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U.S. Department of Energy 

Commercial and Industrial Pumps Negotiated Rulemaking Working Group 

Meeting Summary—Fourth Meeting 

Forrestal Building, Washington, D.C. 

March 26-27, 2014 

Members in Attendance (Day 1) 

Lucas Adin U.S. Department of Energy 

Tom Eckman Northwest Power and Conservation Council (ASRAC Member) 

Robert Barbour TACO, Inc. 

Charles Cappelino ITT Industrial Process 

Greg Case Pump Design, Development and Diagnostics (Hydraulic Institute) 

Gary Fernstrom California IOUs 

Mark Handzel Xylem Corporation 

Albert Huber Patterson Pump Company 

Paul Lin Regal Beloit (alternate for Howard Richardson) 

Joanna Mauer Appliance Standards Awareness Project 

Doug Potts American Water 

Charles Powers Flowserve Corporation, Industrial Pumps 

Steve Rosenstock Edison Electric Institute 

Louis Starr Northwest Energy Efficiency Alliance 

Greg Towsley Grundfos USA 

Meg Waltner Natural Resources Defense Council 

Doug Brookman Facilitator, Public Solutions, Inc. 

Additional Attendees 

Robert Boteler, Daniel Cohen, Charles Foster, Jeremiah Freeman, Jack Graul, Elizabeth Kohl, 

Laura Petrillo-Groh, Callie Reis, Arnie Sdano, James Sivigny (Day 2), Brent McManis, Steve 

Thompson, Daniel Weintraub, Sarah Widder and Alison Williams 

Day 1—Working Group Meeting #4, March 26, 2014 

Facilitator Doug Brookman called the Working Group (WG) meeting to order and welcomed all 

present at 9:05AM. The facilitator noted the wintry weather. Surprisingly all members were 

present for the start of the meeting. 

The WG proceeded with introductions around the room. The facilitator referred to the handout 

packet and the listed agenda elements compiled by DOE and the consultant team. He also 

referenced a power point presentation prepared by DOE—a general overview of the Appliance 

Standards rulemaking process, suggesting that presentation be the first agenda item. Following 

that presentation, pursue the following agenda items: 

 Clearly define scope for the negotiation: pump types being considered 
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 Clearly define scope for the negotiation: scope 

 Metrics—details on a possible metric, calculation methods, default values, testing 

 Test Procedure: the Hydraulics Institute to present/discuss 40.6 

Lucas Adin started presenting on the rulemaking process. He noted that the same detailed 

analysis will occur, but for the working group, it would be in a more compressed time frame. 

Continuing he described: 

 The typical standards setting process takes about three years 

 It involves several rounds (phases) of analysis and many data inputs and outputs 

 These result in candidate standard levels for the products under consideration, and 

 Iterations of standards-based savings (10%, 20%, 30%, etc.) and look at life-cycle costs 

and payback periods for each 

 The analysis proceeds with manufacturer impacts and a broader national impact analysis 

 DOE considers different standard levels assuming different levels of shipments and 

typical usage patterns to assess the national energy savings at that standard level 

He continued, “So we start out with a market and technology assessment. What does the market 

look like? What kind of technologies are actually in use? Then utilize screening analysis to 

determine what kinds of technological improvements can be made to the product—which ones 

are feasible? Which technologies are readily available.....all of that goes into an engineering 

analysis where we look at realistically what would it cost to implement those things. What kind 

of efficiency will we get? There is a cost for efficiency improvement.” (p.13) 

Alison Williams, referring to power point slides, continued: “we figure out what equipment 

classes we are looking at; what is the baseline from which we are going to consider these 

additional design actions to improve efficiency; and then in screening analysis of that, there is 

four criteria for determining whether or not a design option is something that could be 

considered. And the practicability to manufacture and things like that and so then what is left 

goes in the engineering analysis and the basic cost efficiency curve of what it costs to get to each 

different efficiency level.” (p.15) 

Alison continued: “the next step is once you have the engineering analysis which involves the 

different efficiency levels and the cost of them, we also look at mark-ups to determine equipment 

price. So we have mark-ups based on distribution channels and mark-up segments that are 

specific to the pump industry. And we apply them separately to the baseline cost as well as the 

incremental cost of this improved efficiency. And so that analysis gives us the equipment price 

that we use when we are looking at effects on the market.....So the next analysis is the energy 

use which primarily gets -- or sort of it is built into the life cycle cost analysis. We are basically 

looking at the amount of energy the pumps use under these different scenarios....basically how 

we are going to do it this time is that we will be looking at the energy use in different sectors: 

industrial, commercial, and agricultural. We find different sources of information to find out 

operating hours, you know how large the pumps are in the application, how they are used, that 

kind of thing to figure out the energy use analysis under these different scenarios. And that gets 

rolled into the life cycle costs and payback period. So it combines the engineering analysis 

which is how much it costs to get to higher efficiency and the energy analysis combined with 

electricity price to find your total operating costs. You combine those two things and it gives 
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you the life cycle cost results on a simple level. So we look at -- all these things go into it but in 

the end we are really looking at...what percentage of the population benefits from a standard, 

what percentage is burdened, what percentage is not impacted and on average...the cost or 

savings to those people. So even if we are looking at a certain equipment cost and different 

efficiency levels, if there is a case where you know too many people are burdened or there is 

negative LCC savings then typically DOE might...cross them off the list....these analyses 

determine where DOE can go with these.” (p.16) 

One member commented that the utility (or efficiency) of the negotiated rulemaking process is 

that these analyses, and the time periods for comment and response, is compressed. Alison 

responded that the analysis team had been working on the analysis since the framework 

meeting—building models and collecting inputs. 

Alison continued: “we have to finalize the market and technologies first. And then once we do 

that we will proceed to present these individual analyses in order along in the next couple of 

meetings. So the shipment analysis basically we try to do a shipment projection over a 30 year 

analysis period....we look at economic indicators. We look at the current stock, lifetimes. We 

usually do a distribution of lifetime so we can analyze how many replacements are needed to go 

into the current stock and that basically generates, between replacement and construction, that 

generates that shipment projection over the 30 year analysis period. And so the shipment 

projection is combined with some of the other things that we’ve done so far to populate the 

national energy saving and net present value....the national energy savings is basically how 

much energy would all those shipments use in the base case and then how much energy would 

they use in each of the different standards cases we are looking at. We just look at the difference 

between those two to see how much energy can be saved nationally by implementing the 

standards.” 

