1 | Energy Efficiency and Renewable Energy eere.energy.gov

April 29, 2015

Ashley Armstrong

Department of Energy

Building Technologies Program

EERE-2013-BT-TP-0055

Pumps2013TP0055@ee.doe.gov 

Notice of Proposed 

Rulemakings for Pumps

Test Procedure and Standards
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of 

this meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar 

conversations.

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Agenda – Morning (TP)

1) 9:00 AM Introductions & Stakeholder Opening Statements

2) 9:30 AM Regulatory History & Scope

3) 10:00 AM Metric

4) 10:30 AM Test Procedure: Determination of Pump Performance

5) 11:00 AM Break

6) 11:15 AM Test Procedure: Determination of Driver Efficiency

7) 11:45 AM Test Procedure: Calculation & Testing Based Methods

8) 12:30 PM Test Procedure: Sampling Plan

9) 12:45 PM Test Procedure: Burden

10) 1:00 PM Lunch
4

Agenda – Afternoon (ECS)

1) 2:00 PM Welcome, Introductions, Opening Statements

2) 2:10 PM Overview, Scope, Market and Technology Assessment, 

Screening Analysis

3) 2:30 PM Engineering Analysis

4) 3:00 PM Energy Use, Markup Analysis, Life-Cycle Cost and Payback 

Period Analysis

5) 3:40 PM Break

6) 3:50 PM Shipments, National Impact Analysis

7) 4:20 PM Manufacturer Impact Analysis

8) 4:35 PM Utility Impact Analysis, Employment Impact Analysis, 

Emissions Analysis, Regulatory Impact Analysis

9) 4:45 PM Closing Remarks
5

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
6

Public Meeting Slide Topics – Afternoon (ECS)

1 Overview

2 Market & Technology; Screening

3 Engineering

4 Markups Analysis; Energy Use

5 Life-Cycle Cost & Payback Period Analysis

6 Shipments; National Impact Analysis

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
7

Listening Via the Webcast

• DOE is broadcasting this meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders 

who are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
8

Purpose of the Public Meeting

• Present DOE’s proposed test procedure and energy conservation 

standards for pumps.

– Morning = Test Procedure Notice of Proposed Rulemaking (NOPR)

– Afternoon = Energy Conservation Standards NOPR

• Discuss next steps in the rulemakings.

• Invite comment on: 

– the test procedure NOPR;

– the energy conservation standard NOPR; and

– any additional issues raised by interested parties. 
9

Opening Remarks

Meeting participants are invited to provide opening remarks or 

statements at this time.
10

• DOE welcomes comments, data, and information concerning 

its proposed test procedure and energy conservation 

standards for pumps. Whether invited by an issue box or not, 

comments are welcome on any part of DOE’s analysis. 

• Issue boxes are not included for the energy conservation 

standard section of this presentation, as the analysis was 

discussed with the Working Group and directly supports 

their Recommendations.

Issues for Discussion

Issue Box: Issue boxes in the test procedure section of 

this presentation correspond to the list of issues 

published at the end of the NOPR document. These 

issues will be numbered corresponding to the numbers 

presented in section V.E of the pumps test procedure 

NOPR.
11

How to Submit Written Comments

In all correspondence, please refer to these pumps rulemakings by:

Postal: Courier

Ms. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies Program, Suite 600

Mailstop EE-2J 950 L’Enfant Plaza, SW

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585-0121 Tel: 202 586-2945

Title Pumps Test Procedure Pumps Energy Conservation 

Standard

Docket Number: EERE-2013-BT-TP-0055 EERE-2011-BT-STD-0031

Regulation 

Identification 

Number (RIN):

1904-AD50 1904-AC54

Email: Pumps2013TP0055@ee.doe.gov Pumps2011STD0031@ee.doe.gov

Comments Due: June 15, 2015, 11:59 PM ET June 1, 2015, 11:59 PM ET
12

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
13

Statutory Authority

• The Energy Policy and Conservation Act (EPCA) of 1975 

established an energy conservation program for certain 

commercial and industrial equipment. 

– This program includes pumps as covered equipment. (42 U.S.C. 6311(1)(A))

– EPCA authorizes DOE to issue standards, test procedures, and labeling 

requirements for covered equipment. (42 U.S.C. 6295(r), 42 U.S.C. 6315(a), 

42 U.S.C. 6316(a)(1))

• Manufacturers must use the test procedure as the basis for:

– Certifying to DOE that their equipment complies with applicable energy 

conservation standards adopted under EPCA. (42 U.S.C. 6295(s) and 

6316(a)(1)), and

– Making representations about the energy consumption of the equipment. 

(42 U.S.C. 6314(d))
14

Regulatory History: Pumps

• There are currently no Federal energy conservations standards or 

test procedures for pumps.

• On June 13, 2011, DOE issued a Request for Information (RFI) to 

gather information related to pumps. 76 FR 34192. 

• On February 1, 2013, DOE published a Framework document 

discussing potential methodologies for considering new energy 

conservation standards and a new test procedure for pumps. 78 FR 

7304.

• On July 23, 2013, DOE issued a notice of intent to form a Working 

Group under the Appliance Standards Rulemaking Federal Advisory 

Committee (ASRAC) to negotiate energy conservation standards for 

pumps (Commercial and Industrial Pumps [Pumps] Working Group). 

78 FR 44036.
15

Pumps Working Group Membership

Member Affiliation

Lucas Adin U.S. Department of Energy

Tom Eckman Northwest Power and Conservation Council (ASRAC Member)

Robert Barbour TACO, Inc.

Charles Cappelino ITT Industrial Process

Greg Case Pump Design, Development and Diagnostics

Gary Fernstrom Pacific Gas & Electric Company, San Diego Gas & Electric Company, 

Southern California Edison, and Southern California Gas Company

Mark Handzel Xylem Corporation

Albert Huber Patterson Pump Company

Joanna Mauer Appliance Standards Awareness Project

Doug Potts American Water

Charles Powers Flowserve Corporation, Industrial Pumps

Howard Richardson Regal Beloit

Steve Rosenstock Edison Electric Institute

Louis Starr Northwest Energy Efficiency Alliance

Greg Towsley Grundfos USA

Meg Waltner Natural Resources Defense Council

• The members of the Pumps Working Group were selected to 

ensure a broad and balanced representation of stakeholder 

interests.
16

Regulatory History: Pumps Working Group

• Between December 2013 and June 2014, DOE held seven open meetings 

and two webinars to discuss scope, metrics, test procedures, and standard 

levels for pumps.

– Details of the negotiation sessions and related materials can be found in the 

docket for the Working Group 

(http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-NOC-0039).

• The Pumps Working Group concluded on June 19, 2014, producing 14 

recommendations for DOE related to pump energy conservation standards 

and the pump test procedure (Working Group Recommendations).

– ASRAC voted unanimously to approve the Working Group Recommendations 

during a July 7, 2014 webinar.

• DOE’s proposed pumps test procedure reflects the Working Group 

Recommendations. 

– Additional details are discussed in this presentation.

• DOE’s proposed energy conservation standards directly reflect the Working 

Group Recommendations.
17

Pumps Test Procedure Rulemaking

• NOPR issued by DOE on March 13, 2015

– NOPR published in the Federal Register on April 1, 2015 (80 FR 17586)

– NOPR Public Meeting today, April 29, 2015

• Comments on NOPR from interested parties accepted until June 15, 2015.

– DOE reviews and considers all written and oral comments

• Transcript records oral comments from today’s public meeting

• Written comments

• Final Rule is expected to be issued by December 2015. 

NOPR Final

Rule
18

Scope of Covered Equipment

• “Pump” is listed as a type of covered 

equipment under EPCA, but is not 

defined.

• Defining “pump” characterizes the 

overall scope of coverage for pumps that 

can be considered in current and future 

rulemakings.

• The proposed energy conservation 

standards and test procedure are 

limited to an identical and more narrow 

range of equipment.

“Pump” as Covered 

Equipment

Pumps Subject 

to Standards 

and TP in these 

Rulemakings

Issue 1: DOE requests comment on its 

proposal to match the scopes of the pump test 

procedure and energy conservation standard 

rulemakings, as recommended by the Working 

Group.

Pumps Working Group Recommendation # 4 and 6-8
19

Pump Configurations

Bare Pump Bare Pump + Driver Bare Pump + Driver + Controls

• Pump means equipment that is designed to move liquids (which 

may include entrained gases, free solids, and totally dissolved 

solids) by physical or mechanical action, and includes a bare 

pump and, if included by the manufacturer at the time of sale, 

mechanical equipment, driver, and controls. 

Proposed Definition of Pump Bare Pump

Pumps Working Group Recommendation # 1 (with slight modification)

Driver

Bare 

Pump

Control Driver

Bare 

Pump
20

• DOE is also proposing definitions related to the components 

that comprise a pump, as recommended by the Working Group:

– Bare pump means a pump excluding mechanical equipment, driver, and 

controls. 

– Mechanical equipment means any component of a pump that transfers 

energy from a driver to the bare pump.

– Driver means the machine providing mechanical input to drive a bare 

pump directly or through the use of mechanical equipment. Examples 

include, but are not limited to, an electric motor, internal combustion 

engine, or gas/steam turbine. 

– Control means any device that can be used to operate the driver. 

Examples include, but are not limited to, continuous or noncontinuous speed controls, schedule-based controls, on/off switches, 

and float switches.

Proposed Definitions of Pumps Components

Pumps Working Group Recommendation # 2 (with slight modification)

Issue 2: DOE requests comment on the 

proposed definitions for ‘‘pump,’’ ‘‘bare pump,’’ 

‘‘mechanical equipment,’’ ‘‘driver,’’ and ‘‘control.’’
21

Proposed Pump-Specific Definition of a Basic Model

• DOE proposes the following pump-specific definition for basic model:

– Basic model means all units of a given type of covered equipment (or class thereof) 

manufactured by one manufacturer, having the same primary energy source, and 

having essentially identical electrical, physical, and functional (or hydraulic) 

characteristics that affect energy consumption, energy efficiency, water 

consumption, or water efficiency; except that: 

• RSV* and VTS** pump models for which the bare pump differs in the number of stages 

must be considered a single basic model, and 

• pump models for which the bare pump differs in impeller diameter, or impeller trim, may 

be considered a single basic model or separate basic models.

• The certified ratings for a given pump basic model will be based on the 

specified numbers of stages required for testing under the test procedure and 

on that model’s full impeller diameter.

– Variations in motor sizing as a result of different impeller trims would not be a basis 

for differentiating basic models.

Pumps Working Group Recommendations # 7, 14

* RSV = Radially split, multi-stage, vertical, in-line diffuser casing pump 

** VTS = Vertical turbine submersible pump
22

Proposed Definition of Full Impeller

• DOE proposes a definition of full impeller that would: 

– apply to all pump models, including custom pumps and those that are 

only distributed in commerce with trimmed impellers, and

– allow manufacturers the flexibility to rate a model with a trimmed 

impeller as less consumptive than at full impeller, if desired.

• Full impeller diameter means [either]:

(1) the maximum diameter impeller used with a given pump basic model 

distributed in commerce or 

(2) the maximum diameter impeller referenced in the manufacturer’s 

literature for that pump basic model, 

whichever is larger.

Issue 7: DOE requests comment on the proposed definition for ‘‘full 

impeller.’’

Pumps Working Group Recommendations # 7 (with slight modification)
23

Basic Model for Pumps Sold with Motors

• Manufacturers often pair a given bare pump with several different motors of 

varying performance characteristics.

• To rate these pump and motor combinations, manufacturers may:

– rate each pairing of a bare pump at full impeller with a motor as a unique basic 

model, OR

– group multiple motor pairings with the same bare pump at full impeller into a 

single basic model.

Pump and Motor 

Combinations

Driver 

Performance

Energy Rating

Multiple Basic Models Single Basic Model

Highest Efficiency Highest Efficiency

Middle Efficiency Middle Efficiency Lowest Efficiency

Lowest Efficiency Lowest Efficiency

Driver A

Bare 

Pump

Driver B

Bare 

Pump

Driver C

Bare 

Pump
24

Requests for Comment

Issue 6: DOE requests comment on DOE’s proposal to allow 

manufacturers the option of rating pumps with trimmed impellers as a 

single basic model or separate basic models, provided the rating for 

each pump model is based on the maximum impeller diameter 

available within that basic model.

Issue 8: DOE requests comment on the proposal to require that all 

pump models be rated in a full impeller configuration only.
25

Pump Categories

ESCC

Rotodynamic Pumps

Rotodynamic Pumps 

Subject to TP and 

Standards

Radial-Split

Horizontal

Positive 

Displacement

Vertical Turbine

DedicatedPurpose Pool

Axial Split 

Multi-Stage

Immersible Double Suction

Circulator

Mixed/Axial

ESFM

VTS

RSV

IL

Pumps

Pumps Working Group Recommendations #5A, 5B, 6

• DOE proposes that the test procedure and energy conservation standards 

are applicable to certain categories of rotodynamic pumps.

