) 

At this time, DOE is continuing to use 

separate equipment class groups for 

open and enclosed electric motors but is 

declining to further break out separate 

equipment classes for different types of 

open or enclosed enclosures because 

DOE does not have data supporting such 

separation. 

g. Other Motor Characteristics 

In the preliminary analysis, DOE 

addressed various other motor 

characteristics, but did not use them to 

disaggregate equipment classes. In the 

preliminary analysis TSD, DOE 

provided its rationale for not 

disaggregating equipment classes for 

vertical electric motors, electric motors 

with thrust or sleeve bearings, closecoupled pump motors, or by rated 

voltage or mounting feet. DOE believes 

that none of these electric motor 

characteristics provide any special 

utility that would impact efficiency and 

justify separate equipment classes. 

In response to the preliminary 

analysis, DOE received comments about 

how it should treat other motor 

characteristics. NEMA agreed with 

DOE’s decision that vertical motors, 

motors with thrust or sleeve bearings, 

and close-coupled pump motors do not 

merit separate equipment classes. 

(NEMA, No. 54 at p. 20) With no 

comments suggesting that DOE use any 

one of the alternative characteristics as 

a criterion for equipment class, DOE is 

using the approach it laid out in its 

preliminary analysis. 

DOE also requests additional 

information from manufacturers on 

whether covering any of these 

technology options would reduce 

consumer utility or performance or 

cause any of the covered electric motors 

to be unavailable in the U.S. and 

whether U-frame motors have any 

particular performance characteristics, 

features, sizes, capacities, or volumes. In 

particular, DOE requests any 

information or data if these technology 

options would lead to increases in the 

size of the motors such that it would no 

longer work in a particular space 

constricted application, to decreases in 

power thereby affecting their usability 

of these motors, or to changes in any 

other characteristics that would affect 

the performance or utility of the motor. 

5. Technology Assessment 

The technology assessment provides 

information about existing technology 

options and designs used to construct 

more energy-efficient electric motors. 

Electric motors have four main types of 

losses that can be reduced to improve 

efficiency: Losses due to the resistance 

of conductive materials (stator and rotor 

I2R losses), core losses, friction and 

windage losses, and stray load losses. 

These losses are interrelated such that 

measures taken to reduce one type of 

loss can result in an increase in another 

type of losses. In consultation with 

interested parties, DOE identified 

several technology options that could be 

used to reduce such losses and improve 

motor efficiency. These technology 

options are presented in Table IV.6. (See 

chapter 3 of the TSD for details). 

TABLE IV.6—TECHNOLOGY OPTIONS TO INCREASE ELECTRIC MOTOR EFFICIENCY

Type of loss to reduce Technology option 

Stator I2R Losses ....................................................................................... Increase cross-sectional area of copper in stator slots. 

Decrease the length of coil extensions. 

Rotor I2R Losses ........................................................................................ Use a die-cast copper rotor cage. 

Increase cross-sectional area of rotor conductor bars. 

Increase cross-sectional area of end rings. 

Core Losses ............................................................................................... Use electrical steel laminations with lower losses (watts/lb). 

Use thinner steel laminations. 

Increase stack length (i.e., add electrical steel laminations). 

Friction and Windage Losses ..................................................................... Optimize bearing and lubrication selection. 

Improve cooling system design. 

Stray-Load Losses ..................................................................................... Reduce skew on rotor cage. 

Improve rotor bar insulation. 

In response to the preliminary 

analysis, DOE received multiple 

comments about these options. 

At the preliminary analysis public 

meeting, NEMA requested clarification 

on what was meant by the technology 

option listed as ‘‘improving rotor bar 

insulation.’’ (NEMA, Public Meeting 

Transcript, No. 60 at p. 158) NEMA 

commented on the option of increasing 

the cross sectional area of the stator 

windings and clarified that this is one 

way to decrease stator resistance, but 

not necessarily a separate technology 

option. (NEMA, No. 54 at p. 44) NEMA 

also clarified that reducing rotor 

resistance through a change in volume 

is synonymous with an increase in rotor 

slot size, unless DOE intends to include 

variations in the volume of the end 

rings. (NEMA, No. 54 at p. 45) 

NEMA also noted that chapter 3 of 

DOE’s preliminary TSD did not discuss 

the option of increasing the flux density 

in the air gap, while chapter 4 did. 

(NEMA, No. 54 at p. 46) NEMA added 

that the air gap flux density is not a 

design option that can be independently 

adjusted and that for a given core length 

the only option available for changing 

the air gap flux density is to change the 

number of effective turns in the stator 

winding. (NEMA, No. 54 at pp. 62, 63) 

NEMA also commented on the 

limitations associated with reducing a 

motor’s air gap by noting that 

manufacturers must ensure that the 

motor is still functional and that the air 

gap is not so small such that the rotor 

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32Quenching is rapid cooling, generally by 

immersion in a fluid instead of allowing the rotor 

temperature to equalize to ambient 

33Creep distance is the shortest path between two 

conductive parts. An adequate creep distance 

protects against tracking, a process that can lead to 

insulation deterioration and eventual short circuit. 

Strike distance is the shortest distance through air 

from one conductor to another conductor or to 

ground. Adequate strike distance is required to 

prevent electrical discharge between two 

conductors or between conductors and ground. 

34 IEEE 841–2009, ‘‘IEEE Standard for Petroleum 

and Chemical Industry—Premium-Efficiency, 

Severe-Duty, Totally Enclosed Fan-Cooled (TEFC) 

Squirrel Cage Induction Motors—Up to and 

Including 370 kW (500 hp),’’ identifies the 

recommended practice for petroleum and chemical 

industry severe duty squirrel-cage induction 

motors. 

and stator may strike each other during 

operation. (NEMA, No. 54 at pp. 44–45) 

Lastly, during the preliminary 

analysis public meeting, Danfoss 

commented that the term ‘‘technology 

options’’ is a bit misleading because of 

the design tradeoffs that must be made 

in order to maintain motor performance 

(other than efficiency). (Danfoss, Public 

Meeting Transcript, No. 60 at pp. 98, 99) 

Regarding the requested clarifications, 

DOE notes the listed option of 

‘‘improved rotor insulation’’ refers to 

increasing the resistance between the 

rotor squirrel-cage and the rotor 

laminations. Manufacturers use 

different methods to insulate rotor 

cages, such as applying an insulating 

coating on the rotor slot prior to diecasting or heating and quenching 32 the 

rotor to separate rotor bars from rotor 

laminations after die-casting. DOE has 

updated the discussion in the TSD 

chapter to clarify that there are multiple 

ways to implement this technology 

option. 

DOE agrees with NEMA that 

increasing the cross-sectional area of 

copper in the stator is synonymous with 

reducing the stator resistance, and has 

updated the discussion in TSD chapter 

3 for clarity. Furthermore, DOE agrees 

with NEMA that increasing rotor slot 

size is a technique that reduces rotor 

resistivity. DOE also considered other 

techniques to reduce rotor resistivity 

such as increasing the volume of the 

rotor end rings and using die-cast 

copper rotors. For the sake of clarity, 

DOE has replaced the technology option 

‘‘reduce rotor resistance’’ in the TSD 

discussion with the specific techniques 

that DOE considered in its analysis: 

Increasing the cross-sectional area of the 

rotor conductor bars, increasing the 

cross-sectional area of the end rings, and 

using a die-cast copper rotor cage. 

With regard to increasing the flux 

density in the air gap, DOE consulted 

with its subject matter expert and 

acknowledges that this approach is not 

necessarily an independently adjustable 

design parameter used to increase motor 

efficiency and has removed it from its 

discussion in chapters 3 and 4 of the 

TSD. DOE notes that it understands that 

the technology options that it discusses 

do have limits, both practical limits in 

terms of manufacturing and design 

limits in terms of their effectiveness. 

DOE also understands that a 

manufacturer must balance any options 

to improve efficiency against the 

possible impacts on the performance 

attributes of its motor designs. 

a. Decrease the Length of Coil 

Extensions 

One method of reducing resistance 

losses in the stator is decreasing the 

length of the coil extensions at the end 

turns. Reducing the length of copper 

wire outside the stator slots not only 

reduces the resistive losses, but also 

reduces the material cost of the electric 

motor because less copper is being used. 

NEMA submitted comments 

acknowledging decreased coil extension 

as an option to increase efficiency, but 

did not see the practicability. NEMA 

asserted that decreasing the length of a 

coil extension has been a common 

industry practice for over 50 years and 

it would be difficult to achieve any 

further reductions in motor losses under 

this option. NEMA added that any 

design changes that would decrease the 

length of a coil extension must be 

carefully considered to ensure that the 

coil heads meet all applicable creep and 

strike distance requirements.33 (NEMA, 

No. 54 at p. 57) 

DOE understands that there may be 

limited efficiency gains, if any, for most 

electric motors using this technology 

option. DOE also understands that 

electric motors have been produced for 

many decades and that many 

manufacturers have improved their 

production techniques to the point 

where certain design parameters may 

already be fully optimized. However, 

DOE maintains that this is a design 

parameter that affects efficiency and 

should be considered when designing 

an electric motor. 

b. Increase Cross-Sectional Area of Rotor 

Conductor Bars 

Increasing the cross-sectional area of 

the rotor bars, by changing the crosssectional geometry of the rotor, can 

improve motor efficiency. Increasing the 

cross-sectional area of the rotor bars 

reduces the resistance and thus lowers 

the I2R losses. However, changing the 

shape of the rotor bars may affect the 

size of the end rings and can also 

change the torque characteristics of the 

motor. 

NEMA acknowledged that increasing 

the cross-sectional area of rotor bars is 

an option to increase efficiency, but 

doubted whether any additional 

reductions in motor losses were possible 

by using this method. After 50 years of 

increasing efficiency through this 

technique, NEMA questioned whether 

manufacturers could further increase 

the cross-sectional area of the rotor bars, 

adding that the increase in rotor current 

cannot exceed the square of the decrease 

in the rotor resistance in order for the 

rotor losses to decrease. NEMA added 

that any design changes using this 

option must be carefully considered to 

ensure that the motor will meet the 

applicable NEMA MG 1 performance 

requirements (i.e., stall time, 

temperature rise, overspeed) and, for 

certain applications, any other industry 

standards (i.e., IEEE 841 34) to maintain 

the same level of utility. (NEMA, No. 54 

at pp. 57, 58) 

DOE recognizes that increasing the 

cross-sectional area of a conductor rotor 

bar may yield limited efficiency gains 

for most electric motors. However, DOE 

maintains that this is a design parameter 

that affects efficiency and must be 

considered when designing an electric 

motor. Additionally, when creating its 

software models, DOE considered rotor 

slot design, including cross sectional 

areas, such that any software model 

produced was designed to meet the 

appropriate NEMA performance 

requirements for torque and locked rotor 

current. 

c. Increase Cross-Sectional Area of End 

Rings 

End rings are the components of a 

squirrel-cage rotor that create electrical 

connections between the rotor bars. 

Increasing the cross-sectional area of the 

end rings reduces the resistance and 

thus lowers the I2R losses in the end 

rings. A reduction in I2R losses will 

occur only when any proportional 

increase in current as a result of an 

increase in the size of the end ring is 

less than the square of the proportional 

reduction in the end ring resistance. 

NEMA commented that increasing the 

end ring size increases the rotor weight, 

and consideration must be given to the 

effects a heavier end ring will have on 

the life of the rotor. NEMA added that 

any design changes using this option 

must be carefully considered to ensure 

that the applicable design requirements 

are met and intended utility retained. 

(NEMA, No. 54 at p. 58) 

When developing its software models, 

DOE relied on the expertise of its 

subject matter expert. Generally, 

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35ASTM Standard A343/A343M, 2003 (2008), 

‘‘Standard Test Method for Alternating-Current 

Magnetic Properties of Materials at Power 

Frequencies Using Wattmeter-Ammeter-Voltmeter 

Method and 25-cm Epstein Test Frame,’’ ASTM 

International, West Conshohocken, PA 2008. 

increases to end ring area were limited 

to 10–20% are unlikely to have 

significant impacts on the mechanical 

aspects of the rotor. Furthermore, DOE 

ensured that the appropriate NEMA 

performance requirements for torque 

and locked-rotor current were 

maintained with its software modeled 

motors. 

d. Increase the Number of Stator Slots 

Increasing the number of stator slots 

associated with a given motor design 

can, in some cases, improve motor 

efficiency. Similar to increasing the 

amount of copper wire in a particular 

slot, increasing the number of slots may 

in some cases permit the manufacturer 

to incorporate more copper into the 

stator slots. This option would decrease 

the losses in the windings, but can also 

affect motor performance. Torque, speed 

and current can vary depending on the 

combination of stator and rotor slots 

used. 

NEMA indicated that increasing the 

number of slots to allow the motor 

design engineer to incorporate 

additional copper into the stator slots is 

contrary to any practical analysis. 

NEMA elaborated that the stator core 

holds the stator winding in the slots and 

carries the magnetic flux in the 

electrical steel. As stator slots increase, 

insulating material will increase, 

reducing the total amount of crosssectional area for stator winding. 

Additionally, too large of an increase in 

the number of stator slots may make it 

impractical to wind the stator on 

automated equipment and the same may 

be true for a low number of stator slots. 

NEMA also commented that while it 

agrees with DOE that the number of 

stator slots can affect motor torque and 

efficiency, there is a relationship 

between the number of rotor slots and 

stator slots, and the combination of the 

two can have significant effects on 

starting torque, sound levels, and stray 

load losses. NEMA concluded that all of 

these effects must be considered to 

ensure the practicability of 

manufacturing the affected motors. 

Other factors NEMA noted included 

winding and potential sound levels—all 

of which could impact utility along with 

health and safety concerns. (NEMA, No. 

54 at p. 61) 

With respect to stator slot numbers, 

DOE understands that a motor 

manufacturer would not add stator slots 

without any appreciation of the impacts 

on the motor’s performance. DOE also 

understands that there is an optimum 

combination of stator and rotor slots for 

any particular frame size and 

horsepower combination. DOE 

consulted with its subject matter expert 

and understands that optimum stator 

and rotor slot combinations have been 

determined by manufacturers and are in 

use on existing production lines.’’ 

Consequently, DOE has removed this 

technology option from chapter 4 of the 

TSD. 

e. Electrical Steel with Lower Losses 

Losses generated in the electrical steel 

in the core of an induction motor can be 

significant and are classified as either 

hysteresis or eddy current losses. 

Hysteresis losses are caused by magnetic 

domains resisting reorientation to the 

alternating magnetic field. Eddy 

currents are physical currents that are 

induced in the steel laminations by the 

magnetic flux produced by the current 

in the windings. Both of these losses 

generate heat in the electrical steel. 

In studying the techniques used to 

reduce steel losses, DOE considered two 

types of materials: Conventional silicon 

steels, and ‘‘exotic’’ steels, which 

contain a relatively high percentage of 

boron or cobalt. Conventional steels are 

commonly used in electric motors 

manufactured today. There are three 

types of steel that DOE considers 

‘‘conventional:’’ cold-rolled magnetic 

laminations, fully processed nonoriented electrical steel, and semiprocessed non-oriented electrical steel. 

One way to reduce core losses is to 

incorporate a higher grade of core steel 

into the electric motor design (e.g., 

switching from an M56 to an M19 

grade). In general, higher grades of 

electrical steel exhibit lower core losses. 

Lower core losses can be achieved by 

adding silicon and other elements to the 

steel, thereby increasing its electrical 

resistivity. Lower core losses can also be 

achieved by subjecting the steel to 

special heat treatments during 

processing. 

The exotic steels are not generally 

manufactured for use specifically in the 

electric motors covered in this 

rulemaking. These steels include 

vanadium permendur and other alloyed 

steels containing a high percentage of 

boron or cobalt. These steels offer a 

lower loss level than the best electrical 

steels, but are more expensive per 

pound. In addition, these steels can 

present manufacturing challenges 

because they come in nonstandard 

thicknesses that are difficult to 

manufacture. 

NEMA and Baldor submitted multiple 

comments concerning DOE’s discussion 

during the preliminary analysis 

regarding the use of Epstein testing to 

determine an electrical steel grade that 

would improve the efficiency of an 

electric motor. (NEMA, No. 54 at pp. 

21–23, 62; NEMA, Public Meeting 

Transcript, No. 60 at pp. 100, 102, 103) 

The grading of electrical steel is made 

through a standardized test known 

worldwide as the Epstein Test.35 This 

test provides a standardized method of 

measuring the core losses of different 

types of electrical steels. NEMA 

commented that relying solely on 

Epstein test results to select grades of 

steel could result in a motor designer 

inadvertently selecting a steel grade that 

performs poorly in a motor design. 

NEMA supplied data on two different 

samples of steel supplied by different 

manufacturers, but consisting of the 

same steel grade. The data illustrated 

how the lower loss steel (as determined 

by Epstein test results) resulted in a less 

efficient motor when used in a 

prototype. NEMA noted that this 

situation poses a problem for computer 

software modeling because a model that 

represents only the general class of 

electrical steel and not the steel source 

(manufacturer) would not be able to 

calculate the difference in the results 

between the supposedly equivalent 

grades of steels from separate 

manufacturers. 

DOE clarifies that its computer 

software did not model general classes 

of electrical steel, but instead modeled 

vendor-specific electrical steel. DOE’s 

software utilized core loss vs. flux 

density curves supplied by an electrical 

steel vendor as one component of the 

core loss calculated by the program. A 

second component was also added to 

account for high frequency losses. DOE 

agrees with NEMA’s claim that relative 

performance derived from Epstein 

testing might not be indicative of 

relative performance in actual motor 

prototypes. DOE did not solely rely on 

relative steel grade when selecting 

electrical steels for its designs. To 

illustrate this point, DOE notes that 

almost all of its software modeled 

designs utilized M36 grade steel, even 

though it was not the highest grade of 

electrical steel considered in the 

analysis. When higher grade M15 steel 

was evaluated in DOE’s software 

modeled designs, the resulting 

efficiencies were actually lower than the 

efficiencies when using M36 grade steel 

for several reasons including the reasons 

cited by NEMA. The Epstein test results 

for various grades of steel provided in 

chapter 3 of the preliminary analysis 

TSD were purely informational and 

intended to give an indication of the 

relative performance of a sample of 

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electrical steels considered. That 

information has been removed from 

chapter 3 of the TSD to avoid any 

further confusion. 

f. Thinner Steel Laminations 

As addressed earlier, there are two 

types of core losses that develop in the 

electrical steel of induction motors— 

hysteresis losses and losses due to eddy 

current. Electric motors can use thinner 

laminations of core steel to reduce eddy 

currents. The magnitude of the eddy 

currents induced by the magnetic field 

become smaller in thinner laminations, 

making the motor more energy efficient. 

In the preliminary analysis, DOE only 

considered conventional steels with 

standard gauges available in the market. 

NEMA agreed with DOE’s initial 

decision to consider only lamination 

thicknesses that are currently used in 

motor manufacturing, as there is a 

practical limit on how thick the 

laminations can be in electric motors 

before additional losses may become 

significant. (NEMA, No. 54 at p. 62) 

DOE continues to consider this as a 

viable technology option in the NOPR 

analysis. 

g. Increase Stack Length 

Adding electrical steel to the rotor 

and stator to lengthen the motor can 

also reduce the core losses in an electric 

motor. Lengthening the motor by 

increasing stack length reduces the 

magnetic flux density, which reduces 

core losses. However, increasing the 

stack length affects other performance 

attributes of the motor, such as starting 

torque. Issues can arise when installing 

a more efficient motor with additional 

stack length because the motor becomes 

longer and may not fit into applications 

with dimensional constraints. 

NEMA requested clarification of the 

phrase ‘‘add stack height,’’ which DOE 

included in its summary of technology 

options for improving efficiency in 

chapter 3 of the preliminary TSD. 

NEMA was unsure if this meant 

increasing the length of the core or 

increasing the outer diameter of the 

stator core laminations. (NEMA, no. 54 

at p. 45) 

DOE clarifies that it was referring to 

increasing the length of the stator and 

rotor. However, increasing the outside 

diameter of the stator core is another 

way in which manufacturers could add 

active material to their electric motor 

designs and potentially increase 

efficiency. 

NEMA agreed that changing the stack 

length of an electric motor can improve 

core losses (i.e. reduce them), but may 

also change other performance 

characteristics such as torque, speed 

and current. However, NEMA stressed 

that there are limits to this technology 

option because too much additional 

stack could cause the motor to increase 

in size (i.e., frame length), which might 

introduce utility problems in spaceconstrained applications (NEMA, No. 54 

at p. 62) NEMA also commented that 

since the EISA 2007 standards were 

enacted, only a limited number of motor 

ratings above NEMA Premium have 

been offered because there is not 

sufficient space available in most frame 

ratings to increase the efficiency. 

(NEMA, No. 54 at p. 7) DOE 

understands that there are limits to 

increased stack length and, as discussed 

in IV.C, DOE established criterion to 

limit the length of the stack considered 

in the engineering analysis. DOE also 

understands that stack length affects 

consumer utility, which is a factor that 

DOE considers in its selection of a 

standard. 

h. More Efficient Cooling System 

Optimizing a motor’s cooling system 

that circulates air through the motor is 

another technology option to improve 

the efficiency of electric motors. 

Improving the cooling system reduces 

air resistance and associated frictional 

losses and decreases the operating 

temperature (and associated electrical 

resistance) by cooling the motor during 

operation. This can be accomplished by 

changing the fan or adding baffles to the 

current fan to help redirect airflow 

through the motor. 

NEMA agreed that changes in the 

cooling system may reduce the total 

losses of a motor, but did not agree that 

this is equivalent to a more efficient 

cooling system, as DOE described. 

NEMA elaborated that when the design 

of an electric motor is changed, losses 

associated with the cooling system may 

increase in order to provide a decrease 

in losses associated with some other 

part of the design. (NEMA, No. 54 at p. 

63) DOE appreciates NEMA’s comments 

and has clarified its phrasing of this 

technology option to reflect the fact that 

it is the motor that becomes more 

efficient, not necessarily the cooling 

system. 

i. Reduce Skew on Conductor Cage 

In the rotor, the conductor bars are 

not straight from one end to the other, 

but skewed or twisted slightly around 

the axis of the rotor. Decreasing the 

degree of skew can improve a motor’s 

efficiency. The conductor bars are 

skewed to help eliminate harmonics 

that add cusps, losses, and noise to the 

motor’s speed-torque characteristics. 

Reducing the degree of skew can help 

reduce the rotor resistance and 

reactance, which helps improve 

efficiency. However, overly reducing the 

skew also may have adverse effects on 

starting, noise, and the speed-torque 

characteristics. 

NEMA inquired if this design option 

was considered for any of the designs 

used in the engineering analysis, as the 

preliminary TSD did not indicate if any 

rotors were skewed. (NEMA, No. 54 at 

p. 63) NEMA also inquired why the 

option to reduce skew on the conductor 

cage, was associated with I2R losses in 

chapter 3 of the preliminary TSD, but in 

chapter 4 of the preliminary TSD this 

option was associated with reducing 

stray load losses. (NEMA, No. 54 at p. 

46) 

DOE notes that all software designs 

used in the analysis had skewed rotor 

designs and, in general, the skews used 

were approximately 100 percent of a 

stator or rotor slot pitch, whichever had 

the smaller number of slots. 

Additionally, DOE intended for the 

option of reducing the skew on the 

conductor cage to be an option 

associated with reducing stray load 

losses and has made the appropriate 

adjustments to its text and tables. 

B. Screening Analysis 

After DOE identified the technologies 

that might improve the energy efficiency 

of electric motors, DOE conducted a 

screening analysis. The purpose of the 

screening analysis is to determine 

which options to consider further and 

which to screen out. DOE consulted 

with industry, technical experts, and 

other interested parties in developing a 

list of design options. DOE then applied 

the following set of screening criteria, 

under sections 4(a)(4) and 5(b) of 

appendix A to subpart C of 10 CFR Part 

430, ‘‘Procedures, Interpretations and 

Policies for Consideration of New or 

Revised Energy Conservation Standards 

for Consumer Products,’’ to determine 

which design options are unsuitable for 

further consideration in the rulemaking: 

• Technological Feasibility: DOE will 

consider only those technologies 

incorporated in commercial equipment 

or in working prototypes to be 

technologically feasible. 

• Practicability to Manufacture, 

Install, and Service: If mass production 

of a technology in commercial 

equipment and reliable installation and 

servicing of the technology could be 

achieved on the scale necessary to serve 

the relevant market at the time of the 

effective date of the standard, then DOE 

will consider that technology 

practicable to manufacture, install, and 

service. 

• Adverse Impacts on Equipment 

Utility or Equipment Availability: DOE 

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will not further consider a technology if 

DOE determines it will have a 

significant adverse impact on the utility 

of the equipment to significant 

subgroups of customers. DOE will also 

not further consider a technology that 

will result in the unavailability of any 

covered equipment type with 

performance characteristics (including 

reliability), features, sizes, capacities, 

and volumes that are substantially the 

same as equipment generally available 

in the United States at the time. 

• Adverse Impacts on Health or 

Safety: DOE will not further consider a 

technology if DOE determines that the 

technology will have significant adverse 

impacts on health or safety. 

Table IV.7 below presents a general 

summary of the methods that a 

manufacturer may use to reduce losses 

in electric motors. The approaches 

presented in this table refer either to 

specific technologies (e.g., aluminum 

versus copper die-cast rotor cages, 

different grades of electrical steel) or 

physical changes to the motor 

geometries (e.g., cross-sectional area of 

rotor conductor bars, additional stack 

height). For additional details on the 

screening analysis, please refer to 

chapter 4 of the preliminary TSD. 

TABLE IV.7—SUMMARY LIST OF OPTIONS FROM TECHNOLOGY ASSESSMENT

Type of loss to reduce Technology option 

Stator I2R Losses ....................................................................................... Increase cross-sectional area of copper in stator slots. 

Decrease the length of coil extensions. 

Rotor I2R Losses ........................................................................................ Use a die-cast copper rotor cage. 

Increase cross-sectional area of rotor conductor bars. 

Increase cross-sectional area of end rings. 

Core Losses ............................................................................................... Use electrical steel laminations with lower losses (watts/lb). 

Use thinner steel laminations. 

Increase stack length (i.e., add electrical steel laminations). 

Friction and Windage Losses ..................................................................... Optimize bearing and lubrication selection. 

Improve cooling system design. 

Stray-Load Losses ..................................................................................... Reduce skew on rotor cage. 

Improve rotor bar insulation. 

1. Technology Options Not Screened 

Out of the Analysis 

The technology options in this section 

are options that passed the screening 

criteria of the analysis. DOE considers 

the technology options in this section to 

be viable means of improving the 

efficiency of electric motors. In NEMA’s 

view, DOE’s screening analysis lacked 

sufficient supporting information 

regarding whether a particular 

technology is included or screened out 

of the analysis. NEMA agreed that it is 

necessary to look at new technologies, 

but added that DOE did not provide 

adequate supporting information in its 

analysis and the group asserted that 

commenters were left without adequate 

material upon which to base comments 

in support of or in opposition to 

statements made in the preliminary 

TSD. NEMA suggested that a form 

clearly identifying the issues pertinent 

to the topic be provided for each option 

analyzed. NEMA stated that providing 

these forms for each technology option 

would supply adequate material on 

which commenters can develop public 

comments. (NEMA, No. 54 at p. 45) 

Additionally, when discussing the 

seven criteria that DOE must consider in 

its analysis, NEMA expressed that there 

are more criteria that should be 

considered. NEMA stated that DOE 

must consider 4(d)(7) of 10 CFR part 

430, subpart C, appendix A which lists 

under sections 4.(d)(7)(viii) impacts of 

non-regulatory approaches and (ix) new 

information relating to the factors used 

for screening design options. (NEMA, 

No. 54 at p. 13) 

Regarding NEMA’s request for a form 

for each technology option considered, 

today’s NOPR provides detailed 

information about each technology 

option considered and DOE is 

requesting comment on each option. 

DOE understands NEMA’s concerns 

about the technology options not 

screened out of the DOE analysis. With 

the exception of copper rotor motors, 

DOE understands that each technology 

option that it has not screened out is a 

design option that a manufacturer 

would consider in each motor designed 

and built. DOE recognizes that 

manufacturers design their motors to 

balance a number of competing factors 

that all inter-relate with each other, 

including performance, reliability, and 

energy efficiency. Because the options 

DOE has identified can be modified to 

improve efficiency while maintaining 

performance, it is DOE’s tentative view 

that at least some significant level of 

energy efficiency improvement is 

possible with each technology option 

not screened out by DOE. 

Furthermore, DOE notes that it did 

not explicitly use each of the technology 

options that passed the screening 

criteria in the engineering analysis. As 

discussed in section IV.C, DOE’s 

engineering analysis was a mixture of 

two approaches that DOE routinely uses 

in its engineering analysis methodology: 

The reverse-engineering approach (in 

which DOE has no control over the 

design parameters) and the efficiencylevel approach (in which DOE tried to 

achieve a certain level of efficiency, 

rather than applying specific design 

options). This hybrid of methods did 

not allow for DOE to fully control which 

design parameters were ultimately used 

for each representative unit in the 

analysis. Without the ability to apply 

specific design options, DOE could not 

include every option that was not 

screened out of the analysis. Finally, 

DOE appreciates NEMA’s comments 

regarding Appendix A to Subpart U of 

part 430. DOE has considered all 

comments related to the two factors 

identified by NEMA in its rule. 

In addition, DOE notes that its 

analysis neither assumes nor requires 

manufacturers to use identical 

technology for all motor types, 

horsepower ratings, or equipment 

classes. In other words, DOE’s standards 

are technology-neutral and permit 

manufacturers design flexibility. 

a. Copper Die-Cast Rotors 

Aluminum is the most common 

material used today to create die-cast 

rotor bars for electric motors. Some 

manufacturers that focus on producing 

high-efficiency designs have started to 

offer electric motors with die-cast rotor 

bars made of copper. Copper offers 

better performance than aluminum 

because it has better electrical 

conductivity (i.e., a lower electrical 

resistance). However, because copper 

also has a higher melting point than 

aluminum, the casting process becomes 

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36The equipment classes NEMA found included 

NEMA Design A motors from 1 to 30 hp, 4-pole 

configurations, and NEMA Design B motors from 

1.5 to 20 hp in a 2-pole configuration, 1 to 20 hp 

in a 4-pole configuration, and 1 hp and 3–10 hp in 

a 6-pole configuration. All motor configurations 

NEMA mentioned were enclosed frame motors. 

more difficult and is likely to increase 

both production time and cost. 

NEMA commented that performance 

is a relative term, and that the NEMA 

MG 1–2011 standard specifies 

performance characteristics and 

specifications for various types of 

motors. NEMA added that tradeoffs 

among various performance 

characteristics related to the 

conductivity of copper are required 

when designing a NEMA Design B 

electric motor that is in full 

conformance with the NEMA MG 1– 

2011 standards. NEMA commented that 

DOE did not address all aspects of 

motor performance specified in the 

NEMA MG 1–2011 standard, especially 

some of the performance requirements 

related to the choice of conductive 

material in the rotor. (NEMA, No. 54 at 

p. 46) 

DOE acknowledges that using copper 

in rotors may require different design 

approaches and considerations. In its 

own modeling and testing of copper 

rotor motors, DOE ensured that 

performance parameters stayed within 

MG 1–2011 limits (i.e., met NEMA 

Design B criteria). DOE seeks comment 

on any particular aspects of copper rotor 

design, especially those on parameters 

widely viewed as challenging to meet, 

and requests explanation of why such 

parameters are especially challenging 

when using copper. 

The Advocates (NEEA, NPCC, ACEEE, 

ASAP, Earthjustice, and ASE) disagreed 

with DOE’s tentative decision during 

the preliminary analysis phase to 

include copper die-cast rotors. It urged 

DOE to exclude this option in order to 

avoid analyzing a technology that is not 

ready for use across all motor types, 

configurations, and horsepower ratings 

that DOE would cover as part of its 

rulemaking. (Advocates, No. 56 at pp. 

3–4) 

On a related note, NEMA commented 

that DOE has not publicly established 

what determines a ‘‘mass quantity.’’ 

NEMA elaborated that a ‘‘mass 

quantity’’ should mean the ability to be 

produced in significant volume for the 

entire industry. NEMA commented that 

DOE screened out certain electrical 

steels because they could not be 

produced in significant volume for the 

entire industry, and this same logic 

should apply to copper rotor 

technology. (NEMA, No. 54 at p. 24) 

DOE did not screen out copper as a 

die-cast rotor conductor material 

because copper die-cast rotors passed 

the four screening criteria. Because 

copper is in commercial use today, DOE 

concluded that this material is 

technologically feasible and practicable 

to manufacture, install, and service. 

Additionally, manufacturers are already 

producing such equipment, which 

suggests that such equipment can be 

safely produced in mass quantities. For 

example, Siemens produces copper 

rotor motors for 1–20 hp and SEWEurodrive manufactures a full line of 

motors from 1–30 hp. In addition, DOE 

notes that its analysis neither assumes 

nor requires manufacturers to use 

identical technology for all motor types, 

horsepower ratings, or equipment 

classes. 

DOE received considerable feedback 

concerning copper rotor technology. 

Consequently, DOE has organized those 

comments into sections below as they 

pertain to the four screening criteria. 

Technological Feasibility 

As part of its analysis, DOE intends to 

ensure that utility, which includes 

frame size considerations, is 

maintained. Increased shipping costs 

are also taken into account in the 

national impact analysis (NIA) and the 

life-cycle cost (LCC) analysis portions of 

DOE’s analytical procedures. 

NEMA commented that the use of a 

technology in a limited subclass of 

electric motors does not imply that the 

technology can be applied to every 

equipment class covered in this 

rulemaking. NEMA is not aware of any 

available complete product line of 

NEMA Design A, B, or C copper die-cast 

rotor electric motors manufactured in 

the United States, and stated that further 

investigation is required to prove this 

technology is valid for an entire range 

of designs. (NEMA, No. 54 at pp. 2, 48, 

49) NEMA was able to find two 

manufacturers currently producing 

copper rotor motors in a total of only 33 

out of over 600 equipment classes 

covered in this rulemaking.36 NEMA 

and Baldor added that none of those 

motors are produced in the United 

States, and only about half of those 

ratings met NEMA Design B 

performance requirements. (NEMA, No. 

54 at pp. 48, 49; Baldor, Public Meeting 

Transcript, No. 60 at pp. 109, 110) 

NEMA commented that the diecasting process for copper rotors can 

increase core or stray load losses in the 

motor, and this is a problem with 

copper die-casting that has not been 

solved in all rotor sizes. (NEMA, No. 54 

at p. 46) 

NEMA cited recently conducted U.S. 

Army studies involving die-cast copper 

rotor motors. It explained that the first 

study evaluated the advantages of a diecast copper rotor versus an aluminum 

rotor. The study also attempted to 

optimize the process and estimate 

manufacturing costs for die-cast copper 

rotors. NEMA commented that the 

results of the study showed that the diecast copper rotor motor was unable to 

stay within the NEMA Design B lockedrotor current limits, and that efficiency 

increased by less than one full NEMA 

band over the comparable NEMA Design 

B aluminum cast-copper rotor motor. 

The study reported that continued 

investment in cast copper rotor motor 

technology development is needed to 

improve design optimization methods, 

improve the casting process, and to 

investigate utilization of cast copper in 

larger motor sizes. NEMA commented 

that the number of die-cast copper 

rotors manufactured in the study was 

insufficient to make any determination 

that die-casting could be performed on 

a high and consistent quality basis 

necessary for general production. 

(NEMA, No. 54 at p. 50, 51) 

NEMA also described a different U.S. 

Army study where a 75-hp aluminum 

rotor motor driving a pump was to be 

replaced with a 75-hp copper rotor 

motor. NEMA explained that in the 

study the die-cast copper rotor motor’s 

optimization study indicated the motor 

would have a one NEMA band increase 

in efficiency over the aluminum die-cast 

rotor motor it was replacing. However, 

once built, the 75-hp die-cast copper 

rotor motor had an actual efficiency of 

more than 1 NEMA band below the 

aluminum die-cast rotor motor, with 

core and stray load losses of the 

physical motor being higher than the 

computer model had predicted. NEMA 

concluded that neither study was 

successful in demonstrating that copper 

rotor die-casting technology is possible 

or feasible in its current state in the 

U.S., and that continued investment in 

die-cast copper rotor technology 

development is necessary to improve 

the copper die-casting process and 

reduce stray load losses. (NEMA, No. 54 

at pp. 51–53) 

BBF, a consulting company working 

on behalf of the Copper Development 

Association (CDA), commented that test 

data of multiple die-cast copper rotor 

motors resulted in an average tested 

efficiency above the motors’ nameplate 

efficiency, whereas the test results from 

a similar model aluminum rotor motor 

tested below its nameplate efficiency. In 

its view, these results fall within the 

allowable variances prescribed by 

NEMA with respect to measuring 

electric motor energy efficiency and 

demonstrate the higher energy 

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73618 Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 

37http://www.teslamotors.com/roadster/

technology/motor. 

38http://www.teslamotors.com/models/specs. 

39http://www.teslamotors.com/roadster/specs. 

40See http://www.coppermotor.com/wp-content/

uploads/2012/04/casestudy_army-truck.pdf. 

41http://www.remyinc.com/docs/hybrid/REM– 

12_HVH410_DataSht.pdf. 

42Available at: http://www.regulations.gov/

#!documentDetail;D=EERE-2010-BT-STD-0048- 

0762. 

43See General Atomics marine propulsion motor 

at: http://www.ga.com/electric-drive-motors. 

efficiency potential of die-cast copper 

rotor motors. (BBF, No. 51 at p. 3) 

NEMA summarized that it is not 

aware of any prototypes or 

commercially available products that 

have demonstrated the technical 

feasibility of utilizing die-cast copper 

rotors sufficient to cover all equipment 

classes covered in this rulemaking. 

NEMA disagreed with DOE’s conclusion 

that die-cast copper rotors successfully 

passed the screening criteria for 

technological feasibility relative to the 

class of all covered electric motors, 

including the 75-hp copper rotor motor 

which DOE used as a representative unit 

in the engineering analysis. NEMA 

added that DOE has not provided any 

evidence that die-casting copper can 

successfully be applied to all electric 

motors covered in this rulemaking by 

December 19, 2015. NEMA added that 

the recent studies conducted by the 

United States Army noted above 

showed that, in the U.S. at present or in 

any foreseeable future time, this 

technology is not currently feasible over 

the range of motor ratings regulated 

under this rulemaking. (NEMA, No. 54 

at pp. 3, 53, 56; NEMA, Public Meeting 

Transcript, No. 60 at p. 111) 

The CDA disagreed with NEMA, and 

stated that die-cast copper rotor motors 

are a feasible technology because 

manufacturers have already successfully 

entered the copper rotor motor market. 

The CDA added that a range of 

development issues have been 

overcome, again suggesting that it is 

technologically feasible, but copper diecast rotors require redesign and 

optimization to take advantage of 

copper’s different electrical properties 

compared to aluminum, and many 

motor manufacturers have undertaken 

this redesign and optimization to take 

advantage of the properties of copper. 

(BBF, No. 51 at p. 3) The CDA agreed, 

however, that current manufacturing 

capacity would be unable to produce 

motors on the scale of five million units 

yearly. (CDA, Public Meeting 

Transcript, No. 60 at p. 119) 

DOE acknowledges that the industry 

is not equipped to produce all motors 

with copper rotors, but has estimated 

the costs of both capital and product 

development through interviews with 

manufacturers of motors and included 

these costs in its engineering analysis. 

DOE welcomes comment on the 

methodology, and on the resulting 

motor prices. As noted earlier, EPCA, as 

amended, does not require 

manufacturers to use identical 

technology for all motor types, 

horsepower ratings, or equipment 

classes. 

DOE recognizes that assessing the 

technological feasibility of highhorsepower copper die-cast rotors is 

made more complex by the fact that 

manufacturers do not offer them 

commercially. That could be for a 

variety of reasons, among them: 

1. Large copper die-cast rotors are 

physically impossible to construct; 

2. They are possible to construct, but 

impossible to construct to required 

specifications; 

3. They are possible to construct to 

required specifications, but would 

require manufacturing capital 

investment to do so and be so costly that 

few (if any) consumers would choose 

them. 

Some exploratory research suggests 

that different organizations have 

developed and used copper rotors in 

high-horsepower traction (i.e., vehicle 

propulsion) motors. For example, Tesla 

Motors powers its Roadster 37 and 

Model S 38 vehicles with copper 

induction motors generating 300 39 or 

more peak horsepower and Oshkosh 

die-cast copper rotor induction motors 

rated at 140 peak hp.40 Remy 

International, Inc. (Remy) also builds 

high-horsepower copper motors that are 

claimed to exceed 300 horsepower at 

600V.41 DOE seeks comment on these, 

and on other high-horsepower motors 

that use copper rotors. 

DOE recognizes that these motors are 

designed for a different purpose than 

most motors in the current scope of this 

rulemaking. Their existence suggests 

that copper has been successfully used 

at high power levels in an application 

where efficiency is critical and casts 

doubt on the idea that copper die-cast 

rotors can be screened out with 

certainty. 

Another reason to be cautious about 

screening out copper die-cast rotors 

comes from an analogous product: 

Distribution transformers. DOE 

conducted a recent rulemaking on 

distribution transformers,42 which (as 

with motors) have two sets of 

conductors that surround electrical steel 

to transfer power. Although distribution 

transformers do not rotate, many of the 

ways that they lose energy (e.g., 

conductor losses) are the same as 

electric motors. They also face 

constraints (as motors do) on 

performance aspects unrelated to 

efficiency; inrush current and overall 

volume are two examples. At current 

prices, copper is generally not viewed as 

economical for most efficiency levels 

but, if properly designed, copper 

windings almost always result in 

smaller, cooler, and more efficient 

transformers. 

In general, copper may improve 

efficiency relative to aluminum because 

it carries an inherently higher level of 

electrical conductivity. Several 

organizations have conducted research 

and built prototype 43 motors that use 

materials even more conductive than 

copper, such as ‘‘superconductive’’ 

materials that have no conductive losses 

to achieve even greater electric motor 

efficiency. While DOE is not 

considering the use of these more 

conductive materials at this time, DOE 

notes their existence for purposes of 

demonstrating the potential advantages 

of using materials that lower conductive 

losses. 

While recognizing that motors are not 

transformers, the parallels that can be 

drawn leave DOE hesitant to screen out 

copper die-cast rotors on the basis of 

technological feasibility. Relative to the 

above list of possible reasons for their 

absence from the high-horsepower 

market, DOE’s analysis does not 

conclude copper die-cast rotors are 

either: (1) Physically impossible to 

construct or (2) possible to construct, 

but impossible to construct to required 

specifications. 

Practicability To Manufacture, Install, 

and Service 

Regarding DOE’s projections that the 

annual sales of electric motors, as 

defined by EISA 2007 will have grown 

to 5,089,000 units by 2015, including 

over 24,000 possible motor 

configurations, NEMA commented that 

only a single manufacturer is currently 

producing die-cast copper rotor motors, 

and in a very limited range. In its view, 

without sufficient data and analysis to 

support DOE’s conclusion that ‘‘mass 

production’’ of die-cast copper rotors is 

possible, NEMA asserts that this 

technology would not pass the 

screening criterion of practicability to 

manufacture, install, and service. It 

argues that, based on the limited 

advances of the technology from 1995 to 

present day in the United States, this 

technology is unlikely to be mature 

enough by the compliance date for this 

rulemaking to meet the required 

production of over 5 million motors in 

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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 73619 

44http://www.teslamotors.com/roadster/

technology/motor. 

45http://www.remyinc.com/docs/hybrid/REM-12_

HVH410_DataSht.pdf. 

46The parameters DOE believed to present the 

largest risk of rendering a motor noncompliant with 

NEMA MG 1–2011 standards were those related to 

NEMA design letter, which were adhered to in 

DOE’s modeling efforts. 

47http://minerals.usgs.gov/minerals/pubs/

commodity/copper/mcs-2012-coppe.pdf. 

48From the context of NEMA’s comment, DOE 

believes the use of the word ‘‘aluminum’’ was a 

typographical error and that NEMA had intended 

this passage to use the word ‘‘copper’’ instead. 

the U.S., even if all manufacturing were 

shifted overseas. (NEMA, No. 54 at pp. 

3, 47, 53, 54, 56; NEMA, Public Meeting 

Transcript, No. 60 at p. 114) NEMA 

noted that mandating this technology 

may also have the indirect effect of 

establishing a monopoly market in the 

U.S. for those manufacturers who can 

produce copper rotor motors, or to push 

production jobs overseas and penalize 

motor manufacturers that do not have 

the capability to produce copper rotor 

motors. (NEMA, No. 54 at p. 24) 

DOE recognizes the importance of 

maintaining a competitive market. 

However, because there are at least two 

domestic manufacturers of motors with 

copper rotors and because several more 

are manufacturing internationally, DOE 

believes the opportunity for price 

manipulation is limited. Furthermore, 

DOE has seen no evidence to suggest 

that a monopoly would be likely to 

occur. DOE requests comment and 

further information that would 

demonstrate the likelihood of a future 

monopoly. 

BBF and the CDA commented that 

there are copper die-casting facilities in 

the U.S.—specifically in Colorado and 

Ohio—as well as in Mexico. They added 

that die-cast rotor motors have been 

produced for North American service 

since 2005, and some of these motors 

meet NEMA Design B requirements. The 

CDA and BBF added that multiple highvolume manufacturers in Europe and 

Asia have produced tens of thousands of 

die-cast copper rotor motors that satisfy 

the NEMA-specified performance 

requirements that meet or exceed the 

NEMA Premium levels. These motors 

have been sold to North American users. 

(BBF, No. 51 at pp. 2, 3) DOE was able 

to purchase and tear down a 5-hp 

copper rotor motor from an Asian 

manufacturer that performed at DOE’s 

max-tech efficiency level, as well as the 

performance requirements for NEMA 

Design B. 

SEW Eurodrive stated that it offers 

only three models of cast-copper rotor 

motors and cited the expenses and 

difficulty of casting copper rotors as the 

reason why it does not offer more diecast copper rotor motor models. (SEWE, 

Public Meeting Transcript, No. 60 at p. 

121) The company did not elaborate 

why it manufactures die-cast copper 

rotor motors in the configurations it 

offers for sale. 

Based on these comments, DOE does 

not believe it has grounds to screen out 

copper die-cast rotors on the basis of 

practicability to manufacture, install, 

and service. The available facts indicate 

that manufacturers are already 

producing smaller motors with die-cast 

copper rotors, leaving the question of 

whether larger motors are being 

manufactured with die-cast copper 

rotors. DOE recognizes that as 

technology scales upward in size, it can 

require different equipment and 

processes. Nonetheless, Tesla’s 44 and 

Remy’s 45 300+ horsepower motors with 

copper rotors cast doubt on the assertion 

that copper is impracticable in this size 

range. 

DOE understands that full-scale 

deployment of copper would likely 

require considerable capital investment 

(see detailed discussion in 

SectionIV.J.2.a) and that such 

investment could increase the 

production cost of large copper rotor 

motors considerably. DOE believes that 

its current engineering analysis reflects 

this likelihood, and welcomes comment 

on this issue. 

Adverse Impacts on Equipment Utility 

or Equipment Availability 

NEMA commented that DOE failed to 

address the adverse impacts on 

equipment utility or availability caused 

by die-cast copper rotors. It asserted that 

the process for manufacturing die-cast 

copper rotors is underdeveloped, and 

energy conservation standards based on 

this technology, and implemented in 

2015, would result in product 

unavailability of over 99 percent of the 

electric motors that would be impacted 

if DOE were to set a standard that would 

require the use of die-cast copper. 

NEMA reiterated that there is no 

justification as to how motors that are 

not available today, made from a 

technology that is not practiced in the 

U.S. today, will become available within 

three years, especially when taking into 

account the time needed for 

prototyping, testing, and AEDM 

certification. (NEMA, No. 54 at pp. 3, 

47, 48, 54, 55, 56; NEMA, Public 

Meeting Transcript, No. 60 at pp. 114, 

115) 

NEMA also commented that it is 

difficult for die-cast copper rotor motors 

to stay under the maximum locked-rotor 

current limit for NEMA Design B 

motors. If this technology were adopted, 

in its view, many current NEMA Design 

B motors would become NEMA Design 

A motors. This would reduce the utility 

of a motor, because a NEMA Design A 

motor is not a direct drop-in place 

replacement for a NEMA Design B 

motor. (NEMA, No. 54 at p. 3) 

DOE agrees that, in some cases, 

redesigning product lines to use copper 

would entail substantial cost. DOE’s 

engineering analysis reflects its 

estimates of these costs and discusses 

them in detail in section IV.C. DOE was 

able to model copper rotor motors 

adhering to the specifications of NEMA 

Design B46, including the reduced 

(relative to Design A) locked-rotor 

current. 

Finally, based on DOE’s own 

shipments analysis (see TSD Chapter 9) 

and estimates of worldwide annual 

copper production,47 DOE estimates 

that .01-.02% of worldwide copper 

supply would be required to use copper 

rotors for every single motor within 

DOE’s scope of coverage. At the present, 

DOE does not believe there is sufficient 

evidence to screen copper die-cast 

rotors from the analysis on the basis of 

adverse impacts to equipment utility or 

availability. 

Adverse Impacts on Health or Safety 

NEMA commented that the 

preliminary TSD does not sufficiently 

explain how DOE concluded that 

mandating performance levels that 

would require copper rotor die-casting 

would not have an adverse impact on 

health or safety, with the implication 

being on occupational health and safety. 