Continuing, “And then we look at the net present value of implementing those standards which is 

basically the increased installed cost of higher efficiency units versus operating costs of the 

higher efficiency units multiplied by all the shipments in the projection. And so basically if the 

net present value is negative that is another indication that that standard level would not be 

considered eventually....preliminary manufacturing impact analysis: so in this stage we are 

combining preliminary analysis and NOPR. We will basically be doing full manufacturing 

impact analysis, which basically looks at industry cash flow and net present value using the 

government regulatory impacts model. And essentially it is just looking at conversion costs and 

all sorts of things that tell you what the industry net present value is. And we look at the change 

in the industry net present value using a different standard that were are considering. You know 

this is just an example of what the impacts are at each level....those are the main analyses. We 

do a bunch of other analyses that I don't think we need to go into in detail here. We look at 

utility impacts, the emissions, savings, monetize the emissions, you get you know the social cost 

of carbon and all those things are required to be done as part of this analysis.” 

In a supplemental comment, the facilitator stated, and Lucas Adin confirmed, that DOE has an 

obligation to “fulfill its responsibilities by statute and other factors to conduct complete analysis 

and do what they would do in a standard rule making process.” Lucas restated that the larger 

goal for the negotiation was for the WG to create a term sheet which DOE will translate into a 
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proposed rule, to be published for comment, review, and ultimately, become a final rule. 

Clearly Define Scope for the Negotiation (p.30) 

The facilitator acknowledged and thanked the Hydraulic Institute (HI), industry members, and 

particularly Al Huber and Mark Handzel, for organizing an industry-wide data gathering effort. 

Al Huber presented the compiled results of the HI membership survey, with 17 companies’ 

yearly pump data, as follows (* indicates ‘load factoring’): 

 Double-suction—5,311 units 

 Vertical Turbine—5,815 units 

 Multi-stage Axially Split—277* units 

 Multi-stage Radial Split—2,874 units 

 Radially Split Vert.—49,975* units 

 Vert. Turbine Submersible—104,406* units (includes non-submersibles) 

 End Suction Close Coupled—171,456* units 

 End Suction Frame Mounted—44,042* units 

 In-line—50,424* units 

A member commented that the survey was limited or constrained to HI’s original scope: 1-200 

horsepower, clean water, temperatures, etc. Al confirmed that the data reflected domestic 

manufacturing including imports and stated that 80-85% of the market is represented by the 17 

companies that participated in the survey. What followed was detailed discussion clarifying 

what specific pump types would be included in different pump categories. In a concluding 

statement, a member noted that the pumps categories listed in green (on the colorful greenyellow-red chart on p.3 of the slides) represent 97% of all the units shipped (p.50). 

Alison Williams reported on new analysis on the energy estimates and described gaps in data, 

specifically: missing data from vertical turbine and radial split horizontal manufacturers 

primarily (p.1 of a new handout on Scope Discussion). After discussion, the group decided to 

review the data even though the data was incomplete. There was insufficient data for radial-split 

horizontal to report and the axial-split numbers represented only a few manufacturers. For 

vertical-turbine submersibles, the data reflected large portions of the market being absent. The 

chart reflected updated annual energy use numbers, new shipments and new shipment-weighted 

horsepower. 

Members commented on the data (p.63): 

 The hours of operation for the in-lines were way higher than the end suctions and one is a 

substitute for the other in the marketplace so they should be similar 

 About 75% to 80% of the pumps sold in most categories are sold as twos where you have 

in an operation, a primary and a backup for the lead and the lag—both of them come into 

play in the unit sold, but both of them will not be operating; one will not operate while 

the other is operating. 

 We are not sure whether the estimated hours are system hours or per pump hours, which 

may reflect how the estimates diverge from total system operating hours. 

 Every one of these applications will be different by specific use and locale 

 In general, your end suctions, in-lines and double-suction split case generally are 
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substitutes for each other in most of the market. So those operating hours should be 

pretty much the same—2000 hours. 

Annual Energy Use Estimates (p.91) 

Alison Williams described how the analysis looks at four different estimates of saving energy; 

two based on MEI and two based on PER. One scenario shown was based on MEI 40. “So what 

we did was take all the pumps that would fail at MEI 40 and roll them up to the minimum 

standard. We looked at the efficiency increases by looking at those two scenarios and 

translated that into energy savings. And just took the min and max of each of those four 

scenarios for each of these (listed).” ((And you can see they are pretty low ranging from across 

all product types from 0.1% to 6.5% energy savings from going to an MEI 40. And so the 

resulting -- I have the resulting energy savings in terawatt hours in the power point and here it 

also translated it into quads in case -- over 30 years in case anyone is interested in looking at 

that.)) 

Questions and comments from members: 

 Clarified that the savings are just savings based on pump efficiency improvement. 

 Asked how the MEI 40 corresponds to DOE’s general practice of establishing trial 

standard levels? Alison answered that MEI 40 is cutting off 40% of the market—other 

levels, both lower and higher to max tech would be considered. 

 Clarified that the percentages listed were on a market average basis 

 Stated that efficiency degradation in pumps could be on average about 1% per year 

 Questioned how to account for trimmed impellers—not being considered for now—if 

necessary, maybe consider using a uniform ‘trim’ percentage 

 Lucas Adin stated that “for the purposes of regulatory coverage we did agree already that 

full impeller is the basis for the standard.” 

Several members questioned the quality and the meaning of the data, as a precursor to taking a 

vote on the pumps to be included in the scope, including (p.120): 

 Lucas clarified that these data are only for the purposes of determining scope 

 Another member clarified that the absolute numbers don’t matter, it is the relative 

numbers that matter 

After more discussion, Alison Williams read the revised numbers (that had emerged in the 

morning’s discussion) cell by cell. Next Dan Weintraub reported on circulators (original 

handout: Incremental Costs for Circulators, p.11). Dan reported that increases in circulator 

manufacturer selling price could occur for two reasons: increased motor cost and increased 

manufacturer markups to cover manufacturer redesign and conversion costs. Responding to 

questions both Dan and industry members confirmed that the great majority of circulators motors 

are permanent-split capacitor wet rotor. Continuing, Dan estimated that “about 90% of the total 

shipments under three horsepower were under one-quarter horsepower, so 90 % of those 

shipments. And the vast majority of those under one-quarter horsepower pumps are these small 

integrated permanent-split capacitor pumps.” 

Dan continued with a detailed description of a cost extrapolation for baseline motors (p.12, 

p.134). His preliminary estimate was that the incremental cost for an ECM motor was $29.50. 
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Members questioned the estimate. 

