1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1

BEFORE THE UNITED STATES DEPARTMENT OF ENERGY PUBLIC MEETING TO ADDRESS RULEMAKING PROCESS FRAMEWORK FOR ELECTRIC MOTOR

ENERGY EFFICIENCY STANDARDS

18 October 2010 Washington, D.C. USA2

1 ATTENDEES: 2 DOUGLAS BROOKMAN Public Solutions, Inc. 3 Moderator 4 EMMANUEL AGAMLOH Motor Systems Engineer 5 Advanced Energy 909 Capability Drive 6 Suite 2100 Raleigh, North Carolina 27606-3870 7 USA PH 919-857-9023 8 FX 919-832-2696 eagamloh@advancedenergy.org 9 KIRK ANDERSON 10 Underwriters Laboratories, Inc. 333 Pfingsten Road 11 Northbrook, Illinois 60062-2096 USA 12 PH 847-664-1888 FX 847-407-1888 13 Kirk.Anderson@us.ul.com 14 JEFF BARTH A.O. Smith Electrical Products Company 15 531 North Fourth Street Tipp City, Ohio 45371 16 USA PH 937-667-2431 17 FX 937-667-5104 jeffbarth@aoscpc.com 18 THOMAS H. BISHOP 19 Senior Technical Support Specialist Electrical Apparatus Service Association, Inc. 20 1331 Baur Boulevard St. Louis, Missouri 63132 21 USA PH 314-993-2220 22 FX 314-993-2998 tbishop@easa.com 23 243 1 ATTENDEES (Continued): 2 AUSTIN H. BONNETT Engineering Consultant 3 Austin Bonnett Engineering, LLC 25341 July Avenue 4 Gallatin, Missouri 64640 USA 5 PH 660-838-4152 FX 660-828-4021 6 CL 660-663-7531 austin.bonnett@emerson.com 7 ROB BOTELER 8 Director of Marketing Nidec Motor Corporation 9 8050 West Florissant Avenue Post Office Box 36912 10 St. Louis, Missouri 63136 USA 11 PH 314-595-8387 FX 314-422-5270 12 CL 314-422-5270 rob.boteler@nidec-motor.com 13 KITT BUTLER 14 Director Motors and Drives 15 Advanced Energy 909 Capability Drive 16 Suite 2100 Raleigh, North Carolina 27606-3870 17 USA PH 919-857-9017 18 FX 919-832-2696 kbutler@advancedenergy.org 19 20 21 22 23 244 1 ATTENDEES (Continued): 2 ROGER H. DAUGHERTY Consulting Engineer 3 Advanced Development Technology Baldor Dodge Reliance 4 6040 Ponders Court Greenville, South Carolina 29615 5 USA PH 864-382-2728 6 FX 864-382-2718 rhdaugherty@baldor.com 7 ANDREW deLASKI 8 Executive Director Appliance Standards Awareness Project 9 20 Belgrade Avenue Suite 1 10 Boston, Massachusetts 02131 USA 11 PH 617-363-9470 FX 617-363-9973 12 adelaski@standardsASAP.org 13 R. NEAL ELLIOTT Associate Director for Research 14 American Council for an Energy-Efficient Economy National Press Building 15 529 Fourteenth Street NW Suite 600 16 Washington, D.C. 20045 USA 17 PH 202-507-4009 FX 202-429-2248 18 CL 202-487-0615 rnelliott@aceee.org 19 JEREMY GORDON 20 Navigant Consulting PH 202-481-8516 21 jeremy.gordon@navigantconsulting.com 22 23 245 1 ATTENDEES (Continued): 2 AMI GRACE-TARDY U.S. Department of Energy 3 CC-71 1000 Independence Avenue SW 4 Washington, DC 20585 USA 5 PH 202-586-5709 Ami.Grace-Tardy@hq.doe.gov 6 MAHIMA "MIMI" GUPTA 7 Associate Director Navigant Consulting 8 PH 202-481-7508 9 DOUGLAS HOFMANN Engineering Leader, Growth Industrial 10 GE Energy 107 Park Street North 11 Peterborough, ON K9J 785 Canada 12 PH +1 705-7487428 FX +1 705-761-3701 13 doug.hofmann@ge.com 14 WILLIAM HOYT Industry Director 15 National Electrical Manufacturers Association 1300 North Seventeenth Street 16 Suite 1752 Rosslyn, Virginia 22209 17 USA PH 703-841-3211 18 FX 703-841-3311 CL 703-678-9565 19 wil_hoyt@nema.org 20 21 22 23 246 1 ATTENDEES (Continued): 2 SANAEE IYAMA Program Manager 3 Energy Analysis Department Environmental Energy Technologies Division 4 Lawrence Berkeley National Laboratory One Cyclotron Road 5 MS 90R4000 Berkeley, California 94720-8136 6 USA PH 510-486-6604 7 FX 510-486-6996 ssiyama@lbl.gov 8 FRANK LADONNE 9 Principal Engineer Underwriters Laboratories, Inc. 10 333 Pfingsten Road Northbrook, Illinois 60062-2096 11 USA PH 847-664-1888 12 FX 847-407-1888 Francis.G.Ladonne@us.ul.com 13 JOHN MALINOWSKI 14 Senior Product Manager AC Motors Baldor Electric Company 15 5711 R.S. Boreham Jr. Street Fort Smith, Arkansas 72901 16 USA PH 479-648-5909 17 FX 479-648-5792 FL 479-459-5909 18 jmalinowski@baldor.com 19 20 21 22 23 247 1 ATTENDEES (Continued): 2 JUSTIN NEUMANN Manager 3 Government Relations The Association of Electrical and Medical Imaging 4 Equipment Manufacturers 1300 North Seventeenth Street 5 Suite 1752 Rosslyn, Virginia 22209 6 USA PH 703-841-3221 7 FX 703-841-3321 justin.neumann@nema.org 8 JAMES RABA 9 U.S. Department of Energy 1000 Independence Avenue SW 10 Washington, DC 20585 PH 202-586-8654 11 FX 202-586-4617 Jim.Raba@ee.doe.gov 12 GREGORY ROSENQUIST 13 Lawrence Berkeley National Laboratory MS 90-4000 14 Berkeley, California 94720 USA 15 PH 510-486-6851 FX 510-486-6996 16 gtrosenquist@lbl.gov 17 TIM SCHUMANN Corporate Engineering 18 Industry Account Manager Corporate Offices 19 SEW-Eurodrive, Inc. 1295 Old Spartanburg Highway 20 Post Office Box 518 Lyman, South Carolina 29365 21 USA PH 864-439-7537 22 DR 864-661-1262 FX 864-661-1276 23 tschumann@seweurodrive.com 248 1 ATTENDEES (Continued): 2 CHARLIE STEPHENS Senior Energy Codes and Standards Engineer 3 Northwest Energy Efficiency Alliance 529 SW Third Avenue 4 Suite 600 Portland, Oregon 97204 5 USA PH 503-827-8416 x 289 6 FX 503-827-8437 cstephens@nwalliance.org 7 ZOLAIKHA STRONG 8 Director Sustainable Electrical Energy 9 Copper Development Association P. O. Box 4622 10 Alexandria, Virginia 22303 USA 11 PH 202-558-7625 212-251-7238 12 CL 202-674-9838 FX 202-380-9085 13 zstrong@cda.copper.org 14 DANIEL TROMBLEY Industrial Engineering Associate 15 American Council for an Energy-Efficient Economy American Council for an Energy-Efficient Economy 16 National Press Building 529 Fourteenth Street NW 17 Suite 600 Washington, D.C. 20045 18 USA PH 202-507-4008 19 FX 202-429-2248 dtrombley@aceee.org 20 21 22 23 249 1 ATTENDEES (Continued): 2 MOLLY TROMBLEY-McCANN Project Manager 3 Energy Solutions 1610 Harrison Street 4 Oakland, California 94612 USA 5 PH 510-482-4420 x 239 FX 510-482-4421 6 mmccann@energy-solution.com 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 241 0

1 I N D E X Page 2 WELCOME 3 By Jim Raba 11 By Doug Brookman 12 4 INTRODUCTIONS AND AGENDA REVIEW 5 By Doug Brookman 12 6 BRIEF OPENING REMARKS FROM INTERESTED PARTIES By E. Neal Elliott 17 7 REGULATORY HISTORY 8 By Jeremy Gordon 22 9 RULEMAKING OVERVIEW AND SCOPE OF COVERAGE By Jeremy Gordon 39 10 MARKET AND TECHNOLOGY ASSESSMENT AND SCREENING 11 ANALYSIS By Jeremy Gordon 69 12 ENGINEERING ANALYSIS 13 By Jeremy Gordon 121 14 ENERGY USE ANALYSIS By Sanaee Iyama 175 15 MARKUPS FOR EQUIPMENT PRICE DETERMINATION 16 By Sanaee Iyama 182 17 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS By Sanaee Iyama 191 18 SHIPMENTS ANALYSIS, NATIONAL IMPACTS ANALYSIS, AND 19 LIFE-CYCLE COST SUBGROUP ANALYSIS By Sanaee Iyama 206 20 MANUFACTURER IMPACT ANALYSIS 21 By Jeremy Gordon 220 22 23 241 1

1 I N D E X (Continued) 2 UTILITY IMPACT ANALYSIS, EMPLOYMENT IMPACT 3 ANALYSIS, ENVIRONMENTAL ASSESSMENT, AND REGULATORY IMPACT ANALYSIS 4 By Sanaee Iyama 226 5 OTHER ISSUES AND COMMENTS By Doug Brookman 238 6 CLOSING REMARKS 7 By Doug Brookman 240 By Jim Raba 241 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 241 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 2

BEFORE THE UNITED STATES DEPARTMENT OF ENERGY PUBLIC MEETING TO ADDRESS RULEMAKING PROCESS FRAMEWORK FOR ELECTRIC MOTOR

ENERGY EFFICIENCY STANDARDS

TRANSCRIPT OF PROCEEDINGS MR. RABA: Good morning. Welcome. I'm Jim Raba, Project Manager for Electric Motors. Today U.S. Department of Energy is initiating a rulemaking to amend the Energy Conservation Standards for commercial and industrial electric motors under Section 342(b) of the Energy Policy and Conservation Act. Now, today's informal public meeting begins the rulemaking process. DOE will present the proposed approach to the data gathering, analyses, and methodologies it will use during the rulemaking process. This public meeting will provide an opportunity for questions and comments and discussion from those present, in addition, throughout the rulemaking process DOE will invite written comments, information, and data from all1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 3 interested parties. Throughout today's presentations you'll see a, an issue box, if you will, question boxes, comment box. We can stop, pause, and, and take any questions, comments, concerned statements of information gathered on the, on the presentation at that point. Also note that the rulemaking comment period for the framework rulemaking, this, is closed October twenty-eighth. So, we invite written comments. And there are three possible means to submit them. You can send them by e-mail, postal mail, or by courier. Once again, welcome. We look forward to hearing from you. And I'll turn this over to Doug Brookman, our facilitator. MR. BROOKMAN: Thank you, Jim. Good morning, everybody. Welcome. Glad you could join us. It's our tradition to do introductions around the room. If you'll say your name, and you might1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 4 as well get in the habit of pushing the microphone

on and seeing that the little green LED button is lit. Please. (Whereupon, at 9:03 a.m. ET, general introductions were had, after which the following occurred:) MR. BROOKMAN: Thank you. Again, thanks for joining us first thing this morning to get an early start on this day. We also have individuals joining us via webinar, so thanks to all of you joining us via the web. All of you received a packet this morning as you registered. We'll launch into the content for the day. Immediately following this Agenda review there's an opportunity for brief opening remarks, summary remarks, summarized remarks, short summary remarks here at the outset. And following that we'll go get a, a regulatory history overview. And then moving straight on, rulemaking overview and scope of coverage. We'll take a break1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 5 midmorning, right about 10:15 or 10:30 or so, and

immediately following the break, market and technology assessment and screening analysis, engineering analysis. We'll break for lunch around about noonish. When we return from lunch, energy use analysis, markups for equipment price determination, life-cycle cost and payback period analysis, and shipments analysis, national impacts analysis, and life-cycle cost subgroup analysis. We'll break mid-afternoon, probably 2:30ish, -30ish or so. Manufacturer impact analysis, utility impact analysis, employment impact analysis, environmental assessment, and regulatory impact analysis. And at the end of the day, around about 3:00 o'clock or so, whenever we get there, there's yet another opportunity for anybody that wishes to do so to comment, to raise any additional issues, to discuss things that haven't been covered fully from your perspective. And then we'll have closing remarks. So, that's the plan for today.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 6 Questions or comments on the Agenda?

(Whereupon, at 9:07 a.m. ET, no response was had.) MR. BROOKMAN: Jim already referenced this colorful packet of PowerPoint slides. You -- He also mentioned that there is a dedicated comment box. The Department is specifically seeking your comments on those issues. They'll be flashed up on the screen for your consideration. Finally I'd ask for your considerations, what have emerged as courtesies during the span of these public meetings. Please speak one at a time. Please say your name for the Record every time you speak. If you're in the habit of saying your affiliation, fine, but you don't need to do that every time; just your name. Also, we received -- Each person here registered as they came in the door. The Department typically will create a Xerox copy of all the business cards that were handed in so everybody will have a record of each person that's shown up here today.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 7 I'm going to be calling people, individuals by name as best I can. I also wish to encourage follow-on comments. Sometimes the back-and-forth between individuals is very helpful to the Department as it weighs these issue. If you could, keep the focus here. Please turn your cell phones on silent mode and limit the sidebar conversations. These microphones do pretty well. They do pretty well at two or three feet, even. And if you could, be concise. Share the air time. There's a lot to be said, a lot of information to be covered during the span of the day. So, that's the overview. Questions and comments before we proceed? And, once again, welcome to those via webinar. The Department is trying hard to provide access to, via, via the web. So, the next item on the agenda, as I promised, is an opportunity for individuals to make opening summary remarks. So, let's, let's do that.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 8 Who would like the start? Yes, please. Neal. DR. ELLIOTT: Thank you. Thank you very much. Appreciate the opportunity. MR. BROOKMAN: Is it on? DR. ELLIOTT: It was. There we go. Thank you for the opportunity. I'm here to speak on behalf of the American Council for an Energy Efficient Economy, for the Appliance Standards Awareness, Project, and National Electric Manufacturers Association. I've had a, been involved, I was commented on my way in this morning, been involved in these proceedings now for over 20 years, so it's a lot of old friends, familiar faces out there in the audience. We've been through this twice before. We view the opportunities continue to exist for greater efficiency by raising the efficiency levels of some motors, and expanding coverage for the covered, for the motors as defined under the EPCA provision here on the levels Table 12-12. We think there's, continues to be1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 9 significant opportunities for increased efficiency

from moving those levels up to that and expanding coverage. The other issue I think that's an important issue as we look to expand coverage is this will greatly simplify the compliance aspects of the proceedings. One of the concerns that many of us have has been that the complexity and ambiguity in the existing Regulations have made compliance difficult. We feel that expanding the product definition so that they cover the vast majority of the 1- to 500-horsepower integral horsepower polyphase motor and corresponding electric motors will enhance compliance so that we're focused on the motors that are excluded, not the motors that are included. We, however, encourage DOE to approach this, the direction of its rulemaking very carefully. Currently, most of the manufacturers who manufacture in the United States produce motors that meet the 12-12 levels in most of these categories, or are in a position to do so.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 0 We think that moving forward with a Standard in a consensus manner presents an opportunity to move these Standards into effect much more rapidly than would be undertaken by regular rulemaking; that this could be in the order of 18 to 24 months in terms of the compliance date. And, we see this as an important opportunity, because with electric motors lasting 25 years in the marketplace, every year that Standards do not go into place represents a lost opportunity. On the other hand, we think it's, the motor marketplace is one of the most complex marketplaces for covered products that the Department has sought to regulate in the past, and so we think that the Department should approach this with great deal of caution. We need to have good information about how decisions are made in the marketplace and the products that are manufactured in the marketplace. And this raises an important issue. We do not have data sufficient to really make a lot of these assessments in the marketplace.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 1 The last comprehensive survey of electric motor use

and sales was prepared by the Department in 1998, and has not been updated since then. In addition, the Census Bureau discontinued collection of market data and imports on manufactured motor shipments in 2003, and without accurate and up-to-date information on the marketplace and installed base of electric motors, the Department and others, such as and the energy efficiency programs cannot accurately determine the best course of action when raising these Standards. We have advocated in the past for collecting this data. There is pending federal legislation that calls for the motor market study to be updated, and an ongoing process to be initiated to maintain the currency of this information. NEMA and the Appliance Standards Awareness Project have initiated some discussions including organizations such as, exploring the possibility of consensus agreement on this Standard. In general, we are in agreement on the following principles for the further expansion of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 2 minimum efficiency performance Standards beyond

those required in the Energy Independence and Security Act of 2007. The principles are, first, the vast majority of polyphase integral horsepower between 1 and 500 horsepower, and their metric should be covered by minimum number efficiency performance Standards at the MG 1 Table 12-12 efficiency level. The second, the scope of products not covered by the MEPS should be limited to specifically design, design, with, defined exceptions. Expanding the scope -- Three, expanding the scope of progress, products covered by MEPS will simplify the enforcement of MDPS for electric motors by federal agencies and in the marketplace. Four, the expansion of coverage and move beyond MG-1 Table 12-12 efficiency, or to, MG-1 Table 12-12 efficiency levels is in the best interest of consumers, manufacturers, and the economy. And fifth and finally, that the MG-1 12-12 efficiency levels and expanded scope of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 3 coverage should go into effect as soon as feasible. When these discussions produce an Agreement, we believe that expanding the scope within the scope of the principles is the best path forward for obtaining the most energy-efficient savings as soon as possible with reasonable costs to manufacturers and minimum disruptions in the marketplace. Thank you very much. MR. BROOKMAN: Thank you. Other comments here at the outset? (Whereupon, no response was had.) MR. BROOKMAN: No additional comments. Okay. So, then let's launch right straight into the content. All of you have this material in your packet. First we're going to hear from Jeremy Gordon. REGULATORY HISTORY MR. GORDON: This is on, right? Thank you, Doug. My name is Jeremy Gordon. I'm from1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 4 Navigant Consulting. This is -- Thank you. This is my first public meeting, so I'm excited. So, I'll start with the regulatory history. So, as many of you know, the Energy Policy and Conservation Act, or EPCA, gave DOE authority to regulate the energy efficiency of several types of equipment. The Energy Policy Act of 1992, or EPACT, established energy cons-, energy conservation standards for electric motors. Then the Energy Independence and Security Act of 2007, or EISA, expanded coverage for electric motors, and set higher standards for those motors that had previously been regulated. Today DOE kicks off a rulemaking process to amend these Standards. Per EPCA, DOE should publish a Final Rule on these Standards by December nineteenth, 2012, and the Standards would go into effect on December nineteenth, 2015. While they've given -- A SPECTATOR: Would you advance the slides? All right.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 5

MR. BROOKMAN: All set?

MR. GORDON: Yeah. All right. While, I've given a brief overview of the Standards rulemaking, I would also like to quickly touch on test procedures for electric motors. In October of 1999, DOE published a final Rule for test procedures that specified test, test methods to be used, and means to establish compliance, including the use of AEDMs. In December of 2008, DOE published a NOPR test procedure that up-, updated definitions of terms and citations to Standards incorporated by reference. DOE is currently developing an SNOPR that will further update definitions and materials incorporated by reference. These may include test procedures and definitions from IEEE, CSA, NEMA, and IEAC. DOE is also considering updated definitions of key terms and citations to industry standards, clarifying the definitions of general-purpose electric motors Subtype 1, NEMA1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 6 Design B electric motor, and fire pump motor. MR. BROOKMAN: Do you wish to comment now, Roger? DR. DAUGHERTY: Yes. MR. BROOKMAN: Please use the microphone. Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. MR. BROOKMAN: Yes. DR. DAUGHERTY: I'd like to address your comment about requesting some information with regards to your proposed definitions. The date of compliance under EISA is two months away. DOE issued a NOPR in 2008 proposing the definitions, for which we've not received a Final Rule on those definitions. Within those definitions, if you examine the present ones, we really don't have a working definition. All we have is a definition of a Subtype 1 that says that the motor shall be general-purpose. Then we have a definition of Subtype 2. What we can tell, as manufacturers, from those two definitions is that by examining Subtype1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 7 2 we see that things like Subtype 2 says that if

the motor is a U-frame, it's Subtype 2. That only tells us that over in Subtype 1 there must be some other frame designation that falls in Subtype 1. Subtype 2 tells us that it covers a Design C. Therefore, somewhere over in Subtype 1 there must be some other design types that are covered. But, we don't expect that all those design types are covered. If we look at voltage under Subtype 2 it says that it covers all voltages up to 600 volts except 230/460. Now, in the Final Rule that was issued back in 1999, and leading up to that Final Rule, there was a lot of discussion that went on as to what was meant by 230/460 volts. And DOE adopted a definition in electric motor that it was not only 230/460 volts, but it was also those motors that could be used on 230/460. But, right now the definition we have proposed would take a motor that's rated at 210, 220, 245, 440 volts, and move that into Subtype 2, because the only ones that appear to be over in1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 8 Subtype 1 are 230 and 460. Another example is that throughout the framework document I encounter the phrase "polyphase" in referring to the motor. I can't find that anywhere in any of the definitions that, that DOE has proposed in that 2008 NOPR, nor within this framework document. I also find reference to 60 Hertz, and I find a sentence that says that 50 Hertz are not covered. But, I can't find any information in the definitions that provide me that guidance as a manufacturer. The only other piece of information that I have available, as a manufacturer, to determine compliance two months from now is Appendix A to Subpart B, where DOE tried to provide guidance as to what was meant by "general purpose" under the DOE's definition of "general purpose." So, my point is that we don't have a lot of time to wait to see a, definitions coming out. We need those definitions. Compliance is coming up, and you're entering into a framework document and wanting to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 9 establish efficiency levels without having provided

a clear definition of what it is that you're going to put into different subtypes. MR. BROOKMAN: Roger, did you or NEMA submit your suggestions to the Department on how these definitions should be parsed? DR. DAUGHERTY: Roger Daugherty. Yes. We attended the public meeting on, on the NOPR. That was on January twenty-ninth, 2009. Comments are in the Transcript. NEMA submitted written comments, and other manufacturers may have submitted individual comments -- MR. BROOKMAN: Thank you. DR. DAUGHERTY: -- and covered this. MR. BROOKMAN: Thank you. I just wanted to make sure we covered this. DR. DAUGHERTY: With that item, yes. MR. BROOKMAN: Yes. Okay, thank you. Then do you wish to proceed, or respond? MR. GORDON: I can respond. I understand your concerns, and we will1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 0 definitely take those into consideration. I'm

