1 | Building Technologies Program eere.energy.gov

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Standards 

Proposed Rulemaking

for Small Electric Motors (SEMs)

James Raba

Department of Energy

Energy Efficiency & Renewable Energy

small_electric_motors_std.rulemaking@hq.doe.gov

December 17, 2009

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• Purposes

– To invite comment on the proposed energy conservation standard 

levels;

– To present methodologies and characterize results for the rulemaking 

analyses;

– To discuss specific issues related to each analysis;

– To seek input from interested parties on methodologies, assumptions, 

data sources, and results from the analyses; and

– To describe the next steps in the rulemaking.

• Comments from Participants

– Participants are invited to provide summary comments or statements; 

and

– Participants are invited to raise additional issues for discussion today.

– NOPR comment period closes January 25, 2010.

Purpose of the Public Meeting and 

Comments From Participants

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The Energy Policy and 

Conservation Act (EPCA)

• EPCA directs DOE to consider seven factors when setting energy 

conservation standards

Factor Analysis

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analysis

Manufacturer impact analysis

2. Lifetime operating cost savings Life-cycle cost analysis

3. Total projected energy savings National impact analysis 

4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact analysis

6. Need for national energy 

conservation

National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessment

Utility impact analysis

Employment impact analysis

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• Test Procedures

– Final Rule published on July 7, 2009, based on Institute of Electrical and 

Electronics Engineers (IEEE) Standard 114 and IEEE Standard112. 74 

FR 32059.

• Energy Conservation Standards

– Determination Analysis published July 10, 2006 71 FR 38799.

– Framework Document published August 10, 2007. 72 FR 44990.

– Notice of Public Meeting and Availability of the Preliminary Technical 

Support Document December 30, 2008. 73 FR 79723.

– Notice of Proposed Rulemaking (NOPR) published November 24, 

2009. 74 FR 61410.

– Final Rule scheduled for publication by February 28, 2010.

DOE Actions for Small Electric Motors

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• The Energy Policy Act of 1992 amended the Energy Policy and 

Conservation Act to direct DOE to prescribe energy conservation 

standards for those small electric motors for which the Secretary 

determines that standards ‘‘would be technologically feasible and 

economically justified, and would result in significant energy 

savings.’’ (42 U.S.C. 6317(b)(1)).

• DOE is scheduled to publish a final rule for these products by 

February 28, 2010, pursuant to the consent decree in State of New 

York, et al. v. Bodman, and NRDC, Inc. et al. v. Bodman. 

Authority for Small Electric Motors

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• DOE is proposing trial standard level (TSL) 5 for polyphase small 

electric motors.

Proposed Energy 

Conservation Standards

Motor horsepower/

standard kilowatt equivalent

Nominal full load efficiency

Polyphase 

(number of poles)

6 4 2

0.25 / 0.18 77.4 72.7 69.8

0.33 / 0.25 79.1 75.6 73.7

0.5 / 0.37 81.1 80.1 76.0

0.75 / 0.55 84.0 83.5 81.6

1 / 0.75 84.2 85.2 83.6

1.5 / 1.1 85.2 87.1 86.6

2 / 1.5 89.2 88.0 88.2

3 / 2.2 90.8 90.0 90.5

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Proposed Energy 

Conservation Standards

• DOE is proposing TSL 7 for single-phase (capacitor-start) small 

electric motors.

Motor horsepower/

standard kilowatt 

equivalent

Nominal full load efficiency

CSIR 

(number of poles)

CSCR 

(number of poles)

6 4 2 6 4 2

0.25 / 0.18 65.4 69.8 71.4 63.9 68.3 70.0

0.33 / 0.25 70.7 72.8 74.2 69.2 71.6 72.9

0.5 / 0.37 77.0 77.0 76.3 75.8 76.0 75.1

0.75 / 0.55 81.0 80.9 78.1 79.9 80.3 77.0

1 / 0.75 84.1 82.8 80.0 83.2 82.0 79.0

1.5 / 1.1 87.7 85.5 82.2 87.0 84.9 81.4

2 / 1.5 89.8 86.5 85.0 89.1 86.1 84.2

3 / 2.2 92.2 88.9 85.6 91.7 88.5 84.9

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• Opening remarks

– At this time, DOE welcomes opening remarks from interested parties on 

the NOPR for small electric motors.

• In addition, DOE specifically invites comment on the proposed 

energy conservation standard levels for small electric motors. 

Opening Remarks and Comments

ISSUE 16. DOE seeks input on the proposed standard level for polyphase 

small electric motors.

ISSUE 17. DOE seeks input on the proposed standard level for single-phase 

(capacitor-start) small electric motors.

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Summary of NOPR Issues on which 

DOE seeks comment

1. Product Classes: The proposal of product classes based on motor category, pole configuration, 

and horsepower.

2. Insulation Class Systems: The proposal to include other insulation class systems besides A, in 

particular B and F insulation class systems.

3. Baseline Motors: The appropriateness of the baseline models and efficiencies used in the 

engineering analysis.

4. Markups: The various markups used in the engineering analysis, in particular the difference in 

overhead markups for designs that use a copper rotor and those that use an aluminum rotor.

