### Mr
. lucas Adin 

### CSA 

## Group

Assistant Secretary for Energy Efficiency and Renewable Energy U.S. Department of Energy Forrestal Building 1000 Independence Ave SW Washington, DC 20585-0121. November 1 , 2013

Sublect: Petition for Recognition as a Notionally Recognized Certification Program for small electric 

### motors . Dear Mr
. Adio, Please accept this letter and accompanying supporting material as CSA Group's petition for recognition of our small motor energy efficiency verification program to be classified as a nationally recognized certification program in the United States, in accordance with 10 CFR Part 431. Enclosed please find three (3) binders, each containing the required information for the Department of Energy (DOE) recognition of nationally recognized certification programs described in Sections 431.447 and 431.448 of 10 CFR Part 431, dated May 4,2012
. Among the topics, this documentation package includes: 

### 1. A guide describing ou r small motor energy efficiency verification service program; 2. A general description of our quality management system covering the essential elements of our standards and procedu res for operating a certification system; 3. CSA Group By-laws and assurance of our independence and influence from manufacturers, suppliers and vendors; and 4. Samples of CSA Group accreditations. CSA Group has been offering a motor Energy Efficiency Verification service program since 1992 in support of Ca nadian Federal and Provincial Regulations and since 2002 fo r evaluation of electric motor efficiencies to US DOE requirements
. Key elements of our program for confirming continued compliance of a motor w ith a standard are (II a deta iled construction report for a motor on its initia l submission; (2) follow-up inspections to confirm consistency of construction and markings; (3) annual re-testing; and (4) cha llenge testing service. CSA Group is confident that our organization and staff have proven experience in operation a certification program in this area, and our certification system procedures fully meet the evaluation criteria for us to be classified by DOE as a nationally recog nized certification program. We, therefore, believe that this petition is in order and that it can be processed without delay. Please let me know ifyou require any further information. Thank you very much for your consideration,

Rick Morrison P.E ng., Technical Manager, Energy Efficiency Verification, (SA Group. CSA Group, 178 Rexdale Boulevard Toronto, ON, M9W 1R3, Canada T: 416 747 4090 Page 1 of9

## Petition for Recognition Energy Efficiency Evaluation of Electric Motors to United States Department of Energy Requirements Documented in 

### 10 CFR 

### 431

- Subpart B and Subpart X Table of Contents Section 

### 1. Scope and Application Section 2. Overview of CSA Group -letters of Patent

-Statement of Independence

-CSA By-laws -An nual Report

-Corporate Organization Chart Section 3
. Certification and Testing - Quality Management System Section 4. CSA Group's Motor Energy Efficiency Verification Program

- Prod uct Directory Section 5- Examples of Other CSA Group Accreditations

Section 1- Scope and Application Since 2002, CSA Group's electric motor (1 hp - 500 hpj energy effiCiency verification program has been DOE listed as a nationally recognized certification program. CSA Group is seeking scope expansion to be classified as a nationally recognized certification program in the United States under EPCA with respect to verifying Small Elect ric Motor (1/4 hp - 3 hpj efficiencies when applying the following test procedures and standards: (a) Test method B of ANSI/IEEE 112-2004, Test Procedure for Polyphase Induction Motors and Generators; (b) Test method of CSA C390-10, Test method, marking requirements and energy efficiency levels for three-phase induction motors; (c) Test method of CSA C747-09. Energy effiCiency test methods for small motors
. (d) Test method of IEEE 114-2001, Test procedure for single-phase induction motors. (e) NEMA MG1- 2009, Motors and Generators

Page 2 of9Facilities CSA Group Certification Facilities CSA Group has facilities in Canada, in the United States, in Europe and in the Far East. For your reference they are as follows: Area Address Montreal 865 EIIingham Street, Pointe Claire, PQ H9R 5E8 Toronto 178 Rexdale Boulevard, Toronto, Ontario M9W lR3 Edmonton**1707~94** Street NW, Edmonton, AS T6N lE6 Vancouver 13799 Commerce Parkway, Richmond, BC V6V 2N9 Cleveland 8501 East Pleasant Valley Road, Cleveland, OH 44131 -5575 Irvine 2805 Barranca Parkway, Irvine, CA**2606~5114** Frankfurt Weismullerstrasse 45, 60314 Frankfurt am Main, Germany Shanghai 1st Floor, Building 4, Q1Iai Indu strial City, 889 Yishan Road, Shanghai, 200233 Ch ina Designated Testing F acil ities As part of CSA Group's motor energy efficiency verification program we are using our Toronto test facility and the Loboratoire des Technologies de I'fnergie of**Hydro~Quebec,** ( LTE) for such purposes as product qualification testing, re-test ing, and challenge tes t ing. The facilities of Toronto are used for testing t he fu ll range of motors from 0.25 up to SO horsepower and the LTE facilities are used for motors ranging 50 to 500 horsepower. Summary ofSection 

