Charles Llenza

BUILDING TECHNOLOGIES PROGRAM

February 20, 2013

Energy Conservation Standards for Commercial & Industrial 

Pumps: Framework Public Meeting 
2 

 Introductions 

 Role of the Facilitator

 Ground Rules (Norms)

• Listen as an ally

• Use short, succinct statements/keep to the point

• Hold sidebar conversations outside the room

• Focus on issues, not personalities

• One person speak at a time (raise hand to be recognized; state your name for 

the record)

• Set cell phones to silent/vibrate

 Housekeeping Items

 Agenda Review

 Opening Remarks

Welcome and Introduction
3 

9:00 – 9:05 am Welcome 

9:05 – 9:30 am Opening Remarks, Introductions, and Agenda Review

9:30 – 9:45 am Rulemaking and Analytical Methodology Overview

9:45 – 10:30 am Legislative History and Coverage

10:30 – 10:45 am Break

10:45 – 11:45 am Regulatory Regimes and Metrics

11:45 – 12:00 pm Test Procedure

12:00 – 1:00 pm Break for Lunch

Agenda: Morning 
4 

1:00 – 1:30 pm Market and Technology Assessment, Screening 

Analysis

1:30 – 2:15 pm Engineering Analysis, Manufacturer Impact 

Analysis

2:15 – 2:45 pm Markups and Energy Use Determination

2:45 – 3:00 pm Break

3:00 – 3:30 pm Life-Cycle Cost and Payback Period Analysis, 

Shipments Analysis, National Impact Analysis

3:30 – 3:45 pm NOPR Analyses

3:45 – 4:00 pm Other Issues and Comments

4:00 pm Closing Remarks

Agenda: Afternoon 
5 

Interested parties who contacted DOE to request an 

opportunity to issue an opening statement should speak 

now.

Opening Remarks
6 

5 

3 

2 

Test Procedure

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 Regulatory Regimes & Metrics

Public Meeting Agenda
7 

Purpose of the Framework Document Public Meeting

 Present the analytical approaches to be used to 

evaluate energy conservation standards for 

commercial and industrial pumps

 Inform interested parties of and facilitate the 

rulemaking process

 Provide a forum for public discussion of rulemaking 

issues

 Encourage interested parties to submit data, 

information, and written comments 

Introduction 
8 

Introduction 

Request for Comment 

Item #-#: DOE solicits comment on a range of specific 

issues throughout the Framework Document.

• Throughout this presentation, these issues will be highlighted for 

discussion in comment boxes such as this.

• Item numbers correspond to those in the Framework Document. 

• DOE welcomes comments concerning these specific issues and any 

other issues related to this rulemaking.
9 

Instructions for Submitting Comments

 In all correspondence, please refer to this Commercial and Industrial Pumps 

Rulemaking by:

• Docket # EERE-2011-BT-STD-0031, and/or RIN 1904-AC54 

 Electronic: Pumps2011STD0031@ee.doe.gov OR www.regulations.gov

 Postal Mail: Ms. Brenda Edwards

 U.S. Department of Energy

 Building Technologies Program, Mailstop EE-2J 

 1000 Independence Avenue, SW. 

 Washington, D.C. 20585-0121 

 Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., 6th Floor

 Phone: (202) 586-2945 

Introduction 

Comment period closes May 2, 2013
10

5 

3 

2 

Test Procedure

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 Regulatory Regimes & Metrics

Public Meeting Agenda
11

Standards Development

 The Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 94-

163) established an energy conservation program for certain commercial 

and industrial equipment. 

 This program, set forth in Part C of Title III of EPCA, includes pumps as 

covered equipment and authorizes DOE to issue standards, test 

procedures and labeling requirements for them. 42 U.S.C. 6311(1)(A) 

 DOE is directed to develop new or amended standards designed to 

achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified for which DOE’s 

rulemaking process provides the schedule and analyses to do so.

Rulemaking Process Overview
12

 EPCA directs DOE to consider seven factors for analysis when setting 

technologically feasible and economically justifiable standards:

Rulemaking Process Overview

EPCA Requirement Corresponding DOE Analyses

1. Economic impact on consumers and 

manufacturers

• Life-Cycle Cost Analysis

• Manufacturer Impact Analysis

2. Lifetime operating cost savings compared to 

increased equipment cost

• Life-Cycle Cost Analysis

3. Total projected energy savings • National Impact Analysis 

4. Impact on utility or performance

• Engineering Analysis

• Screening Analysis

5. Impact of any lessening of competition • Manufacturer Impact Analysis

6. Need for national energy conservation • National Impact Analysis

7. Other factors the Secretary considers relevant

• Emissions Analysis

• Utility Impact Analysis

• Employment Impact Analysis

Source: (42 U.S.C. § 6295(o)(2)(B)(i) and 42 U.S.C. § 6316(a))
13

Rulemaking Process Overview

• TP and ECS rulemakings are separate processes but have integrated timelines.

• The TP rulemaking timeline duration is about 1.5 years from cradle to grave.

• The ECS rulemaking timeline duration is about 3 years from cradle to grave. 

• For additional information on the rulemaking process go to:

http://www1.eere.energy.gov/buildings/appliance_standards/standards_dev_and_revision.html

Energy Conservation 

Standards (ECS)

Test Procedure (TP)

Framework

Document Preliminary 

Analysis NOPR Final

Rule

NOPR Final 

Rule

Test Procedure and Standard Rulemakings Timelines
14

Framework Document

 Provides an overview of the rulemaking process and encourages early 

participation from interested parties

 Invites comments on proposed approach and issues

 Accompanying Federal Register Notice of Public Meeting (NOPM) – 78 

FR 7304, February 1, 2013

• Gives notice of the public meeting and availability of the Framework 

Document being discussed today

• Encourages interested parties to submit comments

Rulemaking Process Overview

Framework 

Document 

Preliminary 

Analysis NOPR Final Rule

Today
15

Preliminary Analysis Document

 Planned Federal Register Notice and Public Meeting (NOPM) –Summer 2014:

• Gives notice of public meeting and availability of the Technical Support Document (TSD)

• Encourages interested parties to submit comments

 Analysis:

Rulemaking Process Overview

Framework 

Document 

Preliminary 

Analysis NOPR Final Rule

• Design options to increase efficiency 

(engineering analysis)

• Manufacturer-to-user markups

• Energy use

• Consumer life-cycle cost (LCC) and payback 

period (PBP) 

• Shipments 

• National impacts (including national energy 

savings (NES) and consumer net present value 

(NPV)

• Preliminary analysis of manufacturer impacts

• Discussion of comments received in response to 

the framework document
16

NOPR Document

 Discussion of comments received in response to Preliminary Analysis TSD

 Analysis of the impacts of potential standards on consumers, 

manufacturers, and the Nation and weighting of these impacts

 Proposed standard levels for public comment

 Accompanying Federal Register Notice of Public Meeting (NOPM) – 

Planned Summer 2015

• Gives notice of the public meeting and availability of the revised Technical 

Support Document (TSD)

• Encourages interested parties to submit comments

Rulemaking Process Overview

Framework 

Document 

Preliminary 

Analysis NOPR Final Rule
17

Final Rule Publication

 Discuss comments received in response to the NOPR

• DOE will consider all written & verbal input in preparing the final rule. 

 Revise analysis of the impacts of standards & weighting of these impacts 

of the final rule

 Determine the standard levels DOE will adopt

 Establish the compliance date for the adopted standards

 Accompanying Federal Register Notice – Planned Spring 2016

Rulemaking Process Overview

Framework 

Document 

Preliminary 

Analysis NOPR Final Rule
18

2013 

ECS Framework 

Document Public 

Meeting

February 2013

ECS NOPR

Public Meeting

Planned – Summer 2015

2015 2016 2019 

Proposed Energy 

Conservation Standard 

Final Rule Effective 

Date 

Spring 2019

Commercial & Industrial Pumps Rulemaking Schedule

2014 

Test Procedure NOPR

Public Meeting

Planned – Fall 2014

ECS Preliminary 

Analysis

Public Meeting

Planned – Fall 2014

Rulemaking Process Overview
19

5 

3 

2 

Regulatory Regimes & Metrics

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 

Test Procedure

Public Meeting Agenda
20

Authority and Background

 Currently no energy conservation standards for commercial and 

industrial pumps

 The Energy Policy and Conservation Act (EPCA) of 1975 (Public Law 94-

163) established an energy conservation program for certain commercial 

and industrial equipment. 

• This program, set forth in Part C of Title III of EPCA, includes pumps as covered 

equipment and authorizes DOE to issue standards, test procedures and 

labeling requirements for them. (42 U.S.C. 6311(1)(A)).

 DOE issued a Request for Information (RFI) on June 13, 2011 (76 FR 

34192) and received comments from stakeholders.

Legislative History and Coverage
21

Authority and Background (cont.) 

 In December 2011, the Appliance Standards Awareness Project and the 

Hydraulic Institute notified DOE that efficiency advocates and pump 

manufacturers had initiated discussions regarding potential energy 

conservation standards for commercial and industrial pumps.