5. Design Limitations: The design options and limitations presented in the engineering analysis, 

such as limitations on motor size, the air gap between the rotor and stator, and the power factor.

6. Scaling: The approach to scale the engineering analysis results to product classes for which a 

complete analysis was not performed, especially the decisions to use the relationship found for 

CSIR motors to scale results for CSCR motors.

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Summary of NOPR Issues on which 

DOE seeks comment (continued)

7. Nominal Efficiency: The proposal to define nominal efficiency as the average full-load efficiency 

of a large population of motors or the same design.

8. INPV Scenarios: The preservation of operating profits as the lower bound scenario and the 

preservation of return on invested capital as the upper bound scenario for the INPV results 

generated in the manufacturer impacts analysis.

9. Capital Costs: The capital investments needed to reach each efficiency level

10. Market Reaction: Input and data regarding how the single-phase market will respond to the 

proposed standard. In particular, DOE seeks comment regarding its CSIR/CSCR market share 

model, the current shares of CSIR and CSCR motors in each combination of motor power and 

number of poles, and the barriers the customers face if they switch from CSIR to CSCR motors or 

vice versa.

11. Market Reaction: Input data regarding how the small electric motors market will respond to the 

proposed standards. In particular, DOE seeks comment regarding alternative small electric motor 

technologies and how they could potentially affect the projected shipments and energy savings.

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12. Space-Constrained Applications: The behavior of customers with space-constrained 

applications, the costs they face, and the time-frame over which they may need to redesign a 

system or large piece of equipment to accommodate a larger-component small electric motor. 

DOE also seeks further information regarding the population and distribution of space-constrained 

customers among motor applications.

13. Impact of Standards: DOE seeks comment on how forecasted uncertainty in market shifts can 

be estimated and weighed against the potential increases in benefits when selecting a higher 

standard level that may cause a shift in motor purchases.

14. Emissions Discount Rates: The appropriateness of using other discount rates in addition to 

seven percent and three percent real to discount future emissions reductions.

15. Environmental Assessment: The determination of the anticipated environmental impacts of the 

proposed rule, particularly with respect to the methods for valuing the expected CO2 and NOx

emissions savings due to the proposed standards.

16. Trial Standard Levels: The proposed standard level for polyphase small electric motors.

17. Trial Standard Levels: The proposed standard level for single-phase (capacitor-start) small 

electric motors.

Summary of NOPR Issues on which 

DOE seeks comment (continued)

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Scope of Coverage

• Statutory Definition of Small Electric Motor

– “a NEMA [National Electrical Manufacturers Association] generalpurpose alternating current single-speed induction motor, built in a twodigit frame number series in accordance with NEMA Standards 

Publication MG1–1987. ” (42 U.S.C. 6311(13)(G))

– EPCA particularly defines small electric motors by citing the 1987 

version of MG1; therefore it is the only version of that document which 

is applicable to the definition.

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• Only open motors are considered covered products under the EPCA 

definition of “small electric motor.”

• DOE covers IEC motors by establishing standards for horsepower 

ratings and the corresponding kilowatt ratings.

• Insulation class systems

– DOE interprets the definition “general-purpose, alternating current 

motor” as being applicable to insulation classes rated A or higher.

– Insulation class systems, B, F, and H all meet requirements for class A 

systems.

– In the current market, class B and F insulation systems are much more 

common in small electric motors than A.

ISSUE 2. DOE seeks comment on the proposal to include other insulation 

class systems besides A, in particular B and F insulation class systems

Scope of Coverage

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Product Classes

• In general, DOE divides covered products into classes based on:

– (1) the type of energy used;

– (2) the capacity of the equipment; and 

– (3) any other performance related features that require different 

standard levels, such as features affecting consumer utility (42 USC 

6295(q))

• For small electric motors, DOE defines product classes using 

three motor characteristics

– Motor category (polyphase, CSIR, and CSCR)

– Horsepower ratings (1/4, 1/3, 1/2, 3/4, 1, 1 1/2, 2, and ≥3)

– Pole configuration (2, 4, and 6)

ISSUE 1. DOE seeks comment on the proposal to separate product classes 

based on motor category, pole configuration and horsepower rating.

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Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

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• Purpose

– To evaluate design options that improve efficiency relative to the 

baseline models.

– To characterize manufacturer cost-efficiency relationships for higher 

efficiency equipment.

• Methodology

1. Select representative product classes to analyze.

2. Develop baseline models.

3. Model motors of higher efficiency using designs created in a 

technical expert’s proprietary software program.

4. Use a bill of materials and markups to generate cost-efficiency 

curves.

5. Scale to unanalyzed product classes.

Engineering Analysis

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Basic Characteristics of 

Motors Analyzed Baseline Efficiency %

Polyphase, 1 hp, 4-pole, 56 frame 77.2

CSIR, 1⁄2 hp, 4-pole, 48 frame 57.7

CSCR, 3⁄4 hp, 4-pole, 56 frame 71.0

Representative Product Classes and 

Baseline Models

ISSUE 3. DOE seeks comment on the appropriateness of the 

baseline models and efficiencies used in the engineering analysis.

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Software Design Approach

• DOE applied various design options to the baseline models to 

create more efficient motor designs.

• Design limitations were used to maintain both manufacturability 

and utility of the baseline model.

