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U.S. Department of Energy 

Commercial and Industrial Pumps Negotiated Rulemaking Working Group 

Meeting Summary—Seventh and Final Meeting 

Forrestal Building, Washington, D.C. 

June 17 - 19, 2014 

Members in Attendance (Day 1) 

Lucas Adin U.S. Department of Energy 

Tom Eckman Northwest Power and Conservation Council (ASRAC Member) 

Robert Barbour TACO, Inc. 

Charles Cappelino ITT Industrial Process 

Greg Case Pump Design, Development and Diagnostics (Hydraulic Institute) 

Gary Fernstrom California IOUs 

Mark Handzel Xylem Corporation 

Al Huber Patterson Pump 

Joanna Mauer Appliance Standards Awareness Project 

Doug Potts (via web) American Water 

Jay Savigny Flowserve Corporation, Industrial Pumps 

Louis Starr Northwest Energy Efficiency Alliance 

Greg Towsley Grundfos USA 

Meg Waltner Natural Resources Defense Council 

Doug Brookman Facilitator, Public Solutions, Inc. 

Absent Dan Delaney Regal Beloit (alternate for Howard Richardson) 

Steve Rosenstock Edison Electric Institute (Day 1 & 2) 

Additional Attendees 

Jeff Alascio, Ashley Armstrong, Rob Boteler, Daniel Cohen, Jeremiah Freeman, Jiangang Hu, 

Elizabeth Kohl, Christopher Lau, Emily Marchetti, (Brent McManis), Doug Rawald, Steve 

Thompson, Daniel Weintraub, Sarah Widder and Alison Williams 

Author’s note 

The transcript for the June 17-19 WG Meeting #7, the WG’s Final Meeting, was made available 

after the WG concluded its business on June 19th. The final meeting resulted in a unanimous 

agreement on recommended standards levels for in-scope pumps as well as other related 

recommendations. That agreement is detailed in the WG’s Term Sheet, which can be found in 

Appendix A of this Meeting Summary. Since the regulatory negotiation was successfully 

concluded prior to writing this summary, the following meeting summary will be somewhat 

abbreviated. 

 
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Day 1—Working Group Meeting #7, June 17, 2014 

Facilitator Doug Brookman called the Working Group (WG) meeting to order and welcomed all 

present at 9:05AM. The WG proceeded with introductions around the room. 

Al Huber, speaking on behalf of the manufacturers, made opening remarks. He noted that 

changes had been made to slide deck content, for example, on the quads of energy savings. The 

manufacturers’ caucus wanted to understand the changes. He also inquired about the latest 

version of the calculator, which had not been distributed. He indicated that the manufacturers’ 

technical resource persons needed the calculator. Sarah Widder confirmed that a new calculator 

had not been sent and said she would try to send it out that day. She also stated that the 

calculator is not the reason the numbers in slide deck had changed. Tom Eckman echoed Al’s 

statement, wanting to understand the changes. 

Alison Williams addressed the question of the changes to the data, saying the C values were 

slightly different than previously presented and energy savings estimates depend on the C values. 

She also gave a detailed description of how the two databases (DOE and HI) had been merged. 

That changed the population and overall distribution of pumps in the data set. Members 

questioned the methods and results (p. 18). Alison also described an error in the original 

calculation, which contributed to the differences. She concluded by saying the merged data sets 

resulted in very minimal changes—probably fewer than 2 percent of the characterized pumps 

changed. 

Alison began presenting the results, showing PER levels across all the equipment classes. And 

continuing, presenting the national impact analysis (NIA) and manufacturer impact analysis 

(MIA) results. A member asked if these C value results were final and Alison replied they were 

“mostly final.” Al Huber, speaking on behalf of the industry, asserted that his caucus needed to 

have certainty with the numbers, “the target has got to stop moving.” Alison described some 

potential very small “tweaks”, but concluded “all the pump categories for which we have 

impacts, we could consider final right now.” The analysis team noted that they were not 

calculating impacts for RS-V and VT-S 1,800 pumps (p.37). 

A member questioned the calculations on industry net present value (INPV). He noted changes 

that emerged in the webinar, where markups for motors were added, would overstate INPV. Dan 

Weintraub described the survey data that he had re-examined and stated that those data supported 

the results given (p. 42). A few manufacturers, relying on practical experience, confirmed the 

general thrust of Dan’s conclusion. 

Alison Williams continued, presenting updated LCC savings and payback period analyses for the 

two different scenarios that WG has considered. She noted that, in general, consumer impacts 

are positive across the board for both the no-cost recovery and full-cost recovery scenarios. 

The facilitator asked if the WG established or ‘fixed’ the figures presented, if that would also fix 

the NIA and MIA results. Alison replied yes, for the purposes of this negotiation, but what gets 

published in the NOPR “might not be exactly the same” because of additional requirements and 

review by OIRA and others. Al Huber confirmed his caucus’ desire to establish or fix the values 
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as much as possible. What followed was very detailed discussion on the difficulty of accurately 

calculating and establishing C values (p. 55). 

Next, Alison described how VT-S 1800 and RS-V pumps should be considered differently from 

the other pump classes because, as described earlier, there are no energy efficiency impacts 

associated with them (p. 60). The WG broke to caucus. 

The WG reconvened and Tom Eckman, representing the energy efficiency advocates, presented 

the results: “we can both say we’re (both caucuses) mostly in agreement.” Tom, presenting a 

joint proposal, went on to describe the ‘high points’ of the agreement and the issues yet to be 

resolved. 