ESCC
26

Rotodynamic Pumps Subject to Proposed TP and Standards

Equipment Class Acronym HI Nomenclature

 

(A)

End Suction Close-Coupled ESCC OH7

 

(A)

End Suction Frame Mounted ESFM OH0,OH1

 

(A)

In-Line IL OH3, OH4, OH5

 

(B)

Radially Split, Multi-Stage,

Vertical, Inline Diffuser Casing RSV VS8

 

(B)

Vertical Turbine Submersible VTS VS0

Note: Pump diagrams provided by HI. 

Source: (A) 2014 version of ANSI/HI Standard 1.1-1.2, “Rotodynamic (Centrifugal) Pumps For Nomenclature And 

Definitions” (ANSI/HI 1.1-1.2–2014) or (B) 2008 version of ANSI/HI Standard 2.1-2.2, “Rotodynamic (Vertical) 

Pumps For Nomenclature And Definitions” (ANSI/HI 2.1-2.2–2008). 

Pumps Working Group Recommendation #4
27

Proposed Definitions of Pump Classes: Method

• DOE developed proposed definitions for the five pump 

equipment classes to accomplish the following:

– Cleary identify the equipment that would be subject to the standards 

and test procedure.

• DOE referenced HI nomenclature in the definitions as requested by 

stakeholders.

– Create mutually exclusive equipment classes, e.g. ESCC versus ESFM.

– Make the equipment classes mutually exclusive from other pumps not 

proposed to be part of this rulemaking, for example:

• ESCC, ESFM, and IL versus circulators;

• ESCC and ESFM versus dedicated-purpose pool pumps; and

• RSV versus immersible pumps.

• DOE also proposed definitions for rotodynamic pump, end 

suction pump, and single axis flow pump to support the 

equipment class definitions.
28

Add’l Proposed Definitions Related to Pump Equipment Classes

• Rotodynamic pump means a pump in which energy is 

continuously imparted to the pumped fluid by means of a 

rotating impeller, propeller, or rotor.

• End suction pump means a single-stage, rotodynamic pump in 

which the liquid enters the bare pump in a direction parallel to 

the impeller shaft and on the side opposite the bare pump’s 

driver-end. The liquid is discharged through a volute in a plane 

perpendicular to the shaft.

• Single axis flow pump means a pump in which the liquid inlet of 

the bare pump is on the same axis as the liquid discharge of the 

bare pump.
29

Proposed Definitions of Pump Equipment Classes (1)

• End suction close-coupled (ESCC) pump means an end suction pump in which: 

(1) the motor shaft also serves as the impeller shaft for the bare pump; 

(2) the pump requires attachment to a rigid foundation to function as designed

and cannot function as designed when supported only by the supply and discharge 

piping to which it is connected; and 

(3) the pump does not include a basket strainer.

– Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature OH7, as described 

in ANSI/HI 1.1–1.2–2014.

• End suction frame mounted (ESFM) pump means an end suction pump where: 

(1) the bare pump has its own impeller shaft and bearings and does not rely on the motor 

shaft to serve as the impeller shaft; 

(2) the pump requires attachment to a rigid foundation to function as designed and cannot 

function as designed when supported only by the supply and discharge piping to which it is 

connected; and 

(3) the pump does not include a basket strainer. 

– Examples include, but are not limited to, pumps complying with ANSI/HI 

nomenclature OH0 and OH1, as described in ANSI/HI 1.1–1.2–2014.

• In-line (IL) pump means a single-stage, single axis flow, rotodynamic pump in which: 

(1) liquid is discharged through a volute in a plane perpendicular to the impeller shaft; and 

(2) the pump requires attachment to a rigid foundation to function as designed and cannot 

function as designed when supported only by the supply and discharge piping to which it is 

connected. 

– Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature OH3, OH4, or OH5, 

as described in ANSI/HI 1.1–1.2–2014.

To exclude 

circulators

To exclude dedicatedpurpose pool pumps
30

Proposed Definitions of Pump Equipment Classes (2)

• Radially split, multi-stage, vertical, inline diffuser casing (RSV) pump means 

a vertically suspended, multi-stage, single axis flow, rotodynamic pump in 

which: 

(1) liquid is discharged in a plane perpendicular to the impeller shaft, 

(2) each stage (or bowl) consists of an impeller and diffuser, and 

(3) no external part of such a pump is designed to be submerged 

in the pumped liquid. 

– Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature 

VS8, as described in ANSI/HI 2.1–2.2–2008.

• Vertical turbine submersible (VTS) pump means a single-stage or multistage 

rotodynamic pump that is designed to be operated with the motor and 

stage(s) (or bowl(s)) fully submerged in the pumped liquid, and in which: 

(1) each stage of this pump consists of an impeller and diffuser, and 

(2) liquid enters and exits each stage of the bare pump in a direction parallel 

to the impeller shaft. 

– Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature 

VS0, as described in ANSI/HI 2.1–2.2–2008.

To exclude 

immersible
31

Requests for Comment

Issue 10: DOE requests comment on its application of the proposed 

test procedure to the five listed pump equipment classes.

Issue 11: DOE requests comment on the proposed definitions for the 

five equipment classes.

Issue 12: DOE requests comment on whether the references to 

ANSI/HI nomenclature are (1) necessary as part of the equipment 

definitions in the regulatory text or (2) likely to cause confusion 

because of inconsistencies. DOE also seeks comment on whether 

discussing the ANSI/HI nomenclature in this preamble would provide 

sufficient reference material for manufacturers when determining the 

appropriate equipment class for their pump models. 
32

Requests for Comment

Issue 13: DOE requests comment on whether it needs to clarify the 

flow direction to distinguish RSV pumps from other similar pumps 

when determining test procedure and standards applicability.

Issue 14: DOE requests comment on whether any additional 

language in the RSV definition is necessary to make the exclusion of 

immersible pumps clearer.

Issue 17: DOE is interested in whether any pumps commonly 

referred to as ESCC, ESFM, or IL do not require attachment to a rigid 

foundation to function as designed.
33

Circulators and Pool Pumps

• The Pumps Working Group recommended that circulator pumps and 

dedicated-purpose pool pumps be addressed as part of separate rulemakings.

• To distinguish between circulator and dedicated-purpose pool pumps, DOE 

proposed design-based definitions:

– Circulator means a pump that: 

(1) is either an end suction pump or a single-stage, 

single-axis flow, rotodynamic pump; and 

(2) has a pump housing that only requires the support of the 

supply and discharge piping to which it is connected (without 

attachment to a rigid foundation) to function as designed. 

• Examples include, but are not limited to, pumps complying with ANSI/HI nomenclature 

CP1, CP2, or CP3, as described in ANSI/HI 1.1–1.2– 2014.

– Dedicated-purpose pool pump means an end suction pump 

designed specifically to circulate water in a pool and 

that includes an integrated basket strainer.

• If mutually exclusive through design, a size-based 

threshold is unnecessary. 

Pumps Working Group Recommendations # 5A, 5B

Use of only pipemounted support 

provides clear and 

unambiguous 

differentiation from 

pumps in this 

rulemaking.

Use of integrated basket 

strainer as design 

feature differentiating 

from pumps in this 

rulemaking.

Issue 16: DOE also requests comment on the proposed 

definitions for circulators and dedicated-purpose pool pumps.
34

Axial/Mixed Flow and Positive Displacement Pumps

Issue 18: DOE requests comment on its initial determination that axial/mixed 

flow and PD pumps are implicitly excluded from this rulemaking based on the 

proposed definitions and scope parameters. In cases where commenters 

suggest a more explicit exclusion be used, DOE requests comment on the 

appropriate changes to the proposed definitions or criteria that would be 

needed to appropriately differentiate axial/mixed flow and/or PD pumps from 

the specific rotodynamic pump equipment classes proposed for coverage in 

this NOPR.

• The Pumps Working Group recommended excluding axial/mixed flow 

and positive displacement pumps from the current rulemakings.

• DOE believes that the proposed definitions and scope parameters 

implicitly exclude these pump types.

Pumps Working Group Recommendation #6
35

Definition of Clean Water Pump

• DOE proposed to limit the 

scope of the test procedure 

and energy conservation 

standards to clean water 

pumps, defined as follows:

– Clean water pump means a pump 

that is designed for use in 

pumping water with a maximum 

non-absorbent free solid content 

of 0.25 kilograms per cubic meter, 

and with a maximum dissolved 

solid content of 50 kilograms per 

cubic meter, provided that the 

total gas content of the water 

does not exceed the saturation 

volume, and disregarding any 

additives necessary to prevent 

the water from freezing at a 

minimum of -10 °C.

Pumps

Clean Water Pumps

Wastewater Chemical Process 

Hydrocarbon (ASME B73.1)

(API 610)

Fire

Sump

Solids

Handling

Slurry

Sanitary (3A 

02-11)

SelfPriming

PrimeAssist

Sealless

Nuclear 

Facility

MILSPEC

Clean Water 

Pumps In 

Rulemaking

Pumps Working Group Recommendation #8

Issue 19: DOE requests comment on the 

proposed definition for ‘‘clean water pump.’’

Fire Pump
36

Requests for Comment

Issue 21: DOE requests comment on the proposed definition for ‘‘fire pump,’’ ‘‘selfpriming pump,’’ ‘‘prime-assisted pump,’’ and ‘‘sealless pump.’’

Issue 22: Regarding the proposed definition of a self-priming pump, DOE notes that 

such pumps typically include a liquid reservoir above or in front of the impeller to allow 

recirculating water within the pump during the priming cycle. DOE requests comment on 

any other specific design features that enable the pump to operate without manual repriming, and whether such specificity is needed in the definition for clarity.

Issue 23: DOE requests comment on the proposed specifications and criteria to 

determine if a pump is designed to meet a specific Military Specification and if any Military 

Specifications other than MIL–P–17639F should be referenced.

Issue 24: DOE requests comment on excluding the following pumps from the test 

procedure: Fire pumps, self-priming pumps, prime-assist pumps, sealless pumps, pumps 

designed to be used in a nuclear facility, and pumps meeting the design and construction 

requirements set forth in Military Specification MIL–P–17639F.
37

Proposed Pump Parameters

• DOE proposes to further limit the test procedure and energy 

conservation standards to:

– pumps with the following performance and design characteristics:

– And pumps designed to operate with the following styles of motors:

Pumps Working Group Recommendation #7 (with modification)

Parameter Criteria

Shaft Power at the Best Efficiency Point, BEP*, at Full Impeller Diameter 

for the Number of Stages Required for Testing to the Standard

1–200 hp 

BEP Flow Rate at Full Impeller Diameter ≥25 gpm 

Head at BEP at Full Impeller Diameter ≤459 feet

Design Temperature -10 to 120 °C

Bowl Diameter for VTS Pumps (HI VS0) ≤6 inches

Style of Motor Nominal Speed of Rotation 

for Rating (at 60 Hz)

2-Pole Induction Motor 3,600 rpm

4-Pole Induction Motor 1,800 rpm

Non-Induction Motor Designed to Operate Between 2,880 and 4,320 rpm 3,600 rpm

Non-Induction Motor Designed to Operate Between 1,440 and 2,160 rpm 1,800 rpm
38

Proposed Definition of Bowl Diameter

Issue 25: DOE requests comment on the listed design 

characteristics (i.e., power, flow, head, design temperature, design 

speed, and bowl diameter) as limitations on the scope of pumps to 

which the proposed test procedure would apply.

Issue 26: DOE requests comment on the proposed definition for 

‘‘bowl diameter’’ as it would apply to VTS pumps.

• To ensure consistent application of the design criteria related to bowl 

diameter, DOE proposes to define bowl diameter as follows:

– Bowl diameter means the maximum dimension of an imaginary straight line 

passing through and in the plane of the circular shape of the intermediate 

bowl or chamber of the bare pump that is perpendicular to the pump shaft 

and that intersects the circular shape of the intermediate bowl or chamber 

of the bare pump at both of its ends, where the intermediate bowl or 

chamber is as defined in ANSI/HI 2.1–2.2–2008.
39

• The proposed test procedure and energy conservation standards would 

apply to pumps in three main configurations:

• However, the appropriate and applicable test method(s) will depend on the 

style of driver and control with which the pump is being rated:

Pump Configurations

Non-Electric

Driver

Single-Phase

Induction 

Motor

Covered 

Poly-Phase 

Electric Motor

Non-Covered

Poly-Phase

Electric Motor

Submersible

Motor

Continuous

Control

Non-Continuous

Control

Controls

Other than

Continuous or 

Non-Continuous

Driver

Bare Pump Bare Pump + Driver Bare Pump + Driver + Controls Bare Pump

Driver

Bare 

Pump

Control Driver

Bare 

Pump

Control
40

• DOE is primarily concerned with controls that reduce pump power input at a 

given flow rate, specifically continuous and non-continuous controls:

Proposed Control Category Definitions

• Continuous control means a control that 

adjusts the speed of the pump driver 

continuously over the driver operating speed 

range in response to incremental changes in 

the required pump flow, head, or power 

output. 

