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Joint Petition to Adopt Joint Stakeholder Proposal As it Relates to the Rulemaking on Energy Conservation

Standards for Electric Motors

Docket No. EERE–2010–BT–STD–0027

August 15, 2012

National Electrical Manufacturers Association

American Council for an Energy‐Efficient Economy

Appliance Standards Awareness Project

Alliance to Save Energy

Earthjustice

Natural Resources Defense Council

Northwest Energy Efficiency Alliance

Northeast Energy Efficiency Partnerships

Northwest Power and Conservation Council

I. Introduction and Background

Pursuant to sections 325(p)(4) and 345(a) of the Energy Policy and Conservation Act, 42 U.S.C. §§ 6295(p)(4),

6316(a), and section 8 of DOE’s Process Improvement Rule, 10 CFR Part 430, Subpart C, Appendix A, the

parties listed above (the “Joint Stakeholders”) respectfully offer this statement recommending specific

energy conservation standards for electric motors.  Several of the Joint Stakeholders, entities fairly

representative of manufacturers of electric motors and efficiency advocates, have previously submitted in

this rulemaking proceeding the substance of a proposal with respect to energy conservation standards for

electric motors on behalf of the “Motor Coalition,” and they are now joined in this petition by

representatives of additional stakeholders to submit more detailed recommendations to the Secretary of

Energy.  In summary, the recommendations primarily, but not exclusively are aimed at expanding the

coverage of types of electric motors not currently regulated under the Energy Policy and Conservation Act

(EPCA) to achieve the maximum amount of energy savings that are technologically feasible and economically

justified.  Significantly, the recommended energy conservation standards will not require a change in

existing test procedures.1

Energy conservation standards for electric motors were originally established by Congress in 1992 for certain

types or configurations of single‐speed, polyphase, “general purpose” induction motors meeting

specifications found in NEMA Standards Publication MG1‐1987 as defined in section 122 of the Energy Policy

                                                            

1 While no changes in the test procedures are required, some guidance should be included in an Appendix to the test

procedures related to the configuration of some newly regulated electric motors during testing so that uniform practices

are followed.  Appendix B to this petition contains the petitioners’ recommendations.
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Act of 1992, Pub.L. 102‐486. These EPAct 1992 provisions were subsequently amended by section 313 of the

Energy Independence and Security Act of 2007, Pub.L.  110‐140 (EISA 2007), which, among other things,

deleted the definition of “electric motor” in EPAct 1992, and in its place inserted definitions of certain types

of electric motors for which revised energy conservation standards were codified, including some new types

of motors that were not previously subject to energy conservation standards.  EISA 2007 raised the energy

conservation standards for the types of electric motors covered in EPAct 1992 to levels depicted in NEMA

MG‐1, Table 12‐12, while applying the EPAct 1992 energy conservation standard levels (NEMA MG‐1, Table

12‐11) to (a) “fire pump motors,” (b) additional configurations of electric motors not previously regulated by

EPAct 1992 (called “general purpose electric motor subtype II”), and (c) certain higher horsepower NEMA

Design B, general purpose electric motors rated greater than 200 hp up to 500 hp for the first time.   

The Motor Coalition’s proposal incorporated the idea of adopting a very broad definition of electric motor

that would be a “covered product,” and identifying a small number of types of electric motors that would be

excluded from energy conservation standards, primarily because of difficulties in applying test procedures,

but also because of the much lower national energy consumption accounted for by those excluded motor

types.   Recently, on May 4, 2012, the Secretary of Energy adopted a Final Rule amending test procedures

for electric motors and small electric motors, which adopted a broad definition of electric motor,  amending

10 CFR 431.12 to read as follows:  “Electric motor means a machine that converts electrical power into

rotational mechanical power.”  77 Fed. Reg. 26608, 26633 (May 4, 2012). This amendment is consistent with

the proposal of the Motor Coalition in this proceeding, although we would recommend some further

clarifying language so that it is understood that “partial motors” are included in this definition.

To understand the migration of energy conservation standards proposed by the Joint Stakeholders’

recommendations, we refer to the following table that identifies where the improvements in energy savings

would occur from our recommendations.

Motor Type EISA‐2007 Standards Joint Stakeholders’

Recommendations

General Purpose Electric Motor

Subtype I (EPAct 1992 motors) 1‐

200 hp

NEMA MG‐1, Table 12‐12   Unchanged (but extend the

application of Table 12‐12

standards to motors up to 500

hp)

Fire pump electric motors 1‐500

hp

NEMA MG‐1, Table 12‐11 Unchanged

General Purpose Electric Motor

Subtype II (EISA 2007

NEMA MG‐1, Table 12‐11 Except for U‐frame motors,

increase efficiency to NEMA MG‐

1, Table 12‐12 (and extend the
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configurations) 1‐200 hp application of Table 12‐12

standards to motors up to 500

hp)

U‐frame motors NEMA MG‐1, Table 12‐11 as

included in Subtype II

Unchanged, but would now

include U‐frame motors up to

500 hp

NEMA Design B General Purpose

motors, 201 – 500 hp

NEMA MG‐1, Table 12‐11 Increase efficiency to NEMA MG‐

1, Table 12‐12

Other single‐speed polyphase

continuous duty (MG1) or duty

type S1 (IEC), squirrel‐cage (MG)

or cage (IEC) induction electric

motors previously excluded,

including definite purpose,

special purpose, ’56’ frame size

motors that are not “small

electric motors,” 1‐500 hp

Excluded and not regulated Would now be covered at NEMA

MG‐1, Table 12‐12.

Liquid‐cooled electric motors

Submersible electric motors

Air‐over electric motors

Integral brake electric motors

Excluded and not regulated Would remain excluded and not

regulated

Appendix A to this Petition identifies the proposed changes to the current regulations at 10 CFR 431.12,

431.25, and 431.31 that the Joint Stakeholders believe would implement these recommendations, which the

Joint Stakeholders submit is fully consistent with the requirements of the Energy Policy and Conservation

Act.   

We recommend that our proposed new and amended standards be applicable to covered equipment

manufactured on or after January 1, 2015.

II. Identity of the Joint Stakeholders   

The American Council for an Energy‐Efficient Economy (ACEEE) is a nonprofit, non‐partisan, organization

dedicated to advancing energy efficiency as a means of promoting economic prosperity, energy security, and

environmental protection. ACEEE fulfills its mission by conducting in‐depth technical and policy assessments;

advising policymakers and program managers; working collaboratively with businesses, public interest
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groups, and other organizations; publishing books, conference proceedings, and reports; organizing

conferences and workshops; and educating consumers and businesses.

The Appliance Standards Awareness Project (ASAP) is a coalition group dedicated to advancing cost‐effective

energy efficiency standards for appliances and equipment. ASAP works at both the state and federal levels

and is led by a Steering Committee with representatives from consumer groups, utilities, state government,

environmental groups, and energy‐efficiency groups.

The Alliance to Save Energy (Alliance) is a nonprofit organization that promotes energy efficiency worldwide

through research, education and advocacy. The Alliance encourages business, government, environmental

and consumer leaders to use energy efficiency as a means to achieve a healthier economy, a cleaner

environment and greater energy security.   The Alliance’s Associates (members) include more than 160

organizations, composed of manufacturers, commercial, industrial, and utility users of energy, and

associations representing these groups, committed to energy efficiency as a primary way to achieve the

nation's environmental, economic, energy security and affordable housing goals. Associates work with the

Alliance and each other on energy efficiency policy and programs.   

Earthjustice is a non‐profit public interest law firm dedicated to protecting the magnificent places, natural

resources, and wildlife of this earth, and to defending the right of all people to a healthy environment.