### 1 Supporting Documentation Section 1 of the CSA petition contained no supporting documents.
Section 2 - Overview of CSA Group Name andAddress CSA Group 178 Rexdale Blvd, Toronto, Ontario, M9W lR3 (Headquarters) Background CSA Group is an independent organization providing services in the fields of Standards Development and Conformity Assessment. The Standards Division of CSA Group is responsible for the administration of the development of voluntary consensus based standards, while the Certification and Testing Division provides conformity assessment programs including laboratory testing certification and inspection . The Consumer Product Evaluation Division provides services for consumer product evaluation. Page 3 of9

### Canadian StandardsAssociation, operating as CSA Group, was established in 1919 as an independent, not-far-profit corporation under Part II of the 

### Canada Corporations Act
. CSA Group is a membership association whose purpose is to make standards work for people and business. CSA Group is the largest standards developer in Canada, certifies and tests various products to standards which may be destined for retail markets in Canada, the US and internationally, and tests consumer products to retaile r protocols
. CSA Group has staff which includes approximately 1100 employees in 14 offices across North America, as well as over 7,000 members who volunteer their time and knowledge to develop standards and programs that benefit business, industry and society. CSA Group has sales of approximately S250M, is involved in 52 technologies, and has over 2,000 standards and over 88,000 customers. Ownership CSA Group is an independent, not-far-profit organizat ion governed by a Board of Directors selected by the membership
. The Association has no affiliation with manufacturers or suppliers of the products submitted for certification. Attachment 1 provides information regarding: (a) CSA's lette rs of Patent; (b) Statement of Independence; and (e) By-laws. 

### Board ofDirectors and Principal Officers See CSA Group's Annual Report for the ind ividuals serving on our Board of Directors and Executive Management Team
. See Attachment 2. Major components ofthe Association are shown on the "Corporate Organization Chart." See Attachment 3. 

### Summary of Section 

### 2 Supporting Documentation Section 2, Attachment 1, contains copies of: the Canadian Engineering Standards Association Charter, dated January 21, 1919; the Canadian Standards Association Supplementary Letters Patent, dated April 26, 1944; Section 2, Attachment 2, a sworn Statement of Independence, dated October 16, 2013; Section 2, Attachment 3, is a copy of the CSA Group 2012 Annual Report
. Section 2, Attachment 4, is a copy ofthe CSA Group senior management organization chart.

Page 4 of9Section 3 - CSA Group Certification Services Quality Management System CSA Group's Certification Division maintains the quality assurance system for the Association's worldwide operations. The objective of this system is to ensure, (a) technical excellence; (b) consistency of interpretation, application of standards, programs and procedures; (c) integrity of our Mark; and (d) continuous improvement. The Quality Assurance system for the Division is based on national and international accreditation requirements and specific contractual customer requ irements. The accreditation req uirements are found in the applicable editions of the following standards. ISO/IE( Guide 65/ General Requirements for Bodies Operating Product Certification Systems SCC/CAN-P3 SCC/CAN-P-1500 Additional Requirements for Accreditation of Certification Bodies ISO/lEe 17025/ General Requirements for the Competence of Calibration and Testing laboratories SCC/CAN P-4 ANSI Z34.1 American National Standard for Certification-third party certification program CSA Group has implemented the requirements specified in ISO/IEC Guide 65, General requirements for bodies operating product certification systems. CSA Group facilities are accredited by accreditation bodies such as Standard Council of Canada and ANSI to these req uireme nts
. Divisional Quality Documents (DQDs) are operating procedures and gUidelines used by staff in support of the quality assurance system. 

