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Commercial and Industrial Pumps 

Manufacturer’s Interview Guide 

 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

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INTRODUCTION 

Thank you for expressing interest in participating in The U.S. Department of Energy (DOE) 

Manufacturer Impact Analysis for the commercial and industrial pumps rulemaking. Currently, 

there are no established energy conservation standards for commercial and industrial pumps. 

DOE has initiated a rulemaking process to develop such standards based on the authority 

described below. The rulemaking process typically includes four major phases: 

1. The publication of a framework document in which DOE describes the overall approach 

it is considering in developing potential energy conservation standards for a particular 

product or equipment; 

2. The publication of a preliminary analysis that focuses on the analytical methodology 

DOE is considering in setting potential standards; 

3. The issuance of a notice of proposed rulemaking (NOPR); and 

4. The issuance of a final rule. 

At each of the first three steps, DOE holds a public meeting and solicits comments from the on 

issues relevant to the development of potential standards. It should also be noted that a separate 

rulemaking process to establish a test procedure for the covered equipment will run in parallel to 

the energy conservation standards rulemaking. The resulting test procedure will establish both a 

metric and method for measuring the energy consumption of the equipment. 

History of this rulemaking to date: 

The framework document for commercial and industrial pumps was published in February 2013 

and comments on the framework were accepted until May 2, 2013. The next phase of the 

rulemaking is the preliminary analysis during which DOE will consider feedback on the 

approach presented in the framework and explore methods to establish candidate, or draft, 

standards levels (CSLs). CSLs span the range of efficiencies from the most basic equipment to 

the most efficient technology (max-tech) that is both feasible and cost effective. DOE conducts 

an engineering analysis to determine the costs associated with increasing efficiency from the 

baseline to various higher levels of efficiency. 

Authority: 

Title III of the Energy Policy and Conservation Act of 1975 (EPCA), as amended (42 U.S.C. 

6291 et seq.), sets forth various provisions designed to improve energy efficiency. Part C of Title 

III of EPCA (42 U.S.C. 6311-6317) (re-designated as part A-1 upon codification in the U.S. 

Code), establishes the "Energy Conservation Program for Certain Industrial Equipment," which 

covers electric motors and pumps. Under EPCA, any new or amended standards must achieve 

the maximum improvement in energy efficiency that is technologically feasible and 

economically justified. The DOE Appliances and Equipment Standards Program, within the 

Office of Energy Efficiency and Renewable Energy’s Building Technologies Office (BTO), 

develops and promulgates these potential energy conservation standards. 

Method: 

One method by which DOE collects information on costs is through interviews between DOE 

contractors and manufacturers. Due to concerns regarding the Freedom of Information Act and 

its potential for disclosures, DOE has hired Navigant Consulting, Inc. (Navigant) and Lawrence 

Berkley National Laboratory (LBNL) to interview manufacturers and aggregate responses across 
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Preliminary Analysis Interview Guide 

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the industry. These aggregated responses protect individual sources while also allowing 

rulemaking stakeholders an insight into issues that are sensitive for manufacturers. 

 

During an interview, the contractor asks a series of questions relating to production costs, 

historical shipment data, capital conversion expenditures, marketing costs, R&D investment, and 

the potential impact of standards on a manufacturer. 

The above approach enables Navigant and LBNL to characterize the cost-efficiency relationship 

for all pumps equipment categories. This approach also allows the public to examine aggregate 

cost and design assumptions that underlie the cost-efficiency estimates, while maintaining the 

confidentiality of each manufacturer’s proprietary data. Understanding the cost-efficiency 

relationship will inform downstream evaluation of the CSLs and help DOE determine whether an 

energy conservation standard is economically justified. Manufacturer participation is needed for 

potential impacts and costs to the industry to be accurately captured and presented to decisionmakers. 

Confidentiality: 

In order to maintain confidentiality of any sensitive data submitted, the two DOE contractors for 

this rulemaking, Navigant and LBNL, will treat any submitted or discussed data per the terms of 

any agreement reached with a manufacturer. Any material shared with either DOE contractor 

under the terms of a non-disclosure will not be shared with DOE, other than in aggregate for an 

industry, obfuscating the sources for the data. Materials submitted to DOE may be subject to a 

variety of laws and regulations governing the disclosure of Federal agency information. 

Information submitted to DOE will be protected in accordance with all applicable federal laws, 

rules, or regulations, including but not limited to the Trade Secrets Act, 18 U.S.C. §1905, and the 

Freedom of Information Act (FOIA), 5 U.S.C. §552, and DOE's implementing regulations at 10 

CFR 1004. 

To aid the manufacturer interview process, Navigant and LBNL have developed this “interview 

guide” with sets of questions regarding the aforementioned topics. Navigant and LBNL welcome 

pre-prepared responses to help facilitate discussion. The guide is broken into three sections: A) 

the Engineering Analysis, B) the Market Questionnaire, and C) the Manufacturer Impact 

Questionnaire. Each section provides details describing the analysis and its contribution to the 

overall rulemaking process. 