The National Electrical Manufacturers Association (NEMA) is a not‐for‐profit trade association representing

approximately 400 manufacturers of electrical equipment and medical imaging products, including all the

major manufacturers of electric motors in the United States.  The current membership of NEMA’s Motor and

Generator Section include the leading manufacturers of energy‐efficient electric motors:  Baldor Electric

Company (an ABB Group member), Cummins, Inc., General Electric Company, Nidec Motor Corporation,  

Regal‐Beloit Corporation, Schneider Electric, SEW Eurodrive, Inc., Siemens Industry, Inc., Sterling Electric,

Inc., TECO‐Westinghouse Motor Company, Toshiba International Corporation, and WEG Electric Corp.    

NEMA and its members who manufacture electric motors have been at the vanguard in promoting the use

of energy efficient electric motors, establishing standards for a more energy‐efficient class of motors known

as NEMA Premium® together with a marketing campaign that has increased market penetration for those

motors that met the higher standards.  NEMA collaborates with other groups in the promotion of energy‐

efficient products.  NEMA has been long‐involved in the national appliance standards program in the

development of energy conservation standards, test procedures, labeling and information requirements.

The Natural Resources Defense Council (NRDC) is a national environmental advocacy organization with over

1.3 million members and online activists. NRDC has spent decades working to build and improve DOE’s

federal appliance standards programs because of the important energy, environmental, consumer, and

reliability benefits of appliance efficiency standards.  NRDC participated in the enactment of the first federal

legislation establishing efficiency standards, and has been active in all significant rulemakings since then.
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The Northeast Energy Efficiency Partnerships (NEEP) is a non‐profit organization that transforms the way we

use and think about energy, through advocacy, collaboration and education designed to accelerate energy

efficiency and highlight its impacts on the region, the economy, and the planet.

The Northwest Energy Efficiency Alliance (NEEA) is a non‐profit organization working to encourage the

development and adoption of energy‐efficient products and services. NEEA is supported by the region's

electric utilities, public benefits administrators, state governments, public interest groups and efficiency

industry representatives. This unique partnership has helped make the Northwest region a national leader in

energy efficiency.

The Northwest Power and Conservation Council is an interstate compact between the states of Idaho,

Montana, Oregon and Washington authorized by the Northwest Electric Power Planning and Conservation

Act of 1980 (PL96‐501).  The Council’s role is to ensure that the Northwest’s electric power system will

provide adequate and reliable energy at the lowest economic and environmental cost to its citizens.  The

U.S. Congress charged the Council with developing integrated electric power plans for the Northwest. These

plans are to rely on cost‐effective conservation as their first priority resource.    

III. Development of the Recommendations

The rationale for the Joint Stakeholder recommendations was first presented to DOE in this proceeding in

October 2010 by Dr. R. Neal Elliott, Associate Director for Research at ACEEE on behalf of ACEEE, NEMA, and

ASAP:

While there are many advanced motor types that aren’t covered [by current DOE energy

conservation standards], including motors using permanent magnet technology, electronically

commutated motor technology, or switched reluctance motor technology, there are also many

motors defined by NEMA as “definite purpose” or “special purpose” within the integral poly‐

phase category that could be covered with the current “general purpose” motors with efficiency

levels as specified by NEMA Standard MG 1, Table 12‐12.  Previous rules have already increased

standards for these covered motors upwards of 95%.  Analysis by NEMA shows that increasing

MEPS for covered, general‐purpose motors would increase their efficiency by 0.7% on average.  

Expanding the definition of covered product to include many “definite purpose” and “special

purpose” could increase the efficiency of these motors by 2.2% to 5.3%.

In addition to resulting in greater energy savings, expanding coverage would dramatically

simplify enforcement of standards by narrowing the scope of products not currently covered by

MEPS.  The current ambiguity in definition of covered products, combined with the large

number of parameters that are used to determine whether a motor is covered by MEPS, has

made the enforcement of the standards more difficult than it needs to be.  We feel it is

important to improve enforcement both because of the energy savings that are lost, but also
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out of a sense of fairness for the 14 NEMA manufacturers who make good‐faith effort to comply

and are undercut by manufacturers and importers who circumvent the standards.  We thus

encourage the Department to seek to simplify definitions of covered products in this coming

rulemaking to make standards more easily enforced.

We encourage DOE to approach the direction of this rulemaking carefully.  Currently, most

domestic manufacturers could produce the motors that would be covered by this proposed

expansion in scope designing models at the MG 1, Table 12‐12 level.  Thus, while there would

still be costs to manufacturers, it would not be an undue burden and standards could go into

effect as soon as 18 months after the Department issues its rule.  This period would be far

shorter than would be undertaken with an approach that increased efficiency levels [above

Table 12‐12 for already regulated equipment], and would result in significant additional savings

from the earlier implementation date, since motors typically have an operating life of

approximately 25 years.   

On the other hand, raising the efficiency levels above MG 1, Table 12‐12 at this point could

result in unintended market impacts that might actually result in increased energy consumption.  

The motor marketplace differs significantly from many other types of equipment covered by

DOE standards.  It is thus important to consider the market impacts of this rule, as well as the

technical aspects of this rule.

Since October 2010, the Motor Coalition has continued to review and discuss the proposal and refine

estimates of the energy savings and other impacts expected from their proposal as well as other

technical aspects.  Further information has been provided by the Motor Coalition to DOE since that time

including joint comments filed in response to the March 2011 Request for Information (76 FR 17577).  

This Petition formalizes their petition for a direct final rule to DOE.   

IV.  DOE’s PTSD Analysis Validates the Motor Coalition’s Proposed Approach

At the Framework stage of this rulemaking, DOE outlined an analysis plan focused primarily on

consideration of increased efficiency for existing covered motors.  As described above, the Motor

Coalition proposed another approach, focused instead on increasing scope of coverage and bringing the

vast majority of motors up to the efficiency levels depicted in Table 12‐12.  This focus would drive large

savings in two ways.  First, the increase in per unit motor efficiency would be much greater for

uncovered motors than any conceivable increase for most already‐covered motors.  Second, applying

Table 12‐12 levels nearly across the board to an expanded pool of covered motors would address the

circumvention of existing standards achieved by slight alterations to motors which would otherwise be

covered.   

In response to the Motor Coalition comments, DOE began to investigate increased scope, leading to

publication of the July 2012 Preliminary Technical Support Document (PTSD). Consistent with DOE’s
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statutory obligations and past practice, DOE evaluated a wide range of efficiency levels (termed

“Candidate Standards Levels” or CSLs), including the electric motors designated by DOE as maximum

technologically feasible.   

The DOE PTSD validates the recommendation of the Motor Coalition and this petition.  The analysis

shows that expanding the applicability of the Table 12‐12 standards as we recommend would save

about 4.4 quads of cumulative energy and yield life cycle cost savings for motor purchasers.2

  Had DOE

adhered to its initial plan of focusing only on increasing efficiency requirements for already covered

motors, achieving 4.4 quads of savings would likely have required the adoption of levels that the PTSD

indicates are not cost‐effective for the vast majority of motor purchasers.3

  The diminishing returns of

further increases in efficiency for currently covered motors are illustrated by the fact that the Motor

Coalition proposal saves more than twice as much energy as increasing the efficiency of subtype I

motors from Table 12‐12 levels to the higher levels depicted in CSL 3.4

Although the PTSD suggests that additional increases in efficiency beyond the Table 12‐12 levels could be

lifecycle cost effective for some motor purchasers, the PTSD fails to account for several factors that undercut the

assumption that higher efficiency levels will lead to increased cost‐effective energy savings.  Raising levels

beyond Table 12‐12 would increase the first cost difference between covered and uncovered motors, fostering

increased rates of circumvention.  The higher initial costs would also encourage refurbishment of existing

motors rather than replacement with more efficient new motors.  Even more problematic, increasing efficiency

                                                            

2 Section VII of this petition addresses scope and the petition’s recommendations would slightly change these savings

estimates.