Parameters with Design Limitations

Air gap between rotor and stator Service factor

Slot fill Assumed stray-load losses

Stator slot opening Motor diameter

Locked-rotor torque Cooling system

Locked-rotor current Rotor skew

Breakdown torque Stack length

Power factor Thermal performance

Speed at rated load

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• Stack Length

– In general, increasing stack length is a relatively inexpensive way to 

increase motor efficiency.

– Increasing stack length can also affect a motor’s ability to fit in some 

space-constrained applications.

– For each representative unit DOE developed two cost-efficiency 

curves, one for motors going into space-constrained applications and 

one for motors going into non-space constrained applications.

– DOE assumed space-constrained applications could only allow a 

20% increase in stack length, while non-space constrained 

applications could allow the stack length to double.

Motor Size Design Limitations: 

Stack Length

ISSUE 5. DOE seeks comment on the design options and 

limitations presented in the engineering analysis.

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Manufacturer

Selling Price

• Manufacturer Markups

– DOE applied a markup to the motor bill of materials for scrap factor, 

factory overhead, and non-production costs to develop manufacturer 

selling prices.

• Copper Rotor Pricing

– DOE increased the factory overhead markup for the higher 

depreciation of the tooling necessary to manufacture motors with a 

copper die-cast rotor.

Markups

ISSUE 4. DOE seeks comment on the various markups used in the 

engineering analysis, in particular the difference in overhead markups for 

designs that use a copper rotor and those that use an aluminum rotor.

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Example Cost-Efficiency Curve

(Polyphase, 4-pole, 1 hp motor)

$0

$50

$100

$150

$200

$250

$300

$350

76 78 80 82 84 86 88 90

Manufacturer Selling Price ($2008)

Full Load Efficiency (%)

Space Constrained

Non-Space Constrained

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Scaling the Engineering Analysis

Small Electric Motor Product Classes

Polyphase CSIR CSCR

hp / kW 2 

poles

4 

poles

6 

poles

2 

poles

4 

poles

6 

poles

2 

poles

4 

poles

6 

poles

1/4 / .18

1/3 / 0.25

1/2 / 0.37 Rep.

Unit

3/4 / 0.55 Rep. 

Unit

1 / 0.75 Rep. 

Unit

1 1⁄2 / 1.1

2 / 1.5

≥3 / 2.2

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• Scaling Motor Efficiencies

– DOE purchased and tested motors to develop efficiency relationships 

between poles and horsepower ratings.

– Testing was done by an independently accredited laboratory, who 

used the appropriate IEEE test procedures.

– The test data were supplemented with efficiencies from manufacturer 

catalogs.

• CSCR Scaling

– DOE used the same relationships found for CSIR motors to scale 

efficiencies for CSCR motors due to limited product availability.

• Scaling Manufacturer Selling Prices

– DOE developed scaling equations for prices based on data pulled 

from manufacturer catalogs.

Scaling the Engineering Analysis 

(continued)

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Scaling the Engineering Analysis 

(continued)

ISSUE 6. DOE seeks comment on the approach to scale the 

engineering analysis results to product classes for which a 

complete analysis was not performed, especially the decision to 

use the relationship found for CSIR motors to scale results for 

CSCR motors.

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• In the July 7, 2009, Final Rule for small electric motor test procedures, 

DOE uses the term “nominal full load efficiency” when defining the term 

basic model (§431.442) and when discussing the selection of basic 

models for testing if an AEDM [alternative efficiency determination 

method] is to be applied (§431.445(c)(i)(D)).

• Today, DOE proposes to define “nominal full load efficiency” as the 

average (arithmetic mean) full load efficiency of a population of motors.

– This is different than the definition used for electric motors.

– Electric motors definition is based on data that is not applicable to 

small electric motors.

– DOE will consider revising the definition in the future, should 

appropriate data become available.

Nominal Full Load Efficiency

ISSUE 7. DOE seeks comment on the proposal to define nominal efficiency 

as the arithmetic mean of the full load efficiencies of a population of motors 

of the same design.

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Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

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• Energy Use Characterization

– To develop electrical energy consumption savings estimates for selected 

equipment efficiency levels. 

– To develop distributions representing the variety of motor use patterns, 

including variability in motor hours of operation and motor loading.

• Markups for Equipment Price Determination

– To characterize the channels for how equipment is distributed from the 

manufacturer to the customer.

– To determine prices paid by customers based on manufacturer selling prices 

for baseline and higher efficiency equipment.

• Life-Cycle Cost and Payback Period Analyses

– To develop the customer life-cycle cost savings and payback period for higher 

efficiency equipment.

Purpose

Energy Use, Markups, Life Cycle Cost, 

and Payback Period

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Energy Use Characterization

• In view of additional information, new data, and comments after 

the preliminary analysis, DOE revised its methodology for 

calculating energy use. 

– In the preliminary analysis, DOE used values scaled from the 

engineering designs.

– For this NOPR analysis, DOE used the losses and power factors of 

the specific motor designs developed in the Engineering Analysis to 

calculate the energy use of representative product classes under 

each standards scenario.

• DOE used distributions to characterize motor loading and 

annual hours of operation. 

– In the preliminary analysis, DOE used point values.