• Non-continuous control means a control that 

adjusts the speed of a driver to one of a 

discrete number of non-continuous preset 

operating speeds, and does not respond to 

incremental reductions in the required pump 

flow, head, or power output. 

“Control” as Part of Covered 

Equipment

Controls that Reduce 

Energy Consumption

On/Off 

Switch

Float 

Switch Schedule-Based

VFD

ECM

Multi-Speed 

Motor

Continuous 

Controls Non-Continuous 

Controls

Issue 3: DOE requests comment on the proposed definitions 

for ‘‘continuous control’’ and ‘‘non-continuous control.’’
41

Rated As Test 

Method Applicable Pump Configurations

Bare 

Pump

Calculation

-Based 

Only

Pump + 

Motor

TestingBased Only

TestingBased or 

Calculation

-Based

Pump + 

Motor +

Controls

TestingBased Only

TestingBased or 

Calculation

-Based

Rating Covered Pump Configurations

Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Electric

Driver

Bare 

Pump

Single-Phase

Induction 

Bare 

Pump

Motor

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor

Non-Continuous

Control

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor

Non-Continuous

Control

Bare 

Pump

Non-Covered

Poly-Phase 

Electric Motor

Continuous or 

Non-Continuous

Control

Bare 

Pump

Submersible

Motor

Bare 

Pump

Non-Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Pumps Working Group 

Recommendation #3 

(Non-Electric Drivers)

Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Submersible 

Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump
42

Requests for Comment

Issue 27: DOE requests comment on its proposal to test pumps 

sold with non-electric drivers as bare pumps.

Issue 28: DOE requests comment on its proposal that any pump 

distributed in commerce with a single-phase induction motor be 

tested and rated in the bare pump configuration, using the 

calculation method.

Issue 29: DOE requests comment from interested parties on any 

other categories of electric motors, except submersible motors, 

that: (1) are used with pumps considered in this rulemaking and 

(2) typically have efficiencies lower than the default nominal fullload efficiency for NEMA Design A, NEMA Design B, or IEC 

Design N motors.
43

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
44

Proposed Rating Metric

Pump Energy Index Constant Load Pump Energy 

Index (PEICL)

Variable Load Pump Energy Index 

(PEIVL)

Ratio

Pump Energy Rating

 * *

PER Load Profile i = 75, 100, and 110% 

of BEP Flow

i = 25, 50, 75, and 100%

of BEP Flow

PERSTD

PERCL for Minimally Compliant Pump of the Same Equipment Class 

Serving the Same Hydraulic Load 

Applicable Pump 

Configurations

Pumps Sold without Continuous 

or Non-Continuous Controls

Pumps Sold with Continuous or 

Non-Continuous Controls

*Where: wi = weight at each load point i

P

in

i = power input to the “pump” at the driver, inclusive of the controls if present, (hp)

i = Percentage of flow at the Best Efficiency Point (BEP) of the pump

PEICL =

PERCL

PERSTD

PEIVL =

PERVL

PERSTD

PERCL = ωi P

in

i

i

PERVL = ωi P

in

i

i

Pumps Working Group Recommendation #11
45

Metric Rated As Test 

Method Applicable Pump Configurations

PEICL

Bare 

Pump

CalculationBased Only

Pump + 

Motor

TestingBased Only

TestingBased or 

CalculationBased

PEIVL

Pump + 

Motor +

Controls

TestingBased Only

TestingBased or 

CalculationBased

Proposed Rating Metric Based on Pump Configuration

Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Electric

Driver

Bare 

Pump

Single-Phase

Induction 

Bare 

Pump

Motor

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor

Non-Continuous

Control

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor

Non-Continuous

Control

Bare 

Pump

Non-Covered

Poly-Phase 

Electric Motor

Continuous or 

Non-Continuous

Control

Bare 

Pump

Submersible

Motor

Bare 

Pump

Non-Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Submersible 

Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump
46

Issue 30: DOE requests comment on the proposed load points and 

weighting for PEICL for bare pumps and pumps sold with motors and 

PEIVL for pumps inclusive of motors and continuous or non-continuous 

controls.

Issue 31: DOE requests comments on the proposed PEICL and PEIVL

metric architecture.

Requests for Comment
47

Determining PEI

• The PEI represents the performance of the pump, motor, and 

controls, if present.

Metric Rated As Test 

Method

Bare Pump

Performance Motor Performance Controls Performance

PEICL

Bare 

Pump

Calculation

-Based 

Only

Tested

Minimally Compliant Motor

Efficiency with Assumed 

Part-Load Losses

N/A

Pump + 

Motor

TestingBased 

Only

Tested N/A

TestingBased or 

Calculation

-Based

Tested

Nominal Motor Efficiency 

with Assumed Part-Load 

Losses

N/A

PEIVL

Pump + 

Motor +

Controls

TestingBased 

Only

Tested

TestingBased or 

Calculation

-Based

Tested Nominal Motor Efficiency

Assumed System Curve 

and Assumed Part-Load 

Losses of Motor + Controls
48

Determining PEICL for an Uncontrolled Pump

PEICL =

PERCL

PERSTD

=

ω75% P

in

75% +ω100% P

in

100% +ω110% P

in

110%

PERSTD

=

1

3

∗ P75%+L75% +

1

3

∗ P100%+L100% +

1

3

∗ P110%+L110%

PERSTD

Testing-Based Approach Calculation-Based Approach

• Tested driver input power (P

in

100%) is

measured directly

– Pivalues are the tested input power 

to the driver (motor) at each load 

point i.

• i = 75%, 100%, and 110% of flow 

rate at BEP of the bare pump

• Equal weighting

– Reflects the performance of both the 

bare pump and the motor.

• Bare Pump Performance

– Pivalues are the tested shaft input power to the 

pump (speed x torque) at each load point i.

• i = 75%, 100%, and 110% of flow rate at BEP of the 

bare pump

• Equal weighting

• Motor Performance (Losses)

– Liis either: 

• (A) the part-load losses of a motor that is paired with 

the pump for pumps sold with motors or

• (B) the part-load losses of an open or enclosed motor 

that is minimally compliant with DOE’s motor 

regulations (10 CFR 431.25) for NEMA Design A, 

Design B, IEC Design N Electric Motors except for 

submersible motors, sized based on shaft input power 

of the pump evaluated at 120% of BEP flow

• No Controls • No Controls
49

PERSTD: Minimally Compliant Pump

• PERSTD is equivalent to PERCL for a minimally compliant pump 

– Based on the tested characteristics and hydraulic load of the pump being rated.

– Assumes a pump curve shape for the minimally compliant pump and always assumes no 

controls.

– Motor losses are that of a minimally compliant open or enclosed motor for the appropriate 

pump equipment class, horsepower configuration, and speed.

– The minimally compliant pump efficiency is calculated for each pump equipment class based on 

a function of flow and speed of the pump being rated.

PERSTD = ω75%

PHydro,75%

0.95 ∗ ηpump,STD

+ L75% + ω100%

PHydro,100%P

ηpump,STD

+ L100% + ω110%

P1.10%

0.985 ∗ ηpump,STD

+ L110%

Where: Ns = the specific speed at 60 Hz, 

Q = the flow rate of the pump at BEP in GPM, 

C = the C-value of the surface, which is set based 

on the speed of rotation of the pump, and 

the pump equipment class

ηpump,STD = −0.85 ∗ ln Q100%

2 − 0.38 ∗ ln Ns ∗ ln Q100% − 11.48 ∗ ln Ns 2 + 17.80

∗ ln Q100% + 179.80 ∗ ln Ns − (C + 555.6)
50

Determining PEIVL for a Controlled Pump

PEIVL =

PERVL

PERSTD

=

ω25% P

in

25% + ω50% P

in

50% + ω75% P

in

75% + ω100% P

in

100%

PERSTD

=

1

4

P25% + L25% +

1

4

P

in

50% + L50% +

1

4

P

in

75% + L75% +

1

4

P

in

100% + L100%

PERSTD

Testing-Based Approach Calculation-Based Approach

• Tested driver input power (P

in

100%) is measured 

directly

– Pivalues are the tested input power to the 

driver (control) at each load point i.

• i = 25%, 50%, 75%, and 100% of flow rate at 

BEP of the bare pump

• Equal weighting

– Reflects the performance of the bare pump, 

motor, and control.

• Pump Performance

– Pin values are the input electrical power to the 

drive a load point i.

• i = 25%, 50%, 75%, and 100% of flow rate at BEP of 

the pump

• Equal weighting

• Motor Performance (Losses)

– Liis the part-load losses of motor and control 

that are paired with the pump 

• Controls Performance

– Benefit is captured in the calculation of 

bare shaft input power.

– Accounts for drive efficiency in tested driver 

input power.

• Controls Performance

– Benefit is captured in the calculation of bare 

shaft input power.

– Accounts for drive efficiency in calculated losses
51

Request for Comment

Issue 32: DOE requests comment on its proposal to base the default 

motor horsepower for the minimally compliant pump on that of the 

pump being evaluated. That is, the motor horsepower for the 

minimally compliant pump would be based on the calculated pump 

shaft input power of the pump when evaluated at 120 percent of BEP 

flow for bare pumps and the horsepower of the motor with which that 

pump is sold for pumps sold with motors (with or without continuous or 

non-continuous controls).
52

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
53

Determination of Pump Performance

• To determine PEICL or PEIVL, as applicable, the input power to the pump at 

the specified load points is required.

• The proposed test procedure requires physically measuring either:

– the bare pump (for calculation-based methods), or

– the entire pump, inclusive of any motor, continuous control, or non-continuous 

control (for testing-based methods).

• DOE’s test procedure, as proposed, requires instructions for how to 

physically measure the performance of bare pumps, pumps with motors, 

and pumps with motors and continuous or non-continuous controls in a 

standardized and consistent manner.
54

Referenced Industry Standards

• Consistent with Working Group Recommendations, DOE 

proposes to incorporate by reference the Hydraulic 

Institute (HI) Standard 40.6–2014, “Methods for 

Rotodynamic Pump Efficiency Testing,” as part of DOE’s 

test procedure for measuring the energy consumption of 

pumps, with a few minor modifications. 

Pumps Working Group 

Recommendation # 10 (with slight 

modifications)

Issue 33: DOE requests comment on using HI 40.6–

2014 as the basis of the DOE test procedure for pumps.

Proposed Minor Modifications Include:

Exclude sections not relevant 

to DOE’s regulatory 

framework

Section 40.6.5.3 and appendix B (reporting) & 

section A.7 (high temperature testing)

Specify data collection interval Collect data every 5 seconds

Specify allowable integration 

of data for stabilization

Dampening devices cannot integrate over time 

periods ≥5 seconds

Improve test repeatability Pumps speed, power supply characteristics,

number of stages for multi-stage pumps, 

determination of pump shaft input power, 

electrical measurement equipment, pumps 

with BEP at run-out, calculations and rounding
55

Pump Speed

• HI 40.6–2014 does not clearly specify nominal rating speeds for tested pump models.

• DOE proposes that all test data be adjusted (in accordance with section 40.6.6.1.1) to 

the following nominal speed prior to use in subsequent calculations:

• Consistent with HI 40.6–2014, DOE proposes that the tested speed must be 

maintained within 20 percent of the nominal speed, and the speed of rotation 

recorded at each test point may not vary more than ±1 percent to ensure accurate 

and reliable results. 

Pump Configuration Pump Design Speed of 

Rotation Style of Motor

Nominal Speed 

of Rotation for 

Rating

Bare Pump 2,880 and 4,320 rpm N/A 3,600 rpm

1,440 and 2,160 rpm 1,800 rpm

Pump + Motor OR 

Pump + Motor + Control

N/A 2-Pole Induction Motor 3,600 rpm

N/A 4-Pole Induction Motor 1,800 rpm

N/A

Non-Induction Motor Designed 

to Operate Between 2,880 and 

4,320 rpm 

3,600 rpm

N/A

Non-Induction Motor Designed 

to Operate Between 1,440 and 

2,160 rpm

1,800 rpm
56

Requests for Comment

Issue 37: DOE requests comment on its proposal to require data collected at 

the pump speed measured during testing to be normalized to the nominal 

speeds of 1,800 and 3,600 rpm. 