 Agreement on TSL2 which is 25 percent, 25 PER, 25 precisely. Al Huber contributed 

that the caucuses meant 25, not 27 or 26. Alison clarified that now the C values are not 

fixed. The two spokespersons confirmed “they will be fixed at 25” and “whatever 

produces that result.” 

 A four-year lead time/effective date (which Al confirmed) from the publication date of 

the final rule 

 Clarified that these terms apply to all the equipment classes except RS-V pumps 

 The RS-V standard would be set at whatever MEI is “the crosswalk” with MEI 40. 

A member asked if two additional provisions could be added: 

 An early, voluntary certification provision, and 

 Voluntarily, manufacturers will submit additional part-load data at power levels 75, 100 

and 110 to be reported and included in a DOE data base 

In discussion, it was determined that some additional consultation was needed. The WG broke 

for lunch. Returning from lunch, the facilitator re-stated the joint proposal as listed above. 

Members also clarified the proposal included that RS-V pumps should be set at the equivalent to 

the MEI 40 in EU. After a short delay, the facilitator confirmed that a quorum was present and 

referred, again, to the proposal elements listed above. This proposal did not include the two 

additional provisions. The facilitator asked for a vote and, by a show of hands, all the 

members present voted unanimously to accept the joint proposal (14 yeas, one abstention 

while absent, one member absent). 

The discussion turned to certification and data collection issues. As an introduction, a member 

rearticulated the two additional provisions listed above. Ashley Armstrong indicated that early 

voluntary certification by manufacturers is possible, but DOE would need to complete some 

steps beforehand, such as completing the test procedure rulemaking. Regarding additional data, 

Ashley stated that DOE collects a lot of information on different products and it does not need to 

be limited to the standard. If the WG made a recommendation to collect certain data elements 

the Department could consider it as a part of a separate rulemaking. 

Doug Rawald continued with a description of what DOE requires for reports: an excel 

spreadsheet template which includes model number and other key descriptors/characteristics, 

such as efficiency and other features. A second part includes a manufacturer’s sworn statement 

that his product is compliant. He continued that whether there were fields in the spreadsheet to 
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input additional numbers is something that could be discussed in a future certification 

rulemaking. 

A member restated that if the WG came up with a term sheet that lists agreed template elements, 

DOE could incorporate them in some form of rulemaking. Ashley confirmed that would be 

possible. The discussion continued in considerable detail on certification, including potential 

sampling requirements, the importance of defining basic models (p. 109) and citing detailed 

examples and possible applications (p. 117). In this context, a manufacturer re-affirmed (and 

confirmed) his understanding that testing and certification would occur with full diameter 

impellers. 

The discussion turned to details on testing and the potential applications of a test procedure 

(p.125). Manufacturers expressed concerns about pumps, as actually tested, not being able to 

meet/beat the calculated (nominal imputed) values, in part because of lack of data for drives and 

controls. Ashley and Doug Rawald described ways that this could be addressed, starting with a 

well-designed test method (p. 135), describing several options and referring to DOE’s experience 

with other products (p. 145). A manufacturer reiterated that controls are a variable that make this 

difficult. As discussion continued, members and DOE explored many different options. 

A manufacturer began closing out the discussion by reiterating that the energy efficiency benefits 

of utilizing a drive (and controls) are so large that this should not be made too complex, “the 

number one thing that prevents people from adopting an extended product solution is the 

complexity of implementations (p.161).” A member asked about distributors and whether they 

would be subject to the regulation. Doug responded that DOE does not have an answer yet. 

Ashley concluded this segment by restating that the first step was to develop the test procedure 

and DOE would create a starting point for that discussion. Members inquired about HI’s 40.6 as 

a starting point. Ashley stated that DOE’s intention was “to utilize as much of the industry 

standard without changing it” as possible (p. 175). 

The meeting moved toward closure with questions about the term sheet. Lucas Adin confirmed 

that DOE would create a draft for the WG to review that would include all the WG’s agreements. 

Ashley’s final caveat was that any language the WG created would be reviewed and ‘tweaked’ to 

conform to regulatory text standards. Dan Cohen reiterated Lucas’ earlier comment, that a clear 

expression of the WG’s intent is what matters in the drafting. The facilitator confirmed the 

agenda for Day 2 and the meeting adjourned. 

Day 2—Pumps WG Meeting #7, June 18, 2014 

Attendance: All members present for Day 1 were present for Day 2 

The facilitator welcomed everyone and the WG commenced with introductions around the room. 

Lucas Adin made introductory remarks, saying that the DOE team was going to provide a draft 

of a term sheet for everyone to review. Moving to the agenda, he noted that both the test 

procedure and the metric were slated to be covered and DOE intended to reflect, as much as 

possible, the content provided by the WG in its review. 
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The facilitator mentioned that several members had expressed a desire to him to conclude the 

WG’s work in this June meeting if possible. A member asked if the issue of circulators could be 

addressed in a July meeting. Another member asked if a DOE representative could be available 

during the WG meeting to address the timeframe for circulators and pool pumps. 

Test Procedure 

(Note: the actual pumps test procedure will formulated by DOE in separate rulemaking, which 

will be the subject of a full comment and review by stakeholders) 

Sarah Widder provided an overview. The goal would be to describe how one would go about 

testing a pump, translating that tested data into inputs that would be fed into algorithms or 

equations that the WG had discussed previously. She verified that she was awaiting some 

feedback on the last version of the calculator. She detailed some of the anticipated revisions and 

said the most recent version of the calculator would be sent out soon (p. 18). 