– DOE used survey data for motor duty factor to develop annual 

hours of operation distributions that correspond to the average and 

typical (median) hours of operation developed in earlier stages of 

the analysis, but better reflect the wide range of small motor duty 

factor.

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• Inputs

– U.S. Census Bureau data (2002) from the 2002 Economic Census 

Manufacturing Industry Series for 11 types of OEMs

– Retailer and Distributor data from U.S. Census Business Expenses 

Survey

– National distribution of sales taxes

• Outputs

– Overall weighted average baseline markups of 2.49 (2.42 in preliminary 

analysis) for SEMs (including sales tax). 

– Overall weighted average incremental markups of 1.83 (1.75 in 

preliminary analysis) for SEMs (including sales tax).

Markups to Determine Equipment Price

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Markups: Distribution Channels 

• Estimated Fraction of Equipment Shipments by Distribution 

Channels

(Modified from preliminary analysis based on public comment)

SEM Market Shares 5% 65% 30%

Manufacturer

Motor User

Original 

Equipment 

Manufacturer 

(OEM)

Motor User Motor User

OEM

Distributor

Distributor

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• Life-Cycle Cost (LCC) equals customer price plus the sum of annual 

operating costs discounted to a particular base year (2015, in this case).

• Economic evaluation from the customer perspective.

• Analysis implemented in an Excel® spreadsheet combined with Crystal 

Ball® to estimate impacts for a sample of motor customers.

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

• Payback period (in years) is also calculated and reported in this analysis.

Life-Cycle Cost and Payback Period 

Analyses

Combine Changes 

in Costs LCC Results

Installed Cost

(Customer Price + Installation Cost)

Operating Expenses

Convert to 

Present 

Value

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• Electricity prices are distributions of average prices derived from 

2007 EIA Form 861 data and adjusted for inflation.

• Separate distributions derived for industrial, commercial, and 

residential customers. Agricultural customers were assumed to pay 

industrial electricity prices. 

• Electricity price projections were based on the ARRA case of AEO 

2009.

– Sensitivity analyses performed on high and low energy price forecasts. 

• Prices beyond 2030 are extrapolated based on the trend from 2020-

2030.

Life-Cycle Cost and Payback Period 

Analyses: Energy Prices

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• Installation costs based on RS Means, unchanged from preliminary analysis.

• Shipping costs of $0.50 per pound added in response to public comments.

• Discount rates (weighted average cost of capital—data updated from 2008 

Damodaran Online website). Average discount rate is 5.86% for commercial 

customers, 5.92% for industrial customers, and 5.5% for residential customers.

• Repair and maintenance costs do not change with efficiency (unchanged from the 

preliminary analysis)

• Equipment lifetime average 9 years for polyphase and 7 years for single-phase 

motors

– For NOPR analysis, DOE added correlation between annual hours of operation and motor 

lifetime

• A motor is retired when it reaches either its mechanical lifetime (measured in hours of 

operation) or the equipment of which it is a part reaches its lifetime (measured in 

years), whichever happens first.

• Distribution of shipments between applications changed from the preliminary 

analysis

• DOE estimated that shipments to space-constrained applications comprise 20% of 

motor shipments

Other Inputs

Life-Cycle Cost and Payback Period 

Analyses

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$1,200

$1,225

$1,250

$1,275

$1,300

$1,325

$1,350

$1,375

$1,400

76.0 78.0 80.0 82.0 84.0 86.0 88.0 90.0

Motor Efficiency (%)

Life Cycle Cost

Life Cycle Cost Analysis: Total Average Life Cycle Cost

Baseline

EL 1

EL 2

EL 3

EL 4

EL 5

EL 6

Sample Life-Cycle Cost Analysis Results: 

Polyphase 4-pole, 1 hp

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Life Cycle Cost Analysis: Customers with Net Benefit

0%

10%

20%

30%

40%

50%

60%

78.0 80.0 82.0 84.0 86.0 88.0 90.0

Motor Efficiency (%)

Percent of Customers with Net Benefit

EL 1

EL 2

EL 3

EL 4

EL 5

EL 6

EL 7

Sample Life-Cycle Cost Analysis Results: 

Polyphase 4-pole, 1 hp

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DOE invites comments on any issues pertaining to the Energy Use, Markups, 

and Life-Cycle Cost and Payback Period Analyses.

Public Comment

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Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

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• Purpose

– To evaluate the economic impacts of standards on customer subgroups 

that may be disproportionately impacted compared with the general user 

population.

• Method

– DOE identified two subgroups: disadvantaged businesses, exemplified 

by small businesses (which experience a higher discount rate); and 

customers with space-constrained applications.

– DOE used the LCC spreadsheet model to determine the impact on these 

two customer subgroups.

• Output

– LCC savings and simple payback period (in years) for the identified 

customer subgroup.

– Space-constrained customers and small businesses experience greater 

costs or fewer benefits than average customers.

Life-Cycle Cost Subgroup Analysis

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Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

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• Shipments Analysis

– To estimate small electric motor shipments over time.

• National Impact Analysis

– To estimate the National Energy Savings (NES) from small electric 

motors at different trial standard levels (TSLs), and

– To estimate the national economic impact on the nation (or the Net 

Present Value (NPV)) from equipment energy conservation 

standards at different efficiency levels.