3 The PTSD projects that raising efficiency levels to CSL 3would yield energy savings of about 7.5 quads – roughly 3.1 quads

more than the energy savings achieved by the standards recommended in this petition.  However, these savings include the

effect of an increase in efficiency for both currently covered motors and motors that are presently exempt from standards.  

The portion of CSL 3’s projected energy savings attributable to already covered motors is likely much less than 4.4 quads, as

discussed further in footnote 3 below.  Therefore, matching the 4.4 quads of savings reached through this petition without

expanding the scope of coverage would likely have necessitated moving currently covered motors up to the levels analyzed

in CSL 4, which the PTSD shows are clearly not cost‐effective.  

4 Because subtype I motors are already required to meet CSL 2 levels, it is possible to separate out the incremental energy

savings projected for CSL 3 into (1) energy savings from subtype I motors and (2) energy savings from subtype II and newly

covered motors.  The incremental increase in energy savings from CSL1 (energy efficient) to CSL2 (premium) is about 4.4 ‐ 1

= 3.4 quads.  This corresponds to an average reduction in total losses of between 20% and 30% (or two to three NEMA

bands).  Assuming 25% (2.5 NEMA bands), then one NEMA band corresponds to an energy savings of 3.442/2.5 = 1.4 quads

for subtype II and newly covered motors.  The increase in energy savings from CSL 2 to CSL 3, one NEMA band, is 7.5 ‐ 4.4 =

3.1 quads.  Of this 3.1 quads, the increase related to the subtype II and newly covered motors is again about 1.4 quads.  

That leaves 3.1 ‐ 1.4 = 1.7 quads as the result of increasing the efficiency level of subtype I.  
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levels beyond the Table 12‐12 levels would impose unacceptable consequences for motor purchasers and motor

manufacturers (see section VI below for more detail).

V. Compliance of the Joint Stakeholder Proposal with the Energy Policy and Conservation Act

Requirements

Any new or amended energy conservation standard prescribed by the Secretary under the Energy Policy

and Conservation Act must be designed to achieve the maximum improvement in energy efficiency,

which the Secretary determines is technologically feasible and economically justified.  42 U.S.C. §

6295(o).   

A. Technical Feasibility

The Joint Stakeholders, which includes NEMA on behalf of its motor manufacturer members,

represent that the recommended standards can be achieved based upon existing technology and

motor design capability.

B. Economic Impact to Commercial and Industrial Consumers including Life Cycle Cost Impacts

Several of the Joint Stakeholders first recommended that DOE consider expanding scope of coverage

nearly two years ago.  Our recommendation at that time was and remains today based on an

assessment that standards set at table 12‐12 levels covering most motors would be cost‐effective on

average for purchasers.  DOE’s lifecycle cost and payback analyses published in the PTSD validate

that assessment.  We believe the DOE analyses provide a reasonable basis for decision‐making.   

The PTSD demonstrates that our recommended standards yield lifecycle cost savings for affected

commercial and industrial customers.  DOE estimates that operating cost savings over the average

estimated life of the covered product exceed the burdens of increases in price. The table below

reproduces DOE’s estimates of the lifecycle cost impacts and payback periods (PTSD Tables ES.3.18 –

ES.3.22) for the efficiency levels we recommend and DOE’s estimated lifetimes (PTSD Table 8.2.31).  

Representative Unit

Recommended CSL

(i.e. NEMA Premium)

Average LCC

savings

Median payback

Estimated product

life

1  (5 hp, Design B) 2 $25 5.1 years 10.5 years

2  (30 hp, Design B) 2 $177 5.3 years 12.2 years

3  (75 hp, Design B) 2 $663 1.5 years 10.3 years

4  (5 hp, Design C) 1 $34 4.6 years 10.9 years

5  (50 hp, Design C) 2 $236 5.9 years 12.8 years
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Our recommended standard levels yield average LCC savings for each of the representative units.  In

each case, the estimated incremental cost of efficiency pays back well within the lifetime of the

affected electric motor.  For representative units 3 ‐ 5, our recommended levels minimize estimated

lifecycle costs.  For representative units 1 and 2, the recommended CSLs are the highest level with

positive LCC impacts which would not result in unacceptably high costs to manufacturers, risk

significant domestic job losses and, potentially, result in the unavailability of some motor types.  

Section VI below provides more detail on why going above the Table 12‐12 levels would be contrary

to EPCA even in those cases where the DOE’s LCC analysis shows positive LCC results.

DOE calculates the net present value of the Joint Stakeholders’ recommended standards at $18

billion using a 3% discount rate and more than $7 billion using a 7% discount rate.  (We note that

DOE found all evaluated levels for Fire Pump motors to increase lifecycle costs.  Therefore, DOE’s

analysis supports our recommendation for no change to the Fire Pump motor standards.)

C. Economic Impact to Manufacturers

The Joint Stakeholders represent that the impacts of the recommended standards on motor

manufacturers will be acceptable.  This conclusion is endorsed by all of the manufacturers in the

NEMA Motor and Generator Section.  Some, but not all designs of presently covered electric motors

which we are recommending should be subject to the energy conservation standards in NEMA MG

1, Table 12‐12, are already designed and sold to Table 12‐12 standards where the customer asks for

it, so the fact that these designs already exist will mitigate some of the burden of shifting to a higher

minimum standard.

The most significant impact on motor manufacturers will occur as a result of enlarging the number

of different types of electric motors which would now be covered by new energy conservation

standards.  This will entail some new designs, retooling, and process changes to increase the

efficiency of such designs not now subject to any energy conservation standards.   

All electric motors impacted by the recommended standards will also require the use of higher

grade electrical steels and other materials in order to meet the higher energy conservation

standards recommended by the Joint Stakeholders.  The supply of these electrical steels is an

important issue for motor manufacturers, but it is believed that the steel and lamination

manufacturers will be able to adjust their production and retool for steel and die changes within the

24‐month period leading to the recommended compliance date.5

D. Energy Savings

                                                            

5 Assuming the proposed Direct Final Rule is published in the Federal Register no later than December 31, 2012.
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The Joint Stakeholders’ recommendations would result in total projected energy savings with

benefits exceeding burdens to the greatest extent practicable. For the efficiency levels we

recommend, the DOE PTSD estimates cumulative national savings of more than 4.4 quads of primary

energy, considering motors sold over a thirty year period (Table ES.3.27).  This estimate places this

rulemaking in the top echelon of recent DOE rules in terms of energy savings delivered for the

nation.  For comparison purposes, the recent clothes washer standard will save 2 quads and the

recent fluorescent ballast standard will save 2.7 – 5.6 quads according to DOE.  

E. Lessening of Utility or Performance or Availability of Products

The Joint Stakeholders’ recommendations will provide no significant lessening of utility or

performance or availability of covered products as prohibited by the Energy Policy and Conservation

Act.  The primary impact will be the elimination of some SKUs that will not meet the higher energy

conservation standards, but this does not mean a reduction in the performance or availability of

electric motors.  

F. Impact of Lessening of Competition

The Joint Stakeholders believe their recommendations would not support a Department of Justice

determination that the standard would lead to the likelihood of reduced competition under the

Energy Policy and Conservation Act.  The recommendations were developed through a negotiation

process that included the active participation of the manufacturers of electric motors and have been

designed to mitigate any negative competitive impacts.  The recommendations are not expected to

eliminate any competitors.   