Alison Williams provided an update on the C values being calculated at PER 25. The analysts 

need to iterate using the calculator. Dan Weintraub continued that there were some other 

features, like motor losses, that still need to be nailed down by the WG. But he reassured the 

members, “we are going to be very close with these C values.” Sarah added that the calculator is 

not a formal DOE-endorsed template or tool. 

Sarah continued, starting with a bare pump in a pump stand, we anticipate testing in accordance 

with HI 40.6., as follows: 

 Sweep through seven specified points (40, 60, 75, 90, 100, 110 and 120 percent) of BEP 

 Head torque speed and flow rate would be captured at each of these points 

 There is a specification for water and how pressure is measured 

 The actual tested BEP of the pump is determined by finding the maximum of a best fit 

curve of efficiency versus flow rate. A specific method for the regression is outlined. 

 Then determine one hundred percent of BEP flow rate, then use that to specify the 25, 50, 

75 and 110 percent of BEP flow rates that will be used in subsequent calculations. 

 At this point, the test procedure moves to manipulation of data, with no new data 

collection 

Sarah continued with a detailed review of the draft test procedure provisions, including the 

following major points (P. 31): 

 Use linear regression (she also described interpolation) to determine flow rates at very 

low flow and very high flow and use the result to calculate shaft input power 

 Use data to determine hydraulic output power 

 The hydraulic output power is used to match the minimally compliant pump to your test 

pump 

 You use a minimally compliant motor 

Sarah also described more testing options for bare pump, bare pump plus motor and bare pump 

plus motor and controls and a detailed discussion on the application of the test procedure ensued 

(P. 38). 
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A member asked if the DOE proposed rule would utilize this extensive level of detailed 

description. Sarah and Lucas both said yes. 

Sarah’s very detailed presentation continued with many questions and comments. Referring to 

the equation nomenclature, a member asked why the denominator was labeled PER max when it 

is referring to a minimally compliant pump. Sarah acknowledged that it was confusing, but it 

denotes a maximum value. In discussion, the denominator was relabeled PER standard. 

After the mid-morning break, Sarah continued with a detailed description of the calculation 

method that could be used to test a bare pump and motor, featuring two options (P.80). 

Speaking on behalf of manufacturers, Al Huber stated that his caucus did not have “any problem 

using the default loss curves (in the calculations) as long as they are the same ones used to 

calculate the minimum standard.” 

Sarah moved on to a detailed presentation on a configuration where a bare pump is sold with a 

motor and controls (P. 89). A member commented that a load loss curve was a necessity and that 

the values had to be very conservative. Continuing, he described the need to develop loss curves 

for motors used with controls. Sarah said that one reason a new version of the calculator had not 

been sent was that different drive efficiency curves were not incorporated in the latest version. 

Al Huber suggested that there be two separate calculators, one for constant load and one for 

variable load. As review of the options continued, members described their preference for a 

controlled motor loss curve and a controlled drive loss curve rather than some conservative static 

value. 

Sarah continued with a description of wire-to-water test methods (P. 116). She asked if other 

inputs/changes were needed to the HI 40.6 procedure. A member suggested that a power factor 

value would be useful in determining utility cost savings versus initial investment. Discussion 

continued on the practical applications. A member confirmed that DOE intended to include a 

separate motor table for submersible pumps in the new version of the calculator. 

Returning from lunch, the facilitator referenced a short document that he and Alison Williams 

had prepared, which was a summary of all the votes and results to date from the WG. He stated 

it would be sent out for the WG’s review. 

The facilitator then returned to a question raised by a member earlier, on scheduling of follow-on 

activity for circulator and dedicated pool pumps. Lucas replied that the DOE analytic team 

would not be available to support any additional work in a July meeting—they would be 

dedicated to completing the details on this rulemaking. The same member suggested that, even 

absent analytic support, it could be productive for the WG to meet to consider these issues. 

A manufacturer referred to a circulators committee that was underway through HI. Al Huber, 

referencing a conversation with Tom Eckman, suggested that the NGOs come up with a proposal 

on scope and levels and the HI committee would review it and get back to them. Al continued, 

that the committee had meetings scheduled in October and February, and that the industry could 

probably seek an agreement with the NGOs in March timeframe. In discussion, members 

described the potential parameters for the negotiation and agreed that meeting for three days in 
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July was not necessary. Another member asked whether the pumps test procedure effort 

underway could include circulators. A manufacturer stated that the circulator test would be wireto-water and it would be very similar to what is being proposed. 

A member raised the outstanding issue of pool pumps. In discussion, Lucas indicated that the 

word “pump” is in EPCA. Another member interpreted that, as a consequence, it is potentially a 

covered product. The WG agreed to insert specific language in the Term Sheet which would 

recommend to ASRAC that DOE undertake some ‘notice’ or other effort relative to pool pumps. 

Continuing, a member asked if the WG should vote on the metric or the test procedure. After 

discussion, the WG confirmed that it could make a recommendation to ASRAC for DOE to 

adopt HI’s 40.6. The WG decided to wait on an actual vote. 

Metric 

Sarah Widder returned to previously presented material on the metric (P. 174); “this is the 

general nomenclature that we had agreed to previously, that the pump energy rating for a 

controlled or variable load would describe the weighted average electrical input power to the 

pump including a motor or drive if present over a specified load profile. And the weights were 

to be 110% or the load points were to be 110%, 100% and 75% of the best efficiency point flow 

at nominal speed for uncontrolled pumps for the constant load profile; and then 25, 50, 75, 100% 

of BEP flow for the controlled or variable load P-E-R. And then the weights were to be equally 

weighted among those three or four points. And the then pump energy index would be actually 

the standard that is set.” 