Purpose of Shipments Analysis and 

National Impacts Analysis

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Approach

• Shipment forecasts (2015-2045) derived from:

– Estimated 2008 shipments and

– Growth drivers in the industrial, commercial, and residential sectors.

• Alternative shipments scenarios were examined through sensitivity analyses

– High Growth (AEO 2009)

– Low Growth (AEO 2009)

– Falling Market Share, which models constant shipments regardless of economic 

growth

• Shipments and stocks of equipment tracked by vintage and product class.

– DOE used the number of models as a proxy for shipments in order to estimate the 

shipments in product classes where no data were available.

Shipments Analysis

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Example of Shipments Forecasts: 

Polyphase Small Electric Motors

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

Year

Shipments (Millions)

Reference Case

High Growth Case

Low Growth Case

Falling Market Share

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Shipments Analysis: Market Response 

to Standards

• DOE's reference shipments analysis assumed that the market for covered 

small electric motors is inelastic. DOE conducted a sensitivity analysis with 

elasticities of -0.25 and -0.5, between covered small electric motors and 

totally enclosed small motors, using the same technologies.

ISSUE 10. DOE seeks input and data regarding how the small electric 

motors market will respond to the proposed standards. In particular, DOE 

seeks comment regarding alternative small electric motor technologies, such 

as electronically commutated motors, and how elasticity between the market 

for these alternative technologies and the market for covered motors could 

potentially affect the projected shipments and energy savings.

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Shipments Analysis: CSIR/CSCR 

Market Dynamics

• DOE developed a market share model based on current market shares, 

efficiencies, and prices.

• DOE used this model to forecast market shares in each product class 

under each TSL.

-20%

0%

20%

40%

60%

80%

100%

120%

-6 -4 -2 0 2 4 6

Cost Factor

Market Share

DOE Market Share Model

Current Estimated Market Share

EERE-2007-BT-STD-0007 COMMENT 20.3
45 | Building Technologies Program eere.energy.gov

ISSUE 11. DOE seeks input and data regarding how the single-phase small 

motor market will respond to the proposed standards. In particular, DOE 

seeks comment regarding its CSIR/CSCR cross-elasticity model, the current 

market shares of CSIR and CSCR motors in each combination of motor 

power and number of poles, and the barriers the customers face if they 

switch from CSIR to CSCR motors or vice versa.

• DOE developed a CSIR/CSCR market share cross-elasticity model using its 

shipments estimates for each combination of motor power and number of 

poles. The model uses the purchase price difference and energy use 

difference between CSIR and CSCR motors with the same power and number 

of poles to predict market share for each product class under each standards 

scenario.

Shipments Analysis: CSIR/CSCR Market 

Response to Standards

EERE-2007-BT-STD-0007 COMMENT 20.3
46 | Building Technologies Program eere.energy.gov

• National energy savings calculated for equipment purchased from 2015-2045 and National NPV 

calculated over the lifetime of those products (2015-2065). 

• Base case incorporates the penetration of higher efficiency motors.

Example: Polyphase Motors

• Standards “roll up” inefficient equipment, but do not affect efficient equipment.

Example: Standard at Efficiency = Level 4

• Account for all stock resulting from shipments during the period 2015-2045.

• Use national average customer prices for each product class (including different prices for spaceconstrained and non-space-constrained motors), annual energy use, lifetime, and energy prices from 

LCC analysis. Streams of energy use and total costs calculated over analysis time periods and costs 

discounted to the present. 

Level 1 Level 2 Level 3 Level 4 Level 5 Level 6 Level 7 Total

82.0% 4.0% 4.0% 4.0% 6.0% 0.0% 0.0% 100%

Level 1 Level 2 Level 3 Level 4 Level 5 Level 6 Level 7 Total

0.0% 0.0% 0.0% 94.0% 6.0% 0.0% 0.0% 100%

National Impact Analysis

EERE-2007-BT-STD-0007 COMMENT 20.3
47 | Building Technologies Program eere.energy.gov

NIA: Space Constrained Applications

ISSUE 12. DOE seeks comment regarding the behavior of customers with 

space-constrained applications, the costs they face, and the time-frame over 

which they may need to redesign a system or large piece of equipment to 

accommodate a larger-component small electric motor. DOE also seeks 

further information regarding the population and distribution of spaceconstrained customers among motor applications.

• DOE’s NIA analysis assumes that 20% of customers face space constraints, 

and that these customers are distributed across applications in proportion with 

all small motor customers.

• DOE’s analysis also assumes that the additional costs faced by motor 

customers with space-constrained applications do not change during the 

analysis period, and are equal to the additional cost of motors which use more 

expensive design options in order to avoid increases in stack length of more 

than 20%.

EERE-2007-BT-STD-0007 COMMENT 20.3
48 | Building Technologies Program eere.energy.gov

NIA: Combined Assumptions

ISSUE 13. DOE seeks comment regarding the combined effect of the several 

assumptions and estimates that DOE makes in order to estimate the impact of 

standards under expected market shifts. DOE seeks comment regarding its 

approach and suggestions on how forecasted market shifts can be estimated 

and weighed against the potential increases in benefits when selecting a higher 

standard level that may induce a shift in motor purchases.

