Mr. Otto Krepps

Manager, Accreditations CSA International 178 Rexdale Boulevard Toronto, Ontario Canada M9W 1R3 Dear Mr. Krepps: 

## Department 

## of Energy Washington, DC 20585

CSA International (CSAJ) has submitted to the Department of Energy (Department). on November 12. 1999. a petition to have its motor efficiency verification service program (Program) classified as a nationally recognized certification program for electric motor efficiency. The CSAI pen-ion was published in the Federal Register on April 26. 2000 (65 Fed. Reg. 24429). For a certification program to be classified by the Department as being nationally recognized the program must (1) have satisfactory procedures for conducting and administering a certification system. (2) be independent. (3) operaie in a highly competent manner. (4) have personnel expert in the content and application of IEEE Standard 112-1996 Test Method B and CSA Standard C390-93 Test Method (1). and (5) must have satisfactory criteria and procedures for selection and sampling of electric motors. Section 431.27(b) of Title 10 Code of Federal Regulations Part 431 (10 CFR Part 431). Guidance as to the documentary evidence a petitioning organization should provide to the Department. including evidence that establishes experience in the application of guidelines contained in ISO/IEC Guides 65, 27. 28, and 25. is found in section 431.27(c) of 10 CFR R-Part 431. We have examined the CSAJ Program and find that, in part, it is deficient to be classified as a `'nationally recognized program." The Department. however. would classify the CSAI Program as nationally recognized if CSAI submits satisfactory information as to the following: 1) Documents DQD 316. 384, 385 and others relevant to the motor efficiency evaluation procedure which have been processed and approved by the CSAI Engineering Quality Assurance group. 2) Documents of policy or procedure that would provide further assurance of CSAI's independence from manufacturers , importers , or private labelers. 3) Evidence that the CSAI Toronto test facility is at present operational, initial compliance testing is in fact witnessed by CSAI Staff , and procedures are in place for regular quality inspections.

Punted with soy ink on recycled paper4) Notification of CSAI's intent to assign additional expert staff to its motor efficiency

verification service, and evidence as to the nature and extent of its training of current staff involved with the motor efficiency evaluation service. 5) A plan and procedures to evaluate a manufacturer ' s alternative efficiency determination methods (AEDMs). 6) Substantiation that the CSAI motor sampling procedures are statistically valid, use random selection, and render confidence limits such that the true mean energy efficiency of a basic model meets or exceeds the motor's represented energy efficiency level. Further elaboration as to the Department's findings and requests for additional information can are found below. Background CSA International petitioned the Deputme.n:.. on November 12, 1999, to have its Program classified as nationally recognized. The Dep,urtment published in the Federal Register , 65 Fed. Reg. 24429 (April 26, 2000), public notice of the CSAI petition, and solicited comments, data and information as to whether to grant CSA International's petition. Also, the Department conducted its own fact-finding investigation to obtain independent information concerning the CSAI Program. In response to the Federal Register notice, the Department received comments from Sterling Electric, Inc. (Sterling), Siemens Energy & Automation. Inc. (Siemens), and GE Industrial Systems (GE), dated May 16, May 23. and May 24. 2000, respectively. Also, the findings of the Department's independent investigation are contained in the "Review of the CSAI Petition'' (Final Report), dated February 17, 2001. Comments and findings are enclosed. Findings by the Department The Department has reviewed the CSAI petition, comments from Sterling, Siemens, and GE, and the Final Report, and makes the following findings with respect to the criteria set forth under sections 431.27(b) and (c) summarized as points (1) - (5) above. 1) Standards and Procedures for Conducting and Administering a Certification System
Sections 431.27(b)(1) and (c)(1) of 10 CFR Part 431 set forth criteria and guidelines for the standards and procedures to be used in administering a certification system and granting a certificate of conformity. In Section 3, "Certification Division Quality Assurance Manual," of the CSA International petition, it is stated that "CSA International has implemented the requirements specified in ISO/IEC Guide 65, General requirements for bodies operating product certification systems." The Department understands that the CSA International Quality Assurance system is based on national and international accreditation requirements, and that CSA International carries out theISO/fEC Guide 65 requirements through its Quality Assurance system and divisional quality