NEMA commented that the preliminary 

TSD mentioned potential impacts on the 

health or safety caused by the higher 

melting point of copper, but DOE did 

not elaborate on what these potential 

impacts were. NEMA disagreed with 

DOE’s conclusion not to screen out diecast copper rotor technology on the 

premise that handling molten copper is 

similar to handling molten aluminum. 

NEMA noted that copper has a pouring 

temperature of 2100 degrees Fahrenheit 

and a 150 percent higher casting 

pressure than aluminum, and that, 

combined, these two characteristics 

would increase the severity of any 

potential accidents. NEMA mentions an 

incident involving the two U.S. Army 

die-cast copper rotor studies previously 

mentioned, which resulted in injuries 

during the die-casting of aluminum 48

[sic] cage rotors and caused the only 

U.S. manufacturer of copper die-casting 

equipment to withdraw that equipment 

from the market. NEMA added that the 

equipment currently remains 

unavailable for purchase. (NEMA, No. 

54 at pp. 10, 55, 56; NEMA, Public 

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49For a list, see: http://www.osha.gov/pls/imis/

citedstandard.sic?p_esize=&p_state=FEFederal&p_

sic=3364. 

50 In practice, of course, a manufacturer may opt 

to do either or both. 

Meeting Transcript, No. 60 at p. 115) 

NEMA added that, especially regarding 

die-casting copper on larger motor sizes, 

DOE cannot justifiably claim that there 

are no adverse impacts on health or 

safety until they conduct a thorough 

investigation or feasibility study 

regarding this topic. (NEMA, No. 54 at 

p. 3) 

However, BBF also commented that 

copper die-cast rotors can be safely 

manufactured, as one major 

manufacturer indicated that they have 

had no worker injuries in volume 

production over multiple years. (BBF, 

No. 51 at p. 3) 

BBF commented that, with the 

extensive capabilities of copper die-cast 

rotors and commercial availability of 

copper die-cast rotors with efficiencies 

higher than NEMA MG 1–2011 Table 

12–12 efficiencies, DOE should include 

in its evaluations copper die-cast rotor 

motors. BBF also added that they 

strongly disagree with the NEMA 

representatives’ contrary verbal 

suggestions towards copper rotor motor 

technology presented during the public 

meeting. (BBF, No. 51 at p. 4) 

DOE is aware of the higher melting 

point of copper (1084 degrees Celsius 

versus 660 degrees Celsius for 

aluminum) and the potential impacts 

this may have on the health or safety of 

plant workers. However, DOE does not 

believe at this time that this potential 

impact is sufficiently adverse to screen 

out copper as a die cast material for 

rotor conductors. The process for die 

casting copper rotors involves risks 

similar to those of die casting 

aluminum. DOE believes that 

manufacturers who die-cast metal at 660 

Celsius or 1085 Celsius (the respective 

temperatures required for aluminum 

and copper) would need to observe 

strict protocols to operate safely. DOE 

understands that many plants already 

work with molten aluminum die casting 

processes and believes that similar 

processes could be adopted for copper. 

DOE has not received any supporting 

data about the increased risks associated 

with copper die casting, and could not 

locate any studies suggesting that the 

die-casting of copper inherently 

represented incrementally more risks to 

worker safety and health. DOE notes 

that several OSHA standards relate to 

the safety of ‘‘Nonferrous Die-Castings, 

Except Aluminum,’’ of which die-cast 

copper is part. DOE seeks comment on 

any adverse safety or health impacts and 

on these OSHA standards,49 and on any 

other specific information document the 

safety of die-casting for both copper and 

aluminum. 

b. Increase the Cross-Sectional Area of 

Copper in the Stator Slots 

Increasing the slot fill by either 

adding windings or changing the gauge 

of wire used in the stator winding can 

also increase motor efficiency. Motor 

design engineers can achieve this by 

manipulating the wire gauges to allow 

for a greater total cross-sectional area of 

wire to be incorporated into the stator 

slots. This could mean either an 

increase or decrease in wire gauge, 

depending on the dimensions of the 

stator slots and insulation thicknesses. 

As with the benefits associated with 

larger cross-sectional area of rotor 

conductor bars, using more total crosssectional area in the stator windings 

decreases the winding resistance and 

associated losses. However, this change 

could affect the slot fill factor of the 

stator. The stator slot openings must be 

able to fit the wires so that automated 

machinery or manual labor can pull (or 

push) the wire into the stator slots. In 

the preliminary analysis, DOE increased 

the cross-sectional area of copper in the 

stator slots of the representative units by 

employing a combination of additional 

windings, thinner gauges of copper 

wire, and larger slots. 

In response to the preliminary 

analysis, NEMA commented that a 

majority of stator windings are 

manufactured on automated equipment. 

NEMA and Baldor noted that there is a 

practical limit of 82 percent slot fill for 

automated winding equipment for 

motors with four or more poles; motors 

with two poles have a limit of 78 

percent. (NEMA, No. 54 at p. 58; Baldor, 

Public Meeting Transcript, No. 60 at p. 

146) NEMA commented that the values 

for maximum slot fill for the automated 

winding models was approximately 82 

percent and those based on hand 

winding were 85 percent. NEMA noted 

that this is not a practical change based 

on a change in conductor size alone 

because conductors are sized in a larger 

increment than this difference would 

suggest. Therefore, it would appear that 

the size of the stator slot in each case 

was selected to purposely result in the 

corresponding level of slot fill. (NEMA, 

No. 54 at p. 59) In other words, instead 

of only adjusting the conductor gauge to 

the slot size, the slot size could be 

adjusted to the conductor gauge.50

(NEMA, No. 54 at p. 59) Baldor added 

that slot fills above 85 percent would be 

very difficult to do in current 

production volumes (5 million motors 

annually) and noted that this slot fill 

percentage was based on a DOEpresented software model and has not 

been proven in a prototype. (Baldor, 

Public Meeting Transcript, No. 60 at pp. 

146, 147) NEMA requested that DOE 

clarify the method it used for 

calculating slot fill to avoid confusion 

among other interested parties who may 

have used a different calculation 

method. (NEMA, No. 54 at p. 58) 

DOE calculated the slot fill by 

measuring the total area of the stator slot 

and then subtracting the cross sectional 

area for the slot insulation. This method 

gave DOE a net area of the slot available 

to house copper winding. DOE then 

identified the slot with the most 

windings and found the cross sectional 

area of the insulated copper wires to get 

the total copper cross sectional area per 

slot. DOE then divided the total copper 

cross sectional area by the total slot area 

to derive the slot fill. DOE’s estimated 

slot fills for its teardowns and software 

models are all provided in chapter 5 of 

the TSD. 

NEMA commented that several of 

DOE’s designs presented maximum 

values of slot fill at 85 percent, whereas 

the closest automated winding slot fill 

was 82-percent. NEMA questioned the 

significant benefit DOE projected in 

designing the stator slot such that a 

hand winding would be required to gain 

a 3-percent change in slot fill. In 

NEMA’s view, the change in core loss 

that might result from increasing the 

stator slot area by 3 percent would not 

be significant enough to warrant handwinding the stator. (NEMA, No. 54 at p. 

59) DOE notes that the software designs 

exhibiting these changes in slot fill were 

used when switching from aluminum to 

a copper rotor design. Therefore, 

changing slot geometries impacted the 

design’s slot fill and the slot fill changes 

resulted from different motor designs. 

Consequently, a 3 percent increase in 

slot fill does not imply that this change 

was made to increase the efficiency of 

another design, but could have been 

made to change other performance 

criteria of the motor, such as lockedrotor current. 

In the preliminary analysis, DOE 

indicated that motor design engineers 

can adjust slot fill by changing the gauge 

of wire used in fractions of half a gauge. 

NEMA commented that it did not 

understand DOE’s statement, and 

indicated that manufacturers limit the 

number of gauges used at any particular 

manufacturing plant, and few of those 

gauges are ‘‘fractions of a half a gauge.’’ 

NEMA added that manufacturers may 

use multiple wire gauges in a particular 

winding, but DOE’s examples in chapter 

5 gave no indication that any sizes other 

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than a single conductor size was used in 

each winding. (NEMA, No. 54 at pp. 58, 

59) DOE clarifies that all the modeled 

motors utilized standard AWG wire 

sizes, either whole- or half-gauge sizes 

(i.e., 18 or 181⁄2). DOE clarifies that the 

statement of ‘‘fractions of a half gauge’’ 

referred to sizes in between a whole 

gauge (i.e. 181⁄2 of a gauge is a fraction 

of 18 gauge wire). DOE did not end up 

using fractions consisting of a half gauge 

of wire sizes to conduct its modeling, 

but did indicate that this was a design 

option used by the motor industry. 

NEMA also commented that it is not 

uncommon for a manufacturer to use 

the same stator lamination design for all 

horsepower ratings built in the same 

NEMA MG 1–2011 Standard frame 

series. NEMA indicated that a high slot 

fill may require hand winding for one of 

the ratings and automated winding for 

the other rating, and that a good design 

practice for stator laminations will take 

into consideration more than just one 

motor rating to determine the best 

design for all ratings in that frame 

series. (NEMA, No. 54 at p. 59) 

NEMA and Baldor questioned DOE’s 

decision not to screen out hand-wound 

stators, and both parties commented 

that moving to hand-wound technology 

would be a reversal of the trend to 

automate manufacturing practices 

whenever possible. (NEMA, No. 54 at p. 

59; Baldor, Public Meeting Transcript, 

No. 60 at pp. 122, 123) NEMA noted 

that none of the teardown motors in 

DOE’s analysis appeared to use hand 

winding technology. (NEMA, No. 54 at 

p. 59) 

While NEMA agrees that hand 

winding cannot be ruled out on the 

grounds of technological feasibility, it 

does believe that hand winding would 

not be practicable to use in mass 

production. A NEMA member survey 

indicated that hand winding can take up 

to 25 times longer than machine 

winding. NEMA added that the 

manpower required to replace 

automated winding would require an 

increase in manpower in excess of 20 

times the number of automated 

machines. (NEMA, No. 54 at p. 60) 

NEMA and Baldor commented that 

moving to an energy conservation level 

based on hand-wound technology 

would not be achievable on the scale 

necessary to serve the relevant market at 

the time of the effective date of the 

standard. (NEMA, No. 54 at p. 60; 

Baldor, Public Meeting Transcript, No. 

60 at p. 123) NEMA added that it would 

not be aware if such an expansion of the 

infrastructure would be required until 

after any amended or new standards are 

announced. (NEMA, No. 54 at p. 60) 

DOE is aware of the extra time involved 

with hand winding and has attempted 

to incorporate this time into efficiency 

levels (ELs) that it believes would 

require hand winding. DOE reiterates 

that should the increase in 

infrastructure, manpower, or motor cost 

increase beyond a reasonable means, 

then ELs utilizing this technology will 

be screened out during the downstream 

analysis. 

NEMA also expressed concern that 

standards based on hand winding 

would shift U.S. manufacturing jobs to 

locations outside of the U.S. which have 

lower labor rates, and Nidec added that 

most U.S. manufacturers are currently 

globally positioned to move laborintensive work into low-cost labor 

countries if energy conservation 

requirements force them to do so. 

(Nidec, Public Meeting Transcript, No. 

60 at p. 124) DOE intends to fully 

capture this impact during the 

manufacturer impact analysis (MIA) 

portion of DOE’s analysis. Please see 

section IV.J for a discussion of the 

manufacturer impact analysis. 

NEMA also commented that handwound technology would have an 

adverse impact on product utility or 

product availability, saying that the 

infrastructure would not be in place in 

sufficient time to support the hand 

winding of all of the stators, and there 

will be an adverse impact on the 

availability of various ratings of electric 

motors at the time of effective standards. 

(NEMA, No. 54 at p. 60) 

NEMA commented that hand winding 

would have adverse impacts on worker 

health or safety, as both hand winding 

and hand insertion of stator coils 

require operations performed by hand 

with repetitive motions, and such hand 

winding of stators also involves the 

moving and lifting of various stator and 

winding components, which may be of 

substantial size in larger horsepower 

rated electric motors. NEMA added that 

any increase in personnel performing 

the repetitive tasks required by hand 

winding can have an adverse effect on 

the overall health and safety record of 

any facility. (NEMA, No. 54 at p. 60; 

NEMA, Public Meeting Transcript, No. 

60 at p. 123) 

DOE disagrees with NEMA’s assertion 

concerning the adverse impacts on 

health or safety, and notes that hand 

winding is currently practiced by 

industry. Furthermore, DOE is not 

aware of any data or studies suggesting 

hand-winding leads to negative health 

consequences. DOE acknowledges that, 

were hand-winding to become 

widespread, manufacturers would need 

to hire more workers to perform handwinding to maintain person-windinghour equivalence, and has accounted for 

the added costs of hand-winding in its 

engineering analysis. DOE requests 

comment on its cost estimates for handwound motors, as well as on the matter 

of hand-winding in general and on 

studies suggesting negative health 

impacts in particular. 

NEMA summarized its concerns, 

saying that hand winding is not a viable 

technology option, especially for a slot 

fill increase of less than 5 percent. 

NEMA believes that the engineering 

analysis should not be based on stator 

slot fill levels which require hand 

winding, which are generally slot fills 

above 78 percent for 2-pole motor and 

82 percent for 4-, 6-, and 8-pole motors. 

(NEMA, No. 54 at p. 60) 

DOE acknowledges that the industry 

is moving towards increased 

automation. However, hand winding is 

currently practiced by manufacturers, 

making it a viable option for DOE to 

consider as part of its engineering 

analysis. Considering the four screening 

criteria for this technology option, DOE 

did not screen out the possibility of 

changing gauges of copper wire in the 

stator as a means of improving 

efficiency. Motor design engineers 

adjust this option by using different 

wire gauges when manufacturing an 

electric motor to achieve desired 

performance and efficiency targets. 

Because this design technique is in 

commercial use today, DOE considers 

this technology option both 

technologically feasible and practicable 

to manufacture, install, and service. 

DOE is not aware of any adverse 

impacts on consumer utility, reliability, 

health, or safety associated with 

changing the wire gauges in the stator to 

obtain increased efficiency. Should the 

technology option prove to not be 

economical on a scale necessary to 

supply the entire industry, then this 

technology option would be likely not 

be selected for in the analysis, either in 

the LCC or MIA. 

DOE seeks comment generally on the 

process of increasing the cross-section 

of copper in the stator, and in particular 

on the costs and reliability of the hand 

winding process. 

2. Technology Options Screened Out of 

the Analysis 

DOE developed an initial list of 

design options from the technologies 

identified in the technology assessment. 

DOE reviewed the list to determine if 

the design options are practicable to 

manufacture, install, and service; would 

adversely affect equipment utility or 

equipment availability; or would have 

adverse impacts on health and safety. In 

the engineering analysis, DOE did not 

consider any of those options that failed 

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to satisfy one or more of the screening 

criterion. The design options screened 

out are summarized in Table IV.8. 

TABLE IV.8—DESIGN OPTIONS

SCREENED OUT OF THE ANALYSIS

Design option 

excluded 

Eliminating screening 

criterion 

Plastic Bonded Iron 

Powder (PBIP).

Technological Feasibility. 

Amorphous Steels ..... Technological Feasibility. 

NEMA agreed with DOE in that 

plastic bonded iron powder has not 

been proven to be a technologically 

feasible method of construction of stator 

and rotor cores in induction motors. 

(NEMA, No. 54 at p. 64) NEMA also 

agreed that amorphous metal 

laminations are not a type of material 

that lends itself to use in electric motors 

in the foreseeable future. However, 

NEMA expressed concern that this 

technology was only screened out on 

the basis of technological feasibility 

because it had not been used in a 

prototype. (NEMA, No. 54 at p. 63) 

Baldor and NPCC also agreed with 

DOE’s decision to exclude PBIP and 

amorphous steels from the engineering 

analysis. (Baldor, Public Meeting 

Transcript, No. 60 at p. 108; Advocates, 

No. 56 at p. 3) 

DOE is continuing to screen out both 

of these technology options from further 

consideration in the engineering 

analysis. Additionally, DOE 

understands the concerns expressed by 

NEMA regarding technological 

feasibility, but DOE maintains that if a 

working prototype exists, which implies 

that the motor has performance 

characteristics consistent with other 

motors using a different technology, 

then that technology would be deemed 

technologically feasible. However, that 

fact would not necessarily mean that a 

technology option would pass all three 

of the remaining screening criteria. 

Chapter 4 of this preliminary TSD 

discusses each of these screened out 

design options in more detail, as well as 

the design options that DOE considered 

in the electric motor engineering 

analysis. 

C. Engineering Analysis 

The engineering analysis develops 

cost-efficiency relationships for the 

equipment that are the subject of a 

rulemaking by estimating manufacturer 

costs of achieving increased efficiency 

levels. DOE uses manufacturing costs to 

determine retail prices for use in the 

LCC analysis and MIA. In general, the 

engineering analysis estimates the 

efficiency improvement potential of 

individual design options or 

combinations of design options that 

pass the four criteria in the screening 

analysis. The engineering analysis also 

determines the maximum 

technologically feasible energy 

efficiency level. 

When DOE proposes to adopt a new 

or amended standard for a type or class 

of covered product, it must determine 

the maximum improvement in energy 

efficiency or maximum reduction in 

energy use that is technologically 

feasible for such product. (42 U.S.C. 

6295(p)(1)) Accordingly, in the 

engineering analysis, DOE determined 

the maximum technologically feasible 

(‘‘max-tech’’) improvements in energy 

efficiency for electric motors, using the 

design parameters for the most efficient 

products available on the market or in 

working prototypes. (See chapter 5 of 

the NOPR TSD.) The max-tech levels 

that DOE determined for this 

rulemaking are described in IV.C.3 of 

this proposed rule. 

In general, DOE can use three 

methodologies to generate the 

manufacturing costs needed for the 

engineering analysis. These methods 

are: 

(1) The design-option approach— 

reporting the incremental costs of 

adding design options to a baseline 

model; 

(2) the efficiency-level approach— 

reporting relative costs of achieving 

improvements in energy efficiency; and 

(3) the reverse engineering or cost 

assessment approach—involving a 

‘‘bottoms up’’ manufacturing cost 

assessment based on a detailed bill of 

materials derived from electric motor 

teardowns. 

1. Engineering Analysis Methodology 

DOE’s analysis for the electric motor 

rulemaking is based on a combination of 

the efficiency-level approach and the 

reverse engineering approach. Primarily, 

DOE elected to derive its production 

costs by tearing down electric motors 

and recording detailed information 

regarding individual components and 

designs. DOE used the costs derived 

from the engineering teardowns and the 

corresponding nameplate nominal 

efficiency of the torn down motors to 

report the relative costs of achieving 

improvements in energy efficiency. DOE 

derived material prices from current, 

publicly available data as well as input 

from subject matter experts and 

manufacturers. For most representative 

units analyzed, DOE was not able to test 

and teardown a max-tech unit because 

such units are generally cost-prohibitive 

and are not readily available. Therefore, 

DOE supplemented the results of its test 

and teardown analysis with software 

modeling. 

When developing its engineering 

analysis for electric motors, DOE 

divided covered equipment into 

equipment class groups. As discussed, 

there are four electric motor equipment 

class groups: NEMA Design A and B 

motors (ECG 1), NEMA Design C motors 

(ECG 2), fire pump electric motors (ECG 

3), and brake motors (ECG 4). The 

motors within these ECGs are further 

divided into equipment classes based on 

pole-configuration, enclosure type, and 

horsepower rating. For DOE’s 

rulemaking, there are 580 equipment 

classes. 

2. Representative Units 

Due to the high number of equipment 

classes for electric motors, DOE selected 

and analyzed only a few representative 

units from each ECG and based its 

overall analysis for all equipment 

classes within that ECG on those 

representative units. During the NOPR 

analysis, DOE selected three units to 

represent ECG 1 and two units to 

represent ECG 2. DOE based the analysis 

of ECG 3 on the representative units for 

ECG 1 because of the low shipment 

volume and run time of fire pump 

electric motors. DOE also based the 

analysis of ECG 4 on the analysis of ECG 

1 because the vast majority of brake 

motors are NEMA Design B motors. 

When selecting representative units for 

each ECG, DOE considered NEMA 

design type, horsepower rating, poleconfiguration, and enclosure. 

a. Electric Motor Design Type 

For ECG 1, which includes all NEMA 

Design A and B motors that are not fire 

pump or brake motors, DOE only 

selected NEMA Design B motors as 

representative units to analyze in the 

preliminary analysis engineering 

analysis. DOE chose NEMA Design B 

motors because NEMA Design B motors 

have slightly more stringent 

performance requirements, namely their 

locked-rotor current has a maximum 

allowable level for a given rating. 

Consequently, NEMA Design B motors 

are slightly more restricted in terms of 

their maximum efficiency levels. 

Therefore, by analyzing a NEMA Design 

B motor, DOE could ensure 

technological feasibility for all designs 

covered in ECG 1. Additionally, NEMA 

Design B units have much higher 

shipment volumes than NEMA Design A 

motors because most motor driven 

equipment is designed (and UL listed) 

to run with NEMA Design B motors. 

NEMA agreed with DOE’s decision to 

base any amended or new standards for 

ECG 1 motors on NEMA Design B motor 

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51With the exception of having a thermal shutoff 

switch, which could prevent a fire pump motor 

from performing its duty in hot conditions, NFPA 

20 also excludes several motor types not considered 

in this rulemaking from the NEMA Design B 

requirement. They are direct current, high-voltage 

(over 600 V), large-horsepower (over 500 hp), 

single-phase, universal-type, and wound-rotor 

motors. 

types because consumers generally 

prefer NEMA Design B motors due to 

the fact that locked-rotor current is 

constrained to established industry 

standards in these motors, making it 

easier to select suitable motor-starting 

devices. NEMA pointed out that, on the 

other hand, the use of a NEMA Design 

A motor may require the purchaser of 

the motor to expend a significant 

amount of time and expense in selecting 

suitable motor-starting devices to 

operate the motor in an appropriate and 

safe manner. NEMA elaborated that it is 

important to base the analysis on NEMA 

Design B motors in order to minimize 

any disruption to consumers based on 

their preference for NEMA Design B. 

(NEMA, No. 54 at p. 64) DOE 

appreciates NEMA’s feedback. For its 

NOPR engineering analysis, DOE has 

continued to select NEMA Design B 

motors as its representative units in 

ECG 1. 

As mentioned for ECG 2, DOE 

selected two representative units to 

analyze. Because NEMA Design C is the 

only NEMA design type covered by this 

ECG, DOE only selected NEMA Design 

C motors as its representative units. 

For ECG 3, which consists of fire 

pump electric motors, DOE based its 

engineering analysis on the NEMA 

Design B units analyzed for ECG 1 in the 

preliminary analysis. As noted, in order 

to be in compliance with section 9.5 of 

National Fire Protection Association 

(NFPA) ‘‘Standard for the Installation of 

Stationary Pumps for Fire Protection’’ 

Standard 20–2010, which is a 

requirement for a motor to meet DOE’s 

current definition of a fire pump electric 

motor, the motor must comply with 

NEMA Design B (or IEC Design N) 

requirements.51 Although DOE 

understands that fire pump electric 

motors have additional performance 

requirements, DOE believed that 

analysis of the ECG 1 motors would 

serve as a sufficient approximation for 

the cost-efficiency relationship for fire 

pump electric motors. The design 

differences between a NEMA Design B 

motor (or IEC-equivalent) and fire pump 

electric motor are small and unlikely to 

greatly affect incremental cost behavior. 

NEMA disagreed with DOE’s assertion 

that fire pump electric motors are 

required to meet NEMA Design B 

standards, and commented that, as 

defined in 10 CFR 431.12, fire pump 

electric motors are not limited to NEMA 

Design B performance standards. NEMA 

requested that DOE clarify DOE’s 

statement in the preliminary analysis 

that currently, efficiency standards have 

only been established for fire pump 

electric motors that are NEMA Design B. 

(NEMA, No. 54 at p. 25) NEMA also 

commented that the additional 

performance requirements for fire pump 

electric motors (e.g., the ability to 

withstand stall conditions for longer 

periods of time) mean they are usually 

designed with lower locked-rotor 

current limits. Therefore, NEMA stated 

that fire pump electric motors may have 

a maximum efficiency potential slightly 

lower than typical, general purpose 

NEMA Design B motors. (NEMA, No. 54 

at pp. 24–25, 40, 64, 70; NEMA, Public 

Meeting Transcript, No. 60 at pp. 135, 

136) NEMA added that they support 

DOE’s decision to analyze fire pump 

motors in a separate equipment class 

group because of the short run time of 

fire pump electric motors. (NEMA, No. 

54 at p. 71) 

Regarding DOE’s fire pump electric 

motor definition, as detailed in the final 

electric motors test procedure, DOE 

intends its fire pump electric motor 

definition to cover both NEMA Design 

B motors and IEC-equivalents that meet 

the requirements of section 9.5 of NFPA 

20. See 77 FR 26617–18. As stated in the 

final electric motors test procedure, 

DOE agrees with stakeholders that IECequivalent motors should be included 

within the scope of the definition of 

‘‘fire pump electric motor,’’ although 

NFPA 20 does not explicitly recognize 

the use of IEC motors with fire pumps. 

77 FR 26617. DOE realizes that section 

9.5 of NFPA 20 specifically requires that 

fire pump motors shall be marked as 

complying with NEMA Design B. The 

fire pump electric motor definition that 

DOE created focuses on ensuring that 

compliance with the energy efficiency 

requirements are applied in a consistent 

manner. DOE believes that there are IEC 

motors that can be used in fire pump 

applications that meet both NEMA 

Design B and IEC Design N criteria, as 

well as NEMA MG1 service factors. 

DOE’s definition encompasses both 

NEMA Design B motors and IECequivalents. To the extent that there is 

any ambiguity as to how DOE would 

apply this definition, in DOE’s view, 

any Design B or IEC-equivalent motor 

that otherwise satisfies the relevant 

NFPA requirements would meet the fire 

pump electric motor definition in 10 

CFR 431.12. To the extent that there is 

confusion regarding this view, DOE 

invites comments on this issue, along 

with any data demonstrating whether 

any IEC-equivalent motors are listed for 

fire pump service either under the 

NFPA 20 or another relevant industry 

standard. 

Regarding NEMA’s other fire pump 

electric motor comment, DOE agrees 

that some fire pump electric motors may 

not be required to meet the NEMA 

Design B performance requirements (or 

IEC-equivalent comments). However, 

those motors that are not required to 

meet the NEMA Design B performance 

requirements are direct-current motors, 

motors with high voltages (i.e., greater 

than 600 V), motors with high 

horsepower ratings (i.e., greater than 

500 horsepower), single-phase motors, 

universal-type motors, or wound-rotor 

motors. Any motor with such attributes 

would not meet the nine motor 

characteristics that define the scope of 

electric motors covered in this 

rulemaking. Additionally, any fire 

pump electric motor that is not rated for 

continuous duty is not, and would not 

be, covered by the scope of today’s 

rulemaking. Therefore, DOE clarifies 

that any fire pump electric motor 

currently subject to, or potentially 

subject to, energy conservation 

standards as a result of this rulemaking, 

would have to meet the NEMA Design 

B (or IEC-equivalent) performance 

requirements. As indicated above, DOE 

seeks comment on whether its current 

regulatory definition requires further 

clarification. 

Additionally, DOE understands 

NEMA’s comments regarding the 

potential limitations of fire pump 

electric motors. However, DOE believes 

that its approximation, by using the 

NEMA Design B electric motors from 

ECG 1 is sufficient, at this time. In 

DOE’s preliminary analysis, DOE found 

that all efficiency levels analyzed for 

fire pump electric motors resulted in 

negative life-cycle cost savings for 

consumers and a negative net present 

values for the Nation. This was the 

result of extremely low operating hours 

and therefore, limited energy cost 

savings potential. DOE notes that there 

are minimal shipments and no 

efficiency levels are likely to be deemed 

economically justifiable. 

Additionally, DOE understands that 

fire pump motors are similar in both 

performance and architecture to NEMA 

Design B motors, the chief difference 

being the absence of thermal cutoff 

capability that would render a fire 

pump motor unable to perform its 

function in a hot environment. For 

compliance purposes, however, the 

distinction is less important. DOE 

welcomes comment on the similarity 

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52 ‘‘D’’ dimension is the length from the centerline 

of the shaft to the mounting feet of the motor, and 

impacts how large the motor’s laminations can be, 

impacting the achievable efficiency of the motor. 

‘‘D’’ dimensions are designated in NEMA MG 1– 

2011 Section 4.2.1, Table 4–2. 

between fire pump and NEMA Design B 

motors. 

Equipment class group 4, consisting 

of brake motors, is also based on ECG 

1 because DOE is only aware of brake 

motors being built to NEMA Design B 

specifications. Furthermore, DOE 

understands that there is no 

fundamental difference in design 

between brake and non-brake electric 

motors, other than the presence of the 

brake. Therefore, the same design 

options could be used on both sets of 

electric motors and both motor types are 

likely to exhibit similar cost versus 

efficiency relationships. 

For the final rule, DOE may consider 

combining ECGs 1 and 4 again, as was 

done for the preliminary analysis, but 

such a decision depends, in part, on the 

outcome of its concurrent electric 

motors test procedure rulemaking. 

Currently, DOE believes that its 

proposed approach to testing brake 

motors will mitigate the impact of the 

brake component’s contributions to 

motor losses such that the demonstrated 

efficiency would be the same as if the 

motor had been tested with the brake 

completely removed (essentially making 

it no different from the motors covered 

by ECG 1). (See 78 FR 38467) With this 

approach, a separate ECG would not be 

necessary. 

b. Horsepower Rating 

Horsepower rating is an important 

equipment class setting criterion. When 

DOE selected its preliminary analysis 

representative units, DOE chose those 

horsepower ratings that constitute a 

high volume of shipments in the market 

and provide a wide range upon which 

DOE could reasonably base a scaling 

methodology. For NEMA Design B 

motors, for example, DOE chose 5-, 

30-, and 75-horsepower-rated electric 

motors to analyze as representative 

units. DOE selected the 5-horsepower 

rating because these motors have the 

highest shipment volume of all motors. 

DOE selected the 30-horsepower rating 

as an intermediary between the small 

and large frame number series electric 

motors. Finally, DOE selected a 75- 

horsepower unit because there is 

minimal variation in efficiency for 

motors with horsepower ratings above 

75-horsepower. Based on this fact, DOE 

determined it was unnecessary to 

analyze a higher horsepower motor. 

Additionally, as horsepower levels 

increase, shipments typically decrease. 

Therefore, DOE believed there would be 

minimal gains to its analysis had it 

examined a higher horsepower 

representative unit. 

During the public meeting, Baldor 

commented that the representative units 

should have been selected based on 

energy consumption and not shipment 

numbers. Baldor indicated that using 

this approach, the 10-horspower motor 

would have been designated as a 

representative unit rather than the 5- 

horsepower motors. (Baldor, Public 

Meeting Transcript, No. 58 at p. 132, 

133) NEMA reiterated Baldor’s stance in 

its submitted comments, saying that the 

5-horsepower motor would not appear 

to be the only choice for the 

representative unit. (NEMA, No. 54 at 

p. 65) NEMA and Baldor also 

commented that there are motors built 

in frame series larger than the standard 

75-horsepower frame series and DOE 

should select a motor built in the largest 

NEMA MG 1 frame series as a 

representative unit. (NEMA, No. 54 at 

p. 65; Baldor, Public Meeting 

Transcript, No. 60 at p. 133) NEMA 

added that efficiency ratings start to 

level off once horsepower ratings exceed 

150-horsepower, not above 75- 

horsepower. Therefore, they argued that 

selecting a horsepower rating above 150- 

horsepower would have been a better 

indicator if the perceived increase in 

efficiency calculated for lower 

horsepower ratings would be achievable 

by larger horsepower ranges. (NEMA, 

No. 54 at pp. 27, 65) Baldor reiterated 

this comment in the preliminary 

analysis public meeting. (Baldor, Public 

Meeting Transcript, No. 60 at pp. 133– 

134) 

While DOE agrees with NEMA that 

the 5-horsepower electric motor was not 

the only choice for the representative 

unit, it selected the 5-horsepower motor 

for multiple reasons. The 5-horsepower 

unit had the highest percentage of 

shipments for all covered electric 

motors, which ensured that there would 

be multiple efficiency levels from 

multiple manufacturers available for 

comparison during the teardown 

analysis. In addition, because DOE later 

employed scaling, it attempted to find a 

frame series and D-dimension 52 that 

could serve as a strong basis from which 

to scale to a relatively small set of 

unanalyzed frame series. The standard 

NEMA MG 1–2011 frame series for the 

5-horsepower enclosed motor was a 

midpoint between the standard frame 

series for 1 horsepower and 10- 

horsepower motors, which was the 

group of ratings covered by the 5- 

horsepower representative unit. A larger 

representative unit would have meant a 

larger range of frame series on which to 

apply the scaling methodology. 

As to DOE’s selection of the 75- 

horsepower representative unit as a 

maximum, DOE understands that the 

75-horsepower motor is not built in the 

largest NEMA MG 1–2011 frame series 

covered, but maintains that its selection 

is appropriate for this analysis. As 

stated previously, efficiency changes 

slowly when approaching the highest 

horsepower ratings, and choosing a 

higher horsepower rating would not 

have provided any appreciable 

improvement over the data DOE already 

developed for its analysis. DOE has 

found minimal variation in efficiency 

for motors above 75-horsepower. 

Because the change in efficiency 

diminishes with increasing horsepower, 

one may achieve a similar level of 

analytical accuracy with fewer data 

points at higher horsepower. Stated 

inversely, one needs more data points to 

accurately characterize a curve where it 

has a greater rate of change, such as 

lower horsepower. Finally, DOE notes 

that its scaling methodology mirrors the 

scaling methodology used in NEMA’s 

MG 1–2011 tables of efficiencies, 

including the rate of change in 

efficiency with horsepower. 

DOE also notes that section 13 of 

NEMA MG 1–2011 does not standardize 

frame series for NEMA Design B motors 

at the highest horsepower levels covered 

in today’s proposal. Therefore, motors 

with the highest capacity have 

variability in their frame series. This 

added flexibility would give 

manufacturers more options to improve 

the efficiency of their largest motors 

covered by this rulemaking. Although 

altering the frame size of a motor may 

be costly, DOE believes that its selection 

of a 75-hp representative unit for higher 

horsepower motors is appropriate for 

scaling higher horsepower efficiency 

levels and the efficiency levels 

examined are technologically feasible 

for the largest capacity motors. 

For NEMA Design C electric motors, 

DOE again selected the 5-horsepower 

rating because of its prevalence. In 

addition, DOE selected a 50-horsepower 

rating as an incrementally higher 

representative unit. DOE only selected 

two horsepower ratings for these electric 

motors because of their low shipment 

volumes. For more information on how 

DOE selected these horsepower ratings 

see chapter 5 of the TSD. 

In submitted comments, NEMA 

expressed confusion over DOE’s 

selection of the 50-horsepower 

representative unit for the NEMA 

Design C equipment class group. NEMA 

stated that the NEMA T-frame size for 

such a rating is 326T, which is three 

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NEMA T-frame number series below the 

largest frame number series of 440. 

NEMA requested that DOE clarify why 

it limited its NEMA Design C 

representative unit to such a low value 

in its engineering analysis. (NEMA, No. 

54 at p. 66) Finally, NEMA commented 

that the 2011 shipment data that DOE 

used to select its representative units 

was not broken down by NEMA design 

type. NEMA believed that using such 

data to select representative units for 

ECGs 1 and 2 was not appropriate and 

requested clarification. (NEMA, No. 54 

at p. 66) 

As with ECG 1, DOE selected 

representative units that fell in the 

middle of the range of ratings covered 

in this rulemaking and not necessarily 

the largest frame size covered in the 

rulemaking. Furthermore, as discussed 

earlier, NEMA Design C motors are 

produced in a smaller range of 

horsepower ratings than NEMA Design 

B motors (1 to 200 rather than 1 to 500). 

With this smaller horsepower range, a 

correspondingly smaller range of 

representative units is needed. 

Therefore, DOE selected a slightly lower 

rating as its maximum for ECG 2. As for 

the shipments data used to select the 5- 

hp representative unit, DOE 

acknowledges that it did not separate 

the data by design type, and has revised 

the text for the NOPR’s TSD to add 

clarity. However, DOE still maintains 

that the prevalence of 5-hp units make 

it an appropriate selection as a 

representative unit. 

c. Pole-Configuration 

Pole-configuration is another 

important equipment class setting 

criterion that DOE had to consider when 

selecting its representative units. For the 

preliminary analysis, DOE selected 4- 

pole motors for all of its representative 

units. DOE chose 4-pole motors because 

they represent the highest shipment 

volume of motors compared to other 

pole configurations. DOE chose not to 

alternate between pole configurations 

for its representative units because it 

wanted to keep as many design 

characteristics constant as possible. By 

doing so, it would allow DOE to more 

accurately identify how design changes 

affect efficiency across horsepower 

ratings. Additionally, DOE believed that 

the horsepower rating-versus-efficiency 

relationship is the most important 

(rather than pole-configuration and 

enclosure type-versus-efficiency) 

because there are significantly more 

horsepower ratings to consider. 

NEMA noted that efficiency gains 

based on a 4-pole configuration do not 

confirm that those same gains are 

achievable in other pole configurations, 

and there is no foundation for scaling 

across different pole configurations. 

NEMA added that it is necessary to 

know how designs change with respect 

to pole-configuration, and analyzing 

samples of one pole configuration limits 

the ability to make decisions based on 

other pole-configurations. NEMA 

commented that designs significantly 

vary across pole-configurations, 

especially regarding torque 

characteristics. (NEMA, No. 54 at pp. 

26, 66–67) NEMA also stated that the 

purpose of the engineering analysis is 

not necessarily to determine the 

‘‘reasons for efficiency improvements,’’ 

but to determine if efficiency can be 

improved in accordance with meeting 

the requirements of being 

technologically feasible and 

economically justified per 42 U.S.C. 

6295(o)(A) and (B). (NEMA, No. 54 at p. 

26) Baldor also commented on scaling 

across pole configurations, saying that 

the rotor diameter grows as the pole 

number increases, which may cause 

higher losses in 2-pole motors compared 

to other pole configurations covered in 

this rulemaking. (Baldor, Public Meeting 

Transcript, No. 60 at pp. 130, 131) 

As mentioned earlier, DOE is 

assessing energy conservation standards 

for 580 equipment classes. Analyzing 

each of the classes individually is not 

feasible, which requires DOE to select 

representative units on which to base its 

analysis. DOE understands that different 

pole-configurations have different 

design constraints. Originally, DOE 

selected only 4-pole motors to analyze 

because they were the most common, 

allowing DOE to most accurately 

characterize motor behavior at the pole 

configuration consuming the majority of 

motor energy. Additionally, by holding 

pole-configuration constant across its 

representative units, DOE would be able 

to develop a baseline from which to 

scale. By maintaining this baseline and 

holding all other variables constant, 

DOE is able to modify the horsepower 

of the various representative units and 

isolate which efficiency effects are due 

to size. 

As discussed in section IV.C.8, DOE 

has used the simpler of two scaling 

approaches presented in the preliminary 

analysis because both methods had 

similar results. This simpler approach 

does not require DOE to develop a 

relationship for 4-pole motors from 

which to scale. Furthermore, DOE notes 

that the scaling approach it selected 

mirrors the scaling laid out in NEMA’s 

MG 1–2011 tables, in which at least a 

subset of the motors industry has 

already presented a possible 

relationship between efficiency and 

pole count. DOE has continued to 

analyze 4-pole electric motors because 

they are the most common and DOE 

believes that all of the efficiency levels 

it has developed are technologically 

feasible. 

d. Enclosure Type 

The final equipment class setting 

criterion that DOE considered when 

selecting its representative units was 

enclosure type. For the preliminary 

analysis, DOE elected to analyze electric 

motors with enclosed designs rather 

than open designs for all of its 

representative units. DOE selected 

enclosed motors because, as with poleconfigurations, these motors have higher 

shipments than open motors. Again, 

DOE did not alternate between the two 

design possibilities for its representative 

units because it sought to keep design 

characteristics as constant as possible in 

an attempt to more accurately identify 

the reasons for efficiency improvements. 

NEMA commented that DOE’s 

analysis did not consider the 

significance of enclosure type as it 

relates to efficiency, and that the NEMA 

MG 1 frame designations for open frame 

motors are often in a smaller frame 

series than an enclosed-frame motor of 

the same horsepower rating. NEMA and 

Baldor commented that there is 

generally a lower efficiency level 

designated for open-frame motors, and 

that there is no direct scaling 

relationship between the efficiency 

standards for open motors relative to 

enclosed frame motors in the scope of 

this rulemaking. (NEMA, No. 54 at p. 

68; Baldor, Public Meeting Transcript, 

No. 60 at p. 131) Baldor recommended 

that DOE analyze motors of different 

enclosures in order to understand the 

difference between achievable efficiency 

levels in open and enclosed electric 

motors. (Baldor, Public Meeting 

Transcript, No. 60 at pp. 131–132) 

NEMA commented that the engineering 

analysis should be supported by the 

testing and analysis of both open and 

enclosed frame motors. (NEMA, No. 54 

at p. 68) Finally, NEMA commented that 

by not selecting representative units 

with different enclosure types, DOE fails 

to meet the statutory requirement that 

any prescribed amended or new 

efficiency standards are in fact 

technically feasible, practical to 

manufacture, and have no adverse 

impacts on product utility or product 

availability. (NEMA, No. 54 at pp. 68– 

69) 

DOE acknowledges the comments 

from interested parties regarding 

enclosure type and its selection of 

representative units. The final 

equipment class setting criterion that 

DOE had to consider when selecting its 

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53For the purposes of the NOPR analysis, the 

term ‘‘efficiency level’’ (EL) is equivalent to that of 

Candidate Standard Level (CSL) in the preliminary 

analysis. 

54EPACT 1992 only established efficiency 

standards for motors up to and including 200 hp. 

Eventually, NEMA MG 1–2011 added a table, 20– 

A, which functioned as an extension of Table 12– 

11. So, although EPACT 1992 is a slight misnomer, 

DOE is using it to refer to those ELs that were based 

on Table 12–11. 

55Because motor efficiency varies from unit to 

unit, even within a specific model, NEMA has 

established a list of standardized efficiency values 

that manufacturers use when labeling their motors. 

Each incremental step, or ‘‘band,’’ constitutes a 10 

percent change in motor losses. NEMA MG 1–2011 

Table 12–10 contains the list of NEMA nominal 

efficiencies. 

representative units was enclosure type. 

For the preliminary analysis, DOE 

analyzed only electric motors with 

totally enclosed, fan-cooled (TEFC) 

designs rather than open designs for all 

of its representative units. DOE selected 

TEFC motors because, as with pole 

configurations, DOE wanted as many 

design characteristics to remain 

constant as possible. DOE believed that 

such an approach would allow it to 

more accurately pinpoint the factors 

that affect efficiency. While DOE only 

analyzed one enclosure type, it notes 

that its scaling follows NEMA’s 

efficiency tables (Table 12–11 and Table 

12–12), which already map how 

efficiency changes with enclosure type. 

Finally, TEFC electric motors 

represented more than three times the 

shipment volume of open motors. DOE 

chose ELs that correspond to the tables 

of standards published in NEMA’s MG 

1–2011 and to efficiency bands derived 

from those tables, preserving the 

relationship between NEMA’s standards 

for open and enclosed motors. 

In the preliminary analysis, DOE 

stated that, given the same frame size, 

open motors are more efficient than 

enclosed motors. NEMA commented 

that DOE should not compare open and 

enclosed motors in the same frame size 

because NEMA MG 1 specifies larger 

frame sizes and a higher service factor 

for enclosed motors of a given rating 

than it does for open motors. NEMA 

added that TEFC motors have a fan 

which adds to the friction and windage 

losses, and even with this fan the TEFC 

motors can have higher efficiencies than 

open frame motors of the same 

horsepower and pole configuration. 

(NEMA, No. 54 at p. 41) DOE 

appreciates the clarification and has 

altered its discussion in chapter 3 of the 

TSD. 

3. Efficiency Levels Analyzed 

After selecting its representative units 

for each electric motor equipment class 

group, DOE examined the impacts on 

the cost of improving the efficiency of 

each of the representative units to 

evaluate the impact and assess the 

viability of potential energy 

conservation standards. As described in 

the technology assessment and 

screening analysis, there are numerous 

design options available for improving 

efficiency and each incremental 

improvement increases the electric 

motor efficiency along a continuum. 

The engineering analysis develops cost 

estimates for several efficiency levels 

(ELs) 53 along that continuum. 

ELs are often based on: (1) Efficiencies 

available in the market; (2) voluntary 

specifications or mandatory standards 

that cause manufacturers to develop 

equipment at particular efficiency 

levels; and (3) the max-tech level. 

Currently, there are two energy 

conservation standard levels that apply 

to various types of electric motors. In 

ECG 1, some motors currently must 

meet efficiency standards that 

correspond to NEMA MG 1–2011 Table 

12–11 (i.e., EPACT 1992 levels 54), 

others must meet efficiency standards 

that correspond to NEMA MG 1–2011 

Table 12–12 (i.e., NEMA Premium 

levels), and some are not currently 

required to meet any energy 

conservation standard levels. Because 

DOE cannot establish energy 

conservation standards that are less 

efficient than current standards (i.e., the 

‘‘anti-backsliding’’ provision at 42 

U.S.C. 6295(o)(1) as applied via 42 

U.S.C. 6316(a)) but ECG 1 includes both 

currently regulated and unregulated 

electric motors, DOE’s analysis assumed 

the respective EPACT 1992 or NEMA 

Premium standard as the baseline for 

ELs 1 and 2. For ECG 1, DOE established 

an EL that corresponded to each of these 

levels, with EL 0 as the baseline (i.e., the 

lowest efficiency level available for 

unregulated motors and EPACT 1992 or 

NEMA Premium, as applicable, for 

currently regulated motors), EL 1 as 

equivalent to EPACT 1992 levels (or 

NEMA Premium, as applicable, for 

currently regulated motors), and EL 2 as 

equivalent to NEMA Premium levels. 

Additionally, DOE analyzed two ELs 

above EL 2. One of these levels was the 

max-tech level, denoted as EL 4 and one 

was an incremental level that 

approximated a best-in-market 

efficiency level (EL 3). For all 

equipment classes within ECG 1, EL 3 

was a one ‘‘band’’ increase in NEMA 

nominal efficiency relative to NEMA 

Premium and EL 4 was a two ‘‘band’’ 

increase.55 For ECG 3 and 4, DOE used 

the same ELs with one exception for 

ECG 3. Because fire pump electric 

motors are required to meet EPACT 

1992 efficiency levels and those are the 

only motors in that equipment class 

group, EPACT 1992 levels were used as 

the baseline efficiency level, which 

means that fire pump electric motors 

have one fewer EL than ECGs 1 and 4 

for purposes of DOE’s analysis. 

Following the preliminary analysis, 

DOE adjusted one max-tech Design B 

representative unit level (5 hp) after 

receiving additional data. This allowed 

this unit to be based more on physical 

models for the NOPR analysis, thereby 

reducing exposure to modeling errors. 

Table IV.9 and Table IV.10 show the ELs 

for ECGs 1, 3, and 4. 

TABLE IV.9—EFFICIENCY LEVELS FOR EQUIPMENT CLASS GROUPS 1 AND 4 

Representative unit 

EL 0 

(baseline) 

(percent) 

EL 1 

(EPACT 1992) 

(percent) 

EL 2 

(NEMA 

premium) 

(percent) 

EL 3 

(best-inmarket) * 

(percent) 

EL 4 

(max-tech) 

(percent) 

5 hp (ECG 1 and 4) ............................................................. 82.5 87.5 89.5 90.2 91.0 

30 hp (ECG 1 and 4) ........................................................... 89.5 92.4 93.6 94.1 94.5 

75 hp (ECG 1 only **) .......................................................... 93.0 94.1 95.4 95.8 96.2 

* Best-in-market represents the best or near best efficiency level at which current manufacturers are producing electric motors. Although these 

efficiencies represent the best-in-market values found for the representative units, but when efficiency was scaled to the remaining equipment 

classes, the scaled efficiency was sometimes above and sometimes below the best-in-market value for a particular rating. 

** ECG 4 does not have a 75-horsepower representative unit because DOE was unable to find brake motors built with such a high horsepower 

rating. The maximum horsepower rating for ECG 4 is 30-horsepower. 

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TABLE IV.10—EFFICIENCY LEVELS FOR EQUIPMENT CLASS GROUP 3 

Representative unit 

(percent) 

EL 0 

(EPACT 1992) 

(percent) 

EL 1 

(NEMA 

premium) 

(percent) 

EL 2 

(best-inmarket) * 

(percent) 

EL 3 

(max-tech) 

(percent) 

5 hp .................................................................................................................. 87.5 89.5 90.2 91.0 

30 hp ................................................................................................................ 92.4 93.6 94.1 94.5 

75 hp ................................................................................................................ 94.1 95.4 95.8 96.2 

For ECG 2, DOE took a similar 

approach in developing its ELs as it did 

for ECG 1, but with two primary 

differences. First, when DOE examined 

catalog data, it found that no NEMA 

Design C electric motors had efficiencies 

below EPACT 1992 levels, which is the 

current standard for all covered NEMA 

Design C electric motors. For DOE’s 

representative units, it also found no 

catalog listings above the required 

EPACT 1992 levels. Additionally, when 

DOE’s subject matter expert modeled 

NEMA Design C motors, the model 

would only generate designs at NEMA 

Premium levels and one incremental 

level above that while maintaining 

proper performance standards. 

Therefore, ECG 2 only contains three 

ELs: EPACT 1992 (EL 0), NEMA 

Premium (EL 1), and a max-tech level 

(EL 2). 