G. Need of the Nation to Conserve Energy

Improved energy efficiency improves the nation’s energy security, strengthens the economy, and

reduces the environmental impact of energy production. As noted in Paragraph D. above, the

energy savings from the Joint Stakeholders’ recommendations will reach more than 4.4 quads

considering motors sold over a thirty year period according to DOE.  One of the most significant

opportunities for further domestic energy savings is in the industrial sector, and the recommended

standards are expected to have their greatest energy saving impact there.   

H. Other Factors

Looking forward, one of the most exciting opportunities for further energy conservation in the industrial

sector is expected to be derived from advanced motor technology systems such as a combination of a motor

and any required associated electronic control, which offers variable or multiple speed operation, and uses

permanent magnet technology, electronically commutated motor technology, or switched reluctance motor

technology.  Manufacturers are beginning to make significant investments in these advanced systems, and
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energy conservation standards above Table 12‐12, in addition to imposing higher costs on motor customers

and users with projected per unit energy savings significantly smaller than the energy savings projected from

the Joint Stakeholders recommendations, would divert manufacturer resources available for development

away from advanced motor technologies to compliance.  The Joint Stakeholders’ proposal will have the

additional benefit of simplifying enforcement, because it substantially reduces the number of electric

motors that are excluded from regulation and the time and effort in distinguishing covered from non‐

covered equipment.

VI.    Levels Higher Than the Joint Stakeholder Proposal Are Not Justified

Section V of this petition explains why the Joint Stakeholders’ recommendation meets EPCA’s criteria for

new standards.  Any energy efficiency level higher than the recommended levels is not economically justified for

the following reasons:

A. Unacceptable impacts on manufacturers.   The impacts of requiring manufacturers to produce

electric motors to higher minimum energy efficiency standards than the levels recommended by

the Joint Stakeholders’ petition are substantial.  While DOE’s PTSD notes there are manufacturer

catalogs that show general purpose motors with higher efficiency levels than those cited in

Table 12‐12 of NEMA MG‐1, there is no manufacturer that makes a complete line of electric

motors exceeding the standards in Table 12‐12.  The few cited examples are not generally

representative of a given manufacturer’s complete product line.  The examples represent a

small fraction of the product line and do not reflect the challenges to motor manufacturers of

increasing efficiency more broadly across their product lines. To raise efficiency to CSL‐3, every

manufacturer will need to redesign a significant portion of their product line, either electrically,

mechanically or both, in order to raise efficiency.  The cost of the redesign and implementation

of increasing energy conservation standards above Table 12‐12 is estimated to be $80‐$100

million per manufacturer, easily one billion dollars for the entire industry.  Additionally,

manufacturers will be forced to procure more expensive materials and would face additional

direct labor costs (hand winding vs. machine winding) to manufacture these electric motors.  

This converts the acceptable burden of the Joint Stakeholders’ proposal to an unacceptable

burden that is economically unjustifiable.  The motor manufacturers would require a much,

much longer time to retool in order to meet the higher requirements than the January 1, 2015

effective date contemplated by the Joint Stakeholders’ proposal, and in that case the earlier

energy savings contemplated by the Joint Petition would be lost.  Motor manufacturers

conservatively estimate that the time needed to comply with efficiency standards above Table

12‐12 is greater than five years and perhaps as much as seven years.  Such extensive redesign

and use of new materials would require extensive prototype testing as well as final design

testing to be certain each redesign would meet the higher efficiency standard.  The qualification

testing of final designs for certification under the requirements in 10 CFR §§ 431.17 and 431.36

cannot be accomplished until after all the infrastructure is in place to produce the electric

motors as general production units.  In addition to the financial burden already mentioned,

electrical and mechanical engineering resources are simply unavailable to accomplish such a
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challenge in a shorter amount of time, and the machine tool industry would not have the

capacity to meet the retooling demands of motor manufacturers in a shorter period of time.

B. Unacceptable impacts on customers.   If motor manufacturers have to redesign most of their

product lines to higher efficiency levels, some if not many of those redesigns will present

problems for OEM customers who will have to redesign their products in which motors are used

because of the increase in frame size.  In addition to the costs OEM customers would incur for

product redesign, CSL 3 levels could impact the utility of replacement products for existing uses.  

This would also necessitate a substantial delay in the effective date of the standards as well.

C. Other factors in the national interest.   The concern here is related to principles that underlie

Executive Orders 13609, 77 Fed.Reg. 26413 (May 1, 2012), and 13563, 76 Fed.Reg. 3821

(January 8, 2011), where it is recognized that harmonization, rather than divergence among

international standards can promote export sales.  Domestic manufacturers of electric motors

have been promoting improved energy conservation standards outside the United States

harmonized with Table 12‐12 standards in part as an export growth strategy.  Domestic motor

manufacturers who design and produce electric motors to meet US energy conservation

standards have difficulty competing outside the US with motor manufacturers who build less

efficient motors meeting the lower efficiency standards in other countries.  Secondly, if US

standards for induction motors are promulgated above Table 12‐12 levels, it becomes very

difficult to promote harmonization if the US should adopt a very expensive domestic standard

that is not likely to be supported and adopted by other countries.  For example, the IEC 60034‐

306 Standard defining the IE classification of efficiency levels referred to as the source of

efficiency standard levels for induction motors in various countries states that “it is expected

that technologies other than cage induction motors will be required to meet IE4 levels,” which

are those values above the IE3 equivalent of Table 12‐12 for 60 Hz.  This is a significant factor

that weighs in favor of the Joint Stakeholders’ proposal.  Third, lack of harmonization may have

an additional impact on US machinery manufacturers who are building equipment with

compliant motors that compete against importers that bring in equipment that has much less

expensive non‐compliant motors because of enforcement limitations.  Harmonization of

standards reduces this risk.  Fourth, harmonization enhances compliance and enforcement

domestically.

VII.    Integral Brake Motors, U‐frame motors and Fire Pump Motors   

The recommended scope of coverage provided in this petition is very close to that included in DOE’s

PTSD analysis.  In addition, DOE has generally proposed product classes that are consistent with our

recommendations.  In this section, we address our proposed treatment for three particular motor types,

including where the DOE analysis diverges from the joint proposal.   

                                                            

6 IEC 60034‐30 (Edition 1.0, 2008‐10, Part 30:  Efficiency classes of single speed, three‐phase, cage‐induction motors (IE‐

code).
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A. Integral brake motors.  The Joint Stakeholder proposal includes an exclusion for integral brake

motors.  The primary reason for this exclusion is that there are compliance and enforcement

complications for integral brake motors, because there are no test standards for this motor type.  

Removal of the integral brake parts for testing just the motor may leave the electric motor

inoperable or may alter the physical arrangement of parts so as to affect severely the ability of the

motor to dissipate heat in the motor at rated load.  For example, removal of the brake components

between an exterior fan and the motor endshield will leave a large empty void that inhibits effective

distribution of the airflow from the fan over the motor frame.  Losses would be specific to each

manufacturer, and would not be uniformly comparable across the industry. The total losses of an

integral brake motor differ by design, and removing the brake or building a motor without a brake,

does not give an accurate result.  Secondly, this motor type is a very small percentage of the market

and has a de minimis impact on energy consumption.  NEMA members estimate that the number of

integral brake motors sold each year in the United States is no more than 150,000 units,

representing no more than 0.9% of the connected horsepower of all covered equipment.