hoping that when I touch upon the scope later on in this presentation, that that may clarify some of the concerns that you have. And if not, then moving forward we definitely will take into consideration those

concerns. MR. BROOKMAN: Do you want -- Do you want to comment again, Roger Daugherty? DR. DAUGHERTY: Roger Daugherty. I'd also like to comment on your question about test procedures. The -- We, we do know the CSA C-390 was updated in 2007. We don't have any indication whether the Department is going to be moving to that, that version of CSA C-390. We do know that that is not in, would not then be in agreement with IEEE-112, and, and we would just wonder how the Department's going to handle that, since they have normally referred to IEC-, the IEEE Standard, adopting it as being an equivalent test Standard. The other is that within the framework document you refer to NVLAP contrasting of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 1 efficiency of electric motors. You've noted that

that has been updated, but you also contain a statement that the recent version is not applicable until the Department makes a determination to adopt that updated version. And I, I guess, as manufacturers, we would like to know where that stands. Has the Department adopted a new version that didn't have that Standard? (Whereupon, at 9:24 a.m. ET, Mr. Raba and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. BROOKMAN: So, noting that this is test procedures and not Standards, I don't know how prepared anybody is to comment on that today. MR. GORDON: Yeah. MR. BROOKMAN: Let's wait for Jim, unless we wish to venture forth. Jim, I don't know. Is the Department prepared to talk on, about test procedures? MR. RABA: I say -- This is Jim Raba. Good comments. These are concerns as1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 2 well as the Department that Roger has raised. I

note that these are addressed in the Supplementary NOPR rule-making. It's been difficult to address all the comments that came in back from January, 2009, but, yes, you'll see that the definitions, the test procedures, the NAVLAP Handbook will all be addressed per public comment, again, as a Supplementary Notice of Proposed Rulemaking. And I think at that time we can get more specific on what we're presenting, proposals and comments back from interested parties, as well. So, we've heard your concerns; certainly ones back in January, 2009, and we're doing our best to address them. We note that as time goes by, unfortunately, -- It is getting close to December nineteenth, 2010. -- that also we've had to update many things that happened since then: IEEE, CSA, and other test procedures. NEMA Standards have been updated, too. And so in our process, we try to keep pace in some fashion with what's actually happening in the real world.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 3 So, at this point I think we've seen a point where things have settled down. We can present our in a timely fashion. So, it's under review. It should be out relatively soon. MR. BROOKMAN: Okay. Thank you. Roger, go ahead DR. DAUGHERTY: Roger Daugherty. Jim, please, with respect to your reference to the SNOPR that's coming out, I note that in the framework document, in Clause 1.3.1, there's the comment, and I quote: As described in Section 1.2, DOE is currently developing an SNOPR primarily focused on updating various definitions and incorporations by reference related to the current test procedure. Until those updates are finalized, manufacturers are required to determine compliance using test procedures. Close quote. But, but within that stated comment, you also referred to those definitions. Is it the intent that until a Final Rule comes out, that for the, for definition of "compliance" come December,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 4 that the manufacturers are to follow the present

determination of "compliance" for covered products? Thank you. MR. BROOKMAN: Ami. MS. GRACE-TARDY: Yeah, that is -- Ami Grace-Tardy, General Counsel's Office. That's correct. What's actually the law and what's in the Regs now is what we have on the books, and unless we change the Regulations, manufacturers are to comply with what's in the current Regulations. MR. BROOKMAN: Roger. DR. DAUGHERTY: Roger Daugherty. One problem we have, that, as manufacturers, is the En Masse technical correction that was made to Part 431. That wiped out the definition of "electric motor" that we are presently compliant of. So, if, if anyone goes back and looks in Part 431, they won't find the definitions of "electric motor" under which the present compliance Rules apply and to which this paragraph seems to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 5 say would be the continuing Rules until a final,

another Final Rule comes out. So, what's a manufacturer to do? But, he, he doesn't have a document that contains the definition that will now still be in effect after December that he's presently complying under. (Whereupon, at 9:28 a.m. ET, Mr. Raba and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, after which the following occurred:) MR. BROOKMAN: Ami. MS. GRACE-TARDY: Jim says he doesn't want to answer that question, so I'll answer. Well, I think what a lot of people in this room have been doing, which I think is the right thing to do, we understand that there's confusion, and the Department's doing its best to address that in a timely manner. DOE realizes we have this December nineteenth deadline, and we understand the pressure that the manufacturers are under. We do recommend that you consult with the Department as questions arise as need be.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 6 I know a lot of the people have been doing that, and we've been doing our best to get back to those individual questions. Thank you. MR. RABA: Jim Raba, Department of Energy. I'd also say that from what I can see at this time, we are trying to recover those specifics, the older Regulations, as best we can within our scope of our framework of what we can do either in the document, SNOPR, what we can do in a rulemaking process. So, we're looking to recover some of those specificities that are lacking now. MR. BROOKMAN: Okay. That, that was helpful. Thank you. Then, yes, please. MR. MALINOWSKI: John Malinowski, Baldor Electric. Department of Energy has received -- Excuse me. The Department of Energy has received a letter from the Senator Bingaman's office. I think there's been a dialogue back and forth on technical corrections that, that we need1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 7

clarified. Jim, you know about this. This is from

the -- DR. ELLIOTT: Energy and Natural Resources Committee. MR. MALINOWSKI: -- Energy and -- MR. RABA: Jim Raba. Drawing a blank right now, John. Sorry. MR. BROOKMAN: Could you be more specific what the concern would be about those technical corrections? MR. MALINOWSKI: It basically -- Neal

can -- DR. ELLIOTT: Neal Elliott, ACEEE. Immediately following the passage of the EISA Bill in 2007, -- MR. BROOKMAN: We're familiar with the form. DR. ELLIOTT: -- there was an awareness that there were errors that were made. And the Department has issued, or the Committee has drafted technical corrections approximately 18 months ago. MR. BROOKMAN: Okay. Jim.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 8

DR. ELLIOTT: And there's been recent correspondence from the Committee to the Department. MR. RABA: Jim Raba. Thank you for refreshing my memory here. Thursday was a long time ago. The Department and General Counsel, with General Counsel, the Project Office pre-MUPS had discussed those -- MR. BROOKMAN: Technical correction. MR. RABA: -- technical corrections from Senator Bingaman's office. And as I understand, the Department went back, I think on Friday, to address them back on the Hill. So, I don't know what happened after that. All I know is we got the comments in, we had discussions about that, and they were presented back to the Hill staff last Friday. MR. BROOKMAN: Okay. MR. RABA: So, we're aware of that and we're working on that, too. It's in the workbook. MR. BROOKMAN: And that's a part of it, your consideration.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 9 MR. RABA: Oh, yes.

MR. BROOKMAN: Okay. That's what they wanted to hear. MR. RABA: I think, dare I say it, maybe things are in harmony, perhaps. MR. BROOKMAN: Okay, that's also helpful. Neal, you're shaking your head. DR. ELLIOTT: No, I'm just -- MR. BROOKMAN: You're hoping for the best. DR. ELLIOTT: I'm hoping for the best. MR. RABA: Note that. MR. BROOKMAN: Okay. So, this opening round I think has been helpful, and I especially appreciate that the commenters are being specific about the kinds of things they would like to see addressed. I think that's helpful to the Department. I'd like for that to continue, so let's proceed with the presentation. MR. GORDON: All right. So, next up I'd like to give a brief overview of the rulemaking1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 0 process and the steps that DOE will take.

RULEMAKING OVERVIEW AND SCOPE OF COVERAGE: MR. GORDON: EPCA directs DOE to consider the following seven factors when setting energy conservation Standards. These include: Economic impact on manufacturers and consumers; projected energy savings; impact on utility or performance; and impact on competition. DOE performs several analyses that address these factors. We'll discuss each one of those today. Here is a timeline of the schedule that DOE plans to follow for this rulemaking. The preliminary analysis public meeting is scheduled to occur sometime next fall, with the NOPR public meeting happening the following summer. This all leads up to the publication of the Final Rule in December of 2012. At the end of each of these three stages shown there's an opportunity for public comment through these meetings and through written comments. So, as mentioned before, today's meeting covers the framework document for electric motors.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 1 It's located at the link given here, given in your

handout, as well, and comments are to be submitted by October twenty-eighth. This slide maps out the different analyses DOE conducts in the prelim-, preliminary analysis stage. Today we'll be discussing each one of these different analyses, so I'll discuss the market and technology assessment, the screening analysis, and the engineering analysis, and LBNL will cover the remaining topics, which include energy analysis, life-cycle cost, shipment analysis, and national impact analysis. There are also several NOPR analyses that DOE conducts, including a life-cycle cost subgroup analysis, manufacturer, utility and employment impact analyses, and Environmental Assessment, and finally, regulatory impact analysis. And we'll touch upon each of these as well today. And then in preparing for the Final Rule, DOE will revise its NOPR analyses. Next up on the agenda is the scope of coverage. EISA established definitions for1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 2 general-purpose electric motors Subtype 1 and

Subtype 2. A general-purpose electric motor Subtype 1 means any motor that meets the definition of "general purpose" as is currently defined in the Code of Federal Regulations. A general-purpose electric motor Subtype 2 is one that incorporates the design element of a general-purpose Subtype 1, but has at least one of the seven listed characteristics. These include U-frame, Design C, closed-coupled pump motor, footless, vertical solid shaft, eight-pole, poly-phase with voltage less than 600 volts, as well as the motors with other than 230 or 460 volts. In 2009, DOE codified a definition of Subtype 1 to mean a motor that is designed in standard ratings and standard operating characteristics and that can either be used under usual service conditions without restriction to a particular type of application, or unusual service conditions but can be used in most general-purpose applications. This tree shows the breakdown of the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 3 four categories of, of motors in this rulemaking,

and the characteristics that fall into each category. When EISA comes into effect in December, Subtype 1 will have to meet NEMA Premium standards for a motor from 1 to 200 horsepower, and fire pump motors will have to meet EPACT levels. When I say EPACT levels, it means those efficiency standards instituted by EPACT' 92 and NEMA premium standards are those established in MG1. MR. BROOKMAN: Yes. Let's pause right there. Let's -- I like that diagram. I think that's useful. Roger. DR. DAUGHERTY: Roger Daugherty. Going along with that diagram, back in the NOPR in 2008, there was an additional definition that DOE proposed. That was a basic definition of an "electric motor," that an electric motor was a motor that was one of four classifications, those four, the four that are in the top of your chart.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 4 Within -- To explain those four classifications, DOE proposed definitions for all four of those classifications. Comments were made at the public meeting in January, 2009, and in NEMA written comments. But, that creates a, that creates a problem that we see in the way you've made your definitions, and I'd just like to reiterate a couple of those points. One is with regards to the NEMA Design B. You propose a specific definition of NEMA Design B which was not in EISA of 2007. In proposing that definition and making that as one of the classes of electric motors, you separated all NEMA Design B motors away from any of the other three classes. As, as a result, your chart, which is showing NEMA Design B under Subtype 1, is not in agreement with your proposed definitions. Now, we, we had -- NEMA had commented, and at the public meeting, that we saw no need for a definition of NEMA Design B. NEMA Design B was also referred to in1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 5

the definition of "electric motor" that was in the

Final Rule of 1999, as well as Design A. There had been no need to define Design A and Design B at that time, and there's no need now and create this problem of a definition that moves that whole group out into its own category and has the consequence that you're saying that the only Standards that DOE saw developed with NEMA Design B were for above 200 horsepower, up to 500, and that there were no Standards established for 1 to 200. And we see that as a significant problem. And, and we -- So, we encourage that you don't create a definition for NEMA Design B; you just accept it the way you accepted it before. MR. BROOKMAN: They should be included under Subtype 1. Is that correct? DR. ELLIOTT: No. No. DR. DAUGHERTY: They, they -- NEMA Design B motors are a subset of Subtype 1. Then, within -- It's our interpretation that what EISA did was then say that of that grouping -- That's 1 to 200 horsepower under Subtype 1. -- it raised the efficiency levels up to NEMA Premium, and then1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 6 it added for above 200 up to 500, efficiency levels

that are, we call "energy efficient," or, or so-called EPACT levels. All that can be done under Subtype 1. It's not necessary, in our opinion, to develop a definition for Design B, because it creates this conflict between: When's a motor a NEMA Design B, in that class? When is it in Subtype 1 Class? And you, you've got different efficiency levels for those two classes. MR. BROOKMAN: Okay. DR. DAUGHERTY: The other one is definition of fire pump motor. MR. BROOKMAN: Why don't you pause that, because we have another commenter, Andrew deLaski. MR. deLASKI: Just one. Can I ask the Department? We do have Design B motors that are sort of falling into two buckets here. So, what was the purpose of, in creating a separate definition for Design B in that third bucket when you already had them in Bucket 1?1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 7 MR. RABA: Jim Raba, Department of Energy. From what I'm seeing in the wiring diagram here, these are the categories that we're looking at. These are based on Section 431.25 of the Standards. The Standards under EISA 2010 parse out Subtype 1, fire pump, Subtype 2, and Design B. MR. DeLASKI: So, Jim, thus you just, to follow up, -- This is Andrew. -- one's the Standard's different; one is NEMA; one's the EPACT '92 levels; and one's the premium levels. So, is that the reason that you separated it out? MR. RABA: Well, that may be part of it, but I see also here that if Subtype 1s go from 1 to 200, the Design Bs are 250 to 500. MR. DeLASKI: Right. Right. So, even though they're both Design B, they have different Standards? MR. BROOKMAN: Let's let Neal follow on, and coming back to you, Roger.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 8 DR. ELLIOTT: Couple of clarifications here, and responding to -- Neal Elliott, ACEEE. My understanding is that technically a NEMA Design B 201- to 500-horsepower should be considered to be a Type 2 motor, and therefore at the NEMA 12-11 efficiency, and that it is the Type 1 under EISA that is at the NEMA 12-12 level. One clarification here to avoid ambiguity. I think it would be better for us to refer to existing NEMA efficiency levels rather than the term "EPACT" or "NEMA Premium." The -- There is no EPACT definition for motors above 200 horsepower, and the Statute actually calls for that to be at the NEMA 12-11 level, which is the energy-efficient level. So, I think we just need to be a little precise here. There is also the issue that the term "NEMA Premium" is a marketing term that is used by NEMA. The technical definition, as specified by Statute, is "NEMA 12-12." So, I think we need to be a little careful in our definitions there as we use these1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 9

terms. MR. BROOKMAN: Roger, do you want to

follow on? DR. DAUGHERTY: Question. Roger Daugherty. I guess I'd like to address both of the comments that you've just heard. My comments were not with regards to the Standards section of EISA. My comments were with regards to the definitions that DOE was creating from the definitions that were in EISA. So, my, my, my, my basic concern was that by having created a definition of NEMA Design B, and proposing a definition that an electric motor was separated into four different classes, with NEMA Design B being a specific class separate from Subtype 1, Subtype 2, and fire pump, has the consequence that then when you go to the Standards, the only Standard that was created for NEMA Design B specific was for above 200- to 500-horsepower. However, if you take the interpretation that, that Congress did not define NEMA Design B as a separate class of motors; that a NEMA Design B,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 0 as it is today, would fall under Subtype 1, then

what Congress did in the -- (Whereupon, at 9:45 a.m. ET, Mr. Raba and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, during which the following occurred:) DR. DAUGHERTY: -- in the Standards area was to go within Subtype 1, all motors from 1 to 200 horsepower would have the efficiency raised from Table 12-11 up to Table 12-12; then said: "In addition, we will take the NEMA Design B sub-, subset of the Subtype 1s rated above 200- to 500-horsepower, and establish efficiency levels of those to Table 12-11." Then it all makes sense. You don't need -- You don't create a separate class. You don't create one confusion, and the Standards fall right into place with the way it's written in the law. MR. BROOKMAN: So, Roger, let me ask you, before I -- Are you speaking on behalf of NEMA, or your company? AN UNIDENTIFIED PARTICIPANT: Yes.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 1

AN UNIDENTIFIED PARTICIPANT: Yes.

DR. DAUGHERTY: I hear agreement. Roger Daugherty. I hear agreement on speaking on behalf of NEMA. I am the Chairman of the Technical Committee of NEMA. MR. BROOKMAN: So, I want to reflect back. Neal, thought you said NEMA Design B should be a part of Subtype 2. And, Roger, you're saying that NEMA Design B should be a subset, perhaps another box here, under Subtype 1. DR. DAUGHERTY: Roger Daugherty. No, not another box. If you look at the present box it will have, says "Design A and B." So, so what I'm, what I'm referring to is establishment of -- DR. ELLIOTT: Right. DR. DAUGHERTY: -- that under Standards. You'd have another box for Standards that you drop down from there. And same -- (Whereupon, at 9:47 a.m. ET, Mr. Raba1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 2 and Mr. Brookman conferred, out of the hearing of

others and off the Record, during which the following occurred:) DR. DAUGHERTY: -- with NEMA Design B, 2-, 4-, 6-, 8-pole, 201- to 500- -- MR. BROOKMAN: Okay. DR. DAUGHERTY: -- when you get down to the efficiency level, which I guess is really the lowest level on that chart. DR. ELLIOTT: I, I have no problems with Roger's presentation. MR. BROOKMAN: Thank you. I mean, I'm glad you clarified that. Andrew. MR. DeLASKI: I, I want to make a general comment on -- I think the issue here is an, Design B motor is a motor that has certain engineering descriptions to it, and that to define it within certain horsepower ranges is not consistent with what they, or the marketplace. So, that, you know, we should avoid having legal definitions that are in conflict with sort of what they are, what things are in the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 3 marketplace. MR. BROOKMAN: Yeah. And so we would like to have consistency and purity in our definitions. No doubt about that. But, we want to return, also, to the, make sure it's consistent with what we're trying to accomplish today. Jim Raba MR. RABA: Well, yeah. Thank you very much. Jim Raba. Comments are very helpful. Certainly helps in moving those things along. And we'll take them. For the Record, written comments are welcome on these areas, also, Definitions, I appreciate them all, but I think we have to get back to the framework document and the proposes of the next step for the, the next little motor. Is that helpful? Thank you very much. Roger. Neal. Andrew. Yes, Roger. MR. BROOKMAN: Do you want to continue1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 4 on with fire-pumps' motors? DR. DAUGHERTY: Yes. Roger Daugherty. I am actually addressing the framework document, because the framework document, again, proposes a definition for the NEMA Design B. It proposes a definition of "fire pump motors," and it proposes that the definition is that which was proposed in the NOPR back in 2008. Now, my concern about that definition is that you're taking, again, a general item that's out in the marketplace, that has been for -- I don't know. -- 30, 40 years, is well understood, it's covered by NFPA 20, and if you go and examine NFPA 20, you will find that a fire-pump motor can be a polyphased motor. It can be a DC motor. It, it can be a variable-speed motor. It can be a variable-speed motor. There's a whole configuration of motors. What you have done is taken what we call a fire pump motor in all those configurations and tried to limit it to a specific definition for fire pump motors.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 5 So, I'm concerned that you're creating conflict between a 40-year-old definition and a new definition for the purpose of establishing Standards. MR. BROOKMAN: What is NEMA recommending the Department do? DR. DAUGHERTY: Roger Daugherty. The, the best recommendation would be to define a fire pump motor as to its purpose, not its configuration. Then when it comes to the Standards, you can cover the configuration. And in particular, -- And when you try to do that if you look at your present definition you say it's a NEMA Design B motor. That's not what NFPA 20 says. NFPA 20 says that the motor shall have Design B characteristics, not that it's a Design B motor. Because, if you dig further, at least the way it used to be, that, there's a qualification test the motor and, and the whole assembly has to go through. That motor has to be capable of being started ten times in sequence to guarantee that1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 6 that thing's going to start in emergency situation.