### Summary ofCSA Group Section 

### 3 Supporting Documentation Section 3 of the CSA petition contained no supporting documents.
Section 4**~** CSA Group's M otor Energy Efficiency Verification Program Overview of the CSA Verification Program: Application Evaluation and Testing Certification Service Agreement Accompanying Services Follow-up Inspections Product Re-testing Challenge Testing Corrective Action Sampling Process Expertise in Motor Test Procedures Page 5 of9As Canada's premier Standards Development Organization, (SA Group publishes consensus standards to improve products and enhance trade**~** all the time ensuring the needs of our various Stakeholders are met. By establishing consensus among the different interest groups, with a balanced committee process, (SA Group creates effective standards that are frequently referen ced in Canadian Energy Efficiency Regulations. In ad<lition, US DOE electric motor and small electric motor Regulations reference (SA Standards such as C39G-10 and C747-09. CSA Standard (390-10, Test method, marking req uireme nts and, energy efficiency leve ls fo r threephase induction methods, is widely used in Canada as an integral part of Federal and Provincial Regulations. Electrical utility programs also make use ofthis standard to promote the use of higher levels of energy performance on a voluntary basis
. Our intimate knowledge of the standard coupled with CSA Group's recognition as an accredited Certification Organization in Canada for motor efficiency and electrical safety supports the needs of manufacturers, consumers and regulators. We provide the necessary independent assurance that motors covered by government regulations meet and continue to comply with the established energy efficiency requirements. 

### Verification Program The acceptance of motors under the CSA Group's energy efficiency verification program depends upon the satisfactory evaluation and testing to determine that the requirements of t he applicable standard (CSA Standard C390-10, C747-09) are met on a continu ing basis
. The following is a description of the major elements of our program used for qualifying manufacturers' motors or group of motors. 

### Application The customer makes an application requesting energy efficiency verification for his motor and submits all required documentation such as a list of all motors being submitted by model designation, type, and applicable performance ratings. The application is given a specific file to track and record all activities to the project. A qualified person (e.g., professional engineer) is then assigned responsibility for handling the project. 

### Evaluation and Testing (SA Group with the manufacturer's assistance prepares a 

### motor control list, identifying the critical features and the controls fo r these features for maintaining consistent performance with respect to energy efficiency. Representative motor samples are tested by an acceptable facility such as CSA Group or LTEto verify manufacturers rated efficiency values
. Attachment 1 provides a description of the procedures used for the in itial motor qualification testing and the follow-up re-testing service to ensure continued compliance. A find ings letter is then issued giving the results of our evaluation and actions needed, if applicable, to meet the standard. Modified samples may be required for further examination and testing.

Page 6 of9Certification 

### After the resolution of all the action items and all the conditions ofthe s tandard are met, the applicant is formally authorized to apply the CSA Group Energy Efficiency Verification Mark. A report is prepared describing the product and giving the related test results. A directory listing all products verified for energy efficiency is pu blished and available to the general public. See Attachment 2. Service Agreement 

### The applicant authorized to represent its motor as verified with our Energy Efficie ncy Marking must enter a signed agreement with CSA Group. This agreement addresses the conditions for maintaining certification such as access to facilities and records, follow-up inspection, product re-testing and challenge testing. Manufacturers are also requi red to notify CSA Group when changes are made to the motor, which may affect their performance rating
. These te rms and conditions are designed to protect the integrity of our Energy Efficiency Marking. Accompanying Services 

### After the motor has been initially evaluated and found to comply with the standard, our program includes additional services to ensure that motors bearing the CSA Group verification marking continue to meet the applicable requirements. These services are: (a) Follow-up inspections; (b) Product re-testing; and (c) Challenge testing. Follow-up Inspections 

### Follow-up inspections are conducted at the point of manufacturing each year to ensure that, (a) our mark is only applied to motors that have been verified fo r energy efficie ncy; (b) the manufacture rs' product control measures are continuing to produce marked products t hat are in compliance with our report and the standard; (c) samples required for re-testi ng are selected and sealed by CSA Group staff during these visits. Product Re-testing 

### Although a report is generated for motors detailing the critical construction featu res needed for maintaining consistent performance with respect to energy efficiency, our program is supplemented with unannounced motor re-testing to the specified requirement. This facilitates continued compliance with the standard and maintains the integrity of our mark. Challenge Testing 

### Another service-challenge testing- is offered to any manufacturer or other party wishing to confirm the motor efficiency rating of a verified motor. This feature assists in ensuring the integrity ofour verification prog ram and can lead to the motor efficiency de-rating or a delisting of a s eries of motors re presented by the sample motor.