 
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Navigant and LBNL have prepared the following manufacturer’s interview guide with the 

understanding that certain information asked below is sensitive to the manufacturer. Therefore, 

Navigant and LBNL wish to enter into a non-disclosure agreement with your company in order 

to ensure any data you provide in response to this guide is held in the strictest confidence. 

Navigant and LBNL will combine your response with responses from several other companies to 

develop a representative industry ‘average’ response. 

If you have any questions, please contact: 

Callie Reis Daniel Weintraub 

781.270.8326 781.270.8397 

callie.reis@navigant.com daniel.weintraub@navigant.com 
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A. ENGINEERING ANALYSIS 

The purpose of the engineering analysis is to estimate the relationship between manufacturer 

selling price (MSP) of a pump and its corresponding efficiency rating. In determining the costefficiency relationship, DOE estimates the increase in MSP associated with design changes that 

increase the efficiency of pumps relative to the baseline models. In most cases, baseline models 

are defined as the most typical low efficiency equipment currently sold on the market. This 

relationship serves as the basis for the subsequent cost-benefit calculations for individual 

consumers, manufacturers, and the nation. 

The MSP is determined by multiplying manufacturer production costs (MPC) by a markup. 

MPC includes direct production costs such as materials, labor, maintenance, depreciation, and 

taxes. The markup represents the portion of the MSP used to cover profit margins and nonproduction costs. 

MSP typically does not include non-recurring expenses, known as Conversion Costs. These 

costs are generally broken into two sub-categories; Product Conversion Costs (PCC) and Capital 

Conversion Costs (CCC). PCC represents the cost to redesign and test products, while CCC 

represents the cost of capital investments needed to manufacture products meeting new 

standards. Questions regarding these costs can be found in Section C, Manufacturer Impact. An 

opportunity to discuss costs associated with hydraulic redesign will be provided there. 

DOE is currently considering clean-water, centrifugal pumps less than 200 horsepower (HP) for 

coverage in this rulemaking, including pumps of fractional horsepower. In this and other 

sections, please provide responses for the full range of horsepower, 0-200 HP, as directed. 

 
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Below is a table of DOE’s considered equipment categories and their corresponding EU and 

ANSI/HI terminology. 

Table A.1 Commercial and Industrial Pump Equipment Categories 

Equipment Category 

(DOE Terminology) Stage EU Terminology ANSI/HI Nomenclature 

End Suction Close Coupled 

(ESCC) Single ESCC OH7 

End Suction Frame Mounted (ESFM) Single End Suction Own Bearing (ESOB) OH0, OH1 

In-Line (IL) Single ESCCi 

(+ Flexibly and rigidly coupled pumps) OH3, OH4, OH5 

Double Suction (DS) Single N/A BB1 (1 stage) 

Axially Split Multi-Stage (AS) Multi N/A BB1 (2 stage), 

BB3 

Radially Split Multi-Stage Horizontal 

(RS-H) Multi MS-V (+ Flexibly Coupled) BB2 (2 stage), BB4 

Radially Split Multi-Stage Vertical 

(RS-V) Multi MS-V (+ Flexibly Coupled) VS8 

Vertical Turbine (VT) Any N/A VS1 

Submersible (VT-S) Any MSS VS0 

Axial/Propeller and Mixed (A-M) Any N/A OH00 

Wet-running Circulators (CIRC)* Single Glandless Circulators - 

 *This category typically ranges from 0-3HP

A.Q.1. Please comment on whether the “Equipment Category” description in column one of 

Table A.1 matches your definition under the ANSI/HI nomenclature listed in column 

four. 

 
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A.Q.2. To help DOE understand the market and the relative importance of various equipment 

categories to specific manufacturers, please disaggregate your annual unit shipments for 

each product category as shown in the table below. Please indicate whether you purchase 

these products from other manufacturers and what fraction of your product is 

manufactured in the United States. Please provide your answers in the table below (Table 

A.2) 

Table A.2 Market Share and Domestic Manufacturing 

Equipment 

Category 

ANSI/HI 

Nomenclature 

Yearly 

Shipments 

(2012) 

Market Share 

(% of total 

pump market) 

% Made % Bought % Made in 

U.S.A 

ESCC OH7 

ESFM OH0, OH1 

IL OH3, OH4, 

OH5 

DS BB1 (1 stage) 

AS BB1 (2 stage), 

BB3 

RS-H BB2 (2 stage), 

BB4, 

RS-V VS8 

VT VS1 

VT-S VS0 

A-M OH00 

 
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A.Q.3. DOE is also considering coverage of wet-running circulators which range from 

approximately 0-3 HP. For the wet-running circulators you produce, please disaggregate 

your annual unit shipments for each product category as shown in the table below. Please 

indicate whether you purchase these products from other manufacturers and what fraction 

of your product is manufactured in the United States. 

Table A.3 Market Share and Domestic Manufacturing

Equipment 

Category 

ANSI/HI 

Nomenclature 

Yearly 

Shipments 

(2012) 

Market Share 

(% of total 

pump market) 

% Made % Bought % Made in 

U.S.A 

CIRC 

A.Q.4. If your company produces non-wet-running (EU: glanded) circulators, please circle the 

equipment categories that would include those circulators as classified by the DOE 

terminology above. 