A member asked if there would be two PEIs, one for constant load and one for variable load. 

Sarah said yes. She continued, “for the constant load case, which is the uncontrolled pump, we 

mentioned that the load points of 75, 100 and 110 percent in equal weighting. We discussed 

earlier that the motor performance would be that of the minimally compliant motor or the motor 

that is sold with that pump. And we discussed the nuances of that earlier....the equation (is) 

....with the weighted average input power on top and then the bottom here; there is that pump 

hydraulic output power that we discussed earlier, on the pump curve, which is used to describe 

the minimally compliant pump on the denominator, also equally weighted at the same load 

points. The same losses are applied in both cases.” 

Sarah continued, “for the variable load case we have four load points: 25, 50, 75, 100. Other 

than that, the equation looks very similar. And then the one thing that is worth noting is that this 

denominator is an uncontrolled case....That is why we get such a dramatic decrease in the PEI 

for a controlled pump....we discussed at length earlier today how we are going to account for 

drive efficiency with a minimum drive efficiency assumed and an efficiency curve of some sort.” 

And continuing, “This is how we determine the minimally compliant pump. We essentially 

determine the pump efficiency based on this equation that is the same equation used in the EU. 

....And then we have the efficiency of that minimally compliant pump plugged into the PER 

standard equally weighted and we would scale the hydraulic power by that pump efficiency and 

then also translate the pump efficiency that describes the pump -- this equation describes the 

pump efficiency at BEP, and then we scale that pump efficiency or translate that pump efficiency 
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to 110% and 75% of BEP flow by multiplying it by these .985 and .95 factors. And that is 

consistent with what is done in the EU as well to set the MEI. So that is the minimally compliant 

pump.” 

Labeling 

The discussion turned to labeling (P. 183). After some back and forth, Lucas said that, typically, 

DOE’s certification system would require that information on the nameplate would enable a 

consumer to look up an efficiency rating in the DOE data base. In discussion, members clarified 

that after a test procedure is established, if a manufacturer is going to show an energy rating on 

the label, at a minimum, it must be consistent with the test procedure protocol. A member 

commented that a permanent rating on the label was necessary for voluntary programs that 

reward energy efficient products. Members indicated that they wanted the WG’s labeling 

preferences included in the Term Sheet. Manufacturers expressed their concerns about lack of 

control over product once it is shipped. As a consequence, they wanted a label which reflected 

the equipment as shipped, nominal PEI cl or nominal PEI vl, if it is shipped with a control. 

Returning from the mid-afternoon break, Sarah presented information that reflected what she had 

heard earlier, and that might be recommendations from the WG to be inserted in the Term Sheet. 

The first potential recommendation was: 

The pump test procedures should be in accordance with HI 40.6 for determining bare 

pump performance. The facilitator called for a vote and the recommendation was 

approved, 13 yes votes, two abstentions and one absent. 

Next, the discussion returned to consideration of the metric. Sarah re-read the content that she 

had read previously, referencing the listed equation as well. (and listed in the Metric section 

above, beginning on the previous page). Summarized, the recommendation would read: the 

pump energy rating, the PER CL and VL, and pump energy index, PEI CL and VL as 

listed. The facilitator called for a vote and all members present voted unanimously to make 

this recommendation to ASRAC (14 yes, 1 abstention while absent, 1 absent) 

Labeling 

The manufacturers’ caucus proposed that the nameplate label include the nominal PEI cl or PEI 

vl. After a lengthy and detailed discussion, where members described the nuances of impeller 

trimming and its influence on performance, the proposal was modified to read (P. 274): 

Metric applicability: standard versus label. 

 Pumps are labeled based on the configuration in which they are sold. 

--Uncontrolled pumps are constant load pump energy rating PEI cl, 

--Controlled pumps are variable load pump energy rating PEI vl, 

 The following information should be required to be included on a pump nameplate 

After a brief caucus, the facilitator called for a vote. By a show of hands the WG voted to 

approve the recommendation (13 yes, 2 abstentions, one absent) 

Potential Data Elements to be Reported 

Two members had previously referenced the possibility of collecting and posting specific data 

elements that may be in addition to those required for certification. Sarah created two lists, one 

of potentially necessary data elements for compliance with certification, and another list of data 
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elements that might be beneficial in planning efficiency programs, but not required for 

certification. Lucas commented that the exact details would be worked out in DOE’s 

certification and compliance process, a separate rulemaking process. After a lengthy discussion, 

Sarah captured the following as potential recommendation and read it out loud for the WG’s 

consideration: “Certification for RS-V and VT-S pumps shall be based on testing with the 

following number of stages: RS-V - 3 stages, VT-S - 9 stages, unless a model is not available 

with that specific number of stages in the given scope, in which case the model will be tested and 

certified with the next higher number of stages.” The facilitator called for a vote and the WG 

accepted the recommendation (14 yes, 1 abstention, 1 absent). 