Issue 38: DOE requests comment on its proposal to adopt the requirements in 

HI 40.6–2014 regarding the deviation of tested speed from nominal speed and 

the variation of speed during the test. Specifically, DOE is interested if 

maintaining the tested speed within ±1 percent of the nominal speed is feasible 

and whether this approach would produce more accurate and repeatable test 

results.
57

Power Supply Characteristics

• To determine the appropriate power supply characteristics for testing pumps with 

motors and pumps with both motors and continuous or non-continuous controls, 

DOE examined applicable test methods for electric motors and VSD systems.

• DOE proposes to establish these power supply requirements in the DOE pump test 

procedure for measurement of electric input power to the motor or controls.

Test Procedure Applicable 

Equipment

Voltage 

Requirement

Frequency

Requirement

Total Harmonic 

Distortion Impedance

IEEE Standard 112–

2004

Electric

Motors

Maintained 

Within ±0.5% 

and 

“Voltage 

Unbalance” 

≤0.5%

Maintained 

Within ±0.5%

<5% N/A

AHRI 1210–2011 Variable

Speed Drives N/A ≤1%

CSA C838–2013 Variable 

Speed Drives <5% >1% and ≤3%

Issue 39: DOE requests comment on the proposed voltage, frequency, voltage 

unbalance, total harmonic distortion, and impedance requirements that are required 

when performing a wire-to-water pump test or when testing a bare pump with a 

calibrated motor. Specifically, DOE requests comments on whether these tolerances can 

be achieved in typical pump test labs, or whether specialized power supplies or power 

conditioning equipment would be required.
58

Measurement Equipment for Testing of Controlled Pumps

• When measuring input power to the pump for pumps sold with a motor and 

continuous or non-continuous controls, the equipment specified in section 

C.4.3.1, “electric power input to the motor,” of HI 40.6–2014 may not be 

sufficient.

• CSA C838–2013 and AHRI 1210–2011 require that electrical measurements 

for determining variable speed drive efficiency be taken using equipment: 

– capable of measuring current, voltage, and real power up to at least the 40th harmonic of 

fundamental supply source frequency and 

– having an accuracy level of ±0.2 percent of full scale when measured at the fundamental 

supply source frequency.

• DOE proposes that the electrical measurement equipment specified in AHRI 

1210–2011 and CSA C838–2013 be required for the purposes of measuring 

input power to a pump sold with a motor and continuous or non-continuous 

controls.

Issue 43: DOE requests comment on the type and accuracy of required measurement 

equipment, especially the equipment required for electrical power measurements for 

pumps sold with motors having continuous or non-continuous controls.
59

Pump Shaft Input Power at Load Points

• The test protocol in HI 40.6–2014 requires that test data be collected at 40, 60, 75, 

90, 100, 110, and 120 percent of the expected BEP flow.* 

– HI 40.6–2014 does not specify how to determine relevant parameters at the specific load points (i.e., 

75, 100, or 110 percent of the actual BEP flow for PERCL and PERSTD).

• DOE proposes that the pump shaft input power at the specific load points of 75, 100, 

and 110 percent of expected BEP flow be determined by regressing the pump shaft 

input power with respect to flow for the measured data at the load points between 

60 and 110 percent of expected BEP flow.

0

10

20

30

40

50

60

0 50 100 150

Pump Shaft Input Power (hp)

Percent of BEP Flow Rate

Load points above

60% of expected BEP

flow

Load points below

60% of expected BEP

flow

Linear (Load points

above 60% of

expected BEP flow)

Issue 41: DOE requests comment on its 

proposal to use a linear regression of the 

pump shaft input power with respect to 

flow rate at all the tested flow points 

greater than or equal to 60 percent of 

expected BEP flow to determine the 

pump shaft input power at the specific 

load points of 75, 100, and 110 percent of 

BEP flow. DOE is especially interested in 

any pump models for which such an 

approach would yield inaccurate 

measurements.

* For pumps with BEP at run-out data shall be collected at 40, 

50, 60, 70, 80, 90, and 100% of expected BEP flow
60

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
61

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
62

Determining of Motor Efficiency

Nominal Full-Load Motor Efficiency Default Full-Load Motor Efficiency

Metric 

Applicability

PERCL or PERVL for pumps + motors and pumps + 

motors + controls

PERCL for Bare Pumps PERSTD for All Pumps

Default 

Nominal 

Motor FullLoad 

Efficiency for 

Pumps Rated 

with...

Covered Poly-Phase 

Electric Motor

Measured Nominal Full-Load 

Efficiency Determined in 

Accordance with the DOE 

Electric Motor Test Procedure 

Specified at 10 CFR 431.16 

and Appendix B to Subpart B 

of Part 431

Nominal Full-Load Motor Efficiency (Standard) for General 

Purpose, Polyphase, NEMA Design A, NEMA Design B, and 

IEC Design N Motors Defined at 10 CFR 431.25

Non-Covered PolyPhase Electric Motor

Not Applicable (Only TestingBased Approach can be 

Used)

Nominal Full-Load Motor Efficiency (Standard) for General 

Purpose, Polyphase, NEMA Design A, NEMA Design B, and 

IEC Design N Motors Defined at 10 CFR 431.25

Submersible Motor Default Submersible Motor 

Full-Load Efficiency

Default Submersible Motor 

Full-Load Efficiency

Default Submersible 

Motor Full-Load Efficiency

Default 

Motor Speed Equivalent to nominal speed of the rated pump

Default 

Motor 

Horsepower

That of the motor with which the pump is being sold

Either equivalent to, or the 

next highest horsepowerrated level greater than, the 

measured pump shaft input 

power at 120 percent of BEP 

flow

That of the motor with 

which the pump is being 

sold

• Default motor efficiency, or motor losses, are required for determining the PERCL of a 

bare pump or the PERSTD for any pump configuration.
63

Default Motor Efficiencies at 10 CFR 431.25

10 CFR 431.25(h)

Motor 

horsepower

Default Nominal Full-Load Motor 

Efficiency (%)

Nominal Full-Load Efficiencies (%) of NEMA Design A, NEMA Design B and 

IEC Design N Motors (Excluding Fire Pump Electric Motors) at 60 Hz

Minimum Efficiency (%) Enclosed Motors Open Motors

Number of Poles Number of Poles Number of Poles

4 2 4 2 4 2

1 77.0 77.0 85.5 77.0 85.5 77.0

1.5 84.0 84.0 86.5 84.0 86.5 84.0

2 85.5 85.5 86.5 85.5 86.5 85.5

3 85.5 86.5 89.5 86.5 89.5 85.5

5 86.5 88.5 89.5 88.5 89.5 86.5

7.5 88.5 89.5 91.7 89.5 91.0 88.5

10 89.5 90.2 91.7 90.2 91.7 89.5

15 90.2 91.0 92.4 91.0 93.0 90.2

20 91.0 91.0 93.0 91.0 93.0 91.0

25 91.7 91.7 93.6 91.7 93.6 91.7

30 91.7 91.7 93.6 91.7 94.1 91.7

40 92.4 92.4 94.1 92.4 94.1 92.4

50 93.0 93.0 94.5 93.0 94.5 93.0

60 93.6 93.6 95.0 93.6 95.0 93.6

75 93.6 93.6 95.4 93.6 95.0 93.6

100 93.6 94.1 95.4 94.1 95.4 93.6

125 94.1 95.0 95.4 95.0 95.4 94.1

150 94.1 95.0 95.8 95.0 95.8 94.1

200 95.0 95.4 96.2 95.4 95.8 95.0

250 95.0 95.8 96.2 95.8 95.8 95.0
64

Requests for Comment

Issue 45: DOE requests comment on its proposal to determine the default 

motor horsepower for rating bare pumps based on the pump shaft input power 

at 120 percent of BEP flow. DOE is especially interested in any pumps for 

which the 120 percent of BEP flow load point would not be an appropriate 

basis to determine the default motor horsepower (e.g., pumps for which the 

120 percent of BEP flow load point is a significantly lower horsepower than the 

BEP flow load point). 

Issue 46: DOE requests comment on its proposal that would specify the 

default, minimally compliant nominal full-load motor efficiency based on the 

applicable minimally allowed nominal full-load motor efficiency specified in 

DOE’s energy conservation standards for NEMA Design A, NEMA Design B, 

and IEC Design N motors at 10 CFR 431.25 for all pumps except pumps sold 

with submersible motors.
65

Default Submersible Motor Full-Load Efficiency

• Submersible motors are not 

currently subject to the DOE energy 

conservation standards for electric 

motors specified at 10 CFR 431.25.

• DOE proposes to establish a default 

table of motor efficiencies for 

submersible motors to pair with 

VTS pumps when using the 

calculation method or calculating 

the PERSTD.

– DOE determined representative 

minimum submersible motor 

efficiencies from literature review and 

data mining.

– DOE specified the submersible motor 

efficiency based on the number of 

“bands” below comparable NEMA 

Design A, NEMA Design B, or IEC Design 

N motors of the same horsepower.

Motor 

Horse

power 

(hp)

Minimum 

Observed 

Full-Load 

Efficiency 

(2-poles) 

(%)

Observed 

Number of 

“Bands” 

Below the 

Full-Load 

Efficiency in 

in Table 5 of 

10 CFR 

431.25(h)

Default 

Number of 

“Bands” 

Below the 

Full-Load 

Efficiency in 

in Table 5 of 

10 CFR 

431.25(h) 

Default Submersible Motor 

Full-Load Nominal 

Efficiency

2-pole 4-pole

1 67 6

11

55 68

1.5 67 11 66 70

2 73 9 68 70

3 75 9 70 75.5

5 76 10 74 75.5

7.5 77 10

15

68 74

10 75 13 70 74

15 72.2 15 72 75.5

20 76.4 13 72 77

25 79 12 74 78.5

30 79.9 12

12

 

78.5 82.5

40 83 10 80 84

50 83 11 81.5 85.5

60 84 11 82.5 86.5

75 83.8 12 82.5 87.5

100 87 10

14

81.5 85.5

125 86 13 84 85.5

150 86 13 84 86.5

175 88 12 85.5 87.5

200 87 14 86.5 87.5

250 87 14 55 68
66

Issue 47: DOE requests comment on the proposed default minimum full-load 

motor efficiency values for submersible motors. 

Issue 48: DOE requests comment on defining the proposed default minimum 

motor full-load efficiency values for submersible motors relative to the most 

current minimum efficiency standards levels for regulated electric motors, 

through the use of “bands.”

Issue 49: DOE requests comment on the proposal to allow the use of the 

default minimum submersible motor full-load efficiency values to rate: (1) VTS 

bare pumps, (2) pumps sold with submersible motors, and (3) pumps sold with 

submersible motors and continuous or non-continuous controls as an option 

instead of wire-to-water testing.

Requests for Comment
67

Part-Load Motor Losses

• When calculating PERSTD or PERCL for all pumps the part-load motor losses at 

each load point must be determined:

• DOE proposes to determine part-load motor losses based on a “part-load 

loss factor” and the full-load motor losses:

Step Equation Where

1. Calculate full-load losses 

for the motor.

Lfull,default =

MotorHP

ηmotor,full

100 

− MotorHP

Lfull,default= default (or nominal) 

motor losses at full-load (hp),

ηmotor,full = the full-load motor 

efficiency

2. Determine the part-load 

loss factor (yi) for each 

rating point, where partload loss factor at a given 

point represents the partload losses at the given load 

divided by full-load losses.

yi = −0.4508 ×

Pi

MotorHP

3

+ 1.2399 ×

Pi

MotorHP

2

− 0.4301 ×

Pi

MotorHP + 0.6410 

yi = the part-load loss factor at 

load point i, 

Pi = the shaft input power to the 

bare pump (hp), 

MotorHP = the motor horsepower 

(hp)

i = percentage of flow at the BEP of 

the pump.

3. Multiply the full-load 

losses by each part-load loss 

factor to obtain part-load 

losses at each rating point.

Li = Lfull,default × yi

Li= default motor losses at rating 

point i (hp)

P

in

i

= Pi + Li
68

Determination of Part-Load Loss Curve

• DOE evaluated motor efficiency data at 25, 50, 75, and 100 percent of fullload of the motor from multiple sources, including NEMA, the DOE 

MotorMaster database, and the DOE Motor Challenge.

– DOE considered providing multiple part-load loss curves based on motor size, motor speed, 

and/or motor type, but ultimately determined that the rating metric is not sensitive to 

changes in the part-load loss curve based on these factors.