ESCC ESFM IL DS AS RS VT VT-S A-M

Please provide the HP range of the non-wet-running circulators you manufacture: 

 
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A.Q.5. How many pump series do you offer in each equipment category and how many models 

are there typically in each pump series? 

Table A.4 Pump Series by Equipment Category

Equipment 

Category # of Series # Models per Series 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
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A.1 Incremental Efficiency Levels and the EU Method 

To establish a set of preliminary efficiency criteria, DOE is considering the European Directive 

2009/125/EC as a starting point for developing cost-efficiency relationships. The EU regulation 

sets minimum efficiency requirements for certain types of pumps with the goal of preventing a 

set percentage of inefficient pumps from being sold in the marketplace. This minimum efficiency 

requirement is dependent on a pump’s specific speed and flow rate and can be calculated by 

using the following equation: 

 

where C is determined by the pump type, design speed, and the desired percentage of pumps to 

be “cut-off” (removed) from the marketplace. Q is flow in m3

/h and ns is specific speed in metric 

units. 

The percentage of pumps cut-off by a certain C value is represented by the Minimum Efficiency 

Index (MEI). For example, an MEI of 0.4 indicates that 40% of pumps sold in the EU (based on 

efficiencies available in the 2008 market) would be removed by the minimum efficiency 

requirement. 

The EU regulation increases the MEI on a biennial basis. The first requirement, MEI 0.1, went 

into effect in January 2013. This requirement will increase to MEI 0.4 in January 2015. 

The EU regulation also evaluates pumps not only at best efficiency point (BEP) but also 75% 

BEP flow and 110% BEP flow, allowing lower efficiency levels for these flows. If a pump fails 

to meet efficiency criteria at any one flow, it is not compliant with the regulation. 

 
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A.Q.6. DOE would like to quantify differences between US and EU product offerings. Please 

use Table A.5 to provide the number of SKUs sold in one region, but not the other. In 

addition, please provide the revenues associated with these SKUs.

Table A.5 Unique US and EU Product Offerings

Sold in EU but not sold 

in US 

Sold in both the EU 

and US 

Sold in US but not sold 

in EU 

SKUs (#) 

SKUs as a Percent of Total 

US & EU SKUs (%) 

Revenues for Listed SKUs 

($) 

What are the major differences between the EU and US market that cause you to develop 

different SKUs? 

A.Q.7. By 2016, in absence of a US standard, how do you anticipate the range of efficiency of 

pumps sold in the US may have changed due to the EU regulation? 

A.Q.8. In absence of a US standard, do you anticipate discontinuing the sale of certain products 

or product lines in the US because they do not meet EU efficiency requirements? 

 
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A.Q.9. What percentage of your current US products would be cut-off for the following MEIs, 

and of those, what percentage would be redesigned? What percentage would be dropped 

all together? How many individual models do these numbers represent? 

Table A.6 Percentage of pumps removed by EU standards 

% of Pumps removed by EU Efficiency Equation (10, 40, 70) 

Equipment 

Category MEI = 0.1 MEI = 0.4 MEI = 0.7 

ESCC 

e.g., 13% cut-off (3 pump 

models) 

5% redesigned 

 

ESFM 

 

IL 

 

DS 

 

AS 

 

RS - H 

 

RS - V 

 

VT 

 

VT-S 

 

A-M 

 

CIRC 

 

A.Q.10.To meet a US standard, will you be able to utilize design or other modifications made to 

comply with the EU standard? 
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A.2 Design Options 

Historically, DOE considers different design options that increase product efficiency in order to 

analyze the relationship between manufacturer selling price and the efficiency of the product. 

DOE is aware that other approaches may need to be considered for pumps, but still seeks 

information on how certain design options impact efficiency. 

A.Q.11.Please comment on the estimated gain in efficiency offered by each of the design 

options listed below. For what type or size of pumps are these gains realistic? It is 

understood that gains may or may not be additive. 

 Smoothing Surface Finish: 1-3% increase 

 Reducing running clearances: up to 3% increase 

 Reducing mechanical friction in seals: < 1% 

 Reducing other volumetric losses: 1-3% 

 Hydraulic redesign: 10-12% 

(Includes impeller design/geometry, and volute design/geometry) 

 Please list any other design options that you may implement, along with 

associated estimated gains in efficiency. 
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A.Q.12. Do any of these efficiency gains vary with capacity, specific speed, or other parameter? 

If so, how? (i.e. lower at low Ns, higher in small pumps, etc.) 

A.Q.13.Please provide an estimated range of cost, per unit, for implementing the above design 

options. Please provide your ranges in terms of example pumps. Please specify model 

numbers, or flows, heads, and speed. Will these costs vary by equipment category? 

 Smoothing surface finish: 

 Reducing running clearances: 

 Reducing mechanical friction in seals: 

 Reducing other volumetric losses: 

 Hydraulic redesign: 

 Other: 

 
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A.Q.14.Do any of these design options have issues related to: 

1. Degradation (e.g., surfaces become rough or clearances widen after a few months 

use) 

2. Additional maintenance burden 

3. Increased rate of failure/decreased time between repair (MTBR) 

4. Installation constraints (i.e. only work if the pump user follows specific practices) 

5. Adverse impacts on consumer utility 

6. Increase installation cost to the user? Why and by how much? 

Please indicate your answer in Table A.7 and describe the estimated magnitude of the issue. 