Moving to manufacturer redesign and conversion costs (new packet, p.2, p.139), Dan described 

the following estimates for less than one-quarter horsepower circulators: 

 Aggregate industry conversion cost $39,000,000 

 Annual shipments 1,500,000 

 Estimated payback period (years) 4 

 Shipments over payback period 6,000,000 

 Incremental cost per shipment $6.50 

 Incremental cost to customer $61.73 (MFG Markup + Distribution markup) 

 Total incremental cost to customer (p.3) $71.81 

A member stated that a four year payback would be considered too long for his company. 

Another member commented that market forces would lower prices and at volume production 

those same market forces would cause manufacturer’s markups to be less. 

Alison Williams pulled up a new slide (Updated Circulator Energy Use...., p.4, new packet). 

After some examination and discussion the WG concluded that the data shown had not been 

properly updated. After detailing some corrections, Alison described four scenarios, two 

operating hours/year assumptions and two motor cost assumptions which resulted in payback 

periods ranging from 9.6 years down to 4.2 years. Members commented. One stated that a 10-

year payback was untenable for manufacturers—it would result in product being manufactured 

off shore. Another questioned the savings estimates for ECM motors based on constant full load 

(p.158). Another member commented that these were only preliminary estimates, but of more 

interest, was the aggregate potential energy savings. 

Continuing, another member interpreted that the data “would provide justification for second 

rulemaking on circulators separately because the amount of energy savings available of Lot 11 is 

similar in quantity available in circulators....by themselves.” Another member commented that 

this math “probably looks about right.” Alison interjected that the estimated savings were 

predicated on using ECMs for circulators. Following, a member described “It is a 1% to 2% or 

3% (savings) on the pump. And a 50% on the motor. You don't have to have near as many.” 

Other members commented on the pros and cons of a second rulemaking, the time frames 

involved and potentially including controls. A member inquired about the level of effort and 

timing of including circulators in this rulemaking (p.168). Alison responded “the two biggest 

differences we see are going to be the engineering analysis and the LCC because engineering 

will be covering motors instead of hydraulic efficiency. It is a completely different analysis 

essentially; different design options and all that. So while we've already conducted the 

manufacturer interviews and have all sorts of detailed analysis are basically ready to go 

essentially...for Lot 11 pumps.” Members asked additional questions about the feasibility of 

including circulators in this rulemaking. Alison and Dan Weintraub responded, essentially, that 

it would be a complicated, time consuming, wholly-different analysis and the analysis team had 

“only touched the surface” on circulators (p.174). 

With the lunch break approaching, the facilitator made general inquiries about how to conduct 
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the anticipated vote on scope when the WG returned from lunch. Members suggested that a 

caucus was needed. The WG recessed for lunch. 

Returning from lunch, Tom Eckman, speaking on behalf of the EE caucus, offered the following 

proposal: 

 Circulator pumps (and pool pumps) can be held to a second event—however, include in 

the term sheet a schedule which indicates our intention that circulators be addressed “as 

quickly as practicable”, that the term sheet specifies a target date for the second 

negotiation—to commence by the end of December of 2014—“that would be the goal” 

Al Huber, speaking on behalf of the manufacturer’s caucus offered the following proposal: 

 Support for the proposal of the EE caucus 

 Adopt the Lot 11 pump types (as listed) 

 Not adopt the Lot 11 Plus pump types—the energy savings are not great and the costs of 

redesign would be extremely high and extremely time consuming 

Members clarified that the pool pumps could be described as dedicated or integrated pool pumps. 

Tom Eckman, speaking again on behalf of the EE caucus, confirmed that the EE caucus 

supported the manufacturer’s caucus proposal. 

A member requested that the terms and descriptors used in the official record be made as clear as 

possible. Alison made corrections to the power point slide (Scope of Negotiation, p.3) to specify 

the items in green as Lot 11 and a special Phase 2 designation for circulators and pool pumps. 

Specific questions emerged about some of the Lot 11 Plus pumps (p.194). Detailed discussion 

ensued. 

As the facilitator called for a vote on the pending proposals, Lucas Adin clarified that his vote 

would not be an indication or commitment that he could effectuate the December 31, 2014 date 

to commence the second negotiation. Continuing, he commented on an earlier question about 

compliance periods, “our view anyway is that from a legal prospective there is -- EPCA is pretty 

clear that it is a five year compliance period from publication of final rule. So if we do this 

follow-on rule, and we publish a rule with standards, they would have five years to comply from 

the date of that rule.” In answering a member’s question, Betsy Kohl confirmed what Lucas had 

said. 

As the facilitator called for a vote, Steve Rosenstock asked to make an amendment to the 

proposal: “move a Lot 11 Plus VT into the covered products because of economies of scale, the 

possible same application and their competitive qualities”. After discussion and clarification, the 

amendment was put to a vote. Eight members voted against the amendment, so the amendment 

was defeated. 

Once again the facilitator asked for a vote on the original two-caucus (joint) proposal that was 

still pending. Asking for a show of hands, fifteen members voted to accept the proposal and one 

member abstained. The WG obtained a consensus on the scope for the negotiation (p.227). 
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The facilitator raised the issue of sanitary pumps, which was one more pump type left on the 

exclusions list. Greg Towsley supplied a definition and Alison read it into the record (p.229). 

After discussion, a member clarified that these pumps meet a USDA guideline (3-A) for sanitary 

design and fabrication of dairy processing equipment. The facilitator asked for a vote to exclude 

sanitary pumps from the scope of coverage. In a show of hands, all sixteen members voted 

unanimously to exclude sanitary pumps. 

Next, Lucas Adin began to present information on the definition of clean water (referring to p.5 

in the packet, p.238). The slide said “Clean water pump means a pump that is designed for use 

in pumping clean water, except the following pump types:” and then listed seven excluded pump 

types. A more detailed definition was supplied on page 6. Lucas stated that he was not 

proposing a specific definition for the WG to vote on because crafting the regulatory language 

adequately may require resources outside the WG. DOE was trying to “evaluate conceptually 

what does it mean to be a clean water pump?” 

In discussion, members contributed: 

 That the WG-developed parameters for horsepower, temperature, etc. would be included. 

 Another clarified that other specifications would be fully spelled out. 