 Letters to DOE and an Ex Parte Meeting Memo are available in the 

docket at www.regulations.gov. 

 DOE published a Federal Register Notice and Public Meeting (NOPM) – 

78 FR 7304, February 1, 2013 - 

• Some aspects of the stakeholder proposals are referenced in the Framework 

Document and this presentation.

Legislative History and Coverage
22

Pumps for Which DOE is Considering Standards

 Clean Water Pumps

• Consistent with the EU regulation and stakeholder agreement

• DOE may define “clean water” as in the EU or “pumps designed for clean 

water.”

- The latter might be based on metallurgy, sealing/sealless technology, impeller type, 

replaceable wear plates, barrel casing, and center-line support.

 Rotodynamic (Clean Water) Pumps

• Consistent with the EU regulation and stakeholder agreement

• Represent 70% of sales by value and 90% of pump energy use

• Not considering positive displacement pumps at this time

Legislative History and Coverage

Not Considering Covering Possibly Considering Covering

Wastewater, Sump, Slurry, Solids Handling ANSI Chemical Pumps

API 610 Pumps Pumps for other liquids with no solids 

that behave similarly to water
23

Pumps for Which DOE is Considering Standards

Legislative History and Coverage

Request for Comment

Item 1-1: DOE seeks comment on its proposal to cover only clean water pumps 

in this rulemaking. 

Item 1-2: DOE requests comment on whether it should rely on a definition of 

‘clean water’ to determine coverage of pumps, as in the EU, or if, instead, the 

definition of ‘clean water pumps’ should include physical characteristics that 

distinguish pumps designed for clean water or exclude pumps designed for 

other purposes.

Item 1-3: DOE seeks comment on the list of physical differences that may exist 

between pumps designed for clean water and pumps designed for other 

substances. Specifically, (1) is the list accurate and exhaustive, (2) do the 

differences impact efficiency, and (3) do the differences have increased cost?
24

Pumps for Which DOE is Considering Standards

Legislative History and Coverage

Request for Comment

Item 1-4: DOE seeks comment on whether it should consider 

standards for pumps designed for non-water liquids that contain 

limited solids in this rulemaking. DOE is specifically interested in ANSI 

chemical process pumps, API 610 pumps, sealless (magnetic drive, 

canned, or cantilever) pumps, sanitary pumps, refrigerant pumps , and 

general industrial pumps. When suggesting pump types for which 

standards should not be considered, please be specific as to the 

reason why. 

Item 1-5: DOE requests comment on whether any design changes 

made to standard clean water pumps would carry through to pumps 

designed for other applications. 
25

Pumps for Which DOE is Considering Standards

Legislative History and Coverage

Request for Comment

Item 1-6: DOE seeks comment on its proposal to consider standards 

for rotodynamic pumps and not positive displacement pumps. In 

particular, DOE requests comment on the extent of the overlap 

between rotodynamic and positive displacement pumps and whether 

there are certain categories of rotodynamic pumps (pump types and 

ranges of flow and specific speed) for which positive displacement 

pumps could be a direct replacement.
26

Pumps for Which DOE is Considering Standards

Pump Type Sub-Type Stages DOE Coverage Proposal and Terminology

EU Coverage/ 

Stakeholder Proposal

End Suction

Close Coupled Single End Suction Close Coupled (ESCC) Covered

Two

Own Bearings/ 

Frame Mounted

Single End Suction Frame Mounted (ESFM) Covered

Two

In-Line Single In-Line (IL) Covered

Two

Axial Split Single Double Suction (DS) Not Covered

Multi Axially Split Multi-Stage (AS) Not Covered

Radial Split Single

Multi Radially Split Multi-Stage (RS) Partial (vertical in-line) 

Vertical Turbine

NonSubmersible Any Vertical Turbine (VT) Not Covered

Submersible Any Submersible (VT-S) Partial (> 1 stage) 

Axial/Propeller and Mixed Flow Any Axial/Propeller and Mixed (A-M) Not Covered

Regenerative Turbine Any

Pitot Any

Legislative History and Coverage
27

Pumps for Which DOE is Considering Standards

Legislative History and Coverage

Request for Comment

Item 1-7: DOE seeks comment on its proposal to consider standards 

for pumps not covered in the EU.

Item 1-8: DOE seeks comment on its development of pump equipment 

categories and whether these categories provide an appropriate basis 

for developing equipment classes. (See section 3.2.)

Item 1-9: DOE seeks comment on whether standards for any 

additional pump categories should be considered. In particular, DOE is 

interested in pump categories that may have significant potential for 

energy savings.
28

Pumps for Which DOE is Considering Standards

Legislative History and Coverage

Request for Comment

Item 1-10: DOE seeks comment on the pump types as described by ANSI/HI 

nomenclature that fall into the equipment categories set forth in Table 1.1 

(Slide 28). For example, pump type OH1 would be classified as an end suction 

frame mounted pump. For ANSI/HI pump types that would not fall into the 

categories in Table 1.1, please provide a specific reason, such as “solidshandling only.” 

Item 1-11: DOE seeks comment on whether wet-running circulator-type 

pumps should be covered in this rulemaking.

Item 1-12: DOE seeks comment on the market size for wet-running circulators 

in the United States, including the split between commercial and residential 

applications in terms of physical size or other features, as well as the potential 

for growth of the market for circulators in commercial applications.
29

Parameters for Potential Energy Conservation Standards

 DOE is considering excluding self-priming pumps and pumps designed for 

fire-fighting applications.

• DOE does not consider vertical turbine pumps to be self-priming.

 DOE is not considering adopting other coverage parameters except to 

exempt certain pumps from standards for specific reasons.

Legislative History and Coverage

Request for Comment

Item 1-15: DOE requests comment on the technical features and 

applications for fire-fighting pumps and self-priming pumps that 

would allow it to determine whether these pumps should be covered. 
30

Parameters for Potential Energy Conservation Standards

 Stakeholder Coverage Parameter Proposal*:

• 25 gpm and greater

• 295 feet of head maximum

• 1-200 horsepower

• Temperature range from -10 to 120 degrees C

• Meant to generally align with EU scope (although it is different)

 DOE estimates of pumps excluded by these parameters:

Legislative History and Coverage

Pump Category Percent Excluded

Model Availability Shipments (Units)

End Suction Close Coupled (ESCC) 43% 71% 

End Suction Frame Mounted (ESFM) 41% 34% 

In-Line (IL) 43% 47% 

Double Suction (DS) 58% 32% 

Axially Split Multi-Stage (AS) 80% 86% 

Radially Split Multi-Stage (RS) 87% 49% 

Vertical Turbine (VT) 49% 43% 

Submersible (VT-S) 54% 42% 

Axial/Propeller and Mixed (A-M) 36% 40% 

Total 48% 68%

*Material available in docket from DOE meeting 5/1/12. 
31

Parameters for Potential Standards

Legislative History and Coverage

Request for Comment

Item 1-13: DOE requests comment on which parameters, if any, should be 

added to this rulemaking. For each parameter proposed, please include the 

rationale and the type of pump that the parameter is designed to exclude 

from standards. Comments may address those translated from the EU or those 

proposed by stakeholders, but do not have to be limited to those proposals. 

DOE especially seeks comments on parameters that should be added to 

exclude pumps used primarily in residential applications. DOE also seeks 

comment on whether, if using power as a coverage parameter, hydraulic 

power would be more appropriate than shaft power.

Item 1-14: DOE requests comments on the estimates of pumps that would be 

excluded based on the stakeholders’ proposed parameters.
32

Proposed Pump Definitions

 Currently there are no statutory definitions for pumps.

• Definitions have been discussed in the Framework Document.

 DOE Proposed Definitions – 

• Pump: A device that moves liquid by physical or mechanical action.

• Rotodynamic water pump: A pump that moves clean water by means of 

hydrodynamic forces, excluding regenerative turbine pumps.

• End suction water pump: A single-stage rotodynamic water pump in which 

the liquid enters from the end, opposite the pump’s shaft-end and parallel 

with the shaft, and the discharge is at a right angle from the shaft. 

• End suction frame mounted water pump: An end suction rotodynamic water 

pump with its own bearings; such a pump does not rely on the motor bearings 

to support the impeller.

• End suction close coupled water pump: An end suction rotodynamic water 

pump in which the motor shaft is extended to become also the pump shaft.

Legislative History and Coverage
33

Proposed Pump Definitions

 DOE Proposed Definitions (cont.) – 

• In-line water pump: A single-stage rotodynamic water pump in which the 

water inlet of the pump is on the same axis as the water outlet of the pump; 

such pumps are generally installed with the shaft oriented vertically and the 

motor on top. 

• Radially split multi-stage water pump: A rotodynamic water pump with two 

or more stages in a radially split case. Flow proceeds from the inlet through 

the stages in series, with each stage increasing the total head. The flow rate is 

the same through each stage.

