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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 (alter nate 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 Gr oup (WG) meeting to order and welcomed all present at 9:05AM. The facilitator noted the wi ntry 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 compile d by DOE and the consultant team. He also referenced a power point presen tation prepared by DOE—a gene ral overview of the Appliance Standards rulemaking process, suggesting that pr esentation be the first agenda item. Following that presentation, pursue the following agenda items:

 Clearly define scope for the negotia tion: pump types being considered2 Page | 2  Clearly define scope fo r 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 pr ocess 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-base d 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 standa rd levels assuming different levels of shipments and typical usage patterns to assess the national energy sa vings at that standard level

He continued, “So we start out with a market a nd technology assessment. What does the market look like? What kind of technologi es are actually in use? Then utilize screening analysis to determine what kinds of technological improve ments can be made to the product—which ones

are feasible? Which t echnologies are readily available.....all of that goes into an engineering analysis where we look at realis tically what would it cost to imp lement 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 baseli ne 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 a nd 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 th e cost of them, we also look at mark-ups to determine equipment price. So we have mark-ups based on distri bution 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. A nd 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 agricu ltural. 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 scen arios. And that gets rolled into the life cycle costs and payback pe riod. So it combines the engineering analysis which is how much it costs to get to higher effi ciency and the energy analysis combined with electricity price to find your total operating cost s. You combine those tw o things and it gives3 Page | 3 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 percenta ge 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 ev en if we are looking at a cert ain 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 effi ciency) 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 life time so we can analyze how many replacements are needed to go

into the current stock and that basically generates, between re placement and construction, that generates that shipment projection over the 30 year analysis period. And so the shipment projection is combined with so me of the other things that we’ve done so far to populate the national energy saving and net present value....t he 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 th ose standards which is basically the increased installed cost of higher efficiency units versus operating costs of the higher efficiency units multiplied by all the shipment s in the projection. A nd so basically if the net present value is negative th at is another indication that th at standard level would not be considered eventually....preliminary manufacturi ng 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 indus try cash flow and net pr esent 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 ar e 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, moneti ze 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 stat ed, 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 ma king process.” Lucas rest ated that the larger goal for the negotiation was for the WG to create a term sheet which DOE will translate into a4 Page | 4 proposed rule, to be published for comment, re view, and ultimately, become a final rule.

Clearly Define Scope for the Negotiation (p.30) The facilitator acknowledged and thanked the Hydr aulic 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* un its (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 categ ories listed in green (on the colorful greenyellow-red chart on p.3 of the slides) repres ent 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 Discus sion). After discussion, the group decided to review the data even though the da ta was incomplete. There was in sufficient data for radial-split horizontal to report and the axial-split numbers represented only a few manufacturers. For vertical-turbine submersibles, th e data reflected large portions of the market being absent. The chart reflected updated annual energy use numbe rs, new shipments and new shipment-weighted horsepower.

Members commented on the data (p.63):

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

substitute for the other in the ma rketplace 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 th e 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 hour s 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 are5 Page | 5 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 fa il 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 po wer 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 ba sed on pump efficiency improvement.

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

standard levels? Alison answered that ME I 40 is cutting off 40% of the market—other levels, both lower and higher to max tech would be considered.

 Clarified that the percentages list ed were on a market average basis

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

 Questioned how to account for trimmed im pellers—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 onl y 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 th e revised numbers (that had emerged in the morning’s discussion) cell by ce ll. Next Dan Weintraub repo rted on circulators (original handout: Incremental Costs for Circulators, p.11). Dan reported that incr eases in circulator manufacturer selling price could occur for tw o 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 estimate d 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 unde r 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 $29.50.6 Page | 6 Members questioned the estimate.

Moving to manufacturer redesi gn and conversion costs (new packet, p.2, p.139), Dan described the following estimates for less than one-quarter horsepow er 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 detail ing some corrections, Alison de scribed 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 comm ented. One stated that a 10- year payback was untenable for manufacturer s—it would result in product being manufactured off shore. Another questioned th e 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 th e data “would provide ju stification 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.” Alis on interjected that the estimated savings were predicated on using ECMs for circulators. Follo wing, 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 includi ng controls. A member inquired about the level of effort and timing of including circulators in this rulema king (p.168). Alison respo nded “the two biggest differences we see are going to be the engine ering analysis and the LCC because engineering will be covering motors instead of hydraulic effici ency. It is a completely different analysis essentially; different design options and all that. So wh ile 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. Alis on and Dan Weintraub responded, essentially, that it would be a complicated, time consuming, wholly-d ifferent analysis and the analysis team had “only touched the surfac e” on circulators (p.174).