Table A.7 Barriers to design option implementation 

Design Option Degradation Maintenance MTBR Install. 

Constraints Utility Installation Cost 

Smoothing 

Surface Finish 

 

Reducing 

running 

clearances 

 

Reducing 

mechanical 

friction in seals 

 

Reducing other 

volumetric losses 

 

Hydraulic 

redesign 

 

Other 

(Please Specify) 

 

 
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A.Q.15.Which of the above options would you be likely to implement? What determines your 

choice? 

A.Q.16.In the absence of efficiency regulations, what were your key design priorities, and how 

did they generally rank. For example, durability/reliability, costs, efficiency, etc.? 

 
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A.Q.17. Assuming DOE were to use the EU efficiency equation and MEI values for the US 

market, what ranges of incremental changes in manufacturing production costs (MPC) 

would be associated with each increase in MEI? This assumes you decide to redesign 

non-compliant pumps, rather than discontinue them. 

Please provide your ranges in terms of example pumps Please specify model numbers, 

or flows, heads, and speed. 

Table A.8 Incremental costs associated with improvements in efficiency 

% of Pumps removed by EU Efficiency Equation (10, 40, 70) 

Equipment 

Category MEI = 0.1 MEI = 0.4 MEI = 0.7 

ESCC 

e.g., Smoothing operation on 

volute, $2-$6/(100-1000gpm, 50-

150ft, 1800RPM, models 123-128)

 

ESFM 

 

IL 

 

DS 

 

AS 

 

RS-H 

 

RS - V 

 

VT 

 

VT-S 

 

A-M 

 

CIRC 

 

 
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A.Q.18.What design features currently differentiate efficient pumps from those that may not 

meet new standards? Do these features differ by equipment category? 

A.3 Pump Motor and Control System 

A.Q.19.Is the same pump, in terms of hydraulic design, sold with the intent of being used at 

multiple design speeds? Do you indicate the design speed/speed range of the pump on 

the nameplate when sold without a motor? With a motor? 

A.Q.20. Are there hydraulic (or other) design changes that could be made to reduce the net 

positive suction head required (NPSHr) for higher speed pumps so that a higher design 

speed and specific speed pump could be used for typically low specific speed 

applications? 

A.Q.21.In your opinion how important is it that pumps are able to be sold without a motor 

specified or distributed by the manufacturer? What is the utility to the consumer of a 

bare pump? What about the utility of a pump and motor without VSD or other controls? 
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A.4 Materials, Manufacturing, Sourcing, and Assembly 

A.Q.22.From what materials are the following components typically manufactured? Please use 

Table A.9 to specify by equipment category. Be as specific as possible with metal 

alloys. 

Table A.9 Component Materials 

Equipment 

Category Impeller Volute Wear Rings Shaft Shaft Sleeve 

ESCC 

Example: 

316 Stainless Steel 

C903 Tin Bronze 

 

ESFM 

 

IL 

 

DS 

 

AS 

 

RS-H 

 

RS-V 

 

VT 

 

VT-S 

 

A-M 

 

CIRC 

 

 
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A.Q.23.For the following product categories, please describe the extent to which you purchase 

components from outside vendors or manufacture in-house. 

 Specifically, please try to answer the following questions: 

 Are these parts cast in-house? 

 Are these parts finish machined in-house? 

Or; 

 Do these parts arrive completely finished and ready for assembly? 

Table A.10 Make vs. Buy 

Equipment 

Category Impeller Volute Wear Rings Shaft Shaft Sleeve 

ESCC 

Example: 

Purchased casting 

Machined inhouse 

Example: 

Purchased 

complete from 

vendor

Example: 

Machined inhouse from barstock

 

ESFM 

 

IL 

 

DS 

 

AS 

 

RS-H 

 

RS-V 

 

VT 

 

VT-S 

 

A-M 

 

CIRC 

 
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A.Q.24.What factors drive your Make vs. Buy decision making process? What type of premium 

do you typically pay to have a component made out of house, versus in-house? Have 

you switched any of these components recently? 

A.Q.25.For components cast in-house: 

 Please provide the bulk costs for the raw materials listed in Table A.10. Cost 

should represent the delivered cost of ingot and like raw materials, inclusive of 

all shipping and processing fees. 

 What is the average reject-rate for your casting process? 

 Is the same cast used for multiple pump models, such as those of different 

materials? 

 
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A.Q.26.For components that are finish-machined in-house: 

What are the key manufacturing processes that each component goes through after 

casting? What types of machines are used in these processes? Please note if any specific 

processes are outsourced. 

Impeller: 

Volute: 

Wear Rings:

Shaft Sleeves: 

Shaft: 

A.Q.27.What are your key manufacturing investments? e.g. Casting, Machining, Grinding, etc. 