The discussion returned to certification and data (P. 316). After detailed discussion, the 

facilitator read the edited proposed recommendation on the screen: 

“Recommended data to be concluded in the certification report/database 

 manufacturer name; 

 model number (numbers); 

 equipment class PEI cl, PEI vl (as applicable); 

 BEP flow rate and head rated speed; 

 number of stages tested, 

 full impeller diameter; 

 whether the PEI cl or PEI vl is calculated or tested; 

 input power to the pump at each load point” 

The facilitator called for a vote and the WG accepted the recommendation (13 yes, 2 

abstentions, 1 absent) 

A member asked about the schedule and language around follow-on rulemakings for circulators 

and pool pumps. She noted the language in the draft term sheet did not reflect the most recent 

proposal. The facilitator suggested that simple language could be inserted to reflect the process 

that caucus leaders had outlined earlier in the day. The member continued that the original 

language included the desire for DOE to undertake a follow-on rulemaking and she suggested 

July 2015 as the target date for a NOPR. Members speculated about the target date and the 

availability of DOE resources. After considerable discussion, the members decided to defer the 

decision to Day 3. 

Day 3—Working Group Meeting #7, June 19, 2014 

All members present on Day 2 were present for Day 3, (Meg Waltner via phone). Steve 

Rosenstock was present for Day 3. Dan Delaney was absent 

Facilitator Doug Brookman welcomed the members and the group commenced with 

introductions around the room. The facilitator said that a detailed review and action on the Term 

Sheet was the principal agenda item 

A member raised the issue of sampling. Lucas Adin responded, reiterating that pumps would be 

handled in a separate compliance and certification rulemaking. He continued, there are 

exceptions, but the general requirement that DOE has is for each basic model of a covered 

product, the certified rating has to be based on tested sample of at least two units. There are 

certain statistics that are used to determine a representative rating, based on that sample. The 
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sampling plan is determining also what the appropriate statistical level is to assure that that 

product is compliant and that the rating is representative of the overall population when 

considering the likely variation between units and the rating you’ve measured (P. 10). 

He confirmed that the sampling plan is used to determine the rating for each basic model that is 

being testing. Continuing, he described enforcement “where we do any random sampling of the 

population of units that are out in production in the market...to the extent we're going to verify 

compliance of that particular basic model with the standard and verify that its certifying rating is 

valid, it would be based on the same sampling plan and testing method that was used to certify 

the basic model to begin with.” He continued, that for verification testing DOE typically 

purchases the products from retail; for enforcement testing there is a different process and DOE 

requires that certain sample products be supplied at the manufacturer’s expense. 

Lucas confirmed that a manufacturer is required to make a signed declaration as part of his 

certification report, certifying all the basic models. More detailed questions on testing emerged. 

Lucas restated that these details will be addressed in the rulemaking. Manufacturers stated their 

concern about the cost of testing and talked about the practical applications (P. 26). The 

manufacturers continued with detailed real-world application questions. A member asked if 

manufacturers would have access on an ongoing basis to DOE as the rulemaking proceeded. 

Lucas replied that DOE would try to gather the right information and that it had different tools to 

accomplish that. 

Final Review of the Term Sheet (WG Adopted Term Sheet is Appendix A) 

The facilitator previewed a review of the Term Sheet, noting the WG’s ground rule that all 

previous agreements are provisional until the WG establishes them as final agreements. He also 

noted that all the content in this draft Term Sheet was reviewed and agreed to previously during 

the course of the negotiation. The WG commenced with a section-by-section review, starting at 

the beginning. Alison Williams was making real time edits to the document. The review 

proceeded as follows: 

Background—no comments 

Definition of covered product—no comments; consensus confirmed 

Recommendation #2—no comments; consensus confirmed 

Recommendation #3—no comments; consensus confirmed 

In-Scope and Out-of-Scope Pumps—no substantive comments; consensus confirmed 

Recommendation #5 revised—The WG started with the addition of descriptors CP1, CP2 and 

CP3 after the word circulators. Continuing, Tom Eckman and Al Huber began by describing a 

proposal that had emerged the previous day. After discussion, the WG arrived at the following: 

“Recommendation #5A. Circulators (CP1, CP2, CP3) will be held for additional informal 

negotiation between manufacturers, efficiency advocates, and other interested parties. Advocates 

to make initial proposal and manufacturers to respond with a goal by October. Stakeholders aim 

to present joint proposal to DOE by March/April 2015. Stakeholders request DOE commitment 

for technical support from consultants to facilitate analysis and test procedure development. 

 ASRAC-approved negotiation to begin in March following joint proposal. 

 Goal for NOPR publication by end of September 2015.” 
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Also, after considerable detailed discussion, mostly on dates, and an additional caucus review, 

members arrived at the following language that reflected another general agreement that emerged 

the previous day: 

Recommendation #5B. DOE should initiate a separate rulemaking on dedicated-purpose pool 

pumps by the end of calendar year 2014. 

In a separate vote (after the mid-morning break), following the discussion creating the new language, the 

WG approved the new language in recommendations #5A and #5B (consensus—14 yeses, 2 absent) 

Recommendation #6—no comments; consensus confirmed 

Recommendation #7—limited revision: remove the brackets in the first clause of the draft; no 

additional comments; consensus confirmed 

Recommendation #8—the WG accepted new explanatory language in the header to read: “It has 

been the intent of the working group to limit the scope of this rulemaking to pumps designed for 

use in pumping clean water. The rulemaking will explicitly exclude the following types of 

pumps that might otherwise meet the definition of an in-scope pump type:” 

The WG also accepted footnotes indicating intent, which referenced the EU’s clean water 

definition; confirmed DOE’s intent to maintain these exclusions while it drafts the proper 

regulatory language; and, confirmed that gray water should not be excluded. 

 

A member asked to return to Recommendation #7 (under Scope Refinements), seeking 

additional clarification on the meaning of ‘full impeller diameter’. The WG deleted the first 

bullet, ‘full impeller diameter’ and added an explanatory sentence: “In addition, the pump 

certified rating for a given model will be based on testing at full impeller diameter.” 

