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 ofthe Framework DocumentforCommercial and Industrial Electric Motors, 75 Fed.Reg. 59657 (September 28, 2010).

To: expartecomm u nications@hg.doe.gov

From: Clark R. Silcox, General Counsel National Electrical ManufacturersAssociation

Date: March 9, 2012

cc: Bill Hoyt, Alex Boesenberg, Rob Boeteler, John Malinowski, Andrew DeLaski, 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 Departmentof Energy (DOE) pursuantto the DOE's Guidance on Ex Parte Communications.

In attendance atthe meetingwere:

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 foran Energy-Efficient Economy Appliance Standards Awareness Project National Electrical Manufacturers Association National Electrical Manufacturers Association National Electrical Manufacturers Association Nidec MotorCompany 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 Departmentof Energy US Departmentof EnergyThe non-governmental participants atthe meeting are part ofan informal group calling itselfThe Motor Coalition that has formed to submitjointviews on a motorefficiency proposal in connection with the proceeding identified above. This coalition has already submitted, on April 19, 2011, jointcomments in response tothe DOE's Request for Information in this proceeding. 76 Fed.Reg. 17577 (March 30, 2011).

The purpose ofthe conversation was to update DOE on the coalition'sviews regarding the best way to increase energy conservation from motors. As expressed previously in thejointcomment, the coalition believes thatfurther incremental increases in efficiency standards on already covered motors are running up against their limits in terms ofeconomicjustification and thatvery substantial opportunities exist forgains 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 acopy ofa presentation that he gave tothe EEMODS 2011 Conference in Alexandria, Virginia last November 2011, acopy of which is attached tothis memorandum.

It is believed thatthe 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 ofwhetherthatwas true for expanding the scope to partial, gear motors,vertical shaft motors, and component sets, and the responses indicated thatthere might need to be some guidance issued for compliance and enforcementtesting purposes so thatthere was clarity and uniformity.Testing these types ofmotors was somethingthat manufacturers and test labs already do. The coalition will provide some further inputto DOE on this issue.

There was also discussion about specific types ofmotorsthat were included and excluded by the proposal. The primary driver behind excluding motorsfrom coverage was the absence ofan applicable test procedure. But there were some motorsthat might be excluded because of unique issues. A question came up aboutthe relationship between 56 frame motors 1HP and greaterand the coverage ofsuch motors underthe Small Electric Motor Rule. The desirability ofharmonizing standards for56 frame size motors with 140frame size motors (which are not covered by the Small Electric Motor rule)
was explained, because they are essentiallythe same motor. Itwas noted thatthe Small Electric Motor rule only covered open construction motors, and the enclosed 56 frame size motorswere not regulated. Coalition members indicated they would supply a list ofincluded and excluded motortypes and discuss the 56 frame size motor issue that might be useful in making acoverage determination.

The coalition also shared a legislative proposal that itwas discussing with Congress, consistent with its priorcommentsto DOE on increasing energy savings by expanding coverage, but also including a provision unrelated tothe pending regulatory proceeding, relating to future energy conservation strategies for electric motors overthe course ofthe decade. This involved advanced motor technologies, and itwas explained thatthe coalition did not have aspecific proposal in mind now. This
was a small partofthe current market, butwas expected to become more significanttoward the end of the decade and from a longer-term strategy point ofviewthe coalition feltthis was the direction DOE oughtto be taking in the future. The coalition also noted acurrent proposal in S.398, now pending in the Senate, that would ask DOE to conduct a motor market assessment study. The lasttime DOE conducted such astudywas in the late 1990s. The coalition felt thatthis study could be valuable in informingthe public and DOE aboutfuture 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

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# 2010-11 Coalition Strategy

D Determine and document a plan to improve the efficiency ofthe greatest number of units providing the 

## greatest savings impact while 

## reducing potential enforcement issues within the 

## least amount oftime. 

## D Deliver a plan to DOE as 

## a platform for a consensus rule that can be acted upon within the 

## leastamount oftime delivering 

## large net benefits.

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# 2 options



# o 1- Increase nominal efficiency level for the existing scope ofcovered motors. 

# o 2- Expand scope of covered motors using existing efficiency levels.

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# 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 ofcovered products to more than double the number of motors regulated 

# o Maintain the nominal efficiency levels atthe current NEMA 12-12 (12-11 for some motors) 

# o Simplify how "coverage" is defined in order to ease compliance and enforcement.

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# 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 orfinished good for both general purpose and the new categories.

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## Me Expanded ProductScope Millions ofunit peryear

Total 4.4 million units USA peryear

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III Partial &

Gearmotor

III Definite &

Special

III Imported

motors or component D56 Frame 

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# Average efficiency gains by motor sizes

DOE 1998 Estimated Kilowatts Table 12- Average Estimated Hours Saved 12 Installed Efficiency Kilowatts Saved peryear @ 4000 Efficiency Efficiency Percent gain per Hour hours ofoperation 1to 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 >20to 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 >200to and including 500 I- 95.8% 93.4% 2.6% 41,595 166,379,547 4,170,307,027

All data at 100% load; powerquality per NEMAstandards; Kwh saved based on 4000 hours Iyearofoperation

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# 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

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# Conclusions



# o Two decades ofcooperative 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.

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