documents (DQDs) numbers 050 , 200, 306, 306.1, 318, 320, 326, and 327, which provide the operating procedures and guidelines in support of the CSA International quality assurance system. The Department's investigation finds that the CSA International procedures for operating a certification system, provided as attachments to the petition, are very general in nature and could be satisfactorily applied to any certification program conducted by CSA International. The Department has concerns as to whether the specific standards and procedures by which the CSA International motor efficiency verification program operates under are adequate, properly documented, well established and maintained, understood and in fact carried out by staff. For example, DQD No. 316, "Witnessing of Tests by CSA Staff at Non-CSA Facilities," was not provided, nor was it mentioned, as an attachment to thc' petition, but in the Department's view represents a critical procedure by which CSA Intematio.-ia1 conducts most of its certification testing of electric motors.Under section 4.6.2 of ISO/IEC Guide 65, the certification body shall have procedures to reevaluate a product in the event of changes in the ownership or management of the supplier. Paragraph 4.3.d of DQD No. 316 asserts that CSA Internat.' onal shall re-qualify a motor manufacturer's test facility when company ownership changes. Whereas, the Department finds that CSA International did not re-qualify the Magnetek Inc. motor business after it was purchased by A.O. Smith Electrical Products Company, nor did it re-qualify The Lincoln Electric Company and the Leeson Electric Corporation after both were purchased by Regal-Beloit Corporation. Under section 4.8.2 of ISO/IEC Guide 65. the certification body shall establish procedures to control all documents and data that relate to its certification functions, and these documents shall be reviewed and approved by authorized personnel prior to being issued following initial development or subsequent amendment. Whereas, the Department finds that procedural documents used in the electric motor efficiency evaluation process, including witnessing of tests by CSA International staff at non-CSA International. facilities and the sampling procedure to be used, were not marked with identification numbers and information such as date of issue, sources or authorities by which the documents were issued and approved, revision number, or the particular page from a set of pages. The Department understands that although DQD No. 316 was originally published in 1991, the procedures and guidelines by which CSA International operates its motor efficiency verification service had not been processed by CSA International Engineering Quality Assurance as of January 12, 2001. Subsequently, the Department has learned that the foregoing CSA International motor efficiency evaluation procedure was replaced and identified as DQD No. 384, presumably tailored to the motor efficiency evaluation service, and includes sampling procedures. Also, the Department has learned that section 4, attachment I to the CSA International petition, has been replaced by a new version identified as DQD 385, "Application Process - CSA Energy Efficiency Verification Program for Three Phase Induction Motors." Moreover, the aforementioned discrepancies concerning document identification, authorization information, and witness testing recur both in DQD Nos. 384 and 385. Also, the Department understands that DQD No. 316, "Witnessing of Tests by CSA Staff at Non-CSA


### 3Facilities," has been replaced by a new version and retitled "Witness Testing." As before, this

new document lacks dates, issuance, and authorization information. It is no where mentioned in the CSAI petition. It appears that the aforementioned documents by which CSA International operates and administers its motor efficiency verification service might have been created after the fact and as a result of the Department's investigation. The Department is concerned that such documents were apparently not well established, nor did they exist, at the time CSA International petitioned the Department of Energy with assertions that it "has implemented the requirements specified in ISO/IEC Guide 65," and that its DQDs "are used by staff in support of the quality assurance system." It is not clear at this point which divisional quality document, or documents, are being used in the motor efficiency evaluation procedure. CSA International should submit to the Department the documents relevant to the motor efficiency evaluaticn procedure that have been processed and approved by the CSA International Engineering Quality Assurance group. 2) Independence Sections 431.27(c)(2) and (3) of 10 CFR Part 431 provide guidance as `o specific criteria for what constitutes "independent status" of a petitioning certification organization and qualifications to operate a certification system, respectively. The latter cites ISO/IEC Guide 65. Sections 4.2 (1-n) of ISO/IEC Guide 65 provide guidance for operating a certification system and set forth guidelines whereby a certification body shall have policies and procedures that distinguish between product certification and other activities, be free from commercial, financial. and other pressures, have formal rules and structures for the appointment and operation of any committees involved in the certification process. and those committees shall be free from pressures that might influence decisions, and where committee members represent a balance of interests and no one interest predominates. Under Section 2, "CSA International," of its petition, CSA International asserts that it is an independent organization, has no affiliation with manufacturers or suppliers of products submitted for certification, and provides copies of documents, such as a "Statement of Independence," to substantiate these claims. Also, the Department understands that the CSA International Standards Division administers development of voluntary consensus standards, while the Certification Division and Quality Management Institute provide conformity assessment programs that include laboratory testing certification and inspection. Notwithstanding the organizational separation between its Standards Division and Certification Division and Quality Management Institute, the Department believes that CSA International could have an ongoing relationship, direct or indirect, with a motor manufacturer, importer, private labeler, or other such entity through (a) the CSA International combined energy efficiency and product safety certification processes, (b) an outright member of CSA International under Article 2, "By-Laws of the Canadian Standards Association," such as under Article 2 section 2.3, "Certification Member," or manufacturers representative that serves on a CSA International technical or standards development committee, and (c) shared certification whereby a