 Others questioned whether the definition would be adequately inclusive of additives, 

including salt water 

Next, Arnold Sdano presented on HI’s 40.6 test standard (p.258). In the draft, the committee has 

defined the speed of rotation, the temperature limits, the loss definitions, the calculation 

methods, the reporting and the calibration of the instrumentation. The 40.6 committee also 

defined ‘clear’ water: a temperature range of 10 degrees to 30 degrees C.; a maximum viscosity 

of 1.5 times to the minus six meters squared per second; and, a maximum density of 1050 

kilograms per cubic meter. He noted this was very similar to the definition of clean water being 

considered by the WG. He described a detailed consideration of pump types, calibration 

descriptions and seven test points: 60, 75, 90, 110 and 120 percent at BEP. Arnold confirmed 

that the test procedure needed to be approved by HI members before it would be eligible to be 

incorporated by reference by DOE. The draft is now out for balloting at HI. The final draft is 

due to DOE by May 15. 

Next Steve Rosenstock presented some information on non-electric drivers based on data he 

obtained from the agricultural sector. Based on the established scope, most of the non-electric 

driver pumps had been excluded. A member commented that diesel pumps had been in use for 

many years and they last a very long time, but that there are very few new diesel installations. 

They are being replaced by small electric motors, although the surge in natural gas has these 

drivers being considered in some places. As a final comment, Lucas Adin said using electric 

motors as the basis in the metric greatly simplifies things. 

The discussion continued with a detailed exploration of non-electric pump applications that 

might try to evade the standard. Sarah Widder added it would be useful to clarify—with a 

vote—that the metric will apply to electric drivers. Alison offered the following language: “In 

this rulemaking ...the metric will not cover non-electric drivers. The test procedure will specify 
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that the bare pump calculations also apply to pumps with non-electric drivers.” The facilitator 

read Alison’s language aloud and called for a vote on proposal. By a show of hands, the 

members voted unanimously to accept the reviewed language to limit the metric to electric 

drivers. 

Metrics (p.294) 

Sarah Widder began to present from a lengthy slide deck, beginning with an overview on 

material that was covered previously. 

A member asked, noting that several possible pumps configurations are potentially being sold 

(bare pump, pump + motor, pump + motor + controls), who is responsible for actually certifying 

the product. There was considerable discussion on who would be responsible. Some members 

recalled that the manufacturer was responsible for the product as sold. Others recalled Betsy 

Kohl’s description of a broader definition which included distributors as the responsible party if 

they were doing assembly. Another member restated his understanding, “really what happens 

is you get your pump efficiency and everything after that is calculated and we slap the label on. 

So if you get your MEI and somehow it gets massaged, you stick it in and you calculate it by 

number.” Sarah clarified that the metric was designed precisely so that any pump configuration 

as distributed and sold could be certified. 

Sarah continued, starting with the issue of weightings (p.308). A member stated that he thought 

the PER nomenclature might be misleading and that a more conventionally descriptive term like 

system or package might be needed. Sarah then described how the PER might be calculated. 

Referring to the projected equation and showing an example, she made the following major 

points: 

 “The load control factor would be fixed. It is essentially a default number that would be 

applied across the board to account for the savings from controls in the absence of a more 

rigorous or widely available test procedure.” 

 “The P on the numerator in this case is the pump shaft brake horsepower that comes out 

at 40.6 at those load points which are also up for discussion. 

 “MEI and EEI are used in the EU and the MEI describes the pump only. So that doesn't 

really meet our purposes.” 

 “The EEI describes the impact of controls on a specific pump only. So that doesn't really 

meet our purposes.” 

 “Some of these other ones gallons per minute (GPM) versus some sort of energy 

denominator doesn't account for head component of what a pump is delivering.” 

After many questions and diversions, Sarah continued with the example of a bare shaft pump and 

how it fits with the PER, “for every pump, every pump regardless of how you sell it, you will 

determine the BEP flow rate. That will be the first step. You test it and according to 40.6, 7 

points, sweep -- to maximum flow rate or the point specified in 40.6. You record head, 

rotational speed, torque, and, in the following table, convert into a power, torque times speed, 

output power is flow rate times head times specific weight of fluid and which the water is one, 

generally, and then efficiency is the output power of the input power.” 

Responding to a question, “all pumps are certified at full impeller diameter only—sold in 
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whatever configuration they are sold in” 

“So this is just for the bare pump case. We would be assigning for every size; the standard motor 

assumption is the same. But it has no bearing on the actual motor, physical motor that is paired 

with that bare pump. And then the poles would be assigned based on speed at which the pump is 

being rated. (p.339) The detailed example continued. 

One member commented, “We've got load factors that we decided we are going to use 25 across 

the board, which we all know is not correct, but it doesn't really matter....as long as everybody 

uses the same one.” Sarah continued that the equal loading was beneficial for manufacturers. 

Sarah continued, summarizing the approach for applying a metric to bare pumps sold with 

motors; “for the bare pump plus motor case there are theoretically two options...You can do A 

which is essentially what we just talked about except for this is manufacturer motor data not 

DOE minimum standard data or you can do a wire to water test for the calculations -- we are just 

talking about calculations. We are just talking about A right now. We will talk about B later.” 

 

“In this case it is exactly the same construct except for it is the measured motor efficiency now at 

each of these load points and in this case we assumed the 95% efficient motor. And this is the 

full load rated or the full load losses of that motor. We have the same data over here. The 

fractional load loss has gone down in this case. And then we have fractional input power that 

has gone down from before and we have a PER of 45.08 if we don't have a denominator 

compared to before we had 45.76. So our PER has gone down which is better as we've 

calculated it here. If we throw a denominator on this all goes down - but essentially in general 

the PER is better and that has accounted for a more efficient motor.” 

Day 1 recessed at 4:40PM 

Day 2—Working Group Meeting #4, March 27, 2014 

Facilitator Doug Brookman called the Working Group (WG) meeting to order and welcomed all 

present at 8:09AM. All the members were present for the start Day 2. 

Sarah Widder began the day by presenting on metrics, previewing the following areas for 

coverage: 

 examples of a calculation-based test procedure 

 a testing-based option for pumps and motors 

 pumps and motors with controls 

 talk in detail about the specific load points 

 weighting options 

 and, finally, denominators 

 

Author’s note: Sarah presented the following proposal uninterrupted for over 30 pages in 

the transcript, referring to detailed graphics and equations. The following is an attempt to 

lift and summarize, mostly at a conceptual level, the most descriptive content. 
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Reiterating from Day 1, she stated that what we are trying to accomplish with this metric is 

equivalently applicable to a bare pump, a bare pump sold with a driver, or a bare pump sold with 

a driver and controls. The bare pump option would also be applicable to pumps sold with other 

than electric drives. Sarah continued, “the covered product is the pump, and the metric is 

intended to be applicable to every piece of equipment that makes up the pump and representative 

of the energy use of each of those components. So to accomplish that, we developed this Pump 

Energy Rating (PER) example metric....in general, it's an average or a weighting of some sort 

of three load points representative of different locations on the pump curve, and in this case, we 

have talked about 100 percent of BEP flow, 110 percent of BEP flow, 75 percent of BEP flow, 

and 50 percent of BEP flow, representative of the light green dots on that curve. And then for 

pump, driver and controls, we would have the same load points in terms of BEP flow, but we 

would follow a system curve that allows speed reduction for the controls that are able to 

accomplish that.” 