These ELs differed slightly from the 

CSLs presented in the preliminary 

analysis for ECG2. In the preliminary 

analysis, a CSL for the 50 hp unit 

existed between two industry standard 

levels in order to provide greater 

resolution in selection of a standard 

(NEMA MG–1 Table 12–11 and Table 

12–12). For the NOPR analysis, this 

level was removed so that the ELs 

analyzed would align with Tables 12–11 

and 12–12. For the 5 hp rep unit, DOE 

also removed one preliminary analysis 

CSL, which was intended to represent 

the ‘‘best in market’’ level in the 

preliminary analysis. After further 

market research, DOE found that few 

Design C motors are offered above the 

baseline, and those that were mainly 

met the NEMA premium level, without 

going higher in efficiency. It determined 

that for the NOPR analysis, the 

previously designated ‘‘max in market’’ 

level was not applicable. The ELs 

analyzed for ECG2 in the NOPR are 

shown in Table IV.11. 

TABLE IV.11—EFFICIENCY LEVELS FOR EQUIPMENT CLASS GROUP 2 

Representative unit 

(percent) 

EL 1 

(EPACT 1992) 

(percent) 

EL 2 

(NEMA 

premium) 

(percent) 

EL 3 

(max-tech) 

(percent) 

5 hp .............................................................................................................................................. 87.5 89.5 91.0 

50 hp ............................................................................................................................................ 92.4 93.6 94.5 

In response to its preliminary 

analysis, DOE received multiple 

comments regarding CSLs. NEMA and 

Baldor expressed confusion over the fact 

that the CSLs for ECG 2 do not align 

with the CSLs from ECG 1, and 

requested that DOE line up CSLs across 

different ECGs in an effort to avoid 

confusion when discussing the CSLs. 

(NEMA, No. 54 at p. 73; Baldor, Public 

Meeting Transcript, No. 60 at pp. 171, 

172) DOE understands NEMA’s 

concerns regarding the nomenclature of 

its ELs, however, it has maintained its 

approach for the NOPR analysis. DOE 

examines each ECG independently, and 

because different motor types have 

different baselines, the EL numbers do 

not always align. 

NEMA also asked if the baseline CSL 

developed for ECG 1, which was 

developed based on an analysis of 

vertical, hollow-shaft motors, included 

losses related to testing those motors 

with thrust bearings. NEMA inquired 

because, at the time of its comment, 

DOE had not yet published the test 

procedure NOPR, indicating how these 

motor types might be tested. (NEMA, 

No. 54 at pp. 71–72, 77) 

DOE clarifies that the vertical hollowshaft motors purchased and used to 

determine the baseline efficiency level 

for ECG 1 contained bearings capable of 

horizontal operation. Therefore, DOE 

tested these motors in a horizontal 

configuration without any modifications 

to the bearings. Additionally, when 

tested, solid-shafts were welded inside 

the hollow-shaft to permit the motor to 

be attached to a dynamometer for 

testing. These modifications are in line 

with the proposals for vertical hollow 

shaft motors as described in DOE’s 

electric motors test procedure NOPR. 78 

FR 38456 (June 26, 2013). 

During the preliminary analysis 

public meeting, NEMA noted that the 

CSL 5 software-modeled efficiency was 

96.4 percent and should have been 

assigned a NEMA nominal efficiency 

level of 96.2 percent rather than 96.5. 

(NEMA, No. 54 at p. 80) NEMA and 

Baldor added that CSL 5 should not be 

included in any engineering analysis 

because of the infeasibility of castcopper rotors, and that CSL 4 is the 

proper max-tech level when CSL 5 is 

eliminated from consideration. (NEMA, 

No. 54 at p. 73; Baldor, Public Meeting 

Transcript, No. 60 at p. 171) The 

Efficiency Advocates also expressed 

concern about some of the CSLs 

analyzed by DOE and questioned the 

viability of CSL 3. The Efficiency 

Advocates noted that some of the CSL 

3 designs were at the very limits of 

critical motor performance parameters, 

such as locked-rotor torque and current. 

The Efficiency Advocates added that 

DOE has not tested motors that perform 

at the levels that would be required by 

CSL 3, 4, and 5. Without having done 

so, DOE cannot verify the predicted 

performance of its representative units. 

(NPCC, No. 56 at pp. 4, 5) 

As discussed, DOE has removed EL 5 

from consideration in the NOPR 

analysis, but it has not eliminated the 

use of copper-die cast rotor technology 

(see I.A.1). With regards to the 

comments from the Efficiency 

Advocates, DOE notes that EL 3 for ECG 

1 is based on teardown data from 

commercially available motors, as it was 

for the preliminary analysis. 

Additionally, for the NOPR, DOE has 

tested a unit at EL 4 for one of its 

representative units. Furthermore, DOE 

has found many instances of electric 

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56 DOE understands that this is not true for every 

equipment classes covered by this rulemaking, but 

has not seen evidence to suggest that the absence 

of equipment in any particular classes is not due 

to lack of market demand instead of technological 

limitations. 

57The Center for Electromechanics at the 

University of Texas at Austin, a 140,000 sq. ft. lab 

with 40 years of operating experience, performed 

the teardowns, which were overseen by Dr. Angelo 

Gattozzi, an electric motor expert with previous 

industry experience. DOE also used Advanced 

Energy Corporation of North Carolina to perform 

some of the teardowns. 

motors being sold and marketed one or 

two NEMA bands of efficiency above 

NEMA Premium, which suggests that 

manufacturers have extended 

technological performance where they 

perceived market demand for higher 

efficiencies. In other words, DOE has 

seen no evidence suggesting that the 

absence of products on the market at 

any given EL implies that such products 

could not be developed, were there 

sufficient demand. DOE contends that 

all of the ELs analyzed in its engineering 

analysis are viable because equipment is 

currently commercially available at 

such levels 56 and, to the extent 

possible, has been included in DOE’s 

analysis. DOE welcomes comment on 

the limits of technology, especially as it 

varies by equipment class. 

Additionally, NEMA and Baldor 

commented on the design options 

analyzed for the various CSLs. NEMA 

and Baldor stressed that not using a 

common design option across all CSLs 

may result in a reduction of available 

product. (NEMA, No. 54 at pp. 3, 27, 73; 

Baldor, Public Meeting Transcript, No. 

60 at pp. 169–171, 176–178) NEMA 

indicated that it is a standard practice 

of manufacturers to minimize the 

number of types of electrical steel used 

at a manufacturing facility and that 

typically a single type of electrical steel 

may be used for all electric motors 

manufactured at the facility. NEMA 

added that DOE should account for this 

situation when performing engineering 

analyses such that a common type of 

electrical steel is used for the different 

NEMA design types covered by a 

common CSL. (NEMA, No. 54 at p. 62) 

NEMA added that although NEMA 

Design C motors constitute less than 1 

percent of total motor shipments, the 

electrical steel and die-cast rotor 

material used for manufacturing NEMA 

Design C electric motors is taken from 

the same inventory as used for NEMA 

Design B electric motors. Therefore, 

they contended that DOE should select 

the same material types for NEMA 

Design C motors as it does for NEMA 

Design B motors. (NEMA, No. 54 at p. 

65, 74) Finally, NEMA stated that it did 

not understand why DOE used different 

steels and rotor conductors for CSLs 4 

and 5 in some of the ECG 1 

representative units but not in others. 

(NEMA, No. 54 at pp. 3, 72; Baldor, 

Public Meeting Transcript, No. 60 at p. 

120) 

As noted earlier, DOE has 

restructured its ELs for the NOPR 

analysis. One consequence of this 

restructuring is that DOE no longer 

mixes rotor casting technologies for a 

given EL. However, DOE does not limit 

the number of electrical steels used at a 

given EL to one. DOE understands that 

manufacturers try to limit the number of 

electrical steels at a given 

manufacturing facility, but most 

manufacturers have more than one 

manufacturing facility. Therefore, 

manufacturers could produce motors 

with multiple grades of electrical steel. 

Additionally, DOE believes that this 

approach is in line with current 

industry practice. For its analysis, DOE 

obtained multiple units for teardowns 

from the same manufacturer. After a 

steel analysis was conducted on its 

teardowns, DOE found that one 

manufacturer utilized multiple grades of 

steel, both across ELs within a 

representative unit and across 

representative units within an EL. 

Finally, DOE believes that the 

restructuring of the ELs should also 

address concerns over the technology 

differences between preliminary 

analysis ELs 4 and 5 because in the 

NOPR analysis there is no EL 5. DOE 

has updated chapter 5 of the TSD to 

include as pertinent design data. 

During the preliminary analysis 

public meeting, ACEEE commented that 

new energy conservation levels would 

have to be raised by at least two NEMA 

bands because an increase of only one 

NEMA band is not statistically 

significant. (ACEEE, Public Meeting 

Transcript, No. 60 at p. 168) DOE 

disagrees with this assessment. 

Although the unit-to-unit efficiency of a 

specific electric motor design may vary 

by multiple NEMA bands of efficiency, 

an increase in the required efficiency 

level by one band would be significant. 

If efficiency standards are raised by one 

NEMA band, there is no evidence to 

suggest that manufacturing practices 

would change such that the distribution 

of unit-to-unit efficiencies for a given 

motor design would change. Therefore, 

if the required efficiency standard were 

changed by one band of efficiency, one 

would assume that the entire population 

of motors of a given design would shift 

by one band of efficiency as 

manufacturers begin to produce motors 

around a higher mean value. 

Finally, NEMA commented that 

another important factor for defining 

CSLs is the ability for CSLs to provide 

efficiency values to be used in the 

scaling process and that it is important 

that the relative difference between the 

efficiency values for CSLs is selected 

such that the relativity is maintained 

across all of the representative units if 

it is to be applied by scaling to all 

electric motors included in an ECG. In 

other words, NEMA argues that CSLs 

must be chosen carefully to correspond 

with similar technologies and materials 

across the range of scaling (i.e., the 

entire equipment class) and that they 

should not be chosen to merely to align 

with NEMA’s own tables and efficiency 

bands. (NEMA, No. 54 at p. 73) 

Responding to this concern, for each EL 

above the established NEMA Premium 

levels, DOE has incremented efficiency 

by one nominal band for all equipment 

classes. This equates to, roughly, a 10 

percent decrease in motor losses for all 

equipment classes for each jump in EL. 

4. Test and Teardowns 

Whenever possible, DOE attempted to 

base its engineering analysis on actual 

electric motors being produced and sold 

in the market today. First, DOE 

identified electric motors in 

manufacturer catalogs that represented a 

range of efficiencies corresponding to 

the ELs discussed in the previous 

sections. Next, DOE had the electric 

motors shipped to a certified testing 

laboratory where each was tested in 

accordance with IEEE Standard 112 

(Test Method B) to verify its nameplaterated efficiency. After testing, DOE 

derived production and material costs 

by having a professional motor 

laboratory 57 disassemble and inventory 

the purchased electric motors. For ECG 

1, DOE obtained tear-down results for 

all of the 5-horsepower ELs and all of 

the 30- and 75-horsepower ELs except 

the max-tech levels. For ECG 2, DOE 

obtained tear-down results only for the 

baseline EL, which corresponds to 

EPACT 1992 efficiency levels. 

These tear-downs provided DOE with 

the necessary data to construct a bill of 

materials (BOM), which, along with a 

standardized cost model and markup 

structure, DOE could use to estimate a 

manufacturer selling price (MSP). DOE 

paired the MSP derived from the teardown with the corresponding nameplate 

nominal efficiency to report the relative 

costs of achieving improvements in 

energy efficiency. DOE’s estimates of 

material prices came from a 

combination of current, publicly 

available data, manufacturer feedback, 

and conversations with its subject 

matter experts. DOE supplemented the 

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findings from its tests and tear-downs 

through: (1) A review of data collected 

from manufacturers about prices, 

efficiencies, and other features of 

various models of electric motors, and 

(2) interviews with manufacturers about 

the techniques and associated costs 

used to improve efficiency. 

As discussed earlier, DOE’s 

engineering analysis documents the 

design changes and associated costs 

when improving electric motor 

efficiency from the baseline level up to 

a max-tech level. This includes 

considering improved electrical steel for 

the stator and rotor, interchanging 

aluminum and copper rotor bar 

material, increasing stack length, and 

any other applicable design options 

remaining after the screening analysis. 

As each of these design options are 

added, the manufacturer’s cost increases 

and the electric motor’s efficiency 

improves. DOE received multiple 

comments regarding its test and teardown analysis. 

NEMA commented that the cost for 

manufacturing an electric motor can 

increase as the efficiency level is 

increased even when the material and 

technology is not changed. It added that 

an increase in core length, without any 

change in the material used, will result 

in a higher cost not only due to the 

increase in the amount of steel, but also 

due to the increase in the amount of 

wire for the stator winding and 

aluminum for the rotor core. (NEMA, 

No. 54 at p. 74) Notwithstanding, DOE 

believes that it has accurately captured 

such changes. When each electric motor 

was torn down, components such as 

electrical steel and copper wiring were 

weighed. Therefore, any increase in 

stack length would result in increased 

costs associated with the increased 

amount of electrical steel and copper 

wiring. 

NEMA also commented that the best 

known value of efficiency for a tested 

and torn down motor is the tested 

efficiency and the accuracy of this value 

improves as sample size increases. 

Because DOE only used a sample size of 

one, NEMA recommended that DOE 

should increase its sample size to 

something more statistically significant. 

(NEMA, No. 54 at p. 75) NEMA also 

referred to the small electric motors 

rulemaking and said that a sufficient 

sample size for testing was proven to be 

necessary. (NEMA, No. 54 at p. 27) 

NEMA also commented that Appendix 

A to Subpart U designates the 

appropriate sample size to support the 

conclusion that the name-plated 

efficiency of a motor is correctly stated. 

(NEMA, No. 54 at p. 79) NEMA and 

Baldor added that Appendix A to 

Subpart U requires the determination of 

a standard deviation from the sample, 

and it is not possible to determine a 

standard deviation when testing a 

sample of one motor, which was the 

sample size of DOE’s motor testing. 

(NEMA, No. 54 at p. 79; Baldor, Public 

Meeting Transcript, No. 60 at p. 154) 

DOE agrees that an increased sample 

size would improve the value of 

efficiency used in its analysis, but only 

if DOE were using an average full-load 

efficiency value, as it did for the small 

electric motors rulemaking engineering 

analysis, which did not have the benefit 

of NEMA-developed nominal efficiency 

values. For today’s analysis, DOE did 

not use the tested efficiency value and 

believes that to do so would be 

erroneous precisely because it only 

tested and tore down one unit for a 

given representative unit and EL. Rather 

than using an average efficiency of a 

sample of multiple units that is likely to 

change with each additional motor 

tested, DOE elected to use the 

nameplate NEMA nominal efficiency 

given. DOE understands that this value, 

short of testing data, is the most 

accurate value to use to describe a 

statistically valid population of motors 

of a given design; that is, in part, why 

manufacturers use NEMA nominal 

efficiencies on their motors’ nameplates. 

Furthermore, when DOE conducts its 

tear-downs, the bill of materials 

generated is most representative of the 

tested value of efficiency, not 

necessarily the NEMA nominal value. 

However, DOE believes that the 

variance from unit-to-unit, in terms of 

materials, is likely to be insignificant 

because manufacturers have an 

incentive to produce equipment with 

consistent performance (i.e., 

characteristics other than efficiency) as 

possible. Changes in the tested 

efficiency are likely to occur because of 

variations in production that motor 

manufacturers have less control over 

(e.g., the quality of the electrical steel). 

DOE does not believe that the amount 

of material (in particular, electrical 

steel, copper wiring, and die-cast 

material) from unit-to-unit for a given 

design is likely to change significantly, 

if at all, because manufacturers have 

much greater control of those 

production variables. Therefore, 

additional tests and tear-downs are 

unlikely to change the MSP estimated 

for a given motor design and DOE 

believes that its sample size of one is 

appropriate. 

In the preliminary engineering 

analysis, DOE replaced a tear-down 

result with a software model for CSL 2 

of its 30-horsepower representative unit 

because it believed that it had 

inadvertently tested and torn down a 

motor with an efficiency equivalent to 

CSL 3. DOE noted that it removed the 

tear-down because there was conflicting 

efficiency information on the Web site, 

in the catalog, and on the physical 

nameplate. Subsequently, NEMA and 

Baldor commented that the 30- 

horsepower, CSL 2 motor should not 

have been replaced with a softwaremodeled motor, stating that the test 

result was statistically viable. (NEMA, 

No. 54 at pp. 76–79; Baldor, Public 

Meeting Transcript, No. 60 at pp. 150– 

155) NEMA and Baldor also asserted 

that DOE had placed emphasis on the 

use of purchased motors in its analysis 

only when the tested value of efficiency 

was less than or not significantly greater 

than the marked value of NEMA 

efficiency. (NEMA, No. 54 at p. 80; 

Baldor, Public Meeting Transcript, No. 

60 at pp. 156, 157) 

DOE understands that the test result 

may have been viable for either of the 

efficiency ratings that the manufacturer 

had assigned. Given the uncertainty, 

however, DOE elected to replace the 

motor. DOE did not discard the unit 

simply because it tested significantly 

above its nameplate efficiency. Rather, 

the motor was listed with different 

values of efficiency depending upon the 

source and when torn down, the 

resulting MSP was higher than the MSP 

for the next CSL. These facts suggested 

that the calculated results were 

erroneous because it is unlikely (based 

on available data) that it would be 

cheaper to build a more efficient motor 

than a less efficient one of comparable 

specifications. If DOE had included 

these data in its analysis, it would likely 

have resulted in a projection that even 

higher CSLs would be economically 

justified. The combination of these 

factors resulted in DOE eliminating that 

motor from the analysis. For its updated 

NOPR engineering analysis, DOE has 

tested and torn down a new 30- 

horsepower motor to describe CSL 2. As 

stated previously, DOE always prefers to 

base its analysis using motors purchased 

in the market when possible. 

NEMA commented that the 

disproportionate variation in frame 

weights between the CSLs suggests that 

the CSLs of some representative units 

were not of similar construction. 

(NEMA, No. 54 at p. 78) When selecting 

motors for tear-down, DOE selected 

motors with increasing efficiencies. 

These motors may not have used the 

same frame material. For example, the 

CSL 0 for the 30-horsepower 

representative units was made out of 

cast aluminum, but CSL 1 unit used cast 

iron. This material change accounts for 

the large difference in frame weight. 

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58 Dr. Howard Jordan, Ph.D., an electric motor 

design expert with over 40 years of industry 

experience, served as DOE’s subject matter expert. 

59The ‘‘C’’ dimension of an electric motor is the 

length of the electric motor from the end of the shaft 

to the end of the opposite side’s fan cover guard. 

Essentially, the ‘‘C’’ dimension is the overall length 

of an electric motor including its shaft extension. 

60 VICA stands for ‘‘Veinott Interactive Computer 

Aid.’’ 

During the preliminary analysis 

public meeting, Nidec requested 

clarification for the increase in stator 

copper weight for the 75-horsepower, 

ECG 1 representative unit between CSL 

2 and CSL 3 since the reported slot fills 

were the same and the motors had 

similar stack lengths. (Nidec, Public 

Meeting Transcript, No. 60 at pp. 164, 

165) After DOE’s tear-down lab 

determined that the torn-down motors 

were machine-wound a precise 

measurement of the slot fill was not 

taken. Although the actual measurement 

of slot fill has no bearing on the 

estimates of the MSP, because the actual 

copper weights were measured and not 

calculated, DOE did ask its lab to 

provide actual measurements of slot fill 

on any subsequent tear-downs and has 

included the data in chapter 5 of the 

TSD. 

5. Software Modeling 

In the preliminary analysis, DOE 

worked with technical experts to 

develop certain CSLs, in particular, the 

max-tech efficiency levels for each 

representative unit analyzed. DOE 

retained an electric motors subject 

matter expert (SME) 58 with design 

experience and software, who prepared 

a set of designs with increasing 

efficiency. The SME also checked his 

designs against tear-down data and 

calibrated his software using the 

relevant test results. As new designs 

were created, DOE’s SME ensured that 

the critical performance characteristics 

that define a NEMA design letter, such 

as locked-rotor torque, breakdown 

torque, pull-up torque and locked-rotor 

currents were maintained. For a given 

representative unit, DOE ensured that 

the modeled electric motors met the 

same set of torque and locked-rotor 

current requirements as the purchased 

electric motors. This was done to ensure 

that the utility of the baseline unit was 

maintained as efficiency improved. 

Additionally, DOE limited its modeled 

stack length increases based on 

teardown data and maximum ‘‘C’’ 

dimensions found in manufacturer’s 

catalogs.59

In response to the preliminary 

analysis, Baldor and NEMA requested 

clarification on how DOE compared its 

software modeled results to the electric 

motors that it had tested and torn down. 

(NEMA, No. 54 at p. 74; Baldor, Public 

Meeting Transcript, No. 60 at p. 148) 

NEMA requested that more details 

regarding that comparison and the name 

of the software program used to be 

included in an updated technical 

support document. (NEMA, No. 54 at p. 

12) Per the request of NEMA and 

Baldor, DOE has provided comparisons 

of software estimates and tested 

efficiencies in appendix 5C of the TSD. 

Additionally, the software program that 

DOE used for its analysis is a 

proprietary software program called 

VICA.60

NEMA expressed concern over 

efficiency standards based on the 

software platform DOE used and stated 

that DOE should build working 

prototypes of its software modeled 

motors to prove the designs work. 

(NEMA, No. 54 at pp. 24–25 and 74–75) 

Baldor reiterated this point in verbal 

comments and suggested that this was 

particularly important for CSLs with 

copper rotor designs given their 

concerns with copper rotor motors. 

(NEMA, No. 54 at pp. 76–77; Baldor 

Public Meeting Transcript, No. 60 at pp. 

160, 161) During the preliminary 

analysis, DOE approached motor 

laboratories in an attempt to prototype 

its software models. DOE was unable to 

identify a laboratory that could 

prototype its software modeled motors 

in a manner that would exactly replicate 

the designs produced (i.e., they could 

not die-cast copper). Consequently, at 

this time, DOE has not built a prototype 

of its software models. However, DOE 

was able to procure a 5-horsepower 

NEMA Design B die-cast copper rotor 

motor with an efficiency two NEMA 

bands above the NEMA Premium level. 

Therefore, DOE elected to use this 

design to represent the max-tech EL for 

the 5-horsepower representative unit in 

equipment class group 1, rather than the 

software-modeled design used in the 

preliminary analysis. DOE’s SME used 

information gained from testing and 

tearing down this motor to help 

corroborate the software modeling. 

In the preliminary analysis, DOE 

indicated that its software modeling 

expert made changes to his software 

designs based on data collected during 

the motor teardowns. NEMA 

commented on this and asked why 

DOE’s software modeling expert made 

changes to some of his designs based on 

teardown data. (NEMA, No. 54 at p. 75) 

DOE clarifies that the software program 

was updated using additional teardown 

data (e.g., more accurate dimensions 

and material types) to maintain as many 

consistencies in design as possible. For 

example, DOE’s software modeling 

expert used lamination diameters 

measured during the teardowns as 

limits for the software models. 

In submitted comments, NEMA noted 

that the NEMA nominal efficiency for 

the software-modeled motors was 

derived by selecting the value that was 

lower than the calculated efficiency. 

NEMA questioned this approach and 

added that assigning a value of NEMA 

nominal efficiency based on a 

calculated value of efficiency requires 

more knowledge than merely selecting 

the closest NEMA nominal value that is 

lower than the calculated value. 

(NEMA, No. 54 at p. 76) DOE notes that 

it selected the closest NEMA nominal 

efficiency that is less than or equal to 

the predicted efficiency of the software 

for multiple reasons. First, DOE wanted 

to maintain the use of nominal 

efficiency values to remain consistent 

with past electric motor efficiency 

standards. Second, DOE chose a value 

below its software estimate because this 

method would provide a more 

conservative approach. DOE believes its 

approach was appropriate given the 

various concerns raised with copper 

rotor motor technologies. 

During the preliminary analysis 

public meeting, Regal-Beloit commented 

that calibration of the software-modeled 

motors is extremely important. RegalBeloit added that the calibration of 

select models is very important due to 

the amount of interpolation that DOE is 

basing on these models. (Regal-Beloit, 

Public Meeting Transcript, No. 60 at pp. 

159–160) Alluding to copper rotor 

motors, NEMA commented on DOE’s 

software modeling, claiming that 

verifying the accuracy of a software 

program with respect to performance 

obtained from testing purchased motors 

does not verify the accuracy of the 

software program when it is used for a 

technology which has not been verified 

by tests. (NEMA, No. 54 at p. 76; Baldor, 

Public Meeting Transcript, No. 60 at pp. 

160, 161) DOE appreciates these 

comments and, as stated, has conducted 

calibration of its software program using 

data obtained from motor teardowns. 

DOE has provided comparisons of 

software estimates and tested 

efficiencies for both aluminum and 

copper rotor motors in appendix 5C of 

the TSD. 

NEMA commented that the 

preliminary TSD did not show that the 

software platform DOE used had been 

substantiated as being sufficiently 

accurate for motors incorporating 

existing and new technologies. (NEMA, 

No. 54 at p. 12) NEMA asserted that it 

is necessary to substantiate the software 

platform used for modeling as an 

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alternate efficiency determination 

method (AEDM) such that the 

calculated efficiencies can be verified as 

accurate for the types of technologies 

included in a motor design. NEMA 

urged that DOE substantiate the 

software platform used by its SME as an 

AEDM. (NEMA, No. 54 at p. 76) Baldor 

added that DOE expects manufacturers 

to prototype five motors to certify a 

program, but DOE has not designed and 

built any of the motors designed in its 

own program. (Baldor, Public Meeting 

Transcript, No. 60 at p. 162) Nidec 

commented during the public meeting, 

asking if the software modeling suite 

DOE used has gone through the same 

scrutiny that manufacturers are subject 

to when they must submit their 25 

samples to correlate their estimated 

computer data with actual testing data. 

(Nidec, Public Meeting Transcript, No. 

60 at p. 147) 

DOE understands the comments 

received regarding its software program, 

but maintains that substantiation of an 

AEDM is a concept intended for 

certifying compliance with energy 

efficiency standards. It is a tool that 

manufacturers use to help ensure that 

the equipment they manufacture 

comply with a Federal standard (which 

is the manufacturers’ duty). It is not a 

tool for assessing whether a particular 

energy efficiency level under 

consideration by DOE satisfies the EPCA 

criteria. Accordingly, the use of the 

AEDM in the manner suggested by 

industry would not be relevant for the 

purposes of this engineering analysis, 

which is geared toward DOE’s standards 

rulemaking. 

NEMA also commented that to 

properly determine the impact of 

increased efficiency on motor utility, 

DOE must recognize the consequences 

of how motor performance, including 

parameters such as acceleration, safe 

stall time, overspeed, service factor, 

thermal performance, and in-rush 

current will be affected by more 

stringent energy conservation standards. 

NEMA also specifically referred to 

performance characteristics found in 

NEMA MG 1 sections 12.44, 12.45, 

12.48, 12.49, 12.53, 12.54, and 12.56. 

(NEMA, No. 54 at pp. 5, 77) NEMA 

added that the narrow margin between 

the NEMA MG 1–2011 limits for lockedrotor current and the calculated lockedrotor current for some of the softwaremodeled designs in the preliminary 

analysis suggest that there will be 

problems with these motors meeting the 

NEMA MG 1 limits if they were 

prototyped. (NEMA, No. 54 at p. 77) 

Finally, NEMA indicated that two of the 

DOE software-modeled motors in the 

preliminary analysis, representing the 

75-horsepower CSLs 4 and 5 for ECG 1, 

had torque ratings twice that of a U.S. 

Army 75-horsepower electric motor 

software model, and suggested that the 

software models used in DOE’s analysis 

are not accurate in modeling copper 

rotor motor performance. (NEMA, No. 

54 at p. 77) 

DOE has carefully considered 

NEMA’s comments in its updated NOPR 

analysis. As noted, DOE has eliminated 

designs from its preliminary analysis 

because of concerns regarding the 

feasibility of those efficiency levels. 

Regarding the additional performance 

parameters, DOE agrees that these 

characteristics must be maintained 

when improving an electric motor’s 

efficiency. However, the performance 

parameters DOE believed to present the 

largest risk of rendering a motor 

noncompliant with NEMA MG 1–2011 

standards were those related to NEMA 

design letter, which were adhered to in 

DOE’s modeling efforts. Based on 

comparisons of motor teardowns and 

software estimates, DOE has no reason 

at this time to believe that its modeled 

designs would violate the additional 

performance parameters mentioned by 

NEMA. 

DOE believes that its subject matter 

expert, who has been designing electric 

motors for several decades, is well 

qualified to understand the design 

tradeoffs that must be considered. 

Although the SME’s primary task was to 

design a more efficient motor using 

various technologies, it was of critical 

importance that the designs be feasible. 

Even though DOE was unable to 

prototype its modeled designs, DOE has 

conducted comparisons of software 

estimates and tested efficiencies for both 

aluminum and copper rotor motors and 

believes this corroborates the modeled 

designs. Based on this work and its total 

analysis, which included input from its 

SME, DOE believes it developed a 

sufficiently robust set of technically 

feasible efficiency levels for its 

engineering analysis. 

NEMA asked how DOE intended to 

take into consideration motor utility as 

motor size increases. (NEMA, No. 54 at 

pp. 23, 24) During the preliminary 

analysis public meeting, Baldor asked if 

the higher CSLs would fit into existing 

frame sizes, or if those motors would 

have to be redesigned to allow for the 

increased stack length. Baldor added 

that if the frame size increases, the 

motor may no longer fit current 

applications, which would cause 

additional burden for end-users or 

original equipment manufacturers. 

(Baldor, Public Meeting Transcript, No. 

60 at pp. 164, 245) Baldor added that 

IEC frame motors are more constrained 

in terms of size and space than NEMA 

frame motors, and it is more difficult to 

increase the efficiency on IEC frame 

motors without changing frame size 

designations, which would lead to space 

constraint issues. (Baldor and ABB, 

Public Meeting Transcript, No. 60 at pp. 

245, 246) Flolo Corporation also 

commented on motor length during the 

public meeting, insisting that it is 

important that DOE recognize the 

difference in ‘‘C’’ dimension that any 

new energy conservation standard 

would mandate, as increasing the ‘‘C’’ 

dimension will make it difficult for a 

motor to fit into its originally intended 

machine. (Flolo, Public Meeting 

Transcript, No. 60 at pp. 243, 244) The 

Efficiency Advocates also commented 

on motor length, indicating that DOE 

should be aware of absolute motor 

length limits when considering 

increased stack length, and that these 

changes could greatly increase the 

installed cost of many of the higher 

CSLs, impacting field and original 

equipment manufacturer (OEM) 

installation. (Advocates, No. 56 at p. 4) 

In the preliminary TSD, DOE 

stipulated that any increase in stack 

length would fit into the existing frame 

designation for that particular motor 

rating. DOE noted that the frame 

designation does not limit frame length, 

but rather frame diameter. DOE also 

understands that manufacturers have 

fixed-length frames that they use when 

manufacturing motors. In addition to 

generating per unit costs associated with 

redesigning motors with new frames at 

all ELs above the NEMA Premium levels 

(see IV.C.6), DOE sought to maintain 

motor length by limiting how much it 

would modify stack dimensions to 

improve efficiency. First, the software 

models created by DOE used lamination 

diameters observed during teardowns, 

which ensured that the softwaremodeled designs would fit into existing 

frame designations. However, for some 

designs DOE increased the number of 

laminations (i.e., length of the stack of 

laminations, or stack length) beyond the 

stack lengths observed during the motor 

teardowns in order to achieve the 

desired efficiency gains. 

DOE limited the amount by which it 

would increase the stack length of its 

software-modeled electric motors in 

order to preserve the motor’s utility. The 

maximum stack lengths used in the 

software-modeled ELs were determined 

by first analyzing the stack lengths and 

‘‘C’’ dimensions of torn-down electric 

motors. Then, DOE analyzed the ‘‘C’’ 

dimensions of various electric motors in 

the marketplace conforming to the same 

design constraints as the representative 

units (same horsepower rating, NEMA 

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frame size, enclosure type, and pole 

configuration). For each representative 

unit, DOE found the largest ‘‘C’’ 

dimension currently available on the 

marketplace and estimated a maximum 

stack length based on the stack length to 

‘‘C’’ dimension ratios of motors it tore 

down. The resulting product was the 

value that DOE chose to use as the 

maximum stack length considered in its 

software modeled designs, although 

DOE notes that it did not always model 

a motor with that maximum stack 

length. In most instances, the SME was 

able to achieve the desired improvement 

in efficiency with a stack length shorter 

than DOE’s estimated maximum. Table 

IV.12 shows the estimated maximum 

stack length, the maximum stack length 

found during tear-downs, and the 

maximum stack length modeled for a 

given representative unit. DOE 

welcomes additional comments on 

software modeling in general, and on 

specific data that could be used to 

calibrate its software designs. 

TABLE IV.12—MAXIMUM STACK LENGTH DATA

Representative unit Estimated maximum stack length Maximum stack length of a 

torn down motor 

Maximum 

stack length 

modeled 

30 Horsepower 

Design B ........................................... 8.87 in. .................................................... 8.02 in. (EL 2) ......................................... 7.00 in. 

75 Horsepower 

Design B ........................................... 13.06 in. .................................................. 11.33 in. (EL 3) ....................................... 12.00 in. 

5 Horsepower 

Design C .......................................... 5.80 in. .................................................... 4.75 in. (EL 0) ......................................... 5.32 in. 

50 Horsepower 

Design C .......................................... 9.55 in. .................................................... 8.67 in. (EL 0) ......................................... 9.55 in. 

6. Cost Model 

When developing manufacturer 

selling prices (MSPs) for the motor 

designs obtained from DOE’s tear-downs 

and software models, DOE used a 

consistent approach to generate a more 

accurate approximation of the costs 

necessary to improve electric motor 

efficiency. DOE derived the 

manufacturer’s selling price for each 

design in the engineering analysis by 

considering the full range of production 

and non-production costs. The full 

production cost is a combination of 

direct labor, direct materials, and 

overhead. The overhead contributing to 

full production cost includes indirect 

labor, indirect material, maintenance, 

depreciation, taxes, and insurance 

related to company assets. Nonproduction cost includes the cost of 

selling, general and administrative items 

(market research, advertising, sales 

representatives, logistics), research and 

development (R&D), interest payments, 

warranty and risk provisions, shipping, 

and profit factor. Because profit factor is 

included in the non-production cost, the 

sum of production and non-production 

costs is an estimate of the MSP. DOE 

utilized various markups to arrive at the 

total cost for each component of the 

electric motor and these markups are 

detailed in chapter 5 of the TSD. 

a. Copper Pricing 

DOE conducted the engineering 

analysis using material prices based on 

manufacturer feedback, industry 

experts, and publicly available data. In 

the preliminary analysis, most material 

prices were based on 2011 prices, with 

the exception of cast copper and copper 

wire pricing, which were based on a 

five-year (2007–2011) average price. 

DOE received comments regarding its 

copper price development. NPCC 

supported DOE’s decision to use a fiveyear price average for copper materials 

and suggested that this method should 

be used whenever a commodity price 

shows a pattern of irregular spikes or 

valleys. (Advocates, No. 56 at p. 4) 

Conversely, the Industrial Energy 

Consumers of America (IECA) stated 

that material costs for high efficiency 

motors are very volatile and cannot be 

reliably projected from a simple fiveyear average, as DOE did with copper 

prices during the preliminary analysis. 

IECA added that as a result of using a 

five-year average, the high efficiency 

motor material costs may be highly 

underestimated in DOE’s engineering 

analysis, and IECA suggested that a 

range of material costs rather than 

averages could better inform a range of 

life-cycle costs and payback periods for 

each CSL. (IECA, No. 52 at p. 3) 

Based on these comments, DOE has 

slightly modified its approach. First, 

DOE added updated data for 2012 

pricing. Second, rather than a five-year 

average, DOE changed to a three-year 

average price for copper materials. DOE 

made this modification based on 

feedback received during manufacturer 

interviews. By reducing to a three-year 

average, DOE eliminated data from 2008 

and 2009, which manufacturers 

believed were unrepresentative data 

points due to the recession. Data from 

those two years had the effect of 

depressing the five-year average 

calculated. 

b. Labor Rate and Non-Production 

Markup 

In the preliminary analysis, DOE 

looked at the percentage of electric 

motors imported into the U.S. and the 

percentage of electric motors built 

domestically and based the balance of 

foreign and domestic labor rates on 

these percentages. During the 

preliminary analysis public meeting, 

Nidec commented that the labor rate 

DOE used in its analysis seems high if 

that number is weighted towards 

offshore labor. Nidec also agreed with 

DOE’s smaller markup on the lowerhorsepower motors, but commented that 

the overall markups DOE used seem to 

be high. (Nidec, Public Meeting 

Transcript, No. 60 at p. 184) WEG added 

to these comments, indicating that they 

believed DOE was adequately 

addressing the cost structure variations 

among the different motor 

manufacturers. Additionally, WEG 

believed that basing a labor rate on both 

foreign and domestic labor rates 

increases accuracy of the analysis, but 

warned that DOE should be careful not 

encourage production moving outside 

the United States. (WEG, Public Meeting 

Transcript, No. 60 at pp. 184–186) 

At this time, DOE has elected to keep 

the same labor rates and markups as 

were used in the preliminary analysis. 

DOE is basing this decision on 

additional feedback received during 

interviews with manufacturers and the 

absence of any alternative labor rate or 

markups to apply. 

Finally, DOE is aware of potential cost 

increases caused by increased slot fill, 

including the transition to hand-wound 

stators in motors requiring higher slot 

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61Labor costs may rise starkly at max-tech levels, 

where hand-winding is employed in order to 

maximize slot fill. DOE’s engineering analysis 

reflects this fact. 

62The ‘‘per-unit adder’’ discussed in this section 

refers to a fixed adder for each motor that varies 

based on horsepower and NEMA design letter. Each 

representative unit has their own unique ‘‘per-unit 

adder’’ that is fixed for the analysis. 

fills. In the preliminary analysis, DOE 

assigned a higher labor hour to any teardown motor which it determined to be 

hand-wound. NEMA commented that 

DOE did not assign a hand-wound 

labor-hour assumption to any of the 

tear-down motors, and requested 

clarification about whether there were 

instances of hand winding in these 

motors. (NEMA, No. 54 at p. 23) DOE 

found that none of the tear-down motors 

were hand-wound, and therefore no 

hand-winding labor-hour amounts were 

assigned. This has been clarified in the 

NOPR analysis. Additionally, DOE has 

assumed that all of its max-tech 

software models require hand-winding, 

which is reflected in its increased labor 

time assumptions for those motors. For 

additional details please see chapter 5 of 

the TSD. 

In response to DOE’s request for 

comment on the possibility of higher 

labor costs for lower-volume electric 

motors, NEMA indicated that plants 

with few manufacturing setup changes, 

because they may focus on standard 

motor designs with no special motors, 

have the ability to produce more motors 

per employee, and that this is the case 

with many offshore companies that 

build designs for import to the U.S. 

(NEMA, No. 54 at pp. 27, 28). For other 

companies that cater to OEMs that 

require special designs and small lot 

production, setup changes eat into the 

capacity of these plants, particularly in 

the 56/140T through 250T frame series 

where there is high volume. A plant 

where the lot (i.e., batch) size per order 

is smaller has less impact from setup. 

DOE acknowledges that lower-volume 

products will often realize higher per 

unit costs, and believes this reality is 

common to most or all manufacturing 

processes in general. Because DOE’s 

analysis focuses on the differential 

impacts on cost due to standards, and 

because DOE has no evidence to suggest 

a significant market shift to lower 

production volume in a post-standards 

scenario, DOE expects that the relative 

mix of high- and low-volume 

production would be preserved. Indeed, 

because DOE is proposing to expand 

scope of coverage and bring many 

previously-excluded motor types to 

NEMA Premium levels, DOE sees the 

possibility that standardization may 

increase and average production volume 

may, in fact, rise.61 DOE welcomes 

additional comment on how standards 

may cause average production run 

volume to rise or fall, and how labor 

costs may vary as a result. 

c. Catalog Prices 

NEMA also requested that DOE 

publish the purchase price for its torn 

down motors, so that they could be 

compared to the MSPs DOE derived 

from its motor tear-downs. (NEMA, No. 

54 at p. 27; Baldor, Public Meeting 

Transcript, No. 60 at pp. 181, 182) At 

this time, DOE is electing not to include 

the purchase price for its torn down 

motors. DOE believes that such 

information is not relevant and could 

lead to erroneous conclusions. Some of 

the purchased motors were more 

expensive to purchase based on certain 

features that do not affect efficiency, 

which could skew the price curves 

incorrectly and indicate incorrect 

trends. For these reasons, in the 

engineering analysis, DOE develops its 

own cost model so that a consistent cost 

structure can be applied to similar 

equipment. The details of this model are 

available in appendix 5A. Because DOE 

purchased electric motors that were 

built by different manufacturers and 

sold by different distributors, who all 

have different costs structures, DOE 

does not believe that such a comparison 

is a meaningful evaluation. 

d. Product Development Cost 

In response to the preliminary 

analysis, NEMA commented that DOE 

presumes that the incremental cost 

between motors of different designs and 

different technologies is based solely on 

the difference in material costs and 

markups. NEMA also commented that 

there is a higher cost of manufacturing 

a die-cast copper rotor compared to an 

aluminum die-cast rotor motor that is 

not captured in material costs. (NEMA, 

No. 54 at p. 12, 74) During the 

preliminary analysis public meeting, 

ACEEE commented that the Motor 

Coalition has concerns about CSL 3 for 

ECG 1, stating that DOE’s analysis may 

not have captured the full cost of an 

industry-transition to that efficiency 

level. (ACEEE, Public Meeting 

Transcript, No. 60 at p. 20) 

DOE has made some additions to its 

cost model for the NOPR analysis based 

on NEMA’s comments. However, DOE 

clarifies that its cost model for the 

preliminary analysis did include an 

incremental markup used to account for 

higher production costs associated with 

manufacturing copper die-cast rotors. 

Although DOE used this incremental 

markup in the preliminary analysis, 

after conducting manufacturer 

interviews for the NOPR analysis, it 

believed that additional costs were 

warranted for the examined ELs that 

exceeded the NEMA Premium level. 

NEMA commented that the 

manufacturer production costs (MPCs) 

and subsequent LCCs must take into 

account the large additional conversion 

costs, since manufacturers would likely 

attempt to recover the costs of meeting 

a higher efficiency standard. (NEMA, 

No. 54 at p. 4) Therefore, DOE 

developed a per-unit adder 62 for the 

MPCs intended to capture one-time 

increased product development and 

capital conversion costs that would 

likely result if an efficiency level above 

NEMA Premium were established. 

DOE’s per-unit adder reflects the 

additional cost passed along to the 

consumer by manufacturers attempting 

to recover the costs incurred from 

having to redevelop their equipment 

lines as a result of higher energy 

conservation standards. The conversion 

costs incurred by manufacturers include 

capital investment (e.g., new tooling and 

machinery), equipment development 

(e.g., reengineering each motor design 

offered), plus testing and compliance 

certification costs. 

The conversion cost adder was only 

applied to ELs above NEMA Premium 

based on manufacturer feedback. Most 

manufacturers now offer NEMA 

Premium motors for a significant 

portion of their equipment lines as a 

result of EISA 2007, which required 

manufacturers to meet this level. Many 

manufacturers also offer certain ratings 

with efficiency levels higher than 

NEMA Premium. However, DOE is not 

aware of any manufacturer with a 

complete line of motors above NEMA 

Premium. Consequently, DOE believes 

that energy conservation standards 

above NEMA Premium would result in 

manufacturers incurring significant 

conversion costs to bring offerings of 

electric motors up to the higher 

standard. 

DOE developed the various 

conversion costs from data collected 

during manufacturer interviews that 

were conducted for the Manufacturer 

Impact Analysis (MIA). For more 

information on the MIA, see TSD 

chapter 12. DOE used the manufacturersupplied data to estimate industry-wide 

capital conversion costs and product 

conversion costs for each EL above 

NEMA Premium. DOE then assumed 

that manufacturers would mark up their 

motors to recover the total conversion 

costs over a seven year period. By 

dividing industry-wide conversion costs 

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wide revenue, DOE obtained a 

percentage estimate of how much each 

motor would be marked up by 

manufacturers. The conversion costs as 

a percentage of 7-year revenue that DOE 

derived for each NEMA band above 

NEMA premium are shown below. 

Details on these calculations are shown 

in Chapter 5 of the TSD. 

TABLE IV.13—PRODUCT CONVERSION

COSTS AS A PERCENTAGE OF 7- 

YEAR REVENUE

NEMA 

bands above 

NEMA premium 

Conversion costs 

as a percentage 

of 7-year 

revenue 

(percent) 

1 ...................................... 4.1 

2 ...................................... 6.5 

The percentage markup was then 

applied to the full production cost 

(direct material + direct labor + 

overhead) at the NEMA Premium levels 

to derive the per unit adder for levels 

above NEMA Premium (see Table 

IV.14). 

TABLE IV.14—PRODUCT CONVERSION COSTS FOR EFFICIENCY LEVELS ABOVE NEMA PREMIUM

Representative unit 

Per unit 

adder for 1 

band above 

NEMA premium 

Per unit 

adder for 2 

bands above 

NEMA premium 

5 HP, Design B ................................................................................................................................................ $11.06 $17.36 

30 HP, Design B .............................................................................................................................................. 32.89 1.61 

75 HP, Design B .............................................................................................................................................. 66.18 103.86 

5 HP, Design C ................................................................................................................................................ 10.68 16.75 

50 HP, Design C .............................................................................................................................................. 60.59 95.08 

7. Engineering Analysis Results 

The results of the engineering analysis 

are reported as cost versus efficiency 

data in the form of MSP (in dollars) 

versus nominal full-load efficiency (in 

percentage). These data form the basis 

for subsequent analyses in today’s 

NOPR. Table IV.15 through Table IV.19 

show the results of DOE’s updated 

NOPR engineering analysis. 

Results for Equipment Class Group 1 

(NEMA Design A and B Electric Motors) 

TABLE IV.15—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline) ................................................................................................................................................ 82.5 330 

EL 1 (EPACT 1992) ......................................................................................................................................... 87.5 341 

EL 2 (NEMA Premium) .................................................................................................................................... 89.5 367 

EL 3 (Best-in-Market) ...................................................................................................................................... 90.2 402 

EL 4 (Max-Tech) .............................................................................................................................................. 91.0 670 

TABLE IV.16—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 30-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline) ................................................................................................................................................ 89.5 848 

EL 1 (EPACT 1992) ......................................................................................................................................... 92.4 1,085 

EL 2 (NEMA Premium) .................................................................................................................................... 93.6 1,156 

EL 3 (Best-in-Market) ...................................................................................................................................... 94.1 1,295 

EL 4 (Max-Tech) .............................................................................................................................................. 94.5 2,056 

TABLE IV.17—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 75-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline) ................................................................................................................................................ 93.0 1,891 

EL 1 (EPACT 1992) ......................................................................................................................................... 94.1 2,048 

EL 2 (NEMA Premium) .................................................................................................................................... 95.4 2,327 

EL 3 (Best-in-Market) ...................................................................................................................................... 95.8 2,776 

EL 4 (Max-Tech) .............................................................................................................................................. 96.2 3,620 

Results for Equipment Class Group 2 

(NEMA Design C Electric Motors) 

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TABLE IV.18—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline/EPACT 1992) .......................................................................................................................... 87.5 331 

EL 1 (NEMA Premium) .................................................................................................................................... 89.5 355 

EL 2 (Max-Tech) .............................................................................................................................................. 91.0 621 

TABLE IV.19—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 50-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline/EPACT 1992) .......................................................................................................................... 93.0 1,537 

EL 1 (NEMA Premium) .................................................................................................................................... 94.5 2,130 

EL 2 (Max-Tech) .............................................................................................................................................. 95.0 2,586 

Results for Equipment Class Group 3 

(Fire Pump Electric Motors) 

TABLE IV.20—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturing 

selling price 

($) 

EL 0 (Baseline/EPACT 1992) .......................................................................................................................... 87.5 341 

EL 1 (NEMA Premium) .................................................................................................................................... 89.5 367 

EL 2 (Best-in-Market) ...................................................................................................................................... 90.2 402 

EL 3 (Max-Tech) .............................................................................................................................................. 91.0 670 

TABLE IV.21—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 30-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline/EPACT 1992) .......................................................................................................................... 92.4 1,085 

EL 1 (NEMA Premium) .................................................................................................................................... 93.6 1,156 

EL 2 (Best-in-Market) ...................................................................................................................................... 94.1 1,295 

EL 3 (Max-Tech) .............................................................................................................................................. 94.5 2,056 

TABLE IV.22—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 75-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline/EPACT 1992) .......................................................................................................................... 94.1 2,048 

EL 1 (NEMA Premium) .................................................................................................................................... 95.4 2,327 

EL 2 (Best-in-Market) ...................................................................................................................................... 95.8 2,776 

EL 3 (Max-Tech) .............................................................................................................................................. 96.2 3,620 

Results for Equipment Class Group 4 

(Brake Electric Motors) 

TABLE IV.23—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline) ................................................................................................................................................ 82.5 330 

EL 1 (EPACT 1992) ......................................................................................................................................... 87.5 341 

EL 2 (NEMA Premium) .................................................................................................................................... 89.5 367 

EL 3 (Best-in-Market) ...................................................................................................................................... 90.2 402 

EL 4 (Max-Tech) .............................................................................................................................................. 91.0 670 

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TABLE IV.24—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 30-HORSEPOWER REPRESENTATIVE UNIT

Efficiency level Efficiency 

(%) 

Manufacturer 

selling price 

($) 

EL 0 (Baseline) ................................................................................................................................................ 89.5 848 

EL 1 (EPACT 1992) ......................................................................................................................................... 92.4 1,085 

EL 2 (NEMA Premium) .................................................................................................................................... 93.6 1,156 

EL 3 (Best-in-Market) ...................................................................................................................................... 94.1 1,295 

EL 4 (Max-Tech) .............................................................................................................................................. 94.5 2,056 

8. Scaling Methodology 

Once DOE has identified costefficiency relationships for its 

representative units, it must 

appropriately scale the efficiencies 

analyzed for its representative units to 

those equipment classes not directly 

analyzed. DOE recognizes that scaling 

motor efficiencies is a complicated 

proposition that has the potential to 

result in efficiency standards that are 

not evenly stringent across all 

equipment classes. However, between 

DOE’s four ECGs, there are 580 

combinations of horsepower rating, pole 

configuration, and enclosure. Within 

these combinations there are a large 

number of standardized frame number 

series. Given the sizable number of 

frame number series and equipment 

classes, DOE cannot feasibly analyze all 

of these variants, hence, the need for 

scaling. Scaling across horsepower 

ratings, pole configurations, enclosures, 

and frame number series is a necessity. 