The WG also created a footnote to address the concern, as follows: “Pump models that otherwise 

meet all the above characteristics will not be excluded on the basis of having a trimmed impeller. 

The certification rating for full diameter will also apply to other trims. Full impeller means the 

largest impeller diameter offered for sale for a given model.” 

Recommendation #7: Returning from the mid-morning break, the facilitator confirmed again 

that the WG was comfortable with the new language. No additional comment; consensus 

confirmed. 

Recommendation #8: the facilitator returned to the revised language (above) to confirm that 

WG had approved the edits. No additional comment; consensus confirmed 

Energy Conservation Standards 

Recommendation #9: After discussion on the words ‘exactly 25%’ and some other minor edits, 

the WG arrived at following revisions, as follows: 

“For ESCC, ESFM, IL, and VT-S pumps in both 1800 and 3600 rpm speeds, the energy 

conservation standards will be set at PEI 25 (with C-values iterated to cut off as near to 25% of 

the pumps [in the DOE analytical team’s merged database] as possible). For RS-V pumps, 

energy conservation standards will be set to harmonize with the European Union No 547/2012 
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MEI 40 level, [with the intent that no models known to pass the EU standard would fail the US 

standard.] The compliance date for all equipment classes will be 4 years from the publication of 

the Final Rule.” 

After more discussion, the facilitator asked the WG if everyone was still comfortable with this 

slightly revised language, as they were on Day 2. No additional substantive comment; one vote 

change from abstain to yes; consensus confirmed 

 

Test Procedure and Metric 

Recommendation #10: No substantive comment; one vote change from abstain to yes; 

consensus confirmed 

The WG returned, briefly, to discussion on Recommendation #9, confirming the meaning and 

uses of the terms PER and PEI and confirming the addition of the words “at full impeller 

diameter.” The facilitator asked if members had any reservations about this content and there 

were none. 

Recommendation #11: Members reviewed the equations and suggested minor edits. The 

facilitator confirmed that the draft was consistent with the earlier conversation and agreement 

and confirmed there were no concerns about the content. No substantive changes; consensus 

confirmed. 

Labeling Requirements 

Recommendation #12: No substantive changes; one vote change from abstain to yes; consensus 

confirmed. 

Certification Reporting Requirements 

Recommendation #13: No comment; one vote change from abstain to yes; consensus 

confirmed. 

Recommendation #14: After considerable discussion, members revised the language to read: 

“Certification for RS-V and VT-S pumps shall be based on testing with the following number of 

stages: 

 RS-V: 3 stages 

 VT-S: 9 stages 

 If a model is not available with that specific number of stages in the given scope, the 

model will be tested and certified with the next closest1

number of stages offered for sale 

by the manufacturer.” 

The revision included the following footnote: If only fewer than the required number of stages 

are available, rate with the highest number of stages offered for sale. If only more than the 

required number of stages are available, rate with the lowest number of stages offered for sale. 

With these substantive changes, the WG confirmed its agreement. One vote change from abstain 

to yes; consensus confirmed. 

The facilitator noted a final correction, to add Howard Richardson from Regal Beloit to the list 

of members in Appendix B. 

 

  
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Summarizing, the facilitator confirmed that was all the Term Sheet content that was to be 

reviewed by the WG. He confirmed that this edited version of the Term Sheet was intended to 

be sent to ASRAC. 

As a final action of the WG, the facilitator asked for a final vote from the members, seeking final 

approval on all the content in the Term Sheet. By a show of hands, all members present voted to 

approve the final version of the term sheet. (15 yeses, 1 absent). WG members closed out the 

negotiation with remarks expressing appreciation for fellow members and staff. The WG 

adjourned from its last meeting for the final time at 11:15AM on June 19, 2014 

 
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Appendix A 

Appliance Standards and Rulemaking Federal Advisory Committee 

Commercial and Industrial Pumps Working Group 

Term Sheet 

June 19, 2014 

Background 

On July 23, 2013, DOE issued a Notice of Intent to Establish the Commercial/Industrial Pumps 

Working Group To Negotiate a Notice of Proposed Rulemaking (NOPR) for Energy 

Conservation Standards for Commercial/Industrial Pumps. 78 FR 44036. This working group is 

established under the Appliance Standards and Rulemaking Federal Advisory Committee 

(ASRAC) in accordance with the Federal Advisory Committee Act (FACA) and the Negotiated 

Rulemaking Act (NRA). The purpose of the working group was to discuss and, if possible, reach 

consensus on a proposed rule for the energy efficiency of commercial/industrial pumps, as 

authorized by the Energy Policy and Conservation Act (EPCA) of 1975, as amended. The 

working group was to consist of representatives of parties having a defined stake in the outcome 

of the proposed standards, and will consult as appropriate with a range of experts on technical 

issues. 

DOE received 19 nominations for membership. Ultimately, the working group consisted of 16 

members, including one member from ASRAC and one DOE representative (see Appendix A). 

The working group met in-person during 7 sets of meetings held December 18-19, 2013 and 

January 30 – 31, March 4 – 5, March 26 – 27, April 29 – 30, May 28 – 29, and June 17– 19, 

2014. The working group successfully reached consensus on proposed energy conservation 

standards for a specific set of pumps. This document includes the working group’s 

recommendations to ASRAC on determining scope of this rulemaking as well as energy 

conservation standards. The group also chose to provide test procedure and metric-related 

recommendations to the committee. 