Sarah walked the WG through an example, referring to an equation, “We talked about how the 

test procedure for establishing BEP, and just in general pump characteristics being consistent 

with 40.6, essentially running the load curve capturing 7 points on the load curve for a pump, 

whether they be specific load points in 40.6 -- it was I think 40, 60, 75, 80, 90, 100 -- or 90, 100, 

110, 120, something like that -- and then through the equation of best fit, finding the BEP flow. 

Some things we want to capture in the test procedure would be the repeatability of that and 

ensuring that then when you found BEP flow, you would actually capture your 100 percent point 

near to what you thought would be BEP flow [based on the rated performance of the pump].” 

Bare Pump 

Sarah continued, “for the bare pump option...the pump performance data would come from 40.6 

at the specific load points....and then multiplying by standardized motor performance and 

potentially standardized control performance. This would be purely an algorithm since the two 

components on the left don't exist for this bare pump case. (In this example) we took the pump 

data at those four load points and plugged them into the equation.” 

To account for motor performance, we would include the part load losses of the motor at each 

load point. “We talked about the method to account for motor losses,” continued Sarah.” “ So 

we can look up a default full-load motor efficiency in the tables at CFR 431.25, which is the 

section for motors. In this case, we have a specific way of determining the size that's to be 

paired with this pump, looking at the horsepower, the shaft horsepower, at 120 percent of BEP 

flow. We found that to be 53.65, round up to 60. We have a rated efficiency of 93.6 percent, 

and that's actually not applied directly to your equation; instead, we take that rated efficiency, 

which also from the test procedure has a rated full-load loss associated with it that's essentially 

the component of -- the losses are what make the efficiency go down, so greater full-load losses 

will result in less efficiency.” “And we'll calculate the loading of the motor as opposed to the 

loading of the pump at each of the points that we've specified previously. So in most cases, this 

will mean that the motor loading is slightly less than the pump loading because the pump is a 

little bit oversized -- well, not oversized, but a little bit larger horsepower than the pump.” 

“Using this algorithm that we developed based on MotorMaster data for how losses change with 

loading of the motor, we can calculate the horsepower losses at each load point for the pump. 
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Note that the motor losses equation is representative of the worst performing, or most 

conservative, motor in the database, so that any tested pump and motor combination would 

always receive a better rating than this default calculation. And this table just represents that 

data. So there are four flow points on the left-hand side: 110, 100, 75, and 50, and these are the 

bare pump shaft power. Then we calculated the load fraction on the motor for each of those 

cases: the part-load loss factor, which is plugging in that xi term into the yi quadratic equation 

that was on the previous slide; and then the fractional-load loss is a horsepower [term],where we 

multiplied the yi times the full-load losses (p.12).” 

Bare Pump and Motor 

“For bare pump and motor case, it looks very, very similar. This is the same table that we saw 

before, ....[but instead of a default motor] we are calculating the fractional-load loss that's 

associated with a 95 percent efficient motor, which is what we're pairing with the pump in this 

example. So instead of the default motor efficiency, it's a 95 percent motor, it has full-load 

losses of 3.16 horsepower ...the PER calculation method is exactly the same as it was for the 

bare pump case. The P values will be exactly the same as it was for the bare pump case. The 

only thing that's changing for a pump and motor is the motor efficiency, that's the only thing 

that's different, and in specific, the full-load losses. So we don't actually input motor efficiency 

into the equation. The way it's calculated is the full-load losses times the fractional-load loss 

factor.” 

“So in this case, the only thing that's different, these data are exactly the same as it was for the 

bare pump case, but now this fractional-load loss term has decreased slightly and we resulted in a 

slightly decreased input power to the motor at each of the load points, and so we've gotten a 

slightly decreased PER value as compared to the bare pump case, but the only thing that changed 

was the motor, and in specific, this full-load loss -- calculated full-load losses, or rated full-load 

losses, that comes from the motor test procedure.” 

Bare Pump, Motor and Controls 

“There are several options that we could consider for rating a bare pump that's sold combined 

with motor and controls....This is the same equation that we saw for the bare pump and motor, 

and the same data would be applied except for in this case we are not using four rated pump 

input horsepower or pump shaft input power. Before, we had measured data at each of these load 

points and in this case, we're just going to take the measured BEP shaft horsepower. And then 

because we're accounting for speed reduction and the power reduction that's associated with 

moving down the system curve, we're going to assume a system curve and calculate these 

....shaft power at these lower values.” 

“[To apply this in the test procedure, we're going to talk through how we might calculate the load 

control factor that would be applied equally to all pumps that were sold with a specific type of 

control....in this case...we're going to talk about a VFD. The load control factor in general will 

be the PER of the controlled pump case moving down that system curve, which will be lower, as 

the numerator, divided by the uncontrolled PER, which for this pump would be the 45.08 

horsepower number that we got with the bare pump plus the 95 percent efficient motor, assuming 

that it's sold with the same motor and controls, so just adding on controls in this case.... we 

developed load control factors for each specific type of control. (Here I've developed examples 
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for variable speed drive and for a 2-speed motor or a multi-speed motor, but we could make a list 

of other control options that should be considered and how those system curves might look 

different, but I would definitely welcome input from the committee on that point.)” 

Continuing, “ we have made some assumptions about the efficiency of the control as 96 percent 

efficient, and then also we have assumed this conservative system curve, and this is to 

accomplish the same thing as the motor losses equation accomplishes for us. This makes sure 

that this load control factor always gives us a worst case for a pump sold with motors and 

controls, and if you were to test it and actually measure the power input to the system at those 

reduced loadings, you would get a better rating than you would using the calculation approach. 

