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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. USA 
 

 

 

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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

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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

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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

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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 

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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 

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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 

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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

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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 

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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 

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11

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 

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12

 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 all 
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 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 might 
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 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 break 
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 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. 
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 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. 
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 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. 
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 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 be 
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 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. 
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 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. 
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 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 of 
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 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 of 
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 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 from 
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 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. 
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 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, NEMA 
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 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 Subtype 
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 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 in 
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 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 to 
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 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 will 
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 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 of 
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 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 as 
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 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. 
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 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, 
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 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 to 
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 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. 
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 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 need 
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 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. 
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 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. 
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 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 rulemaking 
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 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. 
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 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 for 
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 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 the 
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 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. 
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 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 in 
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 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 then 
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 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? 
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 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. 
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 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 these 
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 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, 
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 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. 
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 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. Raba 
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 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 the 
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 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 continue 
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 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. 
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 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 that 
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 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 is 
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 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 saying 
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 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 how 
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 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. 
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 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 of 
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 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 focus 
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 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 my 
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 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. 
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 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 to 
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 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, most 
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 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 the 
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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. 
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 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 this 
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 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 more 
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 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 intended 
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 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 a 
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 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. 
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 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. 
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 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. 
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 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 specific 
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 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. 
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 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. 
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 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 some 
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 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 as 
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 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 requesting 
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 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 all 
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 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. 
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 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. 
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 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 under 
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 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. 
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 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 to 
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 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. 
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 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 confusion 
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 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. 
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 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. 
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91

 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 a 
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 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 the 
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 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 of 
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 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. 
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 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. 
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 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. 
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 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 comment 
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98

 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. 
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 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 have 
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100

 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 one 
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 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 framework 
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 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 fifth 
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 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-motor 
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 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, and 
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 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 somewhere 
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 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 based 
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 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 support 
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 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. 
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 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 completely 
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110

 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. 
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 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. 
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 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, but 
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113

 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 I 
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 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. 
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 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 technology 
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 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 efficient 
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 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. 
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 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, 
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 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 that 
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120

 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 consequence 
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 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 been 
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 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 engineering 
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 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 to 
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 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. 
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 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 these 
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 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. 
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 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? Why 
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 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 pump 
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 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 of 
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 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 company 
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 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. 
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 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. 
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 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 things 
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 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:) 
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 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'll 
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 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-horsepower 
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 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 and 
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 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 into 
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 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. 
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 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 for 
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 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 independent 
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 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. 
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 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 of 
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 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. 
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 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, we 
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 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 that 
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 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 rule 
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 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. 
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 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 a 
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 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. 
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 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 available 
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 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, 
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 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. 
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 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 the 
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 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 the 
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 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 you 
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 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 to 
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 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 changed 
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 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 AEDM 
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 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 include 
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 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. 
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 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 Europe 
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 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 costs 
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 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 test 
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 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 between 
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 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 that 
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 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, 
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 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 the 
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 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. 
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 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 frame 
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 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, as 
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 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-8 
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 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. 
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 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 the 
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 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 1:27 
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 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. 
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 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:) 
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 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 would 
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 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 --
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 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 we 
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 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 impacts 
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 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. 
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 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 involved 
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184

 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 the 
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 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. 
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 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, 
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 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, 
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 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 to 
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 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 well 
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 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 the 
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 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 the 
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192

 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. 
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 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 little 
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 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 the 
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 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 motor 
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 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. 
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 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. 
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 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. 
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 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.) 
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 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 to 
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 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. 
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 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 in 
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 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 30 
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 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 various 
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 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 a 
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 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 web 
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 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 the 
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 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 and 
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 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. 
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 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. 
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 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. 
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 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 the 
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 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 and 
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 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. Other 
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 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 energy 
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 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 have 
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 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. 
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 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. 
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 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 to 
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 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? 
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 (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 impact 
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 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 no 
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 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 as 
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 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 of 
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 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, that 
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 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 we 

mentioned 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. 
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 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 the 
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 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:) 
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 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. 
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 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 by 
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 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. For 
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 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 the 
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 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. 
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 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: Molly 
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 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. 
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 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 that 
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 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 a 
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 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. 
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 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 the 
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 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 present 
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 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. 
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 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. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 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.)