• The results of DOE’s single-phase NIA model depend on several assumptions 

made throughout the analyses, including: the costs associated with purchasing 

motors for space-constrained applications, the portion of space-constrained 

applications in the market, shipments in each product class, the scaling of 

motor losses and prices between product classes, and the mathematical form 

of DOE’s cross-elasticity model.

EERE-2007-BT-STD-0007 COMMENT 20.3
49 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
50 | Building Technologies Program eere.energy.gov

• Purpose

– To develop a list of standard levels from which impacts are weighed and a 

proposed standard level is selected.

• Method 

– Trial standard levels were developed for the NOPR.

– Analyzed standard levels cover a range of efficiencies and can include:

– Efficiency level with the highest energy savings;

– Efficiency level with the lowest life-cycle cost;

– Most energy efficient level; and

– Efficiency levels that fill in large gaps between standard levels.

– The two capacitor-start motor categories were paired together when 

creating TSLs due to the market interaction between the two categories.

Trial Standard Levels (TSLs)

EERE-2007-BT-STD-0007 COMMENT 20.3
51 | Building Technologies Program eere.energy.gov

TSL CSIR EL CSCR EL Notes

8 7 7 EL combination with greatest energy 

savings

7 7 3 Same efficiency requirements for CSIR 

and CSCR motors

6 7 8 Maximum-Technology ELs

5 6 3 NEMA Recommended Level 2*

4 6 4 Highest ELs with positive LCC savings

3 5 3 Highest ELs with majority LCC 

beneficiaries

2 4 3 Minimum LCCs for CSIR and CSCR

1 4 2 NEMA Recommended Level 1*

* NEMA-recommended levels represent levels that NEMA requested DOE to examine through their submitted comment.

TSLs for Capacitor-Start 

Small Electric Motors

EERE-2007-BT-STD-0007 COMMENT 20.3
52 | Building Technologies Program eere.energy.gov

Polyphase

TSL

Polyphase 

EL Notes

7 7 EL with the greatest energy savings

6 6 Intermediate EL

5 5 Harmonizes with Medium Motors Standards 

(NEMA Premium)

4 4 Highest EL with Positive LCC Savings

3 3 Minimum LCC

2 2 Intermediate EL

1 1 Intermediate EL

TSLs for Polyphase 

Small Electric Motors

EERE-2007-BT-STD-0007 COMMENT 20.3
53 | Building Technologies Program eere.energy.gov

• Polyphase Small Electric Motors

– TSL 5 is the highest TSL with a positive NPV, $0.06 billion.

– Estimated national energy savings for TSL 5 are 0.33 quads.

• Capacitor-Start Small Electric Motors

– TSL 7 provides an NPV of $1.47 to $5.67 billion at a 7-percent 

discount rate.

– Estimated national energy savings for TSL 7 are 2.10 to 2.13 

quads.

– Ranges in capacitor-start values reflect the uncertainty regarding 

changes in CSIR and CSCR motor market shares in response to 

the standards.

NPV and NES Results by TSL

EERE-2007-BT-STD-0007 COMMENT 20.3
54 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
55 | Building Technologies Program eere.energy.gov

• Purpose

– To assess the impacts of standards on SEM manufacturers;

– To identify and estimate impacts on manufacturer sub-groups that may 

be more severely impacted than the industry as a whole; and

– To examine the impact of cumulative regulatory burdens on the 

industry.

• Method 

– Analyze industry cash flow and net present value through use of the 

Government Regulatory Impact Model (GRIM); and

– Interview manufacturers to refine inputs to the GRIM, develop subgroup analyses, and address qualitative issues.

Manufacturer Impact Analysis

EERE-2007-BT-STD-0007 COMMENT 20.3
56 | Building Technologies Program eere.energy.gov

• The MIA consists of three phases:

Industry 

profile

Develop 

strawman 

GRIM*

Develop 

interview 

guide

Interviews 

& industrywide/ 

subgroup 

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Finalize

MIA 

results 

for 

NOPR

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

Manufacturer Impact Analysis Process

EERE-2007-BT-STD-0007 COMMENT 20.3
57 | Building Technologies Program eere.energy.gov

• Impact of Increasing Motor Size

– To achieve higher efficiencies manufacturers may need to 

increase motor sizes

– Motor size increases could potentially eliminate some retrofit 

applications

– Consumers could be forced to migrate to unregulated motors 

or smaller horsepower motors for space-constrained 

applications

– DOE incorporates these concerns throughout its analysis 

including the engineering and shipments analyses, which 

are inputs to the GRIM

Key Issues

EERE-2007-BT-STD-0007 COMMENT 20.3
58 | Building Technologies Program eere.energy.gov

• Capital Conversion Costs

– Possible exit of market due to high investments for small 

segment of some manufacturers’ entire business

– Significant investments for alternative metals in redesigns

• DOE estimated capital conversion costs for each design option 

from the engineering analysis giving weights to space 

constrained and non-space constrained assumptions.

• Capital conversion cost estimates were derived through 

information provided by manufacturers and industry experts.

• DOE derived industry wide capital investments by aggregating 

responses from manufacturers and DOE’s own estimates.