(So this is our load curve. One point is that now we're considering 110 percent, we're not 

allowing for overspeeding, so you're just following the pump curve at that point. That was the 

assumption we made here.)” “And then this is the equation of the relationship between flow and 

speed, head and speed, and power and speed are what we're relying on. Typically, that's a square 

relationship between head and speed. N is speed in this case, H is head, Q is flow, P is power. 

And usually a cubic relationship between power, and so that's where the conservative nature of 

this system curve comes in. We used 1.8 and 2.8 instead. There's a small basis, a weak basis I'll 

call it, for that. ASHRAE in the Fundamentals Handbook talks about system curves in the field 

being typically more in the 1.8 to 1.9 range for the relationship between head and flow, and so 

that's the assumption we have used here. 

 

“....we're going to take only two inputs from our tested pump data, the flow at BEP and the shaft 

horsepower at BEP.... Using the pump affinity laws, we then plug those two values in and 

calculate the power at the reduced load points.... Assuming the motor is a 95 percent efficient 

motor, the same we had before in the uncontrolled case, and the drive is 96 percent efficient, the 

controlled PER is then – (the equally weighted shaft input power at the load points that we 

calculated these -- basically these values in the right-hand column, plugged in, and accounting 

for motor losses, so that's why they're a little bit different than the values in the table, so we took 

these values, we ....took these values in the right-hand column, we applied motor efficiency and 

motor losses to them just like it was a motor sold -- or a pump sold with a motor.) We got these 

values that we plugged in the top as input power to the motor, and then we divided that by the 

drive, or assumed drive, efficiency. And so that would give us essentially a PER that is 

accounting for the efficiency of the motor, the efficiency of the drive, and the reduced power 

input to the system as we move down the system curve, and that's what we wanted to accomplish 

here.” 

“So in the future, when manufacturers are selling a bare pump with motor and controls, you 

would certify your pump as you tested their pump, apply the full-load losses and the motor loss 

equation, calculate the PER of the bare pump and motor that it's packaged with, and then 

depending on the type of controls, look up the load control factor that would be static for any 

type of control that you might apply, and if it's a VFD in this case, it's .78, and that would 

essentially just reduce your PER by .78, and you would get, in this case, 33.15 (p.25).” 

Summarizing the benefits of this method and comparing to full wire-to-water test method for 

pumps sold with motors or pumps sold with motors and controls, “One thing to consider with the 

two options, the calculation-based default and then testing methods that will result in better 

ratings, is we can allow that manufacturers or parties certifying equipment have the option to 
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test, or we can require the calculation method for all pumps. These are basically all options on 

the table, and they can be applied to all pumps, no pumps, some pumps, differently. The pros 

and cons, obviously, the calculation method is less burdensome and very repeatable because we 

all have the same calculation. The physical test method is more accurate, allows for better 

differentiation of equipment, but it's more burdensome (p.40).” 

Denominators (p.43) 

Sarah Widder, “we talked about the impact of the different denominators...in general, if you 

don't have a denominator, you get very strong function of speed and flow, and you also have 

larger numbers, which makes it easier to differentiate changes in efficiency. So when I put the 

efficient motor on, my PER was reduced by 2 points in the example case. If you normalize it, 

the numbers will be not as large, they will be somewhere between zero and 1, maybe a little bit 

higher than 1, depending on what the denominator is. So if you apply a 95 percent efficient 

motor, it will change in the hundredths place as opposed to in the single digits place, just based 

on the magnitude of the values. But it might be more intuitive to have something that scales 

between zero and 1, so there are pros and cons on both sides.” 

 

“These are some options that we considered previously....The referenced shaft power for a 

minimally compliant pump would result in values between zero and 1 and would help indicate 

the performance of that pump to some minimum standard level. We could also look at tying it to 

a market average, so comparing that pump to some place in the market that is representative of 

the typical pump. That means that your values won't quite be between zero and 1. You might 

have a pump that is sold in the market that is slightly worse than the market average, and so you 

would result in values higher than 1. And then we could also just do the pump's tested hydraulic 

power. That is the....simplest method, but it also does result in values higher than 1....the tested 

hydraulic power is a direct output of the test, of 40.6. So we have those values, we don't have to 

do any other calculations or manipulation to them; they're part of the test. 

 

“We also discussed...that we could apply these at BEP only or we could apply them at each load 

point. So we could calculate a ratio at each load point as a normalization or just have a static 

normalization. In this case, that's a lot of options to analyze. I just presented if we do a static 

normalization based on BEP, so that would be the equation that we've been showing. I should 

have had an equation here, but the equation we've been showing with the pump input power over 

one denominator at BEP flow. So that's what these cases represent where the PER old is the 

PER we calculated in all the examples we just went through, and then the denominator is 

whatever, is the value, is hydraulic power, is shaft power of the pump, is a minimally compliant 

pump, which in this case is associated with an MEI-10 (and something like an MEI-50 for the 

market average) (p.46).” 

Questions and comments commenced. Members : 

 How are you going to regulate it? In the MEI you had three values and the test would 

require you to meet all three. Answer: the standard (in this proposal) would be a PER, 

and it would be one number. 

 We need a gestation (adoption) period to understand the impacts, to assure we don’t do 

something that will seriously harm manufacturers. 

 I like having three different ways to look at the system, despite the complexity. The 
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question is how would you implement this? We should spend the time to find an elegant 

solution. 

 I have trouble without the denominator, because it could cause market confusion. We 

need some indicator of the relative efficiency of the product. 

 How would we use the scale to implement a utility energy efficiency program? We will 

need some metric to characterize the energy efficiency performance and drive choices. 

 What is the process for actually setting the value? Answer: it will be set based on 

efficiency, improvements of the pump/the hydraulic performance of the pump only. In 

the PER equation, that's represented in the pump shaft power input for a given flow and 

head condition, and essentially we would look at how the pump shaft power could be 

decreased at a given flow and head condition. 

 We will be establishing a metric and then using the metric. As a WG, we will evaluate 

and decide base case levels of efficiency and the types of products and levels for which 

efficiency standards will apply. 

 I’m concerned about potential impacts from new technologies, price and foreign 

competition on domestic manufacturers. 

A member questioned the rationale for going with one metric. The EU has MEI for the pump 

and EEI for the system. Betsy Kohl clarified that it is not a legal issue. A single metric is to 

achieve comparability among the different pump configurations/systems. Another member said 

the “pump guys understand MEI....and they know the effect of adjusting an MEI level is. By 

doing the PER, it’s going to be a much harder thing for them to know how that’s going to affect 

them.” 