• Submersible water pump: A rotodynamic water pump with one or more 

stages designed to be operated in a borehole with the motor fully submerged 

in the pumped water; such pumps are generally vertical turbine pumps with 

submersible motors mounted to the bottom.

• Double suction water pump: An axially split single-stage rotodynamic water 

pump with two inlets. 

Legislative History and Coverage
34

Proposed Pump Definitions

 DOE Proposed Definitions (cont.) – 

• Axially split multi-stage water pump: A rotodynamic water pump with two or 

more stages in an axially split case that is generally oriented horizontally.

• Vertical turbine water pump (non-submersible): A rotodynamic water pump 

in which liquid enters the lower end through the suction bell and then passes 

through one or more stages with impellers and diffuser cases called bowls; 

these pumps are narrow in diameter as a result of their origin as deep-well 

pumps, and the diffuser bowls are in-line with the impellers rather than 

outside them; above the column section, the pump supports a vertical motor 

located above the pumped water. 

• Axial/propeller and mixed flow water pump: A rotodynamic water pump 

with an impeller(s) that develops head (pressure) through axial or close to 

axial forces or a mix of axial and radial forces, with the characteristic of 

relatively high rotational speed and flow relative to head or intermediate flow 

and head. 

Legislative History and Coverage
35

Proposed Pump Definitions

Legislative History and Coverage

Request for Comment

Item 1-23: DOE requests comment on the suggested definitions for 

pumps. 

Item 1-24: DOE requests input on whether the definitions proposed by 

DOE are sufficient to allow manufacturers to determine whether their 

pumps are covered, and in which pump category their equipment 

falls.

Item 1-25: DOE requests comment on what minimum specific speed 

should demarcate the axial/propeller and mixed flow water pump.
36

Proposed Pump Definitions

Legislative History and Coverage

Request for Comment

Item 1-26: DOE requests comment on the definition of ‘clean water’. DOE 

specifically requests input on the translation of wording and units to those 

typically used in the United States, such as parts per million limits for 

suspended and dissolved solids. DOE also seeks comment on the 

appropriateness of the proposed limits. DOE requests clarification on whether 

mixtures including water with freezing points above -10°C should be 

considered clean water for the purposes of this definition and rulemaking. 

Item 1-27: DOE requests comment on whether maximum solids diameter, 

which is a parameter provided with many pump curves, could be used in the 

definition of ‘clean water’. 
37

5 

3 

2 

Test Procedure

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 Regulatory Regimes & Metrics

Public Meeting Agenda
38

Pumping System

 The EU has been exploring an approach to address the pump, inclusive of 

the motor and controls.

• The stakeholders have expressed an interest in this approach.

 Variable Speed Drives (VSDs) are control devices that can address some 

system inefficiencies.

• Savings are found primarily in variable load applications.

- Dependent on time spent at various operating conditions 

- VSDs under constant load operation may degrade efficiency.

• The same pumps can be used in both constant and variable load applications.

- DOE is not aware of any specific pump type that is always used in an application that 

would benefit from a VSD.

 Manufacturers cannot control if or how a VSD is used.

• DOE will conduct analyses across the full spectrum of pump applications and 

baseline conditions to determine in which cases VSDs save energy in the field.

Regulatory Regimes and Metrics
39

Pumping System

 Most pump types are generally sold without motors:

• However, ESCC pumps (generally sold with motors) have the highest shipments

 DOE estimates that only 2% of clean water pumps are sold with VSDs by 

pump manufacturers

• The percentage may be higher in some application categories such as 

circulators or city water pressure booster pumps.

Regulatory Regimes and Metrics

10%

10%

10%

10%

15%

15%

75%

75%

85%

0% 20% 40% 60% 80% 100%

DS

MSAS

A-M 

VT

ESFM

MSRS

ESCC 

IL 

VT-S 
40

Pumping System

Regulatory Regimes and Metrics

Request for Comment

Item 1-16: DOE requests data on how pumps are sold by pump manufacturers. 

Specifically DOE requests data on market share of pumps 1) sold by 

themselves, 2) sold attached to or integrated with motors only, 3) sold 

attached to or integrated with both motors and VSDs, 4) sold physically 

separate from but priced together with a motor only, or 5) sold physically 

separate from but priced together with both a motor and VSD. DOE seeks 

these data by size, equipment category (see section 3.2), and application.

Item 1-17: DOE requests data and information on whether pumps are more 

often combined with motors, VSDs, or both by the pump manufacturer or by 

distributors. 
41

Pumping System

Regulatory Regimes and Metrics

Request for Comment

Item 1-18: DOE requests information on how often and in what 

circumstances the intended application of the pump is known when 

the pump is sold. 

Item 1-19: DOE understands that VSDs are not very effective without 

system feedback. DOE seeks comment on the need for considering 

feedback in any definition for pumps that includes motors and/or 

controls. 
42

Pumping System – Regulatory Regimes Under Consideration by DOE

 Pumps Alone

• Regulatory Regime #1: one equipment class set

- DOE is considering standards for all pump types exclusive of the motor regardless of 

how they are sold

• Consistent with current EU approach for clean water pumps

 Combined Pump Equipment

• Regulatory Regime #2: two equipment class sets

- Pump without VSD (with or without motor)

- Pump with VSD

• Regulatory Regime #3: two equipment class sets

- Pump without motor

- Pump with motor (with or without VSD); VSD is a design option to increase 

efficiency

 DOE notes that in regimes 2 and 3, the same pump model may be placed in two 

equipment classes if it is sold both alone and with a motor (or motor and VSD).

Regulatory Regimes and Metrics
43

Pump 

Sold 

Alone Pump Sold with Motor Pump Sold with VSD

1 

2 

3 

Pumping System - Regulatory Regimes

Regulatory Regimes and Metrics

VSD Motor 

VSD Motor 

VSD Motor 

Motor 

Motor 

VSD Motor 
44

Pumping System

Regulatory Regimes and Metrics

Request for Comment

Item 1-20: DOE requests comment on the benefits and drawbacks of 

the regimes presented above. For regimes 2 and 3, DOE seeks 

comment on whether these regimes could increase the beneficial use 

of VSDs in the field, and whether these regimes could result in the use 

of a VSD in an application for which it is not suited.

Item 1-21: DOE seeks comment on the market share of pumps by 

category that would be used in applications that would benefit from 

VSDs, as well as those where use of a VSD could result in increased 

energy use.
45

Pumping System

 Approximately 10% of pumps DOE is considering may be driven by 

natural gas or diesel engines or steam turbines.

 For pumps sold with an engine or for use with an engine, DOE is 

considering regulating pumps as sold alone regardless of the regulatory 

regime chosen.

Regulatory Regimes and Metrics

Request for Comment

Item 1-22: DOE seeks comment on the market share and applications 

of pumps by category driven by equipment other than an electric 

motor. 
46

Efficiency Metrics - Existing

 Pump Efficiency: The ratio of hydraulic power to shaft input power

• EU clean water pump regulation and clean water pump selection guide

• HI 20.3-2010 Rotodynamic Pump Efficiency Prediction

• Mexico (vertical turbine pumps), South Korea, China

 Overall (Wire to Water) Efficiency: The ratio of hydraulic power to the electric 

power input at the motor and/or the VSD

• Used in Mexico for submersible pumps

 EEI: Energy efficiency index based on average hydraulic power and a reference 

power 

• Used in EU circulator regulation

 Bowl Efficiency: The ratio of hydraulic power output from the bowl to the 

power input to the bowl 

• Considered in HI 14.6-2011 for vertically suspended pumps

Regulatory Regimes and Metrics
47

Efficiency Metric – EU Approach

 Minimum pump efficiency is 

based on an equation taking into 

account flow (Q), specific speed 

(Ns), pump type, and rotating 

speed (N).

• Ns also incorporates head.

 Result is a 3D surface, described 

as a function of Q and Ns.

• The EU raises or lowers the 

surface to cut-off a certain 

percentage of the market for a 

given pump equipment class and 

design speed.

Regulatory Regimes and Metrics
48

Efficiency Metric – EU Approach

 Pump efficiency at BEP, 75% BEP flow (part-load), and 110% BEP flow 

(over-load)

• Standard at 75% is 0.947 of standard at BEP

• Standard at 110% is 0.985 of standard at BEP

• Must pass all three points to meet standard

 Standard and testing based on pumps with a full impeller

 For vertical multi-stage water pumps, standard and testing based on 3 

stage version; For submersible multi-stage water pumps, based on 9 

stage version

Regulatory Regimes and Metrics
49

Efficiency Metric – DOE Considerations

 Pumps sold alone (or all pumps if not considering motor and controls): 

DOE is considering following the EU approach with pump efficiency at 

BEP, 75% BEP, and 110% BEP

• DOE may consider overall (wire-to-water) efficiency for submersible pumps or 

bowl efficiency for vertical turbine and submersible pumps

Regulatory Regimes and Metrics
50

Efficiency Metric – DOE Considerations

 Pumps inclusive of motor and/or controls: The metric needs to reflect 

energy efficiency increases not captured in pump efficiency.