4manufacturer could perform unwitnessed motor testing and submit an initial certification report

to CSA International for review

. Such relationships need more explanation as to why each would not compromise CSA International's independence, or bias information presented to CSA International

for thepurposes of section 345 of EPCA. See section 431.27(b)(2) of 10 CFR Part 431. Also, CSA International should submit to the Department any documents that set forth the policies or procedures that distinguish such relationships, or any relationship it believes might appear to create a conflict of interest for its motor efficiency verification service. 3) Operation of a Certification System in a Highly Competent Manner
Sections 431.27(b)(3), (c)(3), and (c)(4) of 10 CFR Part 431 set forth criteria and guidelines for operating a certification system in a highly competent manner and expertise in motor test procedures

. Section 431.27(c)(4) of 10 CFR Part 431 calls for documentary evidence that establishes , in part , experience in overseeing compliance with the guidelines conwined in ISO/IEC Guide 25. Under Section 1, "Designated Testing Facility," of the CSA International petit on, it is stated that "as part of CSA International's motor energy efficiency verification program we are using our Toronto test facility," and "the facilities of Toronto are used for testing the full range of motors up to 50 horsepower." Also, under Section 3, "Certification Division Quality Assurarr.ce Manual," of the CSA International petition, it is stated that "CSA International has implemented the requirements specified in ISO/IEC Guide 65, General requirements for bodies operating product certification systems." Also, under Section 3, CSA International asserts that its Quality Assurance system is based, in part, on ISO/IEC Guide 25. The Department understands that SCC/CAN P-3 and SCC/CAN P-4, also cited under Section 3 of the petition, are the Standards Council of Canada equivalents of ISO/IEC Guides 65 and 25, respectively. Findings in the enclosed February 17, 2001 CSAI Final Report indicate that the CSA International testing facility in Toronto was not fully operational at the time of the CSA International petition, November 12, 1999, and in fact might not have existed at that time. Also, it appears that the CSAI Program relies heavily on the manufacturer to provide most of the test data, including data for initial qualification based on sampling and testing that are not witnessed by CSA International staff, and to provide other materials that are required to demonstrate initial and continued compliance with energy efficiency requirements for electric motors. Section 431.27 of 10 CFR Part 431 • does not require a certification program to actually operate its own motor testing laboratory, nor is a laboratory operated or observed by a certification program required to be accredited. Nevertheless, there should be well documented procedures in place for rigorous oversight of testing performed at a motor manufacturer's facility to ensure that the sampling procedures are statistically valid, that is, of sufficient size and selected at random, and the measurement of a motor's efficiency is accurate and repeatable. It appears from the findings in the enclosed February 17, 2001 Final Report that there is insufficient evidence that the CSAI Program applies the guidelines contained in ISO/IEC Guide 25 to a manufacturer's laboratory that it qualifies to test an electric motor for efficiency. Nor is itclear what evidence of quality control exists for monitoring the validity of motor efficiency