B. U‐frame motors.   The Joint Stakeholder proposal includes a proposal for maintaining U‐frame

motors at Table 12‐11 nominal efficiency levels.   The reason for maintaining U‐frame motors at

Table 12‐11 is because the cost of redesigning this legacy product that is rapidly becoming obsolete

is high relative to the potential savings,7 and there is no likelihood of subversion of higher energy

conservation standards applicable to other types of covered electric motors because of the

availability of U‐frame motors meeting lower energy conservation standards. Most of the customers

who used U‐frame motors in the past have transitioned to other motor types as substitutes and will

not return to U‐frame motors.  The U‐frame motor is no longer sold for OEM applications, but it is

sold entirely as a replacement motor to the customer who has not transitioned to a T‐frame motor

or other substitute. The number of units of U‐frame motors sold today is estimated to be under

0.2% of the market, and there is very little impact on overall energy consumption by applying Table

12‐12 to these motors.  

C. Fire pump electric motors.  As summarized in the introduction to this petition, the Joint

Stakeholders recommend no change to the existing standards for fire pump electric motors.  DOE’s

analysis supports this recommendation, finding that no increase in efficiency yields lifecycle cost

savings for most fire pump motor purchasers (PTSD Tables ES.3.23 and ES.3.24).8

  The Joint

                                                            

7 NEMA manufacturers estimate the cost of re‐design for U‐frame motors to comply with Table 12‐12 levels as follows:  

there are 18 horsepower ratings and 3 speeds (2‐4‐6 pole) to be evaluated = 54 ratings x 4 days (32 hours) of design and

testing @ $85/hour = $146,880.  Rather than incur the higher cost of compliant U‐frame motors built to Table 12‐12

standards, users may convert to T‐frame motors with adaptor bases.  This could reduce the number of sellers of U‐frame

motors to one or two.

8 We believe that DOE’s analysis for 75 hp fire pump motors, which does show some efficiency increase to be cost‐effective

is anomalous for two reasons: first, DOE found standards for smaller fire pump motors to be not cost effective and, second,

DOE’s results estimate significantly better cost effectiveness for 75 hp fire pump motors than all other 75 hp motors,
14

Stakeholder proposal would create unique marking requirements for fire pump electric motors so

that they would be used only with fire pumps and require that they go through the special third‐

party conformity assessment and listing requirements for fire pump electric motors in NFPA 20.  The

Joint Stakeholders submit that these measures will discourage the subversion of energy

conservation standards applicable to other electric motors.  As the DOE’s PTSD acknowledges, DOE

is aware of the low volume and run‐time (intermittent use) of fire pump electric motors.  This means

there is extremely low energy consumption associated with the use of this class of electric motors,

and there is very little energy savings potential in increasing fire pump electric motor efficiency.

VIII. Definitions

The Joint Petitioners have recommended new definitions for types of electric motors specifically

relating to new terms used in this proposal in the regulatory text contained in Appendix A to this

petition.  Where it was mutually acceptable, the Joint Petitioners have adopted the definitions from

the PTSD.  Where further technical clarification was appropriate, an additional word or words were

added to improve some definitions proposed in the PTSD.  See “liquid‐cooled electric motor,” “air‐

over electric motor,” and “partial motor.”  In the case of “submersible electric motor,” the Joint

Petitioners did not mutually agree to add the second sentence of the definition proposed in the

PTSD, and recommend slightly different wording for the first sentence.  The Joint Petitioners may

submit further comments explaining their recommendations with regard to the proposed definitions

prior to the PTSD comment deadline.

IX. Conclusion

       The Joint Petitioners recommend that the DOE adopt the energy conservation standards in accord with the

language contained in Appendix A. The Joint Petitioners’ proposal would yield very large, economically justified

energy savings on an accelerated schedule. The proposal is further designed to limit circumvention and facilitate

enforcement. We ask that the proposal be adopted no later than December 17, 2012.

Respectfully submitted,

     Kyle Pitsor           R. Neal Elliott

Vice‐President Government Relations     Associate Director for Research

National Electrical Manufacturers Association American Council for an Energy Efficient Economy

                                                                                                                                                                                                              

despite an assumption of identical equipment costs and far lower annual operating hours for fire pump motors.  It’s not

possible to have the same costs but lower benefits and have improved cost‐effectiveness.
15

Andrew deLaski           Charlie Stephens

Executive Director         Sr. Energy Codes & Standards Engineer

Appliance Standards Awareness Project     Northwest Energy Efficiency Alliance

Meg Waltner R. Bruce Lung

Energy Efficiency Advocate Director, Industrial Program

Natural Resource Defense Council Alliance to Save Energy

   Tom Eckman           Tim Ballo

Manager, Conservation Resources     Senior Associate Attorney

Northwest Power and Conservation Council    Earthjustice

Susan Coakley

Executive Director

Northeast Energy Efficiency Partnerships  
16

APPENDIX A

How the Joint Petitioners Envision the Rule Would Look on Effective Date Amending

10 CFR 431.12, 431.25, and 431.31

(Recommended Revisions Shown in Bold; Deletions Strikethrough)

§ 431.12 Definitions.

The following definitions apply for purposes of this subpart, and of subparts U and V of this part. Any words or terms not 

defined in this Section or elsewhere in this Part shall be defined as provided in Section 340 of the Act.

Accreditation means recognition by an accreditation body that a laboratory is competent to test the efficiency of electric 

motors according to the scope and procedures given in Test Method B of IEEE Std 112–2004 and CSA C390–10 

(incorporated by reference, see 10 CFR §431.15.).

Accreditation body means an organization or entity that conducts and administers an accreditation system and grants 

accreditation.

Accreditation system means a set of requirements to be fulfilled by a testing laboratory, as well as rules of procedure and 

management, that are used to accredit laboratories.

Accredited laboratory means a testing laboratory to which accreditation has been granted.

Air-over electric motor means an electric motor which requires cooling provided by a ventilating means not supplied 

with the electric motor. 

Alternative efficiency determination method or AEDM means, with respect to an electric motor, a method of calculating the 

total power loss and average full load efficiency.

Average full load efficiency means the arithmetic mean of the full load efficiencies of a population of electric motors of 

duplicate design, where the full load efficiency of each motor in the population is the ratio (expressed as a percentage) of the 

motor's useful power output to its total power input when the motor is operated at its full rated load, rated voltage, and rated 

frequency.

Basic model means, with respect to an electric motor, all units of a given type of electric motor (or class thereof) 

manufactured by a single manufacturer, and which have the same rating, have electrical characteristics that are essentially 

identical, and do not have any differing physical or functional characteristics which affect energy consumption or efficiency. 

For the purpose of this definition, “rating” means one of the 113 184combinations of an electric motor's horsepower (or 

standard kilowatt equivalent), number of poles, and open or enclosed construction, with respect to which § 431.25 prescribes 

nominal full load efficiency standards.

Certificate of conformity means a document that is issued by a certification program, and that gives written assurance that an 

electric motor complies with the energy efficiency standard applicable to that motor, as specified in § 431.25.

Certification program means a certification system that determines conformity by electric motors with the energy efficiency 

standards prescribed by and pursuant to the Act.

Certification system means a system, that has its own rules of procedure and management, for giving written assurance that a 
17

product, process, or service conforms to a specific standard or other specified requirements, and that is operated by an entity

independent of both the party seeking the written assurance and the party providing the product, process or service.

CSA means Canadian Standards Association.

Definite purpose motor9 means any motor that cannot be used in most general purpose applications and is designed either:

(1) To standard ratings with standard operating characteristics or standard mechanical construction for use under service 

conditions other than usual, such as those specified in NEMA MG1–2009, paragraph 14.3, “Unusual Service Conditions,” 

(incorporated by reference, see § 431.15); or

(2) For use on a particular type of application.

Electric motor means a machine that converts electrical power into rotational mechanical power, including but not limited 

to partial motors. 