How much would it cost to set up a new line for each, from scratch? 
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A.Q.28.For components that are cast and/or finished by outside vendors, please describe the 

price range for each component or manufacturing process, as well as the material. 

Please provide your answer in terms of example pumps. Please specify model number, 

or flow, head, and speed. Cost should represent the delivered cost, inclusive of all 

shipping and processing fees. 

Table A.11 Purchased Part and Outside Processing Costs 

Equipment 

Category Impeller Volute Wear Rings Shaft Shaft Sleeve 

ESCC 

Example: 

Unit: 100gpm, 

50ft, model 123 

Casting: $25 - 

$100 

Bronze C903 

 

ESFM 

 

IL 

 

DS 

 

AS 

 

RS-H 

 

RS-V 

 

VT 

 

VT-S 

 

A-M 

 

CIRC 

 

 
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A.Q.29.For components made by outside vendors, do you provide full designs and specifications 

to vendors, or do you purchase their designs? 

A.Q.30.Can you list your key raw material, casting, and machining suppliers? 

Manufacturing Costs versus Pump Features

A.Q.31.Are there certain costs that do not scale directly with pump size/capacity? 

A.Q.32.How do manufacturing costs relate to, or vary with, specific speed? 

Do mixed flow pump impellers cost more to manufacture than radial flow? 

 
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A.Q.33.How do costs vary for pumps across a series? 

A.Q.34.Are there specific “break points,” or discontinuities, where a pump costs more to 

manufacture? Possible examples: 

 At a certain size the pump becomes too large to handle without overhead cranes 

 At a certain size the pump is too big to fit into standard sized machine tools 

 
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Purchased Parts

A.Q.35.Please provide the range of typical motor costs for those packaged with pumps, before 

markups, in the table below. Please provide your answers in terms of particular pumps, 

and specify the model numbers, head, and flow range. Motor type could be 3-phase 

induction, brushless DC electric motor (ECM), etc. 

Table A.12 Pump motor costs 

Equipment 

Category 

Series Designation & 

Flow Range (gpm) Motor Type HP Motor Cost 

ESCC 

e.g., 

Unit: 100gpm, 50ft, 

model 123 

25 – 100 gpm 

 e.g., 0 – 7 HP $ - $$ 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 

A.Q.36.Do you sell any products with a variable (or adjustable) speed drive? 
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A.Q.37. Which equipment categories are typically paired with a variable (or adjustable) speed 

drive? Please circle. 

ESCC ESFM IL DS AS RS VT VT-S A-M

A.Q.38.Please provide a range of typical variable speed (or adjustable speed) drive costs for 

those packaged with pumps before markups in the table below. Please provide your 

answers in terms of a particular pump or pumps, and specify the model numbers, head, 

and flow range.

Table A.13Pump adjustable speed drive costs 

Equipment 

Category 

Series Designation & 

Flow Range (gpm) 

Adjustable Speed 

Drive Type Cost 

ESCC 

e.g., 

Unit: Model 123 

25 – 100 gpm 

 $ - $$ 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
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A.Q.39.Please provide the typical costs of seals used in your pumps. Please describe seal type 

and supplier(s). Please provide your answers in terms of a particular pump or pumps, and 

specify the model numbers, head, and flow range.

Table A.14 Pump seal costs 

Equipment 

Category Seal Type Supplier Cost 

ESCC $ - $$ 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
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A.5 Markups, and Labor Rates 

Markups 

DOE also assesses the impact of energy conservation standards on industry profitability. DOE 

would like to understand the current markup structure of the industry and how energy 

conservation standards would impact your company’s markup structure and profitability. Please 

consider the following definitions when preparing your response. 

The Manufacturer Production Cost (MPC) is the sum of all materials, labor, overhead, 

and depreciation directly associated with manufacturing a product. 

The Manufacturer Selling Price (MSP) is the price manufacturers charge their first 

customers. This does not include additional costs incurred along the distribution 

channels and as such does not reflect the manufacturer suggested retail price (MSRP). 

The Manufacturer Markup is the ratio of MSP to MPC. It covers non-production costs 

such as SG&A and R&D, as well as profit, but does not directly reflect the profit margin.

A.Q.40.How are markups and margins determined in this industry? How would standards 

potentially impact the pricing or margin structure? 

A.Q.41.Based on publicly available data, DOE estimates an industry average markup of 1.57 

across all equipment types. Please provide an average baseline markup (prior to any 

regulation) for each product category that is representative of your industry. 

Table A.15 Baseline Manufacturer Markups by Equipment Category

Equipment Category Average Baseline Markup 

ESCC

ESFM

IL

DS

AS

RS-H

RS-V 

VT

VT-S

A-M

CIRC 
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A.Q.42.One of the possible scenarios DOE uses to model impacts on industry profitability is the 

impact of commoditization of premium products. Because market disruptions caused by 

standards can alter the pricing of premium products, DOE is interested in understanding 

if efficiency is a feature that earns a premium. Within each product category, does 

markup vary by efficiency level? If yes, please provide information about the markup at 

higher efficiencies. 

A.Q.43.What other factors or product attributes, such as size or capacity, affect the markup of 

pumps within an equipment category? 