Those, those tests went up to 20 times. A NEMA Design B motor only has a requirement of two starts, with the first being from ambient conditions, or one start if it's from low-temperature conditions. So, you -- It's, it's not true to just pull out and interpret NFPA 20 saying it's a NEMA Design B. MR. BROOKMAN: Okay, got it. DR. DAUGHERTY: It has NEMA Design B operating characteristics, but there are some other requirements on the motor. So, again, my best recommendation is define it with respect to application, and then begin trying to write the efficiency levels and the Standards that you qualify into a particular subset of the general item. MR. BROOKMAN: Okay, thank you. Yes, John. In a moment we're going to return to the slides. John. MR. MALINOWSKI: What I'd like to do is1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 7 to refer to the slide prior to this one. MR. BROOKMAN: Um-hum. MR. MALINOWSKI: Jim Raba -- This is John Malinowski. Jim Raba, earlier in his presentation, stated that some of these delays in getting these results done was because of keeping up with changes in industry standards. Here we are with a new NOPR and we're referring to 1993 version of MG 1. We use 2009 version. That's about four versions ago. DOE got in trouble on the small-motor ruling by referring to a 1987 version of MG-1. I mean, let's, let's -- We don't build motors to 1993 Standards today. We build motors to be 2009 Standards today of MG-1. Let's get on board with today's Standards, and not something we don't use. There's been a lot of definitions that have changed within MG-1, and we need to keep up with, with the changing times. MR. RABA: Jim Raba, DOE. Thank you, John. To what I was saying1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 8 before, one of the items in the SNOPR is to update

that very date. So, your comments are well-taken. Thank you. MR. BROOKMAN: Okay. Okay, let's proceed, then. MR. GORDON: Okay. For those uncertain of what distinguishes a NEMA Design A motor from a Design B and Design C. This plot gives a brief overview of the differences. It shows torque versus speed, or more specifically, full-load torque verus present slip. Design B motors are characterized by normal starting torque and normal starting current and are the most popular, while Design A motors have normal starting torques and high starting currents, and Design C motors have high starting torques, which makes them suitable for applications in crushers and conveyors. Design D motors are not covered by current Standards. These normal- or high-starting torques and currents are specified in MG-1. This slide shows a Venn diagram of how1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 9

the different motor features fall into the

different NEMA designs. T-frame motors and closed-coupled pump motors come in all three designs, while U-frame motors and vertical solid-shaft motors come in only Design A and Design B. DOE requests comment on whether this diagram accurately depicts the design characteristics of motors listed. (Whereupon, at 9:54 a.m. ET, no response was had.) MR. GORDON: All right. Moving on, the next up on the agenda, I'll discuss the steps DOE will take during the preliminary analysis. First up is the market and technology assessment. For the market and technology -- MR. BROOKMAN: Let's pause. Andrew deLaski. MR. deLASKI: So, we just went through scope, and in the written document DOE, the short paragraph says you'll consider, that you will consider addressing motors beyond those defined in those four boxes.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 0 But, yet, you didn't address it in the slides at all. Will that come up later today, or where does expansion of scope come in? MR. BROOKMAN: Jim Raba. MR. RABA: This is Jim Raba, DOE. Best I can answer your question is that this slide tries to illustrate the potential scope and coverage, even the interconnection of the motors. The written comments from interested parties would help us also to understand other areas that might be considered, potentially considered for Standards or be not considered for Standards as well. MR. BROOKMAN: Andrew, can you be more specific? MR. RABA: Yeah. MR. deLASKI: Well, I'm looking in the written document, the framework document, -- MR. RABA: Written? MR. deLASKI: -- on Page 6, middle of the page. The document reads: In this rulemaking, DOE is also considering expanding the scope of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 1 production, of production motors necessary, as

necessary with EPCA. And this, this paragraph comes after you've just, the document has just spent several pages defining motors that you're going to address. And then you say, "We're also thinking about addressing motors not previously regulated." So, I'm wondering: Where today will you discuss your thoughts in that area? MR. RABA: Jim Raba, DOE. I think the best is to anybody's thoughts about expansion of coverage, if you would like to address at this time it would be helpful. MR. BROOKMAN: So, if there's no additional comments here, then, of course, in your written comments. MR. deLASKI: Well, just -- I'll make a brief comment, a general comment, which is that we think looking at expansion of scope is a very good idea, and we think that the lion's share of this rulemaking lies in that one-sentence paragraph and the terms of what we're focused on today. I understand the Department has to focus1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 2 the products that are currently regulated as a

statutory obligation, and I think this one is, too, to address products not currently in the scope. But, our sense is that the lion's share of the energy savings lies in that single sentence. MR. BROOKMAN: Thank you. Neal, I thought in your opening comments, I thought you referred to expansion of scope. DR. ELLIOTT: I did. And this is Neal Elliott. To expand on that thing. There are two. The market reaction is that the majority of motors that are being manufactured in the integral polyphase market space today domestically, within the United States, are being manufactured at the NEMA 12-12 level whether they're covered product or not. Or at least they are a product available at those levels. The difficulty, and the burden on manufacturers to move to that level in an orderly way would be fairly minimal. The other point which I made in my1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 3 opening statement which I think is a very critical

one here is this issue of enforcement. And this is something we're very concerned about. At this point, I mean, we've already had disagreement as to what is covered product and what is not covered product. That simple ambiguity that exists creates a loophole that we are concerned is being or could be exploited to lead to circumventing the Standards as specified. Therefore, we think that expanding the scope of coverage, as I'd indicated in the opening remarks, to include everything except for an explicitly established set of excluded products is a good step forward toward addressing that compliance issue. MR. BROOKMAN: Mimi Gupta. MS. GUPTA: Yeah. Mimi Gupta. So, Andrew, are there any specific areas or types of motors that you think haven't been addressed in those, you know, three or four categories -- MR. BROOKMAN: And also Neal Elliott, we'll include you in that query, both of you.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 4 MS. GUPTA: Yeah. -- that you think the DOE should look at specifically? MR. deLASKI: Neal. DR. ELLIOTT: I think there are. A number of the definite and special-purpose motors that are manufactured in the marketplace today that are not covered represent opportunities for expansion of scope. And we can provide, and will provide in written comments, the sort of detailed list. I think might be useful for the Department to start thinking of this sort of in the inverse of the manner in which we've spent the last 18 years looking at it. Instead of looking at what products are covered, maybe the question should be what products are not covered, -- MS. GUPTA: Um-hum. MR. BROOKMAN: Neal Elliott. DR. ELLIOTT: Neal Elliott. -- because as we've moved today, versus where we were in 2000 or 1992, we were looking to cover a subset marketplace. Today I think we should be looking to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 5 cover the vast majority of the 1- to 500-horsepower

integral polyphase motors in the marketplace, and it may be much more beneficial for us to focus on what products should not be covered, rather than what products should be covered. MR. BROOKMAN: Thank you. John Malinowski. MR. MALINOWSKI: Yeah, the -- John Malinowski. I'm speaking right now on behalf of NEMA. I'm the Section's Chair for MG-1, the Motor and Generator Section. We've had several meetings with, with Neal Elliott and Andrew and others trying to come up with ideas on where we could expand coverage up through 500 horsepower. This would be 1 through 500 horsepower. All motors go into NEMA 12-12, including 56-frame motors, partial motors, -- A SPECTATOR: Footless. MR. MALINOWSKI: -- footless motors, closed-coupled pump motors. Just pretty much everything that is in the, the slide that you show as Subtype 2, most1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 6 everything there would go to NEMA Premium. Motors

that are not covered and were exempted by EISA today, motors with special shafts, motors that are footless, like air-over motors, total-enclosed motors, nonvented motors, those would all be covered as well. Just -- You know, as, as Neal Elliott said, it's easier saying what's not covered than what is. And we've done studies on this, and Neal's looked at energy saved. And by looking at the scope of our coverage we can save more energy than bumping up the efficiency by one or two NEMA bands. And it's something, as Neal said, we can put into effect. We've got production tooling today, and we can make this happen in a couple of years, whereas if we were forced to tool up motors to go to a higher efficiency level, it would be an undue burden financially to the industry. It would be a bigger burden to our customer base, who would likely not be real happy with it. And, in addition to this, we've also got the IEEE level of efficiency which is equal to the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 7 NEMA 12-12 level that our foreign motor builders

are, are building motors to these days. So, you know, we're good to go with products, expansion of coverage, and can do that for you rather quickly. You don't need to wait for 2015. MR. BROOKMAN: Yeah. Jim Raba. MR. RABA: Jim Raba, DOE. Thank you, John and Elliott and Andrew. Sounds like, really, the most practical thing to do would be to expand coverage, which will get more motors and more efficiency in the marketplace, rather than raise levels. So, certainly we would welcome your comments, written comments together, if that's how this is, if there's a consensus from both the, the manufacturers and the advocates. And it would be very helpful to know what you propose would be covered, would be not covered, as well. So, that, that's, that's really important. I appreciate those comments. Thank you.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 8 MR. BROOKMAN: Charlie Stephens.

MR. STEPHENS: Charlie Stephens. Just one quick addition, though. I think this brings me to a point of, of focusing back on the definitions again. We better get the definitions right or we're walking in quicksand here when we try and do any of this. So, I'm going to try to focus my attention there. MR. BROOKMAN: Okay. We've had good discussion on the definitions already. Were you finished, Andrew? MR. deLASKI: Just a couple follow-up thoughts. One is that -- Three thoughts. One, Jim's comment to, you know, the primary concept here is to expand scope. But, there are some motors included in the current legislation that are at Table 12-11 levels, and certainly our thought is those should go, by and large should go to 12-12. And we're walking on the ones he think should go there. I also think it's important that, based on the technical economic analysis, that this1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 6 9 helps us understand: What are the right levels? And that clearly has to be developed through the Department's rulemaking process. And I think the other thing to consider is that as we move with this rulemaking towards a more expansive definition of what is a motor and applies to motors broadly, and instead of defining what's in this, defining what's out that that parallels the construction that DOE has for most other products. And that, that, that construction, I think, in general, we've had more problem with definitions of motors than any other part that I know of. And Jim laughs because he's been doing it 15 years. MR. RABA: Not as long as the audience. I'm a rookie. MR. deLASKI: I hear Rob say 25 years. All right. So, if we can move to a definition which is broad as possible, a, at the highest level, and include those things, and then look to have appropriate levels for appropriate motors that fall within that broad definition defined in a more1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 0 narrow way, that will help us get to better clarity

for the marketplace, help address some of the enforcement issues that Neal's raising, and the definitional issues that Charlie's raising. I'm not saying it's going to be easy, but I think having that broad definition will help

us. MR. BROOKMAN: Okay. Okay, this has been productive. I think final comments, but then we're moving on. MARKET AND TECHNOLOGY ASSESSMENT AND SCREENING ANALYSIS MR. GORDON: Okay. So, actually there's, in the Agenda, that we're due for a break after that. I don't know if we want to continue. MR. BROOKMAN: Let's keep going. MR. GORDON: All right. So, next up is the market and technology assessment. For the market and technology assessment, DOE identifies and characterizes the manufacturers of electric motors, estimates shipments and trends in the market, identifies regulatory and nonregulatory initiatives intended1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 1 to improve the efficiency of the equipment covered

under this rulemaking, establishes product classes, and identifies technologies that could improve efficiency. Then in the screening analysis, DOE takes these technology options and screens several of them out based on four screening criteria that we'll discuss later. The remaining technology options now referred to as "design options" are then fed into the engineering analysis. Another key output from the market and technology assessment is the development of product classes, which are also fed into the engineering analysis, and we'll discuss this next. One main task in the marketing technology assessment is to establish product classes, and DOE generally establishes separate energy conservation standards for each product class. DOE divides these product classes by the type of energy used, the capacity of the product, or any other performance-related features that may affect the utility and that would justify a1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 2 separate conservation standard level. Currently,

classes are divided by horsepower, pole configuration, whether open or closed, and then by type as was defined earlier. so, Subtype 1, Subtype 2, NEMA Design B greater than 200 horsepower, or fire pump. And here I've inserted a table taken from the efficiency Standards to demonstrate how these efficiency levels are constructed. And so here we have in the first column horsepower, and along the top there's open motors. And for each open motor there's a number of poles. So, 2, 4, 6, and 8, and then, also for enclosed motors pole configurations as well. And so for unique combination of pole configuration, enclosure, and horsepower, we have a unique efficiency level to be met. For this rulemaking DOE is considering dividing electric motors, again, by horsepower, pole configuration, and enclosure, but also by NEMA design level, frame type, and whether a motor falls into the category of vertical, solid shaft, or fire-pump motor.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 3 This table sums up the classes that I just described, and illustrates how motors would be grouped differently than they currently are. The first two columns break down the classes into five groups of U-frame, NEMA Design A and B, T-frame NEMA Design A and B, T-frame NEMA Design C, vertical solid-shaft motors, and fire-pump motors. Each of the five groups covers the range of horsepowers and pole configurations, and is then divided by enclosure type. We're then left with ten distinct groups. And I say "groups" because a class is really made up of one particular horsepower and one particular pole configuration. The last column indicates at which level the amended EISA Standards are set at. For Groups 3 and 4, while separate Standards were set for motors with 1 to 200 horsepower, versus 200 to 500 horsepower, and two to six poles versus eight poles, DOE is considering grouping all these motors when it amends the Standards. MR. BROOKMAN: John. MR. MALINOWSKI: John Malinowski again.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 4 Minimum efficiency, as Roger said earlier, we need to get away from using EPACT and EISA, because within the EISA document we have two efficiency levels that are allowed, Table 12-11, Table 12-12. So, we need to be very specific as to: Are we 12-11 Table or 12-12 Table down that right-most column? MR. BROOKMAN: You can see how the Department would have a bias towards demonstrating its compliance with the law, right? But, your comments are well-received, I'm certain. Yes, Elliott. DR. ELLIOTT: Just to reiterate my previous comment, the law actually specifies NEMA 12-11/12-12. It does not specify levels. And there is actually no definition in the law with respect to EPACT 1- to 200-horsepower. The law actually explicitly states NEMA 12-11 -- MR. BROOKMAN: Good. DR. ELLIOTT: -- as the Standard. MR. BROOKMAN: Okay. Thank you. Thanks to both of those comments.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 5 That's helpful. Other comments at this pause before we move on? Yes, Molly. MS. TROMBLEY-McCANN: Molly Trombley-McCann. Just pointing out to all of us in the room that if we're going to talk about expanding the scope, that the number of product classes is going to be impacted, and I imagine comments will have a lot more to say to that, but just to be aware that that's going to be necessary. MR. BROOKMAN: Okay. Neal. DR. ELLIOTT: To follow up on Molly's comments, just to look at if we do move to expand the scope I think we have the opportunity to collapse a number of these subaccount groups down into larger categories, such as eliminating the 1- to 200, and 201- to 500-horsepower distinction and basically covering everything in the 1 to 500 horsepower integral polyphase. MR. BROOKMAN: So, your specific1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 6 suggestions, especially considering that you're

going to include in your comments the expanded scope, I think that would be very helpful to the Department. Let's press on. MR. GORDON: All right. In constructing our groups, DOE has initially decided that the following four factors do not provide unique utilities that affect efficiency, and therefore should not be used when selecting classes. These include differences between NEMA Design A and B motors, whether a motor is a close-coupled pump motor, the voltage of the motor, and whether the motor has mounting feet. At this point I'd like to invite comments on the proposed product classes. MR. BROOKMAN: Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. I'd like to address a few of those that you have on the screen, and maybe one that you don't have on the screen. The -- With regards to the NEMA Design A and B, I, I whole-heartedly agree that those should be grouped together.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 7 However, I would, do want to make the point that NEMA Design B does have a limit on the level of locked-rotor current, and that limit also appears in the National Electrical Code, NFPA 70. It's used for the choice of deciding on controlled, motor controllers, motor protective devices, wiring going to the motor. So, it's very important adhering and not exceeding those national limits. The reason I make that point is, in keeping these as the same grouping, is that the ability to obtain more efficient motors is inversely affected by the level of locked-rotor current. So, if I'm searching for very high efficiency and want to reduce losses, I try to get the rotor resistance down, and as a consequence, I lose out on locked-rotor and I end up having higher locked rotor currents. So, within the analysis, as you perform it and look at these two groups together, I encourage that NEMA Design B be the motor classification that's the determining factor in evaluating any increases in efficiency for that common classification.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 8 The next is with respect to voltage. I do realize that in EISA, under Subtype 2, it states that it covers voltages up to and including 600 volts, except for 230/460. But, I would also note that EISA also referred to electric motors of Subtype 1 and also Subtype 2 as being general-purpose according to DOE's definition that was incorporated by the Final Rule of 1999 in Part 431. Part of that definition is, no, it's standard characteristics. Within voltage levels there are standards. In particular, ANSI C 84.1 is the Standard for voltage level of power systems in the United States. So, indirectly, ANSI C 84.1 does actually establish a set of standard voltage ratings within the U.S. And I only make that point that because this, this presents the danger of incorporating some Rule that pulls into Subtype 1 or Subtype 2, particularly Subtype 2, a grouping of motors that may be rated as something like 80 volts at 60 Hertz because that motor's actually being used for some available speed on some1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 7 9 available-speed control and happens to have a

rating of 60, but its true intent is covering a wide voltage range. Because so far in your definition you haven't ruled out the variable-frequency motors. But, by adhering to the standard voltage classes, you will keep up with the NEMA Standard, which also refers to their standard voltages. And, you will be examining the standard motors that are rated for operation and can be used on a, standard systems in the United States. The next is with respect to mounting feet. I only note that in Subtype 2, footless motors are delineated as a specific category under Subtype 2. It was, I guess, my impression in going through the small-motor rulemaking that when you establish classes, those are associated with some efficiency levels. So, within EISA, at the present time a footless motor is of a different class than a foot-mounted motor. Now, I'm not saying that you can't examine efficiency gains of footless the same as1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 0 footed. It's only that I'm trying to be certain

that I don't become confused as you're establishing classes when I see here's a specific delineation in Subtype 2 that a footless motor is a specific class of motor, and, and that if you remove it as a class, I'm not sure how you start with the present level of efficiency, which is different than a foot motor that's over in Subtype 1, and then look at that raises that efficiency. MR. BROOKMAN: May I -- You want to comment, Mimi? MS. GUPTA: Yeah. MR. BROOKMAN: Mimi Gupta. MS. GUPTA: Mimi Gupta. I think the proposal here is, yes, we recognize that right now footless and footed motors have different Standards, but the proposal here is to say that in subsequent amended Standards this would be subject to the same Standard, because from what we can see, there's no specific feature that might affect efficiency having to do with a footless or a footed motor. And this is why, what we're requesting1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 1

comment on. MR. BROOKMAN: Roger. DR. DAUGHERTY: Roger Daugherty. Yes. But, when it comes to doing your economic payback analysis, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- and during your energy-savings analysis and all those analyses, you, you have a base efficiency level that you start it -- MS. GUPTA: Right. DR. DAUGHERTY: -- for a class. A class, to me, of a footless motor under, Subtype 2, starts at Table 12-11. MS. GUPTA: Right. DR. DAUGHERTY: That's your starting point when you're examining efficiency. But, a foot-mounted motor of the same design -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- falls under Subtype 1 in Table 12-12. So, the starting point in doing your economic payback and your energy savings and all1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 2 your other analyses are based on 12-12. MS. GUPTA: Right. DR. DAUGHERTY: So, if you don't carry the class of footless through the document and the work, I don't see how you do a different economic payback analysis of footless versus footed. MS. GUPTA: Well, I think Jeremy will be discussing baselines more in detail later on in the presentation, but one thing that DOE is considering is, you know, analyzing two baselines for a single product class. So, looking at the economics of, you know, someone who's at the 12 dash-11 efficiency level separately from the 12 dash-12 level, and then make, taking both of those into account and establishing an efficiency level, a single efficiency level. But, you know, this is something that we request, or DOE requests comment on. So, if you think that's a bad idea or a good one, -- MR. BROOKMAN: So, so maybe we'll see. We'll wait to see how that's presented. John. MR. MALINOWSKI: John Malinowski.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 3 To expand a little bit more on Roger's comments on voltage, 575 volt, we build motors for Canada. They classify 575 volt the same as our Subtype 1, okay? So, the 575s that many manufacturers are building, we're building to Table 12-11, -- I'm sorry, 12-12. -- where 12-11 is allowed in the U.S. There are parts of the United States that use 575 volts. So, by allowing 575 volt and 200 volt to be Table 12-11 in the U.S., that's really not doing anybody a favor. I mean, we're building 575s for Canada at 12-12, so it's not a burden for us to do, do that as our standard offering. When EISA came out there was a question on what constitutes a closed-coupled pump motor because it's not clearly defined. Many of us look at that and think of that as a, a JP or a JM, or West Coast styled pump mount, but that's only defined, I think, through a 320 frame in the NEMA book. Larger motors than that are commercially available.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 4 We stock them. We sell them to pump manufacturers. But, they're classified as a Z-shaft, a specialty motor, which would be exempted from EISA. The other category of pump motors that's not addressed here that runs lots of hours are closed-coupled hydraulic pumps. There are many standard; Parker and other pump manufacturers. We build thousands of these types of motors, and they're used in process industry on machine tools, on die-cast casting machinery and other such equipment that run 24-hour shifts. Is that covered as a closed-coupled pump motor? We don't interpret it as such under EISA, but we think it probably should be covered. The presence of mounting feet, don't know why that ever got separated in the first place, because if you look, you go into any large distribution center that has conveyors running, you walk into a FedEx distribution center and you may I see 4- or 500 motors running that are footless motors mounted to a gearbox. They, they should be covered under1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 5

12-12. You know. Again, under our proposal we discussed earlier, all of these come together. The other part on the pump motors that you mentioned in a previous slide was a vertical low-thrust pump motor. There's no reason that all vertical motors, including hollow shaft, couldn't be made in a 12-12 configuration. MS. GUPTA: Can I ask a question? MR. BROOKMAN: Yes, please, Mimi. MS. GUPTA: Mimi Gupta. So, I had just a follow-up clarification question for Roger related to Design A and B. You mentioned that the potential efficiency that Design A and B can achieve might be slightly different due to the, the locked-rotor current requirements, but you also mentioned that you agreed that they should be grouped together. And I was wondering why, in your opinion, why should they be grouped together if their efficiency potential is different? DR. DAUGHERTY: Roger Daugherty.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 6 Well, today they're grouped together, and I guess it's just for as long as I've been dealing with motors. The -- Yes, the level of design is higher on, but those go to the specific customers who know how to use them. You can't take a Design A motor, buy a five-horsepower motor, go to the motor controller manufacturer, say, "Give me a 5-horsepower controller," put it, put it on the motor, have a control technician that's normally set to that which is Design B. He tries to start it up. Instantaneous trip. Breaker trips off. He can't start the motor. His protective circuits prevent it. It, it's trying to accelerate. It says your motor's overheating, and it trips off. So, -- But, for those customers who know how to use a Design A motor, and the manufacturers provide that to them with maybe some other benefits, they may be looking for a much, much higher level of torque that you can get out of Design B for their particular application. In -- The NEMA Standards with regards to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 7 torque performance have the same Standards as

minimums for A and B. So, you, you -- There are other performance areas than just the locked-rotor current that come into play. One common way of starting is having to go to Y--Delta start configuration, which means you have to buy a motor that has more than three leads coming out. So, you can do that, and you have to be familiar with doing that in providing correct protection when it's in the Y--starting mode and when it goes over into the Delta running mode for overload protection versus start protection. So, to those who are knowledgeable in the Design A and may need more torque to get their unit accelerated up to load, then they come to the manufacturer. They know what they want, and specifically Design A. So, -- And the real reason the Design A Standard is there and says there's no limit is to adapt to those, those customers who need that kind of performance and were limited by Design B. MR. BROOKMAN: Okay? Neal.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 8

DR. ELLIOTT: Neal Elliott.

Thanks. Following up on Roger's comment, I, I want to make it clear that at the NEMA 12-12 level, Design A motors are commercially available today and that's not a problem. And, and it's the, the application issue. What I, what Roger's indicating, and, and I, -- Correct me if I'm wrong, Roger. -- is you can get Design A motors that go in terms of their IEEE 112(b) efficiencies and above, the 12-12 level, that becomes much more difficult when you go to a Design B motor because of the in-rush current. On the other hand, we're not advocating that we move beyond 12-12 at this point, for, you know, for technical reasons. So, you know, I think what we're looking at is 12-12 is fine for A and B. If you push beyond 12-12 efficiency levels, then you start getting into technology constraints which make the market much more difficult, and potentially create some confusion1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 8 9 and possibly misapplications in the marketplace. MR. BROOKMAN: John Malinowski. MR. MALINOWSKI: Yeah, John Malinowski. Just to clarify it, look at it from a different perspective. If a customer has an existing application where he's running that same 5-horsepower Design B motor and he now replaces it and puts a 5-horsepower motor in that's a Design A, that in-rush current is going to play havoc with his starter. He's going to have nuisance trips, okay? The other thing to think about with these motors is that they work very well with adjustable-speed drives. Remember, the other has a circuit that limits in-rush current. So, many of our inverter-specific motors fall over into this Design A, and they actually provide better performance than a Design B motor: more efficiency; running cooler. You don't have to worry about a limitation on in-rush. You can go crazier with the design.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 0

MR. BROOKMAN: Andrew deLaski.

