MEMORANDUM 

RE: Ex Parte Communication In Connection with 

DocketNo.EERE-2010-BT-STD-Q027 

Energy Efficiency Program for Certain Commercial and Industrial Equipment: Public Meeting and 

Availability of the Framework Document for Commercial and Industrial Electric Motors, 

75 Fed.Reg. 59657 (September 28, 2010). 

To: expa rtecom m u n icatio ns@hg.doe.gov 

From: Clark R. Silcox, General Counsel 

National Electrical Manufacturers Association 

Date: March 9, 2012 

cc: Bill Hoyt, Alex Boesenberg, Rob Boeteler, John Malinowski, Andrew De Laski, Neil Elliott, Dan 

Delaney, Michael Bruin, Tim Schumann 

The purpose of this memorandum is to memorialize a meeting and conversation on March 7, 2012 at 

the Department of Energy (DOE) pursuant to the DOE's Guidance on Ex Parte Communications. 

In attendance at the meeting were: 

Neil Elliott 

Andrew DeLaski 

Alex Boesenberg 

Bill Hoyt 

Clark Silcox 

Rob Boteler 

John Malinowski 

Dan Delaney 

Paul Lin 

Laura Reamer 

Michael Bruin 

Tim Schumann 

Daniel Cohen 

Amy Grace-Tardy 

Ashley Armstrong 

John Cymbalsky 

Jim Raba 

Michael Kido 

American Council for an Energy-Efficient Economy 

Appliance Standards Awareness Project 

National Electrical Manufacturers Association 

National Electrical Manufacturers Association 

National Electrical Manufacturers Association 

Nidec Motor Company 

Baldor Electric Company (ABB Group) 

Regal-Beloit (by phone) 

Regal-Beloit (by phone) 

Regal-Beloit (by phone) 

General Electric Company (by phone) 

SEW Eurodrive (by phone) 

US Department of Energy 

US Department of Energy 

US Department of Energy 

US Department of Energy 

US Department of Energy 

US Department of Energy 
The non-governmental participants at the meeting are part of an informal group calling itself The Motor 

Coalition that has formed to submit joint views on a motor efficiency proposal in connection with the 

proceeding identified above. This coalition has already submitted, on April 19, 2011, joint comments in 

response to the DOE's Request for Information in this proceeding. 76 Fed.Reg. 17577 (March 30, 2011). 

The purpose of the conversation was to update DOE on the coalition's views regarding the best way to 

increase energy conservation from motors. As expressed previously in the joint comment, the coalition 

believes that further incremental increases in efficiency standards on already covered motors are 

running up against their limits in terms of economic justification and that very substantial opportunities 

exist for gains in energy conservation from expanding the scope of regulated motors so that standards 

could be applied more broadly. Andrew DeLaski began the meeting by sharing a copy of a presentation 

that he gave to the EEMODS 2011 Conference in Alexandria, Virginia last November 2011, a copy of 

which is attached to this memorandum. 

It is believed that the approach outlined will be able to rely on existing EPAct 1992 and EISA 2007 test 

standards, labeling, lab accreditation, and compliance certification requirements. In response to 

questions, there was a discussion of whether that was true for expanding the scope to partial, gear 

motors, vertical shaft motors, and component sets, and the responses indicated that there might need 

to be some guidance issued for compliance and enforcement testing purposes so that there was clarity 

and uniformity. Testing these types of motors was something that manufacturers and test labs already 

do. The coalition will provide some further input to DOE on this issue. 

There was also discussion about specific types of motors that were included and excluded by the 

proposal. The primary driver behind excluding motors from coverage was the absence of an applicable 

test procedure. But there were some motors that might be excluded because of unique issues. A 

question came up about the relationship between 56 frame motors 1HP and greater and the coverage 

of such motors under the Small Electric Motor Rule. The desirability of harmonizing standards for 56 

frame size motors with 140 frame size motors (which are not covered by the Small Electric Motor rule) 

was explained, because they are essentially the same motor. It was noted that the Small Electric Motor 

rule only covered open construction motors, and the enclosed 56 frame size motors were not regulated. 

Coalition members indicated they would supply a list of included and excluded motor types and discuss 

the 56 frame size motor issue that might be useful in making a coverage determination. 