– Therefore, DOE proposes to adopt a single curve represented by a cubic polynomial for 

determining the part-load losses of motors when using the calculation method.

y = -0.4508x3 + 1.2399x2- 0.4301x + 0.641

y = 1.0275x3- 1.0686x2 + 0.8818x + 0.1593

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

0.00% 20.00% 40.00% 60.00% 80.00% 100.00%

Part-Load Motor Fractional Load Loss

Fractional Motor Load

NEMA MG-1 part load data

Most conservative loss

fraction curve

Least conservative loss

fraction curve

Issue 50: DOE requests 

comment on the development 

and use of the motor partload loss factor curves to 

describe part-load 

performance of covered 

motors and submersible 

motors including the default 

motor specified for bare 

pumps and calculation of 

PERSTD.
69

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
70

Testing Methods: Calculation- and Testing-Based

• DOE considered both testing-based and calculation-based 

methods for determining the metric for a given pump 

configuration.

Test Method Pros Cons

Calculation

Based Approach Repeatable; Less Burdensome

Assumptions Regarding Change in 

Motor/Controls Efficiency with 

Changing Load Required; 

Decreased Accuracy;

Not applicable to ALL pumps

Testing Based 

Approach

Accurate; Differentiates Performance 

of Different Motor/Controls 

Equipment at Full and Part-Load

Burdensome
71

Calculation-Based: A.1 – Bare Pump

• The bare pump PERCL would be measured based on the pump shaft input power at 

75, 100, and 110 percent of BEP flow.

Where:

ωi = weighting at each rating point (equal weighting or 1/3in this case),

Pi

in = calculated input power to the motor at rating point i (hp),

Pi = the tested shaft input power to the bare pump (hp), 

Li = default motor losses at each load point i (hp), and

i = 75, 100, and 110 percent of BEP flow as determined in accordance with the DOE test 

procedure. 

PEICL =

PERCL

PERSTD

PERCL = ω75% P75%

in + ω100% P100%in + ω110% P110%in

= ω75% P75% + L75% + ω100% P100% + L100% + ω110% P110% + L110%

standardized motor 

efficiency and default 

part-load curve

pump performance data 

from HI 40.6 pump test 

at rated speed

×

MOTOR
72

Calculation-Based: B.1 – Pump Sold With a Motor

• Procedure is the same as for pumps sold as bare pumps except that motor efficiency, 

or losses, would be that of the motor with which the pump is sold when determining 

PERCL, as opposed to the default motor efficiency.

manufacturer motor 

efficiency at full-load 

and default loss curve

pump performance data 

from pump test at rated 

speed

×

Where:

ωi = weighting at each rating point (equal weighting or 1/3in this case),

Pi

in = calculated input power to the motor at rating point i (hp),

Pi = the tested shaft input power to the bare pump (hp), 

Li = default motor losses at each load point i (hp), and

i = 75, 100, and 110 percent of BEP flow as determined in accordance with the DOE test 

procedure. 

PERCL = ω75% P75%

in + ω100% P100%in + ω110% P110%in

= ω75% P75% + L75% + ω100% P100% + L100% + ω110% P110% + L110%

determined based on 

nominal full-load 

efficiency of motor with 

which pump is being 

rated

MOTOR
73

Calculation-Based: C.1 – Pump, Motor & Continuous Control

• PEIVL accounts for the power reduction resulting from continuous controls.

Where:

ωi = weighting at each rating point (equal weighting or 1⁄4 in this case), 

Pi

in = measured or calculated input power to the pump at the input 

to the continuous or non-continuous controls at rating point i, and

Pi = the tested shaft input power to the bare pump (hp), 

Li = default motor and control losses at each load point i (hp), and

i = 25, 50, 75, and 100 percent of BEP flow, as determined in accordance 

with the proposed DOE test procedure. 

PERVL = ω25% P25%

in + ω50% P50%in + ω75% P75%in + ω100% P100%in

= ω25% P25% + L25% + ω50% P50% + L50% + ω75% P75% + L75% + ω100% P100% + L100%

manufacturer motor 

efficiency at full-load

MOTOR

pump performance data 

from pump test at rated 

speed

× ×

default controls 

performance

Controls

Default loss curve for both motor and controls
74

0

50

100

150

200

250

300

350

0 200 400 600 800 1000 1200 1400

Head (ft)

Flow Rate (GPM)

Original VFD load profile

New VFD Load Profile

Example Pump Curve

Best Efficiency Point

20% of BEP Head

Realized potential savings

Reference System Curve 

• DOE proposes a reference system curve based on the pump affinity laws, but with a 

static offset. 

– Static head offset is 20% of BEP head. 

– Given QBEP and HBEP, the system curve becomes: H = 0.8 ∗

Q

Q100%

2

+ 0.2 ∗ H100%

System Curve based on Pump 

Affinity Laws

Reference System Curve with Static 

Offset

Issue 54: DOE requests comment on the proposed system 

curve shape to use, as well as whether the curve should go 

through the origin instead of the statically-loaded offset.
75

Efficiency of Motor and Control

• To determine the representative

part-load losses of the motor and 

control, DOE analyzed the results of 

AHRI 1210-2011 testing for five 

different “motor-drive” 

combinations and additional, 

publically-available data.

– DOE primarily considered maximum 

losses.

• DOE determined that 4 curves 

describing combined motor + 

control efficiency as a function of 

fractional motor load and motor 

horsepower were the most accurate 

representation without being overly 

burdensome or complex.

– DOE also considered curves as a 

function of speed, torque, motor 

size, and other variables. 

zi =

Li(Motor+Continuous Control)

Lfull,default(Motor)

zi = a ∗

Pi

MotorHP

2

+ b ∗

Pi

MotorHP + c

0.00

0.50

1.00

1.50

2.00

2.50

0% 25% 50% 75% 100%

zi = (VFD+MOTOR losses)/(Motor FL losses) 

Motor Load

1-5HP

6-20HP

21-50HP

51+HP

ALL HP

Poly. (1-5HP)

Poly. (6-20HP)

Poly. (21-50HP)

Poly. (51+HP)

Motor Horsepower 

(hp)

Coefficients for Motor and Control Part-Load Loss 

Factor (zi) 

a b c

≤5 -0.4658 1.4965 0.5303

>5 and ≤20 -1.3198 2.9551 0.1052

>20 and ≤50 -1.5122 3.0777 0.1847

>50 -0.8914 2.8846 0.2625
76

Requests for Comment

Issue 55: DOE requests comment on the proposed calculation approach for 

determining pump shaft input power for pumps sold with motors and 

continuous controls when rated using the calculation-based method.

Issue 56: DOE requests comment on the proposal to adopt four part-load loss 

factor equations expressed as a function of the load on the motor (i.e., motor 

brake horsepower) to calculate the losses of a combined motor and continuous 

controls, where the four curves would correspond to different horsepower 

ratings of the continuous control.

Issue 57: DOE also requests comment on the accuracy of the proposed 

equation compared to one that accounts for multiple performance variables 

(speed and torque).

Issue 60: DOE requests comment and data from interested parties regarding 

the extent to which the assumed default part-load loss curve would represent 

minimum efficiency motor and continuous control combinations.
77

Issue 62: DOE requests comment on its proposal to limit the use of 

calculations and algorithms in the determination of pump performance to the 

calculation-based methods proposed in this NOPR.

Test of Bare Pumps and Additional Calculation Approaches

• Under the calculation-based 

approach, DOE proposes that 

testing of bare pump performance 

is required in all cases.

• DOE is not considering additional 

calculations or algorithms at this 

time.

standardized motor 

efficiency and default 

part-load curve

pump performance data 

from HI 40.6 pump test at 

rated speed

× MOTOR

manufacturer motor 

efficiency at full-load

MOTOR

pump performance 

data from pump test 

at rated speed

× ×

default controls 

performance

Controls

Default loss curve for both motor and controls

manufacturer motor 

efficiency at full-load 

and default loss curve

pump performance 

data from pump test 

at rated speed

×

Issue 61: DOE requests comment on MOTOR

its proposal to require testing of each 

individual bare pump as the basis for 

a certified PEICL or PEIVL rating for 

one or more pump basic models.
78

Application of Calculation-Based Test Methods Based on Pump Configuration

Metric Rated As Test 

Method Applicable Pump Configurations Calculation-Based Test Method

PEICL

Bare 

Pump

Calculation

-Based 

Only

A.1: Tested Pump Efficiency of Bare Pump + 

Default Motor Efficiency + Default Motor PartLoad Loss Curve

Pump + 

Motor

TestingBased Only Not Applicable

TestingBased or 

Calculation

-Based

B.1: Tested Pump Efficiency of Bare Pump + 

Motor Nameplate Efficiency for Actual Motor 

Paired with Pump + Default Motor Part-Load 

Loss Curve

PEIVL

Pump + 

Motor +

Controls

TestingBased Only Not Applicable

TestingBased or 

Calculation

-Based

C.1: Tested Pump Efficiency of Bare Pump + 

Motor Nameplate Efficiency for Actual Motor 

Paired with Pump (or Default Submersible 

Motor Efficiency+ Default Motor/Control PartLoad Loss Curve + Refined System Curve

Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Electric

Driver

Bare 

Pump

Single-Phase

Induction 

Motor

Bare 

Pump

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor

Non-Continuous

Control

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor

Non-Continuous

Control

Bare 

Pump

Non-Covered

Poly-Phase 

Electric Motor

Continuous or 

Non-Continuous

Control

Bare 

Pump

Submersible

Motor

Bare 

Pump

Non-Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Submersible 

Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump
79

Testing Methods: Calculation- and Testing-Based

• DOE considered both testing-based and calculation-based 

methods for determining the metric for a given pump 

configuration

Test Method Pros Cons

CalculationBased Approach Repeatable; Less Burdensome

Assumptions Regarding Change in 

Motor/Controls Efficiency with 

Changing Load Required; 

Decreased Accuracy

Physical TestingBased Approach

Accurate; Differentiates Performance 

of Different Motor/Controls 

Equipment at Full and Part-Load

Burdensome; Drive Test Data Not 

Available
80

Testing-Based: B.2 – Pump Sold With a Motor

• For pumps sold with motors, the PEICL can be determined by wire-to-water testing, as 

specified in HI 40.6–2014 section 40.6.4.4. 

– Test similar to bare pump test, except in this case, the input power to the motor is measured directly at 

75, 100, and 110 percent of BEP flow and

– The BEP is determined based on overall efficiency

PERCL = ω75% P75%

in + ω100% P100%in + ω110% P110%in

Where:

ωi = weighting at each rating point (equal weighting or 1/3in this case), 

Pi

in = measured input power to the motor at rating point i, and

i = 75, 100, and 110 percent of BEP flow as determined in accordance with the DOE 

test procedure.

PEICL =

PERCL

PERSTD

MOTOR PUMP

ηoverall =

PHydro

Pi

in
81

Testing-Based: C.2 – Pump, Motor & Control

• For pumps sold with motors and continuous or non-continuous controls, DOE 

proposes that the PEIVL may be determined by wire-to-water testing.

– First, determine the BEP of the pump, inclusive of motor and continuous or non-continuous controls, at 

nominal speed based on overall efficiency. 

– Then adjust the operating speed of the motor and the head until the head and flow conditions specified 

by the reference system curve are reached.

Where:

ωi = weighting at each rating point (equal weighting or 1/4in this case), 

Pi

in = measured input power to the controls at rating point i, and

i = 25, 50, 75, and 100 percent of BEP flow as determined in accordance with the DOE 

test procedure. 

PEIVL =

PERVL

PERSTD

Controls MOTOR PUMP

PERVL = ω25% P25%

in + ω50% P50%in + ω75% P75%in + ω100% P100%in
82

Testing-Based: C.2 – Determining Rated Power

• To ensure accurate and consistent results, DOE is proposing: 

– that tested flow points are within 10 percent of the target flow and head load points 

defined on the reference system curve and 

– measured input power to the pump (at the controls) is extrapolated to the exact load 

points specified by the system curve.

0

20

40

60

80

100

120

0 20 40 60 80 100 120

% of BEP Head

%of BEP Flow

Tested Flow Points Rated Flow Points Reference System Curve

QR,i QT,j

HR,i

HT,j

PR,i =

HR,i

HT,j

QR,i

QT,j

PT,i
83

• In the case of non-continuous controls, the test procedure is the same as for 

pumps sold with motors and continuous controls (C.2), except: 

– the measured head must be no lower than 10 percent below the load points specified by 

the reference system curve and 

– head values above the reference system curve must be used directly and not corrected.

Test Based: C.2 – Non-Continuous Control

0

20

40

60

80

100

120

0 20 40 60 80 100 120

% of BEP Head

%of BEP Flow

Rated Flow Points Measured Flow Points Reference System Curve

Full Speed

Half Speed

Full Speed Pump Curve Half Speed Pump Curve
84

Issue 64: DOE requests comment on the proposed testing-based method 

for pumps sold with motors and continuous or non-continuous controls.

Issue 65: DOE requests comment on the proposed testing-based method 

for determining the input power to the pump for pumps sold with motors and 

non-continuous controls.

Issue 66: DOE requests comment on any other type of non-continuous 

control that may be sold with a pump and for which the proposed test 

procedure would not apply. 