For the preliminary analysis, DOE 

considered two methods to scaling, one 

that develops a set of power law 

equations based on the relationships 

found in the EPACT 1992 and NEMA 

Premium tables of efficiency in NEMA 

Standard Publication MG 1, and one 

based on the incremental improvement 

of motor losses. As discussed in the 

preliminary analysis, DOE did not find 

a large discrepancy between the results 

of the two approaches and, therefore, 

used the simpler, incremental 

improvement of motor losses approach 

in its NOPR analysis. 

As discussed in IV.C.3, some of the 

ELs analyzed by DOE were based on 

existing efficiency standards (i.e., 

EPACT 1992 and NEMA Premium). 

Additionally, the baseline EL is based 

on the lowest efficiency levels found for 

each horsepower rating, pole 

configuration, and enclosure type 

observed in motor catalog data. 

Therefore, DOE only required the use of 

scaling when developing the two ELs 

above NEMA Premium (only one EL 

above NEMA Premium for ECG 2). 

For the higher ELs in ECG 1, DOE’s 

scaling approach relies on NEMA MG 

1–2011 Table 12–10 of nominal 

efficiencies and the relative 

improvement in motor losses of the 

representative units. As has been 

discussed, each incremental 

improvement in NEMA nominal 

efficiency (or NEMA band) corresponds 

to roughly a 10 percent reduction in 

motor losses. After ELs 3 and 4 were 

developed for each representative unit, 

DOE applied the same reduction in 

motor losses (or the same number of 

NEMA band improvements) to various 

segments of the market based on its 

representative units. DOE assigned a 

segment of the electric motors market, 

based on horsepower ratings, to each 

representative unit analyzed. DOE’s 

assignments of these segments of the 

markets were in part based on the 

standardized NEMA frame number 

series that NEMA MG 1–2011 assigns to 

horsepower and pole combinations. In 

the end, EL 3 corresponded to a one 

band improvement relative to NEMA 

Premium and EL 4 corresponded to a 

two-band improvement relative to 

NEMA Premium. In response to the 

preliminary analysis, DOE received 

multiple comments regarding scaling. 

NEMA commented that DOE states 

that scaling is necessary for the national 

impacts analysis, but NEMA contends 

that the foremost reason for the scaling 

is that the scaling is used to establish 

the values of any amended or new 

efficiency standards. (NEMA, No. 54 at 

p. 68) NEMA also expressed its belief 

that the scaling method used in the 

preliminary analysis does not 

adequately take into consideration 

numbers of poles, stack length, and 

frame enclosures and that scaling based 

on changes in efficiency for lower 

horsepower motor models, as 

interpreted by software, does not 

accurately reflect what is achievable for 

higher horsepower ratings. (NEMA, No. 

54 at p. 5) 

During the preliminary analysis 

public meeting, Baldor commented that 

because some energy conservation 

levels could not be reached without 

using a different technology option, at 

least 30 percent of the ratings in an 

equipment classes could not achieve 

energy conservation levels above CSL 2. 

Because of this, a scaling method based 

on any particular set of technology is 

not scalable across all equipment 

classes. Baldor suggested that DOE 

could use software modeling to check 

some of the motor configurations not 

directly analyzed. (Baldor, Public 

Meeting Transcript, No. 60 at pp. 196, 

197, 200) 

Nidec commented during the public 

meeting that scaling has too many 

variables, and that manufacturers do not 

use scaling because it is not possible. 

(Nidec, Public Meeting Transcript, No. 

60 at pp. 198–199) ACEEE added that 

there is no underlying fundamental 

physical theory associated with the 

efficiencies listed in NEMA MG 1–2011 

Table 12–11 or Table 12–12. (ACEEE, 

Public Meeting Transcript, No. 60 at pp. 

198–199) 

DOE appreciates the comments 

received regarding scaling; however, it 

maintains that scaling is a tool 

necessary to analyze the potential 

effects of energy conservation standards 

above NEMA Premium levels. As stated 

earlier, DOE is evaluating energy 

conservation standards for 580 

equipment classes. DOE acknowledges 

that analyzing every one of these classes 

individually is not feasible, which 

requires DOE to choose representative 

units on which to base its analysis. DOE 

agrees with Baldor that the primary 

reason for scaling is to establish 

efficiency levels for any potential new 

or amended standards for electric 

motors. 

However, DOE notes that its analysis 

neither assumes nor requires 

manufacturers to use identical 

technology for all motor types and 

horsepower ratings. In other words, 

although DOE may choose a certain set 

of technologies to estimate cost behavior 

across efficiency, DOE’s standards are 

technology-neutral and permit 

manufacturers design flexibility. DOE 

clarifies that the national impacts 

analysis is one of the primary ways in 

which DOE analyses those potential 

efficiency levels and determines if they 

would be economically justified. As 

DOE has stated, it is also important that 

the levels be technically feasible. In 

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63RS Means (2013), Electrical Cost Data, 36th 

Annual Edition, Kingston, MA. 

64Strategic Energy Group (January, 2008), 

Northwest Industrial Motor Database Summary 

from Regional Technical Forum. http://

rtf.nwcouncil.org/subcommittees/osumotor/

Default.htm. This database provides information on 

motors collected by the Industrial Assessment 

Center (IAC) at Oregon State University (OSU). The 

database includes more than 22,000 records, each 

with detailed motor application and field usage 

data. 

order to maintain technical feasibility, 

DOE has maintained the scaling 

approach that it developed for the 

preliminary analysis. DOE believes that 

this approach, which is as conservative 

as possible while maintaining the use of 

NEMA nominal efficiencies, 

accomplishes that. For each incremental 

EL above the NEMA Premium level, 

DOE has incremented possible 

efficiency levels by just one band of 

efficiency. Through the use of this 

conservative approach to scaling, DOE 

believes that it has helped conserve the 

technological feasibility of each of its 

ELs to the greatest extent practicable. 

D. Markups Analysis 

The markups analysis develops 

appropriate markups in the distribution 

chain to convert the estimates of 

manufacturer selling price derived in 

the engineering analysis to customer 

prices. (‘‘Customer’’ refers to purchasers 

of the equipment being regulated). In 

the preliminary analysis, DOE 

determined the distribution channels for 

electric motors, their shares of the 

market, and the markups associated 

with the main parties in the distribution 

chain, distributors and contractors. For 

the NOPR, DOE retained these 

distribution channels. 

DOE developed average distributor 

and contractor markups by examining 

the contractor cost estimates provided 

by RS Means Electrical Cost Data 

2013.63 DOE calculates baseline and 

overall incremental markups based on 

the equipment markups at each step in 

the distribution chain. The incremental 

markup relates the change in the 

manufacturer sales price of higher 

efficiency models (the incremental cost 

increase) to the change in the customer 

price. Chapter 6 of the NOPR TSD 

addresses estimating markups. 

E. Energy Use Analysis 

The energy use analysis provides 

estimates of the annual energy 

consumption of commercial and 

industrial electric motors at the 

considered efficiency levels. DOE uses 

these values in the LCC and PBP 

analyses and in the NIA. DOE 

developed energy consumption 

estimates for all equipment analyzed in 

the engineering analysis. 

The annual energy consumption of an 

electric motor that has a given nominal 

full-load efficiency depends on the 

electric motor’s sector (industry, 

agriculture, or commercial) and 

application (compressor, fans, pumps, 

material handling, fire pumps, and 

others), which in turn determine the 

electric motor’s annual operating hours 

and load. 

To calculate the annual kilowatthours (kWh) consumed at each 

efficiency level in each equipment class, 

DOE used the nominal efficiencies at 

various loads from the engineering 

analysis, along with estimates of 

operating hours and electric motor load 

for electric motors in various sectors 

and applications. 

In the preliminary analysis, DOE used 

statistical information on annual electric 

motor operating hours and load derived 

from a database of more than 15,000 

individual motor field assessments 

obtained through the Washington State 

University and the New York State 

Energy Research and Development 

Authority to determine the variation in 

field energy use in the industrial sector. 

For the agricultural and the commercial 

sector, DOE relied on data found in the 

literature. 

As part of its NOPR analysis, for the 

industrial sector, DOE re-examined its 

initial usage profiles and recalculated 

motor distribution across applications, 

operating hours, and load information 

based on additional motor field data 

compiled by the Industrial Assessment 

Center at the University of Oregon, 

which includes over 20,000 individual 

motor records. For the agricultural 

sector, DOE revised its average annual 

operating hours assumptions based on 

additional data found in the literature. 

No changes were made to the 

commercial sector average annual 

operating hours. 

Chapter 7 of the NOPR TSD describes 

the energy use analysis. 

1. Comments on Operating Hours 

Several interested parties commented 

on the annual operating hours 

assumptions. NEMA and UL 

commented that fire pumps typically 

operate when being tested on a monthly 

basis and that the annual operating-hour 

assumption for fire pump electric 

motors in the industrial sector seemed 

high but did not provide data to support 

their comment. NEMA agreed with the 

fire pump electric motor annual 

operating-hour assumptions in the 

commercial and agricultural sectors. 

(NEMA, No. 54 at p. 83) (UL, No. 46 at 

p. 1) 

For the NOPR, DOE reviewed the field 

data for fire pump electric motors used 

in the preliminary analysis and noticed 

some values were associated with 

motors driving jockey pumps, which are 

pressure maintenance pumps used to 

maintain pressure in fire sprinkler 

systems. After filtering out the motors 

driving jockey pumps, DOE derived an 

average value of annual operating hours 

similar to the fire pump electric motor 

annual operating hours for the 

commercial and agricultural sectors. 

Therefore, DOE revised its fire pumps 

operating hour assumption accordingly. 

NEMA submitted data regarding 

annual operating hour assumptions in 

the industrial sector based on its expert 

knowledge. These assumptions were 

lower than those used in the 

preliminary analysis. (NEMA, No. 54 at 

p. 10) 

As previously mentioned, DOE 

revised the average operating hours 

associated with applications in the 

industrial sector (compressor, fans, 

pump, material handling, and others) 

based on additional individual motor 

nameplate and field data compiled by 

the Industrial Assessment Center at the 

University of Oregon.64 The revised 

average operating hour values are 

generally lower than the estimates from 

the preliminary analysis and differ from 

what NEMA provided. DOE could not 

verify the estimates provided by NEMA 

and it is not clear that these estimates 

represent an accurate picture of the 

entire industrial sector. In contrast, the 

average operating hours by motor 

application that DOE used in the NOPR 

were based on an analysis of annual 

operating hours for over 35,000 

individual motors. DOE notes that it 

analyzed a sensitivity case that reflects 

the NEMA estimates. 

IECA commented that the database of 

plant assessments is based on surveys 

conducted between 2005 and 2011 and 

there is no explanation of the effects of 

the recession on these surveys. (IECA, 

No. 52 at p. 2) DOE could not estimate 

the impact of the recession on the 

average operating hour values derived 

from the database of field assessment 

from the Washington State University 

and the New York State Energy 

Research and Development Authority, 

as the year of the assessment was not 

specified for all of the entries. The 

additional data from the Industrial 

Assessment Center cover a longer time 

period (1987–2007). Thus, DOE believes 

that its estimates of operating hours are 

not unduly affected by lower industrial 

activity during the recession. 

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65The slip is the difference between the 

synchronous speed of the magnetic field (as defined 

by the number of poles), and the actual rotating 

speed of the motor shaft. 

66 DOE assumed that 60 percent of pumps, fans 

and compressor applications are variable torque 

applications. Of these 60 percent, DOE assumed 

that all fans and a majority (70 percent) of 

compressors and pumps would be negatively 

impacted by higher operating speeds; and that 30 

percent of compressors and pumps would not be 

negatively impacted from higher operating speeds 

as their time of use would decrease as the flow 

increases with the speed (e.g. a pump filling a 

reservoir). 

2. Comments on Other Issues 

In response to DOE’s energy use 

discussion from the preliminary 

analysis, NEMA commented that NEMA 

Design C motors are not typically found 

in pump applications. (NEMA, No. 54 at 

p. 83) For NEMA Design C motors, DOE 

re-examined its distribution by 

application and agrees with NEMA that 

NEMA Design C motors are not typically 

found in pump applications. These 

motors are characterized by high torque 

and generally found in compressors and 

other applications such as conveyors. 

Consistent with this review, DOE 

adjusted its analyses. 

NEMA commented that the curve fit 

for the polynomial equations modeling 

the load versus losses relationships for 

NEMA Design B motors did not seem to 

represent the test data accurately. 

(NEMA, No. 54 at p. 81) 

For each representative unit, DOE 

based its energy use calculation on 

nominal values of efficiency. DOE 

obtained data on part load losses from 

test data developed in the engineering 

analysis and fitted these data to derive 

load versus losses relationships in the 

form of a third degree polynomial 

equation. The representative units 

showed tested efficiencies which were 

not equal to the nominal efficiencies 

and DOE adjusted the coefficients of the 

polynomial equations to match the full 

load losses expected at nominal 

efficiency. The adjusted equation, 

therefore, calculates losses for a motor 

with full load efficiency equal to the full 

load nominal efficiency. For the NOPR, 

DOE followed the same approach and 

revised the polynomial equations to 

reflect the NOPR engineering outputs. 

NEMA commented that the 

installation of a more efficient motor in 

variable torque applications could lead 

to less energy savings than anticipated. 

Because a more efficient motor usually 

has less slip 65 than a less efficient one 

does, this attribute can result in a higher 

operating speed and a potential 

overloading of the motor. NEMA 

recommended that DOE include the 

consequence of a more efficient motor 

operating at an increased speed in any 

determination of energy savings. 

(NEMA, No. 54 at p. 28) 

DOE acknowledges that the arithmetic 

cubic relation between speed and power 

requirement in many variable torque 

applications can affect the benefits 

gained by using efficient electric motors, 

which have a lower slip. DOE agrees 

that it is possible to quantify this impact 

for one individual motor. However, DOE 

was not able to extend this analysis to 

the national level. DOE does not have 

robust data related to the overall share 

of motors that would be negatively 

impacted by higher speeds in order to 

incorporate this effect in the main 

analysis. Further, in the engineering 

analysis, DOE could not extend the 

synchronous speed information from 

the representative units to the full range 

of electric motor configurations. Instead, 

DOE developed assumptions 66 and 

estimated the effects of higher operating 

speeds as a sensitivity analysis in the 

LCC spreadsheet. For the representative 

units analyzed in the LCC analysis, the 

LCC spreadsheet allows one to consider 

this effect as a sensitivity analysis 

according to a scenario described in 

appendix 7–A of the NOPR TSD. 

IECA commented that estimates of 

regional shares of motors should be 

based on current inventories of motors 

rather than sector-specific indicators 

and that the data from the 2006 

Manufacturer Energy Consumption 

Survey (MECS) is outdated. (IECA, No. 

52 at p. 2) DOE did not find any 

information regarding motor inventory 

and instead used indirect indicators to 

derive motor distribution. For the 

NOPR, DOE updated its regional shares 

of motors based on industrial electricity 

consumption by region from AEO 2013. 

F. Life-Cycle Cost and Payback Period 

Analysis 

For each representative unit analyzed 

in the engineering analysis, DOE 

conducts LCC and PBP analyses to 

evaluate the economic impacts on 

individual customers of potential energy 

conservation standards for electric 

motors. The LCC is the total customer 

expense over the life of the motor, 

consisting of equipment and installation 

costs plus operating costs over the 

lifetime of the equipment (expenses for 

energy use, maintenance and repair). 

DOE discounts future operating costs to 

the time of purchase using customer 

discount rates. The PBP is the estimated 

amount of time (in years) it takes 

customers to recover the increased total 

installed cost (including equipment and 

installation costs) of a more efficient 

type of equipment through lower 

operating costs. DOE calculates the PBP 

by dividing the change in total installed 

cost (normally higher) due to a standard 

by the change in annual operating cost 

(normally lower) which results from the 

standard. 

For any given efficiency level, DOE 

measures the PBP and the change in 

LCC relative to an estimate of the basecase efficiency levels. The base-case 

estimate reflects the market in the 

absence of new or amended energy 

conservation standards, including the 

market for equipment that exceeds the 

current energy conservation standards. 

For each representative unit, DOE 

calculated the LCC and PBP for a 

distribution of individual electric 

motors across a range of operating 

conditions. DOE used Monte Carlo 

simulations to model the distributions 

of inputs. The Monte Carlo process 

statistically captures input variability 

and distribution without testing all 

possible input combinations. Therefore, 

while some atypical situations may not 

be captured in the analysis, DOE 

believes the analysis captures an 

adequate range of situations in which 

electric motors operate. 

The following sections contain brief 

discussions of comments on the inputs 

and key assumptions of DOE’s LCC and 

PBP analysis and explain how DOE took 

these comments into consideration. 

1. Equipment Costs 

In the LCC and PBP analysis, the 

equipment costs faced by electric motor 

purchasers are derived from the MSPs 

estimated in the engineering analysis 

and the overall markups estimated in 

the markups analysis. 

To forecast a price trend for the 

preliminary analysis, DOE derived an 

inflation-adjusted index of the producer 

price index (PPI) for integral 

horsepower motors and generators 

manufacturing from 1969 to 2011. These 

data show a long-term decline from 

1985 to 2003, and then a steep increase 

since then. DOE also examined a 

forecast based on the ‘‘chained price 

index—industrial equipment’’ that was 

forecasted for AEO2012 out to 2040. 

This index is the most disaggregated 

category that includes electric motors. 

These data show a short-term increase 

from 2011 to 2015, and then a steep 

decrease since then. DOE believes that 

there is considerable uncertainty as to 

whether the recent trend has peaked, 

and would be followed by a return to 

the previous long-term declining trend, 

or whether the recent trend represents 

the beginning of a long-term rising trend 

due to global demand for electric motors 

and rising commodity costs for key 

motor components. Given the 

uncertainty, DOE chose to use constant 

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67 Vaughen’s (2011, 2013), Vaughen’s Motor & 

Pump Repair Price Guide, 2011, 2013 Edition. 

http://www.vaughens.com/. 

68U.S. Economic Census 1997 and 2007 data on 

the number of motor repair establishments (based 

on NAICS 811, 811310, and SIC 7694). 

69Members of EASA available at: http://

www.easa.com/. 

prices (2010 levels) for both its LCC and 

PBP analysis and the NIA. For the NIA, 

DOE also analyzed the sensitivity of 

results to alternative electric motor price 

forecasts. 

DOE did not receive comments on the 

trend it used for electric motor prices, 

and it retained the approach used in the 

preliminary analysis for the NOPR. 

2. Installation Costs 

In the preliminary analysis, the 

engineering analysis showed that for 

some representative units, increased 

efficiency led to increased stack length. 

However, the electric motor frame 

remained in the same NEMA frame size 

requirements as the baseline electric 

motor, and the motor’s ‘‘C’’ dimension 

remained fairly constant across 

efficiency levels. In addition, electric 

motor installation cost data from RS 

Means Electrical Cost Data 2013 showed 

a variation in installation costs by 

horsepower (for three-phase electric 

motors), but not by efficiency. 

Therefore, in the preliminary analysis, 

DOE assumed there is no variation in 

installation costs between a baseline 

efficiency electric motor and a higher 

efficiency electric motor. 

Two interested parties commented 

that DOE might have to consider 

increased installation costs related to 

larger diameter motors in comparison to 

baseline motors. (CA IOUs, No. 57 at p. 

2; NEMA, No. 54 at p. 83) NEMA added 

that the size of a motor may need to be 

increased to provide the necessary 

material to obtain higher levels of 

energy efficiency, such as CSL 3 

examined for Design B electric motors. 

(NEMA, No. 54 at p. 83) 

DOE’s engineering data show that the 

motor’s ‘‘C’’ dimension remained fairly 

constant across efficiency levels. For 

equipment class Group 1, the stack 

length of higher efficiency motors (EL 3 

and above) did not show significant 

increases in size in comparison to 

NEMA Premium level motors (EL 2). In 

addition, the frame size remained the 

same and the ‘‘C’’ dimension data did 

not significantly vary. Therefore, for the 

NOPR, DOE retained the same approach 

as in the preliminary analysis and did 

not incorporate changes in installation 

costs for electric motors that are more 

efficient than baseline equipment. 

NEMA stated that when a user 

replaces a baseline NEMA Design B 

motor with a higher efficiency NEMA 

Design A motor, the user might 

experience additional installation costs 

compared to replacing the motor with a 

baseline NEMA Design B motor due to, 

for example, potential needs for new 

motor controller or motor protection 

devices. (NEMA, No. 54 at p. 29) In the 

engineering analysis, for equipment 

class Group 1, all representative units 

selected were NEMA Design B motors 

and the NEMA Design B requirements 

are maintained across all efficiency 

levels. Therefore, DOE did not account 

for additional installation costs related 

to the replacement of NEMA Design B 

motors with NEMA Design A motors. 

3. Maintenance Costs 

In the preliminary analysis, DOE did 

not find data indicating a variation in 

maintenance costs between a baseline 

efficiency and higher efficiency electric 

motor. According to data from 

Vaughen’s Price Publishing Company,67

which publishes an industry reference 

guide on motor repair pricing, the price 

of replacing bearings, which is the most 

common maintenance practice, is the 

same at all efficiency levels. Therefore, 

DOE did not consider maintenance costs 

for electric motors. DOE did not receive 

comments on this issue and retained the 

approach used for the preliminary 

analysis for the NOPR. 

4. Repair Costs 

In the preliminary analysis, DOE 

accounted for the differences in repair 

costs of a higher efficiency motor 

compared to a baseline efficiency motor 

and defined a repair as including a 

rewind and reconditioning. Based on 

data from Vaughen’s, DOE derived a 

model to estimate repair costs by 

horsepower, enclosure and pole, for 

each EL. 

The Electrical Apparatus Service 

Association (EASA), which represents 

the electric motor repair service sector, 

noted that DOE should clarify the 

definition of repair as including 

rewinding and reconditioning. (EASA, 

No. 47 at p. 1) DOE agrees with this 

suggestion and has modified its 

terminology in chapter 7 of the NOPR 

TSD. 

One interested party, Flolo 

Corporation, noted that since the 1990’s, 

increased windings protection has led to 

longer repair cycles and the repair 

frequency values used in the 

preliminary analysis were too low. (Pub. 

Mtg. Tr., No. 58 at p. 234) 

For the preliminary analysis, DOE 

estimated that NEMA Design A, B and 

C electric motors were repaired on 

average after 32,000 hours of operation 

based on data for the industrial sector. 

This estimate reflected a situation where 

electric motors from 1 to 20-horsepower, 

with an average lifetime of 5 years, are 

not repaired; motors from 25- to 75- 

horsepower, with an average lifetime of 

10 years, are repaired at half their 

lifetime; and motors from 100- to 500- 

horsepower, with an average lifetime of 

15 years, are repaired at a third of their 

lifetime. In the NOPR analysis, DOE 

retained a similar approach for the 

industrial and commercial sectors. For 

the agricultural sector, DOE did not find 

sufficient data to distinguish by 

horsepower range and assumed that 

motors are repaired on average at half of 

their lifetime. With the revised NOPR 

mechanical lifetime and operating hour 

estimates, the repair frequency in hours 

increased to 48,600 hours in the 

industrial sector compared to DOE’s 

earlier estimate of 32,000 hours. 

5. Unit Energy Consumption 

The NOPR analysis uses the same 

approach for determining unit energy 

consumptions (UECs) as the preliminary 

analysis. The UEC was determined for 

each application and sector based on 

estimated load points and annual 

operating hours. For the NOPR, DOE 

refined the average annual operating 

hours, average load, and shares of 

motors by application and sector. 

In the preliminary analysis, DOE 

assumed that one-third of repairs are 

done following industry recommended 

practice as defined by EASA. (EASA 

Standard AR100–2010, Recommended 

Practice for the Repair of Rotating 

Electrical Apparatus) and do not impact 

the efficiency of the electric motor (i.e., 

no degradation of efficiency after 

repair). DOE assumed that two-thirds of 

repairs do not follow good practice and 

that a slight decrease in efficiency 

occurs when the electric motor is 

repaired. DOE assumed the efficiency 

decreases by 1 percent in the case of 

electric motors of less than 40 

horsepower, and by 0.5 percent in the 

case of larger electric motors. 

NEMA and EASA asked DOE to 

clarify its assumption regarding the 

share of repairs performed following 

industry recommended practices. 

(NEMA, No. 54 at p. 29) (EASA, No. 47 

at p. 1) For the NOPR, DOE reviewed 

data from the U.S. Economic Census 68

and EASA 69 and estimated that the 

majority of motor repair shops are EASA 

members and follow industry 

recommended practices. DOE revised its 

assumption for the NOPR analysis and 

estimated that 90 percent of repairs are 

done following industry recommended 

practice and would not impact the 

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70U.S. Department of Energy Information 

Administration (2003), Commercial Buildings 

Energy Consumption Survey, http://www.eia.gov/

consumption/commercial/data/2003/pdf/a4.pdf. 

71 Gallaher, M., Delhotal, K., & Petrusa, J. (2009). 

Estimating the potential CO2 mitigation from 

agricultural energy efficiency in the United States. 

Energy Efficiency, 2 (2):207–220. 

72Robert Boteler, USA Motor Update 2009, 

Energy Efficient Motor Driven Systems Conference 

(EEMODS) 2009. 

efficiency of the motor (i.e. no 

degradation of efficiency after repair). 

NEMA also requested clarification on 

whether the LCC is based on site energy 

or full fuel cycle energy. (NEMA, No. 54 

at p. 31) In the LCC, DOE considers site 

energy use only. 

6. Electricity Prices and Electricity Price 

Trends 

In the preliminary analysis, DOE 

derived sector-specific weighted average 

electricity prices for four different U.S. 

Bureau of the Census (Census) regions 

(Northeast, Midwest, South, and West) 

using data from the Energy Information 

Administration (EIA Form 861). For 

each utility in a region, DOE used the 

average industrial or commercial price, 

and then weighted the price by the 

number of customers in each sector for 

each utility. 

For each representative motor, DOE 

assigned electricity prices using a Monte 

Carlo approach that incorporated 

weightings based on the estimated share 

of electric motors in each region. The 

regional shares were derived based on 

indicators specific to each sector (e.g., 

commercial floor space from the 

Commercial Building Energy 

Consumption Survey for the commercial 

sector 70) and assumed to remain 

constant over time. To estimate future 

trends in energy prices, DOE used 

projections from the EIA’s Annual 

Energy Outlook 2011 (AEO 2011). The 

NOPR retains the same approach for 

determining electricity prices, and used 

AEO 2013 to project electricity price 

trends. 

IECA commented that the sector 

specific average electricity prices do not 

account for differences across census 

regions where industrial activity is 

concentrated. (IECA, No. 52 at p. 2) As 

noted above, the industrial electricity 

price for each region is a weighted 

average based on the number of 

industrial customers of each utility. 

Thus, the prices reasonably account for 

concentration of industrial activity. 

7. Lifetime 

In the preliminary analysis, DOE 

estimated the mechanical lifetime of 

electric motors in hours (i.e., the total 

number of hours an electric motor 

operates throughout its lifetime), 

depending on its horsepower size. DOE 

then developed Weibull distributions of 

mechanical lifetimes. The lifetime in 

years for a sampled electric motor was 

then calculated by dividing the sampled 

mechanical lifetime by the sampled 

annual operating hours of the electric 

motor. This model produces a negative 

correlation between annual hours of 

operation and electric motor lifetime: 

Electric motors operated many hours 

per year are likely to be retired sooner 

than electric motors that are used for 

only a few hundred hours per year. DOE 

considered that electric motors of less 

than 75-hp are most likely to be 

embedded in a piece of equipment (i.e., 

an application). For such applications, 

DOE developed Weibull distributions of 

application lifetimes expressed in years 

and compared the sampled motor 

mechanical lifetime (in years) with the 

sampled application lifetime. DOE 

assumed that the electric motor would 

be retired at the earlier of the two ages. 

For the NOPR analysis, DOE retained 

the same approach and revised some of 

the lifetime assumptions based on 

additional information collected. 

NEMA and WEG commented that the 

mechanical lifetime of agricultural 

motors should be lower than in the 

commercial or industrial sectors due to 

lower levels of maintenance performed 

in the field and the lighter duty steel 

frame constructions of these motors. 

(Pub. Mtg. Tr., No. 58 at p. 253) The 

NOPR analysis estimates that the 

average motor lifetime (across all sizes) 

for the agricultural sector to be 20 

years.71 This revised estimate translates 

into average mechanical lifetimes 

between 24,000 and 30,000 hours 

depending on the horsepower range, 

which is lower than in the industrial 

sector. 

For the NOPR, DOE collected sectorspecific mechanical motor lifetime 

information where available and revised 

the lifetime assumptions where 

appropriate. For the industrial sector, 

DOE estimated average mechanical 

lifetimes of 5, 15, and 20 years, 

depending on the horsepower range (the 

values correspond to 43,800, 87,600, 

and 131,400 hours respectively). These 

values are higher than those used in the 

preliminary analysis. 

8. Discount Rate 

The discount rate is the rate at which 

future expenditures are discounted to 

estimate their present value. The cost of 

capital commonly is 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 to the firm of 

equity and debt financing. DOE uses the 

capital asset pricing model (CAPM) to 

calculate the equity capital component, 

and financial data sources to calculate 

the cost of debt financing. 

For the NOPR, DOE estimated a 

statistical distribution of industrial and 

commercial customer discount rates by 

calculating the average cost of capital 

for the different types of electric motor 

owners (e.g., chemical industry, food 

processing, and paper industry). For the 

agricultural sector, DOE assumed 

similar discount rates as in industry. 

More details regarding DOE’s estimates 

of motor customer discount rates are 

provided in chapter 8 of the NOPR TSD. 

9. Base Case Market Efficiency 

Distributions 

For the LCC analysis, DOE analyzed 

the considered motor efficiency levels 

relative to a base case (i.e., the case 

without new or amended energy 

efficiency standards). This requires an 

estimate of the distribution of product 

efficiencies in the base case (i.e., what 

consumers would have purchased in the 

compliance year in the absence of new 

standards). DOE refers to this 

distribution of product energy 

efficiencies as the base case efficiency 

distribution. 

Data on motor sales by efficiency are 

not available. In the preliminary 

analysis, DOE used the number of 

models meeting the requirements of 

each efficiency level from six major 

manufacturers and one distributor’s 

catalog data to develop the base-case 

efficiency distributions. The 

distribution is estimated separately for 

each equipment class group and 

horsepower range and was assumed 

constant and equal to 2012 throughout 

the analysis period (2015–2044). 

For the NOPR, DOE retained the same 

approach to estimate the base case 

efficiency distribution in 2012, but it 

updated the base case efficiency 

distributions to account for the NOPR 

engineering analysis (revised ELs) and 

for the update in the scope of electric 

motors considered in the analysis. 

Beyond 2012, DOE assumed the 

efficiency distributions for equipment 

class group 1 and 4 vary over time based 

on historical data 72 for the market 

penetration of NEMA Premium motors 

within the market for integral 

alternating current induction motors. 

The assumed trend is shown in chapter 

10 of the NOPR TSD. For equipment 

class group 2 and 3, which represent a 

very minor share of the market (less 

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73 IMS Research (February 2012), The World 

Market for Low Voltage Motors, 2012 Edition, 

Austin. 

74Bureau of Economic Analysis (March 01, 2012), 

Private Fixed Investment in Equipment and 

Software by Type and Private Fixed Investment in 

Structures by Type. http://www.bea.gov/iTable/

iTable.cfm?ReqID=12&step=1. 

75Business Trend Analysts, The Motor and 

Generator Industry, 2002; U.S. Census Bureau 

(November 2004), Motors and Generators— 

2003.MA335H(03)–1. http://www.census.gov/

manufacturing/cir/historical_data/discontinued/

ma335h/index.html; and U.S. Census Bureau 

(August 2003), Motors and Generators— 

2002.MA335H(02)–1. http://www.census.gov/

manufacturing/cir/historical_data/discontinued/

ma335h/ma335h02.xls. 

than 0.2 percent), DOE believes the 

overall trend in efficiency improvement 

for the total integral AC induction 

motors may not be representative, so 

DOE kept the base case efficiency 

distributions in the compliance year 

equal to 2012 levels. 

Two interested parties commented on 

the base case efficiency distributions. 

Regal-Beloit stated that the share of 1- 

to 5-horsepower motors in equipment 

class 1 at CSL 0 in the base case 

distribution was too low by at least one 

percentage point. (Pub. Mtg. Tr., No. 58 

at p. 263) NEMA requested clarifications 

on how DOE derived its base case 

efficiency distributions and commented 

that it would expect CSL 0 to represent 

60 percent of total units shipped when 

considering the expanded scope as 

proposed by NEMA. (NEMA, No. 54 at 

p. 84) Neither stakeholder, however, 

provided supporting data. 

As mentioned previously, DOE 

developed the 2012 base case efficiency 

distributions based on catalog 

information on the number of models 

meeting the requirements of each 

efficiency level. For the NOPR, DOE 

retained the same methodology and 

revised the catalog information to 

account for the addition of brake motors 

and NEMA 56-frame size enclosed 

electric motors in the analysis. DOE has 

no data to assess the stakeholders’ input 

on the base case efficiency distributions. 

10. Compliance Date 

Any amended standard for electric 

motors shall apply to electric motors 

manufactured on or after a date which 

is five years after the effective date of 

the previous amendment. (42 U.S.C. 

6313(b)(4)) In this case, the effective 

date of the previous amendment 

(established by EISA in 2007) is 

December 19, 2010, and the compliance 

date of any amended energy 

conservation standards for electric 

motors would be December 19, 2015. In 

light of the proposal’s attempt to 

establish amended or new standards for 

currently regulated and unregulated 

electric motor types, DOE has chosen to 

retain the same compliance date for 

both the amended and new energy 

conservation standards to simplify the 

requirements and to avoid any potential 

confusion from manufacturers. The final 

rule for this rulemaking is scheduled to 

be published in early 2014. DOE 

calculated the LCC and PBP for all endusers as if each would purchase a new 

piece of equipment in the year that 

compliance is required. As DOE notes 

elsewhere, DOE is interested in 

comments regarding the feasibility of 

achieving compliance with this 

proposed date. 

11. Payback Period Inputs 

The payback period is the amount of 

time it takes the consumer to recover the 

additional installed cost of more 

efficient equipment, compared to 

baseline equipment, through energy cost 

savings. Payback periods are expressed 

in years. Payback periods that exceed 

the life of the product mean that the 

increased total installed cost is not 

recovered in reduced operating 

expenses. 

The inputs to the PBP calculation are 

the total installed cost of the product to 

the customer for each efficiency level 

and the average annual operating 

expenditures for each efficiency level. 

The PBP calculation uses the same 

inputs as the LCC analysis, except that 

discount rates are not needed. 

12. Rebuttable-Presumption Payback 

Period 

EPCA establishes a rebuttable 

presumption that a standard is 

economically justified if the Secretary 

finds that the additional cost to the 

consumer of purchasing a product 

complying with an energy conservation 

standard level will be less than three 

times the value of the energy (and, as 

applicable, water) savings during the 

first year that the consumer will receive 

as a result of the standard, as calculated 

under the test procedure in place for 

that standard. (42 U.S.C. 

6295(o)(2)(B)(iii)) For each considered 

efficiency level, DOE determines the 

value of the first year’s energy savings 

by calculating the quantity of those 

savings in accordance with the 

applicable DOE test procedure, and 

multiplying that amount by the average 

energy price forecast for the year in 

which compliance with the new or 

amended standards would be required. 

G. Shipments Analysis 

DOE uses projections of product 

shipments to calculate the national 

impacts of standards on energy use, 

NPV, and future manufacturer cash 

flows. DOE develops shipment 

projections based on historical data and 

an analysis of key market drivers for 

each product. 

To populate the model with current 

data, DOE used data from a market 

research report,73 confidential inputs 

from manufacturers, trade associations, 

and other interested parties’ responses 

to the Request for Information (RFI) 

published in the Federal Register. 76 FR 

17577 (March 30, 2011). DOE then used 

estimates of market distributions to 

redistribute the shipments across pole 

configurations, horsepower, and 

enclosures within each electric motor 

equipment class and also by sector. 

DOE’s shipments projection assumes 

that electric motor sales are driven by 

machinery production growth for 

equipment including motors. DOE 

estimated that growth rates for total 

motor shipments correlate to growth 

rates in fixed investment in equipment 

and structures including motors, which 

is provided by the U.S. Bureau of 

Economic Analysis (BEA).74 Projections 

of real gross domestic product (GDP) 

from AEO 2013 for 2015–2040 were 

used to project fixed investments in the 

equipment and structures including 

motors. The current market 

distributions are maintained over the 

forecast period. 

For the NOPR, with the expanded 

scope by horsepower, DOE estimates 

total shipments in scope were 5.43 

million units in 2011. This estimate 

represents an increase compared to the 

shipments estimated in the preliminary 

analysis because of the inclusion of 

integral brake motors and of NEMA 

integral enclosed 56-frame motors. 

For the preliminary analysis, DOE 

collected data on historical series of 

shipment quantities and value for the 

1990–2003 period, but concluded that 

the data were not sufficient to estimate 

motor price elasticity.75 Consequently, 

DOE assumed zero price elasticity for all 

efficiency standards cases and did not 

estimate any impact of potential 

standards levels on shipments. DOE 

requested stakeholder recommendations 

on data sources to help better estimate 

the impacts of increased efficiency 

levels on shipments. 

The Motor Coalition commented that 

higher equipment costs required to 

achieve efficiency levels above CSL 2 

(NEMA Premium) would encourage the 

refurbishment of existing motors rather 

than their replacement by new, more 

efficient motors, leading to reduced cost 

effective energy savings at CSL 3. (Motor 

Coalition, No. 35 at p. 7) 

DOE acknowledges that increased 

electric motor prices could affect the 

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76 IMS Research (February 2012), The World 

Market for Low Voltage Motors, 2012 Edition, 

Austin; Business Trend Analysts, The Motor and 

Generator Industry, 2002; U.S. Census Bureau 

(November 2004), Motors and Generators— 

2003.MA335H(03)–1. http://www.census.gov/

manufacturing/cir/historical_data/discontinued/

ma335h/index.html; and U.S. Census Bureau 

(August 2003), Motors and Generators— 

2002.MA335H(02)–1. http://www.census.gov/

manufacturing/cir/historical_data/discontinued/

ma335h/ma335h02.xls. 

77 DOE understands that MS Excel is the most 

widely used spreadsheet calculation tool in the 

United States and there is general familiarity with 

its basic features. Thus, DOE’s use of MS Excel as 

the basis for the spreadsheet models provides 

interested parties with access to the models within 

a familiar context. In addition, the TSD and other 

documentation that DOE provides during the 

rulemaking help explain the models and how to use 

them, and interested parties can review DOE’s 

analyses by changing various input quantities 

within the spreadsheet. 

‘‘repair versus replace’’ decision, 

leading to the increased longevity of 

existing electric motors and a decrease 

in shipments of newly-manufactured 

energy-efficient electric motors. 

Considering the minimal cost increase 

between EL 2 and EL 3 in the 

preliminary analysis (approximately 3 

percent for representative unit 1), DOE 

does not believe it is reasonable to 

consider non-zero price elasticity when 

calculating the standards-case 

shipments for levels above EL 2 and 

zero price elasticity when calculating 

shipments for the standards case at EL 

2 of the preliminary analysis. For the 

above reasons, DOE retained its 

shipments projections, which do not 

incorporate price elasticities, for the 

NOPR. However, DOE also performed a 

sensitivity analysis that demonstrates 

the impact of possible price elasticities 

on projected shipments and the NIA 

results. See TSD appendix 10–C for 

more details and results. 

NEMA commented that shipments of 

imported motors might decrease if 

higher efficiency levels are mandated. 

(NEMA, No. 54 at p. 29) NEMA, 

however, provided no data in support of 

its view. DOE has reviewed shipments 

information from market reports, the 

U.S. Census, as well as market 

information provided by the Motor 

Coalition and has been unable to obtain 

any data to assess the potential 

reduction in quantity of imported 

motors due to standards and whether 

this would impact the total number of 

motors shipped in the U.S.76 DOE’s 

shipments projection assumes that 

electric motor sales are driven by 

machinery production growth for 

equipment including motors without 

distinction between imported and 

domestic motors. 

H. National Impact Analysis 

The NIA assesses the national energy 

savings (NES) and the national NPV of 

total customer costs and savings that 

would be expected to result from new 

and amended standards at specific 

efficiency levels. 

To make the analysis more accessible 

and transparent to all interested parties, 

DOE used an MS Excel spreadsheet 

model to calculate the energy savings 

and the national customer costs and 

savings from each TSL.77 DOE used the 

NIA spreadsheet to calculate the NES 

and NPV, based on the annual energy 

consumption and total installed cost 

data from the energy use analysis and 

the LCC analysis. DOE forecasted the 

lifetime energy savings, energy cost 

savings, equipment costs, and NPV of 

customer benefits for each product class 

for equipment sold from 2015 through 

2044. In addition, DOE analyzed 

scenarios that used inputs from the AEO 

2013 Low Economic Growth and High 

Economic Growth cases. These cases 

have higher and lower energy price 

trends compared to the reference case. 

DOE evaluated the impacts of 

potential new and amended standards 

for electric motors by comparing basecase projections with standards-case 

projections. The base-case projections 

characterize energy use and customer 

costs for each equipment class in the 

absence of new and amended energy 

conservation standards. DOE compared 

these projections with projections 

characterizing the market for each 

equipment class if DOE were to adopt 

new or amended standards at specific 

energy efficiency levels (i.e., the 

standards cases) for that class. 

Table IV.25 summarizes all the major 

preliminary analysis inputs to the NIA 

and whether those inputs were revised 

for the NOPR. 

TABLE IV.25—INPUTS FOR THE NATIONAL IMPACT ANALYSIS

Input Preliminary analysis description Changes for NOPR 

Shipments ...................................... Annual shipments from shipments model .............................................. No change. 

Compliance date of standard ......... Modeled used January 1, 2015 .............................................................. December 19, 2015 (modeled as 

January 1, 2016). 

Equipment Classes ........................ Three separate equipment class groups for NEMA Design A and B 

motors, NEMA Design C motors, and Fire Electric Pump Motors.

Added one equipment class group 

for brake motors. 

Base case efficiencies ................... Constant efficiency from 2015 through 2044 ......................................... No change for Equipment Class 2 

and 3. Added a trend for the efficiency distribution of equipment 

class groups 1 and 4. 

Standards case efficiencies ........... Constant efficiency at the specified standard level from 2015 to 2044 No change. 

Annual energy consumption per 

unit.

Average unit energy use data are calculated for each horsepower rating and equipment class based on inputs from the Energy use analysis.No change. 

Total installed cost per unit ............ Based on the MSP and weight data from the engineering, and then 

scaled for different hp and enclosure categories.

No change. 

Electricity expense per unit ............ Annual energy use for each equipment class is multiplied by the corresponding average energy price.No change. 

Escalation of electricity prices ........ AEO 2011 forecasts (to 2035) and extrapolation for 2044 and beyond Updated to AEO 2013. 

Electricity site-to-source conversion A time series conversion factor; includes electric generation, transmission, and distribution losses.No change. 

Discount rates ................................ 3% and 7% real ...................................................................................... No change. 

Present year ................................... 2012 ........................................................................................................ 2013. 

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78OMB Circular A–4, section E (Sept. 17, 2003). 

http://www.whitehouse.gov/omb/circulars_a004_a4. 

1. Efficiency Trends 

In the preliminary analysis, DOE did 

not include any change in base case 

efficiency in its shipments and national 

energy savings models. As explained in 

section IV.F, for equipment class groups 

1 and 4, for the NOPR, DOE presumed 

that the efficiency distributions in the 

base case change over time. The 

projected share of 1 to 5 horsepower 

NEMA Premium motors (EL 2) for 

equipment class group 1 grows from 

36.6 percent to 45.5 percent over the 

analysis period, and for equipment class 

group 4, it grows from 30.0 percent to 

38.9 percent. For equipment class group 

2 and 3, DOE assumed that the 

efficiency remains constant from 2015 

to 2044. 

In the standards cases, equipment 

with efficiency below the standard 

levels ‘‘roll up’’ to the standard level in 

the compliance year. Thereafter, for 

equipment class groups 1 and 4, DOE 

assumed that the level immediately 

above the standard would show a 

similar increase in market penetration 

as the NEMA Premium motors in the 

base case. 

The presumed efficiency trends in the 

base case and standards cases are 

described in chapter 10 of the NOPR 

TSD. 

2. National Energy Savings 

For each year in the forecast period, 

DOE calculates the lifetime national 

energy savings for each standard level 

by multiplying the shipments of electric 

motors affected by the energy 

conservation standards by the per-unit 

lifetime annual energy savings. 

Cumulative energy savings are the sum 

of the NES for all motors shipped during 

the analysis period, 2015–2044. 

DOE estimated energy consumption 

and savings based on site energy and 

converted the electricity consumption 

and savings to primary energy using 

annual conversion factors derived from 

the AEO 2013 version of the NEMS. 

Cumulative energy savings are the sum 

of the NES for each year over the 

timeframe of the analysis. 

DOE has historically presented NES 

in terms of primary energy savings. In 

response to the recommendations of a 

committee on ‘‘Point-of-Use and FullFuel-Cycle Measurement Approaches to 

Energy Efficiency Standards’’ appointed 

by the National Academy of Science, 

DOE announced its intention to use fullfuel-cycle (FFC) measures of energy use 

and greenhouse gas and other emissions 

in the national impact analyses and 

emissions analyses included in future 

energy conservation standards 

rulemakings. 76 FR 51281 (August 18, 

2011). While DOE stated in that notice 

that it intended to use the Greenhouse 

Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) model to 

conduct the analysis, it also said it 

would review alternative methods, 

including the use of EIA’s National 

Energy Modeling System (NEMS). After 

evaluating both models and the 

approaches discussed in the August 18, 

2011 notice, DOE published a statement 

of amended policy in the Federal 

Register in which DOE explained its 

determination that NEMS is a more 

appropriate tool for this specific use. 77 

FR 49701 (August 17, 2012). Therefore, 

DOE is using NEMS to conduct FFC 

analyses. The approach used for today’s 

NOPR, and the FFC multipliers that 

were applied, are described in appendix 

10–C of the TSD. 

3. Equipment Price Forecast 

As noted in section IV.F.2, DOE 

assumed no change in electric motor 

prices over the 2015–2044 period. In 

addition, DOE conducted a sensitivity 

analysis using alternative price trends. 

DOE developed one forecast in which 

prices decline after 2011, and one in 

which prices rise. These price trends, 

and the NPV results from the associated 

sensitivity cases, are described in 

appendix 10–B of the NOPR TSD. 

4. Net Present Value of Customer 

Benefit 

The inputs for determining the NPV 

of the total costs and benefits 

experienced by consumers of 

considered equipment are: (1) Total 

annual installed cost; (2) total annual 

savings in operating costs; and (3) a 

discount factor. DOE calculates the 

lifetime net savings for motors shipped 

each year as the difference between the 

base case and each standards case in 

total lifetime savings in lifetime 

operating costs and total lifetime 

increases in installed costs. DOE 

calculates lifetime operating cost 

savings over the life of each motor 

shipped during the forecast period. 

In calculating the NPV, DOE 

multiplies the net savings in future 

years by a discount factor to determine 

their present value. DOE estimates the 

NPV using both a 3-percent and a 7- 

percent real discount rate, in accordance 

with guidance provided by the Office of 

Management and Budget (OMB) to 

Federal agencies on the development of 

regulatory analysis.78 The discount rates 

for the determination of NPV are in 

contrast to the discount rates used in the 

LCC analysis, which are designed to 

reflect a consumer’s perspective. The 7- 

percent real value is an estimate of the 

average before-tax rate of return to 

private capital in the U.S. economy. The 

3-percent real value represents the 

‘‘social rate of time preference,’’ which 

is the rate at which society discounts 

future consumption flows to their 

present value. 

I. Consumer Subgroup Analysis 

In analyzing the potential impacts of 

new or amended standards, DOE 

evaluates impacts on identifiable groups 

(i.e., subgroups) of customers that may 

be disproportionately affected by a 

national standard. For the NOPR, DOE 

evaluated impacts on various subgroups 

using the LCC spreadsheet model. 

The customer subgroup analysis is 

discussed in detail in chapter 11 of the 

TSD. 