testing by a manufacturer. Also, it appears that the CSAI Program lacks sufficient staff to perform all the annual follow-up inspections, bi-annual re-testing, cross-testing every three years. unannounced re-testing, and challenge testing it claims. Moreover, these should include procedures for regular quality reviews by management. Notwithstanding that CSA International previously submitted its Certification Division Quality Assurance Manual, DQD NO. 050, to the Department as an attachment to its petition, CSA International should submit to the Department evidence that: its Toronto motor testing facility is in fact fully operational at the present time; procedures to be used either by CSA International or a motor manufacturer for selecting a motor for testing are substantiated by a statistically valid sampling plan; procedures to ensure that, as a minimum, the initial determination that an electric motor is in compliance with section 431.42(a) of 10 CFR Part 431 is in fact witnessed by CSA International staff and procedures are in place for regular quality audits of all inspection, s and testing. 4) Expertise in IEEE 112 Test Method B and CSA C390- 93 Test Method (1). and Satisfactory Criteria and Procedures for Statistical Samplinc
Sections 431.27(b)(4) and (c )(4) of 10 CFR Part 431 set forth evaluation criteria and guidelines whereby personnel conducting a certification program should be expert and experienced in the content and application of the IEEE Standard 112-1996 Test Method B and CSA Standard C390- 93 Test Method ( 1), or similar procedures , have satisfactory sampling procedures, and provide documents that establish experience in applying the guidelines for confidence in testing laboratories contained in ISO/IEEE Guide 25. Such guidelines include quality audits and reviews, personnel, equipment , test methods

. sampling, and records.
Section 3 , " Certification Division Quality Assurance Manual," of the CSA International petition. states that its Quality Assurance system is based on national and international requirements that include ISO/IEC Guide 25

. Section 6 , " Personnel ," of ISO/IEC Guide 25 sets forth general requirements for the training, technical knowledge , and experience of testing laboratory personnel

. Whereas, it appears from the findings in the enclosed February 17, 2001 CSAI Final Report that the CSAI Program engineering staff lacks a sufficient number of persons having the necessary technical knowledge and experience respecting electric motor construction, performance , and efficiency testing, which are required under section 6 , " Personnel ", of ISO/IEC Guide 25. First, it appears to the Department that the technical qualifications of CSAI persons involved in the motor efficiency verification service are very limited with regard to electric motor construction, performance , and efficiency testing. Second, it appears that CSAI has only one person that actually participates in the qualification of a motor manufacturer ' s test facility, witnesses testing, and both directs and evaluates compliance testing , cross testing, and retesting. Notwithstanding section 5 of DQD 050 which addresses staff training , CSA International should notify the Department as to its intention to assign additional expert staff to its motor efficiency verification service , and submit evidence as to the nature and extent of training the current staff involved with the motor efficiency evaluation service regularly undergo to maintain proficiency in the evaluation of motor design, construction , and practice of efficiency testing.
6Under section 431.24(a)(1) of 10 CFR Part 431, the energy efficiency of a motor must be

determined either by testing or application of an AEDM. The Department believes that it would be prohibitively expensive and time consuming to test all the many basic models that a - manufacturer produces, and therefore section 431.24(a)(1) permits the use of an AEDM that is substantiated by testing at least 5 basic models and comparing the predicted total power loss with the tested total power loss. See sections 431.24(a)(3) and (4) of 10 CFR Part 431. Futhermore, initial substantiation of an AEDM must be stringent because it would underlie compliance determinations for many motors. It is not clear whether the CSAI Program will evaluate a motor's energy efficiency in the manner prescribed under sections 431.24(a)(3) and (4). Under section (5) in the Final Report. CSAI appears to make contrary statements concerning its intentions to substantiate a manufacturer's AEDMs either by analyzing and comparing a manufacturer's energy efficiency modeling methods to actual test measurements or through comparisons between a motor manufacturer's energy efficiency calculations on a software program and a CSAI software program. In one statement, CSAI describes how it examines a manufacturer's software modeling, and then tests at least 5 basic models to verify the results of its examination. Presumably, this CSAI process is conducted along the lines of sections 431.24(a)(3) and (4). In another statement, CS AI asserts that it does not intend to review or evaluate AEDMs. It appears to the Department that there could be reluctance on the part of CSA International to evaluate a manufacturer's AEDMs in the manner prescribed under sections 431.24(a)(3) and (4). Moreover, the Department is concerned that a certification program would be unduly burdensome if actual testing of all basic models is the sole means to determine compliance. CSA International should submit to the Department its plan and procedures to evaluate a manufacturer's AEDMs. The Department understands that the CSAI Program sampling process consists of selecting a minimum of 5 basic models that represent the range of motors within the series, and for each basic model only one unit would be tested. If the efficiency measurement of that one motor equals or exceeds the minimum result from the qualification test for that motor, then no further testing is required. CSA International should provide to the Department documents or other materials to substantiate that its motor sampling procedures are statistically valid and render confidence limits such that the true mean energy efficiency of a basic model (i.e., the average efficiency of all units manufactured) meets or exceeds the motor's represented energy efficiency level.
Conclusion The Department believes that the CSA International motor efficiency verification service could meet the evaluation criteria set forth in section 431.27 of 10 CFR Part 431. Thus, the Department would publish in the Federal Register an interim determination that the CSAI motor efficiency verification service is to be classified as "nationally recognized," provided that CSAI submits the necessary additional information.