Enclosed motor means an electric motor so constructed as to prevent the free exchange of air between the inside and outside 

of the case but not sufficiently enclosed to be termed airtight.

Fire pump electric motor means an electric motor, including any IEC–equivalent, that is marked in accordance with § 

431.31(a)(iii) and that meets the requirements of section 9.5 of NFPA 20 (incorporated by reference, see § 431.15), 

including the requirement of being specifically listed for fire pump service.

Fire pump motors [Reserved by 74 FR 12071].

General purpose electric motor10 means any electric motor that is designed in standard ratings with either:

(1) Standard operating characteristics and mechanical construction for use under usual service conditions, such as those 

specified in NEMA MG1–2009, paragraph 14.2, “Usual Service Conditions,” (incorporated by reference, see § 431.15) and 

without restriction to a particular application or type of application; or

(2) Standard operating characteristics or standard mechanical construction for use under unusual service conditions, such as 

those specified in NEMA MG1–2009, paragraph 14.3, “Unusual Service Conditions,” (incorporated by reference, see § 

431.15) or for a particular type of application, and which can be used in most general purpose applications.

General purpose electric motor (subtype I)11 means a general purpose electric motor that:

(1) Is a single-speed, induction motor;

(2) Is rated for continuous duty (MG1) operation or for duty type S1 (IEC);

                                                            

9 Note:  this definition will not be relevant after January 1, 2015.

10 No longer relevant after January 1, 2015.

11 No longer relevant after January 1, 2015.
18

(3) Contains a squirrel-cage (MG1) or cage (IEC) rotor;

(4) Has foot-mounting that may include foot-mounting with flanges or detachable feet;

(5) Is built in accordance with NEMA T–frame dimensions or their IEC metric equivalents, including a frame size that is 

between two consecutive NEMA frame sizes or their IEC metric equivalents;

(6) Has performance in accordance with NEMA Design A (MG1) or B (MG1) characteristics or equivalent designs such as 

IEC Design N (IEC);

(7) Operates on polyphase alternating current 60–hertz sinusoidal power, and:

(i) Is rated at 230 or 460 volts (or both) including motors rated at multiple voltages that include 230 or 460 volts (or both), or

(ii) Can be operated on 230 or 460 volts (or both); and

(8) Includes, but is not limited to, explosion-proof construction.

NOTE to Definition of General purpose electric motor (subtype I): References to “MG1” above refer to NEMA Standards 

Publication MG1–2009 (incorporated by reference in § 431.15). References to “IEC” above refer to IEC 60034–1, 60034–12, 

60050–411, and 60072–1 (incorporated by reference in § 431.15), as applicable.

General purpose electric motor (subtype II)12 means any general purpose electric motor that incorporates design elements of a 

general purpose electric motor (subtype I) but, unlike a general purpose electric motor (subtype I), is configured in one or 

more of the following ways:

(1) Is built in accordance with NEMA U–frame dimensions as described in NEMA MG1–1967 (incorporated by reference, 

see § 431.15) or in accordance with the IEC metric equivalents, including a frame size that is between two consecutive 

NEMA frame sizes or their IEC metric equivalents;

(2) Has performance in accordance with NEMA Design C characteristics as described in MG1 or an equivalent IEC design(s) 

such as IEC Design H;

(3) Is a close-coupled pump motor;

(4) Is a footless motor;

(5) Is a vertical solid shaft normal thrust motor (as tested in a horizontal configuration) built and designed in a manner 

consistent with MG1;

(6) Is an eight-pole motor (900 rpm); or

(7) Is a polyphase motor with a voltage rating of not more than 600 volts, is not rated at 230 or 460 volts (or both), and 

cannot be operated on 230 or 460 volts (or both).

                                                            

12 No longer relevant after January 1, 2015.
19

NOTE to Definition of General purpose electric motor (subtype II): With the exception of the NEMA Motor Standards 

MG1–1967 (incorporated by reference in § 431.15), references to “MG1” above refer to the 2009 NEMA MG1–2009 

(incorporated by reference in § 431.15). References to “IEC” above refer to IEC 60034–1, 60034–12, 60050–411, and 

60072–1 (incorporated by reference in § 431.15), as applicable.

IEC means the International Electrotechnical Commission.

IEEE means the Institute of Electrical and Electronics Engineers, Inc. 

Integral brake electric motor means an electric motor containing a brake mechanism either inside of the motor 

endshield or between the motor fan and endshield such that removal of the brake component would require extensive 

disassembly of the motor or motor parts.

Liquid-cooled electric motor means an electric motor which is cooled by circulating liquid, with the liquid or liquid 

filled conductors coming in direct contact with the electric motor parts. 

NEMA design B general purpose electric motor [Reserved].

NEMA Design B electric motor means a squirrel-cage motor that is:

(1) Designed to withstand full-voltage starting;

(2) Develops locked-rotor, breakdown, and pull-up torques adequate for general application as specified in sections 12.38, 

12.39 and 12.40 of NEMA MG1–2009 (incorporated by reference, see § 431.15);

(3) Draws locked-rotor current not to exceed the values shown in section 12.35.1 for 60 hertz and 12.35.2 for 50 hertz of 

NEMA MG1–2009; and

(4) Has a slip at rated load of less than 5 percent for motors with fewer than 10 poles.

NEMA means the National Electrical Manufacturers Association.

Nominal full-load efficiency means, with respect to an electric motor, a representative value of efficiency selected from the 

“nominal efficiency” column of Table 12–10, NEMA MG1–2009, (incorporated by reference, see § 431.15), that is not 

greater than the average full-load efficiency of a population of motors of the same design.

Open motor means an electric motor having ventilating openings which permit passage of external cooling air over and 

around the windings of the machine.

Partial electric motor means an assembly necessitating only the addition of one or two endshields with bearings to 

create an operable electric motor. Included under this definition are integral motors and partial 3⁄4 motors. 

Special purpose motor13 means any motor, other than a general purpose motor or definite purpose motor, which has special 

operating characteristics or special mechanical construction, or both, designed for a particular application.

                                                            

13 Not relevant after January 1, 2015.
20

Submersible electric motor means an electric motor designed for operation while continuously submersed in a liquid. 

Total power loss means that portion of the energy used by an electric motor not converted to rotational mechanical power, 

expressed in percent.

§ 431.25 Energy conservation standards and effective dates.

(a) Except as provided for fire pump electric motors in paragraph (b) of this section, each general purpose electric motor 

(subtype I) with a power rating of 1 horsepower or greater, but not greater than 200 horsepower, including a NEMA Design 

B or an equivalent IEC Design N motor that is a general purpose electric motor (subtype I), manufactured (alone or as a 

component of another piece of equipment) on or after December 19, 2010, shall have a nominal full-load efficiency that is 

not less than the following:

Table 1--Nominal Full-Load Efficiencies of General Purpose Electric Motors (Subtype I), Except Fire Pump Electric Motors