• For pumps sold with motors and VSDs (regime 2), DOE is considering a metric 

that can be used to account for the use of more efficient VSDs.

- Possibly overall (wire-to-water) efficiency at the same three points

• For pumps sold with motors (regime 3), DOE must identify a metric that can 

capture the impacts on energy efficiency associated with the use of a VSD in 

comparison to a pump with a motor but without a VSD.

- Possibly based on motor/control input power ,such as input power per unit flow or 

ratio of input power at part-load to input-power at full load in a non-VSD condition, 

also using multiple load points

Regulatory Regimes and Metrics
51

Efficiency Metric – DOE Considerations

 If DOE pursues regime 2 or regime 3, two sets of equipment classes will 

be developed.

 DOE is considering the following three efficiency metric options:

• Different metrics, one for each set of equipment classes [Separate]

• Single, uniform metric for all equipment classes [Same]

• Single efficiency metric for pump-only equipment and multiple metrics for 

pump-motor or pump-motor-VSD equipment [Multiple]

Regulatory Regimes and Metrics
52

Efficiency Metric – DOE Considerations

Regulatory Regimes and Metrics

Regulatory 

Regime

Equipment Class 

Set

Metric Options

Separate Same Multiple

2 Pumps 

inclusive of 

motor and 

VSD

Pumps Without 

VSD (with or 

without motor) 

Pump Efficiency Overall 

Efficiency 

(standardized 

motor)

Pump Efficiency

Pumps With VSD Overall 

Efficiency

Overall 

Efficiency

Pump Efficiency 

and Overall 

Efficiency

3 Pumps 

inclusive of 

motor

Pumps Without 

Motor

Pump Efficiency Electric Input 

Power Based 

(standardized 

motor)

Pump Efficiency

Pumps With Motor 

(with or without 

VSD)

Electric Input 

Power Based

Electric Input 

Power Based

Pump Efficiency 

and Electric 

Input Power 

Based Metric
53

Efficiency Metric – DOE Considerations

 The metric options may impact manufacturer burden.

 A pump sold both with and without a motor (or VSD) could placed into 

two equipment classes.

 DOE believes that the same test stand could be used, but some metrics 

or metric alignment options may require additional measurements or 

calculations such as:

• Shaft input power and electric input power

• Multiply pump efficiency by standard motor and VSD efficiency

Regulatory Regimes and Metrics
54

Efficiency Metric – DOE Considerations

Regulatory Regimes and Metrics

Request for Comment

Item 1-28: DOE requests comment on its proposal to follow the EU approach using 

pump efficiency if pumps are defined without the motor or controls. DOE is especially 

interested in whether a pump should have to meet a standard at multiple load points, 

or if a weighted average metric should be developed.

Item 1-29: DOE requests comment on the selection of 75% BEP flow as the part-load 

point and 110% as the overload point and whether these are the most appropriate 

points to encourage broad pump efficiency curves.

Item 1-30: DOE requests comment on whether the use of an overall efficiency metric for 

submersible pumps would cause problems for manufacturers, as the EU metric is pump 

efficiency.

Item 1-31: DOE requests comment on whether the metric for vertically suspended 

pumps should be bowl efficiency rather than pump efficiency.
55

Efficiency Metric – DOE Considerations

Regulatory Regimes and Metrics

Request for Comment

Item 1-32: DOE requests comment on its proposal to adapt the EU 

standard metric to overall efficiency for pumps sold with both motors and 

VSDs. DOE is also interested in whether additional test points should be 

added below 75% of BEP flow to address more of the operating range of 

pumps with VSDs. 

Item 1-33: DOE requests comment on the appropriate metric to capture 

the energy efficiency impacts of VSDs. DOE is interested in whether test 

points at BEP, 75% BEP flow, and 110% BEP flow are appropriate for this 

metric and whether additional test points should be added below 75% 

BEP flow to address more of the operating range of pumps with VSDs. 

DOE is also interested in whether pumps should be required to meet 

minimum levels at multiple points or if a weighted average metric should 

be developed.
56

Efficiency Metric – DOE Considerations

Regulatory Regimes and Metrics

Request for Comment

Item 1-35: DOE recognizes that the same pump may in some cases be 

sold alone or may be sold in conjunction with a motor or 

motor/control package. DOE seeks comment on any issues that may 

result from having different metrics for pumps sold alone and pumps 

sold with motors or VSDs.
57

Efficiency Metric - Potential Implementation Method

 Efficiency Surfaces

• DOE is considering whether any standard would be a function of specific 

speed and flow, as in the EU water pumps regulation.

• DOE expects to adapt the EU approach to the US market.

- Initial analysis indicates that the distribution of efficiency in the US pump market is 

different from that in the EU.

• DOE could use the EU equation but change the C value (same surface at a 

different vertical position).

• DOE could use the EU equation form but change coefficients (different 

surface).

- Unique to individual equipment classes

- Change surface shape from bottom- to top-of-market 

 The data presented are based on clean water ESCC pump models 

extracted from PUMP-FLOTM Desktop.

Regulatory Regimes and Metrics
58

Efficiency Metric - Potential Implementation Method

Regulatory Regimes and Metrics

 Comparison of EU MEI 50 surface to US average surface
59

Efficiency Metric - Potential Implementation Method

Regulatory Regimes and Metrics

Bottom of Market (Red)

Top of Market (Blue)

Average (Green) Bottom of Market (Red) Top of Market (Blue)

 Average, top-of-market, and bottom-of-market surfaces for US 

ESCC pumps (demonstrating range of efficiencies)
60

Efficiency Metric - Potential Implementation Method

Regulatory Regimes and Metrics

Request for Comment

Item 1-36: DOE seeks comment regarding the implementation 

methodology described in this section, including whether basing 

efficiency on flow and specific speed is appropriate and, if so, whether 

the EU surface should be used as is, with adjusted Cs, or with modified 

shapes (adjustment of all coefficients). The last option would allow 

type- and efficiency level-specific surfaces. DOE also seeks comment 

on whether other parameters or combinations of parameters would 

be more appropriate or easier to implement, such as flow and head 

(instead of specific speed).
61

Efficiency Metric - Potential Implementation Method

Regulatory Regimes and Metrics

Request for Comment

Item 1-37: DOE requests data that would help it improve its database, 

specifically performance data (i.e., head, flow, power, and efficiency at BEP 

and multiple additional points) for clean water pumps from catalogs not 

available on PUMP-FLO.

Item 1-38: DOE seeks comment on how to calculate specific speed (with 

regard to flow) for double suction axial split pumps and axially split multistage pumps with a double-suction first stage (i.e., whether to use total flow 

ore one-half the flow).

Item 1-39: DOE seeks test data for pumps at 75% and 110% BEP flow points 

that would allow it to better analyze potential efficiency levels for these 

points. 
62

Efficiency Metric - Potential Implementation Method

 Testing based on three stages for radially split multi-stage pumps and 

nine stages for submersible pumps

• Axially split multi-stage pumps may have to be tested as sold (not cellular).

 Standard based on full impeller

Regulatory Regimes and Metrics

Request for Comment

Item 1-40: DOE requests comment on the appropriateness of setting a standard based on a full 

impeller.

Item 1-41: DOE requests comment on standards based on certain numbers of stages for radially split 

multi-stage and submersible pumps. DOE also seeks comment on whether the same approach could 

be taken for axially split multi-stage pumps.

Item 1-42: DOE requests data on the percent of pumps sold with a full impeller, as well as the 

distribution of pump sales with reduced impellers (as a percentage of full impeller).
63

5 

3 

2 

Test Procedure

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 Regulatory Regimes & Metrics

Public Meeting Agenda
64

Approach

 DOE is conducting a test procedure rulemaking.

 When establishing test procedures, DOE reviews existing industry test 

procedures to measure the energy use or energy efficiency of the 

covered equipment.

 Once adopted, manufacturers must use a DOE prescribed test procedure 

to establish compliance with any standards and make representation of 

the basic model’s efficiency.

• DOE develops test procedures to ensure test repeatability and fair comparison 

of equipment .

Test Procedure
65

Review of Industry Test Procedures

 ANSI/HI 14.6-2011: “Rotodynamic Pumps for Hydraulic Performance 

Acceptance Tests” 

• Applies to any size centrifugal, mixed, and axial flow rotodynamic pump 

without fittings using any pumped liquid behaving as clear water

• Based on measuring the flow of the pumped liquid

• Allows for the use of alternative homogenous liquids when water is not 

appropriate for the application

 ISO 9906-2012 “Rotodynamic pumps – Hydraulic performance 

acceptance tests – Grades 1, 2 and 3”

• Mirrors ANSI/HI 14.6-2011 

Test Procedure
66

Review of Industry Test Procedures

 ANSI/HI 11.6-2012: “Submersible Pump Tests” 

• Similar metrics, test conditions, and protocols to ANSI/HI 14.6-2011 and ISO 

9906-2012 

• Applies only to centrifugal submersible pumps

• Test must be performed on clean water

 ISO 5198-1999: “Centrifugal, mixed flow, and axial pumps. Code for 

hydraulic performance tests. Precision class”

• Test procedure based on thermodynamic principles rather than flow

• Temperature and pressure measurements are used to determine pump 

efficiency

Test Procedure
67

Test Procedure

Request for Comment

Item 1-43: DOE requests comment on the use of the ANSI/HI 14.6-2011, 

ANSI/HI 11.6-2012, ISO 9906-2012, and ISO 5198-1999 test procedures, as 

well as any other test procedures that DOE should consider, as a basis for the 

development of a DOE test procedure, including any modifications or 

additions that may be necessary.