Requests for Comment
85

Application of Testing-Based Test Methods Based on Pump Configuration

Metric Rated As Test 

Method Applicable Pump Configurations Physical Testing-Based Test Method

PEICL

Bare 

Pump

Calculation

-Based 

Only

Not Applicable

Pump + 

Motor

TestingBased Only B.2: Tested Wire-to-Water Performance

TestingBased or 

Calculation

-Based

B.2: Tested Wire-to-Water Performance

PEIVL

Pump + 

Motor +

Controls

TestingBased Only C.2: Tested Wire-to-Water Performance

TestingBased or 

Calculation

-Based

C.2: Tested Wire-to-Water Performance

Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Electric

Driver

Bare 

Pump

Single-Phase

Induction 

Motor

Bare 

Pump

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor

Non-Continuous

Control

Bare 

Pump

Covered 

Poly-Phase 

Electric Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor 

Continuous

Control

Bare 

Pump

Submersible

Motor

Non-Continuous

Control

Bare 

Pump

Non-Covered

Poly-Phase 

Electric Motor

Continuous or 

Non-Continuous

Control

Bare 

Pump

Submersible

Motor

Bare 

Pump

Non-Covered 

Poly-Phase

Electric Motor

Bare 

Pump

Non-Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Covered

Poly-Phase

Electric Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump

Submersible 

Motor

Controls

Other than

Continuous or 

Non-Continuous

Bare 

Pump
86

Metric Rated 

As

Test 

Method Applicable Pump Configurations Calculation-Based Test Method Physical Testing-Based Test Method

PEICL

Bare 

Pump

Calculate 

Only

Bare Pump; Pump Sold with NonElectric Driver; Pump Sold with SinglePhase Induction MotorA.1: Tested Pump Efficiency of Bare 

Pump + Default Motor Efficiency + 

Default Motor Part-Load Loss Curve

Not Applicable

Pump + 

Motor

Testing 

Only

Pump + Non-Covered Poly-Phase 

Electric Motor (with or without 

Controls Other than Continuous or 

Non-Continuous Controls)

Not Applicable B.2: Tested Wire-toWater Performance

Test or 

Calculate

Pump + Covered Poly-Phase Electric 

Motor (with or without Controls Other 

than Continuous or Non-Continuous 

Controls) OR 

Pump + Submersible Motor (with or 

without Controls Other than 

Continuous or Non-Continuous 

Controls)

B.1: Tested Pump Efficiency of Bare 

Pump + Motor Nameplate Efficiency 

for Actual Motor Paired with Pump + 

Default Motor Part-Load Loss Curve

B.2: Tested Wire-toWater Performance

PEIVL

Pump + 

Motor 

+

Control

s

Testing 

Only

Pump + Non-Covered Poly-Phase 

Electric Motor with Continuous or NonContinuous Controls; 

Pump + Covered Poly-Phase Electric 

Motor with Non-Continuous Controls; 

OR 

Pump + Submersible Motor with NonContinuous Controls

Not Applicable C.2: Tested Wire-toWater Performance

Test or 

Calculate

Pump + Covered Poly-Phase Electric 

Motor with Continuous Controls OR 

Pump + Submersible Motor with 

Continuous Controls

C.1: Tested Pump Efficiency of Bare 

Pump + Motor Nameplate Efficiency 

for Actual Motor Paired with Pump + 

Default Motor/Control Part-Load Loss 

Curve + Assumed System Curve

C.2: Tested Wire-toWater Performance

Applicable Test Methods Based on Pump Configuration
87

Requests for Comment

Issue 67: DOE requests comment on its proposal to establish (1) calculationbased test methods as the required test method for bare pumps and (2) 

testing-based methods as the required test method for pumps sold with motors 

that are not regulated by DOE’s electric motor energy conservation standards, 

except for submersible motors, or for pumps sold with any motors and with 

non-continuous controls. 

Issue 68: DOE also requests comment on the proposal to allow either testingbased methods or calculation-based methods to be used to rate pumps sold 

with continuous control-equipped motors that are either (1) regulated by DOE’s 

electric motor standards or (2) submersible motors.

Issue 69: DOE requests comment on the level of burden that would 

accompany any certification requirements related to reporting the test method 

used by a manufacturer to certify a given pump basic model as compliant with 

any applicable energy conservation standard DOE may set.
88

Representations of Energy Use and Energy Efficiency

• The DOE test procedure describes methods for determining 

PEICL, PERCL, PEIVL, and PERVL. 

• DOE does not wish to limit the representations manufacturers 

may make regarding other pump performance metrics. 

Metric Permitted Representations

PEI Full Impeller Only (at Specified Number of Stages)

PER Full Impeller Only (at Specified Number of Stages)

Pump Efficiency, Overall Efficiency, Bowl 

Efficiency 

Multiple Impeller Trims, Operating Speeds, and 

Number of Stages for a Given Pump

Pump Input Power, Hydraulic Output 

Power, and/or Brake Horsepower

Multiple Impeller Trims, Operating Speeds, and 

Number of Stages for a Given Pump

Non-Energy = Head, Flow (Especially BEP 

Flow), Specific Speed

Multiple Impeller Trims, Operating Speeds, and 

Number of Stages for a Given Pump
89

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
90

Sampling Plans for Pumps

• DOE provides sampling plans in subpart B to 10 CFR part 429 for all covered 

equipment. 

• The purpose of these sampling plans is to provide uniform statistical 

methods for determining compliance with prescribed energy conservation 

standards and when making representations of energy consumption and 

energy efficiency for each covered equipment type on labels and in other 

locations such as marketing materials. 

• DOE proposes to adopt the same statistical sampling procedures that are 

applicable to many other types of commercial and industrial equipment in a 

new section (10 CFR 429.59).

– DOE proposes to apply the minimum requirement of two tested units to certify a basic 

model as compliant.

– DOE proposes to determine compliance in an enforcement matter based on the arithmetic 

mean of a sample not to exceed four units.
91

Determining Sample Size

• Manufacturers must determine the certified rating based on the testing of a 

randomly selected sample of sufficient size such that:

– The PEICL or PEIVL shall be greater than or equal to the higher of:

(A) The mean of the sample:

x =

1

n

 xi

n

i=1

where x is the sample mean; n is the number of samples; and xiis the maximum of the i

th sample;

Or,

(B) The upper 95 percent confidence limit (UCL) of the true mean divided by 1.10:

UCL = x + t0.95

s

n

where s is the sample standard deviation; n is the number of samples; and t0.95 is the t statistic for a 

95 percent one-tailed confidence interval with n-1 degrees of freedom.

• To pass, the certified rating determined based on the above method must be less 

than the standard (1.0).

Issue 70: DOE requests comment on the proposed sampling plan for 

certification of commercial and industrial pump models.
92

Public Meeting Slides Topics – Morning (TP)

1 Introductions & Stakeholder Opening Statements

2 Regulatory History & Scope

3 Metric

4 Test Procedure: Determination of Pump Performance

5 Break

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
93

Review Under the Regulatory Flexibility Act

Initial Regulatory 

Flexibility Analyses Key Assumptions Key Findings

Identification of 

small businesses

• NAICS 333911, “Pump and Pumping Equipment 

Manufacturing,” and SBA standard ≤500 employees (13 CFR 

part 121) are applicable to this industry

25 domestic small 

businesses

Assessing number of 

basic models

• In most cases manufacturers could use calculation-based 

method and, thus, burden is primarily associated with number 

of bare pump models

Average of 41 basic 

models per company

Burden of 

conducting the test 

procedure

Accounts for:

• capital expenses associated with construction and maintenance 

of a test facilities capable of testing pumps in compliance with 

the test procedure and

• recurring burden associated with ongoing testing activities

(testing of 2 units per pump model)

• $61,000-$221,000

per year per small 

manufacturer

• 0.36-2.55% of 

annual sales

• DOE conducted a Regulatory Flexibility Act analysis for the proposed test procedure 

rule pursuant to the Regulatory Flexibility Act, as amended. (5 U.S.C 601, et seq.)

Issue 82: DOE requests comment on the assumptions and estimates made in the burden analysis 

associated with implementing the proposed DOE test procedure.
94

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History & Scope

4 Metric

5 Test Procedure: Determination of Pump Performance

6 Test Procedure: Determination of Driver Efficiency

7 Test Procedure: Calculation & Testing Based Methods

Test Procedure: Sampling Plan

Test Procedure: Burden

Lunch Break

8

9

10
95

Public Meeting Slides Topics - Standards

1 Overview

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
96

Regulatory History: Pumps Working Group

• The Pumps Working Group concluded on June 19, 2014, with 14 

recommendations for DOE related to pump energy conservation 

standards and the pump test procedure (Working Group 

Recommendations).

• DOE’s proposed energy conservation standards directly reflect 

the Working Group Recommendations.

• DOE conducted analysis during the Pumps Working Group to 

ensure that the recommended standards also meet the relevant 

statutory requirements.
97

Statutory Requirements

• Pursuant to EPCA, any new or amended energy conservation standard must be designed 

to achieve maximum improvement in energy efficiency that is technologically feasible 

and economically justified (42 U.S.C. 6295(o)(2)(A) and 6316(a), and must result in a 

significant conservation of energy (42 U.S.C. 6295(o)(3)(B) and 6316(a).

• EPCA also directs DOE to consider seven factors when setting energy conservation 

standards. (42 U.S.C. 6313(a)(6)(B))

EPCA Factors Corresponding DOE Analyses

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared to 

increased cost for the equipment Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers relevant

Emissions Analysis

Utility Impact Analysis

Employment Impact Analysis
98

Energy Conservation Standards Rulemaking Process

Framework NOPR Final 

Rule

Emissions

Analysis
99

PERSTD: Minimally Compliant Pump

• The actual standard for all equipment classes and efficiency levels considered:

PEI =

PER

PERSTD

≤ 1.00

• The C-value in PERSTD varies by equipment class and with each efficiency 

level/trial standard level.

PERSTD = ω75%

PHydro,75%

0.95 ∗ ηpump,STD

+ L75% + ωBEP

PHydro,100%

ηpump,STD

+ L100% + ω110%

PHydro,110%

0.985 ∗ ηpump,STD

+ L110%

ηpump,STD = −0.85 ∗ ln Q100%

2 − 0.38 ∗ ln Ns ∗ ln Q100% − 11.48 ∗ ln Ns 2 + 17.80 ∗ ln Q100%

+ 179.80 ∗ ln Ns − (C + 555.6)

This value changes 

with efficiency level to 

increase the efficiency 

of a minimallycompliant pump

Determined for each 

pump in the test 

procedure
100

Public Meeting Slides Topics

1 Overview; 

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
101

Market and Technology Assessment

Purpose:

• Develop the scope of coverage for this rulemaking

– Equivalent to the scope proposed for the Test Procedure

• Define equipment classes 

• Characterize the pump manufacturing industry

• Gather historical shipments and other relevant market data

• Characterize the efficiency distribution of the current market

• Identify existing regulatory and voluntary efficiency programs

• Identify technology options for improving efficiency

Note: A detailed description of methodology and results is contained in chapter 

3 of the NOPR technical support document (TSD).
102

Equipment Classes

DOE proposed the following 20 pump equipment classes:

Category Sale Configuration Design Speed 

(rpm) Designation

ESCC

bare pump or pump with motor without controls 1800 ESCC.1800.CL

3600 ESCC.3600.CL

pump with motor and with controls 1800 ESCC.1800.VL

3600 ESCC.3600.VL

ESFM

bare pump or pump with motor without controls 1800 ESFM.1800.CL

3600 ESFM.3600.CL

pump with motor and with controls 1800 ESFM.1800.VL

3600 ESFM.3600.VL

IL

bare pump or pump with motor without controls 1800 IL.1800.CL

3600 IL.3600.CL

pump with motor and with controls 1800 IL.1800.VL

3600 IL.3600.VL

RSV

bare pump or pump with motor without controls 1800 RSV.1800.CL

3600 RSV.3600.CL

pump with motor and with controls 1800 RSV.1800.VL

3600 RSV.3600.VL

VTS

bare pump or pump with motor without controls 1800 VTS.1800.CL

3600 VTS.3600.CL

pump with motor and with controls 1800 VTS.1800.VL

3600 VTS.3600.VL
103

Technology Assessment

Method: DOE identified technology options for improved energy 

efficiency from publically available literature, comments and 

input from stakeholders, and manufacturer interviews.