MR. DeLASKI: Just a follow-up for John. Don't go away, John. So, take your situation you just outlined and reverse it. For a customer who had a Design A motor in an application today, -- (Whereupon, at 10:28 a.m. ET, Mr. Raba and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. deLASKI: How much easier is it to put a Design B motor in that same -- MR. MALINOWSKI: I, I, I think -- John Malinowski again. I think we're getting too hung up on Design A and Design B. Customers don't come to you and really say, "Give me a Design A motor." They come to you and say, "Give me a motor with such-and-such torque, speed, et cetera, efficiency, what other performance," and it just turns out to be Design A because you can't limit the in-rush current to Design B. MR. BROOKMAN: Okay. Okay.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 1 MR. MALINOWSKI: You know, people, people don't buy motors based on design, with the exception of a perception of what a Design C motor or Design D motor is. Design A and B, as we've said all morning, they just are general- -- DR. ELLIOTT: Purpose. MR. MALINOWSKI: -- purpose motors. MR. BROOKMAN: Okay. You have a follow-on, so, -- MS. GUPTA: I have a -- MR. BROOKMAN: -- Mimi Gupta. MS. GUPTA: I have a follow-on additional question. Mimi Gupta. So, we've been talking about potentially going to the NEMA 12-12 level, but DOE's required to look at the max--tech level. So, something potentially above NEMA 12-12. So, John, you mentioned that, for example, closed-coupled pump motors, they can meet the 12-12 level and maybe, might not require a separate category. But, if you're looking at the highest efficiency potential of all of these motors, can, can they meet the same efficiency as a1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 2 nonclosed-coupled pump motor? MR. MALINOWSKI: John Malinowski. I guess my question back to you is, when you say "highest performance," -- MS. GUPTA: Um-hum. MR. MALINOWSKI: -- when we're looking at raising the efficiency above NEMA 12-12, are we talking about one band? Two bands? Three bands? How, how much performance do you want? Because what industry is looking at is switching technologies. We're pretty much maxed out at what we can do with AC induction motors today. MR. BROOKMAN: At 12-12? MR. MALINOWSKI: 12-12, or just maybe a band above it. Some of us offer, you know, a band above. Nobody can do a band or two above across the whole product line. Some particular ratings, we struggle to get the NEMA Premium level. And that's about the maximum we can do without a pretty much wholesale, very expensive redesign that wouldn't be affordable to the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 3 customer. What many of us are looking at are other

technologies; in other words, going to a motor with a permanent magnet rotor, or to a switch-reluctant motor, a different technology than even DOE is, is supporting, is advocating. DOE is, is advocating use of motors with drives, variable-torque load with a drive. A pump or a fan can save 50 percent energy, and, and we're setting (sic) here talking about raising a motor four-tenths of a percent. We take our motor and hook it up to a 50-percent efficient pump. What are we doing with pump efficiencies? What are we doing with compressor? We're just focusing on the motor, but DOE, through Industrial Technologies Program, for years had best practices of looking at system efficiency. Yet, the only system efficiency that DOE is really regulating that, that involves industrial motors is industrial HVAC. And now, with the ruling, you're getting into some other coolers and other things. I mean, we're spending an aweful lot of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 4 time looking at something we're going to get an

incremental, small amount of efficiency raising it above where our 12-12 table is. That's why we think expanding the scope of it is better, but, really, spending more time and going and looking at, looking at system efficiency and, and what can we do to get more-efficient compressors and more-efficient pumps and more-efficient gear boxes, and, and adding drives, and, and just system optimization of process control. MR. BROOKMAN: Neal. DR. ELLIOTT: Neal Elliott, and I'm speaking here on behalf of, of ACEEE alone on this. I want to second what John said. I mean, I think you're -- And if you move to your next slide you begin to talk about different technologies that could move beyond a 12-12 level. And these are technically, and in some applications, economically justified. I think, to John's point, I think you get a lot more by expanding coverage and simplifying the marketplace, enhancing compliance with the Standards, than you do in terms of pushing ultimate efficiency.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 5 And, as Roger Daugherty pointed out earlier, as you push beyond the 12-12 levels for efficiency, you begin to encounter problems with technologies and you'd start to encounter market application concerns. And I indicated in my opening comments that I think it's important to understand the motor marketplace. And one of the key factors here that you encourage the Department to look at very carefully is the motor decision process. In an application when you move beyond the 12-12 levels, and, and in some cases even at the 12-12 levels you no longer have a product that can be directly replaced for an existing noncompliant product. This leads to a potential unintended consequence, which would be that a motor that would normally be replaced with a new premium motor, maybe necessitated that it be repaired instead. So, if we were beyond the 12-12 level, there are many products out there that would shift from a replace category -- Let's say 5-horsepower, 10-horsepower motor. -- to a repair category.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 6 Now what that could do is perpetuate the life in the marketplace of a non-EPACT motor -- MR. BROOKMAN: Right. DR. ELLIOTT: -- in perpetuity, and that would have the potential unintended consequence of actually lowering the efficiency over what would be achieved by maintaining a 12-12 level. So, I think you need to be very, very careful as you explore this. I want to emphasize, this is speaking for ACEEE, not speaking for any one of, of the other parties. MR. BROOKMAN: Thank you. You were, you were, you were clear on that. John. MR. MALINOWSKI: John Malinowski. One thing I'd point out that you've not taken into account is you've ruled out customers that are asking manufacturers to make changes in their motor shaft -- longer length, larger in diameter -- so they can skirt EISA law. They've come to us. Large manufacturers, large E-, OEMs have come to us that want to do this.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 7

If we don't to this as a domestic motor manufacturer, they've stated they'll take business elsewhere. They'll go to China. So, that is covered under our broad-based proposition that that wouldn't make any difference on the motor shaft configuration. It would be a covered product. MR. BROOKMAN: Thank you. I'm going to suggest we take a break right now. It's 10:40, so let's take a 15-minute break, which means we'll resume at 10:55. (Whereupon, at 10:36 a.m. ET, those present took a brief recess and returned at 10:58

a.m. ET. The following then occurred:) MR. BROOKMAN: Please take your seats. We're going to resume. Okay, let's, let's start back up. We can, I think, are on Slide 36 MR. GORDON: Yep. MR. BROOKMAN: The last few commenters were pointing us in that direction, so it seems timely. I'd like to make the comment that I think the -- Let's, let's -- I'd like to simply comment1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 8 that I really think the discussion, that's been

very useful so far, and I kind of appreciate everybody being well-prepared and focused in their comments. So, now we're going to resume on Slide 36 with Jeremy. MR. GORDON: All right. It -- Another goal of the market and technology assessment is to identify all technologies available to improve the efficiency of electric motors. This is accomplished by reducing the four types of losses. Those are I-squared-R, core, friction and windage, and stray-load losses. Here are several technology options that were identified, including increasing the copper wire in the start-, stater slots, use of thinner steel laminations, use of bearings or lubricants with lower losses, et cetera. At this point I'd like to invite comments on the technology sections of the presentation; in particular, the items listed here, which include the rotor stator air gap, core steels, and plastic-bonded iron powder.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 9 9 MR. BROOKMAN: Roger.

And we've already received a few comments on some of these. Please. DR. DAUGHERTY: Roger Daugherty. With regards to your Item 3, there basic comments. One, in the framework document you discuss changing the size of the conductor, changing the shape of the rotor bars, and things in order to achieve greater efficiency. And certainly you, you can do that, but I just wish to point out that there are parts of the Standard that you really need to be certain that you meet as you look into your goal for efficiency. And I notice, like that in the small-motor rulemaking, there were parts of the Standards that maybe you didn't recognize were also important in, in the overall performance requirements. And just to shortly list a few of those, of course we've had a big discussion today on the maximum limit on locking-rotor current it's very important that you adhere to. We would also have1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 00 requirements of minimum limits on locking-rotor

pull-up and breakdown torques. And those were somewhere in the slide that you presented earlier, the speed of torque

curve. Things that you may not be aware of unless you look through the Standard is that we also have that there's a minimum required stall time of 12 seconds. That means a locked rotor, this level of current that is drawing up to Design B limits, or even if you're designing a Design A machine, that motor must be able to handle that current at locked rotor for up to 12 seconds without burning up. And that sometimes is a very serious limitation on the design, particularly when you're working toward high efficiency. Another is that the, the requirement that I had mentioned earlier with regards to starting. That motor must be able to start two times with only a coast-down between those two starts when it starts from ambient temperature, or it must be able, capable of being restarted one1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 01

time with a declared inertia that's in the Standard

when it's at full-load temperature. Of course, that's to handle the application where, for some reason, the unit happens to shut down for some reason and the consumer wishes to get that unit back up and running as soon as possible, and he doesn't want to sit around waiting for the motor to cool down before he can restart it. So, it is something you have to consider, because when you start from full-load temperature and it rises and goes through, during acceleration there's a chance that you could exceed allowable temperatures for the materials that are used in the insulation system, in the stator system, or for the rotor bars. And those are aluminum rotor bars, or copper, whatever you're looking at. So, I just encourage you: Please become familiar with all the performance requirements required of the motor that you are looking at when you try to look at just efficiency as a whole. Another, I notice that in the framework1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 02 document it referred to a problem about cusp being

created by a third harmonic in polyphase motors. To my knowledge there is no third harmonic in, in polyphase motors. There's no multiple of three harmonics in, in polyphase. And the last, which you have as your last item in Item 3 here, regards to air-gap size, I do realize that in the small-motor rulemaking you were looking at three frames, 42, 48, and 56. And in your ride there's some minimum clearance to use. However, you have to understand, now you're looking for 1- to 500-horsepower. Those vary in size, in shaft height from three and a-half to 12 and a-half inches with different rotor diameters according to configuration and number of poles. I would say that it's not practical to try to establish a lower minimum value for the air gap size over such a large range of product sizes. Also, establishing such a lower limit may suggest that someone does not understand stray load loss, and that stray load loss is the fifth1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 03 type of loss that's in a motor. And that's

affected by the size of the air gap. Just for very minimum air gaps may give you stray load loss that makes it difficult to reach your design goal for efficiency. So, I would say that you, you look at designs, but you be careful in how you're selecting the air-gap sizing. Thank you. MR. BROOKMAN: So, I just want to note that in this comment box -- And I think Roger's addressed some of these. -- the Department is specifically asking for comment on reducing I2R losses, reducing core losses, developments of plastic iron powder technology, and reducing friction and windage losses. So, if we have some additional comments that have not been covered so far, that would be helpful. John, please. MR. MALINOWSKI: John Malinowski. I just wanted to comment. As you look at steels that are available, when you look at the steels available in your study on the small-motor1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 04 Ruling, the steel that your consultant selected was

only available from one mill in the United States, and that mill's capacity was 200,000 tons a year. That would not have been enough steel for my company to use, let alone 14 members of NEMA. So, be very careful on steel in general. The quality of electrical-grade steel that we're receiving today is not as good as we did years ago when there was not as much scrap content within that steel. The steel companies will freely admit that to you if you, if you do talk to them. So, be careful on selection of steel. Better yet, you tell us what efficiency we need to do and we'll select what steel we need to do that. The other thing you don't have up here that is of concern is in the small-motor ruling you also looked at copper die-cast rotors. Copper die-cast rotors are very expensive to do. It's not a high-volume production technology. The die-casting molds for that have very short life. Using the present, the best steel that they can make those out of today is H-13 steel, and1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 05 they, on a 20-horsepower motor they only cast 2,000

rotors before the, the tooling is gone. On, on a 500-horse motor they only cast 40 rotors and the tooling is gone. So, for my company in one of my plants I'd have three sets of tooling a day to do that. That die-casting machine is $2 million. So, you know, I'd have to go out and buy a lot of die-casting equipment. The melting pot to do aluminum today melts aluminum at 1,100 degrees. Copper is like 2,200 degrees. When I bring laminations in from my warehouse into that hot die-casting plant I get condensation. It becomes a safety hazard, which OSHA would have big problems with. If you shoot the hot copper in the moist rotor laminations you're going to have a big explosion. So, there's some real safety issues with copper. We would need all new laminations; not just rotor laminations, but stator laminations to optimize a copper die-cast rotor design. So, that's nine NEMA frames times three different pole designs for each one at somewhere1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 06 between 300- and $500,000 per design, not to

mention new winding equipment, new insulating equipment, everything. For my company, the cost could exceed $75 million to retool for copper rotors across the whole scope of 1- to 500-horsepower, and it's not feasible to recoup that money from what you could sell the motors for. I think steel and copper rotors are really our biggest concern. MR. BROOKMAN: Thank you. Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. I'd just like to follow up a little bit on what John just said with regards to electrical steel. And this is your Item 4 with regards to core losses. And this became a major issue in the small-motor rulemaking, and it's serious concerns to the manufacturers in how DOE and their consultants were looking at the use of so-called very low-loss electrical steels. You have to realize that the information that was provided from the steel company is based1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 07 on what's known as an Epstein test. And that's

based on taking rectangular strips of electrical steel at very prescribed orientations to that sheet steel, and then conducting the test to determine the core loss and the VH characteristics. The electric motor, we don't have such a nice, uniform structure for that flux to go through. It rotates through, through the stator lamination and it appears at all different angles, all different possibilities of going through that electrical steel. Now, as a consequence, Epstein test is not a true measure of the amount of core loss you're going to get when you actually build a product and test. And in particular, the DOE had looked at some very thin electrical steels and had projected some tremendous increases in efficiency by using those steels by reduction of core loss. At the public meeting that was held on January 29, 2009, comments were made regarding those conclusions and the use of that Epstein information. DOE, at that meeting, requested information from manufacturers that could support1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 08 the manufacturers' viewpoint that that Epstein

information was not a valid information to be using. That information was provided to DOE at, on actual testing of two different types of that very thin electrical steel manufactured into identical motors as using conventional electrical steel. The test of those two motors showed conclusively that the total core loss of those two motors using the very thin electrical steel, while the Epstein data said you're going to get a tremendous reduction in core loss, in reality the core loss went up with those two electrical steels compared to the conventional steel, totally contradicting the information from the Epstein test that DOE was using in its study. However, after having provided that information to DOE, it got dismissed out-hand, and DOE made this statement in the Final Rule: Quote: DOE believes that the variances between Epstein losses and actual motor losses are not an issue for its engineering analysis.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 09 Well, I'll tell you that for the manufacturer, what those test results show are important to its, his analysis and his being able to produce those motors. So, I encourage you that if you're going to be looking at the so-called high-technology configuration using very thin lamination material, that you gather sufficient information to support any conclusions that you make, and that you don't push the manufacturers into a round of efficiency levels that those manufacturers cannot obtain because the product won't perform the way the DOE says it will. That's all. MR. BROOKMAN: Okay, thank you. Several requested comments. I've listed them a moment ago. Additional comments? Emmanuel. DR. AGAMLOH: Emmanuel Agamloh, Advanced Energy. I just wanted to point out that it is very difficult to correlate the Epstein test, Epstein frame test with increased measurements once the motor is assembled. Those are completely1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 10

different tests. So, if you perform Epstein test on lamination steel and then you use that same lamination steel to assemble a motor, you are going to perform the core loss test by actually the well-known standards and the method that is specified for determining this kind of core loss measurement. It hasn't got any direct correlation to the Epstein test. So, it's not -- You cannot compare the two test results practically and say that this one produced higher core loss results than this, because those are two different tests. The -- At -- By that method, what you determine as core loss may not necessarily be core loss. It might have some frictions and windage, some component of friction and windage, and even stray load loss in there. So, those are two different tests, and that has to be looked as such. MR. BROOKMAN: Okay. Thank you. Rob. MR. BOTELER: Rob Boteler, with Nidec.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 11

We talk an awful lot about the technical side, but one of the things was that when we build more efficient motors, predominantly what happens is we add more active material. So, we're going to add more copper. We're going to increase the slot fill. And one of the -- Neal used the term "unintended consequences." One of these unintended consequences is going to be the need for us, as manufacturers, to move from mechanized machine winding, which is what we try and do in the U.S., to hand--winding, which we do in low-cost countries where we have lower-cost labor. And I think the Department needs to recognize that moving to higher efficiency is going to put the manufacturers in a position where we will be exporting jobs offshore as we move to lower-cost companies to take advantage of the lower cost of hand winding machines. It, I know, doesn't necessarily fit with what exactly we're talking about, about the technical side, but it could be a consequence.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 12 MR. BROOKMAN: Okay, thank you. Thank you. Yes, Molly. MS. TROMBLEY-McCANN: Molly Trombley-McCann. This is more a question to the manufacturers. I'm just wondering. Do you know what the Epstein test was designed for, and who designed it? Because it sounds, certainly, like it was not designed for this, and I'm just wondering. MR. BROOKMAN: Roger, do you want to try that? DR. DAUGHERTY: Roger Daugherty. I'll try to take a shot at that, since it was developed before my lifetime, I think, or at least my, my familiarity with rotating machinery. The, the Epstein test is a good measure of the relative difference between certain classifications. And it's very -- It may work very well in, say, a transformer configuration where the distribution of the flux is very well-defined as you stamp and build transformer laminations, but1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 13 once you move over into a motor in a rotating

field, you're not into that nice configuration. Now, where the manufacturers use of it value is not in determining what the real core loss is going to be, but the value it gives to me is to go to different steel manufacturers and, and to tell them that I want a lamination material of M-19. And associated with M-19 is a specific Epstein characteristic at 1.5 test load, which is flux density in that material in the Epstein test so that I can find from different steel companies what they might have available in that particular grade. But, I have built prototypes back in, as motors, testing these; had those that I know that I actually want that M-19 type of material. That Epstein data doesn't tell me what core loss is going to be, and can't be, that I know of, directly put into any analysis that would predict a core loss, that I see coming out of universities or anywhere. But, it gives me relativity. So, if I1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 14 go to steel manufacturer X; say, "Give me M19;" Go

to Y, "Give me M19," I'll have coming through my door steel coming through that I know uses that product that will give me that core loss that I expect from that type of material. MR. BROOKMAN: Okay. Thank you. (Whereupon, at 11:19 a.m. ET, Ms. Gupta and Mr. Bonnett conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. BROOKMAN: So, I'm going to suggest that we move on now. Yes, right. MR. GORDON: So, next up on the agenda is the screening analysis. In the screening analysis, technology options are screened using the following criteria: Technological feasibility; practicability to manufacture, install and service; adverse impact on product utilities, or availability to consumers; and adverse impact on health and safety. DOE welcomes comment on how the above four screening criteria might apply to the technology options discussed.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 15 MR. BROOKMAN: Any additional comments based on these screening features? Roger. DR. DAUGHERTY: Roger Daugherty. I, I just point out that as I was reading the explanation that's in the framework document with regards to technical feasibility, it was very unclear to me how that applied to the discussion that was on technology options, since it would seem that it would rule out all the technology options that are not presently in use. If you go back and read the framework document it says that the tech-, technological feasibility was with regards to those, that technology that's in present use. Yet, elsewhere in the document you talk about looking at new technology. (Whereupon, at 11:21 a.m. ET, Ms. Gupta and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, during which the following occurred:) DR. DAUGHERTY: But, that seemed to be in conflict with your explanation of technology1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 16 feasibility. So, you may want to reword that or

clarify it. MR. BROOKMAN: Okay. Other comments on these screening analysis features? Bob. Yes. MR. BOTELER: Bob Boteler. Just kind of a general comment on the adverse impacts. Kind of the same issue that we faced with the small motors. When we moved -- If -- Should we move to a higher level of efficiency we're at risk that, you know, the comments we had this morning about Design A and nuisance tripping, the safety issues with the higher temperatures. And I think the other thing would be the, the size of the motor may have to increase. The motor may have to get longer in order to reach the level of efficiency, in which case then it's no longer, in many cases, will be retrofit, so our customers will not be able to use the motor and it would force the motor to then be repaired and put back into operation as a lower-efficient, repaired motor, as opposed to moving to the more efficient1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 17

motor. MR. BROOKMAN: Okay. Thank you. Mimi, did you want a -- MS. GUPTA: Mimi Gupta. So, this is just in response to Roger's, and the question to Roger's comment. Technological feasibility isn't only that which is included in commercially available products, but also that which had been included in a prototype. So, I mean, had -- Do any of the technology options that were listed, have they, or do any of them qualify as not even being incorporated into a prototype motor to your knowledge? MR. BROOKMAN: Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. With regards to your question about prototyping, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- the burden of proof of prototyping is to determine whether or not something is feasible. MS. GUPTA: Right.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 18