Page 7 of9Corrective Action 

### When a motor fails to comply with the stan dards, we take the following steps: 

### (a) remove the verification mark from the affected motor or motors; (b) delist the motor{s); (c) notify the applicable regulatory authorities and government departments of noncompliant motors (i
.e., 

### serial number, date code, or equivalent); (d) re-test and verify the motor efficiency rating after the manufacturer modifies the product. Sampling Process 

### The objective of our sampling process is to minimize manufacturers' tests, costs and time to market, while providing sufficient confidence that the series of motors verified meet the applicable energy efficiency standard. The added features of our program such as unannounced fotlow-up inspections, random motor re-testi ng and challenge testing are critical components for demonstrating continued compliance to the standard. As a consequence of our 

### CSA Group's continual surveillance, the following sampling process guideline has emerged. Samples Required for Motor Model Qualificat ion Testing Test 

### 5 units of each 

### 5 basic motor model type (total of 

### 25 motors). The effiCiency of the sample lot must equal or exceed the required nominal full load effiCiency rating
. The individual sample efficiencies must comply with the nominal efficiency tolerance required by the Standard. Manufacturer's information indicating efficiency ratings must be in agreement with 

### CSA Group's record s. Selection of Basic Model Types to represent a Series of Motors A minimu m of five (5) 

### basic model types are requ ired to be tested to verify the efficiency ratings of a series of motors. The basic model types are to be selected such that they represent the complete range of motors within the series. This may require that more than 

### 5 basic model types are selected. High volume production motors are to be represented in the basic model types selected. Samples Required for Scheduled Motor Re-testing 

### A goal for verifying continued compliance with the standard isto re-test high volume motors at least once every 

### 2 years. Other motors of different frame series are to be retested as needed to ensure continued compliance. The initial sample lot shall consist of one motor. If the result equals or exceeds the minimum result f rom the qualification tests, then no further samples are required. If the result is less than t he minimu m result from the qualifying tests, then select motor samples per the qualifying test procedure.

Page 

### 8 of9

### Expertise in Motor Test Procedures CSA Group has been active in the certification for safety ofelectric motors since before 1940 and has more than 450 certification listings active at this time. (SA Group has been offering the Energy Efficiency Verification Service for Electric Motors since 1992 with motor size from 1 to 500 hp. The motor efficiency is tested to Standards CSA C390-10, IEEE 112- 2004, [EEE 114 and CSA 747-09. (SA has obtained accreditation from DOE in 2002 for motor efficiency US Department of Energy as a nationally recognized certification program in 2002 (Federal Register /Vol 67, No 249/ Friday December 27, 2002/ Notices). 

### Summary ofCSA Group Section 4 

### Supporting Documentation Section 4, Attachment 1, contains a copy of an information letterto "All Manufacturers of AC Three Phase Induction Motors Rated 1 hp to 500 hp," which is entitled "Announcing CSA Standard C390-10 Test methods, marking requirements and energy efficiency levels for three-phase induction motors, 4th edition
. "

Section 5 - Examples of Other CSA Group Accreditations The certification system and technical capabil ities of the Association have enabled CSA Group to be accredited nationally and internationally for a wide product spectrum such as electrical safety, energy efficiency, plumbing and gas. See Attachment 1 for examples of accreditations CSA Group has received
. 

### Qualification of (SA 

### Group 

### to operate as a Certification System The US Department of Energy recognized the Energy Efficiency Verification Service of CSA Group as a Nationally Recognized certification Program in a Federal Register Notice dated 27 December 2002 

### (67 FR 79480). 

### Summary ofCSA Group Section 

### 5 Supporting Documentation Section S, Attachment 1, contains copies of t he following documents CSA Group has received in recognition of its certification system and tech nical capabilities: 

### 1. Certificate of Accreditation under the Certification Body Accreditation Program, from the Standard Council of Canada, June 27, 2013; 2
. Certificate of Accreditation in recognition of being an Accredited Testing organization, from the International Accreditation Service, November 1 , 2012. 3. Certificate of Recognition as a Nationallv Recognized Testing laboratory, from the Occupational S afety and Health Administration, effective through Oecember 31, 2014.

Page 9 of9