A.Q.44.Would you expect changes in your estimated profitability following the introduction of 

an energy conservation standard? If so, please explain why. 

 
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Labor Rates 

A.Q.45.DOE used information gathered from its analysis of common industry practices to 

formulate factory parameters for manufacturers. Please comment on the following factory 

parameter assumptions. 

Table A.16 Factory Parameters

Parameter Estimate Manufacturer Feedback 

Total Annual Production Volume 

(units/year) 

Work Days Per Year (days) 

Assembly Shifts Per Day (shifts) 

Fabrication Shifts Per Day (shifts) 

Fabrication Labor Wages ($/hr) 

Assembly Labor Wages ($/hr) 

Fringe Benefits Ratio 

Burdened Assembly Labor Wage 

($/hr) 

Supervisor Span 

(workers/supervisor) 

Supervisor Wage Premium (over 

fabrication and assembly wage) 

Indirect to Direct Labor Ratio 

Length of Shift (hrs) 

Average Worker Downtime per 

shift 

Average Equipment Installation 

Cost (% of purchase price) 

Average Scrap Recovery Value 

(using base material value) 

Building Life (in years) 
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B. MARKET QUESTIONNAIRE 

B.Q.1. Do you have information on the most common duty points for which customers select 

pumps, and how closely BEP of the pump model selected by the customer matches that 

duty point? 

If not, can you connect us with an affiliated distributor who may be able to answer this 

and similar questions? 

B.1 Shipment Estimates 

B.Q.2. Earlier you provided your 2012 shipments by equipment category. Please provide an 

estimated disaggregation of those shipments by horsepower range. Please also note if you 

serve particular category niches that would make your distributions significantly different 

from the rest of the industry. 

Table B.1 Yearly Shipments by Horsepower 

Equipment 

Category 

ANSI/HI 

Nomenclature 0-1 HP 1-3 HP 

3-10 

HP 

10-25 

HP 

25-50 

HP 

50-100 

HP 

100-200 

HP 

200-500 

HP 

>500 

HP 

ESCC OH7 

ESFM OH0, OH1 

IL 

OH3, OH4, 

OH5 

 

 

 

 

 

DS BB1 (1 stage) 

 

 

 

 

 

AS 

BB1 (2 stage), 

BB3 

 

 

 

 

 

RS 

BB2 (2 stage), 

BB4, VS8 

 

 

 

 

 

VT VS1 

VT-S VS0 

A-M OH00 

CIRC - 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 33 of 48 

B.Q.3. Can model availability be used as a proxy of sales, as in the EU? 

If not, what types of pumps tend to sell more high efficiency units? For example, is high 

efficiency more desirable in a larger pump than a smaller pump? 

B.Q.4. For each equipment category, please provide shipments by customer-provided duty point. 

(Or BEP if customer duty point is not available.) 

Equipment Category:________ 

Flow (gpm)

25 50 100 250 500 1,000 2,000 5,000 10,000 50,000 >50,000 

Head (Feet) 

25 

50 

100 

250 

459 

750 

1,000 

2,000 

>2,000 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 34 of 48 

B.2 Shipment Projections 

B.Q.5. How would you expect shipments to change for the industry as a whole, as a function of 

standards, and why? 

B.Q.6. In order to determine the price-elasticity of pump demand versus price, feedback is 

requested on your estimates for changes in demand as pump prices increase. We 

encourage the use of historical data to inform these estimates. Shipment trends during 

the recent run up, and retreat from, high commodity prices may serve as a relevant 

starting point. 

Looking at price/cost effects only, how would you expect shipments to change for a 5%, 

10%, 25%, or 50% manufacturer price/cost increase? Please provide your data as a 

percent decrease from the baselines provided in Table A.2. 

Table B.2 Change in shipments expected for manufacturer price/cost increases 

Change in Shipments for % MPC increase 

Equipment 

Category 5% 10% 25% 50% 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 35 of 48 

B.Q.7. Looking at price/cost effects only, how would you expect shipments to change for a 0.1, 

0.4, and 0.7 MEI? Please provide your data as a percent decrease from the baselines 

provided in Table A.2. 

Table B.3 Change in shipments expected at MEI levels 

Equipment 

Category MEI = 0.1 MEI = 0.4 MEI = 0.7 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 

 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 36 of 48 

B.Q.8. Which equipment categories are currently available to ship from your factory packaged 

with a motor? For these equipment categories, what percent are shipped with motor and 

without motors? 

Table B.4 Packaged (motor only) pump shipments 

Equipment 

Category 

Available to ship 

packaged w/ motor? % packaged w/ motor? % w/o motor? 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 

 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 37 of 48 

B.Q.9. Which equipment categories are currently available to ship from your factory packaged 

with a VSD or other adjustable speed drive? For these equipment categories, what 

percent are shipped with a VSD or other adjustable speed drive? 

Table B.5 Packaged (motor + VSD) pump shipments 

Equipment 

Category 

Available to ship 

packaged w/ VSD? 

% packaged w/ VSD? 