DR. DAUGHERTY: The fact that some technology may have been used in a prototype but was never brought to fruition means that the manufacturer felt that it, that it wasn't really viable in product. So, I don't know why you would go back and ask manufacturers, "Well, what did you ever look at?" so that you, you'd examine what they may have looked at and use that as feasibility option. I, I mean, the manufacturer looked at it. He decided to rule it out. So, I, I don't know why you'd include prototyping. MS. GUPTA: Well, I mean, I can't say anything for the motor industry, but I know for other industries sometimes people might prototype products and they may determine on an economic basis it's not the right business decision to make it commercially available. So, DOE makes a separate assessment just in terms of determining technological feasibility. DOE looks at, you know, the full scope of commercially available products and product types,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 19 and makes a separate economic analysis. DR. DAUGHERTY: Roger Daugherty. Well, I guess I'd point you to my discussion on electrical steel. We did do prototyping using two different versions of the super-thin electrical steel, of which we decided that it didn't show the core close improvement it was supposed to provide. So, it wasn't a marketability, it wasn't a cost function, anything like that. It didn't work MS. GUPTA: Um-hum. DR. DAUGHERTY: And so I provided that same information to the Department, and, and it, in that sense, tried, to try to encourage you that you wouldn't get what you thought you would be getting. MS. GUPTA: Um-hum. DR. DAUGHERTY: And so -- But, again, we may look at many, many different things that don't come to fruition. It's not always whether or not it's marketable. It may just not work. And I'm not sure why we would want to be presenting information that1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 20 doesn't work, because, frankly, I don't have the

confidence it would be looked at the way that we, the determination that we show that it wouldn't work. MR. BROOKMAN: Okay, thank you. No? Yes, Frank. MR. LADONNE: Frank Ladonne, Underwriters Laboratories. I just want to, I guess, state something; maybe amplify comments that others have made; maybe put it in a little different way. And that is under the heading of "unintended consequences." I think that, you know, as we begin to raise efficiency levels, you know, there's going to be a tipping point. And, and I think the others have, have put the, put this in that you'll reach a point where, for the consumer, it makes more sense for them to have their existing motor, maybe the design and built in the '50s, rebuilt. You know, economically that, that just makes more sense. And since we're not regulating rebuilt motors, there's a, there's no consequence1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 21 to that except the unintended consequence that, you

know, as, as a country you're not achieving the energy levels that you think you're achieving because you're pushing people to have their motors rebuilt. One thought might be, well, then why don't we regulate, you know, rebuilt motors? And the problem with that is that you're never going to be able to take a motor that was designed and built in the 1950s, and bring it to, you know, 2000 or 2010 efficiency levels. And I -- So, I don't have a solution. I'm just pointing out there's a potential for unintended consequence, and recognizing that you may reach a tipping point. MR. BROOKMAN: Thank you. John. MR. MALINOWSKI: John Malinowski. We keep talking technical feasibility. We go back to Slide 36, with all these ideas about reducing losses and redesigning higher-efficiency motors. All these things are things we've been1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 22 doing for the last 30 years. These are not new to

the motor industry. I mean, we, we've done all this. We're, we're about as far as we're going to go. And, you know, we're just getting into the point where: Is it practical? Is, is it financially feasible? Is anybody going to buy this monstrosity once we design it? You know, we saw that in the small-motor ruling. We saw a motor that had an eight-year product life-cycle but the payback on it was 49 years. You know, but yet the ruling was made. I just hope we don't do that again here. MR. BROOKMAN: Okay, thank you. Let's proceed. ENGINEERING ANALYSIS MR. GORDON: All right, next up on the agenda is the engineering analysis. The purpose of this analysis is to establish a cost-efficiency relationship for electric motors, and in doing so, determine the efficiency levels for analysis. These outputs of the engineering1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 23 analysis are inputs into the life-cycle cost

analysis and manufacturer and employment impact analyses. These next slides describe the methodology that DOE plans to take in completing the engineering analysis. The first step is to choose the representative product classes from those discussed earlier. Then, for each of the representative product classes, DOE will define a baseline model from which it will assess changes due to more stringent Standards. Then DOE will choose electric motors to test, tear down, and determine the manufacturer's selling price of, that span the range of efficiencies currently on the market. DOE will also develop candidate standard levels that span the range of efficiencies. And finally, DOE will scale the results from the representative product classes to the product classes not directly analyzed. DOE will begin, begin the engineering analysis by choosing representative product classes that either consist of high-volume products or have the ability to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 24

scale to other classes. This chart from earlier shows four representative product groups that DOE proposes to use in the engineering analysis. Again, I say "group" because a product class entails choosing one horsepower and pole configuration to study as well. Group 4 here consists of the highest-volume motors they're NEMA Design B motors in a T-frame, 1- to 500-horsepower, and in the range of poles shown, and in the enclosed enclosure. Group 2 consists of U-frame motors, and Group 6 consists of Design C motors. In each of these three groups, enclosed motors are more common than open motors, which is why DOE's considering selecting them as representative product groups. Finally, because there isn't a big difference in availability between open and closed vertical solid-shaft motors, DOE is proposing to analyze open motors for Group 7. And I'll discuss how DOE plans to scale from these product groups to the remaining product groups later.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 25 DOE does not intend to analyze fire pump motors separately in the engineering analysis because the cost efficiency relationship is expected to be the same for these motors as it is for NEMA Design B motors. However, a separate economic analysis will be performed that takes into account the low number of operating hours that fire pump motors experience. In defining the baseline models, DOE chooses models that just meet the existing Standards. The models serve as reference points to assess changes due to energy conservation standards. Possible baseline models for the four product groups indicated earlier are shown here. While limited horsepower and pole ranges are shown, DOE plans to test a wider range by choosing additional representative product classes within these four groups. For Group 2, DOE proposes, chooses a Design B motor because they are more popular than Design A, and 4-pole and 7 and a-half horsepower again because of the high popularity of these1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 26

characteristics. For Group 4, again DOE proposes choosing a 4-pole Design B motor in 5 horsepower. Again, this was done by consulting a database of available motors and choosing the highest-volume one. Group 6 consists of a Design C, T-frame motor with 4 poles and 40 horsepower, and Group 7 consists of a Design B Vertical solid-shaft motor with two poles and 20 horsepower. So, at this point I would like to invite comments on these representative models chosen. Specifically, DOE welcomes comment on feasibility of covering such a wide range of horsepowers, and whether it is necessary to test and analyze motors at high horsepowers. MR. BROOKMAN: John Malinowski. MR. MALINOWSKI: Yeah, John Malinowski. If we would go back to Slide Number, I guess it would be 40-, 46, -- MS. GUPTA: Um-hum. MR. MALINOWSKI: -- what, what we would propose is that U-frames were something that was, was used in the automotive industry in the past.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 27 Both General Motors, Ford, and Chrysler, all three

of them have switched to T-frames. So, U-frames are really very low-volume, probably lower volume than fire pump motors. So, that, that's something that I wouldn't waste a lot of time on. Technically, the U-frame, it's in the next larger frame size than a T-frame for the same horsepower of the motor, and there should be no reason you couldn't design the same efficiency for that motor. So, you know, I, I wouldn't spend a lot of time on that. Vertical solid-shaft normal-thrust motors, again, the electrical design of that is a Design B motor. The only thing different about that is the bearing construction. And when we consider the efficiency of that motor, the normal test is that you can switch it out and put ball-bearing motor, ball bearings in the motor for test, which makes it -- You know, it should perform exactly the same as a Design B or a Design A motor of the same rating. So, again, why would you test? Why1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 28 would you need to do an economic study? Because, you know, you just really need to test -- (Whereupon, at 11:33 a.m. ET, Mr. Raba and a technician conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. MALINOWSKI: -- what you have there in the top up there, T-frame, Design A and B, open and enclosed, and Design C. And, and that's really about it. Fire pump, again, it's a very intermittent application. There's not a lot of energy used to do that. But, the vertical, vertical motors there really are a subset of the first part. MR. BROOKMAN: Okay. Thanks, John. Andrew deLaski. MR. deLASKI: I have a question for John, if I could. With, with respect to fire pump motors, John, you said very intermittent in operation. To your knowledge, how many hours a year is fire pump1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 29 motor operated? MR. MALINOWSKI: They normally -- John Malinowski. They normally test the motor a couple times am year. MR. deLASKI: Yeah. MR. MALINOWSKI: You know. And they run it for however many minutes -- MR. deLASKI: Yeah. MR. MALINOWSKI: -- and then it's going to run wherever there's a fire, which may be never. Hoping. MR. deLASKI: So, maybe 30 minutes a year. I understand. So, then the second question is: There were, I mean, hours of operation are, is, is clearly important for those motors, but are there engineering distinctions between a fire pump motor that are important to meet the application's needs? What, what are the specific engineering

-- A SPECTATOR: The number of starts. MR. MALINOWSKI: Yeah, the number of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 30 starts that Roger outlined today, eight starts

instead of two. MR. deLASKI: Uh-huh. MR. MALINOWSKI: But, by NFPA it's defined as a general-purpose motor. And some companies at one point had their general-purpose motor assigned with the NFPA approvals so that they didn't have to inventory two separate motors. MR. deLASKI: Right. MR. MALINOWSKI: You know. And that -- There was our concern, if you remember, when we discussed this. That was our concern: that if we deregulated fire pump motors and made them a lower efficiency, that a company could take that fire pump motor and use it for a general-purpose application. And this is how you get into regulatory problems on: How could you keep somebody from not doing that? You know, you walk in and there's a fire pump motor running a, a regular pump, or running a conveyor, or running an air compressor. You know, it's a lower-cost initial purchase for that company1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 31 that's replacing motors, and there's really nobody

looking to enforce that. I mean, it's, it's okay to build a fire pump motor, but we've not regulated where that motor can be used on the end use. MR. deLASKI: Um-hum. MR. BROOKMAN: Mimi Gupta. MS. GUPTA: Mimi Gupta. So, John, are you -- Is it -- Would it, would it be the correct interpretation to say that you're suggesting that fire pump motors and NEMA Design A and B motors be grouped into a single group with one efficiency standard? MR. MALINOWSKI: I think -- John Malinowski. I think your slide said that from an economic standpoint you can't justify doing anything with fire pump motors, and we concur with that. You know, leave them where they are. You know, they're at Table 12-11. That's fine. They don't run -- There's no usage on them.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 32

MS. GUPTA: Um-hum.

MR. MALINOWSKI: There's no hours run that would -- You know, raising the efficiency would just be, your, your life-cycle costs would be, you know, just -- MS. GUPTA: Um-hum. MR. MALINOWSKI: You know, your justification would show you that that doesn't pay back. What, what I'm, what I'm saying is U-frame motors -- MS. GUPTA: Um-hum. MR. MALINOWSKI: -- are also a low volume, and that I wouldn't spend a great deal of time looking at those. They're, they're only bought for some replacements, you know. But, technically they could be designed to Table 12-12. MS. GUPTA: Um-hum. MR. MALINOWSKI: But, the U-frame motors that many of us stock are to an automotive standard, which doesn't have a NEMA 12-11 or 12-12 table. For the GM Standard it's efficiency times power factor, and it has to meet a certain number.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 33 Now, with the EISA Regulation going into effect on those, we've had to raise some of the efficiencies of our General Motors spec motors so that they comply with EISA. They have to meet Table 12-11, which means they far exceed what General Motors wanted. But, they don't buy those motors anymore except for some old machines they've not converted to T-frames. They buy an IEEE 841 Standard motor these days. That's the standard of General Motors, Ford, and Chrysler. MR. BROOKMAN: Okay? MS. GUPTA: Well, my, my question was really directed at your concern of people who are using fire pump motors in general-purpose applications to, to circumvent the standard. Is, is that your concern? MR. MALINOWSKI: That would -- John Malinowski. That would be a concern that, that we would certainly have, but, you know, we're also concerned about a lot of, a lot of other things1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 34 that are flying under the radar that people are

getting around EISA Standards. And there's, you know, there's just nobody looking at motors. I mean, we're concerned about motors coming in from offshore-run equipment that nobody's looking at. But, you know, we're making all these Rules that grossly affect domestic motor manufacturers, but motor manufacturers overseas that sell motors to OEMs that build machinery that bring machinery in, nobody's looking at those motors. There's no -- There's nobody at Customs looking at those. MR. BROOKMAN: Andrew deLaski. MR. deLASKI: Just on the fire pump question, Mimi, I would just encourage DOE to look closely at the NEMA definitions and the definitions out there so that we can come up with a fire pump definition that is, you know, going to be -- (Whereupon, at 11:40 a.m. ET, Mr. Raba and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, during which the following occurred:)1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 35 MR. deLASKI: -- restrictive enough that you're not going to have fire pump motors, it's not going to be in the interest of the market to use that, and to define it, not in economic, but to define it in some kind of technical. And you know what it is. And you both know better than I do. And presumably it's buried at NABA somewhere, or some type of definitions. MR. BROOKMAN: Do we have an additional comment on baseline models, how that should be approached? Roger. DR. DAUGHERTY: Roger Daugherty. I guess when I look at your chart you have on the screen there I find it interesting that you selected enclosed motors as a baseline product, whereas within the framework document you make a statement that you'll be looking for the motor designs that have the lowest level of efficiency; of course, that meet the Standard. If you take the time to look at Table 12 dash-12 that EISA requires, or table 12-11, you'll1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 36 find that for a horsepower, horsepower and pole

configuration, that typically the efficiency of the open motor is lower than it is for the enclosed motor. And the reason for that is, if you go to Part 13 of NEMA MG 1, and look at the frame assignments for horsepower rating, you'll find that the reason for that difference is that typically the enclosed motor is in a larger frame size and sometimes, frame size number than the open motor. So, the more restrictive product, in trying to do an efficiency analysis, is the open motor. And, and usually within the manufacturer, whatever lamination for both the stator and the rotor that he's using, and maybe even the stator winding that he's using in that open motor is what he puts in an enclosed motor. So, I think you need to, need to reexamine whether or not you're going to be using enclosed motors as your baseline motors. The other I'm a little concerned about is that in Group 4 that you have listed there you're, you're covering 1- to 500-horsepower1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 37 T-frame, and you're selecting a five-horsepower

motor to do that. MR. BROOKMAN: Um-hum. DR. DAUGHERTY: I would just like to see that at least two models be selected to cover such a range, in particular because EISA separated those from 1 to 200, and 201 to 500. I think that if you're really going to check out your design analysis, you need to be looking at something that's above 200 horsepower as one of your baseline models to cover that category, because what you develop in techniques, you develop and increase in efficiency you might develop at five horsepower may not be so applicable when you get to that much higher horsepower. You've got a wide range of ratings you're trying to cover here, and to me, choosing a five-horsepower just doesn't fill the bill for that. MR. BROOKMAN: Okay. MS. GUPTA: Can I ask a quick question? MR. BROOKMAN: Yes, Mimi. MS. GUPTA: So, in terms of the open and1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 38 enclosed comment, Roger, so, just as a

clarification first of all, DOE was first intending to choose a set of representative product groups based on the highest volume, and that's why it chose the closed group. And then within that group, to choose the baseline unit, it would choose the lowest efficiency. So, that's kind of that, the reason why this was done. But, is, is that not true? Is the closed grouping not a larger volume than the open grouping? DR. DAUGHERTY: I see John Malinowski shaking his head, so I'll go along with that. MS. GUPTA: That is true? DR. DAUGHERTY: Like I said, if you choose a 5-horsepower open as your design analysis,

-- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- or, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- or a 5-horsepower closed, then your analysis of what you put into1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 39 that open design most likely will move over into

the enclosed design. But, achieving an efficiency level is more difficult in the open design -- MS. GUPTA: Right. DR. DAUGHERTY: -- than it is in the closed. And my concern is that you're reaching a conclusion in the enclosed, and you'll want to adopt that over into the open, which is the more difficult one to meet. MS. GUPTA: Right. So, -- Mimi Gupta. The intent is not to adopt a, more efficiency with the open as closed, but to, more to create a relationship and see if it's upon to create a relationship between an open efficiency and a closed efficiency. So, if manufacturers could provide us data to say that, well, an open motor is, on average, X percent less efficient than a closed motor, then once establishing a, an efficiency for closed motors, we could scale to open. But, Jeremy's going to ask that question later on in the presentation, if that's possible.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 40 DR. DAUGHERTY: Roger Daugherty.

I was going to say, that comes up later in the scaling methods argument. MS. GUPTA: Um-hum. DR. DAUGHERTY: And I'll probably try to hold off until we get to scaling methods to try to cover that. MS. GUPTA: Um-hum. MR. BROOKMAN: John, you're next in. Could you -- MR. MALINOWSKI: Maybe I'm getting ahead in the queue. John Malinowski. To answer your question on open, I think you'll see open motors used in smaller sizes. You know, you'll get into HVAC applications and compressors and sump pumps indoors. But, then you'll see the TEFC motors used over a wider speed range or a wider horsepower range. Just a comment here. We've got eight poles listed up there. At this time Table 12-12 does not contain an industry-efficiency rating for1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 41 eight-pole motors. But, we are working on that and

we hope to have something next year. So, we will have, amend the table and hopefully have something as a NEMA 12-12 eight-pole. When we're looking at motors through 500-horsepower in six- and eight-pole, even some 4-pole applications, we're getting above the normal frames defined by NEMA MG-1 that goes through 449 frame, and we're starting to get into some ratings that would be 5,000 frame and 5,800 frame motors that are above NEMA, what we would call large motors. There's not a mechanical standard for those. There are some de facto standards, but what you'll get from one manufacturer to the next manufacturer mechanically is going to be different, or could be different. The other question on all of this, which we brought up in the, the, on the thirtieth when we were last together, is: How are you going to test these? Maybe I'm getting ahead of things on the testing aspect of it. There's only one independent1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 42 lab that can test -- Kitt Butler can speak to this.

-- up through, today, up through 200 horsepower. Kitt? Or -- MR. BUTLER: Two-fifty. Two-fifty. MR. MALINOWSKI: Two-hundred and fifty horsepower. So, some of these larger horsepowers you won't be able to test. UL and NCA can test up through 60 horsepower. What they do on larger motors on that is they come to the manufacturer of the motor and they do a witness test using our NVLAP certified lab. And they test that and certify the data with a person on site during the test and witness test that. And that's common. Our customers do that. When they want a witness test, they send a representative to our lab and watch the motor being tested. And that's something that, that I think DOE should consider for these verification tests and, and whatever you do here on your, your testing for these products as well. MR. BROOKMAN: Okay, thank you.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 43 MS. GUPTA: Could I ask a question?

MR. BROOKMAN: Yes. MS. GUPTA: So, in terms of testing and determining efficiency of commercially available motors, how close is the catalog efficiency to what manufacturers might report to DOE? MR. BROOKMAN: Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. MR. MALINOWSKI: Let Roger talk to that. DR. DAUGHERTY: Well, the, the obvious requirement and information is in Part 431, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- where it's required that when a sample of motors, "a sample" being five, are tested for the purpose of certification by testing, that the average efficiency of the sample be within five percent, the total losses of the sample be within five percent of the total losses equivalent to the represented efficiency. MS. GUPTA: Um-hum. DR. DAUGHERTY: The -- Then, looking at it as a statistical distribution, there is another limit that's applied, and that's that none, none of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 44 the five motors that are tested in the sample, or

even if the sample's larger, no motor of the sample shall have an efficiency that's lower than the, the efficiency based on 15 percent additional losses. MS. GUPTA: Um-hum. DR. DAUGHERTY: Then when we move into the enforcement area and go to Subpart -- And these move around now, and it was something like that one time for the enforcement, then it's recognized that, depending on where the motor is tested, that going from one facility to another, there's another influence on results. MS. GUPTA: Um-hum. DR. DAUGHERTY: And so the, the requirement under the enforcement is 20 percent additional losses to, to account for that difference. So, we have, we have three numbers that we really work with. As far as the NEMA standard is developed, then we have the NEMA nominal efficiency, which is in Table 12 dash-8, which is the basis of the 12 dash-11 and 12 dash-12 values that are in that, those tables.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 45

MS. GUPTA: Um-hum.

DR. DAUGHERTY: That has an associated nominal efficiency. And associated with all of those is an efficiency based on that 20-percent difference that might occur because of differences in materials, processing during manufacturing, testing, and where it happens to be tested, that kind of variation. So, we, we try to keep very close and very close tolerance. So, your best guidance right now is the five percent on average that's in Part 431, the 15 percent that, that no motor test below that. Now, how can a manufacturer say with some confidence that it meets that? Well, it may be that if you build a motor and it exceeds that 15-percent or 20-percent minimum that's in, in NEMA, it may go down the production line like that, but when it hits testing before it would, even would leave the door, it gets caught. And so through, through the testing of every motor that's built it weeds out those that are outside that statistical distribution. So, we1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 46 actually chop off those statistics right there at

that 20-percent mark. MS. GUPTA: So, -- Mimi Gupta. Am I hearing that the DOE compliance provisions are slightly different than the NEMA Standard, and therefore what's in the catalog may not correlate exactly to what you, what manufacturers would report in compliance? Is this -- Is that what I'm hearing? DR. DAUGHERTY: Roger Daugherty. No, I'm not saying that. MS. GUPTA: Oh, okay. Sorry. DR. DAUGHERTY: One, one of -- No. What, what I'm saying is that back in the 1990s, when Department of Energy met with NEMA -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- and met with manufacturers, and we actually had worked, we had reformed a Working Group on the measurement of motor efficiency, and that included a representative from NIST who was working on Handbook 150 dash-10. I happened, I happened to chair that1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 47 committee during its work. Under that committee we

developed a, a committee on looking at testing, and did a round-robin test. We looked at another committee that was looking at some other efficiency issues. Based on all that work, and knowing that we had the NEMA Standard that said that there was a minimum that was associated with each nominal, the conclusion of that effort that went into Part 431 was that, okay, that defined minimum to nominal, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- and now we had to figure out that you did a sample testing, what allowance was, was permitted of the average of the sample -- MS. GUPTA: Right. DR. DAUGHERTY: -- to the average of the population. MS. GUPTA: Um-hum. DR. DAUGHERTY: That's where the five percent was finally settled on, saying that if you took a group of motors, tested them in the same facility on the same test equipment to try to rule1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 48 out variability between locations and things like

that, the average would come out that well. Then we settled and said, well, the 20-percent difference, that includes testing at different facilities. So, what, what that Working Group and DOE finally concluded with on 431 was the 15-percent number, saying for the purpose of compliance, where the manufacturer's usually testing in a certain facility, then we will limit the minimum to 15 percent. Then, when we go into the enforcement, that enforcement testing may be being done elsewhere, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- and therefore they recognized the total that's in the NEMA Standard and went to the 20 percent. MS. GUPTA: Okay. MR. BROOKMAN: Boy, we're getting into a lot of depth, but I think -- MS. GUPTA: It's helpful. MR. BROOKMAN: Okay. Just wanted to confirm.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 49 Yes, John. Get into some more depth, please. MR. MALINOWSKI: One more, one more, one more clarification about this. John Malinowski. Your question about if you took a motor out of inventory would it test the same, and chances are maybe not. The finished motor may have some options on it, such as shaft seals, which would create additional friction. It would have full-production amount of grease in it. It could be a vertical motor that has angular packed bearings or roller-bearing motor. And those, of course, add to losses. The IEEE test says we can test a motor with the slush coat on the bearing. We don't have to have full, full amount of grease in the bearing. We don't have to have seals in it. We don't have to have roller bearings, nor do we have to have angular-contact bearings in it. So, what you get off the shelf that's all set up for a particular application may not test like the motor would if it was a1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 50 general-purpose motor. We're using a

general-purpose winding in that motor, but with these additional mechanical enhancements for a specific application. So, it will test at a lower efficiency, okay? MS. GUPTA: Okay. Thank you. MR. BROOKMAN: Okay. Thank you, Roger. Follow on? Same stream of content. Keep going. DR. DAUGHERTY: Okay. Roger Daugherty. Just one other thing to clarify that, since it hasn't been mentioned, and that's that the, the efficiency that's marked on the motor nameplate in accordance with the NEMA Standard is NEMA, NEMA efficiency, which comes, as I said, is a set of values that are selected from Table 12 dash-8. Now, when I'm doing a design a population of motors of the same design, let's say within that table, I have two efficiency levels to choose from, 94.0 and 94.5. MS. GUPTA: Um-hum.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 51 DR. DAUGHERTY: If I come up with a design that comes up to 94.4, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- according to the NEMA, the efficiency that can be marked on a motor cannot be higher than 94.0. So, in actuality, most nominal ratings that are on the motor are probably, most likely lower than the actual average of the population of motors in that design. And so that respect, and using DOE terms, that benefits the consumer, that in all likelihood the consumer, if he purchases a large population of motors, then the average of the population will be at least equal to or greater than the nominal value that's on the nameplate. MS. GUPTA: Thank you. MR. BROOKMAN: I want to make sure we get through the remainder of the slides so we stay on schedule before lunch. So, Jeremy, keep going. MR. GORDON: All right. Next, DOE will identify higher-than-baseline-efficiency motors to test, and will do so using a database of available1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 52

motors. These will be used to fill in the cost

versus efficiency curves for each motor group. In choosing these models, DOE will evaluate all design options that are available, including prototypes and proprietary designs that do not present a unique path to a given efficiency level. DOE welcomes, welcomes comment on whether there are any proprietary designs currently in use in any commercial products that DOE should consider. MR. BROOKMAN: John. You know, John, you'd be welcome to just sit right up there at the table and you wouldn't have to -- MR. MALINOWSKI: Yeah, maybe that's it. John Malinowski. I guess my question here would be, using a database of commercially available electric motors, if you're referring to Motor Master, I wouldn't put a whole lot of faith in the data that's there because it's not maintained very well. Secondly, along the same point, all of the motor manufacturers have rede-, -- You know,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 53 many of us have redesigned our product lines to

comply with EISA, and made efficiency changes in motors to comply with EISA. So, some motors may be raised; some lowered. Who knows. The Motor Master data that was used by CEE to come out with their efficiency program to rebate above Table 12-12, of the 120 motors they represented from Baldor Electric Company, 80 of, of the motors had incorrect data. So, that's the credibility of the data that's out there on Motor Master, okay? And, again, you know, I mean, we can work with you individually, perhaps, on, you know, giving you some designs. There will be some designs that are maybe a, one NEMA band above, or maybe some that are two NEMA bands above, but those are probably pretty rare these days. MR. BROOKMAN: John, that incorrect data, was it simply because the data was not updated? Or, what happened? MR. MALINOWSKI: Yeah, it's probably not been updated for too long.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 5 4 MR. BROOKMAN: Okay.