Alison Williams responded, “how we would potentially set a standard would be basically 

starting with the MEI levels, and this group could pick whatever MEI levels that you want to 

look at, and Dan and I will use those in our analyses and present the results for each of those 

levels. And what we would do is just -- you know, we would agree on how we were going to do 

the default motor and agree on what the default controls is, maybe it's 1, and so you're essentially 

just translating the MEI levels to PER. So you understand the MEI, you only have control over 

the bare pump and so this is really the same thing, it's just a mathematical translation of the MEI 

to a PER. That's how potentially you would set the standard. Yes, you can then use the metric to 

get credit for better motors and controls, but in the actual standard-setting process, it can really 

just be a calculation, a translational thing, where you guys can think about MEI and how you 

want MEI to be. We can decide on how you do this. You can calculate it for all your pumps and 

see what it looks like. It's not going to be exactly the same as the MEI. We know there is a little 

bit different when you plug it in, so you should certainly look at that for your pumps and see 

what happens, but it should be pretty much the same frame of reference as you're used to with 

the MEI (p.76).” 

Another member questioned why the WG could not have three different metrics—it might be 

better in the marketplace. Betsy Kohl clarified, “There are some statutory authority for different 

metrics for different products are set by statute. We don't have that here. So that's why, as we 

understand it, we're limited to a single metric, a single standard. But we didn't understand the 

MEI EEI to have that prohibition, but it's very similar to the MEI feeding into PER, which is 

what we were looking at.” 
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A member stated that, regarding the metric, “a lot of our group would like to see, 

psychologically, as something gets better, it gets bigger.” So the rating system should reflect that 

kind of ordering. 

Another member, abstracting the meaning from a detailed discussion on metric options, 

including comparisons to SEER and EER, said, “the MEI piece we all understand, we can set 

that level. And if I offer a pump to a certain MEI level and it passes, if I offer that pump with a 

motor of a given and known efficiency, there's a simple multiplying factor or simple factor that 

could be used, and then if I use a drive, there's a simple factor that I can use, so that it's really a 

fairly simple approach once you've gotten the MEI straightened out? I mean, is that a feasible 

scenario?” Sarah Widder replied, “Yes, that is completely correct.” 

Sarah continued, “you would rate a given pump. So there are multiple models of pump, but a 

given pump you would rate and you would determine the efficiency at multiple points or the 

power at -- you would get your MEI. It's just fine. To sell that pump, you would have your 

factors that could be more or less complicated, but you just plug it into an equation and get a 

number, and provided it's better than the standard, that's fine. If you were to sell that pump with 

a more efficient motor, the only thing -- and the way we've presented it here is it's a big long 

equation, but you would just change one variable. So you could set it up in a spreadsheet and 

instead of 93.6 percent efficient for the motor, which is the minimum efficiency motor, you 

would plug in 95 if you had a 95 percent efficient motor...at full load. And you just plug in the 

full load efficiency of the motor if you were going to sell it with a better motor and then get a 

different number that was better than the first case. And if you were going to sell that same 

pump with controls, now you would take that number that you had with the bare pump and 

whatever motor it's paired with and apply in this case some factor, .78, that would give you a 

reduced -- a better value representative of the better performance you get with controls. So after 

you rated your pump, all you do is some calculations.” 

A member indicated his discomfort in making a decision on metrics today because of insufficient 

data. Alison clarified, “we need, basically, agreement on a general construct of a metric that we 

can plug into the analysis and show the results.” 

The discussion turned to: 

 labelling options, whether MEI and PER could both be on a required label (p.98) 

 the variability of pump efficiencies in different applications (p.100) 

Another member said he did not want a system that limited his ability to choose different kinds 

of pumps—for example, that would implicitly mandate VFDs. Lucas Adin followed-on, saying 

that economic feasibility would be an important factor in determining whether a particular 

standard level makes sense (p.106). 

A member requested, again, that the consultant team provide a list of “things you need to know 

today.” Sarah responded, showing the equation on slide #6, asking if the WG was generally OK 

with the presented construct of a metric, including: power or pump efficiency or pump hydraulic 

power—some representation of pump performance with load points and weighting (p.115). The 
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WG took its mid-morning break. 

Returning from break, Al Huber, speaking on behalf of his caucus, said the manufacturers would 

like to see two different measurements/standards—stay with a MEI at 75, 100 and 110. And “if 

we want another index, we think it should be EEI and probably .....should be 25, 50, 75 and 100 

and that would take into consideration the system.” That creates alignment with Europe. He 

continued that there was confusion about what the DOE General Counsel had said—whether the 

WG could have two or not. Responding to a question on weighting, he said the caucus thought 

there should be equal weighting (on the MEI) and “equal weighting on the VFD is fine.” Other 

caucus members contributed that they wanted to encourage pump manufacturers to operate in the 

preferred operating range and give them a clear value “to shoot for, just on the pump.” 

Betsy Kohl responded to questions about labelling and the potential for two measures, “The 

label -- we have a standard that we would develop in this group. The label can -- and the 

statutory cite is 42 U.S.C. 6315 -- contain other useful measures of energy consumption, annual 

energy cost. Right? So MEI could be one of those. But it would just be information that you 

put out, it wouldn't be a separate standard that you would have to meet. So, I mean, and the way 

we understood that -- for the bare pump class, you would have your MEI, but your ultimate 

standard would be an EEI as it would be for all of your -- whether you have a motor or a motor 

and controls, you would just have some standard value for the motor and control efficiency, so it 

would all be EEI. That's why we kind of understood that there wouldn't be an issue. I mean, I 

don't know why there would necessarily be a problem with that because you know what the MEI 

is.” 

Returning to the issue of the metric, Lucas Adin stated his concern that with MEI, you lose the 

potential for comparability going beyond the bare pump alone into those pump-‘plus’ 

configurations—especially since the definition of pump is broad. A manufacturer asked if it was 

possible to utilize both the MEI—to set a standard, and a label with EEI—to allow for 

comparisons? In the detailed discussion that followed, manufacturers described some 

practicalities, especially how a load point as low as 50 percent could reduce overall efficacy for 

both pump designers and consumers. Another member reiterated the cost benefits to 

manufacturers of sticking with the EU metric. 

Responding to earlier proposals from members, Alison Williams asked “can we consider doing 

that by like for a bare pump maybe a weight at .5 is zero or .1, and then for a pump plus motor 

plus VFD, your weight at .5 is much higher?” Members indicated it was a promising approach, 

in part because manufacturers design pumps with an operating range between 75 and 110 percent 

in mind. Members described how this schema could work beneficially for VFDs. 