Definition of Covered Product 

Recommendation #1. The covered product, a ‘pump,’ will be defined as below subject to 

potential edits necessary to accomplish the same intent: 

 ‘Pump’ is a device that moves liquids (which may include entrained gases, free solids, 

and totally dissolved solids) by physical or mechanical action and includes a bare pump 

and, if included by the manufacturer, the mechanical equipment, driver, and controls. 

Vote results: Consensus2

 (15 yes -1 no) on 3/4/2014 

Recommendation #2. The components of a ‘pump’ will be defined as below: 

 ‘Bare pump’ is a ‘pump’ excluding mechanical equipment, driver, and controls. 

 

2 There are 16 members of the working group. Consensus has been defined as no more than 2 no votes.
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 ‘Mechanical equipment’ is any component that transfers energy from the driver to the 

bare pump. 

 ‘Driver’ is the machine providing mechanical input to drive the bare pump directly or 

through the mechanical equipment, and may include an electric motor, internal 

combustion engine, or gas/steam turbine. 

 ‘Controls’ means any device that can be used to control the driver. 

Vote results: Consensus (15 yes - 1 absent) on 3/4/2014 

Recommendation #3. In this rulemaking, the metric will not cover non-electric drivers. The test 

procedure will specify that the bare pump rating calculations for the energy conservation 

standard also apply to pumps with non-electric drivers. 

Vote results: Unanimous on 3/26/14 

In-Scope and Out-of-Scope Pumps 

Recommendation #4. The scope of this rulemaking will include the following pump types:3 

 End suction frame mounted/own bearings (ESFM/OH0, OH1) 

 End suction close coupled (ESCC/OH7) 

 Inline (IL/OH3, OH4, OH5) 

 Radial split (multistage) vertical (RS-V/VS8) 

 Vertical turbine submersible (VT-S/VS0) 

Vote results: Consensus (15 yes - 1 abstain) on 3/26/14 

Recommendation #5A. Circulators (CP1, CP2, CP3) will be held for additional informal 

negotiation between manufacturers, efficiency advocates, and other interested parties. Advocates 

to make initial proposal and manufacturers to respond with a goal by October. Stakeholders aim 

to present joint proposal to DOE by March/April 2015. Stakeholders request DOE commitment 

for technical support from consultants to facilitate analysis and test procedure development. 

 ASRAC-approved negotiation to begin in March following joint proposal. 

 Goal for NOPR publication by end of September 2015. 

Vote results: Consensus (15 yes – 1 absent) on 6/19/14 

Recommendation #5B. DOE should initiate a separate rulemaking on dedicated-purpose pool 

pumps by the end of calendar year 2014. 

Vote results: Consensus (15 yes – 1 absent) on 6/19/14

Recommendation #6. This rulemaking will explicitly exclude the following types of pumps: 

 Positive displacement pumps 

 Axial/mixed flow pumps 

 

3 Items in parentheses represent DOE and ANSI/HI nomenclature.
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Vote results: Unanimous on 1/31/14 

 Double suction (DS) pumps 

 Multistage axially split (AS) pumps 

 Multistage radial split-horizontal (RS-H) pumps 

 Multistage radial split vertical immersible pumps 

 Vertical turbine (non-submersible) (VT) pumps 

Vote results: Consensus (15 yes - 1 abstain) on 3/26/14 

Scope Refinements

Recommendation #7. For the in-scope pump types, this rulemaking will be limited to pumps 

with the following characteristics: 

 1-200 Horsepower (shaft power at BEP at full impeller diameter) 

o applies to number of stages required for testing to the standard 

 25 gallons/minute and greater (at BEP at full impeller diameter) 

 459 feet of head maximum (at BEP at full impeller diameter) 

 Design temperature range from -10 to 120 degrees C 

 Pumps designed for nominal 3600 or 1800 rpm driver speeds 

 6 inch or smaller bowl diameter (VT-S/HI VS0) 

In addition, the pump certified rating for a given model will be based on testing at full impeller 

diameter.4

Vote results: Consensus (15 yes - 1 absent) on 3/4/14 

Recommendation #8. It has been the intent of the working group to limit the scope of this 

rulemaking to pumps designed for use in pumping clean water5

. The rulemaking will explicitly 

exclude the following types of pumps that might otherwise meet the definition of an in-scope 

pump type:6

 Wastewater, sump, slurry, solids handling7

 

 API 610 pumps 

 ASME/ISO chemical pumps 

 Fire pumps 

o if compliant with NFPA 20 and UL listed or FM approved 

 

4 Pump models that otherwise meet all the above characteristics will not be excluded on the basis of having a

trimmed impeller. The certification rating for full diameter will also apply to other trims. Full impeller means the

largest impeller diameter offered for sale for a given model.   5 Intent is to use the definition of ‘clean water’ in the EU pump standards. (Commission Regulation (EU) No

547/2012; Article 2 (13)) 6 Definitions designed to maintain the intent of these exclusions will be proposed in the NOPR by DOE. Information

in sub‐bullets may be used to inform these definitions. 7 Gray water should not be treated as part of this exclusion category.
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 Self-priming pumps 

 Prime-assisted pumps 

Vote results: Unanimous on 1/31/14 

 Nuclear pumps 

o Complies with ASME Boiler and Pressure Vessel Code Section III or 10 CFR 50; 

Non Code or Code/Safety Related. 