MR. MALINOWSKI: And we've been in contact with them from our company about the need to, you know, send a call out to all the motor manufacturers for update data so that we can get it updated and in compliance with the levels for EISA. MR. BROOKMAN: CEE, or somebody maintains a list with the data, and it's just not being updated? MR. MALINOWSKI: No, not CEE. Motor Master. MR. BROOKMAN: Motor Master. Okay. MR. MALINOWSKI: And that's our friends out in Washington. MR. BUTLER: Kitt Butler, with Advanced Energy. Washington State University's energy program is a contractor to the Department of Energy to, to keep the Motor Master software database up to date, and they rely on the motor manufacturers to submit them data. (Whereupon, at 12:01 p.m. ET, Mr. Malinowski and Dr. Daugherty conferred, out of the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 55 hearing of others and off the Record, during which

the following occurred:) MR. BUTLER: Whether or not that's not working well, I'm not commenting on. That's the process. And I believe the data that was used by CEE was an older version of Motor Master, but there currently is a newer version available today. MR. BROOKMAN: Okay, that's helpful. Mimi Gupta. MS. GUPTA: Yeah. And just as a note, we, we weren't actually referring to Motor Master. DOE is working separately on kind of extracting catalog data from manufacturers' late, latest catalogs to develop this commercially available database. But, you know, if there's any updates on what, your product offering, offerings that aren't represented in your latest catalogs, we definitely appreciate that information. MR. BROOKMAN: Okay. So, keep going, then, Jeremy. (Whereupon, at 12:02 p.m. ET, Mr. Malinowski and Ms. Gupta conferred, out of the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 56 hearing of others and off the Record, during which

the following occurred:) MR. GORDON: DOE will develop manufacturing and production costs by tearing down and making a Bill of Materials for each motor. Manufacturer markups will then be applied to calculate the selling price of each motor. DOE may also supplement this process by collecting data from manufacturers and conducting manufacturer interviews. Then we invite comments again on the approach proposed to calculate the manufacturer's selling price. MR. BROOKMAN: The approach itself. Okay, John. No rush. MR. MALINOWSKI: Okay. MR. BROOKMAN: Okay, I'm serious. We -- Yes. Okay. Okay. MR. MALINOWSKI: Keep going. I mean, we'll -- I mean, go ahead. MR. BROOKMAN: Okay. If we, if we give any of this short shrift, we'll return to it if you have additional comments, especially when you1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 57 return from lunch, for example, okay? So, keep going. MR. GORDON: Okay. DOE will then develop candidate standard levels that span the range of efficiencies from baseline to maximum technologically feasible level, or max tech. Maximum available may not correspond to max tech if some design options are not commercially available. DOE will seek input from interested parties to develop max--tech efficiency and cost, and this max--tech level may be calculated using modeling software. DOE invites comment on any software packages that may be appropriate for this type of modeling. MR. BROOKMAN: Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. I just comment with regards to software. I'm not aware of any commercially available package, particularly one that would look into some of the high technology areas that, that you've been talking about. And this was of particular concern to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 58

the motor manufacturers in the small-motor

rulemaking, that, that choice of software that was being used, because when the first sample -- And it also relates to your sample testing. When you first tested a sample of motors of the baseline models and compared them to the software, you reached a conclusion that the accuracy of the calculation of total losses was reasonable with respect to your sample. However, your sample that you had tested had efficiency very high compared to what the manufacturer represented as total efficiency. So, that was challenged at one of the public meetings, and DOE went back and increased the sample size to five, and now their average efficiency from that sample was more in line with what the manufacturer had indicated the nominal efficiency was. But, as a consequence to that, then, you were left with the condition that the software was now predicting losses which were very significantly lower than the value your test actually supported, which left DOE in a position that in the end, in the final Rule, that DOE arbitrarily just changed1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 59 the value of total losses coming out of the

software, or to increase them to try to make them line up closer to sample. That's not the purpose of software. When you calculate the total losses from your software, that's supposed to be the number you arrive at. The manufacturers use AEDM, Alternative Efficiency Determination Methods, as described in Part 431. Those get verified against sample testing of at least five basic models, testing five of each, and showing that the total losses as calculated is within ten percent of, of the average of the samples in order to be able to use that. We asked why that wasn't applied to the software the Department was using and just received information that that wasn't necessary; it didn't need to be that accurate. Well, as I say, that's a very serious concern to the manufacturers. So, I encourage you that if you look into external software, whatever you look at, that you be certain that it's capable of, of meeting the verification requirement for efficiency of an AEDM1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 60 that's required in Part 431. And I encourage it

specifically when you try, if you try to look at the high technology electrical systems, as you did in the small-motor rulemaking, as I've indicated earlier, for which core losses were very different than you were reporting in any of the analyses that you were doing. The -- A couple of other points that I, I had noted on that software was that the, some of those supposedly higher efficiency designs indicated that there was a lack of understanding on how to account properly for the effects of using new materials or design changes which had not previously been modeled in the software or, and verified by testing. So, just, just because you, you get, in one instance, some Epstein data, doesn't mean that that software is going to accurately represent that particular material. And, and you need some support information as you look at how to do that in the software. It also became evident, software used for the small electric motors did not include1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 61 analysis of thermal characteristics of the motor to

properly evaluate the temperature rise at rated load and service factor if applicable. Now, in, in the open motors in Table 12 dash-11 and 12 dash-12, if you go to Part 13, that Standard for open motors has a service factor rating of 1.15. And so thermally they're evaluated there. The enclosed motors have a standard service factor of 1.0, although most manufacturers probably provide 1.15 as their standard basis. So, I guess all I'm trying to say is that, that in this day and age, and with AEDMs having been in use for about 15 years, and verified through the DOE's requirements, that I encourage that any software that you use be able to meet that same standard of verification to give some confidence in the levels of the losses that you're actually calculating and projecting for any future increases. Thank you. MR. BROOKMAN: Thank you. John? MR. MALINOWSKI: John Malinowski.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 62 On software, again I'd emphasize you need to be very careful on how you do this, and, and hopefully select somebody that understands it better than the fellow that did the small motors. One of the people you might contact is professor Kirtley (sic) at MIT. His spelling is K-i-r-k-l-e-y (sic). MR. BROOKMAN: Kirtley. MR. MALINOWSKI: Kirkley (sic). MR. BROOKMAN: T. MR. MALINOWSKI: He's a professor at MIT, and he does a lot of courses on how to design motors, and, and would fit into that scope. When you look at designing, tearing a motor apart and looking at costs for the, a motor, I guess I'm real concerned about that in, in the idea that there's so many different motor manufacturers, how do you get a real feel of how they're built? There's not that many motor companies within the United States anymore. A lot of products are made in Mexico, Brazil, China. A lot of equipment comes in from Europe1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 63 made in Italy, made in Germany. A lot comes from

India. Rather than focus on the motor manufacturers just in the United States that may have a fair amount of automation and a lot of additional cost from, from that, you need to look at the hand-wound motors from China, where you see motors coming in that are -- Well, we can't talk about price, but from a, a market standpoint you kind of scratch your head and try to understand the whole thing. It's, it's really tough because of vertical integration of each company. We've got one company in South America that's hugely vertically integrated that, that has foundries, makes their own rosins for their varnish, makes their own copper magnet wire, hugely vertically integrated, to companies in Europe that basically buy part sets and just have somebody wind motors and then they assemble them and, and sell them here. So, there's huge differences in, in the companies you're going to look at, and the costs1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 64 of, of building these motor designs. So, just be

very careful that you look at a wide enough range, rather than the main players that are in the United States. MR. BROOKMAN: Thank you. We're going to keep going on here. MR. GORDON: Great. All right. The final stage of the engineering analysis involves scaling from the representative product classes to -- MR. BROOKMAN: Go ahead. Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. I guess just making a comment. You had Item 11 on that same slide -- MR. BROOKMAN: Yes. DR. DAUGHERTY: -- with the Item 10. And I just note under 5.2.2, under "Methodology," you write the motors will be tested for efficiency according to the appropriate DOE test procedures for electric motors. And you reference 10 CFR 431.16. I only note that the actual test1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 65 procedure, the actual procedure for determination

of efficiency is in 431.17. While the test procedure may be in -16, the actual method for determining efficiency is in -17. And I bring that up because that calls into samples and average efficiencies and all the things we've been talking about. MR. BROOKMAN: Okay. Okay, thank you. MR. GORDON: All right. Final stage of the engineering analysis involves scaling from the representative product classes to all other classes. DOE intends to establish a scaling relationship from closed to open motors as is shown by the vertical arrows. As mentioned before, DOE also intends to scale from NEMA-designed B motors to fire pump motors. This plot shows losses versus horsepower for open motors with two, four, and six poles. As is shown, losses decrease lineally with horsepower when plotted on a log-log graph. As described in more detail in the framework document, DOE intends to scale between1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 66 horsepowers, using a power law equation. A

different equation would exist for each pole configuration and enclosure type. Due to the number of product classes, however, scaling across horsepower is not enough. DOE seeks to be able to also scale between pole configuration and enclosure type, and welcomes comment on how it may do so. MR. BROOKMAN: Roger, do you see the two comment boxes there? Please. DR. DAUGHERTY: Roger Daugherty. This is with respect to Item 15. I note from your figures that you have the thing 0.27 exponent observed from plotting percent losses versus horsepower, and that's, that's percent total losses. And that's based on the motor designs using present materials and present relationships between the five different losses in the motor. As you investigate changes in the materials and changes in the design which may result in a change in a relationship within those five losses to the total losses, I'm not certain that you'll find that1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 67 that 0.27's still applicable. That would be one advantage, certainly, of, at least for the T-frame motors, of choosing at least two baseline models to try to cover not only the wide range, but it will help give some confidence in what you're using for this. Another is that it's noted from your figures that this, the C factor that you're using for Figure 5.1, which I think is the figure before this present slide, is 23.4 for two-pole motors, open motors. It's 18.0 for four-pole. And then somehow you're saying that you're able to scale that, while your figure shows that for a six-pole it's 17. I'm not sure how you get from 23.4 on two-pole, 18 for four, and end up at 17 for six in the scaling rule. Nor is it clear how DOE intends to use the efficiency of any representative units of a single pole number to scale to the efficiency of other pole numbers when Figure 5.1 clearly shows that the efficiency of six-pole motors is between that of two- and four-pole. And if you check, Table 12-11 in NEMA,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 68 MG 1, that's referenced in EISA, will show this

relationship is more difficult when it includes the efficiency level of eight-pole motors. Part of the reason for this, again, is the difference that's found in Part 13 in the frame sizes that are used in the motors for the different horsepower levels in full configurations. MR. BROOKMAN: Mimi Gupta. MS. GUPTA: Mimi Gupta. So, it's not clear because we're not clear yet. We're not sure what, what the best way's to scale to what all these different configurations are. And if you have any suggestions, the Department would really appreciate it, on, on the best way to scale. DR. DAUGHERTY: Roger Daugherty. At this time -- I've never done this kind of scaling, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- so I don't know how. I was only going on your comment that you were going to use two- and four-pole, and scale to the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 69 others related to the C factor, and I didn't see

how you could get to, from two values of two- and four-pole, and end up with the factor you have for six-pole. MS. GUPTA: So, when NEMA derives its efficiency, do they derive each efficiency separately, or is it -- MR. BROOKMAN: Separately derived. Yes. Okay. MS. GUPTA: Okay. MR. BROOKMAN: Okay. MS. GUPTA: Well, I mean, if, if you guys can provide any guidance on how to extend a representative unit analysis to the full table, you know, in your written comments, we would really appreciate it. MR. BROOKMAN: John. MR. MALINOWSKI: John Malinowski. The tables were done by consensus, just as we're doing the eight poles. We'll do a survey of all the members and come up with numbers that everybody feels are reasonable. MS. GUPTA: Um-hum.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 70 MR. MALINOWSKI: And the scaling, you can't do it necessarily by horsepower -- MS. GUPTA: Um-hum. MR. MALINOWSKI: -- because between opens and total enclosed, as Roger said, they change frames sometimes. MS. GUPTA: Um-hum. MR. MALINOWSKI: We can only have a maximum stack length of so much that will fit in a frame. So, you can't say, "Well, we can add 20 percent more stack and, you know, make something." There's not room in there for it. And, we can't make it from a production standpoint. We don't want people out there hand-winding motors. You know, we can't be competitive by doing such production method. So, they could be scalable if they were in the same frame, perhaps, but then you get: How much more material can you do? And then you get to the idea that, well, we can make a higher-efficient motor if we jump frame sizes and go to the next larger frame just by D-squared-L. It works better, but then that frame1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 71 is no longer retrofittable to motors that are

already in the field. I can't take a five-horsepower motor in a 210 frame and fit it in where the population is in a 180 frame. Not going to work. So, you know, there's limitations you're going to run into as, as you do this. MR. BROOKMAN: Roger. DR. DAUGHERTY: Roger Daugherty. To follow along that line in your, your question about scaling, just, just note that the valuation of efficiency that you've used in, in deriving this total losses in this plot in Figure 5 dash-1, you've based these taking them from the Standard. MS. GUPTA: Um-hum. DR. DAUGHERTY: And the Standard is NEMA nominal efficiency values. And so you're, you're sort of representing the slope of a standard, not the slope of an actual population of motors. Then the, the, the problem I see is that we, we have to, to remember that in accordance with the congressional law, and in accordance with, as1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 72 it was interpreted in Part 431, the efficiency on

the motor is NEMA nominal efficiency. And so when you look at what higher level of efficiency may be possible, and you scale one of these values from this table, which are NEMA nominal, up to some higher level, I, I, I guess I can't emphasize enough that the final value you end up needs to be a NEMA nominal. MS. GUPTA: Um-hum. DR. DAUGHERTY: And there's nothing in your scaling method that says you're going to end up at NEMA nominal efficiency. But, that is the marking that's required on the motor since 1992, written into the final Rule in 1999. That's what we've worked with since it was developed back in, I don't know, the '60s or '70s, when it was all put together. So, regardless of how you do scaling and what you end up with, you need to give consideration that that final selected value is a NEMA nominal out of Table -- And I, I misrepresented before. It's Table 12 dash-10 now. I'm still stuck on the small-motor Rule when it was 12 dash-81 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 73

back in 1997. So, just concentrate. If you do any scaling, arrive at some value at, from your baseline models moving it to other ratings, that the final values you end up in a table are NEMA nominal. And that's not to suggest that if you end up at 94.3 as being possible, in the NEMA nominal the closest to that is 94 and a-half. That doesn't mean you can achieve 94 and a-half, -- MS. GUPTA: Um-hum. DR. DAUGHERTY: -- just by rounding it up. It would have to be rounded down to 94.0. So, please take that into consideration. MR. BROOKMAN: Yes, John. MR. MALINOWSKI: And when you start doing the analysis of these motors and you look at slot fill, there's no such thing as 100-percent slot fill. You guys know that already. I think, you know, 80, mid-80s is probably -- Roger, you know. DR. DAUGHERTY: Roger Daugherty.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 74 The -- If you could achieve 80 you're heading toward hand-winding, most definitely. In machine winding, somewhere in the 70-, 75-percent, maybe pushing it a little bit higher. But, -- And it depends on what kind of machine winding technique you're using. There's machine winding where you form the coils and then insert those by dropping them into the slots. There's also a machine winding technique of what we call "bobbin" that actually winds right down the slots and wind, the winding right in the slots. And you get different winding on the technique. So, again, that's something you can ask the manufacturers when you do your survey. But, encourage you to take what they say with a good deal of respect. MR. BROOKMAN: I'm going to move to the next slide and finish this, because we're shortly going to pause for lunch, just so everybody knows. MR. GORDON: DOE also considered the effects of outside regulatory changes, and invites comment on whether there are any to consider in the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 75 engineering analysis. MR. BROOKMAN: Outside regulatory changes in addition. Yes, Roger. DR. DAUGHERTY: Roger Daugherty. I'll only note that there are regulatory requirements in the NFPA 70, the National Electrical Code, covering Design B, C, maybe D, and Design A motors. And, of course, we also have NFPA 20 on the fire pump motors that we need to be certain to be in compliance with. MR. BROOKMAN: Okay. Other comments on other regulatory activities? (Whereupon, at 12:24 p.m. ET, Mr. deLASKI and Mr. Malinowski conferred, out of hearing of others and off the Record, during which the following occurred:) MR. BROOKMAN: I see -- Pardon me. I see none, so it's now 12:25. We've really covered a lot of ground in the morning. I'm going to suggest we pause for lunch. (Whereupon, at 12:24 p.m. ET, those present took a brief recess and returned at 1:271 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 76

p.m. ET, after which the following occurred:) MR. BROOKMAN: Let's, let's resume. Please take your seats. So, we are going to pick, we're going to pick up where we left off, which I believe is on 58. MR. RABA: Fifty-seven, maybe? MR. BROOKMAN: Pardon me, 57. MS. IYAMA: He's going to figure out how to move this slide forward. Okay. ENERGY USE ANALYSIS MS. IYAMA: Thank you. Good afternoon, everyone. I hope you had a nice lunch. Sanaee Iyama, from the Lawrence Berkeley National Lab, and I will go through the five last sections of the Preliminary Analysis, starting with the energy use. So, the purpose of the Energy Use Analysis is to assess the annual energy use data for the electric motors based on field operating conditions. And this data will feed into the LCC calculation, life-cycle cost, and payback period calculation.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 77 The method that DOE will use will rely on calculating average energy use values based on typical motor operating profiles associated with different motor applications such as compressors, fans, or pumps. Variability in the field will be taken into account by using probability distributions for operating hours and motor loading data. We'll be also looking at reactive power demand because this has an impact on the life-cycle cost. We have a couple of issues where we, we would like to request comments from stakeholders. The first one is related to any data or sources of data related to the typical motor applications and associated end-use profiles. We are also interested in information on whether or not the end-use operating profiles associated to each application vary depending on the product class that we're looking at. (Whereupon, at 1:30 p.m. ET, Mr. Raba and a technician conferred, out of the hearing of others and off the Record, during which the following occurred:)1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 78 MS. IYAMA: Finally, we're also interested in comments regarding motor repair practices and their impact on motor energy use, and on any other aspect that might impact the energy use of the electric motors. MR. BROOKMAN: So, as is always the case, the Department is on a search for data. Comments on these comment boxes? (Whereupon, at 1:30 p.m. ET, no response was had.) MS. IYAMA: Okay. Well, I'm going to move on for -- MR. BROOKMAN: Wait just a moment. Bob? MR. BOTELER: This Rob Boteler. I don't think we're ready to comment today so much, but the members of the Motor Generator Section have been looking into the possibilities of a market study to get some of the data on hours of usage and the impact on the end market, and we would, we will be discussing that a little bit more tomorrow. And I guess one thing that we would1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 79 question or ask: Is there a possibility of DOE

participating with the NEMA in this study, and, and sharing in the costing and the, the outcome of the data? MR. BROOKMAN: I see. And, and aside from the cost, can you say what other level of participation you'd expect? MR. BOTELER: I think it would be something where we would develop a series of questions that we would ask of the end users in the marketplace. (Whereupon, at 1:31 p.m. ET, Mr. Raba and Ms. Grace-Tardy conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. BROOKMAN: And is that because you wish to maintain advocate -- MR. BOTELER: Through a third-party. MR. BROOKMAN: -- through a third party as perhaps is done with the interviews, that sort of a form-, format? MR. BOTELER: Yes. MR. BROOKMAN: Well, that's --1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 80

MR. BOTELER: Ami Grace doesn't have a good look on her face. MS. GRACE-TARDY: I was just going to say, can we discuss this at a break after this meeting? MR. BOTELER: Yes. MS. GRACE-TARDY: Okay. MR. BROOKMAN: Charlie Stephens. MR. STEPHENS: Charlie Stephens. Two things. One is, we had talked this morning about potentially expanding the scope of the coverage in this rulemaking, and so we would like to express an interest in having whatever study is done cover some of those additional motors that are outside the current scope. And the second thing is -- MR. BROOKMAN: But, Rob, is that what you were thinking? Rob's nodding his head, "Yes." MR. BOTELER: Yes. MR. BROOKMAN: Go ahead. MR. STEPHENS: I don't know whether this is the area or not, but my organization has a substantial budget to contribute to that, so we1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 81 would be glad to. MR. BOTELER: Duly noted. MR. BROOKMAN: And that would be for a national study, not a Northwest study? MR. STEPHENS: We could probably arrange that. MR. BROOKMAN: Okay. Thanks, Charlie. Good. So, there were several -- Before we move on, there are several comment boxes here. Take a peek to see if anybody's got, can comment now on any of the following. Roger Daugherty. DR. DAUGHERTY: Roger Daugherty. Just when you were sort of reading Item 1 you threw in something about repair. Could you go a little further? Because -- MS. IYAMA: Item 20? DR. DAUGHERTY: It's Item 20. MS. IYAMA: Because we're going to be looking at energy use on, based on field operation, and we are also interested in knowing if any motor repair practices or maintenance practices has an impact on motor efficiency which indirectly impacts1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 82 the energy use, that, that would be something we

would like to know in order to, to model the energy use more accurately. MR. BISHOP: Tom Bishop. In reference to that, there was a study that was performed in the early 2000s by and for a different EASA, Electrical Apparatus Service Association and the Association of Electrical Mechanical Trades in England. And that study, in fact, was sponsored in part by the DOE. At any rate, that study did annualize the effect of motor repair on, on motor efficiency. So, that, that study, that report is out there. If someone wants a copy of that, I've got a few copies of that with me. MR. BROOKMAN: Excellent. So, then will you send that to Jim Raba at the Department of Energy? MR. BISHOP: Oh, yes. I -- Tom Bishop. I can send that to you, Jim, in hard copy here, and also e-mail you the electronic version. MR. RABA: Thank you.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 83 MR. BROOKMAN: Okay, Charlie Stephens.