J. Manufacturer Impact Analysis 

1. Overview 

DOE conducted an MIA for electric 

motors to estimate the financial impact 

of proposed new and amended energy 

conservation standards on 

manufacturers of covered electric 

motors. The MIA has both quantitative 

and qualitative aspects. The quantitative 

part of the MIA primarily relies on the 

GRIM, an industry cash flow model 

customized for electric motors covered 

in this rulemaking. The key GRIM 

inputs are data on the industry cost 

structure, equipment costs, shipments, 

and assumptions about markups and 

conversion expenditures. The key MIA 

output is INPV. DOE used the GRIM to 

calculate cash flows using standard 

accounting principles and to compare 

changes in INPV between a base case 

and various TSLs (the standards case). 

The difference in INPV between the 

base and standards cases represents the 

financial impact of new and amended 

standards on manufacturers of covered 

electric motors. Different sets of 

assumptions (scenarios) produce 

different INPV results. The qualitative 

part of the MIA addresses factors such 

as manufacturing capacity; 

characteristics of, and impacts on, any 

particular sub-group of manufacturers; 

and impacts on competition. 

DOE conducted the MIA for this 

rulemaking in three phases. In the first 

phase DOE prepared an industry 

characterization based on the market 

and technology assessment, preliminary 

manufacturer interviews, and publicly 

available information. In the second 

phase, DOE estimated industry cash 

flows in the GRIM using industry 

financial parameters derived in the first 

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phase and the shipment scenario used 

in the NIA. In the third phase, DOE 

conducted structured, detailed 

interviews with a variety of 

manufacturers that represent more than 

75-percent of domestic electric motors 

sales covered by this rulemaking. 

During these interviews, DOE discussed 

engineering, manufacturing, 

procurement, and financial topics 

specific to each company, and obtained 

each manufacturer’s view of the electric 

motor industry as a whole. The 

interviews provided valuable 

information that DOE used to evaluate 

the impacts of new and amended 

standards on manufacturers’ cash flows, 

manufacturing capacities, and 

employment levels. See section IV.J.4 of 

this NOPR for a description of the key 

issues manufacturers raised during the 

interviews. 

During the third phase, DOE also used 

the results of the industry 

characterization analysis in the first 

phase and feedback from manufacturer 

interviews to group manufacturers that 

exhibit similar production and cost 

structure characteristics. DOE identified 

one sub-group for a separate impact 

analysis—small business 

manufacturers—using the small 

business employee threshold published 

by the Small Business Administration 

(SBA). This threshold includes all 

employees in a business’ parent 

company and any other subsidiaries. 

Based on this classification, DOE 

identified 13 electric motor 

manufacturers that qualify as small 

businesses. 

The complete MIA is presented in 

chapter 12 of the NOPR TSD. 

2. GRIM Analysis and Key Inputs 

DOE uses the GRIM to quantify the 

changes in cash flow over time due to 

a standard. These changes in cash flow 

result in either a higher or lower INPV 

for the standards case compared to the 

base case, the case where a standard is 

not set. The GRIM analysis uses a 

standard annual cash flow analysis that 

incorporates manufacturer costs, 

markups, shipments, and industry 

financial information as inputs. It then 

models changes in costs, investments, 

and manufacturer margins that result 

from new and amended energy 

conservation standards. The GRIM 

spreadsheet uses the inputs to calculate 

a series of annual cash flows beginning 

with the base year of the analysis, 2013, 

and continuing to 2044. DOE computes 

INPVs by summing the stream of annual 

discounted cash flows during this 

analysis period. DOE used a real 

discount rate of 9.1 percent for electric 

motor manufacturers. The discount rate 

estimates were derived from industry 

corporate annual reports to the 

Securities and Exchange Commission 

(SEC 10–Ks) and then modified 

according to feedback during 

manufacturer interviews. Many inputs 

into the GRIM come from the 

engineering analysis, the NIA, 

manufacturer interviews, and other 

research conducted during the MIA. The 

major GRIM inputs are described in 

detail in the sections below. 

a. Product and Capital Conversion Costs 

DOE expects new and amended 

energy conservation standards to cause 

manufacturers to incur one-time 

conversion costs to bring their 

production facilities and product 

designs into compliance with new and 

amended standards. For the MIA, DOE 

classified these one-time conversion 

costs into two major groups: (1) Product 

conversion costs and (2) capital 

conversion costs. Product conversion 

costs are one-time investments in 

research, development, testing, 

marketing, and other non-capitalized 

costs necessary to make product designs 

comply with new and amended 

standards. Capital conversion costs are 

one-time investments in property, plant, 

and equipment necessary to adapt or 

change existing production facilities 

such that new product designs can be 

fabricated and assembled. 

DOE calculated the product and 

capital conversion costs using both a 

top-down approach and a bottom-up 

approach based on feedback from 

manufacturers during manufacturer 

interviews and manufacturer submitted 

comments. DOE then adjusted these 

conversion costs if there were any 

discrepancies in the final costs using the 

two methods to arrive at a final product 

and capital conversion cost estimate for 

each representative unit at each EL. 

During manufacturer interviews, DOE 

asked manufacturers for their estimated 

total product and capital conversion 

costs needed to produce electric motors 

at specific ELs. To arrive at top-down 

industry wide product and capital 

conversion cost estimates for each 

representative unit at each EL, DOE 

calculated a market share weighted 

average value for product and capital 

conversion costs based on the data 

submitted during interviews and the 

market share of the interviewed 

manufacturers. 

DOE also calculated bottom-up 

conversion costs based on manufacturer 

input on the types of costs and the 

dollar amounts necessary to convert a 

single electric motor frame size to each 

EL. Some of the types of capital 

conversion costs manufacturers 

identified were the purchase of 

lamination die sets, winding machines, 

frame casts, and assembly equipment as 

well as other retooling costs. The two 

main types of product conversion costs 

manufacturers shared with DOE during 

interviews were number of engineer 

hours necessary to re-engineer frames to 

meet higher efficiency standards and the 

testing and certification costs to comply 

with higher efficiency standards. DOE 

then took average values (i.e. costs or 

number of hours) based on the range of 

responses given by manufacturers for 

each product and capital conversion 

costs necessary for a manufacturer to 

increase the efficiency of one frame size 

to a specific EL. DOE multiplied the 

conversion costs associated with 

manufacturing a single frame size at 

each EL by the number of frames each 

interviewed manufacturer produces. 

DOE finally scaled this number based 

on the market share of the 

manufacturers DOE interviewed, to 

arrive at industry wide bottom-up 

product and capital conversion cost 

estimates for each representative unit at 

each EL. The bottom-up conversion 

costs estimates DOE created were 

consistent with the manufacturer top 

down estimates provided, so DOE used 

the bottom-up conversion cost estimates 

as the final values for each 

representative unit in the MIA. 

In written comments and during 

manufacturer interviews, electric motor 

manufacturers stated there would be 

very large product and capital 

conversion costs associated with ELs 

above NEMA Premium, especially for 

any ELs that require manufacturers to 

switch to die-cast copper rotors. 

Manufacturers addressed the difficulties 

associated with using copper die-cast 

rotors and the uncertainty of a standard 

that requires manufacturers to produce 

electric motors on a commercial level 

for all horsepower ranges using this 

technology. NEMA stated that switching 

to die-cast copper rotors would cost 

each manufacturer approximately $80 

million in retooling costs and 

approximately $68 million to redesign, 

test and certify electric motors at these 

ELs. (NEMA, No. 54 at p. 11) NEMA 

stated that significant conversion costs 

associated with any EL above NEMA 

Premium exist even if die-cast copper 

rotors are not used. Several 

manufacturers during interviews and in 

comments stated they would need to 

devote significant engineering time to 

redesign their entire production line to 

comply with ELs that are just one 

NEMA band higher than NEMA 

Premium. NEMA also stated that testing 

and certifying electric motors to ELs 

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above NEMA Premium would be a 

significant cost to each manufacturer, 

since each manufacturer could have 

thousands or hundreds of thousands of 

unique electric motor specifications 

they would need to certify. (NEMA, No. 

54 at p. 4) DOE took these submitted 

comments into account when 

developing the industry product and 

capital conversion costs. The final 

product and capital conversion cost 

estimates were in the range of estimates 

submitted by NEMA. 

See chapter 12 of the TSD for a 

complete description of DOE’s 

assumptions for the product and capital 

conversion costs. 

b. Manufacturer Production Costs 

Manufacturing a more efficient 

electric motor is typically more 

expensive than manufacturing a 

baseline product due to the use of more 

costly materials and components. The 

higher MPCs for these more efficient 

equipment can affect the revenue, gross 

margin, and cash flows of electric motor 

manufacturers. 

DOE developed the MPCs for the 

representative units at each EL analyzed 

in one of two ways: (1) DOE purchased, 

tested and then tore down a motor to 

create a bill of materials (BOM) for the 

motor; and (2) DOE created a BOM 

based on a computer software model for 

a specific motor that complies with the 

associated efficiency level. This second 

approach was used when DOE was 

unable to find and purchase a motor 

that matched the efficiency criteria for 

a specific representative unit. Once DOE 

created a BOM for a specific motor, 

either by tear downs or software 

modeling, DOE then estimated the labor 

hours and the associated scrap and 

overhead costs necessary to produce a 

motor with that BOM. DOE was then 

able to create an aggregated MPC based 

on the material costs from the BOM and 

the associated scrap costs, the labor 

costs based on an average labor rate and 

the labor hours necessary to 

manufacture the motor, and the 

overhead costs, including depreciation, 

based on a markup applied to the 

material, labor, and scrap costs based on 

the materials used. 

DOE created a BOM from tear downs 

for 15 of the 21 analyzed representative 

unit ELs and applied these BOM data to 

create ELs for certain representative 

units. The representative unit ELs based 

on tear downs include: All five ELs for 

the Design B, 5-horsepower 

representative unit; the baseline and ELs 

1, 2, and 3 for the Design B, 30- 

horsepower and 75-horsepower 

representative units; and the baseline 

for the Design C, 5-horsepower and 50- 

horsepower representative units. DOE 

created a BOM based on a computer 

software model for the remaining six 

analyzed representative unit ELs: EL 4 

for the Design B, 30-horsepower and 75- 

horsepower representative units; and 

ELs 1 and 2 for the Design C, 5- 

horsepower and 50-horsepower 

representative units. 

Due to the very large product and 

capital conversion costs manufacturers 

would face if standards forced 

manufacturers to produce motors above 

NEMA Premium ELs, DOE decided to 

include the product and capital 

conversion costs as a portion of the 

MPCs for all ELs above NEMA 

Premium. DOE applied a per unit adder, 

which was a flat percentage of the MPC 

at NEMA Premium, for all MPCs above 

NEMA Premium. For a complete 

description of MPCs and the inclusion 

of manufacturer conversion costs into 

the MPC see the engineering analysis 

discussion in section IV.C of this NOPR. 

c. Shipment Forecast 

INPV, the key GRIM output, depends 

on industry revenue, which in turn, 

depends on the quantity and prices of 

electric motors shipped in each year of 

the analysis period. Industry revenue 

calculations require forecasts of: (1) 

Total annual shipment volume; (2) the 

distribution of shipments across 

analyzed representative units (because 

prices vary by representative unit); and, 

(3) the distribution of shipments across 

efficiencies (because prices vary with 

efficiency). 

In the NIA, DOE estimated the total 

number of electric motor shipments by 

year for the analysis period. The NIA 

projects electric motor shipments to 

generally increase over time. This is 

consistent with the estimates 

manufacturers revealed to DOE during 

manufacturer interviews. The NIA then 

estimated the percentage of shipments 

assigned to each ECG. DOE further 

estimated the percentage of shipments 

by horsepower rating, pole 

configuration, and enclosure type 

within each ECG. For the NIA, the 

shipment distribution across ECG and 

the shipment distribution across 

horsepower rating, pole configuration, 

and enclosure type do not change on a 

percentage basis over time. Nor does the 

shipment distribution across ECGs or 

across horsepower rating, pole 

configuration, and enclosure type 

change on a percentage basis due to an 

energy conservation standard (e.g. the 

number of shipments of Design C, 1 

horsepower, 4 pole, open motor are the 

same in the base case as in the standards 

case). Finally, the NIA estimated a 

distribution of shipments across ELs (an 

efficiency distribution), for each 

horsepower range within each ECG. As 

described in further detail below, the 

efficiency distributions for ECG 1 and 

ECG 4 motors become more energy 

efficient over time in the base case, 

while the efficiency distributions for 

ECG 2 and ECG 3 do not change on a 

percentage basis over time (i.e., for ECG 

2 and ECG 3 motors, the efficiency 

distributions at the beginning of the 

analysis period are the same as the 

efficiency distributions at the end of the 

analysis period). DOE also assumed the 

total volume of shipments does not 

decrease due to energy conservation 

standards, so total shipments are the 

same in the base case as in the standards 

case. 

For the NIA, DOE modeled a ‘‘shift’’ 

shipment scenario for ECG 1 and ECG 

4 motors and a ‘‘roll-up’’ shipment 

scenario for ECG 2 and ECG 3 motors. 

In the standards case of the ‘‘shift’’ 

shipment scenario, shipments continue 

to become more efficient after a 

standard is set—in this case, 

immediately after the standards go into 

effect, all shipments below the selected 

TSL are brought up to meet that TSL. 

However, motors at or above the 

selected TSL migrate to even higher 

efficiency levels and continue to do so 

over time. In contrast, in the standards 

case of the ‘‘roll-up’’ shipment scenario, 

when a TSL is selected to become the 

new energy conservation standard, all 

shipments that fall below that selected 

TSL roll-up to the selected TSL. 

Therefore, the shipments that are at or 

above the selected TSL remain 

unchanged in the standards case of the 

‘‘roll-up’’ shipment scenario compared 

to the base case. For the ‘‘roll-up’’ 

shipment scenario, the only difference 

in the efficiency distribution between 

the standards case and the base case is 

that in the standards case all shipments 

falling below the selected TSL in the 

base case are now at the selected TSL 

in the standards case. 

While the shipments from the NIA are 

broken out into a total number of motor 

shipments for each ECG, horsepower 

rating, pole configuration, and enclosure 

type, the MIA consolidates the number 

of motor shipments into the 

representative units for each ECG. For 

example, the Design B, 5-horsepower, 4- 

pole, enclosed motor was the 

representative unit for all Design A and 

B motors between 1 and 10-horsepower 

regardless of the number of poles or 

enclosure type. So in the MIA DOE 

treated all ECG 1 (Design A and B) 

motor shipments between 1 and 10- 

horsepower as shipments of the Design 

B, 5-horsepower representative unit; all 

ECG 1 motor shipments between 15- 

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and 50-horsepower as shipments of the 

Design B, 30-horsepower representative 

unit; and all ECG 1 motor shipments 

between 60- and 500-horsepower as 

shipments of the Design B, 75- 

horsepower representative unit. For 

ECG 2 (Design C) motors, ECG 3 (fire 

pump) motors, and ECG 4 (brake) 

motors the MIA consolidated shipments 

in a similar manner, treating all 

shipments in the representative units’ 

horsepower range as shipments of that 

representative unit. 

See the shipment analysis, chapter 9, 

of this NOPR TSD for additional details. 

d. Markup Scenarios 

As discussed in the MPC section 

above, the MPCs for the representative 

units are the factory costs of electric 

motor manufacturers; these costs 

include material, direct labor, overhead, 

depreciation, and any extraordinary 

conversion cost recovery. The MSP is 

the price received by electric motor 

manufacturers from their direct 

customer, typically either an OEM or a 

distributor. The MSP is not the cost the 

end-user pays for the electric motor 

since there are typically multiple sales 

along the distribution chain and various 

markups applied to each sale. The MSP 

equals the MPC multiplied by the 

manufacturer markup. The 

manufacturer markup covers all the 

electric motor manufacturer’s nonproduction costs (i.e., selling, general 

and administrative expenses (SG&A), 

normal R&D, and interest, etc.) and 

profit. Total industry revenue for 

electric motor manufacturers equals the 

MSPs at each EL for each representative 

unit multiplied by the number of 

shipments at that EL. 

Modifying these manufacturer 

markups in the standards case yields a 

different set of impacts on 

manufacturers than in the base case. For 

the MIA, DOE modeled three standards 

case markup scenarios to represent the 

uncertainty regarding the potential 

impacts on prices and profitability for 

manufacturers following the 

implementation of new and amended 

energy conservation standards: (1) A flat 

markup scenario, (2) a preservation of 

operating profit scenario, and (3) a twotiered markup scenario. These scenarios 

lead to different markup values, which, 

when applied to the inputted MPCs, 

result in varying revenue and cash flow 

impacts on manufacturers. 

The flat markup scenario assumed 

that the cost of goods sold for each 

product is marked up by a flat 

percentage to cover SG&A expenses, 

R&D expenses, interest expenses, and 

profit. There were two values used for 

the flat markup, a 1.37 markup for high 

volume representative units and a 1.45 

markup for low volume representative 

units. The 1.37 markup was used for the 

Design B, 5-horsepower representative 

unit; the Design C, 5-horsepower 

representative unit; the fire pump, 5- 

horsepower representative unit; and the 

brake, 5-horsepower representative unit. 

The 1.45 markup is used for the Design 

B, 30-horsepower and 75-horsepower 

representative units; the Design C, 50 

horsepower representative unit; the fire 

pump, 30-horsepower and 75- 

horsepower representative units; and 

the brake, 30-horsepower and 75- 

horsepower representative units. This 

scenario represents the upper bound of 

industry profitability in the standards 

case because manufacturers are able to 

fully pass through additional costs due 

to standards to their customers. To 

derive the flat markup percentages, DOE 

examined the SEC 10-Ks of publicly 

traded electric motor manufacturers to 

estimate the industry average gross 

margin percentage. DOE then used that 

estimate along with the flat 

manufacturer markups used in the small 

electric motors rulemaking at 75 FR 

10874 (March 9, 2010), since several of 

the small electric motor manufacturers 

are also manufacturers of electric motors 

covered in this rulemaking, to create a 

final estimate of the flat markups used 

for electric motors covered in this 

rulemaking. 

DOE included an alternative markup 

scenario, the preservation of operating 

profit markup, because manufacturers 

stated that they do not expect to be able 

to markup the full cost of production 

given the highly competitive market, in 

the standards case. The preservation of 

operating profit markup scenario 

assumes that manufacturers are able to 

maintain only the base case total 

operating profit in absolute dollars in 

the standards case, despite higher 

product costs and investment. The base 

case total operating profit is derived 

from marking up the cost of goods sold 

for each product by the flat markup 

described above. In the standards case 

for the preservation of operating profit 

markup scenario, DOE adjusted the 

manufacturer markups in the GRIM at 

each TSL to yield approximately the 

same earnings before interest and taxes 

in the standards case in the year after 

the compliance date of the new and 

amended standards as in the base case. 

Under this scenario, while 

manufacturers are not able to yield 

additional operating profit from higher 

production costs and the investments 

that are required to comply with new 

and amended energy conservation 

standards, they are able to maintain the 

same operating profit in the standards 

case that was earned in the base case. 

DOE modeled a third profitability 

scenario, a two-tiered markup scenario. 

During interviews, several 

manufacturers stated they offer two tiers 

of motor lines that are differentiated, in 

part, by efficiency level. For example, 

several manufacturers offer Design B 

motors that meet, and in some cases 

exceed, NEMA Premium levels. Motors 

that exceed these levels typically 

command higher prices over NEMA 

Premium level motors at identical 

horsepower levels. These manufacturers 

suggested that the premium currently 

earned by the higher efficiency tiers 

would erode as new and amended 

standards are set at higher efficiency 

levels, which would harm profitability. 

To model this effect, DOE used 

information from manufacturers to 

estimate the higher and lower markups 

for electric motors under a two-tier 

pricing strategy in the base case. In the 

standards case, DOE modeled the 

situation in which product efficiencies 

offered by a manufacturer are altered 

due to standards. This change reduces 

the markup of higher efficiency 

equipment as they become the new 

baseline caused by the energy 

conservation standard. The change in 

markup is based on manufacturer 

statements made during interviews and 

on DOE’s understanding of industry 

pricing. 

The preservation of operating profit 

and two-tiered markup scenarios 

represent the lower bound of industry 

profitability in the standards case 

because manufacturers are not able to 

fully pass through the additional costs 

due to standards, as manufacturers are 

able to do in the flat markup scenario. 

Therefore, manufacturers earn less 

revenue in the preservation of operating 

profit and two-tiered markup scenarios 

than they do in the flat markup 

scenario. 

3. Discussion of Comments 

During the August 2012 preliminary 

analysis public meeting, interested 

parties commented on the assumptions 

and results of the preliminary analysis 

TSD. Oral and written comments 

addressed several topics, including the 

scope of coverage, conversion costs, 

enforcement of standards, and the 

potential increase in the motor 

refurbishment market. DOE addresses 

these comments below. 

a. Scope of Coverage 

SEW-Eurodrive expressed concern 

about establishing energy conservation 

standards for integral gearmotors. SEWEurodrive stated that manufacturers 

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would have to review and ensure the 

compatibility between the motor and 

the gearbox for all new integral 

gearmotor designs. Setting standards for 

these motors, in its view, may cause 

manufacturers to review potentially 

millions of motor-gear box 

combinations. SEW-Eurodrive also 

stated that since integral gearmotors 

comprise a system whose overall 

efficiency is limited by the low 

efficiency of the mating gearing, an 

increase in the efficiency of the motor 

alone would have a very small effect on 

the overall system efficiency. (SEWEurodrive, No. 53 at p. 3) DOE believes 

that these integral gearmotors can be 

tested by removing the gearbox and 

simply testing the partial motor in 

accordance with the partial motor test 

procedure proposed at 78 FR 38455 

(June 26, 2013). This approach would 

allow integral gearmotor motor 

manufacturers to test and certify the 

electric motors and not every 

combination of electric motor and 

gearbox. 

b. Conversion Costs 

NEMA made a few comments 

regarding the potential difficulties and 

costs associated with increasing energy 

conservation standards to efficiency 

levels above NEMA Premium. First, 

NEMA stated that DOE should consider 

the current difficulties that 

manufacturers from IEC countries are 

having when meeting the efficiency 

levels under NEMA MG 1 Table 12–12. 

NEMA stated these manufacturers 

already face difficulties due to the limits 

of an electric motor frame size and stack 

length, as these limits pose physical 

constraints to higher efficiency levels. 

Moreover, such limits to IEC frame size 

and stack length are comparable to what 

manufacturers of NEMA frame motors 

would face if required efficiency levels 

were increased above current NEMA 

Premium efficiency levels. (NEMA, No. 

54 at p. 84) NEMA did not provide any 

cost data, in engineering time or dollars, 

that these manufacturers were faced 

with regarding their compliance with 

NEMA MG 1 Table 12–12 efficiency 

levels. 

NEMA went on to give estimates for 

the conversion costs associated with 

manufacturers producing motors above 

NEMA Premium efficiency levels. 

NEMA stated that it would cost each 

manufacturer approximately $80 

million in retooling and $68 million in 

reengineering, testing and prototyping 

to switch from currently used materials 

to die-cast copper rotor production. 

NEMA also stated there are other costs 

not directly related to the die-casting 

process manufacturers would incur, if 

standards required copper rotor 

technology. For example, NEMA noted 

that there are additional costs associated 

with redesigning the rotor and stator to 

maintain compliance with NEMA MG 1 

performance requirements. NEMA also 

provided DOE with a few of the major 

costs placed on the manufacturers if 

energy conservation standards exceeded 

NEMA Premium efficiency levels. 

NEMA said manufacturers would incur 

significant costs due to retooling slot 

insulators, automatic winding 

machines, and progressive lamination 

stamping dies—the last of which can 

cost between $500,000 and $750,000 per 

set. Manufacturers would also need to 

reengineer potentially 100,000 to 

200,000 specifications per manufacturer 

to comply with standards above NEMA 

Premium levels. (NEMA, No. 54 at p. 

11) 

DOE took these difficulties and costs 

that could be placed on manufacturers 

into consideration when creating the 

conversion costs of standards above 

NEMA Premium efficiency levels. DOE 

also recognizes the magnitude of the 

conversion costs on the industry at 

efficiency levels above NEMA Premium 

and this was one of the main reasons 

DOE included a portion of the 

conversion costs in the MPC for 

efficiency levels above NEMA Premium. 

DOE believes it is likely that motor 

manufacturers would attempt to recover 

these large one-time extraordinary 

conversion costs at standards above 

NEMA Premium through a variable cost 

increase in the MPCs of electric motors 

sold by manufacturers. 

c. Enforcement of Standards 

NEMA stated that large domestic 

manufacturers could be adversely 

impacted by higher energy conservation 

standards if DOE does not strictly 

enforce those new and amended 

standards, especially on imported 

machinery with embedded motors. 

NEMA commented that domestic 

manufacturers are currently competing 

with imported goods containing electric 

motors that are below current motor 

standards. This practice puts compliant 

motor manufacturers at a disadvantage 

because the machinery containing a 

non-compliant motor is often sold at a 

lower cost than machinery with a 

compliant motor. (NEMA, No. 54 at p. 

11) DOE recognizes the need to enforce 

any energy conservation standard 

established for motors manufactured 

alone or as a component of another 

piece of equipment to ensure that all 

manufacturers are operating on a level 

playing field and to realize the actual 

reduction in energy consumption from 

these standards. 

d. Motor Refurbishment 

NEMA commented that if electric 

motors had to be redesigned to achieve 

higher energy conservation standards 

potential new motor customers may be 

forced to rewind older, less efficient 

motors because the longer or larger 

frame sizes that could be required to 

satisfy more stringent efficiency 

standards might not fit as drop-in 

replacements for existing equipment. 

(NEMA, No. 54 at p. 10) DOE agrees that 

adopting higher energy conservation 

standards for electric motors may force 

motor manufacturers to increase the 

length and/or the diameter of the frame. 

Such increase in motor frame size may 

cause some machinery using electric 

motors to be incompatible with previous 

electric motor designs. DOE requested 

comment on the quantitative impacts 

this could have on the electric motor 

and OEM markets but did not receive 

any quantitative responses regarding 

this issue. DOE is aware this could be 

a possible issue at the ELs above NEMA 

Premium, but does not consider this to 

be an issue at ELs that meet or are below 

NEMA Premium, since the majority of 

the electric motors used in existing 

equipment should already be at NEMA 

Premium efficiency levels. Therefore, 

based on data available at this time, 

DOE does not believe that motor 

refurbishment is likely to act as a barrier 

to the efficiency levels proposed in 

today’s NOPR. 

4. Manufacturer Interviews 

DOE conducted additional interviews 

with manufacturers following the 

preliminary analysis in preparation for 

the NOPR analysis. In these interviews, 

DOE asked manufacturers to describe 

their major concerns with this 

rulemaking. The following section 

describes the key issues identified by 

manufacturers during these interviews. 

a. Efficiency Levels above NEMA 

Premium 

During these interviews, several 

manufacturers were concerned with the 

difficulties associated with increasing 

motor efficiency levels above NEMA 

Premium. Manufacturers stated that 

even increasing the efficiency of motors 

to one band above NEMA Premium 

would require each manufacturer to 

make a significant capital investment to 

retool their entire production line. It 

would also require manufacturers to 

completely redesign almost every motor 

configuration offered, which could take 

several years of engineering time. 

According to manufacturers, another 

potential problem with setting standards 

above NEMA Premium is that this 

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would misalign U.S. electric motor 

standards with global motor standards 

(e.g., IEC motor standards). They noted 

that over the past few decades, there has 

been an effort to harmonize global motor 

standards that setting new U.S. electric 

motor standards at a level exceeding the 

NEMA Premium level would cause U.S. 

electric motor markets to be out of 

synchronization with the rest of the 

world’s efficiency standards. 

Several manufacturers also 

commented they believe any standard 

requiring die-casting copper rotors is 

infeasible. One main concern 

manufacturers have regarding copper is 

that not only has the price of copper 

significantly increased over the past 

several years, there has been 

tremendous volatility in the price as 

well. Manufacturers worry that if 

standards required manufacturers to use 

copper rotors, they would be subject to 

this volatile copper market. 

Manufacturers also noted that motor 

efficiency standards requiring copper 

rotors for all electric motors would 

likely increase the price of copper due 

to the increase in demand from the 

motors industry. 

Another key concern that 

manufacturers have regarding standards 

that require using copper rotors is that 

copper has a much higher melting 

temperature than aluminum, and the 

pressure required to die-cast copper is 

much higher than aluminum. They 

contend that there is a much greater 

chance that a significant accident or 

injury to their employees could occur if 

manufacturers were required to produce 

copper rotors rather than aluminum 

rotors. 

Lastly, several manufacturers stated 

they would not be able to produce 

copper die-cast rotors in-house and 

would have to outsource this 

production. Manufacturers stated that if 

the entire motor industry had to 

outsource their rotor production as a 

result of standards that required the use 

of die-cast copper rotors, there would be 

significant supply chain problems in the 

motor manufacturing process. 

Manufacturers emphasized during 

interviews that the capacity to produce 

copper rotors on a large commercial 

scale does not exist and would be very 

difficult to implement in even a threeyear time period. 

Overall, manufacturers are very 

concerned if any electric motor standard 

required motor efficiency levels beyond 

NEMA Premium, especially if those 

efficiency levels required the use of 

copper rotor technology. According to 

manufacturers, efficiency levels beyond 

NEMA Premium would require a 

significant level of investment from all 

electric motor manufacturers and would 

cause the U.S. to be out of sync with the 

electric motor standards around the 

world. If standards required the use of 

copper rotors, manufacturers would 

experience further difficulties due to the 

potential increase in copper prices and 

the volatility of the copper market, as 

well as the potential safety concerns 

regarding the higher melting 

temperature of copper than aluminum. 

b. Increase in Equipment Repairs 

Manufacturers have stated that as 

energy conservation standards increase 

customers are more likely to rewind old, 

less efficient motors, as opposed to 

purchasing newer more efficient and 

compliant motors. Therefore, if motor 

standards significantly increase the 

price of motors, manufacturers believe 

rewinding older motors might become a 

more attractive option for some 

customers. These customers would in 

turn be using more energy than if they 

simply purchased a currently compliant 

motor, since rewound motors typically 

do not operate at their original 

efficiency level after being rewound. 

Manufacturers believe that DOE must 

take the potential consumer rewinding 

decision into account when deciding on 

an electric motors standard. 

c. Enforcement 

Manufacturers have stated that one of 

their biggest concerns with additional 

energy conservation standards is the 

lack of enforcement of current electric 

motor standards. In general, domestic 

manufacturers have stated they comply 

with the current electric motor 

regulations and will continue to comply 

with any future standards. However, 

these manufacturers believe that there 

are several foreign motor manufacturers 

that do not comply with the current 

electric motor regulations and will not 

comply with any future standards if the 

efficiency standards are increased. This 

would cause compliant manufacturers 

to be placed at a competitive 

disadvantage, since complying with any 

increased efficiency standards will be 

very costly. Some domestic 

manufacturers believe the most cost 

effective way to reduce energy 

consumption of electric motors is to 

more strictly enforce the existing 

electric motor standards rather than 

increase the efficiency standards of 

electric motors. 

K. Emissions Analysis 

In the emissions analysis, DOE 

estimated the reduction in power sector 

emissions of carbon dioxide (CO2), 

nitrogen oxides (NOX), sulfur dioxide 

(SO2), and mercury (Hg) from potential 

energy conservation standards for 

electric motors. In addition, DOE 

estimates emissions impacts in 

production activities (extracting, 

processing, and transporting fuels) that 

provide the energy inputs to power 

plants. These are referred to as 

‘‘upstream’’ emissions. Together, these 

emissions account for the full-fuel-cycle 

(FFC). In accordance with DOE’s FFC 

Statement of Policy (76 FR 51282 

(August 18, 2011) as amended at 77 FR 

49701 (August 17, 2012)), the FFC 

analysis includes impacts on emissions 

of methane (CH4) and nitrous oxide 

(N2O, both of which are recognized as 

greenhouse gases. 

DOE conducted the emissions 

analysis using emissions factors that 

were derived from data in the Energy 

Information Agency’s (EIA’s) Annual 

Energy Outlook 2013 (AEO 2013), 

supplemented by data from other 

sources. DOE developed separate 

emissions factors for power sector 

emissions and upstream emissions. The 

method that DOE used to derive 

emissions factors is described in chapter 

13 of the NOPR TSD. 

EIA prepares the Annual Energy 

Outlook using the National Energy 

Modeling System (NEMS). Each annual 

version of NEMS incorporates the 

projected impacts of existing air quality 

regulations on emissions. AEO 2013 

generally represents current legislation 

and environmental regulations, 

including recent government actions, for 

which implementing regulations were 

available as of December 31, 2012. 

SO2 emissions from affected electric 

generating units (EGUs) are subject to 

nationwide and regional emissions capand-trade programs. Title IV of the 

Clean Air Act sets an annual emissions 

cap on SO2 for affected EGUs in the 48 

contiguous States and the District of 

Columbia (DC). SO2 emissions from 28 

eastern states and DC were also limited 

under the Clean Air Interstate Rule 

(CAIR; 70 FR 25162 (May 12, 2005)), 

which created an allowance-based 

trading program that operates along 

with the Title IV program. CAIR was 

remanded to the U.S. Environmental 

Protection Agency (EPA) by the U.S. 

Court of Appeals for the District of 

Columbia Circuit but it remained in 

effect. See North Carolina v. EPA, 550 

F.3d 1176 (D.C. Cir. 2008); North 

Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 

2008). On July 6, 2011 EPA issued a 

replacement for CAIR, the Cross-State 

Air Pollution Rule (CSAPR). 76 FR 

48208 (August 8, 2011). On August 21, 

2012, the DC Circuit issued a decision 

to vacate CSAPR. See EME Homer City 

Generation, LP v. EPA, No. 11–1302, 

2012 WL 3570721 at *24 (D.C. Cir. Aug. 

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21, 2012). The court ordered EPA to 

continue administering CAIR. The AEO 

2013 emissions factors used for today’s 

NOPR assumes that CAIR remains a 

binding regulation through 2040. 

The attainment of emissions caps is 

typically flexible among EGUs and is 

enforced through the use of emissions 

allowances and tradable permits. Under 

existing EPA regulations, any excess 

SO2 emissions allowances resulting 

from the lower electricity demand 

caused by the adoption of an efficiency 

standard could be used to permit 

offsetting increases in SO2 emissions by 

any regulated EGU. In past rulemakings, 

DOE recognized that there was 

uncertainty about the effects of 

efficiency standards on SO2 emissions 

covered by the existing cap-and-trade 

system, but it concluded that negligible 

reductions in power sector SO2

emissions would occur as a result of 

standards. 

Beginning in 2015, however, SO2

emissions will fall as a result of the 

Mercury and Air Toxics Standards 

(MATS) for power plants. 77 FR 9304 

(Feb. 16, 2012). In the final MATS rule, 

EPA established a standard for hydrogen 

chloride as a surrogate for acid gas 

hazardous air pollutants (HAP), and also 

established a standard for SO2 (a nonHAP acid gas) as an alternative 

equivalent surrogate standard for acid 

gas HAP. The same controls are used to 

reduce HAP and non-HAP acid gas; 

thus, SO2 emissions will be reduced as 

a result of the control technologies 

installed on coal-fired power plants to 

comply with the MATS requirements 

for acid gas. AEO 2013 assumes that, in 

order to continue operating, coal plants 

must have either flue gas 

desulfurization or dry sorbent injection 

systems installed by 2015. Both 

technologies, which are used to reduce 

acid gas emissions, also reduce SO2

emissions. Under the MATS, NEMS 

shows a reduction in SO2 emissions 

when electricity demand decreases (e.g., 

as a result of energy efficiency 

standards). Emissions will be far below 

the cap established by CAIR, so it is 

unlikely that excess SO2 emissions 

allowances resulting from the lower 

electricity demand would be needed or 

used to permit offsetting increases in 

SO2 emissions by any regulated EGU. 

Therefore, DOE believes that efficiency 

standards will reduce SO2 emissions in 

2015 and beyond. 

CAIR established a cap on NOX

emissions in 28 eastern States and the 

District of Columbia. Energy 

conservation standards are expected to 

have little effect on NOX emissions in 

those States covered by CAIR because 

excess NOX emissions allowances 

resulting from the lower electricity 

demand could be used to permit 

offsetting increases in NOX emissions. 

However, standards would be expected 

to reduce NOX emissions in the States 

not affected by the caps, so DOE 

estimated NOX emissions reductions 

from the standards considered in 

today’s NOPR for these States. 

The MATS limit mercury emissions 

from power plants, but they do not 

include emissions caps and, as such, 

DOE’s energy conservation standards 

would likely reduce Hg emissions. DOE 

estimated mercury emissions reduction 

using emissions factors based on AEO 

2013, which incorporates the MATS. 

NEMA commented that DOE should 

consider emissions related to all aspects 

involved in the production of higher 

efficiency motors. (NEMA, No. 54 at p. 

31) In response, DOE notes that EPCA 

directs DOE to consider the total 

projected amount of energy, or as 

applicable, water, savings likely to 

result directly from the imposition of 

the standard when determining whether 

a standard is economically justified. (42 

U.S.C. 6295(o)(2)(B)(i)(III) and 6316(a)) 

DOE interprets this to include energy 

used in the generation, transmission, 

and distribution of fuels used by 

appliances or equipment. In addition, 

DOE is using the full-fuel-cycle 

measure, which includes the energy 

consumed in extracting, processing, and 

transporting primary fuels. DOE’s 

current accounting of primary energy 

savings and the full-fuel-cycle measure 

are directly linked to the energy used by 

appliances or equipment. DOE believes 

that energy used in manufacturing of 

appliances or equipment falls outside 

the boundaries of ‘‘directly’’ as intended 

by EPCA. Thus, DOE did not consider 

such energy use and air emissions in the 

NIA or in the emissions analysis. 

L. Monetizing Carbon Dioxide and Other 

Emissions Impacts 

As part of the development of this 

proposed rule, DOE considered the 

estimated monetary benefits from the 

reduced emissions of CO2 and NOX that 

are expected to result from each of the 

TSLs considered. In order to make this 

calculation similar to the calculation of 

the NPV of consumer benefit, DOE 

considered the reduced emissions 

expected to result over the lifetime of 

equipment shipped in the forecast 

period for each TSL. This section 

summarizes the basis for the monetary 

values used for each of these emissions 

and presents the values considered in 

this rulemaking. 

For today’s NOPR, DOE is relying on 

a set of values for the social cost of 

carbon (SCC) that was developed by an 

interagency process. A summary of the 

basis for these values is provided below, 

and a more detailed description of the 

methodologies used is provided as an 

appendix to chapter 14 of the NOPR 

TSD. 

1. Social Cost of Carbon 

The SCC is an estimate of the 

monetized damages associated with an 

incremental increase in carbon 

emissions in a given year. It is intended 

to include (but is not limited to) changes 

in net agricultural productivity, human 

health, property damages from 

increased flood risk, and the value of 

ecosystem services. Estimates of the 

SCC are provided in dollars per metric 

ton of carbon dioxide. A domestic SCC 

value is meant to reflect the value of 

damages in the United States resulting 

from a unit change in carbon dioxide 

emissions, while a global SCC value is 

meant to reflect the value of damages 

worldwide. 

Under section 1(b)(6) of Executive 

Order 12866, ‘‘Regulatory Planning and 

Review,’’ 58 FR 51735 (Oct. 4, 1993), 

agencies must, to the extent permitted 

by law, assess both the costs and the 

benefits of the intended regulation and, 

recognizing that some costs and benefits 

are difficult to quantify, propose or 

adopt a regulation only upon a reasoned 

determination that the benefits of the 

intended regulation justify its costs. The 

purpose of the SCC estimates presented 

here is to allow agencies to incorporate 

the monetized social benefits of 

reducing CO2 emissions into costbenefit analyses of regulatory actions 

that have small, or ‘‘marginal,’’ impacts 

on cumulative global emissions. The 

estimates are presented with an 

acknowledgement of the many 

uncertainties involved and with a clear 

understanding that they should be 

updated over time to reflect increasing 

knowledge of the science and 

economics of climate impacts. 

As part of the interagency process that 

developed the SCC estimates, technical 

experts from numerous agencies met on 

a regular basis to consider public 

comments, explore the technical 

literature in relevant fields, and discuss 

key model inputs and assumptions. The 

main objective of this process was to 

develop a range of SCC values using a 

defensible set of input assumptions 

grounded in the existing scientific and 

economic literatures. In this way, key 

uncertainties and model differences 

transparently and consistently inform 

the range of SCC estimates used in the 

rulemaking process. 

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79See Average Fuel Economy Standards 

Passenger Cars and Light Trucks Model Year 2011, 

74 FR 14196 (March 30, 2009) (Final Rule); Final 

Environmental Impact Statement Corporate Average 

Fuel Economy Standards, Passenger Cars and Light 

Trucks, Model Years 2011–2015 at 3–90 (Oct. 2008) 

(Available at: http://www.nhtsa.gov/fuel-economy) 

(Last accessed December 2012). 

80See Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 

2011–2015, 73 FR 24352 (May 2, 2008) (Proposed 

Rule); Draft Environmental Impact Statement 

Corporate Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 

2011–2015 at 3–58 (June 2008) (Available at: http:// 

www.nhtsa.gov/fuel-economy) (Last accessed 

December 2012). 

81Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866. Interagency 

Working Group on Social Cost of Carbon, United 

States Government, February 2010. http://

a. Monetizing Carbon Dioxide Emissions 

When attempting to assess the 

incremental economic impacts of carbon 

dioxide emissions, the analyst faces a 

number of serious challenges. A recent 

report from the National Research 

Council points out that any assessment 

will suffer from uncertainty, 

speculation, and lack of information 

about: (1) Future emissions of 

greenhouse gases; (2) the effects of past 

and future emissions on the climate 

system; (3) the impact of changes in 

climate on the physical and biological 

environment; and (4) the translation of 

these environmental impacts into 

economic damages. As a result, any 

effort to quantify and monetize the 

harms associated with climate change 

will raise serious questions of science, 

economics, and ethics and should be 

viewed as provisional. 

Despite the serious limits of both 

quantification and monetization, SCC 

estimates can be useful in estimating the 

social benefits of reducing carbon 

dioxide emissions. Most Federal 

regulatory actions can be expected to 

have marginal impacts on global 

emissions. For such policies, the agency 

can estimate the benefits from reduced 

emissions in any future year by 

multiplying the change in emissions in 

that year by the SCC value appropriate 

for that year. The net present value of 

the benefits can then be calculated by 

multiplying the future benefits by an 

appropriate discount factor and 

summing across all affected years. This 

approach assumes that the marginal 

damages from increased emissions are 

constant for small departures from the 

baseline emissions path, an 

approximation that is reasonable for 

policies that have effects on emissions 

that are small relative to cumulative 

global carbon dioxide emissions. For 

policies that have a large (non-marginal) 

impact on global cumulative emissions, 

there is a separate question of whether 

the SCC is an appropriate tool for 

calculating the benefits of reduced 

emissions. This concern is not 

applicable to this rulemaking, however. 

It is important to emphasize that the 

interagency process is committed to 

updating these estimates as the science 

and economic understanding of climate 

change and its impacts on society 

improves over time. In the meantime, 

the interagency group will continue to 

explore the issues raised by this analysis 

and consider public comments as part of 

the ongoing interagency process. 

b. Social Cost of Carbon Values Used in 

Past Regulatory Analyses 

Economic analyses for Federal 

regulations have used a wide range of 

values to estimate the benefits 

associated with reducing carbon dioxide 

emissions. In the final model year 2011 

CAFE rule, the U.S. Department of 

Transportation (DOT) used both a 

‘‘domestic’’ SCC value of $2 per metric 

ton of CO2 and a ‘‘global’’ SCC value of 

$33 per metric ton of CO2 for 2007 

emission reductions (in 2007$), 

increasing both values at 2.4 percent per 

year. DOT also included a sensitivity 

analysis at $80 per metric ton of CO2.79

A 2008 regulation proposed by DOT 

assumed a domestic SCC value of $7 per 

metric ton of CO2 (in 2006$) for 2011 

emission reductions (with a range of $0– 

$14 for sensitivity analysis), also 

increasing at 2.4 percent per year.80 A 

regulation for packaged terminal air 

conditioners and packaged terminal 

heat pumps finalized by DOE in October 

of 2008 used a domestic SCC range of 

$0 to $20 per metric ton CO2 for 2007 

emission reductions (in 2007$). 73 FR 

58772, 58814 (Oct. 7, 2008). In addition, 

EPA’s 2008 Advance Notice of Proposed 

Rulemaking on Regulating Greenhouse 

Gas Emissions Under the Clean Air Act 

identified what it described as ‘‘very 

preliminary’’ SCC estimates subject to 

revision. 73 FR 44354 (July 30, 2008). 

EPA’s global mean values were $68 and 

$40 per metric ton CO2 for discount 

rates of approximately 2 percent and 3 

percent, respectively (in 2006$ for 2007 

emissions). 

In 2009, an interagency process was 

initiated to offer a preliminary 

assessment of how best to quantify the 

benefits from reducing carbon dioxide 

emissions. To ensure consistency in 

how benefits are evaluated across 

agencies, the Administration sought to 

develop a transparent and defensible 

method, specifically designed for the 

rulemaking process, to quantify avoided 

climate change damages from reduced 

CO2 emissions. The interagency group 

did not undertake any original analysis. 

Instead, it combined SCC estimates from 

the existing literature to use as interim 

values until a more comprehensive 

analysis could be conducted. The 

outcome of the preliminary assessment 

by the interagency group was a set of 

five interim values: Global SCC 

estimates for 2007 (in 2006$) of $55, 

$33, $19, $10, and $5 per metric ton of 

CO2. These interim values represented 

the first sustained interagency effort 

within the U.S. government to develop 

an SCC for use in regulatory analysis. 

The results of this preliminary effort 

were presented in several proposed and 

final rules. 

c. Current Approach and Key 

Assumptions 

Since the release of the interim 

values, the interagency group 

reconvened on a regular basis to 

generate improved SCC estimates. 

Specifically, the group considered 

public comments and further explored 

the technical literature in relevant 

fields. The interagency group relied on 

three integrated assessment models 

commonly used to estimate the SCC: 

The FUND, DICE, and PAGE models. 

These models are frequently cited in the 

peer-reviewed literature and were used 

in the last assessment of the 

Intergovernmental Panel on Climate 

Change. Each model was given equal 

weight in the SCC values that were 

developed. 

Each model takes a slightly different 

approach to model how changes in 

emissions result in changes in economic 

damages. A key objective of the 

interagency process was to enable a 

consistent exploration of the three 

models while respecting the different 

approaches to quantifying damages 

taken by the key modelers in the field. 

An extensive review of the literature 

was conducted to select three sets of 

input parameters for these models: 

climate sensitivity, socio-economic and 

emissions trajectories, and discount 

rates. A probability distribution for 

climate sensitivity was specified as an 

input into all three models. In addition, 

the interagency group used a range of 

scenarios for the socio-economic 

parameters and a range of values for the 

discount rate. All other model features 

were left unchanged, relying on the 

model developers’ best estimates and 

judgments. 

In 2010, the interagency group 

selected four sets of SCC values for use 

in regulatory analyses.81 Three sets of 

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www.whitehouse.gov/sites/default/files/omb/

inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf. 

82Technical Update of the Social Cost of Carbon 

for Regulatory Impact Analysis Under Executive 

Order 12866. Interagency Working Group on Social 

Cost of Carbon, United States Government. May 

2013; revised November 2013.http://

www.whitehouse.gov/sites/default/files/omb/assets/

inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf. 

values are based on the average SCC 

from three integrated assessment 

models, at discount rates of 2.5 percent, 

3 percent, and 5 percent. The fourth set, 

which represents the 95th-percentile 

SCC estimate across all three models at 

a 3-percent discount rate, is included to 

represent higher-than-expected impacts 

from climate change further out in the 

tails of the SCC distribution. The values 

grow in real terms over time. 

Additionally, the interagency group 

determined that a range of values from 

7 percent to 23 percent should be used 

to adjust the global SCC to calculate 

domestic effects, although preference is 

given to consideration of the global 

benefits of reducing CO2 emissions. 

Table IV.26 presents the values in the 

2010 interagency group report, which is 

reproduced in appendix 14–A of the 

NOPR TSD. 

TABLE IV.26—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050 

[In 2007 dollars per metric ton CO2] 

Year 

Discount rate % 

5 3 2.5 3 

Average Average Average 95th Percentile 

2010 ......................................................................................... 4.7 21.4 35.1 64.9 

2015 ......................................................................................... 5.7 23.8 38.4 72.8 

2020 ......................................................................................... 6.8 26.3 41.7 80.7 

2025 ......................................................................................... 8.2 29.6 45.9 90.4 

2030 ......................................................................................... 9.7 32.8 50.0 100.0 

2035 ......................................................................................... 11.2 36.0 54.2 109.7 

2040 ......................................................................................... 12.7 39.2 58.4 119.3 

2045 ......................................................................................... 14.2 42.1 61.7 127.8 

2050 ......................................................................................... 15.7 44.9 65.0 136.2 

The SCC values used for today’s 

notice were generated using the most 

recent versions of the three integrated 

assessment models that have been 

published in the peer-reviewed 

literature.82 Table IV.27shows the 

updated sets of SCC estimates from the 

2013 interagency update in five-year 

increments from 2010 to 2050. 

Appendix 14A of the NOPR TSD 

provides the full set of values. The 

central value that emerges is the average 

SCC across models at 3-percent discount 

rate. However, for purposes of capturing 

the uncertainties involved in regulatory 

impact analysis, the interagency group 

emphasizes the importance of including 

all four sets of SCC values. 