Motor 

horsepower/stan

dard kilowatt 

equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

6 4 2 6 4 2

1/.75 82.5 85.5 77.0 82.5 85.5 77.0

1.5/1.1 86.5 86.5 84.0 87.5 86.5 84.0

2/1.5 87.5 86.5 85.5 88.5 86.5 85.5

3/2.2 88.5 89.5 85.5 89.5 89.5 86.5

5/3.7 89.5 89.5 86.5 89.5 89.5 88.5

7.5/5.5 90.2 91.0 88.5 91.0 91.7 89.5

10/7.5 91.7 91.7 89.5 91.0 91.7 90.2

15/11 91.7 93.0 90.2 91.7 92.4 91.0

20/15 92.4 93.0 91.0 91.7 93.0 91.0

25/18.5 93.0 93.6 91.7 93.0 93.6 91.7

30/22 93.6 94.1 91.7 93.0 93.6 91.7

40/30 94.1 94.1 92.4 94.1 94.1 92.4

50/37 94.1 94.5 93.0 94.1 94.5 93.0

60/45 94.5 95.0 93.6 94.5 95.0 93.6

75/55 94.5 95.0 93.6 94.5 95.4 93.6

100/75 95.0 95.4 93.6 95.0 95.4 94.1

125/90 95.0 95.4 94.1 95.0 95.4 95.0

150/110 95.4 95.8 94.1 95.8 95.8 95.0

200/150 95.4 95.8 95.0 95.8 96.2 95.4
21

(b) Each fire pump electric motor that is a general purpose electric motor (subtype I) or general purpose electric motor 

(subtype II) manufactured (alone or as a component of another piece of equipment) on or after December 19, 2010, shall have 

a nominal full-load efficiency that is not less than the following:

Table 2--Nominal Full-Load Efficiencies of Fire Pump Electric Motors

Motor 

horsepower/

standard

kilowatt 

equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2

1/.75 74.0 80.0 82.5 74.0 80.0 82.5 75.5

1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5

2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0

3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5

5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5

7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5

10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5

15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2

20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2

25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0

30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0

40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7

50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4

60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0

75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0

100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6

125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5

150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5

200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4

300/224 95.4 95.4 95.0 95.0 95.4 95.4

350/261 95.4 95.4 95.0 95.0 95.4 95.4

400/298 95.4 95.4 95.4 95.4

450/336 95.8 95.8 95.4 95.4

500/373 95.8 95.8 95.8 95.4
22

(c) Except as provided for fire pump electric motors in paragraph (b) of this section, each general purpose electric motor 

(subtype II) with a power rating of 1 horsepower or greater, but not greater than 200 horsepower, including a NEMA Design 

B or an equivalent IEC Design N motor that is a general purpose electric motor (subtype II), manufactured (alone or as a 

component of another piece of equipment) on or after December 19, 2010, shall have a nominal full-load efficiency that is 

not less than the following:

 

Table 3--Nominal Full-Load Efficiencies of General Purpose Electric Motors (Subtype II), Except Fire Pump Electric 

Motors

Motor 

horsepower/

standard 

kilowatt 

equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2

1/.75 74.0 80.0 82.5 74.0 80.0 82.5 75.5

1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5

2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0

3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5

5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5

7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5

10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5

15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2

20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2

25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0

30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0

40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7

50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4

60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0

75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0

100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6

125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5

150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5

200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0
23

(d) Each NEMA Design B or an equivalent IEC Design N motor that is a general purpose electric motor (subtype I) 

or general purpose electric motor (subtype II), excluding fire pump electric motors, with a power rating of more than 

200 horsepower, but not greater than 500 horsepower, manufactured (alone or as a component of another piece of 

equipment) on or after December 19, 2010, shall have a nominal full-load efficiency that is not less than the 

following:

Table 4--Nominal Full-Load Efficiencies of NEMA Design B General Purpose Electric Motors (Subtype I and II), 

Except Fire Pump Electric Motors

Motor 

horsepower

/

standard 

kilowatt 

equivalent

Nominal full-load efficiency

Open motors

(number of poles)

Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4

300/224 95.4 95.4 95.0 95.0 95.4 95.4

350/261 95.4 95.4 95.0 95.0 95.4 95.4

400/298 95.4 95.4 95.4 95.4

450/336 95.8 95.8 95.4 95.4

500/373 95.8 95.8 95.8 95.4

(e) For purposes of determining the required minimum nominal full-load efficiency of an electric motor that has a 

horsepower or kilowatt rating between two horsepower or two kilowatt ratings listed in any table of energy 

conservation standards in paragraphs (a) through (d) of this section, each such motor shall be deemed to have a 

listed horsepower or kilowatt rating, determined as follows:

(1) A horsepower at or above the midpoint between the two consecutive horsepowers shall be rounded up to the 

higher of the two horsepowers;

(2) A horsepower below the midpoint between the two consecutive horsepowers shall be rounded down to the 

lower of the two horsepowers; or

(3) A kilowatt rating shall be directly converted from kilowatts to horsepower using the formula 1 kilowatt = 

(1/0.746) horsepower. The conversion should be calculated to three significant decimal places, and the resulting 

horsepower shall be rounded in accordance with paragraph (e)(1) or (e)(2) of this section, whichever applies.

(f) This section doesThe requirements of paragraphs (a) through (d) of this section do not apply to definite 

purpose motors, special purpose motors, or those motors exempted by the Secretary. 

(g) Each NEMA Design A, B, or C type (MG1), or IEC Design H or N type (IEC), single-speed, polyphase, 

continuous duty (MG1) or duty type S1 (IEC), squirrel-cage (MG1) or cage (IEC) induction electric motor 

with a rating of 1 horsepower or greater, but not greater than 500 horsepower, rated for operation directly on 
24

nominal 60 Hertz sinusoidal power and rated 600 volts or less, manufactured (alone or as a component of 

another piece of equipment) on or after January 1, 2015, except ---

(i) electric motors listed for use with fire pumps covered by paragraph (h) of this section, 

(ii) electric motors constructed in U-frames covered by paragraph (i) of this section, 

(iii) electric motors identified in paragraph (j) of this section, and 

(iv) electric motors exempted by the Secretary --- --- 

shall have a nominal full load efficiency that is not less than as shown in the following table: 

Motor 

horsepower/standard 

kilowatt equivalent

Nominal full-load efficiency

Open motors

(number of poles)

 Enclosed motors

(number of poles)

8 6 4 2 8 6 4 2

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

1.5/1.1 77.0 86.5 86.5 84.0 78.5 87.5 86.5 84.0

2/1.5 86.5 87.5 86.5 85.5 84.0 88.5 86.5 85.5

3/2.2 87.5 88.5 89.5 85.5 85.5 89.5 89.5 86.5

5/3.7 88.5 89.5 89.5 86.5 86.5 89.5 89.5 88.5

7.5/5.5 89.5 90.2 91.0 88.5 86.5 91.0 91.7 89.5

10/7.5 90.2 91.7 91.7 89.5 89.5 91.0 91.7 90.2

15/11 90.2 91.7 93.0 90.2 89.5 91.7 92.4 91.0

20/15 91.0 92.4 93.0 91.0 90.2 91.7 93.0 91.0

25/18.5 91.0 93.0 93.6 91.7 90.2 93.0 93.6 91.7

30/22 91.7 93.6 94.1 91.7 91.7 93.0 93.6 91.7

40/30 91.7 94.1 94.1 92.4 91.7 94.1 94.1 92.4

50/37 92.4 94.1 94.5 93.0 92.4 94.1 94.5 93.0

60/45 93.0 94.5 95.0 93.6 92.4 94.5 95.0 93.6

75/55 94.1 94.5 95.0 93.6 93.6 94.5 95.4 93.6

100/75 94.1 95.0 95.4 93.6 93.6 95.0 95.4 94.1

125/90 94.1 95.0 95.4 94.1 94.1 95.0 95.4 95.0

150/110 94.1 95.4 95.8 94.1 94.1 95.8 95.8 95.0

200/150 94.1 95.4 95.8 95.0 94.5 95.8 96.2 95.4

250/186 95.0 95.4 95.8 95.0 95.0 95.8 96.2 95.8 

300/224 95.0 95.4 95.8 95.4 95.0 95.8 96.2 95.8 

350/261 95.0 95.4 95.8 95.4 95.0 95.8 96.2 95.8 

400/298 95.0 95.8 95.8 95.8 95.0 95.8 96.2 95.8 

450/336 95.0 96.2 96.2 95.8 95.0 95.8 96.2 95.8 

500/373 95.0 96.2 96.2 95.8 95.0 95.8 96.2 95.8 
25

(h) FIRE PUMP ELECTRIC MOTORS.--- Each fire pump electric motor with a horsepower rating of 1 

horsepower or greater, but not greater than 500 horsepower, manufactured (alone or as a component of 

another piece of equipment) on or after January 1, 2015, shall have a nominal full load efficiency that is not 

less than as shown in the following table: 