Members requested some new calculations: a PER calculation with zero weight on 50 percent 

and a PER calculation with pump, motor and control at 100, 75, 50 and 25—with equal 

weighting. 

To provide time for the calculations, the facilitator asked for confirmation on a member’s earlier 

request that the metric reflect ‘bigger is better’—restating the observation that this framework 

helps drive consumer behavior. Tom Eckman said, “I think all sides of the table agree with 
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that.” Al Huber, speaking on behalf of his caucus, also agreed. In a brief, informal scan of the 

members, no one indicated dissent. 

Returning to the pending data calculation request, a member indicated he would probably need to 

see some more information on denominators. As the calculation effort proceeded, the WG broke 

for lunch. Returning from lunch, a member inquired about SharePoint access. Lucas Adin 

agreed to follow-up. 

Sarah Widder began to present on the questions posed by members, with the following content 

(p.171): 

 Load factors at 50, 75, 100 and 110 percent of BEP flow 

 Equal weighting at the load points 

 Then applied a normalized distribution 

A member questioned whether the normalized distribution values were relevant. Another 

member clarified that all the manufacturers wanted to see was the bare pump, or bare pump and 

motor with their values judged at 75, 100, and 110 percent; and, the variable speed only—pump, 

motor and control. 

After a brief review of the numbers, where the pump-motor combination was more efficient than 

the pump alone, Sarah reviewed the spreadsheet assumptions. A member clarified that the 

manufacturers were trying to come up with an MEI for the bare pump only, a pump-motor 

combination and a pump-motor-controls combination. There was considerable back and forth 

about what the numbers meant. A member clarified the presented numbers, “your intent with 

this table is not to compare what's more efficient, a bare pump or a bare pump with a VFD, your 

intent is to compare the mathematical options; right?” Sarah agreed with the statement. After 

much back and forth and attempts at clarification, a member said, “ what we were looking at is 

the pump alone is basically the shaft power -- right? -- without any sort of motor. And in order 

to look at the bare pump on a sort of wire-to-water basis in a way, we're just dividing that by a 

standard motor to get this other rating value.” 

The facilitator asked if this general framework, with the understandings that had emerged in the 

previous discussion, would allow the consultant team to proceed with their analysis. Al Huber 

stated that they (the manufacturers ) were okay with the team proceeding, “but we’re going to go 

back and have our people run through it.” 

Alison Williams restated her understanding of how the analysis would proceed: “we'll just move 

forward in the analysis with sort of the equation construct we've been showing, and with these 

yellow cells. So for pumps and pumps plus motors, 75, 100, and 110, equal weighting. And for 

pumps plus motors plus controls, 20, 50, 75, and 100, equal weighting. That is the pump 

manufacturers' proposal.” A member asked if this set up an apples-to-apples comparison since 

the test conditions were so different. Another member compared it to car mileage estimates, 

highway and city. Members asked clarifying questions and made some specific requests to be 

included in the next round of analysis (p.211). 

Alison continued that it might be useful exercise for members to look at your pump’s MEI and 

translate the MEI into PER and see how they fare. A member asked what the target values for 
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MEI would be. She replied that we are probably going to do something like 10, 25, 40, 55, 70 

and max tech. Following on, Sarah said she had started to make a spreadsheet that we can send 

out to the group. You can plug in flow at BEP and shaft input power or efficiency at BEP and 

whatever other load points we decide, and it will calculate the PER for you in a number of 

different permutations. 

Construct of a Metric (p.231) 

Alison asked if we can “move forward with our analysis with 75, 100, and 110 percent of BEP 

flow and equal weighting for no denominator -- with no denominator for the pump and motor 

case, and then changing the load points to 25 percent, 50 percent, 75 percent, and 100 percent of 

BEP flow and equal weighting for the case where a bare pump is sold with controls, which was 

the manufacturers' suggestion. And I just made the assumption that we're moving forward with 

no denominator because we've been talking about that for a long time. The other options we had 

on here were a number of different denominators and the inverse of this, which makes higher 

better.” 

A member of the manufacturer’s caucus indicated that the load points would be okay, as well as 

equal weighting. The EE advocates caucused during the break Tom Eckman reported that the 

caucus was in agreement with weightings in Columns D and E for those two—they were in 

agreement with the manufacturers. Sarah confirmed that was what the team would move 

forward on with its analysis. The facilitator confirmed that this was a preliminary, not a final, 

vote. 

Final Issues (p.249) 

The WG considered taking up the issue of denominators, but decided the time available was too 

short. A brief discussion ensued nevertheless. A member described that it would be useful to 

have an actual number somewhere between zero and one. 

Another member asked if another name could be found to substitute for Lot 11. After 

discussion, the WG agreed to replace Lot 11 with Phase 1 Scope. 

A member asked about consultants’ work products looking ahead. Alison responded that the 

plan for the next meeting is to present the engineering LCC—talking about inputs and 

assumptions and changing them real time. A member requested data be made available that 

showed sales, weighted average, what the distribution of product efficiency for the classes of 

pumps and incremental costs for either product improvement or product disappearance. Alison 

inquired and then confirmed that a histogram of C values would be okay with the manufacturers. 

Another member requested that DOE prepare a list of ‘what we want to get done in our next 

meeting’. 

In closing, the facilitator offered a brief summary of the last two days: 

 We started off with a presentation on the DOE rulemaking process. 

 We reviewed the aggregated results from the new surveys. There is more survey data 

coming in from NEMA-BIS that is going to be sent to DOE, but that was a good start. 

 We reviewed the updated scenarios for circulator energy use savings and payback, and 

that led to a useful discussion and a vote—circulators were excluded from the scope of 
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this rulemaking. 

 We clearly established the scope for this negotiation—a big breakthrough. From now on, 

those items in green, formerly Lot 11, will be referred to as Phase 1 Scope. 

 In addition, we talked about the clean water definition for pumps and talked also about 

how the listed exclusions would complement the clean water definition. We didn't do 

anything specific with that. 

 However, we did conclude, at least for now, the exclusions listed in red on that 

worksheet. Sanitary pumps was included as an excluded item, and we also clarified that 

the standards rulemaking applies to electric drivers only. 

 We had detailed discussion on metrics. We confirmed the load points and weightings 

that are going to be used to enable further analysis 

 We also had a good presentation from Arnie Sdano on HI's 40.6 

The meeting adjourned at 2:45 

Meeting summary prepared by Doug Brookman 

publicsolutions@earthlink.net 

April 24, 2014