TABLE IV.27—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050 

[In 2007 dollars per metric ton CO2] 

Year 

Discount rate % 

5 3 2.5 3 

Average Average Average 95th Percentile 

2010 ......................................................................................... 11 32 51 89 

2015 ......................................................................................... 11 37 57 109 

2020 ......................................................................................... 12 43 64 128 

2025 ......................................................................................... 14 47 69 143 

2030 ......................................................................................... 16 52 75 159 

2035 ......................................................................................... 19 56 80 175 

2040 ......................................................................................... 21 61 86 191 

2045 ......................................................................................... 24 66 92 206 

2050 ......................................................................................... 26 71 97 220 

It is important to recognize that a 

number of key uncertainties remain, and 

that current SCC estimates should be 

treated as provisional and revisable 

since they will evolve with improved 

scientific and economic understanding. 

The interagency group also recognizes 

that the existing models are imperfect 

and incomplete. The National Research 

Council report mentioned above points 

out that there is tension between the 

goal of producing quantified estimates 

of the economic damages from an 

incremental ton of carbon and the limits 

of existing efforts to model these effects. 

There are a number of concerns and 

problems that should be addressed by 

the research community, including 

research programs housed in many of 

the Federal agencies participating in the 

interagency process to estimate the SCC. 

The interagency group intends to 

periodically review and reconsider 

those estimates to reflect increasing 

knowledge of the science and 

economics of climate impacts, as well as 

improvements in modeling. 

In summary, in considering the 

potential global benefits resulting from 

reduced CO2 emissions resulting from 

today’s rule, DOE used the values from 

the 2013 interagency report, adjusted to 

2012$ using the Gross Domestic Product 

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83For additional information, refer to U.S. Office 

of Management and Budget, Office of Information 

and Regulatory Affairs, 2006 Report to Congress on 

the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal 

Entities, Washington, DC. 

84OMB, Circular A–4: Regulatory Analysis (Sept. 

17, 2003). 

85For more information on NEMS, refer to the 

U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary 

is National Energy Modeling System: An Overview 

2003, DOE/EIA–0581(2003) (March, 2003). 

86 DOE/EIA approves use of the name NEMS to 

describe only an official version of the model 

without any modification to code or data. Because 

this analysis entails some minor code modifications 

and the model is run under various policy scenarios 

that are variations on DOE/EIA assumptions, DOE 

refers to it by the name ‘‘NEMS–BT’’ (‘‘BT’’ is DOE’s 

Building Technologies Program, under whose aegis 

this work has been performed). 

price deflator. For each of the four cases 

specified, the values used for emissions 

in 2015 were $11.8, $39.7, $61.2, and 

$117 per metric ton avoided (values 

expressed in 2012$). DOE derived 

values after 2050 using the relevant 

growth rate for the 2040–2050 period in 

the interagency update. 

DOE multiplied the CO2 emissions 

reduction estimated for each year by the 

SCC value for that year in each of the 

four cases. To calculate a present value 

of the stream of monetary values, DOE 

discounted the values in each of the 

four cases using the specific discount 

rate that had been used to obtain the 

SCC values in each case. 

2. Valuation of Other Emissions 

Reductions 

DOE investigated the potential 

monetary benefit of reduced NOX

emissions from the TSLs it considered. 

As noted above, DOE has taken into 

account how new or amended energy 

conservation standards would reduce 

NOX emissions in those 22 states not 

affected by the CAIR. DOE estimated the 

monetized value of NOX emissions 

reductions resulting from each of the 

TSLs considered for today’s NOPR 

based on estimates found in the relevant 

scientific literature. Available estimates 

suggest a very wide range of monetary 

values per ton of NOX from stationary 

sources, ranging from $468 to $4,809 per 

ton in 2012$).83 In accordance with 

OMB guidance,84 DOE calculated a 

range of monetary benefits using each of 

the economic values for NOX and real 

discount rates of 3-percent and 7- 

percent. 

DOE is evaluating appropriate 

monetization of avoided SO2 and Hg 

emissions in energy conservation 

standards rulemakings. It has not 

included monetization in the current 

analysis. 

M. Utility Impact Analysis 

The utility impact analysis estimates 

several effects on the power generation 

industry that would result from the 

adoption of new or amended energy 

conservation standards. In the utility 

impact analysis, DOE analyzes the 

changes in installed electricity capacity 

and generation that would result for 

each trial standard level. The utility 

impact analysis uses a variant of 

NEMS,85 which is a public domain, 

multi-sectored, partial equilibrium 

model of the U.S. energy sector. DOE 

uses a variant of this model, referred to 

as NEMS–BT,86 to account for selected 

utility impacts of new or amended 

energy conservation standards. DOE’s 

analysis consists of a comparison 

between model results for the most 

recent AEO Reference Case and for cases 

in which energy use is decremented to 

reflect the impact of potential standards. 

The energy savings inputs associated 

with each TSL come from the NIA. 

Chapter 15 of the NOPR TSD describes 

the utility impact analysis in further 

detail. 

N. Employment Impact Analysis 

Employment impacts from new or 

amended energy conservation standards 

include direct and indirect impacts. 

Direct employment impacts are any 

changes in the number of employees of 

manufacturers of the equipment subject 

to standards; the MIA addresses those 

impacts. Indirect employment impacts 

are changes in national employment 

that occur due to the shift in 

expenditures and capital investment 

caused by the purchase and operation of 

more efficient equipment. Indirect 

employment impacts from standards 

consist of the jobs created or eliminated 

in the national economy, other than in 

the manufacturing sector being 

regulated, due to: (1) Reduced spending 

by end users on energy; (2) reduced 

spending on new energy supply by the 

utility industry; (3) increased consumer 

spending on the purchase of new 

equipment; and (4) the effects of those 

three factors throughout the economy. 

One method for assessing the possible 

effects on the demand for labor of such 

shifts in economic activity is to compare 

sector employment statistics developed 

by the Labor Department’s Bureau of 

Labor Statistics (BLS). BLS regularly 

publishes its estimates of the number of 

jobs per million dollars of economic 

activity in different sectors of the 

economy, as well as the jobs created 

elsewhere in the economy by this same 

economic activity. Data from BLS 

indicate that expenditures in the utility 

sector generally create fewer jobs (both 

directly and indirectly) than 

expenditures in other sectors of the 

economy. There are many reasons for 

these differences, including wage 

differences and the fact that the utility 

sector is more capital-intensive and less 

labor-intensive than other sectors. 

Energy conservation standards have the 

effect of reducing consumer utility bills. 

Because reduced consumer 

expenditures for energy likely lead to 

increased expenditures in other sectors 

of the economy, the general effect of 

efficiency standards is to shift economic 

activity from a less labor-intensive 

sector (i.e., the utility sector) to more 

labor-intensive sectors (e.g., the retail 

and service sectors). Thus, based on the 

BLS data alone, DOE believes net 

national employment may increase 

because of shifts in economic activity 

resulting from new and amended 

standards. 

For the standard levels considered in 

the NOPR, DOE estimated indirect 

national employment impacts using an 

input/output model of the U.S. economy 

called Impact of Sector Energy 

Technologies, Version 3.1.1 (ImSET). 

ImSET is a special purpose version of 

the ‘‘U.S. Benchmark National InputOutput’’ (I–O) model, which was 

designed to estimate the national 

employment and income effects of 

energy-saving technologies. The ImSET 

software includes a computer-based I–O 

model having structural coefficients that 

characterize economic flows among the 

187 sectors. ImSET’s national economic 

I–O structure is based on a 2002 U.S. 

benchmark table, specially aggregated to 

the 187 sectors most relevant to 

industrial, commercial, and residential 

building energy use. DOE notes that 

ImSET is not a general equilibrium 

forecasting model, and understands the 

uncertainties involved in projecting 

employment impacts, especially 

changes in the later years of the 

analysis. Because ImSET does not 

incorporate price changes, the 

employment effects predicted by ImSET 

may over-estimate actual job impacts 

over the long run. For the NOPR, DOE 

used ImSET only to estimate short-term 

employment impacts. 

For more details on the employment 

impact analysis, see chapter 16 of the 

NOPR TSD. 

O. Other Comments Received 

IECA commented that motor endusers have not participated in DOE’s 

electric motor standards process, and 

they urge DOE to provide an outreach 

effort to include those who buy motors. 

(IECA, No. 52 at p. 3) Throughout the 

rulemaking process, DOE makes a 

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considerable effort to understand 

rulemaking impacts to consumers, most 

specifically in the life-cycle cost 

analysis. It encourages various 

interested parties, including end-users 

of electric motors, to attend public 

meetings and submit comments. DOE 

recognizes the central importance of the 

consumer perspective, and welcomes 

comment from IECA and any other 

organizations serving consumer interest, 

as well as from individual consumers, 

themselves. 

V. Analytical Results 

A. Trial Standard Levels 

DOE ordinarily considers several Trial 

Standard Levels (TSLs) in its analytical 

process. TSLs are formed by grouping 

different Efficiency Levels (ELs), which 

are standard levels for each Equipment 

Class Grouping (ECG) of motors. DOE 

analyzed the benefits and burdens of the 

TSLs developed for today’s proposed 

rule. DOE examined four TSLs for 

electric motors. Table V.1 presents the 

TSLs analyzed and the corresponding 

efficiency level for each equipment class 

group. 

The efficiency levels in each TSL can 

be characterized as follows: TSL 1 

represents each equipment class group 

moving up one efficiency level from the 

current baseline, with the exception of 

fire-pump motors, which remain at their 

baseline level; TSL 2 represents NEMA 

Premium levels for all equipment class 

groups with the exception of fire-pump 

motors, which remain at the baseline; 

TSL 3 represents 1 NEMA band above 

NEMA Premium for all groups except 

fire-pump motors, which move up to 

NEMA Premium; and TSL 4 represents 

the maximum technologically feasible 

level (max tech) for all equipment class 

groups. Because today’s proposal 

includes equipment class groups 

containing both currently regulated 

motors and those proposed to be 

regulated, at certain TSLs, an equipment 

class group may encompass different 

standard levels, some of which may be 

above one EL above the baseline. For 

example, at TSL1, EL1 is being 

proposed for equipment class group 1. 

However, a large number of motors in 

equipment class group 1 already have to 

meet EL2. If TSL1 was selected, these 

motors would continue to be required to 

meet the standards at TSL2, while 

currently un-regulated motors would be 

regulated to TSL1. 

TABLE V.1—SUMMARY OF PROPOSED TSLS

Equipment class group TSL 1 TSL 2 TSL 3 TSL 4 

1 ................................................................................ EL 1 ................................ EL 2 ................................ EL 3 ................................ EL 4 

2 ................................................................................ EL 1 ................................ EL 1 ................................ EL 2 ................................ EL 2 

3 ................................................................................ EL 0 ................................ EL 0 ................................ EL 1 ................................ EL 3 

4 ................................................................................ EL 1 ................................ EL 2 ................................ EL 3 ................................ EL 4 

B. Economic Justification and Energy 

Savings 

As discussed in section II.A, EPCA 

provides seven factors to be evaluated in 

determining whether a potential energy 

conservation standard is economically 

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

following sections generally discuss 

how DOE is addressing each of those 

seven factors in this rulemaking. 

1. Economic Impacts on Individual 

Customers 

DOE analyzed the economic impacts 

on electric motor customers by looking 

at the effects standards would have on 

the LCC and PBP. DOE also examined 

the rebuttable presumption payback 

periods for each equipment class, and 

the impacts of potential standards on 

customer subgroups. These analyses are 

discussed below. 

a. Life-Cycle Cost and Payback Period 

To evaluate the net economic impact 

of standards on electric motor 

customers, DOE conducted LCC and 

PBP analyses for each TSL. In general, 

higher-efficiency equipment would 

affect customers in two ways: (1) 

Annual operating expense would 

decrease, and (2) purchase price would 

increase. Section IV.F of this notice 

discusses the inputs DOE used for 

calculating the LCC and PBP. The LCC 

and PBP results are calculated from 

electric motor cost and efficiency data 

that are modeled in the engineering 

analysis (section IV.C). 

For each representative unit, the key 

outputs of the LCC analysis are a mean 

LCC savings and a median PBP relative 

to the base case, as well as the fraction 

of customers for which the LCC will 

decrease (net benefit), increase (net 

cost), or exhibit no change (no impact) 

relative to the base-case product 

forecast. No impacts occur when the 

base-case efficiency equals or exceeds 

the efficiency at a given TSL. Table V.2 

through Table V.5 show the key 

shipment weighted average of results for 

the representative units in each 

equipment class group. 

TABLE V.2—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 1 

Trial standard level * 1 2 3 4 

Efficiency level 1 2 3 4 

Customers with Net LCC Cost (%) ** ...................................................................................................................... 0.3 8.4 38.0 84.6 

Customers with Net LCC Benefit (%) ** .................................................................................................................. 9.7 32.0 40.4 7.6 

Customers with No Change in LCC (%) ** .............................................................................................................. 90.0 59.6 21.5 7.7 

Mean LCC Savings ($) ............................................................................................................................................ 43 132 68 ¥417 

Median PBP (Years) ................................................................................................................................................ 1.1 3.3 6.7 29.9 

* The results for equipment class group 1 are the shipment weighted averages of the results for representative units 1, 2, and 3. 

** Rounding may cause some items to not total 100 percent. 

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TABLE V.3—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 2 

Trial Standard level * 1 2 3 4 

Efficiency level 1 1 2 2 

Customers with Net LCC Cost (%) ** ...................................................................................................................... 21.5 21.5 94.7 94.7 

Customers with Net LCC Benefit (%) ** .................................................................................................................. 68.6 68.6 5.3 5.3 

Customers with No Change in LCC (%) ** .............................................................................................................. 9.9 9.9 0.0 0.0 

Mean LCC Savings ($) ............................................................................................................................................ 38 38 ¥285 ¥285 

Median PBP (Years) ................................................................................................................................................ 5.0 5.0 22.8 22.8 

* The results for equipment class group 2 are the shipment weighted averages of the results for representative units 4 and 5. 

** Rounding may cause some items to not total 100 percent. 

TABLE V.4—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 3 

Trial standard level * 1 2 3 4 

Efficiency level 0 0 1 3 

Customers with Net LCC Cost (%) ** .................................................................................................... 0.0 0.0 81.7 100.0 

Customers with Net LCC Benefit (%) ** ................................................................................................ 0.0 0.0 0.0 0.0 

Customers with No Change in LCC (%) ** ............................................................................................ 0.0 0.0 18.3 0.0 

Mean LCC Savings ($) .......................................................................................................................... N/A *** N/A *** ¥61 ¥763 

Median PBP (Years) .............................................................................................................................. N/A *** N/A *** 3,299 11,957 

* The results for equipment class group 3 are the shipment weighted averages of the results for representative units 6, 7, and 8. 

** Rounding may cause some items to not total 100 percent. 

*** For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected. 

TABLE V.5—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 4 

Trial standard level * 1 2 3 4 

Efficiency level 1 2 3 4 

Customers with Net LCC Cost (%) ** ...................................................................................................................... 1.0 10.8 33.1 79.6 

Customers with Net LCC Benefit (%) ** .................................................................................................................. 31.8 60.8 65.8 19.9 

Customers with No Change in LCC (%) ** .............................................................................................................. 67.3 28.4 1.1 0.3 

Mean LCC Savings ($) ............................................................................................................................................ 137 259 210 ¥291 

Median PBP (Years) ................................................................................................................................................ 1.2 1.9 3.7 16.0 

* The results for equipment class group 4 are the shipment weighted averages of the results for representative units 9 and 10. 

** Rounding may cause some items to not total 100 percent. 

b. Consumer Subgroup Analysis 

In the customer subgroup analysis, 

DOE estimated the LCC impacts of the 

electric motor TSLs on various groups of 

customers. Table V.6 and Table V.7 

compare the weighted average mean 

LCC savings and median payback 

periods for ECG 1 at each TSL for 

different customer subgroups. 

Chapter 11 of the TSD presents the 

detailed results of the customer 

subgroup analysis and results for the 

other equipment class groups. 

TABLE V.6—SUMMARY LIFE-CYCLE COST RESULTS FOR SUBGROUPS FOR EQUIPMENT CLASS GROUP 1: AVERAGE LCC 

SAVINGS

EL TSL 

Average LCC savings (2012$) * 

Default 

Low 

energy 

price 

Small 

business 

Industrial 

sector 

only 

Commercial 

sector 

only 

Agricultural 

sector 

only 

1 1 43 38 37 53 40 16 

2 2 132 115 111 169 118 5 

3 3 68 46 45 111 53 ¥103 

4 4 ¥417 ¥447 ¥448 ¥356 ¥440 ¥675 

* The results for equipment class group 1 are the shipment weighted averages of the results for representative units 1, 2, and 3. 

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TABLE V.7—SUMMARY LIFE-CYCLE COST RESULTS FOR SUBGROUPS FOR EQUIPMENT CLASS GROUP 1: MEDIAN

PAYBACK PERIOD

EL TSL 

Median payback period 

(Years) * 

Default 

Low 

energy 

price 

Small 

business 

Industrial 

sector 

only 

Commercial 

sector 

only 

Agricultural 

sector 

only 

1 1 1.1 1.3 1.1 0.8 1.3 3.5 

2 2 3.3 3.7 3.3 2.1 3.9 7.0 

3 3 6.7 7.6 6.7 4.2 7.9 22.7 

4 4 29.9 33.7 29.9 18.8 34.7 123.5 

* The results for equipment class group 1 are the shipment weighted averages of the results for representative units 1, 2, and 3. 

c. Rebuttable Presumption Payback 

As discussed in section IV.F.12, EPCA 

establishes a rebuttable presumption 

that an energy conservation standard is 

economically justified if the increased 

purchase cost for equipment that meets 

the standard is less than three times the 

value of the first-year energy savings 

resulting from the standard. (42 U.S.C. 

6295(o)(2)(B)(iii) and 6316(a)) DOE 

calculated a rebuttable-presumption 

PBP for each TSL to determine whether 

DOE could presume that a standard at 

that level is economically justified. DOE 

based the calculations on average usage 

profiles. As a result, DOE calculated a 

single rebuttable-presumption payback 

value, and not a distribution of PBPs, for 

each TSL. Table V.8 shows the 

rebuttable-presumption PBPs for the 

considered TSLs. The rebuttable 

presumption is fulfilled in those cases 

where the PBP is three years or less. 

However, DOE routinely conducts an 

economic analysis that considers the 

full range of impacts to the customer, 

manufacturer, Nation, and environment, 

as required under 42 U.S.C. 

6295(o)(2)(B)(i) as applied to equipment 

via 42 U.S.C. 6316(a). The results of that 

analysis serve as the basis for DOE to 

definitively evaluate the economic 

justification for a potential standard 

level (thereby supporting or rebutting 

the results of any three-year PBP 

analysis). Section V.C addresses how 

DOE considered the range of impacts to 

select today’s NOPR. 

TABLE V.8—REBUTTABLE-PRESUMPTION PAYBACK PERIODS (YEARS) 

Trial standard level 

1 2 3 4 

Equipment Class Group 1 * ..................................................................................................................... 0.6 0.8 1.2 4.3 

Equipment Class Group 2 * ..................................................................................................................... 1.8 1.8 8.0 8.0 

Equipment Class Group 3 * ..................................................................................................................... 0.0 0.0 900 5,464 

Equipment Class Group 4 * ..................................................................................................................... 0.6 0.9 1.3 4.5 

* The results for each equipment class group (ECG) are a shipment weighted average of results for the representative units in the group. ECG 

1: Representative units 1, 2, and 3; ECG 2: Representative units 4 and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units 

9 and10. 

2. Economic Impacts on Manufacturers 

DOE performed an MIA to estimate 

the impact of new and amended energy 

conservation standards on 

manufacturers of electric motors. The 

section below describes the expected 

impacts on manufacturers at each TSL. 

Chapter 12 of the TSD explains the 

analysis in further detail. 

The tables below depict the financial 

impacts (represented by changes in 

INPV) of new and amended energy 

conservation standards on 

manufacturers as well as the conversion 

costs that DOE estimates manufacturers 

would incur at each TSL. DOE displays 

the INPV impacts by TSL for each ECG 

in accordance with the grouping 

described in detail in section V.A. To 

evaluate the range of cash flow impacts 

on the electric motor industry, DOE 

modeled three markup scenarios that 

correspond to the range of anticipated 

market responses to new and amended 

standards. Each markup scenario results 

in a unique set of cash flows and 

corresponding industry value at each 

TSL. All three markup scenarios are 

presented below. In the following 

discussion, the INPV results refer to the 

difference in industry value between the 

base case and the standards case that 

result from the sum of discounted cash 

flows from the base year (2013) through 

the end of the analysis period. The 

results also discuss the difference in 

cash flow between the base case and the 

standards case in the year before the 

compliance date for new and amended 

energy conservation standards. This 

figure represents how large the required 

conversion costs are relative to the cash 

flow generated by the industry in the 

absence of new and amended energy 

conservation standards. In the 

engineering analysis, DOE enumerates 

common technology options that 

achieve the efficiencies for each of the 

representative units within an ECG. For 

descriptions of these technology options 

and the required efficiencies at each 

TSL, see section IV.C of today’s notice. 

a. Industry Cash-Flow Analysis Results 

The results below show three INPV 

tables representing the three markup 

scenarios used for the analysis. The first 

table reflects the flat markup scenario, 

which is the upper (less severe) bound 

of impacts. To assess the lower end of 

the range of potential impacts, DOE 

modeled two potential markup 

scenarios, a two-tiered markup scenario 

and a preservation of operating profit 

markup scenario. As discussed in 

section IV.J.2.d, the two-tiered markup 

scenario assumes manufacturers offer 

two different tiers of markups—one for 

lower efficiency levels and one for 

higher efficiency levels. Meanwhile the 

preservation of operating profit markup 

scenario assumes that in the standards 

case, manufacturers would be able to 

earn the same operating margin in 

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absolute dollars in the standards case as 

in the base case. In general, the larger 

the product price increases, the less 

likely manufacturers are able to fully 

pass through additional costs due to 

standards calculated in the flat markup 

scenario. 

Table V.9, Table V.10, and Table V.11 

present the projected results for all 

electric motors under the flat, two-tiered 

and preservation of operating profit 

markup scenarios. DOE examined all 

four ECGs (Design A and B motors, 

Design C motors, fire pump motors, and 

brake motors) together. The INPV results 

follow in the tables below. 

TABLE V.9—MANUFACTURER IMPACT ANALYSIS FOR ELECTRIC MOTORS—FLAT MARKUP SCENARIO

Units Base case 

Trial standard level 

1 2 3 4 

INPV ............................................................. (2012$ millions) ............. $3,371.2 $3,378.7 $3,759.2 $4,443.7 $5,241.3 

Change in INPV ........................................... (2012$ millions) ............. .................... $7.5 $388.0 $1,072.5 $1,870.1 

(%) ................................. .................... 0.2% 11.5% 31.8% 55.5% 

Product Conversion Costs ........................... (2012$ millions) ............. .................... $6.1 $57.4 $611.7 $620.6 

Capital Conversion Costs ............................ (2012$ millions) ............. .................... $0.0 $26.4 $220.5 $699.8 

Total Conversion Costs ........................ (2012$ millions) ............. .................... $6.2 $83.7 $832.3 $1,320.4 

TABLE V.10—MANUFACTURER IMPACT ANALYSIS FOR ELECTRIC MOTORS—TWO-TIERED MARKUP SCENARIO

Units Base case 

Trial standard level 

1 2 3 4 

INPV ............................................................. (2012$ millions) ............. $3,371.2 $3,374.3 $3,087.6 $2,979.6 $3,335.7 

Change in INPV ........................................... (2012$ millions) ............. .................... $3.2 $(283.5) $(391.6) $(35.5) 

(%) ................................. .................... 0.1% ¥8.4% ¥11.6% ¥1.1% 

Product Conversion Costs ........................... (2012$ millions) ............. .................... $6.1 $57.4 $611.7 $620.6 

Capital Conversion Costs ............................ (2012$ millions) ............. .................... $0.0 $26.4 $220.5 $699.8 

Total Conversion Costs ........................ (2012$ millions) ............. .................... $6.2 $83.7 $832.3 $1,320.4 

TABLE V.11—MANUFACTURER IMPACT ANALYSIS FOR ELECTRIC MOTORS—PRESERVATION OF OPERATING PROFIT

MARKUP SCENARIO

Units Base case 

Trial standard level 

1 2 3 4 

INPV ....................................................... (2012$ millions) ................... $3,371.2 $3,019.5 $3,089.7 $2,356.8 $1,383.1 

Change in INPV ..................................... (2012$ millions) ................... .................... $(351.7) $(281.5) $(1,014.4) $(1,988.1) 

(%) ....................................... .................... ¥10.4% ¥8.4% ¥30.1% ¥59.0% 

Product Conversion Costs ..................... (2012$ millions) ................... .................... $6.1 $57.4 $611.7 $620.6 

Capital Conversion Costs ...................... (2012$ millions) ................... .................... $0.0 $26.4 $220.5 $699.8 

Total Conversion Costs .................. (2012$ millions) ................... .................... $6.2 $83.7 $832.3 $1,320.4 

TSL 1 represents EL 1 for ECG 1, ECG 

2 and ECG 4 motors and baseline for 

ECG 2 motors. At TSL 1, DOE estimates 

impacts on INPV to range from $7.5 

million to ¥$351.7 million, or a change 

in INPV of 0.2 percent to ¥10.4 percent. 

At this proposed level, industry free 

cash flow is estimated to decrease by 

approximately 1.1 percent to $164.9 

million, compared to the base case value 

of $166.7 million in the year leading up 

to the proposed energy conservation 

standards. 

The INPV impacts at TSL 1 range 

from slightly positive to moderately 

negative, however DOE does not 

anticipate that manufacturers would 

lose a significant portion of their INPV 

at this TSL. This is because the vast 

majority of shipments already meets or 

exceeds the efficiency levels prescribed 

at TSL 1. DOE estimates that in the year 

of compliance, 90 percent of all electric 

motor shipments (90 percent of ECG 1, 

eight percent of ECG 2, 100 percent of 

ECG 3, and 67 percent of ECG 4 

shipments) would meet the efficiency 

levels at TSL 1 or higher in the base 

case. Since ECG 1 shipments account for 

over 97 percent of all electric motor 

shipments the effects on those motors 

are the primary driver for the impacts at 

this TSL. Only a few ECG 1 shipments 

not currently covered by the existing 

electric motors rule and a small amount 

of ECG 2 and ECG 4 shipments would 

need to be converted at TSL 1 to meet 

this efficiency standard. 

DOE expects conversion costs to be 

small compared to the industry value 

because most of the electric motor 

shipments, on a volume basis, already 

meet the efficiency levels analyzed at 

this TSL. DOE estimates product 

conversion costs of $6.1 million due to 

the proposed expanded scope of this 

rulemaking which includes motors 

previously not covered by the current 

electric motor energy conservation 

standards. DOE believes that at this 

TSL, there will be some engineering 

costs as well as testing and certification 

costs associated with this proposed 

scope expansion. DOE estimates the 

capital conversion costs to be minimal 

at TSL 1. This is mainly because almost 

all manufacturers currently produce 

some motors that are compliant at TSL 

1 efficiency levels and it would not be 

much of a capital investment to bring all 

motor production to this efficiency 

level. 

TSL 2 represents EL 2 for ECG 1 and 

ECG 4 motors; EL 1 for ECG 2 motors; 

and baseline for ECG 3 motors. At TSL 

2, DOE estimates impacts on INPV to 

range from $388 million to ¥$283.5 

million, or a change in INPV of 11.5 

percent to ¥8.4 percent. At this 

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proposed level, industry free cash flow 

is estimated to decrease by 

approximately 17.2 percent to $138 

million, compared to the base case value 

of $166.7 million in the year leading up 

to the proposed energy conservation 

standards. 

The INPV impacts at TSL 2 range 

from moderately positive to moderately 

negative. DOE estimates that in the year 

of compliance, 59 percent of all electric 

motor shipments (60 percent of ECG 1, 

eight percent of ECG 2, 100 percent of 

ECG 3, and 30 percent of ECG 4 

shipments) would meet the efficiency 

levels at TSL 2 or higher in the base 

case. The majority of shipments are 

currently covered by an electric motors 

standard that requires general purpose 

Design A and B motors to meet this TSL. 

Therefore, only previously non-covered 

Design A and B motors and a few ECG 

2 and ECG 4 motors would have to be 

converted at TSL 2 to meet this 

efficiency standard. 

DOE expects conversion costs to 

increase significantly from TSL 1, 

however, these conversion costs do not 

represent a large portion of the base case 

INPV, since again the majority of 

electric motor shipments already meet 

the efficiency levels analyzed at this 

TSL. DOE estimates product conversion 

costs of $57.4 million due to the 

proposed expanded scope of this 

rulemaking, which includes motors 

previously not covered by the current 

electric motor energy conservation 

standards and the inclusion of ECG 2 

and ECG 4 motors. DOE believes there 

will be sizable engineering costs as well 

as testing and certification costs at this 

TSL associated with this proposed 

scope expansion. DOE estimates the 

capital conversion costs to be 

approximately $26.4 million at TSL 2. 

While most manufacturers already 

produce at least some motors that are 

compliant at TSL 2, these manufacturers 

would likely have to invest in expensive 

machinery to bring all motor production 

to these efficiency levels. 

TSL 3 represents EL 3 for ECG 1 and 

ECG 4 motors, EL 2 for ECG 2 motors 

and EL 1 for ECG 3 motors. At TSL 3, 

DOE estimates impacts on INPV to range 

from $1,072.5 million to ¥$1,014.4 

million, or a change in INPV of 31.8 

percent to ¥30.1 percent. At this 

proposed level, industry free cash flow 

is estimated to decrease by 

approximately 167.5 percent to ¥$112.5 

million, compared to the base case value 

of $166.7 million in the year leading up 

to the proposed energy conservation 

standards. 

The INPV impacts at TSL 3 range 

from significantly positive to 

significantly negative. DOE estimates 

that in the year of compliance, 23 

percent of all electric motor shipments 

(24 percent of ECG 1, less than one 

percent of ECG 2, 19 percent of ECG 3, 

and four percent of ECG 4 shipments) 

would meet the efficiency levels at TSL 

3 or higher in the base case. The 

majority of shipments would need to be 

converted to meet energy conservation 

standards at this TSL. 

DOE expects conversion costs to 

increase significantly at TSL 3 and 

become a substantial investment for 

manufacturers. DOE estimates product 

conversion costs of $611.7 million at 

TSL 3, since most electric motors in the 

base case do not exceed the current 

motor standards set at NEMA Premium 

for Design A and B motors, which 

represent EL 2 for ECG 1. DOE believes 

there would be a massive reengineering 

effort that manufacturers would have to 

undergo to have all motors meet this 

TSL. Additionally, motor manufacturers 

would have to increase the efficiency 

levels for ECG 2, ECG 3, and ECG 4 

motors. DOE estimates the capital 

conversion costs to be approximately 

$220.5 million at TSL 3. Most 

manufacturers would have to make 

significant investments to their 

production facilities in order to convert 

all their motors to be compliant at TSL 

3. 

TSL 4 represents EL 4 for ECG 1 and 

ECG 4 motors, EL 3 for ECG 3 motors 

and EL 2 for ECG 2 motors. At TSL 4, 

DOE estimates impacts on INPV to range 

from $1,870.1 million to ¥$1,988.1 

million, or a change in INPV of 55.5 

percent to ¥59.0 percent. At this 

proposed level, industry free cash flow 

is estimated to decrease by 

approximately 298.4 percent to ¥$330.8 

million, compared to the base case value 

of $166.7 million in the year leading up 

to the proposed energy conservation 

standards. 

The INPV impacts at TSL 4 range 

from significantly positive to 

significantly negative. DOE estimates 

that in the year of compliance only eight 

percent of all electric motor shipments 

(nine percent of ECG 1, less than one 

percent of ECG 2, zero percent of ECG 

3, and less than one percent of ECG 4 

shipments) would meet the efficiency 

levels at TSL 2 or higher in the base 

case. Almost all shipments would need 

to be converted to meet energy 

conservation standards at this TSL. 

DOE expects conversion costs again to 

increase significantly from TSL 3 to TSL 

4. Conversion costs at this TSL now 

represent a massive investment for 

electric motor manufacturers. DOE 

estimates product conversion costs of 

$620.6 million at TSL 4, which are the 

same conversion costs at TSL 3. DOE 

believes that manufacturers would need 

to completely reengineer almost all 

electric motors sold as well as test and 

certify those motors. DOE estimates 

capital conversion costs of $699.8 

million at TSL 4. This is a significant 

increase in capital conversion costs 

from TSL 3 since manufacturers would 

need to adopt copper die-casting at this 

TSL. This technology requires a 

significant level of investment because 

the majority of the machinery would 

need to be replaced or significantly 

modified. 

b. Impacts on Employment 

DOE quantitatively assessed the 

impact of potential new and amended 

energy conservation standards on direct 

employment. DOE used the GRIM to 

estimate the domestic labor 

expenditures and number of domestic 

production workers in the base case and 

at each TSL from the announcement of 

any potential new and amended energy 

conservation standards in 2013 to the 

end of the analysis period in 2044. DOE 

used statistical data from the U.S. 

Census Bureau’s 2011 Annual Survey of 

Manufacturers (ASM), the results of the 

engineering analysis, and interviews 

with manufacturers to determine the 

inputs necessary to calculate industrywide labor expenditures and domestic 

employment levels. Labor expenditures 

involved with the manufacturing of 

electric motors are a function of the 

labor intensity of the product, the sales 

volume, and an assumption that wages 

remain fixed in real terms over time. 

In the GRIM, DOE used the labor 

content of each product and the 

manufacturing production costs to 

estimate the annual labor expenditures 

of the industry. DOE used Census data 

and interviews with manufacturers to 

estimate the portion of the total labor 

expenditures attributable to domestic 

labor. 

The production worker estimates in 

this employment section cover only 

workers up to the line-supervisor level 

who are directly involved in fabricating 

and assembling an electric motor within 

a motor facility. Workers performing 

services that are closely associated with 

production operations, such as material 

handling with a forklift, are also 

included as production labor. DOE’s 

estimates account for only production 

workers who manufacture the specific 

equipment covered by this rulemaking. 

For example, a worker on an electric 

motor line manufacturing a fractional 

horsepower motor (i.e. a motor with less 

than one horsepower) would not be 

included with this estimate of the 

number of electric motor workers, since 

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fractional motors are not covered by this 

rulemaking. 

The employment impacts shown in 

the tables below represent the potential 

production employment impact 

resulting from new and amended energy 

conservation standards. The upper 

bound of the results estimates the 

maximum change in the number of 

production workers that could occur 

after compliance with new and 

amended energy conservation standards 

when assuming that manufacturers 

continue to produce the same scope of 

covered equipment in the same 

production facilities. It also assumes 

that domestic production does not shift 

to lower-labor-cost countries. Because 

there is a real risk of manufacturers 

evaluating sourcing decisions in 

response to new and amended energy 

conservation standards, the lower 

bound of the employment results 

includes the estimated total number of 

U.S. production workers in the industry 

who could lose their jobs if all existing 

production were moved outside of the 

U.S. While the results present a range of 

employment impacts following 2015, 

the sections below also include 

qualitative discussions of the likelihood 

of negative employment impacts at the 

various TSLs. Finally, the employment 

impacts shown are independent of the 

indirect employment impacts from the 

broader U.S. economy, which are 

documented in chapter 16 of the NOPR 

TSD. 

Based on 2011 ASM data and 

interviews with manufacturers, DOE 

estimates approximately 60 percent of 

electric motors sold in the U.S. are 

manufactured domestically. Using this 

assumption, DOE estimates that in the 

absence of new and amended energy 

conservation standards, there would be 

approximately 7,237 domestic 

production workers involved in 

manufacturing all electric motors 

covered by this rulemaking in 2015. The 

table below shows the range of potential 

impacts of new and amended energy 

conservation standards for all ECGs on 

U.S. production workers in the electric 

motor industry. However, because ECG 

1 motors comprise more than 97 percent 

of the electric motors covered by this 

rulemaking, DOE believes that potential 

changes in domestic employment will 

be driven primarily by the standards 

that are selected for ECG 1, Design A 

and B electric motors. 

TABLE V.12—POTENTIAL CHANGES IN THE TOTAL NUMBER OF ALL DOMESTIC ELECTRIC MOTOR PRODUCTION WORKERS

IN 2015 

Base case 

Trial standard level 

1 2 3 4 

Total Number of Domestic Production Workers in 2015 

(without changes in production locations) ...................... 7,237 7,270 7,420 8,287 15,883 

Potential Changes in Domestic Production Workers in 

2015 * ............................................................................. ...................... 33¥0 183¥(362) 1,050¥(3,619) 8,646¥(7,237) 

* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers. 

Most manufacturers agree that any 

standards that involve expanding the 

scope of equipment required to meet 

NEMA Premium would not significantly 

change domestic employment levels. At 

this efficiency level (TSL 2), 

manufacturers would not be required to 

make major modifications to their 

production lines nor would they have to 

undertake new manufacturing 

processes. A few small business 

manufacturers who primarily make 

electric motors currently out of the 

scope of coverage, but whose equipment 

would be covered by new electric motor 

standards, could be impacted by 

efficiency standards at TSL 2. These 

impacts, including employment 

impacts, are discussed in section VI.B of 

today’s NOPR. Overall, DOE believes 

there would not be a significant 

decrease in domestic employment levels 

at TSL 2. DOE created a lower bound of 

the potential loss of domestic 

employment at 362 employees for TSL 

2. DOE estimated only five percent of 

the electric motors market is comprised 

of manufacturers that do not currently 

produce any motors at NEMA Premium 

efficiency levels. DOE estimated that at 

most five percent of domestic electric 

motor manufacturing could potentially 

move abroad or exit the market entirely. 

DOE similarly estimated that all electric 

motor manufacturers produce some 

electric motors at or above TSL 1 

efficiency levels. Therefore, DOE does 

not believe that any potential loss of 

domestic employment would occur at 

TSL 1. 

Manufacturers, however, cautioned 

that any standard set above NEMA 

Premium would require major changes 

to production lines, large investments in 

capital and labor, and would result in 

extensive stranded assets. This is largely 

because manufacturers would have to 

design and build motors with larger 

frame sizes and could potentially have 

to use copper, rather than aluminum 

rotors. Several manufacturers pointed 

out that this would require extensive 

retooling, vast engineering resources, 

and would ultimately result in a more 

labor-intensive production process. 

Manufacturers generally agreed that a 

shift toward copper rotors would have 

uncertain impacts on energy efficiency 

and would cause companies to incur 

higher labor costs. These factors could 

cause manufacturers to consider moving 

production offshore to reduce labor 

costs or they may choose to exit the 

market entirely. Therefore, DOE believes 

it is more likely that efficiency 

standards set above NEMA Premium 

could result in a decrease of labor. 

Accordingly, DOE set the lower bound 

on the potential loss of domestic 

employment at 50 percent of the 

existing domestic labor market for TSL 

3 and 100 percent of the domestic labor 

market for TSL 4. However, these values 

represent the worst case scenario DOE 

modeled. Manufacturers also stated that 

larger motor manufacturing (that is for 

motors above 200 horsepower) would be 

very unlikely to move abroad since the 

shipping costs associated with those 

motors are very large. Consequently, 

DOE does not currently believe 

standards set at TSL 3 and TSL 4 would 

likely result in a large loss of domestic 

employment. 

c. Impacts on Manufacturing Capacity 

Most manufacturers agreed that any 

standard expanding the scope of 

equipment required to meet NEMA 

Premium would not have a significant 

impact on manufacturing capacity. 

Manufacturers pointed out, however, 

that a standard that required them to use 

copper rotors would severely disrupt 

manufacturing capacity. Most 

manufacturers emphasized they do not 

currently have the machinery, 

technology, or engineering resources to 

produce copper rotors in-house. Some 

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manufacturers claim that the few 

manufacturers that do have the 

capability of producing copper rotors 

are not able to produce these motors in 

volumes sufficient to meet the demands 

of their customers. For manufacturers to 

either completely redesign their motor 

production lines or significantly expand 

their fairly limited copper rotor 

production line would require a massive 

retooling and engineering effort, which 

could take several years to complete. 

Most manufacturers stated they would 

have to outsource copper rotor 

production because they would not be 

able to modify their facilities and 

production processes to produce copper 

rotors in-house within a three year time 

period. Most manufacturers agreed that 

outsourcing rotor die casting would 

constrain capacity by creating a 

bottleneck in rotor production, as there 

are very few companies that produce 

copper rotors. 

Manufacturers also pointed out that 

there is substantial uncertainty 

surrounding the global availability and 

price of copper, which has the potential 

to constrain capacity. Several 

manufacturers expressed concern that 

the combination of all of these factors 

would make it difficult to support 

existing business while redesigning 

product lines and retooling. The need to 

support existing business would also 

cause the redesign effort to take several 

years. 

In summary, for those TSLs that 

require copper rotors, DOE believes 

there is a likelihood of capacity 

constraints in the near term due to 

fluctuations in the copper market and 

limited copper die casting machinery 

and expertise. However, for the levels 

proposed in this rule, DOE does not 

foresee any capacity constraints. 

d. Impacts on Sub-Group of 

Manufacturers 

Using average cost assumptions to 

develop an industry cash-flow estimate 

may not be adequate for assessing 

differential impacts among 

manufacturer subgroups. Small 

manufacturers, niche equipment 

manufacturers, and manufacturers 

exhibiting cost structures substantially 

different from the industry average 

could be affected disproportionately. 

DOE analyzed the impacts to small 

businesses in section VI.B and did not 

identify any other adversely impacted 

electric motor-related subgroups for this 

rulemaking based on the results of the 

industry characterization. 

e. Cumulative Regulatory Burden 

While any one regulation may not 

impose a significant burden on 

manufacturers, the combined effects of 

recent or impending regulations may 

have serious consequences for some 

manufacturers, groups of manufacturers, 

or an entire industry. Assessing the 

impact of a single regulation may 

overlook this cumulative regulatory 

burden. In addition to energy 

conservation standards, other 

regulations can significantly affect 

manufacturers’ financial operations. 

Multiple regulations affecting the same 

manufacturer can strain profits and lead 

companies to abandon product lines or 

markets with lower expected future 

returns than competing equipment. For 

these reasons, DOE conducts an analysis 

of cumulative regulatory burden as part 

of its rulemakings pertaining to 

appliance efficiency. 

During previous stages of this 

rulemaking, DOE identified a number of 

requirements, in addition to new and 

amended energy conservation standards 

for electric motors, that manufacturers 

will face for equipment they 

manufacture approximately three years 

prior to and three years after the 

compliance date of the new and 

amended standards. The following 

section briefly addresses comments DOE 

received with respect to cumulative 

regulatory burden and summarizes other 

key related concerns that manufacturers 

raised during interviews. 

Several manufacturers expressed 

concern about the compliance date of 

this rulemaking to the proximity of the 

2015 compliance date for the small 

electric motors rulemaking at 75 FR 

10874 (March 9, 2010). Most 

manufacturers of electric motors 

covered by this rulemaking also produce 

electric motors that are covered by the 

small electric motors rulemaking. 

Manufacturers stated that adopting 

these two regulations in a potentially 

short timeframe could strain R&D and 

capital expenditure budgets for motor 

manufacturers. Some manufacturers 

also raised concerns about other existing 

regulations separate from DOE’s energy 

conservation standards that electric 

motors must meet: the National Fire 

Protection Association (NFPA) 70, 

National Electric Code; the NFPA 20, 

Standard for the Installation of 

Stationary Pumps for Fire Protection; 

and Occupational Safety and Health 

Administration (OSHA) regulations. 

DOE discusses these and other 

requirements in chapter 12 of the NOPR 

TSD. DOE takes into account the cost of 

compliance with other published 

Federal energy conservation standards 

in weighing the benefits and burdens of 

today’s proposed rulemaking. In the 

2010 small motors final rule, DOE 

estimated that manufacturers may lose 

up to 11.3 percent of their INPV, which 

was approximately $39.5 million, in 

2009$. To see the range of impacts DOE 

estimated for the small motors rule, see 

chapter 12 of the NOPR TSD. DOE does 

not describe the quantitative impacts of 

standards that have not yet been 

finalized because any impacts would be 

highly speculative. DOE also notes that 

certain standards are optional for 

manufacturers and takes that into 

account when creating the cumulative 

regulatory burden analysis. 

3. National Impact Analysis 

a. Significance of Energy Savings 

For each TSL, DOE projected energy 

savings for electric motors purchased in 

the 30-year period that begins in the 

year of compliance with new and 

amended standards (2015–2044). The 

savings are measured over the entire 

lifetime of equipment purchased in the 

30-year period. DOE quantified the 

energy savings attributable to each TSL 

as the difference in energy consumption 

between each standards case and the 

base case. Table V.13 presents the 

estimated primary energy savings for 

each considered TSL, and Table V.14 

presents the estimated FFC energy 

savings for each considered TSL. The 

approach for estimating national energy 

savings is further described in section 

IV.H. 

TABLE V.13—CUMULATIVE PRIMARY ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR UNITS

SOLD IN 2015–2044 

Equipment class 

Trial standard level 

1 2 3 4 

quads 

Group 1 (NEMA Design A and B) ........................................................................................................... 0.82 6.27 9.86 12.64 

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87EPCA requires DOE to review its standards at 

least once every 6 years, and requires, for certain 

products, a 3-year period after any new standard is 

promulgated before compliance is required, except 

that in no case may any new standards be required 

within 6 years of the compliance date of the 

previous standards. While adding a 6-year review 

to the 3-year compliance period adds up to 9 years, 

DOE notes that it may undertake reviews at any 

time within the 6 year period and that the 3-year 

compliance date may yield to the 6-year backstop. 

A 9-year analysis period may not be appropriate 

given the variability that occurs in the timing of 

standards reviews and the fact that for some 

consumer products, the compliance period is 5 

years rather than 3 years. 

88OMB Circular A–4, section E (Sept. 17, 2003). 

http://www.whitehouse.gov/omb/circulars_a004_a– 

4. 

TABLE V.13—CUMULATIVE PRIMARY ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR UNITS

SOLD IN 2015–2044—Continued 

Equipment class 

Trial standard level 

1 2 3 4 

Group 2 (NEMA Design C) ...................................................................................................................... 0.02 0.02 0.03 0.03 

Group 3 (Fire Pump Electric Motors) ...................................................................................................... 0.00 0.00 0.00 0.00 

Group 4 (Brake Motors) ........................................................................................................................... 0.26 0.58 0.71 0.81 

Total All Classes ............................................................................................................................... 1.10 6.87 10.60 13.49 

TABLE V.14—CUMULATIVE FULL-FUEL-CYCLE ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR

UNITS SOLD IN 2015–2044 

Equipment class 

Trial standard level 

1 2 3 4 

quads 

Group 1 (NEMA Design A and B) ........................................................................................................... 0.83 6.38 10.02 12.85 

Group 2 (NEMA Design C) ...................................................................................................................... 0.02 0.02 0.03 0.03 

Group 3 (Fire Pump Electric Motors) ...................................................................................................... 0.00 0.00 0.00 0.00 

Group 4 (Brake Motors) ........................................................................................................................... 0.26 0.59 0.73 0.83 

Total All Classes ............................................................................................................................... 1.11 6.98 10.78 13.71 

Circular A–4 requires agencies to 

present analytical results, including 

separate schedules of the monetized 

benefits and costs that show the type 

and timing of benefits and costs. 

Circular A–4 also directs agencies to 

consider the variability of key elements 

underlying the estimates of benefits and 

costs. For this rulemaking, DOE 

undertook a sensitivity analysis using 

nine rather than 30 years of equipment 

shipments. The choice of a nine-year 

period is a proxy for the timeline in 

EPCA for the review of certain energy 

conservation standards and potential 

revision of and compliance with such 

revised standards.87 We would note that 

the review timeframe established in 

EPCA generally does not overlap with 

the equipment lifetime, equipment 

manufacturing cycles or other factors 

specific to electric motors. Thus, this 

information is presented for 

informational purposes only and is not 

indicative of any change in DOE’s 

analytical methodology. The NES 

results based on a 9-year analytical 

period are presented in Table V.15. The 

impacts are counted over the lifetime of 

electric motors purchased in 2015–2023. 

TABLE V.15—CUMULATIVE NATIONAL ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR UNITS

SOLD IN 2015–2023 

Equipment class 

Trial standard level 

1 2 3 4 

quads 

Group 1 (NEMA Design A and B) ........................................................................................................... 0.355 1.440 2.168 2.833 

Group 2 (NEMA Design C) ...................................................................................................................... 0.004 0.004 0.006 0.006 

Group 3 (Fire Pump Electric Motors) ...................................................................................................... 0.000 0.000 0.000 0.000 

Group 4 (Brake Motors) ........................................................................................................................... 0.060 0.125 0.152 0.176 

Total All Classes ............................................................................................................................... 0.420 1,569 2.326 3.015 

b. Net Present Value of Customer Costs 

and Benefits 

DOE estimated the cumulative NPV of 

the total costs and savings for customers 

that would result from the TSLs 

considered for electric motors. In 

accordance with OMB’s guidelines on 

regulatory analysis,88 DOE calculated 

the NPV using both a 7-percent and a 3- 

percent real discount rate. The 7-percent 

rate is an estimate of the average beforetax rate of return on private capital in 

the U.S. economy, and reflects the 

returns on real estate and small business 

capital as well as corporate capital. This 

discount rate approximates the 

opportunity cost of capital in the private 

sector (OMB analysis has found the 

average rate of return on capital to be 

near this rate). The 3-percent rate 

reflects the potential effects of standards 

on private consumption (e.g., through 

higher prices for equipment and 

reduced purchases of energy). This rate 

represents the rate at which society 

discounts future consumption flows to 

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their present value. It can be 

approximated by the real rate of return 

on long-term government debt (i.e., 

yield on United States Treasury notes), 

which has averaged about 3 percent for 

the past 30 years. 