 Navy pumps 

o MIL Specification Compliant (MIL-P-17639, MIL-P-17881, MIL-P-17840, MILP-18682, MIL-P-18472) 

Vote results: Consensus (14 yes - 2 absent) on 3/4/14 

 Sanitary pumps 

o “Hygienic” or “sanitary” pumps are typically used in food processing and 

pharmaceutical applications. They are designed with special parameters, specific 

materials and surface finish to a variety of national and international rules and 

regulations that will minimize the biological growth inside the pump to protect 

public health. These design parameters and materials may result in lower 

efficiencies than for standard water pumps. Certifications for hygienic or sanitary 

products include, but are not limited to: 

 3-A Sanitary Standards 

 EHEDG (European Hygienic Equipment Design Group) recommendations 

 QHD (Qualified Hygienic Design) 

Vote results: Unanimous on 3/26/14 

Energy Conservation Standards 

Recommendation #9. For ESCC, ESFM, IL, and VT-S pumps in both 1800 and 3600 rpm 

speeds, the energy conservation standards will be set at PEI 25 (with C-values iterated to cut off 

as near to 25% of the pumps [in the DOE analytical team’s merged database] as possible). For 

RS-V pumps, energy conservation standards will be set to harmonize with the European Union 

No 547/2012 MEI 40 level, [with the intent that no models known to pass the EU standard would 

fail the US standard.] The compliance date for all equipment classes will be 4 years from the 

publication of the Final Rule. 

Vote results: Consensus (15 yes – 1 absent) on 6/17/14 

Test Procedure and Metric 

Recommendation #10. Pump test procedure should be in accordance with HI 40.6 for 

determining bare pump performance.
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Vote results: Consensus (13 yes – 2 abstain – 1 absent) on 6/18/14 

Recommendation #11. [The metric for assessing compliance with the standard should be PEI, 

which is constructed based on values of PER.] 

Pump Energy Index (PEI) CL and VL: PERCL and PERVL, for a given pump model (at full 

impeller diameter), over the PERCL for a minimally compliant pump (PERSTD) serving the same 

hydraulic load:

௅஼ܴܧܲ ൤ ൌ஼௅ ܫܧܲ

஽்ௌܴܧܲ

൨

௅௏ܴܧܲ ൤ ൌ௏௅ ܫܧܲ

஽்ௌܴܧܲ

൨

Pump Energy Rating (PER) CL and VL: equally weighted average electric input power to the 

‘pump’ measured (or calculated) at the driver input or, when present, controls input, over a 

specified load profile:

ܲܧܴ ௅஼ൌ෍߱௜൫ܲ௜௡

௜൯

௜

ܲܧܴ ௅௏ൌ෍߱௜൫ܲ௜௡

௜൯

௜

Where: 

 wi = weight at each load point i 

 Pin

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

 i = Percentage of flow at the best efficiency point (BEP) of the pump 

 i = 110%, 100%, 75% of Best Efficiency Point (BEP) flow at nominal speed for 

uncontrolled pumps 

 i = 25%, 50%, 75%, and 100% of BEP flow at nominal speed for pumps sold with motors 

and controls 

Vote results: Consensus (14 yes – 1 abstain – 1 absent) on 6/18/14 
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Labeling Requirements 

Recommendation #12. Pumps are labeled based on the configuration in which they are sold. The 

following information would be required to be included on a pump nameplate: 

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

PEICL

Model number 

Impeller diameter for each unit 

PEICL

Model number 

Impeller diameter for each unit 

PEIVL

Model number 

Impeller diameter for each unit 

Vote results: Consensus (14 yes – 1 abstain – 1 absent) on 6/18/14 

Certification Reporting Requirements 

Recommendation #13. Recommended data to be included in certification reports/database: 

 Manufacturer name 

 Model number(s) 

 Equipment class 

 PEICL or PEIVL as applicable 

 BEP flow rate and head 

 Rated speed 

 Number of stages tested 

 Full impeller diameter (in.) 

 Whether the PEICL or PEIVL is calculated or tested 

 Input power to the pump at each load point i (Pin

i) 

Vote results: Consensus (14 yes – 1 abstain – 1 absent) on 6/18/14 

Recommendation #14. Certification for RS-V and VT-S pumps shall be based on testing with 

the following number of stages: 

 RS-V: 3 stages 

 VT-S: 9 stages 

 If a model is not available with that specific number of stages in the given scope, the 

model will be tested and certified with the next closest8

 number of stages offered for sale 

by the manufacturer. 

Vote results: Consensus (15yes– 1 absent) on 6/18/14 

This term sheet has been approved by the ASRAC pumps working group by consensus (15 yes – 1 

absent) on 6/19/14. 

 

8 If only fewer than the required number of stages are available, rate with the highest number of stages offered for

sale. If only more than the required number of stages are available, rate with the lowest number of stages offered

for sale.  
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Appendix B—Members 

U.S. Department of Energy—ASRAC 

Commercial and Industrial Pumps Negotiated Rulemaking Working Group 

Lucas Adin U.S. Department of Energy 

Tom Eckman Northwest Power and Conservation Council (ASRAC Member) 

Robert Barbour TACO, Inc. 

Charles Cappelino ITT Industrial Process 

Greg Case Pump Design, Development and Diagnostics 

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

Southern California Edison, and Southern California Gas Company 

Mark Handzel Xylem Corporation 

Albert Huber Patterson Pump Company 

Joanna Mauer Appliance Standards Awareness Project 

Doug Potts American Water 

Charles Powers Flowserve Corporation, Industrial Pumps 

Howard Richardson Regal Beloit 

Steve Rosenstock Edison Electric Institute 

Louis Starr Northwest Energy Efficiency Alliance 

Greg Towsley Grundfos USA 

Meg Waltner Natural Resources Defense Council