Item 1-44: DOE requests comment on the scope of each test procedure with 

respect to the equipment for which DOE is considering in the scope of this 

rulemaking, as well as any limitations of these test procedures. 

Item 1-45: DOE is also interested in the pros and cons of using a 

thermodynamic approach instead of a flow-based approach to determining 

pump or pumping system efficiency, as in ISO 5198-1999. 
68

Pump+Motor+VSD 

 DOE may define commercial and industrial pumps inclusive of motors 

and VSDs.

 ANSI/HI 14.6-2011 provides a potential basis for testing overall system 

efficiency (wire-to-water) with motors and VSDs, using a wattmeter to 

measure the input power to the motor or VSD.

 ANSI/HI 14.6-2011 also describes a “string” test that relies on rated 

efficiencies of the motor or VSD, or both, to determine the pump 

efficiency.

Test Procedure
69

Test Procedure Accuracy and Repeatability

 Test accuracy and repeatability can vary based on the sensitivity and 

calibration of the selected measurement equipment.

 DOE will consider establishing tolerances on test conditions and test 

results and defining the number of units that should be tested.

Test Procedure
70

Test Procedure

Request for Comment

Item 1-47: DOE requests comment on the applicable test procedures 

for complete pump, motor, and VSD system packages.

Item 1-48: DOE requests comment on the accuracy of different 

measurement equipment used to measure pump power, input power 

to a motor or VSD, pump flow, head, or other parameters and their 

impact on the accuracy of the measured pump efficiency. DOE also 

requests comment on the calibration frequency required to maintain 

sufficient equipment accuracy. 
71

Test Procedure

Request for Comment

Item 1-49: DOE requests comment on the applicability of calculation 

methods to determine rated pump efficiencies from similar, tested 

pump efficiencies. 

Item 1-50: DOE requests comment on the number of unique pump 

models manufacturers would have to test, as well as the ability for a 

calculation method to reduce testing burden. DOE also requests 

comment on the reduction in test accuracy when using a calculation 

method to determine rated efficiency of a unit.
72

5 

3 

2 

Test Procedure

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 Regulatory Regimes & Metrics

Public Meeting Agenda
73

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
74

Market and Technology Assessment

 Purpose:

• Characterize the commercial and industrial pump markets and the measures 

to improve efficiency

 Method: 

• Identify and characterize manufacturers of commercial and industrial pumps

• Estimate shipments and trends in the market

• Identify technologies that could improve efficiency

• Identify regulatory and non-regulatory initiatives intended to improve the 

efficiency of the equipment covered under this rulemaking

Preliminary Analysis
75

Manufacturer Overview

 In the United States, ten companies represent 60-70% of the total U.S. 

pumps market: Grundfos, Sulzer, Weir Group, KSB, Xylem, Flowserve, 

Ebara, Pentair, Roper Industries, and ITT Goulds. 

 There has been significant consolidation in the global pump market in 

the past 25 years, and these ten companies comprise approximately 70 

brands or divisions.

 A list of major suppliers and their parent companies is available on page 

44 of the Framework Document.

Market and Technology Assessment
76

Shipments Overview

 DOE examined census data for pumps.

• Pages 46-51 in the Framework document shows mapping of product codes to 

DOE pump equipment categories, estimated allocations of imports and 

exports to equipment categories, and estimated percent of pumps that are 

clean water.

 DOE estimates that 89% of shipments of covered pumps are ESCC – but 

only 35% by value.

Market and Technology Assessment

89%

7%

3%

Shipments (Units)

ESCC 

IL 

ESFM

VT

DS

MSRS

VT-S 

A-M 

MSAS

35%

9% 11% 4%

15%

11%

2% 10%

3%

Shipments (Value)

ESCC 

IL 

ESFM

VT

DS

MSRS

VT-S 

A-M 

MSAS
77

Market Assessment

Market and Technology Assessment

Request for Comment

Item 3-1: DOE requests information that would contribute to the market 

assessment for the pumps that would be covered in this rulemaking, especially for 

those equipment classes designated in section 3.2. Examples of information 

sought include current equipment features and efficiencies, equipment feature and 

efficiency trends, and historical equipment shipments and prices.

Item 3-2: DOE requests input on its identification of product codes in the U.S. 

Census data that match the equipment classes proposed for coverage in this 

rulemaking. 

Item 3-3: DOE requests feedback on its estimates of the disaggregation of pump 

exports and imports to product codes, its estimates of the percentage of shipments 

of clean water pumps, and its estimates of the percent of shipments sold with 

motors by the pump manufacturer.
78

Considered Equipment Classes

 If DOE uses regulatory regimes 2 or 3, equipment class sets for pumps sold with motors 

or VSDs would likely mirror the set shown above.

Market and Technology Assessment

Pump Type Sub-Type Stages DOE Terminology

Design 

Speed

End Suction

Close Coupled Single End Suction Close Coupled (ESCC) 3,500

1,750

Own Bearings/ 

Frame Mounted Single End Suction Frame Mounted (ESFM) 3,5001,750

In-Line Single In-Line (IL) 3,500

1,750

Axial Split

Single Double Suction (DS) 3,500

1,750

Multi Axially Split Multi-Stage (AS) 3,500

1,750

Radial Split Multi Radially Split Multi-Stage (RS) 3,500

1,750

Vertical Turbine

Non-Submersible Any Vertical Turbine (VT) 3,500

1,750

Submersible Any Submersible (VT-S) 3,500

1,750

Axial/Propeller and Mixed Flow Any Axial/Propeller and Mixed (A-M) 3,500

1,750
79

Equipment Classes

Market and Technology Assessment

Request for Comment

Item 3-4: DOE welcomes comments on which performance-related features or design characteristics 

DOE should consider to define pump equipment classes.

Item 3-5: DOE requests information regarding the utility of different pump categories proposed for 

coverage that would warrant separate equipment classes. For example, could end suction pumps be 

a single equipment class, or are the breakdowns shown necessary to preserve equipment utility that 

would affect performance? Could axially and radially split multi-stage pumps be a single equipment 

class? Could all vertical turbine pumps (both submersible and non-submersible) be a single 

equipment class? 

Item 3-6: DOE requests information on whether any of the equipment proposed for coverage 

provides utility that requires further breakdown from the categories shown in Table 3.8 (Slide 83). 

For example, do multi-stage pumps with a double suction first stage require a separate equipment 

class? Do vertical turbine can pumps require a separate equipment class from vertical turbine 

lineshaft pumps? 

Item 3-7: DOE requests comment on whether equipment classes can be developed for pump 

categories that would always be used in variable load applications.
80

Equipment Classes – Design Speed

 The EU regulation contains separate efficiency standards for pumps 

operating at 1450 rpm and pumps operating at 2900 rpm (equivalent to 

1750 and 3500 in the US).

• This captures a size effect, in which a larger pump running at lower speed is 

assumed to be more efficient than a geometrically similar smaller pump 

running at higher speed (4 pole > 2 pole).

 Having separate standards for pumps at different speeds has 

implications for a single pump offered at multiple speeds.

• As shown in Framework Table 3.9, depending on the method of creating 

efficiency equations, predicted efficiency for a single pump is sometimes 

higher at 2 pole and sometimes at 4 pole, and the difference between the 

same pump at 2 pole and 4 pole may be as much as 7% points.

 DOE wants to make sure the method of determining minimum efficiency 

produces appropriate results at all speeds.

Market and Technology Assessment
81

Equipment Classes – Design Speed

 Regardless of whether DOE sets equipment classes based on design 

speed, DOE must determine speed for testing and compliance.

• May be difficult to select a single speed for testing because of variation in 

each equipment class

• Could require calculating minimum efficiency at multiple speeds and require 

testing and compliance at the speed with the most stringent efficiency

Market and Technology Assessment
82

Equipment Classes – Design Speed

Market and Technology Assessment

Request for Comment

Item 3-8: DOE requests comment on whether it should consider using 

Reynolds number instead of flow in setting minimum efficiency standards for 

pumps and whether this choice would prevent adding design speed as an 

additional parameter. DOE notes that there are multiple methods of 

calculating Reynolds number for pumps and that all calculations do not 

produce the same relative results. As a result, DOE seeks comment on the 

most appropriate form of Reynolds number for pumps.