MR. STEPHENS: Charlie Stevens. My organization also may have up to eight years' worth of data from our motor rewind program that we may be able to make available. I don't know exactly what's in there, but whatever there is is public so we can make that available. MR. BROOKMAN: Great. Okay, thank you. (Whereupon, at 1:35 p.m. ET, Mr. Raba and Mr. Bonnett conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. BROOKMAN: Okay, then moving on. MS. IYAMA: Thank you. So, next I'll be covering the markups for equipment price determination. MARKUPS FOR EQUIPMENT PRICE DETERMINATION MS. IYAMA: The purpose of this analysis is to assess consumer motor, motor prices based on manufacturer costs, and to characterize the motor distribution channels. The, the method that DOE will use is to identify markups for each of the parties involved1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 84 in the distribution channel, and to use these to

convert the manufacturer costs, -- (Whereupon, at 1:36 p.m. ET, Mr. Raba and Mr. Bonnett conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: -- which will be the output of the engineering analysis into consumer, consumer motor prices. And we'll be also looking at retail price data for validation purposes. (Whereupon, at 1:36 p.m. ET, Mr. Bonnett and Mr. Gordon conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: In terms of a sources that we'll be using in order to assess the distribution channel markups, which include original equipment manufacturer markups, distributor markups, and contractor mark-, markups, we'll be using data from the U.S. Census Bureau as well as from RSMean. And, we intend to be looking at three different motor segments when identifying the distribution channels. The first one would be the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 85 new motors, then replacement motors, and also

upgrades. We have some preliminary indication that we have, that there is, there could be six distribution channels, which are illustrated on this chart here. And based on a previous DOE study from, from the '80s, there's indication that the share of motors sold through each of these channels varies, depending on different criterias. One of them could be the horsepower. For example, motors included between 1 and 20 horsepower are mostly sold through, to the end user through OEMs, whereas for larger motors it's, it represents a, a very small percentage of the shipments. Any comments on the distribution channels on the key stakeholders, on the typical markups and overall markups applied throughout the distribution channels as well? MR. BROOKMAN: I guess, Rob. Sorry. MR. BOTELER: Sorry. MR. BROOKMAN: Rob first. MR. BOTELER: Rob Boteler.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 86 We're all business people here, and we are competitors, so we're not going to talk about price. But, I'll tell you just one thing. I've been doing this marketing thing for a long time, and one of the things I've learned early is cost doesn't determine price. Market conditions drive price. So, if you think you're going to go back and you're going to establish cost of motors based on the amount of material or guesses of labor, guesses at burden rate, which is all going to be, as we pointed out earlier, going to be all over the map, and then you're going to extrapolate that and think you're arriving at true market levels for any of the distribution channels, you are gravely mistaken. You are not. We all compete with each other all day long based on opportunity and availability, costs of the moment, and some cases we sell product and we make very substantial margins on it. And the next day we sell very similar product and we make very little margin on it,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 87 depending on what's going on in the marketplace,

how many competitors we have in that particular job. So, trying to set up a spreadsheet and tell us you're going to come up with an average margin and average selling price, it's not going to happen. We're not going to have believable numbers when you bring them to us, no matter what you do. MR. BROOKMAN: What about the distribution channels? How have -- MR. BOTELER: The distribution channels, we, as motor manufacturers, we would sell -- Would you put the channel back? Motor manufacturers selling direct to the end user, I only know one motor manufacturer's numbers. But, it's less than one or two percent of our total number of units. Selling to a contractor, I'm not sure how you define a contractor, but I'd say the same thing: Less than one or two percent. If we look after typical, distribution typical power shocks, like Tom's group or that,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 88 it's about 50 percent. And OEMs are, are about 50

percent, and it's going to vary a little bit from manufacturer to manufacturer because some of us build more of one type of product than the other. But, by and large, we don't send to end users and we don't sell to contractors. MR. BROOKMAN: Yeah. I have notes that John's wanting to comment, also. MR. MALINOWSKI: John Malinowski. Yeah, I think I'd probably take the contractor off that. The manufacturer would be gone. Typical sales channel would be distributor or OEM. I would also categorize distributor as -- Split that in half. You would have shops like EASA shops, motor-repair shops on the one side of the distributor group, and on the other side of the distributor group you have national distribution chains likes Motion Industries, Command, Applied, all the big nation-wide distributors. And, you know, that may be split somewhat evenly between there, 50 percent to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 89 distribution, 50 percent to OEM. I would also not categorize one- to 20-horse motors necessarily as being one place or the other. A lot of motors in that size go into HVAC, but -- in conveyors and a lot of the other things on the OEM side. But, at the same time there's an OEM market for those over on the distributor side. So, you really can't categorize one place or the other. Smaller motors are not rewound as commonly as larger ones. Tom can probably correct me, but I think an ACEEE number, an old number was one motor sold for every ten repaired. MR. BISHOP: I don't know. Five percent. MR. MALINOWSKI: Five? Well, anyway. MR. BOTELER: Five. MR. MALINOWSKI: Well, anyway, if it is, I mean, even one to five, and, you know, just don't get too -- As Rob says, don't get too wrapped up in your numbers on -- We can't talk about price. We are competitors. We've got -- We would have NEMA's legal counsel down on us, as well1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 90

as yours. You know, we sell value; we don't sell

price. We find a lot of it, offshore people selling price more than value. As the new laws come up, what may be more, more common is selling availability rather than anything else, because there may be some motor shortages as we, as we come through this adoption of the EIS-, of the EISA law in December. MR. BROOKMAN: Molly, let's let Rob continue. Yes. MR. BOTELER: Rob Boteler. Maybe just to carry on with that, maybe I didn't explain when we talk about the retail placing one of the things. You know, there's an assumption, I think, on the part of the Department that we sell one motor to one customer one at the time. That's, a lot of times, that's not how it works. We sell a million-dollar project going into a capital expansion, and we sell 400 motors from five horsepower to 10,000 horsepower, on the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 91 same job. And when we do that, we're looking at it

in relationship to the job. We're not looking at it one motor at a time as far as where the pricing would be, or the margins. MR. BROOKMAN: Okay, Molly. MS. TROMBLEY-McCANN: Molly Trombley-McCann. This is a question for Rob or John, and I'm not sure you can answer it, but I want to just ask. But, just -- I hear you say that the margin fluctuates a lot from sale to sale, so I'm wondering if there's kind of a steady margin on an annual basis or per-job basis? No? MR. BOTELER: You'd have to look at our public records and you'd find that out if you went to our annual report, I guess. Not that we would share. MR. BROOKMAN: Please. Your name for the Record? MR. HOFMANN: Doug Hofmann, GE. Just didn't want to lose the light of the fact that a lot of motors are imported into the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 92 United States. So, whether you call an importer a

distributor or not, you're not, if you're using this model you might want to include the concept of the importer being part of that chain. And that arrow going from distributor to OEM, you probably have that as a two-way street, not only equipment that contains motors that should be falling under the scope here, goes OEM to distributor before it hits an end user. MS. IYAMA: Thank you. MR. BROOKMAN: Okay, thanks. Final comments on this segment? (Whereupon, at 1:44 p.m. ET, no response was had.) MR. BROOKMAN: Okay. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS: MS. IYAMA: Next I'll be covering the life-cycle costs and payback period analysis. The purpose of this analysis is to assess the life-cycle cost impact and payback period for the consumers of commercial and industrial electric motors under the different considered efficiency levels.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 93 So, here we're looking at results in terms of LCC difference between a base case, which is a situation without new or amended standards, and a, a standards case. And we're also looking at payback period, which is the first cost or total installed cost divided by the change in the first year of operating cost. The life-cycle cost includes two components. The first one is the total installed cost or first cost, and the second one is the sum of the annual operating costs which are discounted to a particular base here. In our analysis we'll be modeling the uncertainty and variability of the inputs using a Monte Carlo simulation approach. And, we'll be implementing, implementing this analysis in a Microsoft Excel spreadsheet combined with Crystal Ball, -- (Whereupon, at 1:46 p.m. ET, Mr. Malinowski and Mr. deLaski conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: -- which is a little1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 94 software that allows having inputs in the form of

probability attributions. So, like I said on the previous slide, life-cycle costs includes two main components. The first one is the total installed cost and the second one is the annual operating expenses. On this chart you have the overall flow chart for the LCC calculation. The upper part represents the development of the total installed cost and the bottom part represents the parameters involved in the calculation of the annual operating expenses. In yellow we have the different inputs; in green, the intermediate results, and in blue, the final results, which are the payback period and the life-cycle costs. And in the next slides I'll be covering the different inputs that we haven't already discussed during the engineering, engineering analysis, markup determ-, and the product price determination, and during the energy use analysis. And I'll start with the energy prices. So, the electricity prices are used to convert the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 95 energy use into energy cost. And here DOE will use projections of national average energy prices which are found in the EIA Annual Energy Outlook, and we'll be using that same source to, to get the reactive power prices. And here we have a, a comment box on the electricity prices. MR. BROOKMAN: John. MR. MALINOWSKI: I would just question here on electricity prices. When we look at the distribution of motor population in the U.S. you really need to look at that, because I think you'll find that a lot of motors are in areas that have fairly low electricity costs and are going to skew things, rather than looking at the northeast or California. We see six and a-half cents as pretty normal price for energy. And it -- Excuse me. The, the other idea on this is: Is it the end user, or is it the OEM? Because the OEM isn't going to really care about energy cost. He just wants the least costly motor1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 96 that is legal to buy to put on his machine. He's

not generally caring about life-cycle cost. MS. IYAMA: Um-hum. MR. MALINOWSKI: He's looking at first cost of his completed machine. He's got a different motive than the end user, who is trying to run a factory and control his energy costs. MS. IYAMA: So, for the, the LCC calculation we would do it from the perspective of the end user. MR. MALINOWSKI: It probably makes more sense that way, but you have to remember that half the motors bought are by OEMs, and they're not going to be happy. They're not happy about having to have efficiencies raised for EISA and, you know, pay more money for those motors. You know, they're looking for all these loop holes to get around doing that. So, just kind of be careful on that. The other thing you might have in here -- So, I, I didn't see anything on rebates or any, any incentives from utilities that, that might be there. You know, some, some are still there.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 97 Rob -- They'll be done differently. They'll be through measurement and verification rather than -- MR. BROOKMAN: Prescriptive. MR. MALINOWSKI: -- prescriptive rebates. The other thing is they may be budgeted with an inverter rebate and, and done that way. So, I don't know how you would build that in, but certainly that may help your, your cost. MR. BROOKMAN: So, I followed about -- I didn't get all of that, but I'm just not sure we need it in the Record. But, -- In here now. But, in your written comments you should describe how that works, okay? There's a lot of variability in how that works, right? MR. MALINOWSKI: Yes. Right. Yes. MR. BROOKMAN: Yeah. Charlie Stephens. MR. STEPHENS: Just real quick. I, I think some of this sort of highlights the kind of data that could be gathered in a very good market study that we were talking about earlier.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 98 If -- Some of this can be gathered as part of that if, if we're smart about how we go about that. So, let's be real careful about the questions we ask, and maybe we can learn a lot more than just where, when motors are running for how many hours. MR. BROOKMAN: Yeah. Molly. MS. TROMBLEY-McCANN: Molly Trombley-McCann. Just to continue to, on the California, the California utilities are going to continue to operate the rebates after the NEMA. One of the aspects may be an early retirement program where essentially there's an incentive for people to turn over their older motors. MR. BROOKMAN: Super. MS. TROMBLEY-McCANN: So, those are factors. MR. BROOKMAN: How long have you been operating that program? MS. TROMBLEY-McCANN: The upstream program has been in place for at least five years.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 99 MR. BROOKMAN: So, you've got data.

MS. TROMBLEY-McCANN: Yes. I don't know to what degree it's public because we work with distributors on a confidential level. MR. BROOKMAN: That would be helpful, I'm sure. Jim Raba, Department of Energy, would appreciate that. Good comments there. Other additional comments before we move on? MS. IYAMA: Another input to the LCC calculation are the discount rates. We use -- DOE uses the discount rates to assess the present value of lifetime operating expenses, and will be deriving a distribution of discount rates for the commercial and industrial sectors by calculating the discount rates based on a weighted-average cost-of-capital model. It's a method that has been used in other rulemakings so far. And here we have a, a comment box on this aspect of the analysis. MR. BROOKMAN: Discount rates. (Whereupon, at 1:53 p.m. ET, no response was had.)1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 00 MR. BROOKMAN: Okay, go ahead.

MS. IYAMA: Next we have the installation, maintenance, and repair costs. Here DOE will evaluate how these costs change with increased efficiency. Again, we're looking at results in terms of life-cycle cost difference between a standard case and a base case. Some of the sources that we will be looking at include RSMeans and Vaughens. On the installation cost, DOE's aware that larger and more efficient motors may be more difficult to install in constrained spaces or configurations. On repair and maintenance costs, DOE does not currently have any information that indicates that the repair and maintenance costs are different for more efficient motors. MR. BROOKMAN: Rob. MR. BOTELER: We touched on a couple of things that are going to influence us, and, and one of them was Roger talked about Design A product. And should the levels go to a level where more product is Design A, then the DOE would have to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 01 take into consideration the change in starters or

control systems which will have to be added to the cost that the end user would pay. Your installation costs based on constrained spaces, I best guess the answer there would be if, if the, if the product changed in its mechanical configuration, then there would be a huge cost potentially to the end user because he would have to reconfigure his piece of equipment. You know, my analogy there is I have a more efficient tire, but you have to buy a whole new set of wheels in order to use my tire. You know, it's the same sort of thing. Repair and maintenance cost for the premium efficient motors, I don't know of anything that would lead me to believe that there was any incremental cost or repair costs for the, for the motors. Your repair would be more from the, from the rewinding just simply because of more active material, and possibly, I guess, when we get into more slot-filled, it would be more difficult to, to fill the slot and maintain the efficiency.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 02 MR. BROOKMAN: Thank you.

Yes, John. MR. MALINOWSKI: I just want to add a little bit on there. Just so you understand, we've got two different kinds of motors we're talking about. Fundamentally we have cast-iron frame motor, which, when we build that, we have a fixed length of casting. So, however much stack and wind can fit in there, that's all you can get until you go to the next larger one. We also build another type of motor that has a steel band on it, and those, they're not necessarily fixed lengths. As you add more stack, the, length of the motor gets longer, up to a maximum length. And that's the case where we have problems with, we're having that problem with the EISA law. And by adding more efficiency on top of that, we'll get a motor that's too long and it won't fit into the space the OEM has designed, whereas with a cast-iron motor it is somewhat. And you can only get so much material in1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 03 it to go to such-and-such an efficiency. In that

case, jumping a frame size and going onto a larger diameter motor would prohibit that. One of the things to add to, onto what Rob said is the control circuit on a Design A motor. It may not only be the control circuit. It may also be changing the gauge of the wire between the motor and the starter and the starter and the transformer to a larger diameter to comply with National Electrical Code. So, you have that, that cost as well. Say a third thing is the application itself. As we raise the efficiency of the motor, typically what happens is the motor has less slip. What I mean by that is if you have an 1,800 RPM synchronous speed, it may run 1700 RPM under a certain efficiency, but you raise the efficiency and it will run 1790. When you put that on a centrifugal load, as the speed changes, the horsepower requirement changes by the cube. So, by raising that ten RPM or 15 RPM, or whatever it is, he may have had an old EISA-level motor and it's changing by 25 or 301 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 04

RPM. That could overload the motor if the

impeller or fan he's designed is for that slower speed motor. Or, at worse case, even if it doesn't overload the motor, the motor is working harder and producing more than its rated horsepower with that impeller on it, and you may not be saving any energy. So, what you'd have to do in that case is go in and change the fan, or change the impeller, or do something engineering-wise that the average user isn't going to have the skill to do. He's going to put in the new, higher efficiency motor expecting to save electricity. It's going to be producing more flow or more work, drawing more current as it does so, and his electricity bill is going to go up. So, you're not saving any energy in the end. MR. BROOKMAN: Okay. MS. IYAMA: Thank you. One of the other inputs to the life-cycle calculation is the lifetime, electric motor lifetime. Here we will use data from various1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 05 sources, including manufacture literature, and we

may also consider developing a correlation between motor lifetime, loading, and operating hours. So, any comments on this approach is welcome. MR. BROOKMAN: Rob. MR. BOTELER: I'll go out on a limb here. This is Rob. I would tell you that loading and, and duty factor, or duty cycle, as we call it, you have a profound effect on the amount of efficiency and the energy usage. I think we've heard numbers that over 60 percent of integrated horsepower motors operate below 50-percent load. I think Chuck Young, from EASA, has done a number of studies on that, and, and developed some models as to what, what happens with efficiency. This may be something that, as we talk about maybe doing a, a study together where we have a third party take a look at this and do some interviews with it. Again, some information. I mean, all the manufacturers recognize this as a, as a, as a1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 06 huge impact on efficiency and energy usage, but I

don't think any of us have any good hard data on, on what's going on in the marketplace. MR. BROOKMAN: Yes. Okay. Thank you. DR. AGAMLOH: May I? MR. BROOKMAN: Yes, please. DR. AGAMLOH: I would like to go add that -- MR. BROOKMAN: Emmanuel. DR. AGAMLOH: -- the Agency carried out a 100-load study where load was emergent in several bands across the, in three states, and so that data is available in the public domain. You can find that, a representative loading profile of, of more of them that way in the program. MR. BROOKMAN: And where did you say that was? DR. AGAMLOH: A hundred-motor study. MR. BROOKMAN: Okay. DR. AGAMLOH: There are parties on the line and we can supply it. MR. BUTLER: They're actually at our web1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 07

site. MR. BROOKMAN: Okay, at your web site.

And that web site is? MR. BUTLER: Kitt Butler, with Advanced Energy. The web site is advancedenergy, all one word, .org. And I'll -- We'll be happy to make it available to the Department or anybody that's interested in it. MR. BROOKMAN: Thank you, sir. SHIPMENTS ANALYSIS, NATIONAL IMPACTS ANALYSIS, AND LIFE-CYCLE COST SUBGROUP ANALYSIS: MS. IYAMA: Thank you. Next I'll be covering the shipments analysis. And the purpose of this analysis is to estimate the electric motor shipments in the base case as well as in the different standard case considered. And in order to do so, we'll be developing a shipments model based on different sources of data, including data that we can get through national market reports, manufacturing industry organizations, national energy and motor use surveys, and also we'll be looking at the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 08 historical shipments available through the U.S.