Table V.16 shows the customer NPV 

results for each TSL considered for 

electric motors. In each case, the 

impacts cover the lifetime of equipment 

purchased in 2015–2044. 

TABLE V.16—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR

UNITS SOLD IN 2015–2044 

[Billion 2012$] 

Equipment class Discount 

rate % 

Trial standard level 

1 2 3 4 

Group 1 (NEMA Design A and B) ..................................................................... 4.5 20.7 1.5 ¥41.2 

Group 2 (NEMA Design C) ................................................................................ 0.0 0.0 0.0 0.0 

Group 3 (Fire Pump Electric Motors) ................................................................ 3 0.0 0.0 0.0 0.0 

Group 4 (Brake Motors) ..................................................................................... 1.3 2.5 1.5 ¥1.2 

Total All Classes ......................................................................................... 5.8 23.3 3.0 ¥42.4 

Group 1 (NEMA Design A and B) ..................................................................... 2.2 7.7 ¥3.7 ¥29.1 

Group 2 (NEMA Design C) ................................................................................ 0.0 0.0 0.0 0.0 

Group 3 (Fire Pump Electric Motors) ................................................................ 7 0.0 0.0 0.0 0.0 

Group 4 (Brake Motors) ..................................................................................... 0.5 1.0 0.3 ¥1.2 

Total All Classes ......................................................................................... 2.7 8.7 ¥3.4 ¥30.3 

The NPV results based on the aforementioned 9-year analytical period are 

presented in Table V.17. The impacts 

are counted over the lifetime of 

equipment purchased in 2015–2023. As 

mentioned previously, this information 

is presented for informational purposes 

only and is not indicative of any change 

in DOE’s analytical methodology or 

decision criteria. 

TABLE V.17—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR

UNITS SOLD IN 2015–2023 

[Billion 2012$] 

Equipment class Discount 

rate % 

Trial standard level 

1 2 3 4 

Group 1 (NEMA Design A and B) ..................................................................... 2.253 6.473 2.541 ¥12.055 

Group 2 (NEMA Design C) ................................................................................ 0.011 0.011 ¥0.012 ¥0.012 

Group 3 (Fire Pump Electric Motors) ................................................................ 3 0.000 0.000 ¥0.001 ¥0.009 

Group 4 (Brake Motors) ..................................................................................... 0.389 0.706 0.495 ¥0.372 

Total All Classes ......................................................................................... 2.654 7.190 3.023 ¥12.448 

Group 1 (NEMA Design A and B) ..................................................................... 1.344 3.492 ¥0.102 ¥12.017 

Group 2 (NEMA Design C) ................................................................................ 0.005 0.005 ¥0.016 ¥0.016 

Group 3 (Fire Pump Electric Motors) ................................................................ 7 0.000 0.000 ¥0.001 ¥0.007 

Group 4 (Brake Motors) ..................................................................................... 0.225 0.391 0.201 ¥0.498 

Total All Classes ......................................................................................... 1.574 3.887 0.083 ¥12.537 

c. Indirect Impacts on Employment 

DOE expects energy conservation 

standards for electric motors to reduce 

energy costs for equipment owners, and 

the resulting net savings to be redirected 

to other forms of economic activity. 

Those shifts in spending and economic 

activity could affect the demand for 

labor. As described in section IV.N, DOE 

used an input/output model of the U.S. 

economy to estimate indirect 

employment impacts of the TSLs that 

DOE considered in this rulemaking. 

DOE understands that there are 

uncertainties involved in projecting 

employment impacts, especially 

changes in the later years of the 

analysis. Therefore, DOE generated 

results for near-term time frames (2015– 

2019), where these uncertainties are 

reduced. 

The results suggest that today’s 

standards are likely to have negligible 

impact on the net demand for labor in 

the economy. The net change in jobs is 

so small that it would be imperceptible 

in national labor statistics and might be 

offset by other, unanticipated effects on 

employment. Chapter 16 of the NOPR 

TSD presents detailed results. 

4. Impact on Utility or Performance 

DOE believes that the standards it is 

proposing today will not lessen the 

utility or performance of electric motors. 

5. Impact of Any Lessening of 

Competition 

DOE has also considered any 

lessening of competition that is likely to 

result from new and amended 

standards. The Attorney General 

determines the impact, if any, of any 

lessening of competition likely to result 

from a proposed standard, and transmits 

such determination to the Secretary, 

together with an analysis of the nature 

and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) 

To assist the Attorney General in 

making such determination, DOE will 

provide DOJ with copies of this NOPR 

and the TSD for review. DOE will 

consider DOJ’s comments on the 

proposed rule in preparing the final 

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rule, and DOE will publish and respond 

to DOJ’s comments in that document. 

6. Need of the Nation To Conserve 

Energy 

Enhanced energy efficiency, where 

economically justified, improves the 

Nation’s energy security, strengthens the 

economy, and reduces the 

environmental impacts or costs of 

energy production. Reduced electricity 

demand due to energy conservation 

standards is also likely to reduce the 

cost of maintaining the reliability of the 

electricity system, particularly during 

peak-load periods. As a measure of this 

reduced demand, chapter 15 in the 

NOPR TSD presents the estimated 

reduction in generating capacity in 2044 

for the TSLs that DOE considered in this 

rulemaking. 

Energy savings from standards for 

electric motors could also produce 

environmental benefits in the form of 

reduced emissions of air pollutants and 

greenhouse gases associated with 

electricity production. Table V.18 

provides DOE’s estimate of cumulative 

emissions reductions projected to result 

from the TSLs considered in this 

rulemaking. DOE reports annual 

emissions reductions for each TSL in 

chapter 13 of the NOPR TSD. 

TABLE V.18—CUMULATIVE EMISSIONS REDUCTION ESTIMATED FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS

Trial standard level 

1 2 3 4 

Primary Energy Emissions 

CO2 (million metric tons) .......................................................................................................... 62.4 374.1 576.0 733.3 

NOX (thousand tons) ............................................................................................................... 105.3 669.7 1,034.7 1,315.5 

SO2 (thousand tons) ................................................................................................................ 33.5 196.3 301.9 384.5 

Hg (tons) .................................................................................................................................. 0.1 0.8 1.3 1.6 

N2O (thousand tons) ................................................................................................................ 1.2 8.3 12.9 16.4 

CH4 (thousand tons) ................................................................................................................ 7.3 46.3 71.6 91.0 

Upstream Emissions 

CO2 (million metric tons) .......................................................................................................... 3.5 22.0 34.0 43.2 

NOX (thousand tons) ............................................................................................................... 0.8 4.7 7.3 9.3 

SO2 (thousand tons) ................................................................................................................ 48.6 303.1 467.8 595.0 

Hg (tons) .................................................................................................................................. 0.0 0.0 0.0 0.0 

N2O (thousand tons) ................................................................................................................ 0.0 0.2 0.3 0.4 

CH4 (thousand tons) ................................................................................................................ 294.8 1,841.4 2,841.9 3,614.6 

Total Emissions 

CO2 (million metric tons) .......................................................................................................... 65.9 396.1 610.0 776.5 

NOX (thousand tons) ............................................................................................................... 106.0 674.4 1,042.0 1,324.8 

SO2 (thousand tons) ................................................................................................................ 82.1 499.4 769.6 979.5 

Hg (tons) .................................................................................................................................. 0.1 0.8 1.3 1.6 

N2O (thousand tons) ................................................................................................................ 1.3 8.5 13.2 16.8 

CH4 (thousand tons) ................................................................................................................ 302.2 1,887.7 2,913.5 3,705.5 

As part of the analysis for this rule, 

DOE estimated monetary benefits likely 

to result from the reduced emissions of 

CO2 and NOX that DOE estimated for 

each of the TSLs considered. As 

discussed in section IV.L, DOE used 

values for the SCC developed by an 

interagency process. The four sets of 

SCC values resulting from that process 

(expressed in 2012$) are represented by 

$12.9/metric ton (the average value from 

a distribution that uses a 5-percent 

discount rate), $40.8/metric ton (the 

average value from a distribution that 

uses a 3-percent discount rate), $62.2/

metric ton (the average value from a 

distribution that uses a 2.5-percent 

discount rate), and $117.0/metric ton 

(the 95th-percentile value from a 

distribution that uses a 3-percent 

discount rate). These values correspond 

to the value of emission reductions in 

2015; the values for later years are 

higher due to increasing damages as the 

projected magnitude of climate change 

increases. 

Table V.19 presents the global value 

of CO2 emissions reductions at each 

TSL. For each of the four cases, DOE 

calculated a present value of the stream 

of annual values using the same 

discount rate as was used in the studies 

upon which the dollar-per-ton values 

are based. DOE calculated domestic 

values as a range from 7 percent to 23 

percent of the global values, and these 

results are presented in chapter 14 of 

the NOPR TSD. 

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TABLE V.19—ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER ELECTRIC MOTORS TRIAL

STANDARD LEVELS

[Million 2012$] 

TSL 

SCC Case * 

5% discount 

rate, 

average * 

3% discount 

rate, 

average * 

2.5% discount 

rate, 

average * 

3% discount 

rate, 95th 

percentile * 

Primary Energy Emissions 

1 ....................................................................................................................... 433 1,961 3,113 6,040 

2 ....................................................................................................................... 2,366 11,179 17,876 34,552 

3 ....................................................................................................................... 3,622 17,159 27,452 53,047 

4 ....................................................................................................................... 4,622 21,871 34,985 67,609 

Upstream Emissions 

1 ....................................................................................................................... 24 110 174 338 

2 ....................................................................................................................... 136 650 1,042 2,012 

3 ....................................................................................................................... 209 1,001 1,604 3,097 

4 ....................................................................................................................... 266 1,274 2,042 3,943 

Total Emissions 

1 ....................................................................................................................... 457 2,071 3,287 6,378 

2 ....................................................................................................................... 2,502 11,829 18,918 36,564 

3 ....................................................................................................................... 3,831 18,159 29,056 56,143 

4 ....................................................................................................................... 4,888 23,145 37,027 71,552 

*For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and $117.0 per metric ton (2012$). 

DOE is well aware that scientific and 

economic knowledge about the 

contribution of CO2 and other 

greenhouse gas (GHG) emissions to 

changes in the future global climate and 

the potential resulting damages to the 

world economy continues to evolve 

rapidly. Thus, any value placed on 

reducing CO2 emissions in this 

rulemaking is subject to change. DOE, 

together with other Federal agencies, 

will continue to review various 

methodologies for estimating the 

monetary value of reductions in CO2

and other GHG emissions. This ongoing 

review will consider the comments on 

this subject that are part of the public 

record for this and other rulemakings, as 

well as other methodological 

assumptions and issues. However, 

consistent with DOE’s legal obligations, 

and taking into account the uncertainty 

involved with this particular issue, DOE 

has included in this proposed rule the 

most recent values and analyses 

resulting from the ongoing interagency 

review process. 

DOE also estimated a range for the 

cumulative monetary value of the 

economic benefits associated with NOX

emissions reductions anticipated to 

result from new and amended standards 

for electric motors. The low and high 

dollar-per-ton values that DOE used are 

discussed in section IV.L present the 

cumulative present values for each TSL 

calculated using seven-percent and 

three-percent discount rates. 

TABLE V.20—ESTIMATES OF PRESENT

VALUE OF NOX EMISSIONS REDUCTION UNDER ELECTRIC MOTORS

TRIAL STANDARD LEVELS

[Million 2012$] 

TSL 3% discount 

rate 

7% discount 

rate 

Power Sector Emissions 

1 ................ 49.5 26.4 

2 ................ 257.1 120.2 

3 ................ 392.2 181.6 

4 ................ 501.3 233.2 

Upstream Emissions 

1 ................ 68.0 33.8 

2 ................ 378.4 164.8 

3 ................ 579.9 250.3 

4 ................ 739.7 320.6 

Total Emissions 

1 ................ 117.5 60.2 

2 ................ 635.4 285.0 

3 ................ 972.2 432.0 

TABLE V.20—ESTIMATES OF PRESENT

VALUE OF NOX EMISSIONS REDUCTION UNDER ELECTRIC MOTORS

TRIAL STANDARD LEVELS—Continued 

[Million 2012$] 

TSL 3% discount 

rate 

7% discount 

rate 

4 ................ 1,241.0 553.8 

7. Summary of National Economic 

Impacts 

The NPV of the monetized benefits 

associated with emissions reductions 

can be viewed as a complement to the 

NPV of the customer savings calculated 

for each TSL considered in this 

rulemaking. Table V.21 presents the 

NPV values that result from adding the 

estimates of the potential economic 

benefits resulting from reduced CO2 and 

NOX emissions in each of four valuation 

scenarios to the NPV of customer 

savings calculated for each TSL 

considered in this rulemaking, at both a 

seven-percent and three-percent 

discount rate. The CO2 values used in 

the columns of each table correspond to 

the four sets of SCC values discussed 

above. 

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TABLE V.21—NET PRESENT VALUE OF CUSTOMER SAVINGS COMBINED WITH NET PRESENT VALUE OF MONETIZED

BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS

[Billion 2012$] 

TSL 

SCC Case 

$11.8/metric 

ton CO2* and 

low value 

for NOX** 

SCC Case 

$39.7/metric 

ton CO2* and 

medium value 

for NOX** 

SCC Case 

$61.2/metric 

ton CO2* and 

medium value 

for NOX** 

SCC Case 

$117.0/metric 

ton CO2* and 

high value 

for NOX** 

Customer NPV at 3% discount rate added with: 

1 ....................................................................................................... 6.3 8.0 9.2 12.4 

2 ....................................................................................................... 25.9 35.7 42.8 61.0 

3 ....................................................................................................... 7.0 22.1 33.0 60.9 

4 ....................................................................................................... ¥37.3 ¥18.0 ¥4.1 31.4 

Customer NPV at 7% discount rate added with: 

1 ....................................................................................................... 3.2 4.8 6.1 9.2 

2 ....................................................................................................... 11.2 20.8 27.9 45.7 

3 ....................................................................................................... 0.5 15.2 26.1 53.5 

4 ....................................................................................................... ¥25.3 ¥6.6 7.3 42.3 

* These label values represent the global SCC in 2015, in 2012$. 

** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton, and High Value corresponds to 

$4,809 per ton. 

Although adding the value of 

customer savings to the values of 

emission reductions provides a valuable 

perspective, two issues should be 

considered. First, the national operating 

cost savings are domestic U.S. customer 

monetary savings that occur as a result 

of market transactions, while the value 

of CO2 reductions is based on a global 

value. Second, the assessments of 

operating cost savings and the SCC are 

performed with different methods that 

use quite different time frames for 

analysis. The national operating cost 

savings is measured for the lifetime of 

equipment shipped in 2015–2044. The 

SCC values, on the other hand, reflect 

the present value of future climaterelated impacts resulting from the 

emission of one metric ton of CO2 in 

each year. These impacts continue well 

beyond 2100. 

8. Other Factors 

The Secretary of Energy, in 

determining whether a standard is 

economically justified, may consider 

any other factors that the Secretary 

deems to be relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(VI)) No other factors 

were considered in this analysis. 

C. Proposed Standards 

When considering proposed 

standards, the new or amended energy 

conservation standard that DOE adopts 

for any type (or class) of covered 

equipment shall be designed to achieve 

the maximum improvement in energy 

efficiency that the Secretary of Energy 

determines is technologically feasible 

and economically justified. (42 U.S.C. 

6295(o)(2)(A) and 6316(a)) In 

determining whether a standard is 

economically justified, the Secretary 

must determine whether the benefits of 

the standard exceed its burdens to the 

greatest extent practicable, considering 

the seven statutory factors discussed 

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

and 6316(a)) The new or amended 

standard must also ‘‘result in significant 

conservation of energy.’’ (42 U.S.C. 

6295(o)(3)(B) and 6316(a)) 

For today’s NOPR, DOE considered 

the impacts of standards at each TSL, 

beginning with the max-tech level, to 

determine whether that level was 

economically justified. Where the maxtech level was not justified, DOE then 

considered the next most efficient level 

and undertook the same evaluation until 

it reached the highest efficiency level 

that is technologically feasible, 

economically justified and saves a 

significant amount of energy. 

Throughout this process DOE also 

considered the recommendations made 

by the Motors Coalition and other 

stakeholders in their submitted 

comments. For more details on the 

Motors Coalition see Section II.B.2. 

To aid the reader in understanding 

the benefits and/or burdens of each TSL, 

tables in this section summarize the 

quantitative analytical results for each 

TSL, based on the assumptions and 

methodology discussed herein. The 

efficiency levels contained in each TSL 

are described in section V.A. In addition 

to the quantitative results presented in 

the tables, DOE also considers other 

burdens and benefits that affect 

economic justification. These include 

the impacts on identifiable subgroups of 

customers who may be 

disproportionately affected by a national 

standard, and impacts on employment. 

Section V.B.1.b presents the estimated 

impacts of each TSL for the considered 

subgroup. DOE discusses the impacts on 

employment in electric motor 

manufacturing in section V.B.2.b, and 

discusses the indirect employment 

impacts in section V.B.3.c. 

1. Benefits and Burdens of Trial 

Standard Levels Considered for Electric 

Motors 

Table V.22 and Table V.23 summarize 

the quantitative impacts estimated for 

each TSL for electric motors. 

TABLE V.22—SUMMARY OF ANALYTICAL RESULTS FOR ELECTRIC MOTORS: NATIONAL IMPACTS

Category TSL 1 TSL 2 TSL 3 TSL 4 

National Full-Fuel-Cycle Energy Savings 

quads: 

1.1 ............................. 7.0 ............................. 10.8 ........................... 13.7 

NPV of Consumer Benefits 2012$ billion: 

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TABLE V.22—SUMMARY OF ANALYTICAL RESULTS FOR ELECTRIC MOTORS: NATIONAL IMPACTS—Continued 

Category TSL 1 TSL 2 TSL 3 TSL 4 

3% discount rate .......................................... 5.8 ............................. 23.3 ........................... 3.0 ............................. ¥42.4 

7% discount rate .......................................... 2.7 ............................. 8.7 ............................. ¥3.4 ......................... ¥30.3 

Cumulative Emissions Reduction (Total FFC 

Emissions): 

CO2 million metric tons ................................ 65.9 ........................... 396.1 ......................... 610.0 ......................... 776.5 

SO2 thousand tons ....................................... 106.0 ......................... 674.4 ......................... 1,042.0 ...................... 1,324.8 

NOX thousand tons ...................................... 82.1 ........................... 499.4 ......................... 769.6 ......................... 979.5 

Hg tons ......................................................... 0.1 ............................. 0.8 ............................. 1.3 ............................. 1.6 

N2O thousand tons ....................................... 1.3 ............................. 8.5 ............................. 13.2 ........................... 16.8 

CH4 thousand tons ....................................... 302.2 ......................... 1,887.7 ...................... 2,913.5 ...................... 3,705.5 

Value of Emissions Reduction (Total FFC 

Emissions): 

CO2 2012$ million* ....................................... 457 to 6,378 ............. 2,502 to 36,564 ........ 3,831 to 56,143 ........ 4,888 to 71,552 

NOX—3% discount rate 2012$ million ......... 117.5 ......................... 635.4 ......................... 972.2 ......................... 1,241.0 

NOX—7% discount rate 2012$ million ................ 60.2 ........................... 285.0 ......................... 432.0 ......................... 553.8 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. 

TABLE V.23—SUMMARY OF ANALYTICAL RESULTS FOR ELECTRIC MOTORS: MANUFACTURER AND CONSUMER IMPACTS

Category TSL 1 TSL 2 TSL 3 TSL 4 

Manufacturer Impacts: 

Industry NPV 2012$ million ...................................................................... 3,378.7– 

3,019.5 

3,759.2– 

3,087.6 

4,443.7– 

2,356.8 

5,241.3– 

1,383.1 

Industry NPV % change ........................................................................... 0.2–(10.4) 11.5–(8.4) 31.8–(30.1) 55.5–(59.0) 

Consumer Mean LCC Savings * 2012$: 

Equipment Class Group 1 ........................................................................ 43 132 68 ¥417 

Equipment Class Group 2 ........................................................................ 38 38 ¥285 ¥285 

Equipment Class Group 3 ........................................................................ N/A ** N/A ** ¥61 ¥763 

Equipment Class Group 4 ........................................................................ 137 259 210 ¥291 

Consumer Median PBP* years: 

Equipment Class Group 1 ........................................................................ 1.1 3.3 6.7 29.9 

Equipment Class Group 2 ........................................................................ 5.0 5.0 22.8 22.8 

Equipment Class Group 3 ........................................................................ N/A ** N/A ** 3,299 11,957 

Equipment Class Group 4 ........................................................................ 1.2 1.9 3.7 16.0 

Equipment Class Group 1: 

Net Cost % ............................................................................................... 0.3 8.4 38.0 84.6 

Net Benefit % ........................................................................................... 9.7 32.0 40.4 7.6 

No Impact % ............................................................................................. 90.0 59.6 21.5 7.7 

Equipment Class Group 2: 

Net Cost % ............................................................................................... 21.5 21.5 94.7 94.7 

Net Benefit % ........................................................................................... 68.6 68.6 5.3 5.3 

No Impact % ............................................................................................. 9.9 9.9 0.0 0.0 

Equipment Class Group 3: 

Net Cost (%) ............................................................................................. 0.0 0.0 81.7 100.0 

Net Benefit (%) ......................................................................................... 0.0 0.0 0.0 0.0 

No Impact (%) .......................................................................................... 0.0 0.0 18.3 0.0 

Equipment Class Group 4: 

Net Cost (%) ............................................................................................. 1.0 10.8 33.1 79.6 

Net Benefit (%) ......................................................................................... 31.8 60.8 65.8 19.9 

No Impact (%) .......................................................................................... 67.3 28.4 1.1 0.3 

** The results for each equipment class group (ECG) are a shipment weighted average of results for the representative units in the group. ECG 

1: Representative units 1, 2, and 3; ECG 2: Representative units 4 and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units 

9 and 10. 

** For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected. 

First, DOE considered TSL 4, the most 

efficient level (max tech), which would 

save an estimated total of 13.7 quads of 

energy, an amount DOE considers 

significant. TSL 4 has an estimated NPV 

of customer benefit of ¥30.3 billion 

using a 7 percent discount rate, and 

¥42.4 billion using a 3 percent discount 

rate. 

The cumulative emissions reductions 

at TSL 4 are 776.5 million metric tons 

of CO2, 979.5 thousand tons of NOX, 

1,324.8 thousand tons of SO2, and 1.6 

tons of Hg. The estimated monetary 

value of the CO2 emissions reductions at 

TSL 4 ranges from $4,888 million to 

$71,552 million. 

At TSL 4, the weighted average LCC 

impact ranges from $¥763 for ECG 3 to 

$¥285 for ECG 2. The weighted average 

median PBP ranges from 16 years for 

ECG 4 to 11,957 years for ECG 3. The 

weighted average share of customers 

experiencing a net LCC benefit ranges 

from 0 percent for ECG 3 to 19.9 percent 

for ECG 4. 

At TSL 4, the projected change in 

INPV ranges from a decrease of $1,988.1 

million to an increase of $1,870.1 

million. If the decrease of $1,988.1 

million were to occur, TSL 4 could 

result in a net loss of 59 percent in INPV 

to manufacturers of covered electric 

motors. 

In view of the foregoing, DOE 

concludes that, at TSL 4 for electric 

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motors, the benefits of energy savings, 

emission reductions, and the estimated 

monetary value of the emissions 

reductions would be outweighed by the 

potential multi-billion dollar negative 

net economic cost; the economic burden 

on customers as indicated by the 

increase in customer LCC (negative 

savings), large PBPs, the large 

percentage of customers who would 

experience LCC increases; the increase 

in the cumulative regulatory burden on 

manufacturers; and the capital and 

engineering costs that could result in a 

large reduction in INPV for 

manufacturers at TSL 4. Additionally, 

DOE believes that efficiency standards 

at this level, could result in significant 

impacts on OEMs due to larger and 

faster motors. Although DOE has not 

quantified these potential impacts, DOE 

believes that it is possible that these 

impacts could be significant and further 

reduce any potential benefits of 

standards established at this TSL. 

Consequently, DOE has concluded that 

TSL 4 is not economically justified. 

Next, DOE considered TSL 3, which 

would save an estimated total of 10.6 

quads of energy, an amount DOE 

considers significant. TSL 3 has an 

estimated NPV of customer benefit of 

$¥3.4 billion using a 7 percent discount 

rate, and $3.0 billion using a 3 percent 

discount rate. 

The cumulative emissions reductions 

at TSL 3 are 610.0 million metric tons 

of CO2, 769.6 thousand tons of NOX, 

1,042.0 thousand tons of SO2, and 1.3 

tons of Hg. The estimated monetary 

value of the CO2 emissions reductions at 

TSL 4 ranges from $3,831 million to $ 

56,143 million. 

At TSL 3, the weighted average LCC 

impact ranges from $¥285 for ECG 2 to 

$210 for ECG 4. The weighted average 

median PBP ranges from 3.7 years for 

ECG 4 to 3,299 years for ECG 3. The 

share of customers experiencing a net 

LCC benefit ranges from 0 percent for 

ECG 3 to 65.8 percent for ECG 4. 

At TSL 3, the projected change in 

INPV ranges from a decrease of $1,014,4 

million to an increase of $1,072.5 

million. If the decrease of $1,014.4 

million were to occur, TSL 3 could 

result in a net loss of 30.1 percent in 

INPV to manufacturers of covered 

electric motors. 

In view of the foregoing, DOE 

concludes that, at TSL 3 for electric 

motors, the benefits of energy savings, 

positive weighted average customer LCC 

savings for some ECGs, generating 

capacity reductions, emission 

reductions, and the estimated monetary 

value of the emissions reductions would 

be outweighed by the potential negative 

net economic cost; the economic burden 

on customers as indicated by the 

increase in weighted average LCC for 

some ECGs (negative savings), large 

PBPs, the large percentage of customers 

who would experience LCC increases; 

the increase in the cumulative 

regulatory burden on manufacturers; 

and the capital and engineering costs 

that could result in a large reduction in 

INPV for manufacturers at TSL 3. 

Additionally, DOE believes that 

efficiency standards at this level could 

result in significant impacts on OEMs 

due to larger and faster motors. 

Although DOE has not quantified these 

potential impacts, DOE believes that it 

is possible that these impacts could be 

significant and further reduce any 

potential benefits of standards 

established at this TSL. Consequently, 

DOE has concluded that TSL 3 is not 

economically justified. 

Next, DOE considered TSL 2, which 

would save an estimated total of 7.0 

quads of energy, an amount DOE 

considers significant. TSL 2 has an 

estimated NPV of customer benefit of 

$8.7 billion using a 7 percent discount 

rate, and $23.3 billion using a 3 percent 

discount rate. 

The cumulative emissions reductions 

at TSL 2 are 396.1 million metric tons 

of CO2, 674.4 thousand tons of NOX, 

499.4 thousand tons of SO2, and 0.8 tons 

of Hg. The estimated monetary value of 

the CO2 emissions reductions at TSL 4 

ranges from $2,502 million to $36,564 

million. 

At TSL 2, the weighted average LCC 

impact ranges from no impacts for ECG 

3 to $259 for ECG 4. The weighted 

average median PBP ranges from 0 years 

for ECG 3 to 5 years for ECG 2. The 

share of customers experiencing a net 

LCC benefit ranges from 0 percent for 

ECG 3 to 68.6 percent for ECG 2. The 

share of motors already at TSL 2 

efficiency levels varies by equipment 

class group and by horsepower range 

(from 0 to 62 percent). For ECG 1, which 

represents the most significant share of 

the market, about 30 percent of motors 

meet the TSL 2 levels. 

At TSL 2, the projected change in 

INPV ranges from a decrease of $283.5 

million to an increase of $388 million. 

If the decrease of $283.5 million were to 

occur, TSL 2 could result in a net loss 

of 8.4 percent in INPV to manufacturers 

of covered electric motors. 

After considering the analysis and 

weighing the benefits and the burdens, 

DOE has tentatively concluded that at 

TSL 2 for electric motors, the benefits of 

energy savings, positive NPV of 

customer benefit, positive impacts on 

consumers (as indicated by positive 

weighted average LCC savings for all 

ECGs impacted at TSL 2, favorable 

PBPs, and the large percentage of 

customers who would experience LCC 

benefits, emission reductions, and the 

estimated monetary value of the 

emissions reductions would outweigh 

the slight increase in the cumulative 

regulatory burden on manufacturers and 

the risk of small negative impacts if 

manufacturers are unable to recoup 

investments made to meet the standard. 

In particular, the Secretary of Energy 

has concluded that TSL 2 would save a 

significant amount of energy and is 

technologically feasible and 

economically justified. 

In addition, DOE notes that TSL 2 

most closely corresponds to the 

standards that were proposed by the 

Motor Coalition, as described in section 

II.B.2. Based on the above 

considerations, DOE today proposes to 

adopt the energy conservation standards 

for electric motors at TSL 2. Table V.24 

through Table V.27 present the 

proposed energy conservation standards 

for electric motors. 

TABLE V.24—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC

MOTORS

[Compliance starting December 19, 2015] 

Motor 

horsepower/standard 

kilowatt equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................. 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .............................. 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ................................. 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5 

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TABLE V.24—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC

MOTORS—Continued 

[Compliance starting December 19, 2015] 

Motor 

horsepower/standard 

kilowatt equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

3/2.2 ................................. 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ................................. 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .............................. 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ............................... 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ................................ 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ................................ 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ............................. 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ................................ 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7 

40/30 ................................ 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7 

50/37 ................................ 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4 

60/45 ................................ 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0 

75/55 ................................ 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1 

100/75 .............................. 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1 

125/90 .............................. 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1 

150/110 ............................ 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1 

200/150 ............................ 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1 

250/186 ............................ 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0 

300/224 ............................ 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0 

350/261 ............................ 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0 

400/298 ............................ 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0 

450/336 ............................ 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0 

500/373 ............................ 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0 

TABLE V.25—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN C ELECTRIC MOTORS

[Compliance starting December 19, 2015] 

Motor 

horsepower/standard 

kilowatt equivalent 

Nominal full load efficiency (%) 

4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................................................................. 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .............................................................................. 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ................................................................................. 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ................................................................................. 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ................................................................................. 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .............................................................................. 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ............................................................................... 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ................................................................................ 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ................................................................................ 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ............................................................................. 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ................................................................................ 93.6 94.1 93.0 93.6 91.7 91.7 

40/30 ................................................................................ 94.1 94.1 94.1 94.1 91.7 91.7 

50/37 ................................................................................ 94.5 94.5 94.1 94.1 92.4 92.4 

60/45 ................................................................................ 95.0 95.0 94.5 94.5 92.4 93.0 

75/55 ................................................................................ 95.4 95.0 94.5 94.5 93.6 94.1 

100/75 .............................................................................. 95.4 95.4 95.0 95.0 93.6 94.1 

125/90 .............................................................................. 95.4 95.4 95.0 95.0 94.1 94.1 

150/110 ............................................................................ 95.8 95.8 95.8 95.4 94.1 94.1 

200/150 ............................................................................ 96.2 95.8 95.8 95.4 94.5 94.1 

TABLE V.26—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS

[Compliance starting December 19, 2015] 

Motor 

horsepower/standard 

kilowatt equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................. 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0 

1.5/1.1 .............................. 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5 

2/1.5 ................................. 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5 

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89 DOE used a two-step calculation process to 

convert the time-series of costs and benefits into 

annualized values. First, DOE calculated a present 

value in 2013, the year used for discounting the 

NPV of total consumer costs and savings, for the 

time-series of costs and benefits using discount 

rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For 

the latter, DOE used a range of discount rates, as 

shown in Table I.3. From the present value, DOE 

then calculated the fixed annual payment over a 30- 

year period (2015 through 2044) that yields the 

same present value. The fixed annual payment is 

the annualized value. Although DOE calculated 

annualized values, this does not imply that the 

time-series of cost and benefits from which the 

annualized values were determined is a steady 

stream of payments. 

TABLE V.26—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS—Continued 

[Compliance starting December 19, 2015] 

Motor 

horsepower/standard 

kilowatt equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

3/2.2 ................................. 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5 

5/3.7 ................................. 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5 

7.5/5.5 .............................. 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5 

10/7.5 ............................... 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5 

15/11 ................................ 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5 

20/15 ................................ 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2 

25/18.5 ............................. 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2 

30/22 ................................ 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0 

40/30 ................................ 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0 

50/37 ................................ 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7 

60/45 ................................ 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4 

75/55 ................................ 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6 

100/75 .............................. 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6 

125/90 .............................. 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6 

150/110 ............................ 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6 

200/150 ............................ 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6 

250/186 ............................ 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5 

300/224 ............................ 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5 

350/261 ............................ 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5 

400/298 ............................ 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5 

450/336 ............................ 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5 

500/373 ............................ 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5 

TABLE V.27—PROPOSED ENERGY CONSERVATION STANDARDS FOR BRAKE MOTORS

[Compliance starting December 19, 2015] 

Motor 

horsepower/standard 

kilowatt equivalent 

Nominal full load efficiency (%) 

4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................. 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .............................. 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ................................. 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ................................. 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ................................. 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .............................. 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ............................... 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ................................ 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ................................ 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ............................. 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ................................ 93.6 94.1 93.0 93.6 91.7 91.7 

2. Summary of Benefits and Costs 

(Annualized) of the Proposed Standards 

The benefits and costs of today’s 

proposed standards, for equipment sold 

in 2015–2044, can also be expressed in 

terms of annualized values. The 

annualized monetary values are the sum 

of: (1) The annualized national 

economic value of the benefits from 

consumer operation of equipment that 

meet the proposed standards (consisting 

primarily of operating cost savings from 

using less energy, minus increases in 

equipment purchase and installation 

costs, which is another way of 

representing consumer NPV), and (2) 

the annualized monetary value of the 

benefits of emission reductions, 

including CO2 emission reductions.89

Although combining the values of 

operating savings and CO2 emission 

reductions provides a useful 

perspective, two issues should be 

considered. First, the national operating 

savings are domestic U.S. consumer 

monetary savings that occur as a result 

of market transactions while the value 

of CO2 reductions is based on a global 

value. Second, the assessments of 

operating cost savings and CO2 savings 

are performed with different methods 

that use different time frames for 

analysis. The national operating cost 

savings is measured for the lifetime of 

electric motors shipped in 2015 –2044. 

The SCC values, on the other hand, 

reflect the present value of some future 

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climate-related impacts resulting from 

the emission of one ton of carbon 

dioxide in each year. These impacts 

continue well beyond 2100. 

Estimates of annualized benefits and 

costs of the proposed standards for 

electric motors are shown in Table V.28. 

The results under the primary estimate 

are as follows. Using a 7-percent 

discount rate for benefits and costs other 

than CO2 reduction, for which DOE 

used a 3-percent discount rate along 

with the average SCC series that uses a 

3-percent discount rate, the cost of the 

standards proposed in today’s rule is 

$462 million per year in increased 

equipment costs; while the estimated 

benefits are $1,114 million per year in 

reduced equipment operating costs, 

$586 million in CO2 reductions, and 

$21.5 million in reduced NOX

emissions. In this case, the net benefit 

would amount to $957 million per year. 

Using a 3-percent discount rate for all 

benefits and costs and the average SCC 

series, the estimated cost of the 

standards proposed in today’s rule is 

$577 million per year in increased 

equipment costs; while the estimated 

benefits are $1,730 million per year in 

reduced operating costs, $586 million in 

CO2 reductions, and $31.5 million in 

reduced NOX emissions. In this case, the 

net benefit would amount to 

approximately $1,354 million per year. 

TABLE V.28—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR ELECTRIC MOTORS

[million 2012$/year] 

Discount rate Primary 

estimate * 

Low Net 

benefits 

estimate * 

High Net 

benefits 

estimate * 

Benefits: 

Consumer Operating Cost Savings .............. 7% ............................... 1,114 ........................... 924 .............................. 1,358. 

3% ............................... 1,730 ........................... 1,421 ........................... 2,134. 

CO2 Reduction Monetized Value ($11.8/t 

case) *.

5% ............................... 155 .............................. 134 .............................. 179. 

CO2 Reduction Monetized Value ($39.7/t 

case) *.

3% ............................... 586 .............................. 506 .............................. 679. 

CO2 Reduction Monetized Value ($61.2/t 

case) *.

2.5% ............................ 882 .............................. 762 .............................. 1022. 

CO2 Reduction Monetized Value $117.0/t 

case) *.

3% ............................... 1,811 ........................... 1,565 ........................... 2,098. 

NOX Reduction Monetized Value (at $2,639/

ton) **.

7% ............................... 21.46 ........................... 18.55 ........................... 24.68. 

3% ............................... 31.48 ........................... 27.20 ........................... 36.39. 

7% plus CO2 range .... 1,290 to 2,947 ............ 1,077 to 2,507 ............ 1,562 to 3,481. 

Total Benefits † ...................................... 7% ............................... 1,721 ........................... 1,449 ........................... 2,061. 

3% plus CO2 range .... 1,916 to 3,572 ............ 1,583 to 3,014 ............ 2,350 to 4,268. 

3% ............................... 2,347 ........................... 1,955 ........................... 2,849. 

Costs: 

Consumer Incremental Equipment Costs ..... 7% ............................... 462 .............................. 492 .............................. 447. 

3% ............................... 577 .............................. 601 .............................. 569. 

Net Benefits: 

7% plus CO2 range .... 585 to 2,016 ............... 1,115 to 3,033 ............ 1,353 to 3,438. 

7% ............................... 957 .............................. 1,614 ........................... 1,887. 

Total † .................................................... 3% plus CO2 range .... 982 to 2,413 ............... 1,781 to 3,700 ............ 1,957 to 4,043. 

3% ............................... 1,354 ........................... 2,280 ........................... 2,492. 

* This table presents the annualized costs and benefits associated with electric motors shipped in 2015–2044. These results include benefits to 

consumers which accrue after 2044 from the equipment purchased in years 2015–2044. Costs incurred by manufacturers, some of which may 

be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The Primary, 

Low Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy Outlook (AEO) 2013 Reference 

case, Low Estimate, and High Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected equipment 

price in the Primary Estimate, a decline rate for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1. 

** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC 

from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile 

SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature 

change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate 

an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount 

rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled 

discount rate, and those values are added to the full range of CO2 values. 

VI. Procedural Issues and Regulatory 

Review 

A. Review Under Executive Orders 

12866 and 13563 

Section 1(b)(1) of Executive Order 

12866, ‘‘Regulatory Planning and 

Review,’’ 58 FR 51735 (Oct. 4, 1993), 

requires each agency to identify the 

problem that it intends to address, 

including, where applicable, the failures 

of private markets or public institutions 

that warrant new agency action, as well 

as to assess the significance of that 

problem. The problems that today’s 

standards address are as follows: 

(1) There are external benefits 

resulting from improved energy 

efficiency of covered electric motors 

which are not captured by the users of 

such equipment. These benefits include 

externalities related to environmental 

protection and energy security that are 

not reflected in energy prices, such as 

emissions of greenhouse gases. DOE 

attempts to quantify some of the 

external benefits through use of Social 

Cost of Carbon values. 

In addition, DOE has determined that 

today’s regulatory action is an 

‘‘economically significant regulatory 

action’’ under section 3(f)(1) of 

Executive Order 12866. Accordingly, 

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section 6(a)(3) of the Executive Order 

requires that DOE prepare a regulatory 

impact analysis (RIA) on today’s rule 

and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office 

of Management and Budget (OMB) 

review this rule. DOE presented to OIRA 

for review the draft rule and other 

documents prepared for this 

rulemaking, including the RIA, and has 

included these documents in the 

rulemaking record. The assessments 

prepared pursuant to Executive Order 

12866 can be found in the technical 

support document for this rulemaking. 

DOE has also reviewed this regulation 

pursuant to Executive Order 13563, 

issued on January 18, 2011 (76 FR 3281, 

Jan. 21, 2011). EO 13563 is 

supplemental to and explicitly reaffirms 

the principles, structures, and 

definitions governing regulatory review 

established in Executive Order 12866. 

To the extent permitted by law, agencies 

are required by Executive Order 13563 

to: (1) Propose or adopt a regulation 

only upon a reasoned determination 

that its benefits justify its costs 

(recognizing that some benefits and 

costs are difficult to quantify); (2) tailor 

regulations to impose the least burden 

on society, consistent with obtaining 

regulatory objectives, taking into 

account, among other things, and to the 

extent practicable, the costs of 

cumulative regulations; (3) select, in 

choosing among alternative regulatory 

approaches, those approaches that 

maximize net benefits (including 

potential economic, environmental, 

public health and safety, and other 

advantages; distributive impacts; and 

equity); (4) to the extent feasible, specify 

performance objectives, rather than 

specifying the behavior or manner of 

compliance that regulated entities must 

adopt; and (5) identify and assess 

available alternatives to direct 

regulation, including providing 

economic incentives to encourage the 

desired behavior, such as user fees or 

marketable permits, or providing 

information upon which choices can be 

made by the public. 

DOE emphasizes as well that 

Executive Order 13563 requires agencies 

to use the best available techniques to 

quantify anticipated present and future 

benefits and costs as accurately as 

possible. In its guidance, the Office of 

Information and Regulatory Affairs has 

emphasized that such techniques may 

include identifying changing future 

compliance costs that might result from 

technological innovation or anticipated 

behavioral changes. For the reasons 

stated in the preamble, DOE believes 

that today’s NOPR is consistent with 

these principles, including the 

requirement that, to the extent 

permitted by law, benefits justify costs 

and that net benefits are maximized. 

B. Review Under the Regulatory 

Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility 

analysis (IRFA) for any rule that by law 

must be proposed for public comment, 

unless the agency certifies that the rule, 

if promulgated, will not have a 

significant economic impact on a 

substantial number of small entities. As 

required by Executive Order 13272, 

‘‘Proper Consideration of Small Entities 

in Agency Rulemaking,’’ 67 FR 53461 

(August 16, 2002), DOE published 

procedures and policies on February 19, 

2003, to ensure that the potential 

impacts of its rules on small entities are 

properly considered during the 

rulemaking process. 68 FR 7990 DOE 

has made its procedures and policies 

available on the Office of the General 

Counsel’s Web site (http://energy.gov/

gc/office-general-counsel). 

DOE has prepared an IRFA for this 

rulemaking, a copy of which DOE will 

transmit to the Chief Counsel for 

Advocacy of the SBA for review under 

5 U.S.C. 605(b). As presented and 

discussed below, the IFRA describes 

potential impacts on electric motors 

manufacturers associated with capital 

and product conversion costs and 

discusses alternatives that could 

minimize these impacts. 

A statement of the objectives of, and 

reasons and legal basis for, the proposed 

rule are set forth elsewhere in the 

preamble and not repeated here. 

1. Description and Estimated Number of 

Small Entities Regulated 

a. Methodology for Estimating the 

Number of Small Entities 

For manufacturers of electric motors, 

the Small Business Administration 

(SBA) has set a size threshold, which 

defines those entities classified as 

‘‘small businesses’’ for the purposes of 

the statute. DOE used the SBA’s small 

business size standards to determine 

whether any small entities would be 

subject to the requirements of the rule. 

The size standards are listed by North 

American Industry Classification 

System (NAICS) code and industry 

description available at: http://

www.sba.gov/content/table-smallbusiness-size-standards. Electric motor 

manufacturing is classified under 

NAICS 335312, ‘‘Motor and Generator 

Manufacturing.’’ The SBA sets a 

threshold of 1,000 employees or less for 

an entity to be considered as a small 

business for this category. 

To estimate the number of companies 

that could be small business 

manufacturers of equipment covered by 

this rulemaking, DOE conducted a 

market survey using publicly available 

information. DOE’s research involved 

industry trade association membership 

directories (including NEMA), 

information from previous rulemakings, 

UL qualification directories, individual 

company Web sites, and market 

research tools (e.g., Hoover’s reports). 

DOE also asked stakeholders and 

industry representatives if they were 

aware of any other small manufacturers 

during manufacturer interviews and 

DOE public meetings. DOE used 

information from these sources to create 

a list of companies that potentially 

manufacture electric motors covered by 

this rulemaking. As necessary, DOE 

contacted companies to determine 

whether they met the SBA’s definition 

of a small business manufacturer. DOE 

screened out companies that do not 

offer equipment covered by this 

rulemaking, do not meet the definition 

of a ‘‘small business,’’ or are foreign 

owned and operated. 

DOE initially identified 60 potential 

manufacturers of electric motors sold in 

the U.S. After reviewing publicly 

available information DOE contacted 27 

of the companies that DOE suspected 

were small business manufacturers to 

determine whether they met the SBA 

definition of a small business and 

whether they manufactured the 

equipment that would be affected by 

today’s proposal. Based on these efforts, 

DOE estimates that there are 13 small 

business manufacturers of electric 

motors. 

b. Manufacturer Participation 

DOE contacted the 13 identified small 

businesses to invite them to take part in 

a small business manufacturer impact 

analysis interview. Of the electric motor 

manufacturers DOE contacted, 10 

responded and three did not. Eight of 

the 10 responding manufacturers 

declined to be interviewed. Therefore, 

DOE was able to reach and discuss 

potential standards with two of the 13 

small business manufacturers. DOE also 

obtained information about small 

business manufacturers and potential 

impacts while interviewing large 

manufacturers. 

c. Electric Motor Industry Structure and 

Nature of Competition 

Eight major manufacturers supply 

approximately 90 percent of the market 

for electric motors. None of the major 

manufacturers of electric motors 

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covered in this rulemaking is a small 

business. DOE estimates that 

approximately 50 percent of the market 

is served by imports. Many of the small 

businesses that compete in the electric 

motor market produce specialized 

motors, many of which have not been 

regulated under previous standards. 

Most of these low-volume 

manufacturers do not compete directly 

with large manufacturers and tend to 

occupy niche markets for their 

equipment. There are a few small 

business manufacturers that produce 

general purpose motors; however, these 

motors currently meet NEMA Premium 

efficiency levels, the efficiency levels 

being proposed in today’s notice. 

d. Comparison Between Large and Small 

Entities 

For electric motors, small 

manufacturers differ from large 

manufacturers in several ways that 

affect the extent to which a 

manufacturer would be impacted by 

proposed standards. Characteristics of 

small manufacturers include: lower 

production volumes, fewer engineering 

resources, less technical expertise, and 

less access to capital. 

Lower production volumes lie at the 

heart of most small business 

disadvantages, particularly for a small 

manufacturer that is vertically 

integrated. A lower-volume 

manufacturer’s conversion costs would 

need to be spread over fewer units than 

a larger competitor. Thus, unless the 

small business can differentiate its 

product in some way that earns a price 

premium, the small business is a ‘price 

taker’ and experiences a reduction in 

profit per unit relative to the large 

manufacturer. Therefore, because much 

of the same equipment would need to be 

purchased by both large and small 

manufacturers in order to produce 

electric motors at higher TSLs, 

undifferentiated small manufacturers 

would face a greater variable cost 

penalty because they must depreciate 

the one-time conversion expenditures 

over fewer units. 

Smaller companies are also more 

likely to have more limited engineering 

resources and they often operate with 

lower levels of design and 

manufacturing sophistication. Smaller 

companies typically also have less 

experience and expertise in working 

with more advanced technologies. 

Standards that required these 

technologies could strain the 

engineering resources of these small 

manufacturers if they chose to maintain 

a vertically integrated business model. 

Small business electric motor 

manufacturers can also be at a 

disadvantage due to their lack of 

purchasing power for high performance 

materials. For example, more expensive 

low-loss steels are needed to meet 

higher efficiency standards and steel 

cost grows as a percentage of the overall 

product cost. Small manufacturers who 

pay higher per pound prices would be 

disproportionately impacted by these 

prices. 

Lastly, small manufacturers typically 

have less access to capital, which may 

be needed by some to cover the 

conversion costs associated with new 

technologies. 

2. Description and Estimate of 

Compliance Requirements 

In its market survey, DOE identified 

three categories of small business 

electric motor manufacturers that may 

be impacted differently by today’s 

proposed rule. The first group, which 

includes approximately five of the 13 

small businesses, consists of 

manufacturers that produce specialty 

motors that were not required to meet 

previous Federal standards, but would 

need to do so under the expanded scope 

of today’s proposed rule. DOE believes 

that this group would likely be the most 

impacted by expanding the scope of 

equipment required to meet NEMA 

Premium efficiency levels. The second 

group, which includes approximately 

five different small businesses, consists 

of manufacturers that produce a small 

amount of covered equipment and 

primarily focus on other types of motors 

not covered in this rulemaking, such as 

single-phase or direct-current motors. 

Because generally less than 10 percent 

of these manufacturers’ revenue comes 

from covered equipment, DOE does not 

believe new standards will substantially 

impact their business. The third group, 

which includes approximately three 

small businesses, consists of 

manufacturers that already offer NEMA 

Premium general purpose and specialty 

motors. DOE expects these 

manufacturers to face similar 

conversion costs as large manufacturers, 

in that they will not experience high 

capital conversion costs as they already 

have the design and production 

experience necessary to bring their 

motors up to NEMA Premium efficiency 

levels. It is likely, however, that some of 

the specialty equipment these 

manufacturers produce will be included 

in the expanded scope of this proposed 

rule and is likely to result in these small 

businesses incurring additional 

certification and testing costs. These 

manufacturers could also face product 

development costs if they have to 

redesign any motors that are not 

currently meeting the NEMA Premium 

level. 

At TSL 2, the level proposed in 

today’s notice, DOE estimates capital 

conversion costs of $1.88 million and 

product conversion costs of $3.75 

million for a typical small manufacturer 

in the first group (manufacturers that 

produce specialized motors previously 

not covered by Federal standards). 