(by type of drive as 

appropriate) 

% w/o VSD? 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 

B.Q.10. If your company produces wet-running circulators what percentage of these products are 

always shipped with a motor? with a VSD? What percentage of wet-running circulators 

are sold with a high-efficiency motor and integrated controls, such as an ECM? 

B.Q.11. Please list all pump motor suppliers that you are aware of in the industry, indicating 

which ones you currently use. 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 38 of 48 

B.Q.12. Please list all VSD or other adjustable speed drive suppliers that you are aware of in the 

industry, indicating which ones you currently use. 

B.3 Product Mix and Profitability 

B.Q.13. How would your company’s product mix and market strategy change with changes in 

the efficiency standard?

B.4 Market Shares and Industry Consolidation 

B.Q.14. How would new standards affect your ability to compete? 

B.Q.15. Could new standards disproportionately advance or harm the competitive positions of 

some firms? 

B.5 Distribution Channels 

B.Q.16. Pump sales are often made to consumers by a distributor or sales representative. Please 

describe the relationship with your distributors. 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 39 of 48 

B.Q.17. What are your distribution channels and what percentage of your products go through 

each channel? 

B.Q.18. How common is it for distributors or sales representative and their engineering teams to 

assemble or design a pump + motor + VSD package independent of the manufacturer? 

B.Q.19. Are pump/motor or pump/motor/VSD packages assembled and sold by authorized 

distributors considered as packaged sales in your shipment estimates? 

B.Q.20. Does your company make recommendations to distributors on how to package pumps? 

B.Q.21. If a pump is sold as a package with a motor and VSD is the package setup and installed 

on site by the distributor or by a representative from the manufacturer? Who is 

responsible for implementing the correct control/feedback scheme? 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 40 of 48 

C. MANUFACTURER IMPACTS 

During the Preliminary Analysis phase of the rulemaking, DOE attempts to characterize pump 

manufacturer impacts on a high level. This includes any relevant issues manufacturers may face 

resulting from increased efficiency standards. During the next phase of the rulemaking, the 

Notice of Proposed Rulemaking (NOPR) phase, DOE will perform an in-depth analysis of the 

impacts on manufacturers. 

C.1 Conversion Costs 

Energy conservation standards may cause your company to incur capital and product conversion 

costs. These are the costs needed to redesign existing products and make changes or upgrades to 

production lines, in order to comply with the energy conservation standard. Depending on the 

magnitude, the conversion costs may have a substantial impact on the outputs used by DOE to 

evaluate the industry impacts and the economic viability of a particular standard level. 

In this analysis, DOE considers two types of conversion costs. 

 Capital conversion costs (CCCs) are one-time investments in plant, property, and 

 equipment (PPE) necessitated by an energy conservation standard. These may be 

 incremental changes to existing PPE or the replacement of existing PPE. Included are 

 expenditures on buildings, equipment, and tooling. 

 Product conversion costs (PCCs) include the related research, product development, 

 testing, marketing, and other non-capital costs necessary to bring products into 

 compliance with a new energy conservation standard. 

C.Q.1. Are hydraulic redesigns conducted at the individual model level, or at the series level? 

If some pumps in a series meet the new standard, but some don’t, would the whole series 

be redesigned? 

Would some re-designed volutes/housings be used with different impeller types for nonwater applications? 

 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 41 of 48 

C.Q.2. What product conversion costs would you expect to incur to manufacture products 

compliant with efficiency standards? Please describe what these activities would be and 

provide your best estimate on their respective magnitudes. Magnitudes represent 

aggregate cost to redesign all pumps effected in a given product category. 

Table C.1 Product conversion costs, needed to comply with a certain MEI 

Equipment 

Category MEI = 0.1 MEI = 0.4 MEI = 0.7 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 42 of 48 

C.Q.3. Capital conversion costs (CCCs) are one-time investments in plant, property, and 

equipment (PPE) necessitated by an energy conservation standard. These may be 

incremental changes to existing PPE or the replacement of existing PPE. Included are 

expenditures on buildings, equipment, and tooling. Please describe what these 

investments would be and provide your best estimate on their respective magnitudes. 

Magnitudes represent aggregate cost to redesign all pumps effected in a given product 

category. 

Table C.2 Capital conversion costs, needed to comply with a certain MEI 

Equipment 

Category MEI = 0.1 MEI = 0.4 MEI = 0.7 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 43 of 48 

C.Q.4. How would the imposition of new energy conservation standards affect capacity 

utilization or production levels at your domestic production facilities? Would throughput 

be affected? 

C.Q.5. Would a new standard result in stranded capital assets? Stranded assets include 

machinery that would become obsolete if an energy conservation standard were adopted. 

Please report the value of any un-depreciated assets that would be stranded at the 

following standard levels: 

Table C.3 Stranded capital assets resulting from an energy conservation standard 

Equipment 

Category MEI = 0.1 MEI = 0.4 MEI = 0.7 

ESCC 

ESFM 

IL 

DS 

AS 

RS-H 

RS-V 

VT 

VT-S 

A-M 

CIRC 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 44 of 48 

C.Q.6. At what MEI (0.1, 0.4, 0.7) do you expect to: 

 Close current manufacturing plants rather than upgrade them to make higher-efficiency 

products? (e.g. moving production to new facilities, out-sourcing, or ceasing operations 

altogether). 