7I request that you forward within 30 days responses that show CSA International fully

understands and complies with the objections put forward in this letter to: U.S. Department of Energy, Office of Building Research and Standards, EE-41, 1000 Independence Avenue, S. W., Washington, DC 20585-0121. In case you or the organization have of any questions concerning the above, please should contact Mr. James Raba, of my staff, at 202-586-9127. Thank you for your cooperation in this matter. Sincerely,

Edward O. Pollock, Jr., Director Office of Building Research and Stand Office of Building Technology, State and Community Programs Energy Efficiency and Renewable Energy
Enclosures

## EL E C T RI C , C.

May 16, 2000 16752 Armstrong Ave., Irvine , CA 92606 ( 8003 654-0220 Fax (949 ) 474-0543 7973 Allison Ave., Indianapolis , IN 46268 ( 800) 866-7973 Fax (317 ) 872-0907 799 Rennie St., Hamilton , Ontario L8H7L4 ( 905) 547

-2345 Fax ( 905) 547-2381



### Office of Energy Efficiency and Renewable Energy, EE-41 U. S. Department of Energy 1000 Independence Avenue S.W. Washington , D.C. 20585-0121
Attn: Ms. Brenda Edwards-Jones RE: Federal Register, Vol. 65, No. 81, 4-26-2000; Docket No. EE-RM-96-400; CSA International Petition to be Classified as a Nationally Recognized Certification Program for Electric Motor Efficiency; Solicitation of Comments
Dear Ms. Edwards-Jones: We believe CSA International to be eminently qualified in the fields of product testing and verification of energy efficiency. We urge the Department of Energy to move expediently to classify their motor efficiency verification service program as a nationally recognized certification program in the United States. CSA International has several years experience in the testing and certification of motor efficiency for various Canadian national and provincial requirements. The knowledge, systems and procedures , and administrative staff are in place. Their personnel are experts in the field of product testing and verification , specifically those relating to motor efficiency testing as required by EPCA. The Canadian and U. S. testing and certification requirements are similar , and CSA has organizational capability to handle the required work within the time frame allotted by the DOE.



## Where Quality Is In Control

### Ms. Brenda Edwards-Jones Office of Energy Efficiency and Renewable Energy Department of Energy May 16, 2000 Page 2

CSA International, with their worldwide presence, is unparalleled in the capability to perform this type of verification , certification and follow-up. We motor manufacturers and importers have a lot of work to do in a very short time and an additional certification body such as CSA is needed for this program. Respectfully,

Joseph E. Hunter Senior Vice President T eciu"cai o ci Jiies 

### JEH:jmb cc: Mr. Otto Krepps Manager, Accreditations CSA International 178 Rexdale Boulevard Toronto, Ontario, Canada M9 W I R322 May, 2000 Baldor Electric Company 5711 R.S. Horsham Jr. St. Fort Smith, AR 72908 (501) 546-4711 FAX (501) 548-5841 www.baldor.com Ms. Brenda Edwards Office of Energy Efficiency and Renewable Energy EE-41 U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585-0121 Re: CSA International Petition to be Classified as a Nationally Recognized Certification Program for Electric Motor Efficiency
Dear Ms. Edwards:

Baldor has held the CSA International Energy Efficiency Marking since 1 994. The process to obtain the marking involved CSA personnel , at Baldor, to inspect and observe motor efficiency testing . It also involved like Baldor motors being tested at the CSA laboratories . The results were the same. Thus, although we have not personally visited/ inspected the Toronto and LTEE facilities , we feel that they are good in that they duplicated the results from our laboratory of which we are quite proud. Recently CSA has reviewed Baldor relative to quality assurance procedures in the Baldor motor testing laboratory. This relates to the Department solicitation for comments in this arena. The procedures and processes set forth by CSA parallel those of NVLAP as we understand them. The "Sampling Process" of CSA relative to motor efficiency testing/ verification is that of the EPCA law from our perspective. Thus, we feel that the CSA organization is competent and professional. we enjoy a good working relationship with CSA and urge the expeditious acceptance of their petition. 

### Regards,

James R. Kimzey, Ph.D. Randal G. Walfrr:. Executive Vice President Research Vice Presidet,t En ineerin and Engineering and Motor -{:^ie^^teicans
dkw-t

'To be the best es determined by our customers'05/23 / 00 13 : 54 e501 8974844 SIEMENS LR

Date : 5/23/00
Ms. Brenda Edwards-Jones Office of Energy Efficiency and Renewable Energy, EE-41 US Department of Energy 1000 Independence Avenue, SW Washington, D.C. 20585-0121 Fax-4: 202-586-4617
Cc: Mr. Otto Krepps Manager, Accreditations CSA International 178 Rexdale Boulevard Toronto, Ontario , Canada M9W 1R3 Fax-4: 416- 747-4173

Siemens Energy & Automation is in favor of CSA being recognized as a certification program for electric motor efficiency. We look forward to certifying our Guadajalara, Mexico lab through CSA. Thanks,

Paul Young Siemens Energy & Automation Product Electrical Engineer 14000 Dineen Dr Little Rock, Arkansas 72206 Email#: paull .young(Z1 sea.siemens.com Tel: (501) 897-1334 Fax: (501 ) 897-1412



### Siemens Energy & Automation, Inc. Q001

Motors and Drives Division ® 14000 Dineen Drive o Little Rock, AR 72206 9 Tel: (501) 897-4905 e FAX: (501) 897-4050GE Industrial Systems

May 24, 2000

Ms. Brenda Edwards-Jones Office of Energy Efficiency and Renewable Energy, EE-41 U.S. Department of Energy 1000 Independence Avenue, SW Washington DC 20585-0121 Subject: CSA International Petition to be classified as a Nationally Recognized Certification Program for

Electric Motor Efficiency
Dear Ms. Edward-Jones: The following are comments on the petition of CSA International to be classified by the U S. Department of Energy as a nationally recognized certification program for electric motor efficiency . Comm ents are made in the order of review of the subjects in the Federal Register ,'Vol. 65, No. 81, and page 24430 with additional comments at the end.
1. Section 1: Based on experience with motor test labs and in a sense of fairness to participants, it is recommended the competency of test facilities used for the purposes of establishing energy efficiency be established and maintained by a process equivalent to the NIST NVLAP EEM accreditation documented in NIST

1.1 UUVVl, 1JV-iv. 2. Section 3- Similarly, while the content of SCC/CAN-P3 and the other documents identified in Section 3. - Certification Division Quality Assurance Manual are not known, there is reason to believe they should be acceptable if generally recognized to provide appropriate guidelines for certification programs. It would be appropriate to understand the level of confidence CSA feels appropriate for the efficiency data developed in the test programs along with the basis for the confidence level.
3. Section 4: The current interpretation of the requirements is motors are -I erentiated by horsepower, synchronous speed, and enclosure into what is termed a basic model. Each basic model with the scope of EPAct must, in turn, be qualified by empirical test or an alternate energy efficiency determination method (AEDM). The CSA approach described in this segment indicates a test of 5 basic models with a sample size of 1 to 5. One would expect the minimum data required under the current AEDM qualification protocol is 5 samples of 5 basic models. The 5 of 5 sampling, if random samples, allows a look at both the population and statistical variation in the base model. More samples would be required to determine if a significant number of basic models were to be qualified by test. Assuming there are ongoing process variables, statistical process control would suggest frequent sampling over time is more appropriate to assess and manage the influence of both design and manufacturing variables, so an ongoing sampling program would probably be appropriateMs. Brenda Edwards-Jones