The coalition also shared a legislative proposal that it was discussing with Congress, consistent with its 

prior comments to DOE on increasing energy savings by expanding coverage, but also including a 

provision unrelated to the pending regulatory proceeding, relating to future energy conservation 

strategies for electric motors over the course of the decade. This involved advanced motor 

technologies, and it was explained that the coalition did not have a specific proposal in mind now. This 

was a small part of the current market, but was expected to become more significant toward the end of 

the decade and from a longer-term strategy point of view the coalition felt this was the direction DOE 

ought to be taking in the future. The coalition also noted a current proposal in S.398, now pending in 

the Senate, that would ask DOE to conduct a motor market assessment study. The last time DOE 

conducted such a study was in the late 1990s. The coalition felt that this study could be valuable in 

informing the public and DOE about future energy conservation strategies. 
The Motor Coalition Members 

D American Council for an Energy-Efficient 

Economy 

D Alliance to Save Energy 

D Appliance Standards Awareness Project 

D Earthjustice 

D Natural Resources Defense Council 

D Northeast Energy Efficiency Partnerships 

D Northwest Energy Efficiency Alliance 

D National Electrical Manufactures Association 

D Pacific Gas and Electric 

March 2012 Motors 

2010-11 Coalition Strategy 

D Determine and document a plan to improve 

the efficiency of the greatest number of 

units providing the greatest savings 

impact while reducing potential 

enforcement issues within the least 

amount of time. 

D Deliver a plan to DOE as a platform for a 

consensus rule that can be acted upon 

within the least amount of time 

delivering large net benefits. 

March 2012 Motors 

3/6/2012 

1 
2 options 

o 1- Increase nominal efficiency level 

for the existing scope of covered 

motors. 

o 2- Expand scope of covered motors 

using existing efficiency levels. 

March 2012 Motors 

Motor Coalition Proposed Approach 

o Base future regulations on existing Epact 92 and EISA test standards, labeling, lab 

accreditation, compliance certification 

requirements 

o Expand the scope of covered products to 

more than double the number of motors 

regulated 

o Maintain the nominal efficiency levels at the 

current NEMA 12-12 (12-11 for some 

motors) 

o Simplify how "coverage" is defined in order 

to ease compliance and enforcement. 

March 2012 Motors 

3/6/2012 

2 
Me's Proposed Expanded Scope 

o Partial motors 

o 3.4 motors 

o Gear motors 

o Integral shafts 

o Definite purpose 

o Special shafts 

o Special flanges 

o Special purpose 

o Vertical 

o 56 or 90 Frame motors 

o TENV 

o NEMA or lEe 

More effectively capture motors imported as a component or finished 

good for both general purpose and the new categories. 

March 2012 Motors 

Me Expanded Product Scope 

Millions of unit per year 

Total 4.4 million units USA per year 

March 2012 Motors 

tilllType 1 and 2 

III Partial & 

Gearmotor 

III Definite & 

Special 

III Imported 

motors or 

component 

D56 Frame 

3/6/2012 

3 
Average efficiency gains by 

motor sizes 

DOE 

1998 Estimated Kilowatts 

Table 12- Average Estimated Hours Saved 

12 Installed Efficiency Kilowatts Saved per year @ 4000 

Efficiency Efficiency Percent gain per Hour hours of operati on 

1 to and including 5 HP 89.5% 82.7% 8.2% 205,300 821,199,187 

>5 to and including 20 HP 91.7% 86.8% 5.6% 375,480 1,501,920,413 

>20 to and including 50 HP 94.1% 89.2% 5.5% 244,605 978,421,429 

>50 to and including 100 HF 95.0% 91.9% 3.4% 124,166 496,663,025 

>100 to and including 200 I- 95.4% 92.7% 2.9% 51,431 205,723,427 

>200 to and including 500 I- 95.8% 93.4% 2.6% 41,595 166,379,547 

4,170,307,027 

All data at 100% load; power quality per NEMA standards; Kwh 

saved based on 4000 hours I year of operation 

March 2012 Motors 

Comparing the Two Options 

Savings Potential 

Option 1 

o Two efficiency bands average 1.4% 

increase over current NEMA Premium levels 

o Incremental energy saved calculated to 

be 600 million Kwh using current product 

scope 

Option 2 

o Compared to 4.2 billion Kwh Motor 

Coalition proposal 

o Annual Motor Coalition incremental 

savings 3.6 billion Kwh 

March 2012 Motors 

3/6/2012 

4 
Conclusions 

o Two decades of cooperative 

development of new motor standards 

have delivered large benefits 

o Greatest current opportunity lies in 

expanding scope 

o This approach is supported by a 

broad coalition of motor 

manufacturers and efficiency 

proponents. 

March 2012 Motors 

3/6/2012 

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