Item 3-9: DOE requests comment on which method of surface fitting produces 

the most appropriate results for both cases: (1) a smaller pump at higher 

speed compared to a larger pump at lower speed; and (2) identical pumps 

running at two different speeds. DOE requests comment on whether these 

relationships are expected to differ by equipment class.
83

Equipment Classes – Design Speed

Market and Technology Assessment

Request for Comment

Item 3-10: DOE requests comment on the use of pump design speed as a feature that 

distinguishes equipment classes. In particular, DOE seeks comment on whether pumps 

designed for different rotating speeds perform differently enough to warrant separate 

equipment classes. DOE also requests comment on any physical differences between 

pump models offered at different speeds and the nature of those differences, including 

whether DOE could determine by physical inspection at what speeds a pump can safely 

operate. 

Item 3-11: DOE requests comment on the testing and compliance burden on 

manufacturers under the approaches set forth above.

Item 3-12: DOE requests comment on whether it could require all pumps in a given 

equipment class to be tested at (a) certain speed(s) and, if so, which speed(s) is (are) 

most appropriate.

Item 3-13: DOE requests comment on how manufacturers in the EU are determining the 

minimum efficiency required for a pump offered at multiple speeds.
84

Representative Classes

 DOE may determine an appropriate subset of representative equipment 

classes to analyze for the engineering analysis.

• DOE would extrapolate the results to the remaining equipment classes.

• Typically each representative equipment class would represent the majority of 

shipments.

 ESCC and ESFM pump wet-ends are often identical but supplied with 

different motors.

• ESFM would be preferred in terms of accuracy of pump efficiency 

measurement, but ESCC represent more shipments.

 Vertical turbine and submersible vertical turbine pumps could be 

represented by one class depending on choice of metric.

Market and Technology Assessment
85

Representative Units

 Selection based on identification of units that are functionally equivalent 

in all aspects except efficiency

• For pumps, this is expected to be pumps with approximately constant BEP 

flow and specific speed but with different efficiency levels.

 A representative unit represents multiple models of pumps – one at 

baseline level, and one or more at higher efficiency levels.

 DOE will scale the engineering analysis results for the representative 

units to cover the full range of flow and specific speeds within the 

equipment class.

Market and Technology Assessment
86

Request for Comment

Item 5-2: DOE welcomes comment from interested parties on the best 

methodology for scaling cost-efficiency curve results from the representative 

units to the representative equipment classes and extrapolating from the 

representative equipment classes to the remaining equipment classes not 

directly analyzed.

Item 5-3: DOE seeks comment on its selection of representative classes: which 

classes could be grouped together for this analysis, and which class should be 

tested. 

Item 5-4: DOE welcomes comment on the selection of representative units in 

terms of appropriate flow and specific speed ratings within each equipment 

class.

Representative Classes and Units

Market and Technology Assessment
87

Baseline Models

 Baseline models serve as a reference point to calculate cost and energy 

savings of more efficient models in the engineering analysis.

 Typically a model that just meets current standards

• For pumps, should represent least efficient, most typical pump offered

 DOE is considering the appropriate method to develop baseline 

efficiency levels.

 Shipments data will help identify levels, as baseline level should have 

significant shipments.

Market and Technology Assessment
88

Baseline Models

Figure 5.1 Example Baseline Efficiency Levels for ESCC Pumps (Ns=1500-2500)

Market and Technology Assessment
89

Efficiency Levels

 DOE will conduct the engineering analysis (and LCC and PBP analyses) on 

all equipment classes for which it suggests efficiency levels.

 DOE is required to analyze maximum technologically feasible (“max 

tech”) efficiency levels.

 DOE will seek interested party input on the appropriate max-tech levels.

 DOE will analyze design options and costs associated with improving 

efficiency from the baseline through the max-tech model.

 DOE is considering how to define max-tech based on market maximums.

Market and Technology Assessment
90

Efficiency Levels

Market and Technology Assessment

Figure 5.2 Example Max-Tech Efficiency Levels for ESCC Pumps (Ns=1500-2500)
91

Request for Comment

Item 5-5: DOE seeks comment on the selection and performance 

characteristics of baseline models for each equipment class. DOE will 

consider such comments in defining the characteristics of the 

proposed baseline models. 

Item 5-6: DOE seeks input from stakeholders regarding the range of 

efficiency levels that should be examined as part of its analysis.

Item 5-7: DOE seeks input from interested parties on a methodology 

that would be appropriate for determining the max-tech models for 

each pump analyzed.

Baseline Models and Efficiency Levels

Market and Technology Assessment
92

Initial Technology Options to Improve Efficiency

 Pumps

• Improving hydraulic design 

• Smoothing surface finish

• Reducing running clearances

• Reducing mechanical friction in seals

 Pumps+Motors(+VSD) 

• Adding a VSD (which enables users to reduce speed when possible)

• Improving VSD efficiency

• Reducing VSD standby and off mode power usage

 Other? 

Market and Technology Assessment
93

Technology Options

Market and Technology Assessment

Request for Comment

Item 3-14: DOE welcomes comment on the technology options identified in this section, 

including further details on methods (such as lists of specific methods for each listed 

broad option) and potential efficiency gains, as well as information on whether the 

method in question is applicable to all pumps in a given equipment class or only pumps 

with certain design characteristics). DOE also welcomes comment on whether there are 

other technology options that it should also consider.

Item 3-15: DOE welcomes comment on the relevance of the technology options 

identified to pumps sold with smaller impellers than the full impeller on which DOE is 

tentatively proposing to base a standard. In particular, would these design options be 

carried through to pumps with all impeller sizes? 

Item 3-16: DOE requests information related to various impeller types used in clean 

water pump designs and the efficiency impacts of each type. 
94

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
95

Screening Analysis

 Purpose:

• Screen out technology options that DOE will not consider in the engineering 

analysis for commercial and industrial pumps

 Method: 

• DOE will evaluate each technology option based on the following criteria:

- Technological feasibility

- Practicability to manufacture, install and service on a commercial scale at the time 

compliance with any final standards would be required

- Impacts on product utility or available to consumers

- Impact on health and safety

Preliminary Analysis
96

Screening Analysis

Request for Comment

Item 4-1: Are there any technologies, including those listed in the 

Framework Document, that DOE should not consider because of any 

of the four screening criteria? If so, which screening criteria apply to 

the cited technology or technologies? 
97

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
98

 Develop the cost-efficiency curve, which characterizes the relationship 

between manufacturer selling price (MSP) and energy efficiency.

 The cost-efficiency curves for the examined equipment classes are key inputs 

for the downstream rulemaking analyses. 

Engineering Analysis

Rulemaking Analyses

• Life-Cycle Cost and Payback 

Period Analysis

• Manufacturer Impact Analysis 

• Employment Impact Analysis

Manufacturer Selling Price – 

Efficiency Relationship

Manufacturer 

Selling Price (MSP)

Efficiency Level

Purpose 
99

Approach

 Design Option Approach: Determination of costs and efficiency 

improvement potential based on individual and groups of design options.

 Efficiency Level Approach: Determination of costs at predetermined 

efficiency levels to represent the cost/efficiency relationship.

 Reverse Engineering Approach: Calculation of costs for the efficiency 

levels associated with reverse-engineered products using a manufacturing 

cost model. 

Engineering Analysis

DOE will consider using any one or a combination of these approaches, 

employing available data sources to develop the cost-efficiency 

relationships.
100

Methodology

• Determine characteristics of common or typical models 

which will serve as reference points to assess changes due 

to energy conservation standards. 

Define Baseline 

Models 

• Conduct tests to verify efficiency ratings.

• Perform equipment disassembly to identify design options 

and provide input to manufacturing cost models to 

determine designs and costs associated with each efficiency 

level.

Teardown and Testing

• Collect available cost data on efficient pump designs.

• Conduct interviews with manufacturers to enhance 

understanding of efficiency improvements and associated 

costs.

Data Collection and

Interviews

• Develop cost-efficiency relationship based on reverseengineering and cost data from available sources including 

manufacturer interviews.

Develop CostEfficiency Relationships

Engineering Analysis
101

Request for Comment

Item 5-1: DOE seeks input on the methods and approaches used by 

manufacturers to improve the efficiency of pumps and, in particular, 

how frequently hydraulic re-design would be the only method 

employed.

Item 5-8: For each equipment class, DOE welcomes comments on 

methods and approaches that DOE intends to employ to determine 

potential efficiency improvements for pumps. Detailed information on 

the pump performance and the incremental manufacturing costs (e.g., 

material costs, labor costs, overhead costs, building conversion capital 

expenditures, capital expenditures for tooling or equipment 

conversion associated with more efficient designs, R&D expenses, and 

marketing expenses) would be useful. 

Methodology

Engineering Analysis
102

Teardown & Test Methodology

Fabricated 

Parts

Selection of 

Units

Physical 

Teardown

Bill of Materials

Assembly 

Process

Manufacturer 

Costs

Purchased 

Parts

Engineering Analysis
103

Manufacturer Cost Estimate

 Equipment Costs (MSP)

• Includes manufacturer production costs (MPC) as well as non-production 

costs, such as maintenance, depreciation, and taxes

• Markups will be used to represent non-production costs and convert the MPC 

to the MSP.