Key Issues (continued)

ISSUE 9. DOE seeks comment on the capital investments needed 

to reach each efficiency level.

EERE-2007-BT-STD-0007 COMMENT 20.3
59 | Building Technologies Program eere.energy.gov

• Preservation of Return on Invested Capital - Upper Bound 

Scenario

– Return on invested capital is the ratio of net operating profits (after 

taxes) to invested capital.

– Markups are set so that as invested capital increases, net operating 

profits proportionately increase.

• Preservation of Operating Profit (Absolute Dollars) - Lower 

Bound Scenario

– Operating profit is earnings before interest and taxes.

– Assumes once standards are implemented, manufacturers maintain 

same total operating profits as before standards.

ISSUE 8. DOE seeks comments on the use of the preservation of 

operating profits as the lower bound scenario and the 

preservation of return on invested capital as the upper bound 

scenario for the INPV results generated in the MIA.

Analyzed Markup Scenarios

EERE-2007-BT-STD-0007 COMMENT 20.3
60 | Building Technologies Program eere.energy.gov

Polyphase Motors

Units Base

Case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 TSL 7

INPV (2008$ 

millions) 64 63 – 65 63 – 65 62 – 66 62 – 67 55 – 75 51 – 80 4 – 149

Change in 

INPV

(2008$

millions) - (1.14) –0.52

(1.56) –

1.11

(2.01) –

1.83

(2.39) –

2.41

(8.83) –

10.85

(13.09) –

15.94

(59.74) –

85.23

(%) - (1.78) –

0.80

(2.42) –

1.74

(3.14) –

2.86

(3.73) –

3.73

(13.76) –

16.91

(20.41) –

24.84

(93.14) –

132.87

Total 

Investment 

Required

(2008$

millions) - 1.4 1.6 1.7 1.9 5.9 9.2 30.9

SEM GRIM Results

EERE-2007-BT-STD-0007 COMMENT 20.3
61 | Building Technologies Program eere.energy.gov

CSIR – CSCR Motors

Units Base

Case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 TSL 7 TSL 8

INPV (2008$ 

millions) 279 264 – 290 263 – 291 256 – 297 247 – 310 250 – 307 141 – 467 243 – 309 226 – 336

Change in 

INPV (2008$

millions) - (14.87) –11.21

(15.64) –

12.22

(22.87) –

18.03

(31.57) –

31.21

(29.01) –

27.96

(137.53) –

187.88

(35.84) –

29.80

(53.30) –

56.70

(%) - (5.33) –

4.02

(5.61) –

4.38

(8.20) –

6.47

(11.32) –

11.19

(10.41) –

10.03

(49.33) –

67.39

(12.86) –

10.69

(19.12) –

20.34

Total 

Investment 

Required

(2008$

millions) - 16.9 17.9 24.5 27.3 24.5 70.8 45.7 50.4

SEM GRIM Results (continued)

EERE-2007-BT-STD-0007 COMMENT 20.3
62 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
63 | Building Technologies Program eere.energy.gov

• Purpose

– To investigate the effects on utilities from reduced energy sales and peak 

load demand due to potential standards.

• Method

– Use National Energy Savings Results; and

– Use the EIA’s National Energy Modeling System (NEMS-BT) tailored for 

DOE’s Building Technologies Program.

• Output

– Change in electricity sales and price by region;

– Change in the mix of electricity generation; and

– Change in installed capacity and generation.

Utility Impact Analysis

EERE-2007-BT-STD-0007 COMMENT 20.3
64 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
65 | Building Technologies Program eere.energy.gov

• Purpose

– To report net jobs created or eliminated nationally as a consequence of new or 

amended energy conservation standards. Employment impacts include direct and 

indirect impacts.

• Method

– Uses the Impact of Sector Energy Technologies (ImSET) model to assess the 

indirect employment impacts;

– Estimate changes in employment, industry output, and wage income in the overall 

United States economy resulting from changes in expenditures in the various 

sectors of the economy;

– Estimate changes in costs and benefits using the NES analysis; and

– Direct employment impacts are addressed in the Manufacturer Impact Analysis 

(MIA).

• Output

– Change in employment in national economy, other than in the manufacturing 

sector being regulated, as a consequence of the amended energy conservation 

standards.

Employment Impact Analysis

EERE-2007-BT-STD-0007 COMMENT 20.3
66 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
67 | Building Technologies Program eere.energy.gov

• Purpose

– To report environmental impacts as a consequence of the amended energy 

conservation standards, including changes in power plant emissions.

• Output

– Calculated the reduction in power plant emissions of carbon dioxide (CO2), oxides 

of nitrogen (NOX) and mercury (Hg), using the NEMS-BT computer model.

– Sulfur dioxide (SO2) emission was not included due to uncertainty regarding 

impacts of electricity use reductions on the capped emissions under Title IV of the 

Clean Air Act and the Clean Air Interstate Rule. The NEMS-BT model predicts no 

change in physical SO2 emissions from the power sector.

– Monetized value of reductions in CO2, NOX, and Hg.

– Particulate matter (PM) was not included because DOE is unable to generate a 

reliable estimate due to the complex interactions between PM, other power plant 

emissions, meteorology and atmospheric chemistry that impact human exposure 

to particulates.