Census Bureau. (Whereupon, at 2:02 p.m. ET, Mr. Raba and a technician conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: So, DOE's considering two options, depending on the availability of data to de-, to develop the shipments model. Option one which is based on an accounting model, is the preferred option. Here we would be using an accounting methodology to determine the new installation, replacement motors, and retrofits or early replacement motors. Sothis model would be a bottom-up approach that would require to have precise stock data or precise historical shipments data related to the specific motors covered by the rulemaking, as well as data on lifetime. And so if we do not have sufficient data, we'll be using Option 2. In Option 2, the shipments forecast, would be based on forecasted economic growths of the different industrial and1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 09

commercial sectors where the motors are in use. MR. BROOKMAN: Charlie Stephens. MR. STEPHENS: Charlie Stephens. Are you, are you intending to do this study based at all on the motor end uses where these things are running? MS. IYAMA: Well, for the, for the energy use analysis we will be definitely -- We, we need to know the distribution in terms of motor applications, because that will drive the motor loads and, and hours of operation. So, yes, we'll, we'll be looking at the end uses. MR. STEPHENS: I mean in this particular shipment model. The reason I ask is because I would argue that even if you use Option 2 with NEMS growth projections, the growth projections for individual, commercial, or industrial sectors are going to be different. MS. IYAMA: Yeah. MR. STEPHENS: If you just look at what's been off-shored over the last ten or 15 years, and what hasn't, I think you're going to find there's going to be different projections.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 10 And I think -- I'm concerned that you take those

into account. MS. IYAMA: We would. We would take those into account. MR. BROOKMAN: Please. MR. HOYT: Bill Hoyt, with a, with NEMA. We do a lot of the data collection for our members on motor shipments. However, we do not make that available publicly. So, my suggestion to the Department would be, as an aspect of potential third-party investigation, that we would look into doing motor shipments as well as part of that study that we're considering for motors, to collect the data. I'm sure the manufacturers would, would be more than happy to contribute to a third-party study like that. MR. BROOKMAN: Bill, are there -- Help, help me to understand. You, you collect the data. Is there a nice way you can distribute it? It could be masked, or -- MR. HOYT: There is no way. MR. BROOKMAN: Okay. Okay.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 11 So, additional comments on the shipments model and methodology? John. MR. BOTELER: This is Rob Boteler. I only have one comment, and that is: One of the things that we can't miss is the amount of equipment coming from offshore with the motor embedded in another piece of equipment. Some of us were recently a, at a trade show in New Orleans, and I walked around that trade show for two days. And, of course, being a motor guy, all I do is look at the equipment that was there and the motors that are on it. And I was not able to find one motor that had a compliance number for the EPACT level of efficiency on the motor. MR. BROOKMAN: This was all imported motors, or -- MR. BOTELER: It was all imported. The show had covered everything, but the imported motors that I saw, the equipment that had imported motors, none of the, of the motors could I find a compliance on.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 12 MR. BROOKMAN: Among the total population of motors that you saw, the ones that you knew to be imports, none of those had the appropriate label? MR. BOTELER: Correct. MR. BUTLER: Well-said. MR. RABA: This is Jim Raba, DOE. Considering Rob's comment about possible imports, and maybe lacking of compliance data, we don't know, from the Department's point of view. We would be grateful to get comments on it that, that you could supply to us. And you could supply that to us, maybe. MS. GRACE-TARDY: That was the comment I think John Malinowski said something similar to in the beginning. And I think we've had comments in the past. And if there's specific information that you feel -- The Department, as Jim said, would be happy to see that information. Thanks. MR. BROOKMAN: Okay, thank you. So, -- MS. IYAMA: I'm going to continue on the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 13 shipments analysis. So, like I said previously,

we're going to develop shipments forecast, both in the base case, which is a situation without new standards, and also for the different standard cases considered. So, the, the base case which is the situation without new or amended standards provides the basis to compare forecasts for high efficiency levels. And in order to establish the base case, we'll be describing the current and forecasted mix of electric motor efficiencies sold in the absence of new regulation. This will require data on historical shipments, breakdown of shipments by product class, as well as breakdown of shipments by efficiency. For the shipments forecast in the Standards-Case we'll be relying on similar data. However, we'll also be looking at how purchase price increases, and operating, operating cost savings can affect the shipments. We will be also looking at any cross-elasticity between the motors covered under the rulemaking, as well as between covered and1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 14

noncovered motors. Finally, we'll be considering impacts from market-pull programs on efficiency distributions. And we have three comment boxes. The first one relates to any data or sources of data related to electric motor shipments and distribution by product classes, as well as long-term trends in motor shipments. Second, we welcome any comments on the accounting methodology; comments regarding stock of motor use, the different applications where these motors are used, as well as motor lifetime. (Whereupon, at 2:10 p.m. ET, Mr. Hoyt and Mr. Malinowski conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: And finally, any comments on how Standards on electric motors can affect shipments, comments on cross--elasticity, as well as on how market programs can affect the efficiency of ship-, of motor shipments are of interest here. MR. BROOKMAN: We already have a plan, we think, for putting together this data. Other1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 15 comments that, as you see, pardon me, listed here

in the box, boxes? (Whereupon, at 2:10 p.m. ET, no response was had.) MR. BROOKMAN: No additional comments at this time. MS. IYAMA: So, I'm going to move on to the last section of the preliminary analysis, which is the National Impact Analysis. The purpose of this analysis is to assess the national energy savings and the national consumer economic impacts from the considered Standards. And then we're com-, we're comparing the results here to the, to the base case. Here we'll be developing annual values over a period of 30 years, starting from the year that the Standard comes into force, and we'll be calculating annual national energy savings and national consumer economic impacts. And since we're looking at a time series of money, we'll be using discount rates to convert that into present value. On this flow chart here, the methodology to calculate the national energy1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 16 savings is described. So, we start off with the shipments analysis, which provides the shipments forecast in the base case, as well as the shipments forecast in the standard case. So, here, in the base case for each year over the 30-year period, we recalculate the annual energy consumption associated to the stock of motors, and we use outputs from the LCC in order to do that. (Whereupon, at 2:12 p.m. ET, various spectators conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: Then we accumulate the energy use over the 30-year period, and we do the same in the standard case. And, actually, before we accumulate the energy consumption, we use a site-to-source conversion factor to get to the source energy consumption. And then the difference between the base case and the standard case cumulative energy use gives the national energy savings. Now, for the, for the national consumer net present value we have1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 17 a similar diagram. And we also start off with the shipments analysis, which provide the shipments forecast both, both in the base case and the standard case. For each year of the 30-year period we calculate the energy cost and repair and maintenance cost, and we also calculate the total installed cost. We accumulate the operating cost savings by looking at the difference between energy cost, repair, maintenance costs between the standard case and the base case, and we calculate the cumulative total installation costs by looking at the difference between the base case and the standard

case. We use a discount rate to convert those values into present value, and the difference between the cumulative operating cost savings and the cumulative total installation cost increase provides the net present value. And so if, it, it's pos- -- If, if the cumulative operating cost savings are greater than the total installation cost increase, then we have a net benefit for the Nation.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 18 So, again, DOE intends to calculate the national energy consumption for each year beginning the year that the Standard comes into force and over a 30-year period. And we'll be implementing the analysis under the Microsoft Excel spreadsheet, which is standard, and we have a standard model -- (Whereupon, at 2:15 p.m. ET, Mr. deLaski and Mr. Malinowski conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: -- that is used in the DOE rulemakings. We have a comment box on that aspect. MR. BROOKMAN: Comment on the NES spreadsheet models it proposes for estimating the -- No additional comments? MR. BISHOP: Just one question. My own ignorance. What's the reason for using a 30-years period? And my -- It's Tom Bishop. MR. BROOKMAN: Just looking for the -- MR. RABA: Jim Raba. Don't look at me.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 19

MS. TROMBLEY-McCANN: It's a nice round number. MR. BROOKMAN: Mimi Gupta. MS. GUPTA: This is Mimi Gupta. It's just been a tradition of using a 30-year. In the past, DOE has tried to use a similar analysis period so it can compare different rulemakings. MR. BUTLER: Thank you. MR. BROOKMAN: Yes, Charlie Stephens. MR. STEPHENS: Charlie Stephens. I can answer that a little different way. We use a 30-year analysis where we come from, too, and the reason we do that, the reason is for everything we analyze it's at least one product lifetime. MS. GUPTA: Yeah. MR. STEPHENS: And some products, the lifetime actually goes beyond 30 years. Most of them are covered in 30 years. MS. GUPTA: Um-hum. MR. BROOKMAN: Okay. Okay. MS. IYAMA: So, next we're moving on to1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 20 the NOPR analysis. The NOPR stage starts off with

the revision of the preliminary analysis, and then we'll be covering six sections, life-cycle cost subgroup analyses, manufacturer impact analysis, which Jeremy will be talking about, utility impact analysis, employment impact analysis, environmental assessment, and regulatory impact analysis. And I'm going to start with the LCC subgroup. So, the, the purpose of this analysis is to determine if there is any subset of end users which would be disproportionally impacted by Standards. (Whereupon, at 2:17 p.m. ET, Mr. Raba and a technician conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: And the method we use to assess this is to extend the LCC analysis using inputs that are specific to that subset of end users. And so here we welcome any comments on what customer subgroup would be appropriate to consider under that section of the analysis. MR. BROOKMAN: No comments on this?1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 21 (Whereupon, Ms. Gupta and Mr. Raba conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. BROOKMAN: Rob. Yes. MR. BOTELER: Rob Boteler. Well, I would just tell you that the customer subgroup that will have a negative impact would be if, if we were to move to a level of efficiency that required a change in the performance, either electrical or mechanical, the subgroup would be anybody who tried to replace a failed motor. It's not, it's not a category or an application. It's just anyone who had to replace that motor that was modified because of electrical or mechanical changes resulting from a Regulation. MR. BROOKMAN: Okay. MS. IYAMA: And next, I'll pass the floor to Jeremy. MR. GORDON: Thanks. Thank you, Sanaee. MANUFACTURER IMPACT ANALYSIS MR. GORDON: So, next up is the Manufacturing Impact Analysis. Manufacturer impact1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 22 analysis is undertaken to identify the impacts of

energy conservation standards on manufacturers, both quantitatively and qualitatively. This is done by first creating an industry cash-flow model called the Government Regulatory Impact Model that takes into account any investment and revenue changes that the industry might experience. Next, DOE interviews manufacturers to refine the GRIM. The MIA occurs over three phases, from the preliminary analysis stage through the NOPR stage. DOE will develop an interview questionnaire to help guide interviews with manufacturers. DOE will also examine impacts on competition, manufacturing capacity, employment, and regulatory burden. DOE welcomes comment on any cost issues related to the MI A MR. BROOKMAN: Roger. DR. DAUGHERTY: Well, Roger Daugherty. What I observed in previous Standards rulemaking was that once motors were divided into classes, then each one of those classes became examined as independent groups, with no1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 23 interrelationship between the classes, as a result

that the technology that was developed for the efficiency level that was set for one class was very different than it was for another class, such as one may have required using copper rotors to achieve the efficiency level which was not required of another class. One of the classes required the, the very thin electrical steel, which was not in the other class's technology in the determination. That seems to ignore the fact that all those classes were being made by a manufacturer in the same facility. And it's not to a manufacturer's interest to develop a lot of different technologies for the little groups of motors that may fall especially under Subtype 2 here by determining that DOE determines some efficiency levels based on some elevated technology that is not applicable over to the Subtype 1, which is the predominant motors that manufacturer may be making. So, my, my point is that when you examine the classes, don't treat the classes as1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 24 independent. If you're looking at, say, copper

rotors, and the cost of implementing it into one of the little classes, that cost should also be examined as a total cost of whether that gets implemented into all the products within that facility, not just that little class. So, don't want you to get misled and lead in and say, "Now, Mr. Manufacturer, I've got six classes here of technology in each of these six are different. Build all those six in the same facility." It's, it's just not practical, and has a very major impact on the manufacturer. MR. BROOKMAN: Okay, thank you. I guess for the Record I'd note all the manufacturers are nodding their heads in agreement. MR. BOTELER: Turn your mic' up. MR. BROOKMAN: It must have died on me. Yes, it did. MR. MALINOWSKI: John Malinowski. I guess I just got a comment here. When you did the small-motor study it looked like you spent a fair amount of time talking with a lot of1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 25

the domestic motor manufacturers. Great number of our motors, probably the majority of our motors that are sold in the U.S. come from offshore. I guess I'd be real concerned that you get a representative survey of companies making motors offshore: China, India, Mexico, Brazil, Europe, -- MR. LADONNE: Korea. MR. MALINOWSKI: -- Korea, you know, so that you understand the, the variances from company to company. To build on Roger's point, we build product families, trying to use as many standardized parts as possible. We don't want to subdivide different product categories and have those pushed to special efficiency levels. The plant that Baldor Electric has in Arkansas that builds one- to 20-horsepower motors builds 6,000 motors a day, and the average lot size going through that plant are 20 units or less, you know. So, you know, industrial motors are built in fairly small quantities. They're not like commercial motors, that1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 26 we are building thousands and thousands at a time,

okay? So, you need, you need to take a, a lot of those kind of things into consideration. We build motors as we get orders. We don't build thousands of motors and put them on the shelf waiting for somebody to come by and, and buy that type. You know, it's just-in-time delivery. You build motors for inventory and you try to turn that inventory over and over and over many times in a year. It's, it's different than importers. And how are you going to treat companies who wementioned before are more like importers-slashmaster distributors that are having a motor built to their frame, and then they sell them here like a motor manufacturer, but yet they're really not a manufacturer? They're a, they're an importer. You know, you, you need to -- You know, that -- There, there's several fairly large companies that are doing that, and you need to get them under the scope of your survey as well.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 27 And how they can -- You know, some of those can't respond to the EISA efficiency Regulations. So, -- (Whereupon, at 2:25 p.m. ET, Mr. Raba and a technician conferred, out of the hearing of others and off the Record, during which the following occurred:) MR. MALINOWSKI: -- you know, they're out of control in bringing efficiency levels you might think up in the future. MR. BROOKMAN: Thank you. MR. GORDON: All right. So, we'll return again with the utility impact analysis. MS. IYAMA: There's, there's a break on there on the Agenda. MR. BROOKMAN: Let's keep going. UTILITY IMPACT ANALYSIS, EMPLOYMENT IMPACT ANALYSIS, ENVIRONMENTAL ASSESSMENT, AND REGULATORY IMPACT ANALYSIS MS. IYAMA: Okay. So, the purpose of this analysis is to assess the impacts of Standards on domestic electricity suppliers. And the method that DOE has used in the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 28 past and that we'll be using in this rulemaking is

to use a modified version of NEMS called NEMS-BT, which allows to -- (Whereupon, at 2:26 p.m. ET, Mr. Raba and a technician conferred, out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: -- analyze the impacts of energy conservation standards. NEMS is the model that is used to develop the energy forecast that you see in the Annual Energy Outlook Reports. And so this is the basis that we'll be using for the utility impact analysis. The inputs to the model will be the national energy savings from the national impact analysis, and the outputs will be expressed in terms of forecasts of electricity generation and avoided capacity resulting from a comparison of the base case and the standard case. (Whereupon, at 2:27 p.m. ET, Mr. Malinowski and Mr. Ladonne conferred, out of the hearing of others and off the Record, during which the following occurred:)1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 29 MS. IYAMA: And here DOE welcomes any interest, inputs or comments on the, on the utility impact analysis. MR. BROOKMAN: Questions or comments? John. MR. MALINOWSKI: Oh, just question here. If we push efficiencies up, we may switch the population over to a lot of Design A motors, which are going to have a higher in-rush current. So, the utilities could be faced with some higher peak charges from their users, which could impact their ability to maintain a good, solid grid out there. You go in, you turn the plant on, and they're all, another couple hundred-percent in-rush current. We could have a big problem. We could have California going in some blackouts and brownouts out there. MR. BROOKMAN: Thank you. Okay. MS. IYAMA: So, next we have the employment impact analysis. And the purpose of this analysis is to assess the impacts of Standards on national employment.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 30 The overall analysis includes both direct and indirect employment impacts. And Jeremy, Jeremy already touched upon the direct employment impacts under the manufacturer impact analysis. Here we're looking at indirect employment impacts, and in order to assess those we'll be using the impact of sector energy technologies, which is the ImSET Model. And this is a, is a method that DOE has been using for quite some time. And the outputs to the model are the changes in, in direct employment resulting from the, from the Standards. MR. BROOKMAN: Rob. MR. BOTELER: Well, Rob Boteler. I think we mentioned this earlier, and I think John just hit on it again. You know, as, as we looked at the product, if we go to higher levels of efficiency, we move to more hand operations. Being the newest member of NEMA, as a foreign-owned company, we did the numbers this morning. There are now seven of us owned by1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 31 foreign companies. And I guess 11, talking about a total of 11 or 12 companies. And as John said, the bulk of the product we're talking manufactured off-shore, there's about three manufacturers left that manufacture this product within the U.S. I think it would be a shame -- I mean, I'm now a foreign company. I think it would be a shame that we would put in a Regulation that would effectively drive the rest of the business off-shore and we could lose the jobs in America. MR. BROOKMAN: Okay, thank you. MS. IYAMA: Next we have the Environmental Assessment. And the purpose of this analysis is to assess the impact of standards on air emissions from electricity power plants. And here DOE intends to use the NEMS-BT model again, which is the same model used in the utility impact analysis. It allows to estimate different air emissions. And here we'll be reporting carbon dioxide, mercury, and nitrogen oxide in the 22 States where these emissions are not capped. For1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 32 the States where the emissions are capped, as well

as for sulfur dioxide where there is an existing legislation capping these emissions, DOE states that the appliance Standards do not have any impacts on those emissions. And here welcome inputs on this approach, on the use of NEMS-BT and the -- MR. BROOKMAN: You can see the media that are listed there. Comments? Yes, John. MR. MALINOWSKI: Yes. Just want to -- John Malinowski. Wanted you to take specific look at copper rotors and the high level of emissions that might, might come from that. The amount of energy to, to melt copper is tremendous. You have to preheat the rotor. It takes 60 kilowatts to preheat a 20-horsepower rotor. Going to be a lot of energy used to do this. And the return from that energy is incremental. You get maybe one NEMA band out of it, four-tenths of a percent, not to mention the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 33 complete cost of retooling all the motors for that.

Just be real careful on, on the carbon footprint we, we look at for that, and also the higher level of steel, extra processing it takes to do that. MR. BROOKMAN: Okay, thank you. Other comments on Environmental Assessment? (Whereupon, at 2:32 p.m. ET, no response was had.) MS. IYAMA: Okay. Also, in recent rulemakings DOE has started to monetize the emission reductions. And in order to do so, DOE intends to use the most current social cost of carbon values developed by interagency review. And so the social cost of carbon is intended to represent a monetary measure of the incremental damage resulting from greenhouse gases emission. And we'll be using the different values that you have on these slides, dollar values. And we'll be also estimating the potential monetary benefits from reduced NOx emissions resulting from the considered Standards.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 34 And here we welcome any comments on the approach and the use of monetized values associated to the emission reductions. MR. BROOKMAN: You can see the -- Rob, go ahead. Questions? MR. BOTELER: Would you go back and explain -- Would you go back and explain what -- The second bullet: What does that mean in the last line, emissions in 2010 are 4.7, 21.4, and 35.1? What does that, what does it mean? MS. IYAMA: So, these are the values in dollar that correspond to the measure of the damage resulting from greenhouse gases emissions. It's, it's a way to monetize the, the, -- (Whereupon, at 2:34 p.m. ET, Mr. Raba and the technician conferred, and Mr. Malinowski and Mr. deLaski conferred, each out of the hearing of others and off the Record, during which the following occurred:) MS. IYAMA: -- the, the costs of impacts on the emissions. MR. BROOKMAN: Molly. MS. TROMBLEY-McCANN: Molly1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 35 Trombley-McCann. Is this the range of -- MS. IYAMA: They are different, depending on the different scenarios. MR. BOTELER: You don't know what the scenarios are? MS. IYAMA: They represent different discount rates. MR. BOTELER: Thank you. MS. IYAMA: And there's an appendix, in the small-motor study, where all the methodology on the monetization is explained. MR. BOTELER: Okay. Thank you. MR. BROOKMAN: Charlie Stephens. MR. STEPHENS: Charlie Stephens. We do the same kind of analysis out where we are every year. These are just surrogate values on the price of carbon, be it in regards to trading scheme or tax or whatever. But, there are different scenarios involved with pricing carbon, and it just shows you what the best case/worse case might be, depending on who you are. MR. BROOKMAN: Okay.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 36 MS. IYAMA: Finally, we have the regulatory impact analysis. And the purpose of this analysis is to investigate the national impacts of non-regulatory alternatives compared with mandatory energy conservation standards. The non-regulatory alternatives that may be considered in this section include consumer rebates, consumer and manufacturer tax credits, voluntary efficiency targets, early replacement, and bulk government procurement. The method that we use to assess the impacts of those non-regulatory alternative is to develop a separate national impact analysis spreadsheet for each of these scenarios, and we estimate the impacts based on previous experience with the considered policies. The outputs are similar to the outputs of the National Impact Analysis, and they're expressed in terms of net present value and national energy savings. MR. BROOKMAN: Charlie Stephens. MR. STEPHENS: Charlie Stevens. Have you yet done an analysis that1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 37 considers a combined regulatory and non-regulatory

approach? MR. BROOKMAN: What, what would be involved in that, in your opinion? MR. STEPHENS: Well, we have already sort of seen -- There's an agreement, for instance, on the table right now for some other products that involves a non-regulatory lead-up program to the regulatory effective date of a Standard which changes manufacturer impacts. It changes, you know, a lot of things potentially. Have you looked at -- Do you formally analyze that? I would suggest it might be about time to think about that. MS. GRACE-TARDY: Yeah. I think we do not formally formalize that, as I understand. But, we would take comment, and sounds like you'd be providing that. MR. BROOKMAN: Sounds like a lot of potential variables, right? MR. STEPHENS: Right. MR. BROOKMAN: So, that would be a1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 38 different analysis? MR. STEPHENS: Actually not. It's more like scenario analysis. And, like I say, there are examples on the table right now. You could analyze those and do some what-ifs on those and see what it looked like, and what mitigating impacts there my might be, depending on what the scenario is you'd put together. MR. BROOKMAN: So, since you have a lot of experience in this, maybe you'd describe for them in detail what steps we can do that. MR. STEPHENS: We can certainly look at what we already are contemplating. MR. BROOKMAN: Yes, Molly. MS. TROMBLEY-McCANN: Molly Trombley-McCann. I'm not sure this is what you can analyze, but at least in California we've had very good success in what are considered upstream rebate programs where the rebates goes to the, not the consumer, but to the distributor. And that, that has been very, very effective in moving the market.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 39 So, that's something I'd consider the Department look at. MR. BROOKMAN: Okay, good. Thank you. Final comments on these regulatory approaches? (Whereupon, at 2:38 p.m. ET, no response was had.) MR. BROOKMAN: Okay, go to the next. Yes. We're going to hand out the evaluation form. As we said first thing this morning, now is another opportunity for anybody that wishes to do so to make a, an additional comment, final comments, to supplement what's been said, to create another point of emphasis briefly as a close. Roger. DR. DAUGHERTY: Roger Daugherty. I think we've heard throughout the today that it's very important to have a very clear definition as to the motors that are considered as covered product in the application, whether it's Table 12-11 or Table 12-12 out of NEMA. Realizing that the, the, that the1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 40 compliance date is two months away and I don't see

any likelihood that we're going to have a final Rule that's going to establish those definitions, I would like to suggest that the Department consider -- And it's not without precedence, but in 1997 the Department issued a guidance to the manufacturers and, and users and OEMs as to what it considered to be covered products, and it established Appendix, what is now Appendix A to Subpart B. I would like to encourage the Department to get out such a guidance to provide similar guidance to the manufacturers with this effective date of December coming up this year in anticipation that that would be, what would be in that guidance would be most likely what will be in the Final Rule. But, we really need guidance, because we, we have OEMs. We have customers. They call in and they ask us: Is this motor going to be a covered product? Is, is it going to be to Table 12-11? Is it going to be to Table 12-12? The only guidance we have at the present1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 41 time is Appendix A to Subpart B. So, it's become a

very important document to us. And, as, as I'd asked earlier, and I heard a con-, a response back that it appeared that there is some opinion on the Department's part that the present definitions stand while waiting for a final Rule. And, and those definitions and that guidance is over that Appendix A. So, I, I'd like to encourage a definitive guidance coming out very soon out of the Department that provides enough guidance to us as manufacturers to make a clear determination that, to the best of our abilities, as to whether or not a particular design is a covered product, and what efficiency level would apply, waiting for a final Rule. MR. BROOKMAN: Thank you. Additional comments here in closing? (Whereupon, no response was had.) MR. BROOKMAN: No additional comments. Okay. So, then for my part I'm going to turn it back to Jim Raba. Thanks to all of you.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2 42 Covered a lot of ground, and very productive. Very, very productive discussion today. I'm certain that the Department will really benefit from these comments. The -- Put this slide here, the slide which shows also in your packet how to submit your comments. Jim Raba. MR. RABA: The Department thanks you for being in attendance today. Sharing a lot of good information thus far, and expect certainly a lot

more. Go back and look at this in retrospect and provide data, further comments, and information that can be used to further this rulemaking. We understand it's very complex. There's much at play here from top to bottom, and we're doing our best to look at all sides of this and provide a thorough analysis. It's the beginning of the rulemaking process. The framework has provided methodologies and thoughts about analyses. Clearly got some good thoughts and guidance already on the table here.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2 43 We'll take it into consideration. But, again, thank you for being here. Any comments from the group here further? (Whereupon, no response was had.) MR. RABA: Thank you all, and look forward to hearing from you in the near future. (Whereupon, at 2:43 p.m. ET, the above Hearing was concluded.)