Results: DOE identified the following technology options:

• Improved surface finish on wetted components

• Reduced running clearances

• Reduced mechanical friction in seals

• Reduction of other volumetric losses

• Improved hydraulic design

• Addition of a variable speed drive (VSD)

• Improvement of VSD efficiency

• Reduced VSD standby and off mode power usage

Note: Chapter 3 of the NOPR TSD contains a detailed description of the 

identified technologies.
104

Screening Analysis

Purpose: Screen out technologies that do not save energy and/or do not 

meet all of the following four criteria:

1. Technological feasibility

2. Practicability to manufacture, install and service on a commercial scale at the 

time that compliance with any final standards would be required

3. Impacts on product utility or available to consumers

4. Impact on health and safety

Results: Technology Option Status

Reduced Running Clearances Screened Out

Reduction of Other Volumetric Losses Screened Out

Improved Surface Finish of Wetted Components Screened Out

Reduced Mechanical Friction in Seals Screened Out

Addition of a Variable Speed Drive Screened Out

Improvement of VSD Efficiency Screened Out

Reduced VSD Standby and Off Mode Power Usage Screened Out

Hydraulic Redesign Passed to Engineering 

Note: Chapter 4 of the NOPR TSD discusses 

screening and elimination of certain technologies.
105

Public Meeting Slides Topics

1 Overview

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
106

Engineering Analysis

Purpose: Establish efficiency levels and determine incremental 

changes in manufacturer selling price (MSP) at each level.

Method:

• Efficiency levels established using a market-distribution 

approach. Levels based on the current market-available 

range of efficiency.

• Base-case and incremental MSPs were determined using

confidential market-wide revenues, shipments, and markups 

data, as well as specific manufacturer input. 

Note: Chapter 5 of the NOPR TSD contains a detailed description of the 

Engineering Analysis.
107

Engineering Analysis: Efficiency Levels

Results: Efficiency Levels and Corresponding C-values

Equipment 

Class

EL0 EL1 EL 2 EL 3 EL 4 EL 5

Baseline

10th

Efficiency 

Percentile

25th

Efficiency 

Percentile

40th

Efficiency 

Percentile

55th

Efficiency 

Percentile

70th

Efficiency 

Percentile/ 

Max Tech

ESCC.1800 134.43 131.63 128.47 126.67 125.07 123.71

ESCC.3600 135.94 134.60 130.42 128.92 127.35 125.29

ESFM.1800 134.99 132.95 128.85 127.04 125.12 123.71

ESFM.3600 136.59 134.98 130.99 129.26 127.77 126.07

IL.1800 135.92 133.95 129.30 127.30 126.00 124.45

IL.3600 141.01 138.86 133.84 131.04 129.38 127.35

RSV.1800 129.63 N/A N/A N/A N/A 124.73

RSV.3600 133.20 N/A N/A N/A N/A 129.10

VTS.1800 137.62 135.93 134.13 130.83 128.92 127.29

VTS.3600 137.62 135.93 134.13 130.83 128.92 127.29
108

Engineering Analysis: Base-Case MSP-Efficiency Relationship

Results: Base-Case MSP-Efficiency Relationship

• DOE found a relationship between manufacturer markup and efficiency.

• DOE determined that improved efficiency does not increase manufacturer 

production cost (MPC).

• DOE modeled the average MPC for pumps within scope.

• The base-case MSP for a pump of a given size and efficiency (MSP-Efficiency 

Relationship) is found using the Average MPC Model (below, left) and the 

Markup vs. Efficiency Percentile model (below, right) for each equipment class:

MSP = MPC × Markup
109

Engineering Analysis: Conversion Costs

Hydraulic redesigns result in significant conversion costs and manufacturers may 

use increased markups to recover these conversation costs.

Method: Bottom-up approach to find industry conversion costs

1. Determine the industry-average cost, per model, to redesign pumps of varying 

sizes to meet each of the proposed efficiency levels. 

2. Model the distribution of unique pump models that would require redesign at 

each efficiency level. 

3. For each efficiency level, multiply the number of unique failing models by the 

associated cost to redesign and sum to reach an estimate of the total conversion 

cost for the industry. 

Results: Aggregate Industry Conversion Cost at Each Efficiency Level (Million USD)

All Values in Millions 

of Dollars

EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

Baseline 10th

Percentile

25th

Percentile

40th

Percentile

55th

Percentile

70th

Percentile

ESCC/ESFM* $0 $12.4 $49.4 $110.6 $210.4 $344.7

IL $0 $5.1 $20.0 $45.3 $88.2 $144.0

VTS $0 $2.5 $9.3 $19.2 $37.8 $61.3

Total Industry $0 $20.0 $78.7 $175.1 $336.4 $550.0 

Note: Chapter 5 of the NOPR TSD contains a detailed description 

of the Conversion Cost Analysis.
110

Engineering Analysis: Standards-Case MSP-Efficiency Relationship

Method: DOE evaluated two standards-case MSP-Efficiency scenarios 

to represent the uncertainty regarding the potential impacts of 

standards on prices and profitability.

1. Flat Pricing

• Pricing structure not modified to recover conversion costs.

– i.e., Same markup structure as in the base-case

• This scenario is considered a lower bound for revenues.

2. Cost Recovery Pricing

• Pricing structure modified to recover conversion costs over the analysis 

period.

– i.e., Increased markups, even as MPC remains the same

• This scenario is considered an upper bound for revenues.

• This scenario provides the highest cost to consumers and is used for the LCC 

analysis.

Results are incorporated into the LCC and MIA analyses
111

Public Meeting Slides Topics

1 Overview

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
112

Markups Analysis

Purpose

• Determine consumer prices based on manufacturer’s selling price for 

baseline and higher efficiency equipment

• Characterize pump distribution channels

Method

• Analyze company direct costs, expenses, and profits

– Original Equipment Manufacturers: U.S. Census Bureau, 2007 Manufacturing 

Industry Series

– Distributors: U.S. Census Bureau, 2012 Annual Wholesale Trade Survey, 

Hardware, Plumbing, and Heating Equipment and Supplies Merchant Wholesalers

– Contractors: RSMeans, 2013 Electrical Cost Data

– Sales Taxes: The Sales Tax Clearinghouse, 2014

• Calculate baseline and incremental markups

– Baseline markups applied to MSP of baseline level

– Incremental markups applied to incremental difference in MSP at each level 

above baseline; covers only expenses that vary with MSP, or in this case, 

expense that increase due to an efficiency standard
113

Markups Analysis Markups Analysis: Overall Markups

Markup

Manufacturer 

to Distributor 

to Contractor 

to End-User

(70%)

Manufacturer 

to Distributor 

to End-User

(17%)

Manufacturer 

to OEM to 

End-User

(8%)

Manufacturer 

to End-User

(2%)

Manufacturer 

to Contractor 

to End-User

(1%)

Other

(2%)

Baseline Incr. Baseline Incr. Baseline Incr. Baseline Incr. Baseline Incr. Baseline Incr.

OEM - - - - 1.43 1.38 - - - - - -

Distributor 1.39 1.15 1.39 1.15 - - - - - - -

Contractor 1.1 1.1 - - - - - - 1.1 1.1 - -

Sales Tax 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 - -

Overall 1.64 1.35 1.49 1.23 1.53 1.48 1.07 1.07 1.18 1.18 1.59 1.34

• NOTE: These markups are applied to the MSP, which already includes the 

manufacturer markup.
114

Energy Use Analysis

Purpose

• Determine annual energy use (UEC) of pumps at the considered efficiency 

levels to find annual energy costs and savings.

• Annual energy costs are inputs to Life-Cycle Cost and Payback Period 

Analysis.

Method

• The annual energy use is calculated as a weighted sum of input power 

multiplied by the annual operating hours across all load points.

– where:

• Qiis the flow load point

• Hiis the head at Qi, calculated from the pump curve

• ηiis the pump efficiency calculated from the efficiency curve

• ηmotor,i is the motor efficiency

• OpHourirefers to annual hours of operation at load point i

 





LoadProfile ,

i

i motor i

i i

OpHour Q HAEU

 
115

Input Description

Duty Point

The LCC uses a set of representative units constructed from binning the 

manufacturer survey data into 9 power bins x 9 flow bins, logarithmically 

spaced. All efficiencies within a bin are assumed available for the representative 

unit. Pump curve, efficiency curve, base price and BEP efficiency are normalized 

to the bin average specific speed and flow.

Pump Sizing

Represented by a “BEP offset:” FlowDuty = 1 + x FlowBEP

X is chosen from a uniform distribution between -0.25 to 0.10 (to represent 

pump sizing between 75% and 110% of BEP flow).

Annual Hours of 

Operation

Distributions of annual operating hours by application based on a consultant 

estimate with Pumps Working Group review and modification.

Load Profile 4 typical load profiles – flat load [30%], flat/over-sized [30%], variable/over-sized 

[30%], and variable/under-sized [10%].

Pump Losses Accounted for using efficiency curve calculated for each representative unit.

Motor Losses

Selected a motor using the default sizing procedure in the TP NOPR (based on 

power required at 120% BEP flow). For each motor pole and horsepower 

configuration, used the minimum motor efficiency values under 10 CFR 431.25.

Determined part-load motor losses using default method in the TP NOPR.

Control Losses Assumed that all users with variable loads were throttling their pumps. VSD 

users handled in a sub-group analysis.

Energy Use Analysis: Inputs
116

Public Meeting Slides Topics

1 Overview;

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
117

Life-Cycle Cost (LCC) and Payback Period (PBP) Analysis

Purpose

• Provide an economic evaluation from the consumer’s perspective.

• Life-Cycle Cost (LCC) is the total consumer cost over the life of the 

equipment. 

• Payback Period (PBP) is the time required to recover the increased purchase 

price of more energy-efficient equipment through reduced operating costs.

Method

• 10,000 pump installations (pump user + pump) for each LCC run.

• Many variables (discount rate, operating hours per year, total lifetime 

operating hours, load profile type) are chosen from distributions.

• User characteristics (including lifetime and operating hours) are the same 

for all efficiency levels.

• In the base case, pumps are distributed to users according to the efficiency 

distribution in the shipments.

• Pump characteristics change with EL if the user’s base case pump does not 

pass the efficiency criteria for that EL.

• If a pump fails, a user purchases the same pump that has been redesigned 

to meet the efficiency level in each standards case.
118

LCC and PBP Analysis: Overview

Total Installed Cost

Payback Period

Lifetime Operating 

Cost

Life-Cycle Cost

Energy Consumption

Electricity Prices

Annual Energy Cost

Repair Cost

Maintenance Cost

Electricity Price 

Trend

Annual Operating 

Cost

Lifetime

Discount Rates

Customer Price

Installation Cost

Data Inputs

Intermediate Analysis

Output Results

From Engineering 

Analysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups 

Analysis

Baseline MSP

Std-level MSP

From Engineering 

Analysis

Price is a function 

of efficiency

From Energy Use 

Analysis
119

Input Description

Sample Weights Fraction of total sample by pump type, speed, power, flow, sector, and application determined 

based on databases of pump operation in the field, consultant estimates, and shipment data.

Equipment Price

In the base case, determined from the MSP (engineering analysis) and distribution channel 

markups (markups analysis). In each standards case, new MSPs for redesigned pumps are 

determined by distributing conversion costs (engineering analysis) to each power and flow bin 

based on percentage of total revenue, and dividing the new revenue requirement by the 

number of failing pumps. Constant real prices used to project pump equipment prices. (PPI 

does not show a clear trend after 2009.)

Installation Cost Not expected to change with efficiency level, so not included in analysis.

Annual Energy Use Provided by the Energy Use Analysis.

Electricity Prices Based on average national commercial and industrial electricity prices from the AEO 2014

reference case, with extrapolation after 2040.

Maintenance Cost Not expected to change with efficiency level, so not included in analysis.

Repair Cost Not expected to change with efficiency level, so not included in analysis.

Equipment Lifetime

Started with typical service lifetimes in years. Used a distribution of mechanical lifetime in 

hours to allow a negative correlation between annual operating hours and lifetime in years. 

Also lifetime variation by pump speed.

Discount Rate

Used to convert streams of annual operating expenses to the year of purchase (i.e., 2020). For 

industrial, commercial, and agricultural, estimated using the CAPM model (equity capital) and 

Damodaran Online (debt financing). For municipal, calculated based on inflation-adjusted 

interest rates on state and local bonds from 1983 to 2012, issued by the Federal Reserve.

Efficiency Distribution Determined by performance data of shipments provided by manufacturers and HI.

LCC and PBP Analysis: Inputs
120

LCC and PBP Analysis: ESCC 3600 Results

Efficiency 

Level

Average Costs

(2013$)

Average 

Savings 

(2013$)

Percent of 

Consumers

with Net 

Cost (%)

Simple 

Payback

(years) Installed 

Cost

First 

Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

Base Case 1,092 1,592 9,823 10,915 - - -

EL 1 1,098 1,588 9,800 10,898 17 1 1.4

EL 2 1,111 1,574 9,713 10,823 92 2 1.0

EL 3 1,141 1,565 9,653 10,794 122 14 1.8

EL 4 1,170 1,551 9,566 10,736 180 14 1.9

EL 5 1,215 1,528 9,422 10,638 278 12 1.9
121

Public Meeting Slides Topics

1 Overview;

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; Closing Remarks

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
122

Shipments Analysis

Purpose

• To estimate shipments over the 30-year analysis period.