Environmental Assessment

EERE-2007-BT-STD-0007 COMMENT 20.3
68 | Building Technologies Program eere.energy.gov

ISSUE 14. DOE seeks comment on the appropriateness of using other discount 

rates in addition to seven percent and three percent real to discount future 

emissions reductions. 

ISSUE 15. DOE seeks comment on the determination of the anticipated 

environmental impacts of the proposed rule, particularly with respect to the 

methods for valuing the expected CO2, NOX, and Hg emissions savings due to the 

proposed standards. 

– DOE believes that discounted environmental benefits represent a policy perspective wherein 

benefits farther in the future are less significant than energy savings closer to the present.

– DOE has made several additions to its monetization of environmental emissions reductions in 

today’s proposed rule, and has chosen to report these benefits both separately from and together 

with the net benefits of energy savings.

– Nothing in EPCA, nor in the National Environmental Policy Act, requires that the economic value 

of emissions reduction be incorporated in the net present value analysis of the value of energy 

savings. 

– Unlike energy savings, the economic value of emissions reduction is not priced in the 

marketplace. 

Environmental Assessment (continued) 

EERE-2007-BT-STD-0007 COMMENT 20.3
69 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
70 | Building Technologies Program eere.energy.gov

• Purpose

– To investigate the national impacts of non-regulatory alternatives 

compared with mandatory energy conservation standards.

– The non-regulatory alternatives that DOE analyzed include: 

• No New Regulatory Action;

• Bulk Government Purchases;

• Customer Rebates;

• Customer Tax Credits; 

• Manufacturer Tax Credits; and

• Voluntary Energy-Efficiency Targets—ENERGY STAR or NEMA Premium.

• Method

– A variant of the National Impact Analysis spreadsheet model evaluated 

the national energy savings and net present value of each nonregulatory alternative.

• Output

– National Energy Savings and Net Present Value of each of the nonregulatory alternatives.

Regulatory Impact Analysis

EERE-2007-BT-STD-0007 COMMENT 20.3
71 | Building Technologies Program eere.energy.gov

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Trial

Standard

Levels

Revise 

Preliminary 

Analyses

Environmental 

Assessment

Regulatory 

Impact 

Analysis

Employment

Impact

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analyses

National

Impact

Analysis

Framework

Document

Preliminary

Analysis NOPR

Final

Rule

Customer

Subgroup

Analysis

NOPR Analyses Flow Diagram 

EERE-2007-BT-STD-0007 COMMENT 20.3
72 | Building Technologies Program eere.energy.gov

• DOE is proposing trial standard level (TSL) 5 for polyphase small 

electric motors.

Proposed Energy 

Conservation Standards

Motor horsepower/

standard kilowatt equivalent

Nominal full load efficiency

Polyphase 

(number of poles)

6 4 2

0.25 / 0.18 77.4 72.7 69.8

0.33 / 0.25 79.1 75.6 73.7

0.5 / 0.37 81.1 80.1 76.0

0.75 / 0.55 84.0 83.5 81.6

1 / 0.75 84.2 85.2 83.6

1.5 / 1.1 85.2 87.1 86.6

2 / 1.5 89.2 88.0 88.2

3 / 2.2 90.8 90.0 90.5

EERE-2007-BT-STD-0007 COMMENT 20.3
73 | Building Technologies Program eere.energy.gov

Proposed Energy 

Conservation Standards

• DOE is proposing TSL 7 for single-phase (capacitor-start) small 

electric motors.

Motor horsepower/

standard kilowatt 

equivalent

Nominal full load efficiency

CSIR 

(number of poles)

CSCR 

(number of poles)

6 4 2 6 4 2

0.25 / 0.18 65.4 69.8 71.4 63.9 68.3 70.0

0.33 / 0.25 70.7 72.8 74.2 69.2 71.6 72.9

0.5 / 0.37 77.0 77.0 76.3 75.8 76.0 75.1

0.75 / 0.55 81.0 80.9 78.1 79.9 80.3 77.0

1 / 0.75 84.1 82.8 80.0 83.2 82.0 79.0

1.5 / 1.1 87.7 85.5 82.2 87.0 84.9 81.4

2 / 1.5 89.8 86.5 85.0 89.1 86.1 84.2

3 / 2.2 92.2 88.9 85.6 91.7 88.5 84.9

EERE-2007-BT-STD-0007 COMMENT 20.3
74 | Building Technologies Program eere.energy.gov

Request for Additional Comments

DOE invites comments on any remaining issues pertaining to this 

NOPR.

Public Comment

EERE-2007-BT-STD-0007 COMMENT 20.3
75 | Building Technologies Program eere.energy.gov

• Public Meeting – Oral comments will be captured in the transcript and 

become part of the public record.

• Written comments – NOPR comment period is open until January 25, 

2010.

Reference docket #: EERE-2007-BT-STD-0007 and/or RIN #: 1904-

AB70.

Email: small_electric_motors_std.rulemaking@hq.doe.gov. 

Mail: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE–2J

1000 Independence Avenue, SW.

Washington, DC 20585–0121.

Telephone: (202) 586–2945.

Courier: Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, SW., 6th Floor,

Washington, DC 20024.

Submission of Comments

EERE-2007-BT-STD-0007 COMMENT 20.3