May 24, 2000 Page 2

4. Other: Recommend considering any energy certification agency along with certified sources participate in the KIST NYLAP EEM proficiency testing to ensure the variation in motor test results due to slight variation in facilities are understood, documented, and publicized to benefit participating test labs. Yours truly,

cc: Mr. Otto Krepps , Manager, Accreditation

CSA International 178 Rexdale Boulevard Toronto , Ontario , Canada M9W 1R3
Mr. James Raba U.S. Department of Energy Office of Energy Efficiency and Renewable Energy, Mail Station EE-41 1000 Independence Avenue, SW Washington, DC 20585-0121.Utz, U( GUU1 1U•L )4 r 'r' (J1 'jb( J11D 1U 1^Ut tib4bl( Y'.U..3?UJ

Setting Standards for Excellence
May 26, 2000

r^ Mr. James Raba

Office of Energy Efficiency and Renewable US Department of Energy, EE-41 1000 Independence Ave., SW Washington, DC 20585-0121

Dear Jim: In response to the Federal Register Notice (65 FR 24429) regarding CSA's application "To be a Nationally Recognized Certification Program for Electric Motor Efficiency", NEMA has concern with the sampling process outlined-in the Notice.
CSA's Sampling Process requirements appear to be more burdensome than required by DOE. NEMA will elaborate further in a future correspondence. If you have any questions or need further assistance please do not hesitate to call me at 703-841-3245.

National Electrical Manufacturers Assodation ,,. 13QO North 17th Street, Suite 1847 ! bsslyn, VA 22209 (703) 841-3200 FAX (703) 841-sgoo

** TOTRL PRGE.03 **16752 ARMSTRONG AVENUE - IRVINE, CA 92606-4912 949.474.0520 - FAX 949.474.0543 - SALES 800.654.6220

www. sterlingelectric. com

April 3, 2001

CERTIFIED MAIL The Honorable Spencer Abraham Secretary of Energy U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585
Dear Mr. Abraham: For Sterling Electric, Inc ., I am requesting an extension of the November 5, 2001 date for compliance with the final rule relating to energy efficient electric motors. Sterling Electric, Inc. has been "waiting" for C.S.A. to be approved by the D.O.E. as an independent third -party certification body. As of this date , C.S.A. is not approved and only one U

. S. independent lab has been approved by the D.O.E..
In the Public Hearing (January, 1997 ), in the Final Rule (October , 1999) and in numerous conversations with the D. O.E.'s Mr. Raba, Sterling Electric , Inc. has been assured there would be multiple organizations that could do third

- party certification . THERE IS ONLY ONE!
'why the D.O.E. and C.C. i. l v'en ' t comple ted C. .. A .'3 rec ognition 13 a 

### mystei; to us! Ha. ring worked `J t C.S.A. for many decades, Sterling Electric , Inc. and many other motor manufacturers requested that C.S.A. be one of the recognized bodies for test certification from the beginning . The D.O.E. even cites the C.S.A. test method in the Rule.
We have been assured by D.O.E. that "there will not be a problem for the small manufacturer". After nearly 75 years in the electric motor manufacturing business, NOW WE HAVE A PROBLEM!
The motors we currently sell in commerce meet and exceed the EPACT efficiency levels. However, since C.S.A. is not recognized by the D.O.E., Sterling Electric, Inc. will be out of business because we will not have a CC number for our motors.
I am requesting an extension of 18 months from November 5, 2001 by the D.O.E. for Sterling Electric, Inc. to obtain the CC number for our line of motors. The serious consideration of this request and the necessary action [a temporary CC number or a "Grandfather Clause" exception] to allow us to stay in business will be appreciated. I would appreciate a timely response from the appropriate D.O.E. parties.

cc: Mr. Jim Raba, D.O.E.

SERVING AMERICA'S INDUSTRY SINCE 1927