 Require the development of a “clean sheet” product platform to meet higher efficiency 

levels? 

C.Q.7. For products produced abroad, do you own the factories in which you manufacture these 

products, or do you OEM from other product manufacturers? 

C.Q.8. How might a new standard impact product innovation? 

 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 45 of 48 

C.Q.9. Financial Parameters. Please compare your company’s commercial & industrial pump 

equipment financial parameters to the GRIM parameters tabulated below. 

DOE will conduct an industry-wide cash-flow analysis using the GRIM, identify and 

analyze subgroups of manufacturers whose businesses vary significantly from the 

industry as a whole, perform a competitive impacts assessment, and review the 

cumulative regulatory burden for the industry. 

C.2 General Manufacturer Impact 

C.Q.10.Key Issues: What are the key issues for your company regarding any new energy 

conservation standards for pumps? 

C.Q.11.Your Company’s Niches: What are your product lines, niches and relative strengths in 

the pumps market? 

GRIM Input Definition Industry Estimated

Value

Your Actual

Income Tax

Rate

Corporate effective income tax paid

(percentage of earnings before taxes, EBT)    

Discount Rate Weighted average cost of capital (inflation‐

adjusted weighted average of corporate cost

of debt and return on equity)

   

Working

Capital

Current assets less current liabilities

(percentage of revenues)    

SG&A Selling, general, and administrative expenses

(percentage of revenues)    

R&D Research and development expenses

(percentage of revenues)    

Depreciation Amortization of fixed assets (percentage of

revenues)    

Capital

Expenditures

Outlay of cash to acquire or improve capital

assets (percentage of revenues, not including

acquisition or sale of business units)

   

Cost of Goods

Sold

Includes material, labor, overhead, and

depreciation (percentage of revenues)    
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 46 of 48 

C.Q.12.Company Demographics: Where are your production facilities located, and what is the 

product mix manufactured at each location? Does the bulk of your company’s 

production occur domestically? What are your employment levels at these facilities? Are 

there any manufacturing or employment issues that DOE should be aware of in terms of 

producing more energy efficient pumps at your facility/facilities? 

Table C.4 Manufacturing Facilities 

Facility Location Equipment Categories 

Manufactured Employees Annual Shipments

Example Brunswick, ME ESCC, ESFM 125 8,500 

1 

2 

3 

4 

5 

C.Q.13. Direct Employment Impacts: Would your domestic employment levels be expected 

to change significantly under amended energy conservation standards? If so, please 

identify particular standard levels which may trigger changes in employment.

Other Impacts: Generally how would new efficiency standards on pumps impact your 

customer mix, distribution channels and corresponding profit margins? Please explain.

C.Q.14. In your industry, a small business is defined as a company with less than 500 

employees. Below is a list of small business identified by DOE. Please list any 

additional small businesses of which you are aware. 

Afton Pumps Gusher Pump All-Flo Pump Company, 

Inc. Vaughn Pump 

Ardox MWI Pumps Blacoh Fluid Controls, 

Inc. Discflow 

Carver Price Pump Gilbert Gilkes & Gordon 

Ltd Hayward Gordon 

Cascade Simflow Hayward Tyler, Inc. Carter Pump 

ChemPump Smith & Loveless Inc. PumpWorks 610 Vanton 

Essco Pumps Vertiflo Pump Reddy-Buffaloes Pump, 

Inc. 

FPI Wilfley Wanner Engineering, Inc 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 47 of 48 

C.Q.15. Small Businesses: To what extent will new standards require small businesses to 

acquire new equipment or cause manufacturing process changes that could destabilize 

their business? 

C.Q.16. Depreciation: What are the depreciation periods for the three types of capital 

expenditures (building, equipment, and tooling)? 

C.Q.17. Exports and Competition: Would new standards change your projected export sales? 

Would new standards have an impact on the portion of the domestic market served by 

foreign competition?

C.Q.18. Industry Consolidation: In the absence of new standards, do you expect any industry 

consolidation?

C.Q.19. IP Issues: Are there concerns over intellectual property, patent licensing, or other 

related issues? Is there any intellectual property that would disproportionally advantage 

one company over another with respect to energy conservation standards? 
Commercial and Industrial Pumps 

Preliminary Analysis Interview Guide 

Page 48 of 48 

C.Q.20. Impacts on Consumers: Could new standards result in disproportionate economic or 

performance penalties for particular consumer/user subgroups? Beyond price and 

energy efficiency, could new standards result in products that will be more or less 

desirable to consumers due to changes in product functionality, utility or other features? 

C.Q.21. Regulatory Burden: Will the current and proposed EU regulations on pumps or 

related products (Lot 11, 28, and 29) create regulatory burden on the industry in the 

US? Are there any other regulations that contribute to cumulative regulatory burden, 

thus making it more difficult for pump manufacturers to respond to energy conservation 

standards, if the US were to adopt them? What is the total expected impact of those 

other regulations? Are there regulations on anything else you manufacture?