• DOE intends to estimate manufacturer markups based on publicly available 

financial information and manufacturer interviews. 

 Conversion Costs 

• Includes the difference in investments required to build production facilities 

required for higher-efficiency designs as compared with investments for 

production facilities used for current designs

• DOE typically does not include conversion costs in the engineering analysis.

• One option to improve pump efficiency is hydraulic re-design. The nonrecurring R&D costs required to develop such new designs also would not be 

part of the MSP calculated in the engineering analysis. 

Engineering Analysis
104

Request for Comment

Item 5-9: DOE welcomes comment on the markup approach proposed 

for developing estimates of manufacturer selling prices. 

Item 5-10: DOE welcomes comment on the approach to determining 

the relationship between manufacturer selling price and pump 

efficiency. 

Item 5-11: DOE welcomes comment on the conversion costs required 

to improve the efficiency of the pumps to various levels, as well as 

what portion of these costs would be passed on to the consumer.

Methodology and Manufacturer Cost Estimates

Engineering Analysis
105

Outside Regulatory Changes

 DOE will consider the effects of other DOE energy conservation 

standards and regulatory changes outside DOE’s rulemaking process that 

can impact manufacturers of covered equipment.

 Some regulatory changes can also affect the efficiency or energy 

consumption of the pumps covered under this rulemaking. 

 DOE will attempt to identify any outside engineering issues. that could 

impact the engineering analysis.

Engineering Analysis

Request for Comment

Item 5-12: DOE welcomes comment on whether there are outside 

regulatory changes that DOE should consider in its engineering 

analysis of pumps.
106

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
107

Manufacturer Impact Analysis

 Purpose:

• Assess the impacts of standards on manufacturers 

• Identify and estimate impacts on manufacturer subgroups that may 

experience greater impacts than the industry as a whole

• Examine the impact of cumulative regulatory burden on the industry

 Method: 

• Analyze industry cash flow and NPV through use of the Government 

Regulatory Impact Model (GRIM)

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

analyses, and address qualitative issues

Preliminary Analysis
108

Manufacturer Impact Analysis

The MIA consists of three main phases: 

Industry 

profile

Develop 

strawman 

GRIM

Develop 

interview 

guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Phase 2 Phase 3

Initial MIA 

Interviews

Phase 1

Interim 

Analysis

NOPR

Item 12-1: DOE seeks comments on the subgroups of pump equipment manufacturers 

that it should consider in a manufacturer subgroup analysis. 

Item 12-2: DOE seeks comments on what other existing regulations or pending 

regulations it should consider in its examination of cumulative regulatory burden.

Item 12-A: DOE seeks comment on small businesses that could be impacted by potential 

energy conservation standards for commercial and industrial pumps, as well what these 

impacts might be.

Request for Comment
109

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
110

Mark-Ups Analysis

 Purpose:

• Convert manufacturer selling price estimates from the engineering 

analysis to customer prices

 Method: 

• Identify distribution channels 

• Estimate how equipment is marked up in the distribution chain

Preliminary Analysis
111

Approach

 Distribution Channels

Mark-Ups Analysis

Manufacturer  Customer (Direct End-User Channel)

Manufacturer  OEM  OEM Distributor  Customer (OEM Channel)

Manufacturer  Wholesaler  Customer (Distributor Channel) 

Manufacturer  Wholesaler  Contractor  Customer (Contractor Channel)
112

Types of Markups in Distribution Chain

 Baseline Markups:

• Markups relate end-user price to manufacturers selling price (MSP) averaged 

over all distribution channels.

• Baseline markups relate price to MSP for all currently sold equipment.

• Baseline markups indicate a consumer price that covers all of a distributor’s or 

contractor’s current expenses plus profit.

 Incremental Markups:

• Incremental markups relate the incremental change in end-user price to the 

incremental change in MSP due to higher efficiency designs.

• Some of the distributor’s costs, such as direct labor costs (salaries, payroll, 

rental and occupancy), do not vary with efficiency induced changes and are 

excluded from the calculation of incremental markups.

• Incremental markups cover only expenses that are expected to vary with 

higher cost of equipment sold e.g., business promotion, interest and insurance 

etc.

Mark-Ups Analysis
113

Request for Comment

Item 6-1: DOE requests information on the distribution channels under 

consideration.

Item 6-2: DOE requests comments and additional information on the 

appropriate way to establish distribution channel percentages across 

equipment classes and application (market) segments for the current 

rulemaking. In particular, DOE seeks information on the percentage by market 

segment (i.e., agriculture, municipal, commercial, industrial, and other 

markets) of direct sales, OEM sales, wholesaler to customer sales, wholesaler 

to contractor sales, and other sales. DOE seeks this information over the total 

market. 

Item 6-3: DOE seeks comment on other sources of relevant data that could be 

used to characterize markups for commercial and industrial pumps.

Mark-Ups Analysis
114

Request for Comment

Item 6-4: DOE requests feedback on its proposal to use incremental 

distribution channel markups.

Item 6-5: DOE seeks comment on appropriate transportation and 

shipping costs to include in the analysis and whether those costs are 

likely to vary for higher efficiency commercial and industrial pumps.

Mark-Ups Analysis
115

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
116

Energy Use Analysis

 Purpose:

• Identify how pumps are actually operated by users and to determine the 

energy savings potential of more efficient designs in the field

• Estimate annual energy consumption (AEC) for baseline and higher-efficiency 

designs using the load profiles developed for each application

 Issues:

• End-use duty profiles are expected to vary across the equipment classes and 

application segments.

• Pumps are often designed to exceed the flow rate capacity and head 

requirements as an engineering precaution.

• Pumps are often selected based on the peak load or maximum system 

capacity.

Preliminary Analysis
117

Approach

 Estimate annual energy consumption (AEC) for baseline and higher-efficiency 

designs using the load profiles developed for each application:

• Where

- AEC = annual energy consumption (kWh),

- Qi = flow rate at the operating point i, gallons per minute (gpm), 

- Hi = pump head at the operating point i, (ft),

- Ni = operating hours at the operating point i, 

- ηOverall = ηF × ηT × ηM × ηC at the operating point i, 

– ηF = pump efficiency,

– ηT = transmission efficiency,

– ηM = motor efficiency, 

– ηC = control system efficiency, 

- Sp.Gr = specific gravity of the fluid, and 

- 5,308 is a unit conversion constant.

 Develop statistical models describing the expected range of duty profiles for 

pumps in different applications

Energy Use Analysis

308,5/).()/(

All_operating_points

1

AEC HQ SpN Gr

i

ii ii overall ×













 = ∑ × × =

η
118

Request for Comment

Item 7-1: DOE requests input and recommendations for identifying high sales volume and 

large installed base application segments corresponding to specific applications for which the 

pumps used may have similar duty profiles.

Item 7-2: DOE welcomes recommendations on sources of data or analysis methods that would 

provide end-use duty profiles for each of the equipment classes of pumps covered under this 

rulemaking in the major application segments.

Item 7-3: DOE requests input on ways to characterize pump sizing and selection practices for 

different equipment classes and applications. 

Item 7-4: DOE requests comment on the degree of oversizing prevalent in different application 

segments. 

 

Item 7-5: DOE welcomes comment on methods for determining nominal (non-market 

segment specific) duty profiles for pump equipment classes considered in this rulemaking.

Energy Use Analysis
119

Request for Comment

Item 7-6: DOE welcomes comment on the current penetration level of VSDs in the installed 

base of equipment in each application segment for each of the equipment classes considered 

in this rulemaking. DOE also welcomes comment on the baseline condition for applications 

without VSDs, such as running at full load, use of a throttling valve, etc.

Item 7-7: DOE requests comment and recommendation on the range and number of sizes over 

which the analysis should be carried out for each specific speed in different classes of 

equipment.

Item 7-8: DOE requests information on current industry practices and recommendations on 

the selection of representative operating points for a given specific speed. DOE welcomes 

comment on whether the analysis should be extended to a range of operating points away 

from BEP.

Item 7-9: DOE requests comment and estimates to establish the mean value and the ranges of 

likely values for transmission, motor, and motor control efficiencies, as well as the impact of a 

control on motor performance and efficiency.

Energy Use Analysis
120

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
121

Life-Cycle Cost and Payback Period Analysis

 Purpose:

• Assess the net life-cycle cost (LCC) impacts of differing efficiency levels on the 

customer

 Method: 

• LCC equals customer price plus the sum of annual operating costs (including 

repair and maintenance costs) discounted to a particular base year.

• Economic evaluation from the customer perspective

• Results are expressed as LCC difference (baseline minus standard level).

• Payback Period (PBP) is also calculated and reported in this analysis.

Preliminary Analysis
122

Approach

 For each of the representative units in each representative equipment 

class:

• Consider the pump selection process to reflect product choices by customers

- Some customers will not be affected by the standard

• Develop distribution of equipment efficiencies expected for the compliance 

year

• Aggregate the annual energy consumption over a pump’s lifetime 

• Develop probability distributions to characterize operating costs

• Model uncertainty and variability in the inputs using a Monte Carlo simulation 

method and probability distributions

Life-Cycle Cost and Payback Period Analysis
123

Approach

Life-Cycle Cost and Payback Period Analysis
124

Approach

 Installation Costs

• Consist of labor (including overhead) and any miscellaneous materials and 

parts

 Energy Prices

• DOE will survey commercial and industrial energy tariffs as a means of 

establishing marginal electricity prices. 