• Shipments are inputs to the National Impact Analysis.

Method

• Use initial shipments estimates for each equipment class from the Hydraulic 

Institute and major manufacturers.

• Distribute total shipments into four sectors using estimates from the LCC.

• Project shipments by sector using the application of indicator variables from 

AEO 2014 forecasts:

• (1) commercial floor space, 

• (2) value of manufacturing shipments (industrial), 

• (3) value of agriculture, mining, and construction shipments (ag), and 

• (4) population (municipal).

• Disaggregate into equipment class based on 2012 market shares.

• Use same shipments in base case and standards case.
123

Shipments Analysis: Results
124

Purpose

• Determine the projected national energy savings and consumer national net present value.

Method

• Develop annual series of national energy and economic impacts.

• Use the shipments model to estimate the total stock of pumps in service each year. 

• Calculate National Energy Savings for 30 years of shipments (2020-2049) as the difference 

between standards case cumulative energy use and base case cumulative energy use.

• Calculate NPV for 30 years of shipments (2020-2049) by comparing standards case to base 

case in terms of cumulative operating cost savings (energy costs) and cumulative installed 

cost increases (equipment prices) and applying a discount rate.

National Impact Analysis

Shipments 

Model

National 

Energy 

Savings

National

Economic

Impacts

LCC Analysis 

Results and 

Other Inputs

National 

Energy Savings 

(Quads)

National 

Net Present Value 

(NPV)

(US$2013, billion)
125

Input Description

Total Installed Cost

Weighted-average per unit values as a function of efficiency level taken from the 

LCC analysis.

Equipment costs vary with efficiency level. Because installation costs do not vary 

by efficiency level, they are not included in this analysis.

Repair and 

Maintenance Costs

Maintenance and repair costs do not vary as a function of efficiency level, and 

are not included in this analysis.

Annual Energy Use

Annual weighted-average per unit values as a function of efficiency level taken 

from LCC analysis. Additional adjustments made for trimmed impellers and 

pumps used with VFDs, which may reduce potential energy savings.

Base-Case 

Efficiencies

Shipments-weighted efficiencies determined for the compliance year. Based on 

base-case efficiency distribution from LCC analysis. No projected growth.

Standards-Case 

Projected 

Efficiencies

For each efficiency level analyzed, DOE used a “roll-up” scenario to establish the 

market shares by efficiency level. No change in efficiency distribution over time.

Energy Prices Projected energy prices from EIA AEO 2014 forecasts (to 2040) and extrapolated 

thereafter.

Full-Fuel-Cycle Multiplier to convert site energy to full-fuel-cycle energy.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A-4.

Present Year Future expenses are discounted to the year 2015.

National Impact Analysis: Inputs
126

National Impact Analysis: Trial Standard Levels

TSL Formulation Criteria

1

Each equipment class (except RSV) moves up one efficiency level from the 

current baseline; RSV remains at baseline.

2

Each equipment class (except RSV) moves up two efficiency levels from the 

current baseline; RSV remains at baseline.

3

Each equipment class (except RSV) moves up three efficiency levels from the 

current baseline; RSV remains at baseline.

4

Each equipment class (except RSV) moves up four efficiency levels from the 

current baseline; RSV remains at baseline.

5

Maximum technologically feasible level, maximum NPV and maximum NES. 

Each equipment class (except RSV) moves up five efficiency levels from the 

current baseline. RSV moves to max-tech.
127

National Impact Analysis: Trial Standard Levels

Equipment Class

Baseline TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Efficiency Level/C-value

ESCC 1800 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

134.43 131.63 128.47 126.67 125.07 123.71

ESCC 3600 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

135.94 134.60 130.42 128.92 127.35 125.29

ESFM 1800 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

134.99 132.95 128.85 127.04 125.12 123.71

ESFM 3600 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

136.59 134.98 130.99 129.26 127.77 126.07

IL 1800 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

135.92 133.95 129.30 127.30 126.00 124.45

IL 3600 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

141.01 138.86 133.84 131.04 129.38 127.35

RSV 1800* EL 0 EL 0 EL 0 EL 0 EL 0 EL 5

129.63 129.63 129.63 129.63 129.63 124.73

RSV 3600* EL 0 EL 0 EL 0 EL 0 EL 0 EL 5

133.20 133.20 133.20 133.20 133.20 129.10

VTS 1800* EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

137.62 135.93 134.13 130.83 128.92 127.29

VTS 3600 EL 0 EL 1 EL 2 EL 3 EL 4 EL 5

137.62 135.93 134.13 130.83 128.92 127.29

*Equipment classes not analyzed due to lack of available data (RSV) or lack of market share (VT-S 1800).
128

National Impact Analysis: National Energy Savings

Equipment Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

quads

ESCC 1800 0.017 0.05 0.08 0.12 0.17

ESCC 3600 0.017 0.08 0.12 0.18 0.28

ESFM 1800 0.003 0.06 0.12 0.25 0.37

ESFM 3600 0.002 0.02 0.03 0.05 0.07

IL 1800 0.016 0.05 0.08 0.12 0.17

IL 3600 0.003 0.01 0.02 0.02 0.03

VTS 3600 0.002 0.02 0.11 0.17 0.24

TOTAL 0.059 0.28 0.56 0.91 1.32

Note: Components may not sum to total due to rounding.

Cumulative Full-Fuel-Cycle National Energy Savings
129

National Impact Analysis: Consumer NPV

National Net Present Value

Equipment Class

Discount 

Rate

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Billion 2013$

ESCC 1800

3% 0.052 0.20 0.29 0.40 0.47

7% 0.018 0.07 0.11 0.14 0.15

ESCC 3600 3% 0.069 0.34 0.46 0.68 1.06

7% 0.028 0.14 0.18 0.26 0.41

ESFM 1800 3% 0.010 0.20 0.44 0.88 1.28

7% 0.003 0.06 0.14 0.27 0.39

ESFM 3600 3% 0.009 0.08 0.14 0.20 0.30

7% 0.003 0.03 0.05 0.07 0.11

IL 1800 3% 0.063 0.18 0.25 0.28 0.34

7% 0.022 0.06 0.08 0.07 0.07

IL 3600 3% 0.011 0.04 0.06 0.08 0.11

7% 0.004 0.01 0.02 0.03 0.04

VTS 3600 3% (0.001) 0.07 0.49 0.71 0.90

7% (0.002) 0.02 0.20 0.28 0.35

TOTAL 3% 0.213 1.11 2.13 3.23 4.47

7% 0.077 0.41 0.77 1.13 1.51

*Numbers in parenthesis indicate negative NPV

Note: Components may not sum to total due to rounding.
130

Public Meeting Slides Topics

1 Overview;

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; 

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
131

MIA: Overview

Purpose:

• To assess the impacts of standards on manufacturers

• To identify and estimate impacts on manufacturer subgroups that may be 

more severely affected than the industry as a whole

• To examine the direct employment, manufacturing capacity, and cumulative 

regulatory impacts on the industry

Methodology:

• Analyze industry cash flow and industry net present value (INPV) using the 

Government Regulatory Impact Model (GRIM):

• Interview manufacturers to refine inputs to the GRIM, develop subgroup 

analyses, and address qualitative issues
132

MIA: INPV

Units Base 

Case

Trial Standard Level

1 2 3 4 5

INPV (2013$ M) 121.4

111.6 

to

121.8

81.9

to 

129.7

22.4

to 

125.4

(85.0)

to 

114.1

(228.4)

to 

94.1

Change in INPV (%) -

(8.0) 

to

.3

(32.5) 

to

6.9

(81.6) 

to

3.3

(170.0) 

to

(6.0)

(288.2) 

to

(22.5)

Results:
133

Results:

• DOE identified twenty-five domestic small business 

manufacturers of pumps falling into the classes that would be 

addressed by the proposed standards.

• DOE only identified one small manufacturer that exclusively 

produced covered product.

• In aggregate, approximately 24% of product offerings from 

small manufacturers were covered by this rule.

• DOE estimates the impacts of a standard on an average small 

business manufacturers would be comparable to the impacts on 

an average large manufacturer.

MIA: Small Business Impacts
134

• LCC Subgroup

– DOE calculated the LCC and PBP for consumers who operate their pumps with variablefrequency drives (VFD) as they will typically have lower energy use and may be 

disproportionately impacted compared with the general user population. 

• Emissions Impact

– Estimates full-fuel-cycle emissions reductions resulting from amended energy conservation 

standards, including carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides (NOX), nitrous 

oxide (N2O), and methane (CH4), mercury (Hg).

– Use AEO 2014 to derive emissions factors applied to annual energy savings from NIA.

• Emissions Monetization

– DOE uses the most current Social Cost of Carbon (SCC) values developed by an interagency 

process.

– DOE also monetizes the NOx emissions reductions resulting from amended standards.

• Utility Impact

– DOE estimates changes in electricity capacity and generation that would result from amended 

energy conservation standards (as compared to the base case).

– Uses cases published from the National Energy Modeling System (NEMS) that incorporate 

efficiency-related policies to estimate the marginal impacts of reduced energy demand on the 

utility sector.

• Employment

– Uses the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect 

employment impacts resulting from amended energy conservation standards.

• Regulatory Impact

– DOE modified the NIA spreadsheet to analyze the six non-regulatory alternatives and their 

impact on purchase price and energy use; presents NES and NPV for these alternatives.

NOPR Analyses
135

Public Meeting Slides Topics

1 Overview;

2 Market & Technology; Screening;

3 Engineering;

4 Markups Analysis; Energy Use;

5 Life-Cycle Cost & Payback Period Analysis;

6 Shipments; National Impact Analysis;

7 MIA; NOPR Analyses; 

8

Proposed Standards; Labeling and Certification; 

Closing Remarks
136

Proposed Standard Levels

Equipment Class Maximum PEI* C-value**

ESCC 1800 1.00 128.47

ESCC 3600 1.00 130.42

ESFM 1800 1.00 128.85

ESFM 3600 1.00 130.99

IL 1800 1.00 129.30

IL 3600 1.00 133.84

RSV 1800 1.00 129.63

RSV 3600 1.00 133.20

VTS 1800 1.00 134.13

VTS 3600 1.00 134.13

*Equipment rated at constant load: PEICL; Equipment rated at variable load: PEIVL

**C-values shown must be used in the equation for PERSTD when calculating PEICL or PEIVL.
137

Labeling Requirements

• The Pumps Working Group recommended that pumps be labeled based 

on the configuration in which they are sold:

• DOE proposes that these labeling requirements be applied to marketing 

materials and pump nameplates.

Bare Pump Bare Pump + Motor Bare Pump + Motor + Controls

PEICL PEICL PEIVL

Model number Model number Model number

Impeller diameter for each unit Impeller diameter for each 

unit

Impeller diameter for each unit
138

Certification Requirements

• The Pumps Working Group recommended specific data be 

included in certification reports.

– DOE proposes to require the data recommended by the Working Group, 

with additions and clarifying modifications.

• The following list summarizes selected key certification data 

requirements proposed by DOE: 

– Equipment class and rating configuration

– Nominal and tested speed in rpm, at the BEP

– BEP flow rate and head at nominal operating speed

– Pump efficiency at BEP

– Nominal motor hp and efficiency

– Driver input hp at each load point, corrected to nominal speed

– PEICL or PEIVL, and whether PEICL or PEIVL is calculated or tested

NOTE: For the complete list of requirements see Section VI of the 

NOPR document.
139

Pool Pumps RFI

• The Pumps Working Group recommended that dedicated-purpose pool pumps be 

addressed as part of a separate rulemaking.

• On April 28, 2015, DOE issued an RFI for dedicated-purpose pool pumps that 

discussed the following topics:

– Review of existing regulatory and voluntary programs

– Scope (definitions, parameters, product type, sales configuration)

– Test procedure and rating metrics

– Data needs for rulemaking analysis

• To clearly distinguish dedicated-purpose pool pumps from the pumps, DOE proposed 

the following design-based definition:

– Dedicated-purpose pool pump means an end suction pump designed specifically to 

circulate water in a pool and that includes an integrated basket strainer.

• The RFI poses whether to treat several types of pumps as dedicated-purpose pool 

pumps:

– Inground and aboveground

– Inflatable pool (integrated filter systems)

– Auxiliary 

– Spa

– Pool cover

– Solar-powered and bottom-feeder

Pumps Working Group Recommendation # 5B
140

Closing Remarks

Meeting participants are invited to provide any closing remarks 

or statements at this time.