Meanwhile, DOE estimates a typical 

large manufacturer would incur capital 

and product conversion costs of $3.29 

million and $7.25 million, respectively, 

at the same TSL. Small manufacturers 

that predominately produce specialty 

motors would face higher relative 

capital conversion costs at TSL 2 than 

large manufacturers because large 

manufacturers have been independently 

pursuing higher efficiency motors as a 

result of the efficiency standards 

prescribed by EISA 2007 (10 CFR part 

431.25) and consequently have built up 

more design and production experience. 

Large manufacturers have also been 

innovating as a result of the small 

electric motors rulemaking at 75 FR 

10874 (March 9, 2010), which exempted 

many of the specialized equipment that 

these small business manufacturers 

produce. Many large manufacturers of 

general purpose motors offer equipment 

that was covered by the 2010 small 

electric motors rule, as well as 

equipment that falls under this 

proposed rule. Small manufactures 

pointed out that this would give large 

manufacturers an advantage in that they 

already have experience with the 

technology necessary to redesign their 

equipment and are familiar with the 

steps they will have to take to upgrade 

their manufacturing equipment and 

processes. Small manufactures, whose 

specialized motors were not required to 

meet the standards prescribed by the 

small electric motors rule and EISA 

2007 have not undergone these 

processes and, therefore, would have to 

put more time and resources into 

redesign efforts. 

The small businesses whose product 

lines consist of a high percentage of 

equipment that are not currently 

required to meet efficiency standards 

would need to make significant capital 

investments relative to large 

manufacturers to upgrade their 

production lines with equipment 

necessary to produce NEMA Premium 

motors. As Table VI.1 illustrates, these 

manufacturers would have to drastically 

increase their capital expenditures to 

purchase new lamination die sets, and 

new winding and stacking equipment. 

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TABLE VI.1—ESTIMATED CAPITAL AND PRODUCT CONVERSION COSTS AS A PERCENTAGE OF ANNUAL CAPITAL

EXPENDITURES AND R&D EXPENSE

Capital conversion 

cost as a percentage of annual 

capital 

expenditures 

(%) 

Product conversion cost as a 

percentage of 

annual R&D 

expense 

(%) 

Total conversion 

cost as a percentage of annual 

revenue 

(%) 

Typical Large Manufacturer ....................................................................................... 14 31 2 

Typical Small Manufacturer ....................................................................................... 188 490 75 

Table VI.1 also illustrates that small 

manufacturers whose product lines 

contain many motors that are not 

currently required to meet Federal 

standards face high relative product 

conversion costs compared to large 

manufacturers, despite the lower dollar 

value. In interviews, these small 

manufacturers expressed concern that 

they would face a large learning curve 

relative to large manufacturers, due to 

the fact that many of the equipment they 

produce has not had to meet Federal 

standards. In its market survey, DOE 

learned that for some manufacturers, the 

expanded scope of specialized motors 

that would have to meet NEMA 

Premium could affect nearly half the 

equipment they offer. They would need 

to hire additional engineers and would 

have to spend considerable time and 

resources redesigning their equipment 

and production processes. DOE does not 

expect the small businesses that already 

manufacture NEMA Premium 

equipment or those that offer very few 

alternating-current motors to incur these 

high costs. 

Manufacturers also expressed concern 

about testing and certification costs 

associated with new standards. They 

pointed out that these costs are 

particularly burdensome on small 

businesses that produce a wide variety 

of specialized equipment. As a result of 

the wide variety of equipment they 

produce and their relatively low output, 

small manufacturers are forced to certify 

multiple small batches of motors, the 

costs of which need to be spread out 

over far fewer units than large 

manufacturers. 

Small manufacturers that produce 

equipment not currently required to 

meet efficiency standards also pointed 

out that they would face significant 

challenges supporting current business 

while making changes to their 

production lines. While large 

manufacturers could shift production of 

certain equipment to different plants or 

product lines while they made updates, 

small businesses would have limited 

options. Most of these small businesses 

have only one plant and would have to 

find a way to continue to fulfill 

customer needs while redesigning 

production lines and installing new 

equipment. In interviews with DOE, 

small manufacturers said that it would 

be difficult to quantify the impacts that 

downtime and the possible need for 

external support could have on their 

businesses. 

3. Duplication, Overlap, and Conflict 

With Other Rules and Regulations 

DOE is not aware of any rules or 

regulations that duplicate, overlap, or 

conflict with the rule being considered 

today. 

4. Significant Alternatives to the 

Proposed Rule 

The discussion above analyzes 

impacts on small businesses that would 

result from the TSL DOE is proposing in 

today’s notice. Though TSLs lower than 

the proposed TSL are expected to 

reduce the impacts on small entities, 

DOE is required by EPCA to establish 

standards that achieve the maximum 

improvement in energy efficiency that 

are technically feasible and 

economically justified, and result in a 

significant conservation of energy. 

Therefore, DOE rejected the lower TSLs. 

In addition to the other TSLs being 

considered, the NOPR TSD includes a 

regulatory impact analysis in chapter 

17. For electric motors, this report 

discusses the following policy 

alternatives: (1) Consumer rebates, (2) 

consumer tax credits, and (3) 

manufacturer tax credits. DOE does not 

intend to consider these alternatives 

further because they either are not 

feasible to implement or are not 

expected to result in energy savings as 

large as those that would be achieved by 

the standard levels under consideration. 

DOE continues to seek input from 

businesses that would be affected by 

this rulemaking and will consider 

comments received in the development 

of any final rule. 

5. Significant Issues Raised by Public 

Comments 

DOE’s MIA suggests that, while TSL 

2 presents greater difficulties for small 

businesses than lower efficiency levels, 

the business impacts at higher TSLs 

would be greater. DOE expects that most 

small businesses will generally be able 

to maintain profitability at the TSL 

proposed in today’s rulemaking. It is 

possible, however, that the small 

manufacturers whose product lines 

consist of a high percentage of 

previously exempted motors could 

incur significant costs as a result of this 

proposed rule, and those high costs 

could endanger their business. DOE’s 

MIA is based on its interviews of both 

small and large manufacturers, and 

consideration of small business impacts 

explicitly enters into DOE’s choice of 

the TSLs proposed in this NOPR. 

DOE did not receive any public 

comments suggesting that small 

businesses would not be able to achieve 

the efficiency levels at TSL 2. 

C. Review Under the Paperwork 

Reduction Act 

Manufacturers of electric motors that 

are currently subject to energy 

conservation standards must certify to 

DOE that their equipment comply with 

any applicable energy conservation 

standards. In certifying compliance, 

manufacturers must test their 

equipment according to the DOE test 

procedures for electric motors, 

including any amendments adopted for 

those test procedures. The collection-ofinformation requirement for the 

certification and recordkeeping is 

subject to review and approval by OMB 

under the Paperwork Reduction Act 

(PRA). This requirement has been 

approved by OMB under OMB control 

number 1910–1400. Public reporting 

burden for the certification is estimated 

to average 20 hours per response, 

including the time for reviewing 

instructions, searching existing data 

sources, gathering and maintaining the 

data needed, and completing and 

reviewing the collection of information. 

DOE intends to address revised 

certification requirements for electric 

motors in a separate rulemaking. 

Notwithstanding any other provision 

of the law, no person is required to 

respond to, nor shall any person be 

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subject to a penalty for failure to comply 

with, a collection of information subject 

to the requirements of the PRA, unless 

that collection of information displays a 

currently valid OMB Control Number. 

D. Review Under the National 

Environmental Policy Act of 1969 

Pursuant to the National 

Environmental Policy Act (NEPA) of 

1969, DOE has determined that the 

proposed rule fits within the category of 

actions included in Categorical 

Exclusion (CX) B5.1 and otherwise 

meets the requirements for application 

of a CX. See 10 CFR Part 1021, App. B, 

B5.1(b); 1021.410(b) and Appendix B, 

B(1)–(5). The proposed rule fits within 

the category of actions because it is a 

rulemaking that establishes energy 

conservation standards for consumer 

products or industrial equipment, and 

for which none of the exceptions 

identified in CX B5.1(b) apply. 

Therefore, DOE has made a CX 

determination for this rulemaking, and 

DOE does not need to prepare an 

Environmental Assessment or 

Environmental Impact Statement for 

this proposed rule. DOE’s CX 

determination for this proposed rule is 

available at http://cxnepa.energy.gov/. 

E. Review Under Executive Order 13132 

Executive Order 13132, ‘‘Federalism.’’ 

64 FR 43255 (Aug. 10, 1999) imposes 

certain requirements on Federal 

agencies formulating and implementing 

policies or regulations that preempt 

State law or that have Federalism 

implications. The Executive Order 

requires agencies to examine the 

constitutional and statutory authority 

supporting any action that would limit 

the policymaking discretion of the 

States and to carefully assess the 

necessity for such actions. The 

Executive Order also requires agencies 

to have an accountable process to 

ensure meaningful and timely input by 

State and local officials in the 

development of regulatory policies that 

have Federalism implications. On 

March 14, 2000, DOE published a 

statement of policy describing the 

intergovernmental consultation process 

it will follow in the development of 

such regulations. 65 FR 13735. EPCA 

governs and prescribes Federal 

preemption of State regulations as to 

energy conservation for the equipment 

that are the subject of today’s proposed 

rule. States can petition DOE for 

exemption from such preemption to the 

extent, and based on criteria, set forth in 

EPCA. (42 U.S.C. 6297) No further 

action is required by Executive Order 

13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing 

regulations and the promulgation of 

new regulations, section 3(a) of 

Executive Order 12988, ‘‘Civil Justice 

Reform,’’ imposes on Federal agencies 

the general duty to adhere to the 

following requirements: (1) Eliminate 

drafting errors and ambiguity; (2) write 

regulations to minimize litigation; and 

(3) provide a clear legal standard for 

affected conduct rather than a general 

standard and promote simplification 

and burden reduction. 61 FR 4729 (Feb. 

7, 1996). Section 3(b) of Executive Order 

12988 specifically requires that 

Executive agencies make every 

reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect, if any; (2) clearly 

specifies any effect on existing Federal 

law or regulation; (3) provides a clear 

legal standard for affected conduct 

while promoting simplification and 

burden reduction; (4) specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. Section 3(c) of Executive Order 

12988 requires Executive agencies to 

review regulations in light of applicable 

standards in section 3(a) and section 

3(b) to determine whether they are met 

or it is unreasonable to meet one or 

more of them. DOE has completed the 

required review and determined that, to 

the extent permitted by law, this 

proposed rule meets the relevant 

standards of Executive Order 12988. 

G. Review Under the Unfunded 

Mandates Reform Act of 1995 

Title II of the Unfunded Mandates 

Reform Act of 1995 (UMRA) requires 

each Federal agency to assess the effects 

of Federal regulatory actions on State, 

local, and Tribal governments and the 

private sector. Public Law 104–4, sec. 

201 (codified at 2 U.S.C. 1531). For a 

proposed regulatory action likely to 

result in a rule that may cause the 

expenditure by State, local, and Tribal 

governments, in the aggregate, or by the 

private sector of $100 million or more 

in any one year (adjusted annually for 

inflation), section 202 of UMRA requires 

a Federal agency to publish a written 

statement that estimates the resulting 

costs, benefits, and other effects on the 

national economy. (2 U.S.C. 1532(a), (b)) 

The UMRA also requires a Federal 

agency to develop an effective process 

to permit timely input by elected 

officers of State, local, and Tribal 

governments on a proposed ‘‘significant 

intergovernmental mandate,’’ and 

requires an agency plan for giving notice 

and opportunity for timely input to 

potentially affected small governments 

before establishing any requirements 

that might significantly or uniquely 

affect small governments. On March 18, 

1997, DOE published a statement of 

policy on its process for 

intergovernmental consultation under 

UMRA. 62 FR 12820. DOE’s policy 

statement is also available at http://

energy.gov/gc/downloads/unfundedmandates-reform-actintergovernmental-consultation. 

Although today’s proposed rule does 

not contain a Federal intergovernmental 

mandate, it may require expenditures of 

$100 million or more on the private 

sector. Specifically, the proposed rule 

will likely result in a final rule that 

could require expenditures of $100 

million or more. Such expenditures may 

include: (1) Investment in research and 

development and in capital 

expenditures by electric motor 

manufacturers in the years between the 

final rule and the compliance date for 

the new standards, and (2) incremental 

additional expenditures by consumers 

to purchase higher-efficiency electric 

motors, starting at the compliance date 

for the applicable standard. 

Section 202 of UMRA authorizes a 

Federal agency to respond to the content 

requirements of UMRA in any other 

statement or analysis that accompanies 

the proposed rule. 2 U.S.C. 1532(c). The 

content requirements of section 202(b) 

of UMRA relevant to a private sector 

mandate substantially overlap the 

economic analysis requirements that 

apply under section 325(o) of EPCA and 

Executive Order 12866. The 

SUPPLEMENTARY INFORMATION section of 

the NOPR and the ‘‘Regulatory Impact 

Analysis’’ section of the TSD for this 

proposed rule respond to those 

requirements. 

Under section 205 of UMRA, the 

Department is obligated to identify and 

consider a reasonable number of 

regulatory alternatives before 

promulgating a rule for which a written 

statement under section 202 is required. 

2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most 

cost-effective and least burdensome 

alternative that achieves the objectives 

of the proposed rule unless DOE 

publishes an explanation for doing 

otherwise, or the selection of such an 

alternative is inconsistent with law. As 

required by 42 U.S.C. 6295(d), (f), and 

(o) and 6316(a), today’s proposed rule 

would establish energy conservation 

standards for electric motors that are 

designed to achieve the maximum 

improvement in energy efficiency that 

DOE has determined to be both 

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technologically feasible and 

economically justified. A full discussion 

of the alternatives considered by DOE is 

presented in the ‘‘Regulatory Impact 

Analysis’’ section of the TSD for today’s 

proposed rule. 

H. Review Under the Treasury and 

General Government Appropriations 

Act, 1999 

Section 654 of the Treasury and 

General Government Appropriations 

Act, 1999 (Pub. L. 105–277) requires 

Federal agencies to issue a Family 

Policymaking Assessment for any rule 

that may affect family well-being. This 

proposed rule would not have any 

impact on the autonomy or integrity of 

the family as an institution. 

Accordingly, DOE has concluded that it 

is not necessary to prepare a Family 

Policymaking Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under Executive 

Order 12630, ‘‘Governmental Actions 

and Interference with Constitutionally 

Protected Property Rights’’ 53 FR 8859 

(Mar. 18, 1988), that this proposed 

regulation would not result in any 

takings that might require compensation 

under the Fifth Amendment to the U.S. 

Constitution. 

J. Review Under the Treasury and 

General Government Appropriations 

Act, 2001 

Section 515 of the Treasury and 

General Government Appropriations 

Act, 2001 (44 U.S.C. 3516, note) 

provides for Federal agencies to review 

most disseminations of information to 

the public under guidelines established 

by each agency pursuant to general 

guidelines issued by OMB. OMB’s 

guidelines were published at 67 FR 

8452 (Feb. 22, 2002), and DOE’s 

guidelines were published at 67 FR 

62446 (Oct. 7, 2002). DOE has reviewed 

today’s NOPR under the OMB and DOE 

guidelines and has concluded that it is 

consistent with applicable policies in 

those guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, ‘‘Actions 

Concerning Regulations That 

Significantly Affect Energy Supply, 

Distribution, or Use’’ 66 FR 28355 (May 

22, 2001), requires Federal agencies to 

prepare and submit to OIRA at OMB, a 

Statement of Energy Effects for any 

proposed significant energy action. A 

‘‘significant energy action’’ is defined as 

any action by an agency that 

promulgates or is expected to lead to 

promulgation of a final rule, and that: 

(1) Is a significant regulatory action 

under Executive Order 12866, or any 

successor order; and (2) is likely to have 

a significant adverse effect on the 

supply, distribution, or use of energy, or 

(3) is designated by the Administrator of 

OIRA as a significant energy action. For 

any proposed significant energy action, 

the agency must give a detailed 

statement of any adverse effects on 

energy supply, distribution, or use 

should the proposal be implemented, 

and of reasonable alternatives to the 

action and their expected benefits on 

energy supply, distribution, and use. 

DOE has tentatively concluded that 

today’s proposed regulatory action, 

which sets forth potential energy 

conservation standards for commercial 

and industrial electric motors, is not a 

significant energy action because the 

proposed standards are not likely to 

have a significant adverse effect on the 

supply, distribution, or use of energy, 

nor has it been designated as such by 

the Administrator at OIRA. Accordingly, 

DOE has not prepared a Statement of 

Energy Effects on the proposed rule. 

L. Review Under the Information 

Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in 

consultation with the Office of Science 

and Technology Policy (OSTP), issued 

its Final Information Quality Bulletin 

for Peer Review (the Bulletin). 70 FR 

2664 (Jan. 14, 2005). The Bulletin 

establishes that certain scientific 

information shall be peer reviewed by 

qualified specialists before it is 

disseminated by the Federal 

Government, including influential 

scientific information related to agency 

regulatory actions. The purpose of the 

bulletin is to enhance the quality and 

credibility of the Government’s 

scientific information. Under the 

Bulletin, the energy conservation 

standards rulemaking analyses are 

‘‘influential scientific information,’’ 

which the Bulletin defines as scientific 

information the agency reasonably can 

determine will have, or does have, a 

clear and substantial impact on 

important public policies or private 

sector decisions. 70 FR 2667. 

In response to OMB’s Bulletin, DOE 

conducted formal in-progress peer 

reviews of the energy conservation 

standards development process and 

analyses and has prepared a Peer 

Review Report pertaining to the energy 

conservation standards rulemaking 

analyses. Generation of this report 

involved a rigorous, formal, and 

documented evaluation using objective 

criteria and qualified and independent 

reviewers to make a judgment as to the 

technical/scientific/business merit, the 

actual or anticipated results, and the 

productivity and management 

effectiveness of programs and/or 

projects. The ‘‘Energy Conservation 

Standards Rulemaking Peer Review 

Report’’ dated February 2007 has been 

disseminated and is available at the 

following Web site: 

www1.eere.energy.gov/buildings/

appliance_standards/peer_review.html. 

VII. Public Participation 

A. Attendance at the Public Meeting 

The time, date, and location of the 

public meeting are listed in the DATES

and ADDRESSES sections at the beginning 

of this notice. If you plan to attend the 

public meeting, please notify Ms. 

Brenda Edwards at (202) 586–2945 or 

Brenda.Edwards@ee.doe.gov. As 

explained in the ADDRESSES section, 

foreign nationals visiting DOE 

Headquarters are subject to advance 

security screening procedures. 

In addition, you can attend the public 

meeting via webinar. Webinar 

registration information, participant 

instructions, and information about the 

capabilities available to webinar 

participants will be published on DOE’s 

Web site at: https://

www1.eere.energy.gov/buildings/

appliance_standards/rulemaking.aspx/

ruleid/42. Participants are responsible 

for ensuring their systems are 

compatible with the webinar software. 

B. Procedure for Submitting Prepared 

General Statements For Distribution 

Any person who has plans to present 

a prepared general statement may 

request that copies of his or her 

statement be made available at the 

public meeting. Such persons may 

submit requests, along with an advance 

electronic copy of their statement in 

PDF (preferred), Microsoft Word or 

Excel, WordPerfect, or text (ASCII) file 

format, to the appropriate address 

shown in the ADDRESSES section at the 

beginning of this notice. The request 

and advance copy of statements must be 

received at least one week before the 

public meeting and may be emailed, 

hand-delivered, or sent by mail. DOE 

prefers to receive requests and advance 

copies via email. Please include a 

telephone number to enable DOE staff to 

make follow-up contact, if needed. 

C. Conduct of the Public Meeting 

DOE will designate a DOE official to 

preside at the public meeting and may 

also use a professional facilitator to aid 

discussion. The meeting will not be a 

judicial or evidentiary-type public 

hearing, but DOE will conduct it in 

accordance with section 336 of EPCA 

(42 U.S.C. 6306). A court reporter will 

be present to record the proceedings and 

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prepare a transcript. DOE reserves the 

right to schedule the order of 

presentations and to establish the 

procedures governing the conduct of the 

public meeting. After the public 

meeting, interested parties may submit 

further comments on the proceedings as 

well as on any aspect of the rulemaking 

until the end of the comment period. 

The public meeting will be conducted 

in an informal, conference style. DOE 

will present summaries of comments 

received before the public meeting, 

allow time for prepared general 

statements by participants, and 

encourage all interested parties to share 

their views on issues affecting this 

rulemaking. Each participant will be 

allowed to make a general statement 

(within time limits determined by DOE), 

before the discussion of specific topics. 

DOE will allow, as time permits, other 

participants to comment briefly on any 

general statements. 

At the end of all prepared statements 

on a topic, DOE will permit participants 

to clarify their statements briefly and 

comment on statements made by others. 

Participants should be prepared to 

answer questions by DOE and by other 

participants concerning these issues. 

DOE representatives may also ask 

questions of participants concerning 

other matters relevant to this 

rulemaking. The official conducting the 

public meeting will accept additional 

comments or questions from those 

attending, as time permits. The 

presiding official will announce any 

further procedural rules or modification 

of the above procedures that may be 

needed for the proper conduct of the 

public meeting. 

A transcript of the public meeting will 

be included in the docket, which can be 

viewed as described in the Docket 

section at the beginning of this notice. 

In addition, any person may buy a copy 

of the transcript from the transcribing 

reporter. 

D. Submission of Comments 

DOE will accept comments, data, and 

information regarding this proposed 

rule before or after the public meeting, 

but no later than the date provided in 

the DATES section at the beginning of 

this proposed rule. Interested parties 

may submit comments, data, and other 

information using any of the methods 

described in the ADDRESSES section at 

the beginning of this notice. 

Submitting comments via 

regulations.gov. The regulations.gov 

Web page will require you to provide 

your name and contact information. 

Your contact information will be 

viewable to DOE Building Technologies 

staff only. Your contact information will 

not be publicly viewable except for your 

first and last names, organization name 

(if any), and submitter representative 

name (if any). If your comment is not 

processed properly because of technical 

difficulties, DOE will use this 

information to contact you. If DOE 

cannot read your comment due to 

technical difficulties and cannot contact 

you for clarification, DOE may not be 

able to consider your comment. 

However, your contact information 

will be publicly viewable if you include 

it in the comment itself or in any 

documents attached to your comment. 

Any information that you do not want 

to be publicly viewable should not be 

included in your comment, nor in any 

document attached to your comment. 

Otherwise, persons viewing comments 

will see only first and last names, 

organization names, correspondence 

containing comments, and any 

documents submitted with the 

comments. 

Do not submit to regulations.gov 

information for which disclosure is 

restricted by statute, such as trade 

secrets and commercial or financial 

information (hereinafter referred to as 

Confidential Business Information 

(CBI)). Comments submitted through 

regulations.gov cannot be claimed as 

CBI. Comments received through the 

Web site will waive any CBI claims for 

the information submitted. For 

information on submitting CBI, see the 

Confidential Business Information 

section below. 

DOE processes submissions made 

through regulations.gov before posting. 

Normally, comments will be posted 

within a few days of being submitted. 

However, if large volumes of comments 

are being processed simultaneously, 

your comment may not be viewable for 

up to several weeks. Please keep the 

comment tracking number that 

regulations.gov provides after you have 

successfully uploaded your comment. 

Submitting comments via email, hand 

delivery/courier, or mail. Comments and 

documents submitted via email, hand 

delivery, or mail also will be posted to 

regulations.gov. If you do not want your 

personal contact information to be 

publicly viewable, do not include it in 

your comment or any accompanying 

documents. Instead, provide your 

contact information in a cover letter. 

Include your first and last names, email 

address, telephone number, and 

optional mailing address. The cover 

letter will not be publicly viewable as 

long as it does not include any 

comments. 

Include contact information each time 

you submit comments, data, documents, 

and other information to DOE. If you 

submit via mail or hand delivery/

courier, please provide all items on a 

CD, if feasible. It is not necessary to 

submit printed copies. No facsimiles 

(faxes) will be accepted. 

Comments, data, and other 

information submitted to DOE 

electronically should be provided in 

PDF (preferred), Microsoft Word or 

Excel, WordPerfect, or text (ASCII) file 

format. Provide documents that are not 

secured, that are written in English, and 

that are free of any defects or viruses. 

Documents should not contain special 

characters or any form of encryption 

and, if possible, they should carry the 

electronic signature of the author. 

Campaign form letters. Please submit 

campaign form letters by the originating 

organization in batches of between 50 to 

500 form letters per PDF or as one form 

letter with a list of supporters’ names 

compiled into one or more PDFs. This 

reduces comment processing and 

posting time. 

Confidential Business Information. 

According to 10 CFR 1004.11, any 

person submitting information that he 

or she believes to be confidential and 

exempt by law from public disclosure 

should submit via email, postal mail, or 

hand delivery/courier two well-marked 

copies: One copy of the document 

marked confidential including all the 

information believed to be confidential, 

and one copy of the document marked 

non-confidential with the information 

believed to be confidential deleted. 

Submit these documents via email or on 

a CD, if feasible. DOE will make its own 

determination about the confidential 

status of the information and treat it 

according to its determination. 

Factors of interest to DOE when 

evaluating requests to treat submitted 

information as confidential include: (1) 

A description of the items; (2) whether 

and why such items are customarily 

treated as confidential within the 

industry; (3) whether the information is 

generally known by or available from 

other sources; (4) whether the 

information has previously been made 

available to others without obligation 

concerning its confidentiality; (5) an 

explanation of the competitive injury to 

the submitting person which would 

result from public disclosure; (6) when 

such information might lose its 

confidential character due to the 

passage of time; and (7) why disclosure 

of the information would be contrary to 

the public interest. 

It is DOE’s policy that all comments 

may be included in the public docket, 

without change and as received, 

including any personal information 

provided in the comments (except 

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information deemed to be exempt from 

public disclosure). 

E. Issues on Which DOE Seeks Comment 

Although DOE welcomes comments 

on any aspect of this proposal, DOE is 

particularly interested in receiving 

comments and views of interested 

parties concerning the following issues: 

1. DOE requests comment on the 

potential impacts of new and amended 

standards on small electric motor 

manufacturers, especially regarding 

DOE’s proposed expansion of scope of 

covered electric motors. 

2. DOE requests comment on whether 

the proposed standards help resolve the 

potential issue on which it had 

previously issued clarification of 

whether a [IEC] motor may be 

considered to be subject to two 

standards. 

3. DOE seeks comment on any 

additional sources of data that could be 

used to establish the distribution of 

electric motors across equipment class 

groups. 

4. DOE seeks comment on any 

additional sources of data that could be 

used to establish the distribution of 

electric motors across sectors by 

horsepower range and within each 

equipment class group. 

5. DOE seeks comment on any 

additional sources for determining the 

frequency of motor repair depending on 

equipment class group and sector. 

6. DOE seeks comment on any 

additional sources of data on motor 

lifetime that could be used to validate 

DOE’s estimates of motor mechanical 

lifetime and its method of estimating 

lifetimes. DOE defines equipment 

lifetime as the lesser of the age at which 

electric motors are retired from service 

or the equipment in which they are 

embedded is retired. For the NIA, DOE 

uses motor average lifetime in years 

derived from motor mechanical lifetime 

in hours (see Chapter 8, Section 8.2.3) 

and from annual operating hours (see 

Section 10.2.2.2). DOE based expected 

equipment lifetime on discussions with 

industry experts and developed a 

distribution of typical lifetimes for 

several categories of electric motors. 

DOE welcomes further input on the 

average equipment lifetimes for the LCC 

and NIA analyses. 

7. DOE seeks comment on the 

estimated base case distribution of 

product efficiencies and on any 

additional sources of data. 

8. DOE seeks comments on its 

decision to use efficiency trends for 

equipment class groups 1 and 4 and 

constant efficiencies for equipment class 

groups 2 and 3 over the analysis period. 

Specifically, DOE would like comments 

on additional sources of data on trends 

in efficiency improvement. 

9. DOE seeks comment on any sources 

of data that could be used to establish 

the elasticity of electric motor 

shipments with respect to changes in 

purchase price. 

10. DOE seeks comment on its scaled 

values for MSPs. In particular, DOE 

seeks comments on its methodology for 

scaling MSP data from the 

representative equipment classes to the 

remaining equipment classes. 

11. DOE seeks comment on the scaled 

values for motor weights. In particular, 

DOE seeks comments on its 

methodology for scaling weight data 

from the representative equipment 

classes to the remaining equipment 

classes. 

12. DOE seeks comment on the trial 

standard levels (TSLs) developed for the 

NOPR. 

13. DOE seeks comment on its 

proposed compliance date of December 

19, 2015. 

14. DOE seeks comment on its 

decision to analyze brake motors in a 

separate equipment class group. 

15. DOE seeks comment on its 

decision to limit standards for brake 

motors to 1–30 hp, and 4, 6, and 8 pole 

configurations. DOE selected these 

ratings after reviewing manufacturer 

catalogs and only finding brake motors 

in these configurations. 

16. DOE seeks comment on its 

decision to not screen out copper diecast copper rotor motors. 

17. DOE seeks comment on the 

availability of copper in the market to 

manufacture die-cast copper rotor 

motors on a ‘‘mass quantity’’ scale. 

18. DOE seeks comment on its 

decision to not screen out hand winding 

in its analysis. 

19. DOE seeks comment on its 

estimation for labor hours for each 

representative unit. 

20. DOE seeks comments on the cost 

to manufacturers to change their 

product lines to meet EL3. 

21. DOE seeks comments on the cost 

to manufacturers to change their 

product lines to meet EL4. 

22. DOE is aware that motors used in 

fire pump applications may carry 

various definitions, including, but not 

limited to, NEMA, IEC, and NFPA 

designations. DOE requests comment on 

its current definition of fire pump 

motors, the suitability of that definition 

for the United States market, and on its 

advantages or disadvantages relative to 

other potential definitions. 

23. In DOE’s view any Design B or 

IEC-equivalent motor that otherwise 

satisfies the relevant NFPA 

requirements would meet the fire pump 

electric motor definition in 10 CFR 

431.12. To the extent that there is 

confusion regarding this view, DOE 

invites comments on this issue, along 

with any data demonstrating whether 

any IEC-equivalent motors are listed for 

fire pump service either under the 

NFPA 20 or another relevant industry 

standard. 

24. DOE seeks data on any other 

subsets of 56-frame motors, particularly 

those motors that are: (1) Enclosed 

general purpose electric motors that 

have a rating of under 1 horsepower and 

(2) open, special or definite purpose 

(inclusive) electric motors. The types of 

data that DOE seeks include, but are not 

limited to, the following categories: 

Efficiency distribution; shipment 

breakdown between horsepower ratings, 

open and enclosed motors, and between 

general and special and definite purpose 

electric motors; and typical applications 

that use these motors. 

25. Currently, DOE’s reference case 

projects that prices for future shipments 

of motors will remain constant. DOE is 

seeking input on the appropriateness of 

this assumption. 

26. DOE requests comment on 

whether there are features or attributes 

of the more energy-efficient electric 

motors that manufacturers would 

produce to meet the standards in this 

proposed rule that might affect how 

they would be used by consumers. DOE 

requests comment specifically on how 

any such effects should be weighed in 

the choice of standards for the electric 

motors for the final rule. 

27. For this rulemaking, DOE 

analyzed the effects of this proposal 

assuming that the electric motors would 

be available to purchase for 30 years and 

undertook a sensitivity analysis using 9 

years rather than 30 years of product 

shipments. The choice of a 30-year 

period of shipments is consistent with 

the DOE analysis for other products and 

commercial equipment. The choice of a 

9-year period is a proxy for the timeline 

in EPCA for the review of certain energy 

conservation standards and potential 

revision of and compliance with such 

revised standards. We are seeking input, 

information and data on whether there 

are ways to further refine the analytic 

timeline. 

28. DOE solicits comment on the 

application of the new SCC values used 

to determine the social benefits of CO2

emissions reductions over the 

rulemaking analysis period. (The 

rulemaking analysis period covers from 

2015 to 2044 plus the appropriated 

number of years to account for the 

lifetime of the equipment purchased 

between 2015 and 2044.) In particular, 

the agency solicits comment on the 

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agency’s derivation of SCC values after 

2050 where the agency applied the 

average annual growth rate of the SCC 

estimates in 2040–2050 associated with 

each of the four sets of values. 

29. DOE solicits comment on whether 

its proposal presents a sufficiently broad 

scope of regulatory coverage to help 

ensure that significant energy savings 

would be met or whether further 

adjustments to the proposed scope— 

whether to exclude certain categories or 

to include others—are necessary. 

30. DOE requests comment on the 

nine characteristics listed in section 

III.C and their appropriateness for 

outlining scope of coverage. 

VIII. Approval of the Office of the 

Secretary 

The Secretary of Energy has approved 

publication of today’s proposed rule. 

List of Subjects in 10 CFR Part 431 

Administrative practice and 

procedure, Confidential business 

information, Energy conservation, 

Commercial and industrial equipment, 

Imports, Intergovernmental relations, 

Reporting and recordkeeping 

requirements, and Small businesses. 

Issued in Washington, DC, on November 

25, 2013. 

David T. Danielson, 

Assistant Secretary, Energy Efficiency and 

Renewable Energy. 

For the reasons set forth in the 

preamble, DOE proposes to amend part 

431 of chapter II of title 10 of the Code 

of Federal Regulations, as set forth 

below: 

PART 431—ENERGY CONSERVATION 

PROGRAM FOR CERTAIN 

COMMERCIAL AND INDUSTRIAL 

EQUIPMENT 

■ 1. The authority citation for part 431 

continues to read as follows: 

Authority: 42 U.S.C. 6291–6317 

■ 2. Revise § 431.25 to read as follows: 

§ 431.25 Energy conservation standards 

and effective dates. 

(a) Except as provided for fire pump 

electric motors in paragraph (b) of this 

section, each general purpose electric 

motor (subtype I) with a power rating of 

1 horsepower or greater, but not greater 

than 200 horsepower, including a 

NEMA Design B or an equivalent IEC 

Design N motor that is a general purpose 

electric motor (subtype I), manufactured 

(alone or as a component of another 

piece of equipment) on or after 

December 19, 2010, but before 

December 19, 2015, shall have a 

nominal full-load efficiency that is not 

less than the following: 

TABLE 1—NOMINAL FULL-LOAD EFFICIENCIES OF GENERAL PURPOSE ELECTRIC MOTORS (SUBTYPE I), EXCEPT FIRE

PUMP ELECTRIC MOTORS

Motor horsepower/

standard kilowatt 

equivalent 

Nominal full-load efficiency 

Open motors 

(number of poles) 

Enclosed motors 

(number of poles) 

6 4 2 6 4 2 

1 /.75 82.5 85.5 77.0 82.5 85.5 77.0 

1.5 /1.1 86.5 86.5 84.0 87.5 86.5 84.0 

2 /1.5 87.5 86.5 85.5 88.5 86.5 85.5 

3 /2.2 88.5 89.5 85.5 89.5 89.5 86.5 

5 /3.7 89.5 89.5 86.5 89.5 89.5 88.5 

7.5 /5.5 90.2 91.0 88.5 91.0 91.7 89.5 

10 /7.5 91.7 91.7 89.5 91.0 91.7 90.2 

15 /11 91.7 93.0 90.2 91.7 92.4 91.0 

20 /15 92.4 93.0 91.0 91.7 93.0 91.0 

25 /18.5 93.0 93.6 91.7 93.0 93.6 91.7 

30 /22 93.6 94.1 91.7 93.0 93.6 91.7 

40 /30 94.1 94.1 92.4 94.1 94.1 92.4 

50 /37 94.1 94.5 93.0 94.1 94.5 93.0 

60 /45 94.5 95.0 93.6 94.5 95.0 93.6 

75 /55 94.5 95.0 93.6 94.5 95.4 93.6 

100 /75 95.0 95.4 93.6 95.0 95.4 94.1 

125 /90 95.0 95.4 94.1 95.0 95.4 95.0 

150 /110 95.4 95.8 94.1 95.8 95.8 95.0 

200 /150 95.4 95.8 95.0 95.8 96.2 95.4 

(b) Each fire pump electric motor that 

is a general purpose electric motor 

(subtype I) or general purpose electric 

motor (subtype II) manufactured (alone 

or as a component of another piece of 

equipment) on or after December 19, 

2010, but before December 19, 2015, 

shall have a nominal full-load efficiency 

that is not less than the following: 

TABLE 2—NOMINAL FULL-LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Nominal full-load efficiency 

Open motors 

(number of poles) 

Enclosed motors 

(number of poles) 

8 6 4 2 8 6 4 2 

1 /.75 74.0 80.0 82.5 — 74.0 80.0 82.5 75.5 

1.5 /1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5 

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TABLE 2—NOMINAL FULL-LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS—Continued 

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Nominal full-load efficiency 

Open motors 

(number of poles) 

Enclosed motors 

(number of poles) 

8 6 4 2 8 6 4 2 

2 /1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0 

3 /2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5 

5 /3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5 

7.5 /5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5 

10 /7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5 

15 /11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2 

20 /15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2 

25 /18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0 

30 /22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0 

40 /30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7 

50 /37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4 

60 /45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0 

75 /55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0 

100 /75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6 

125 /90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5 

150 /110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5 

200 /150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0 

250 /186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4 

300 /224 — 95.4 95.4 95.0 — 95.0 95.4 95.4 

350 /261 — 95.4 95.4 95.0 — 95.0 95.4 95.4 

400 /298 — — 95.4 95.4 — — 95.4 95.4 

450 /336 — — 95.8 95.8 — — 95.4 95.4 

500 /373 — — 95.8 95.8 — — 95.8 95.4 

(c) Except as provided for fire pump 

electric motors in paragraph (b) of this 

section, each general purpose electric 

motor (subtype II) with a power rating 

of 1 horsepower or greater, but not 

greater than 200 horsepower, including 

a NEMA Design B or an equivalent IEC 

Design N motor that is a general purpose 

electric motor (subtype II), 

manufactured (alone or as a component 

of another piece of equipment) on or 

after December 19, 2010, but before 

December 19, 2015, shall have a 

nominal full-load efficiency that is not 

less than the following: 

TABLE 3—NOMINAL FULL-LOAD EFFICIENCIES OF GENERAL PURPOSE ELECTRIC MOTORS (SUBTYPE II), EXCEPT FIRE

PUMP ELECTRIC MOTORS

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Nominal full-load efficiency 

Open motors 

(number of poles) 

Enclosed motors 

(number of poles) 

8 6 4 2 8 6 4 2 

1 /.75 74.0 80.0 82.5 — 74.0 80.0 82.5 75.5 

1.5 /1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5 

2 /1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0 

3 /2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5 

5 /3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5 

7.5 /5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5 

10 /7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5 

15 /11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2 

20 /15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2 

25 /18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0 

30 /22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0 

40 /30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7 

50 /37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4 

60 /45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0 

75 /55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0 

100 /75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6 

125 /90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5 

150 /110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5 

200 /150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0 

(d) Each NEMA Design B or an 

equivalent IEC Design N motor that is a 

general purpose electric motor (subtype 

I) or general purpose electric motor 

(subtype II), excluding fire pump 

electric motors, with a power rating of 

more than 200 horsepower, but not 

greater than 500 horsepower, 

manufactured (alone or as a component 

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of another piece of equipment) on or 

after December 19, 2010, but before 

December 19, 2015 shall have a nominal 

full-load efficiency that is not less than 

the following: 

TABLE 4—NOMINAL FULL-LOAD EFFICIENCIES OF NEMA DESIGN B GENERAL PURPOSE ELECTRIC MOTORS (SUBTYPE I 

AND II), EXCEPT FIRE PUMP ELECTRIC MOTORS

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Nominal full-load efficiency 

Open motors 

(number of 

poles) 

Enclosed motors 

(number of poles) 

8 6 4 2 8 6 4 

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4 

300/224 — 95.4 95.4 95.0 — 95.0 95.4 95.4 

350/261 — 95.4 95.4 95.0 — 95.0 95.4 95.4 

400/298 — — 95.4 95.4 — — 95.4 95.4 

450/336 — — 95.8 95.8 — — 95.4 95.4 

500/373 — — 95.8 95.8 — — 95.8 95.4 

(e) For purposes of determining the 

required minimum nominal full-load 

efficiency of an electric motor that has 

a horsepower or kilowatt rating between 

two horsepower or two kilowatt ratings 

listed in any table of energy 

conservation standards in paragraphs (a) 

through (d) of this section, each such 

motor shall be deemed to have a listed 

horsepower or kilowatt rating, 

determined as follows: 

(1) A horsepower at or above the 

midpoint between the two consecutive 

horsepowers shall be rounded up to the 

higher of the two horsepowers; 

(2) A horsepower below the midpoint 

between the two consecutive 

horsepowers shall be rounded down to 

the lower of the two horsepowers; or 

(3) A kilowatt rating shall be directly 

converted from kilowatts to horsepower 

using the formula 1 kilowatt = (1/0.746) 

horsepower. The conversion should be 

calculated to three significant decimal 

places, and the resulting horsepower 

shall be rounded in accordance with 

paragraph (e)(1) or (2) of this section, 

whichever applies. 

(f) The standards in Table 1 through 

Table 4 of this section do not apply to 

definite purpose motors, special 

purpose motors, or those motors 

exempted by the Secretary. 

(g) The standards in Table 5 through 

Table 8 of this section apply to electric 

motors that satisfy the following criteria: 

(1) Are single-speed, induction 

motors; 

(2) Are rated for continuous duty (MG 

1) operation or for duty type S1 (IEC); 

(3) Contain a squirrel-cage (MG 1) or 

cage (IEC) rotor; 

(4) Operate on polyphase alternating 

current 60-hertz sinusoidal line power; 

(5) Are rated 600 volts or less; 

(6) Have a 2-, 4-, 6-, or 8-pole 

configuration, 

(7) Have a three-digit NEMA frame 

size (or IEC metric equivalent) or an 

enclosed 56 NEMA frame size (or IEC 

metric equivalent), 

(8) Are rated no more than 500 

horsepower, but greater than or equal to 

1 horsepower (or kilowatt equivalent), 

and 

(9) Meet all of the performance 

requirements of one of the following 

motor types: a NEMA Design A, B, or C 

motor or an IEC design N or H motor. 

(h) Starting on December 19, 2015, 

each NEMA Design A and NEMA 

Design B motor that is an electric motor 

meeting the criteria in paragraph (g) of 

this section and with a power rating 

from 1 horsepower through 500 

horsepower, but excluding fire pump 

electric motors, integral-brake electric 

motors, and non-integral brake electric 

motors, manufactured (alone or as a 

component of another piece of 

equipment) shall have a nominal fullload efficiency of not less than the 

following: 

TABLE 5—NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS

[Excluding fire pump electric motors, integral-brake electric motors, and non-integral brake electric motors] 

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

1 /.75 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5 

1.5 /1.1 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0 

2 /1.5 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5 

3 /2.2 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5 

5 /3.7 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5 

7.5 /5.5 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5 

10 /7.5 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2 

15 /11 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2 

20 /15 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0 

25 /18.5 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0 

30 /22 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7 

40 /30 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7 

50 /37 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4 

60 /45 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0 

75 /55 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1 

100 /75 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1 

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73680 Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 

TABLE 5—NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS— 

Continued 

[Excluding fire pump electric motors, integral-brake electric motors, and non-integral brake electric motors] 

Motor 

horsepower/ 

standard kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

125 /90 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1 

150 /110 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1 

200 /150 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1 

250 /186 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0 

300 /224 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0 

350 /261 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0 

400 /298 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0 

450 /336 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0 

500 /373 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0 

(i) Starting on December 19, 2015, 

each NEMA Design C electric motor that 

is an electric motor meeting the criteria 

in paragraph (g) of this section and with 

a power rating from 1 horsepower 

through 200 horsepower, but excluding 

non-integral brake electric motors and 

integral brake electric motors, 

manufactured (alone or as a component 

of another piece of equipment) shall 

have a nominal full-load efficiency that 

is not less than the following: 

TABLE 6—NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN C ELECTRIC MOTORS

[excluding non-integral brake electric motors and integral brake electric motors] 

Motor horsepower/standard kilowatt equivalent 

Nominal Full Load Efficiency (%) 

4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................................................................. 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .............................................................................. 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ................................................................................. 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ................................................................................. 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ................................................................................. 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .............................................................................. 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ............................................................................... 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ................................................................................ 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ................................................................................ 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ............................................................................. 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ................................................................................ 93.6 94.1 93.0 93.6 91.7 91.7 

40/30 ................................................................................ 94.1 94.1 94.1 94.1 91.7 91.7 

50/37 ................................................................................ 94.5 94.5 94.1 94.1 92.4 92.4 

60/45 ................................................................................ 95.0 95.0 94.5 94.5 92.4 93.0 

75/55 ................................................................................ 95.4 95.0 94.5 94.5 93.6 94.1 

100/75 .............................................................................. 95.4 95.4 95.0 95.0 93.6 94.1 

125/90 .............................................................................. 95.4 95.4 95.0 95.0 94.1 94.1 

150/110 ............................................................................ 95.8 95.8 95.8 95.4 94.1 94.1 

200/150 ............................................................................ 96.2 95.8 95.8 95.4 94.5 94.1 

(j) Starting on December 19, 2015, 

each fire pump electric motor meeting 

the criteria in paragraph (g) of this 

section and with a power rating of 1 

horsepower through 500 horsepower, 

manufactured (alone or as a component 

of another piece of equipment) shall 

have a nominal full-load efficiency that 

is not less than the following: 

TABLE 7—NOMINAL FULL LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS

Motor horsepower/ 

standard kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................. 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0 

1.5/1.1 .............................. 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5 

2/1.5 ................................. 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5 

3/2.2 ................................. 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5 

5/3.7 ................................. 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5 

7.5/5.5 .............................. 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5 

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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules 73681 

TABLE 7—NOMINAL FULL LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS—Continued 

Motor horsepower/ 

standard kilowatt 

equivalent 

Nominal full load efficiency (%) 

2 Pole 4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open Enclosed Open 

10/7.5 ............................... 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5 

15/11 ................................ 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5 

20/15 ................................ 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2 

25/18.5 ............................. 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2 

30/22 ................................ 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0 

40/30 ................................ 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0 

50/37 ................................ 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7 

60/45 ................................ 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4 

75/55 ................................ 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6 

100/75 .............................. 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6 

125/90 .............................. 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6 

150/110 ............................ 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6 

200/150 ............................ 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6 

250/186 ............................ 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5 

300/224 ............................ 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5 

350/261 ............................ 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5 

400/298 ............................ 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5 

450/336 ............................ 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5 

500/373 ............................ 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5 

(k) Starting on December 19, 2015, 

each integral brake electric motor and 

non-integral brake electric motor 

meeting the criteria in paragraph (g) of 

this section, and with a power rating of 

1 horsepower through 30 horsepower, 

manufactured (alone or as a component 

of another piece of equipment) shall 

have a nominal full-load efficiency that 

is not less than the following: 

TABLE 8—NOMINAL FULL LOAD EFFICIENCIES OF INTEGRAL BRAKE ELECTRIC MOTORS AND NON-INTEGRAL BRAKE

ELECTRIC MOTORS

Motor horsepower/standard kilowatt equivalent 

Nominal full load efficiency (%) 

4 Pole 6 Pole 8 Pole 

Enclosed Open Enclosed Open Enclosed Open 

1/.75 ................................................................................. 85.5 85.5 82.5 82.5 75.5 75.5 

1.5/1.1 .............................................................................. 86.5 86.5 87.5 86.5 78.5 77.0 

2/1.5 ................................................................................. 86.5 86.5 88.5 87.5 84.0 86.5 

3/2.2 ................................................................................. 89.5 89.5 89.5 88.5 85.5 87.5 

5/3.7 ................................................................................. 89.5 89.5 89.5 89.5 86.5 88.5 

7.5/5.5 .............................................................................. 91.7 91.0 91.0 90.2 86.5 89.5 

10/7.5 ............................................................................... 91.7 91.7 91.0 91.7 89.5 90.2 

15/11 ................................................................................ 92.4 93.0 91.7 91.7 89.5 90.2 

20/15 ................................................................................ 93.0 93.0 91.7 92.4 90.2 91.0 

25/18.5 ............................................................................. 93.6 93.6 93.0 93.0 90.2 91.0 

30/22 ................................................................................ 93.6 94.1 93.0 93.6 91.7 91.7 

(l) For purposes of determining the 

required minimum nominal full-load 

efficiency of an electric motor that has 

a horsepower or kilowatt rating between 

two horsepower or two kilowatt ratings 

listed in any table of energy 

conservation standards in paragraphs 

(h) through (k) of this section, each such 

motor shall be deemed to have a listed 

horsepower or kilowatt rating, 

determined as follows: 

(1) A horsepower at or above the 

midpoint between the two consecutive 

horsepowers shall be rounded up to the 

higher of the two horsepowers; 

(2) A horsepower below the midpoint 

between the two consecutive 

horsepowers shall be rounded down to 

the lower of the two horsepowers; or 

(3) A kilowatt rating shall be directly 

converted from kilowatts to horsepower 

using the formula 1 kilowatt = (1/0.746) 

horsepower. The conversion should be 

calculated to three significant decimal 

places, and the resulting horsepower 

shall be rounded in accordance with 

paragraph (l)(1) or (2) of this section, 

whichever applies. 

(m) The standards in Table 5 through 

Table 8 of this section do not apply to 

the following electric motors exempted 

by the Secretary, or any additional 

electric motors that the Secretary may 

exempt: 

(1) Air-over electric motors; 

(2) Component sets of an electric 

motor; 

(3) Liquid-cooled electric motors; 

(4) Submersible electric motors; and 

(5) Definite-purpose, inverter-fed 

electric motors. 

[FR Doc. 2013–28776 Filed 12–5–13; 8:45 am] 

BILLING CODE 6450–01–P 

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