• DOE will use EIA’s Annual Energy Outlook to estimate future energy prices.

• DOE will also survey reactive power prices.

 Maintenance & Repair Costs

• DOE expects that maintenance and repair costs will not change with 

incremental increases in equipment efficiency, but may change with significant 

improvements in efficiency.

Life-Cycle Cost and Payback Period Analysis
125

Approach

 Equipment Lifetime

• DOE believes that the average pump lifetime is 10-15 years, with a maximum 

of around 25 years.

• Lifetime varies based on whether the clean water pump is immersed in a 

liquid; values of pump head, horsepower, and speed; and temperature of the 

fluid being pumped.

• Smaller, less expensive pumps are treated as “throwaway” pumps.

• Larger pumps are repaired, with the repair cycle repeated for up to the life of 

the plant or building (30-50+ years).

 Discount Rates

• DOE will derive the discount rates for commercial and industrial users by 

estimating the capital costs for companies that purchase pumps.

Life-Cycle Cost and Payback Period Analysis
126

Request for Comment

Item 8-1: DOE welcomes comment on whether installation costs for pumps increase with 

higher efficiency equipment.

Item 8-2: DOE welcomes input on the proposed methodology for estimating current and 

future electricity prices.

Item 8-3: DOE invites comment on how repair costs may change for more efficient pumps. 

Item 8-4: DOE welcomes comment on appropriate pump lifetimes for the equipment classes 

covered in this rulemaking, as well as data regarding correlation between pump end-use 

patterns and pump lifetime.

Item 8-5: DOE requests data on the degradation of pump efficiency over a pump’s lifetime.

Item 8-6: DOE welcomes input on the proposed approaches for estimating discount rates for 

pump customers.

Life-Cycle Cost and Payback Period Analysis
127

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
128

Shipments Analysis

 Purpose:

• Project future shipments by equipment class

 Method: 

• The shipments model will rely on a range of data sources. 

• The model will only consider shipments of covered products.

Preliminary Analysis
129

Approach

 DOE typically projects shipments for a 30-year period beginning in the 

expected compliance date of any standards.

 DOE will characterize the production of pumps.

• Use appropriate growth indices as an indicator of the performance of 

industrial and commercial sectors where pumps are used

• Use private fixed investment data for equipment incorporating pumps from 

the U.S. Department of Commerce’s Bureau of Economic Analysis

 DOE may use different shipments projection in the standards case as 

compared to the base case.

• Shipments may drop as purchase price increases.

Shipments Analysis
130

Request for Comment

Item 9-1: DOE welcomes comment on the shipments projection methodology. 

DOE invites comments regarding the selection of appropriate economic drivers 

and sources of data for historical shipments and shipment breakdowns by 

equipment class.

Item 9-2: DOE requests historical shipments or bookings data for each of the 

considered equipment classes, with further breakdowns where available 

including, but not limited to, flow, head, specific speed, horsepower, or 

efficiency. 

Item 9-3: DOE welcomes comment on how any standard for pumps might 

impact shipments of the equipment in this rulemaking.

Shipments Analysis
131

Preliminary Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Product

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis
132

National Impact Analysis

 Purpose:

• Determine the projected national energy savings (NES) and net present value 

(NPV) of total customer benefits

 Method: 

• Develop annual series of national energy and economic impacts

• Utilize the shipments model to estimate equipment stock each year

• Utilize the LCC to estimate cost and energy use per unit in any year

• Project a trend in efficiency in base case and standards case

• Aggregate the costs and energy use for all years in the analysis period

• Report NES in primary and full fuel cycle (FFC) savings

• Report change in national customer NPV (in constant year dollars)

• Account for the time-value of money though defined discount rates

Preliminary Analysis
133

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analysis
134

Customer Subgroup Analysis

 Purpose:

• Analyze the economic impacts of standards on customers, including subgroups 

who may be disproportionately impacted compared with the general user 

population

 Method: 

• Extend the LCC analysis to examine the impacts for defined subgroups

NOPR Analysis

Request for Comment

Item 11-1: DOE welcomes comment on what, if any, user subgroups 

are appropriate in setting standards for pumps.
135

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analysis
136

Emissions Analysis

 Purpose:

• Estimate environmental impacts from potential energy conservation 

standards for pumps including changes in Full Fuel Cycle (FFC) emissions

 Method: 

• DOE will base the emission factors for FFC on EIA’s Annual Energy Outlook, 

supplemented by data from other sources. 

• The following emissions are assessed: 

− Carbon dioxide (CO2) 

− Sulfur dioxide (SO2) 

− SO2 emissions from affected electric generating units are subject to nationwide and regional 

emissions cap and trading programs

− Nitrogen oxides (NOx) 

− Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern States and DC

− Methane (CH4) 

− Nitrous Oxide (N2O)

− Mercury (Hg)

NOPR Analysis
137

NOPR Analysis

 DOE intends to use the most current Social Cost of Carbon (SCC) values 

developed by interagency reviews.

• SCC is intended to be a monetary measure of the incremental damage 

resulting from greenhouse gas (GHG) emissions, including but not limited to 

agricultural productivity loss, human health effects, property damage from 

rising sea level, and changes in the ecosystem.

 At present, the most recent interagency estimates of the potential 

global benefits resulting from reduced CO2 emissions in 2015, 

expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton 

avoided. 

• For emission reductions that occur in later years, these values grow in real 

terms over time.

 DOE will also estimate the potential monetary benefit of reduced NOx

emissions resulting from the considered standard levels. 

Monetization of Emissions Reductions
138

Emissions Analysis and Monetization of Emission Reductions

Request for Comment

Item 13-1: DOE seeks input on its approach to conducting the 

emissions analysis for commercial and industrial pumps.

Item 14-1: DOE requests comment on the approach it plans to use for 

estimating monetary values associated with emissions reductions.
139

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analysis
140

Utility Impact Analysis

 Purpose:

• Assess the overall impacts on domestic energy supplies that would result from 

the imposition of standards

 Method: 

• DOE proposes to use NEMS-BT, a variant of the NEMS (National Energy 

Modeling System) developed and used by DOE/EIA for their Annual Energy 

Outlook (AEO) report, as the basis of the Utility Impact Analysis.

• Outputs of the utility impact analysis include projections of electricity sales, 

price, and avoided capacity resulting from a comparison of base and standards 

cases.

• DOE will model the energy savings impacts from potential energy 

conservation standards using NEMS-BT to generate projections that deviate 

from the AEO reference case.

NOPR Analysis
141

Utility Impact Analysis

Request for Comment

Item 15-1: DOE welcomes input from interested parties on its 

proposed approach to conduct the utility impact analysis.
142

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analysis
143

Employment Impact Analysis

 Purpose:

• Assess the overall impact on national employment from the imposition of 

efficiency standards at differing levels

• Include both direct and indirect employment impacts

- Direct employment impacts are estimated in the manufacturer impact analysis.

- Indirect employment impacts result from shifting consumer expenditures among 

goods and services ( “substitution effect”) and changing equipment and energy 

costs (“income effect”). 

 Method: 

• DOE intends to use the ImSET (Impact of Sector Energy Technologies) model 

for the evaluation of indirect employment impacts.

NOPR Analysis
144

Employment Impact Analysis

Request for Comment

Item 16-1: DOE welcomes feedback on its proposed approach to 

assessing national employment impacts.
145

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Customer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions

 Analysis and 

Monetization

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR Final

Rule

Effective

Date

NOPR Analysis
146

Regulatory Impact Analysis

 Purpose:

• Explore the potential for non-regulatory alternatives to new energy efficiency 

standards

 Method: 

• Base the assessment on the actual impacts of any such initiatives to date, but 

consider information presented regarding the impacts that any existing 

initiative might have in the future.

NOPR Analysis
147

5 

3 

2 

Test Procedure

Rulemaking Process Overview

Legislative History & Coverage

1 Introduction

6 Rulemaking Analyses

7 Closing Remarks

4 Regulatory Regimes & Metrics

Public Meeting Agenda
148

Instructions for Submitting Written Comments

 In all correspondence, please refer to this Commercial and Industrial Pumps 

Rulemaking by:

• Docket # EERE-2011-BT-STD-0031, and/or RIN 1904-AC54 

 Electronic: Pumps2011STD0031@ee.doe.gov OR www.regulations.gov

 Postal Mail: Ms. Brenda Edwards

 U.S. Department of Energy

 Building Technologies Program, Mailstop EE-2J 

 1000 Independence Avenue, SW. 

 Washington, D.C. 20585-0121 

 Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., 6th Floor

 Phone: (202) 586-2945 

Closing Remarks

Comment period closes May 2, 2013