Motor 

horsepower/standard

kilowatt equivalent

Nominal full-load efficiency

 

Open motors Enclosed motors

(number of poles) (number of poles)

8 6 4 2 8 6 4 2

1/.75 74.0 80.0 82.5 74.0 80.0 82.5 75.5

1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5

2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0

3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5

5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5

7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5

10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5

15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2

20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2

25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0

30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0

40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7

50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4

60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0

75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0

100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6

125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5

150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5

200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4

300/224 95.4 95.4 95.0 95.0 95.4 95.4

350/261 95.4 95.4 95.0 95.0 95.4 95.4

400/298 95.4 95.4 95.4 95.4

450/336 95.8 95.8 95.4 95.4

500/373 95.8 95.8 95.8 95.4

 
26

(i) U-FRAME ELECTRIC MOTORS.--- Each electric motor as described in paragraph (g) of this section, 

constructed in a U-frame with a horsepower rating of 1 horsepower or greater, but not greater than 500 

horsepower, manufactured (alone or as a component of another piece of equipment) on or after January 1, 

2015, shall have a nominal full load efficiency that is not less than as shown in the following table: 

Motor 

horsepower/standard

kilowatt equivalent

Nominal full-load efficiency

 

Open motors Enclosed motors

(number of poles) (number of poles)

8 6 4 2 8 6 4 2

1/.75 74.0 80.0 82.5 74.0 80.0 82.5 75.5

1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5

2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0

3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5

5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5

7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5

10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5

15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2

20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2

25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0

30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0

40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7

50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4

60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0

75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0

100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6

125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5

150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5

200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0

250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4

300/224 95.4 95.4 95.0 95.0 95.4 95.4

350/261 95.4 95.4 95.0 95.0 95.4 95.4

400/298 95.4 95.4 95.4 95.4

450/336 95.8 95.8 95.4 95.4

500/373 95.8 95.8 95.8 95.4

 (j) EXCLUSIONS.--- The following electric motors are excluded from the standards under this section: 

(i) Liquid-cooled electric motors; 
27

(ii) Submersible electric motors; 

 (iii) Small electric motors defined in 10 CFR 431.442 and covered by the energy conservation 

standards in 10 CFR 431.446 

(iv) Air-over electric motors; 

(v) Integral brake electric motors; and 

(vi) Any other electric motors exempted by the Secretary. 

§ 431.31 Labeling Requirements. 

(a) Electric motor nameplate-- 

(1) Required information. The permanent nameplate of an electric motor for which standards are prescribed in § 

431.25 must be marked clearly with the following information: 

(i) The motor's nominal full load efficiency (as of the date of manufacture), derived from the motor's average full 

load efficiency as determined pursuant to this subpart; and 

(ii) A Compliance Certification number (“CC number”) supplied by DOE to the manufacturer or private labeler, 

pursuant to § 431.36(f), and applicable to that motor. Such CC number must be on the nameplate of a motor 

beginning 90 days after either: 

(A) The manufacturer or private labeler has received the number upon submitting a Compliance Certification 

covering that motor, or 

(B) The expiration of 21 days from DOE's receipt of a Compliance Certification covering that motor, if the 

manufacturer or private labeler has not been advised by DOE that the Compliance Certification fails to satisfy § 

431.36.; and

(iii) Each fire pump electric motor to which standards apply pursuant to § 431.25(h), manufactured (alone or 

as a component of another piece of equipment) on or after January 1, 2015, shall be marked “For Use with a 

Fire Pump Only.” 

(2) Display of required information. All orientation, spacing, type sizes, type faces, and line widths to display this 

required information shall be the same as or similar to the display of the other performance data on the motor's 

permanent nameplate. The nominal full-load efficiency shall be identified either by the term “Nominal Efficiency” 

or “Nom. Eff.” or by the terms specified in paragraph 12.58.2 of NEMA MG1–2009, (incorporated by reference, see 

§ 431.15) as for example “NEMA Nom. Eff.__.” The Compliance Certification number issued pursuant to § 431.36 

shall be in the form “CC__.” 

(3) Optional display. The permanent nameplate of an electric motor, a separate plate, or decalcomania, may be 

marked with the encircled lower case letters “ee”, for example, 
28

or with some comparable designation or logo, if the motor meets the applicable standard prescribed in § 431.25, as 

determined pursuant to this subpart, and is covered by a Compliance Certification that satisfies § 431.36. 

(b) Disclosure of efficiency information in marketing materials. 

(1) The same information that must appear on an electric motor's permanent nameplate pursuant to paragraph (a)(1) 

of this section, shall be prominently displayed: 

(i) On each page of a catalog that lists the motor; and 

(ii) In other materials used to market the motor. 

(2) The “ee” logo, or other similar logo or designations, may also be used in catalogs and other materials to the same 

extent they may be used on labels under paragraph (a)(3) of this section. 
29

APPENDIX B

General: All testing of electric motors for compliance and enforcement will be conducted in accordance

with the prescribed DOE test procedures with the electric motor in a horizontal position.  Motor

manufacturers testing for initial compliance will configure test motors such that lab testing conforms to

DOE test procedures. This may include and is not limited to changing bearings, removing seals, installing

shafts, etc.   

For enforcement testing, the lab and DOE will be responsible for any reconfiguration of an electric

motor which may be required such that all testing can be performed with the electric motor mounted in

a horizontal position and connected to a dynamometer in accordance with the approved DOE test

procedures.  If a motor manufacturer has a concern regarding the impact of this reconfiguration on

motor efficiency test results the manufacturer shall have the right to challenge. The manufacturer shall

bare all expenses associated with the challenge including any additional reconfiguration work or testing.  

The DOE contractor selecting motors for enforcement testing from the marketplace shall do all they can

to mitigate the need for reconfiguration. When reconfiguration is required the lab may utilize local

motor service centers that are equipped to return a motor to the lab configured to be mounted and

tested horizontally.  The lab or service center may request test fixtures or adaptors from the motor

manufacturer if necessary. The enforcement budget from DOE must consider and bear reasonable

reconfiguration costs.  

Specific Motor Configurations:

Shielded Bearings Test per standard with shielded bearing in place – no

reconfiguration required  

Sealed Bearings         Remove bearing seals and test per standard    

Thrust Bearings/Angular Contact Remove  thrust bearing replacing with a  suitable 6000

series ball bearings and test per standard    

Sleeve bearings Test per standard with sleeve bearing in place – no

reconfiguration required      

Contact Seals Remove contact seal and test per standard (current

EPCA)

Partial motors Reconfigure motor to include 6000 series bearing and

endplate necessary to connect test equipment and test

per standard

Close Coupled Motors     Connect to test equipment using a coupling adapter if  

    required and test per standard  

       
30

Immersible Remove contact seal and test in a horizontal position

per test standard  

Vertical Pump Motor (P‐base) Replace thrust bearing with 6000 series, add a shaft

extension to connect to test equipment if necessary and

test per standard in horizontal position.

Gear Motors Remove gear box and reconfigure motor to include

6000 series bearing and endplate necessary to connect

to test equipment and test per standard