With the lunch break approachi ng, the facilitator made general inquiries about how to conduct7 Page | 7 the anticipated vote on scope when the WG retu rned from lunch. Members suggested that a

caucus was needed. The WG recessed for lunch.

Returning from lunch, Tom Eckman, speaking on be half of the EE caucus, offered the following proposal:

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

the term sheet a schedule which indicates our intention that circulat ors be addressed “as quickly as practicable”, that the term sh eet specifies a target date for the second negotiation—to commence by the end of Decem ber of 2014—“that would be the goal”

Al Huber, speaking on behalf of the manufact urer’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 ener gy savings are not great and the costs of redesign would be extremely high and extremely time consuming

Members clarified that the pool pum ps could be described as dedi cated or integrated pool pumps.

Tom Eckman, speaking again on behalf of the EE caucus, confirmed that the EE caucus supported the manufactur er’s caucus proposal.

A member requested that the terms and descriptors used in the offici al 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 Phas e 2 designation for circul ators 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. Continui ng, 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 ha ve five years to comply from the date of that rule.” In answering a membe r’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 covere d products because of ec onomies of scale, the possible same application and th eir competitive qualities”. After discussion and clarification, the amendment was put to a vote. Eight members vot ed against the amendment, so the amendment

was defeated.

Once again the facilitator asked for a vote on the original two-caucus (joi nt) proposal that was still pending. Asking for a show of hands, fift een members voted to acce pt the proposal and one

member abstained. The WG obtained a consensus on the scope for the negotiation (p.227)

.8 Page | 8 The facilitator raised the issue of sanitary pum ps, which was one more pump type left on the exclusions list. Greg Towsley supplied a defini tion and Alison read it into the record (p.229). After discussion, a member clarif ied that these pumps meet a US DA guideline (3-A) for sanitary design and fabrication of dairy pr ocessing equipment. The facilita tor 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 “C lean 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 supplie d 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 horsepowe r, temperature, etc. would be included.

 Another clarified that other specifi cations would be fully spelled out.

 Others questioned whether the definition woul d be adequately inclusive of additives, including salt water

Next, Arnold Sdano presented on HI’s 40.6 test sta ndard (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 temper ature range of 10 degrees to 30 degrees C.; a maximum viscosity of 1.5 times to the minus six meters square d per second; and, a ma ximum density of 1050 kilograms per cubic meter. He noted this was ve ry similar to the defini tion of clean water being considered by the WG. He described a deta iled consideration of pu mp 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 balloti ng at HI. The final draft is due to DOE by May 15.

Next Steve Rosenstock presented some inform ation on non-electric drivers based on data he obtained from the agricultural sector. Based on th e established scope, most of the non-electric driver pumps had been excluded. A member comme nted 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 sma ll electric motors, although the su rge 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 explora tion of non-electric pump applications that might try to evade the standard. Sarah Widde r added it would be usef ul 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-el ectric drivers. The test procedure will specify9 Page | 9 that the bare pump calculations also apply to pumps with non-elec tric 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 th e metric to electric

drivers.

Metrics (p.294) Sarah Widder began to present from a lengt hy slide deck, beginning with an overview on

material that was covered previously.

A member asked, noting that several possible pump s configurations are potentially being sold (bare pump, pump + motor, pump + motor + controls ), who is responsible for actually certifying the product. There was consider able discussion on who would be responsible. Some members recalled that the manufacturer was responsible fo r the product as sold. Others recalled Betsy Kohl’s description of a broader definition which included distributors as th e responsible party if they were doing assembly. Another member re stated his understanding, “really what happens is you get your pump efficiency and everything afte r that is calculated and we slap the label on. So if you get your MEI and somehow it gets ma ssaged, you stick it in an d 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 th en described how the PER might be calculated. Referring to the projected equation and showi ng 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 accoun t for the savings from controls in the absence of a more rigorous or widely availa ble 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 whic h are also up for discussion.

 “MEI and EEI are used in the EU and the ME I 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 mi nute (GPM) versus some sort of energy

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

After many questions and diversi ons, Sarah continued with the example of a bare shaft pump and how it fits with the PER, “for every pump, ev ery 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 th e point specified in 40.6. You record head, rotational speed, torque, and, in the following tabl e, convert into a power, torque times speed, output power is flow rate times head times speci fic 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 certif ied at full impeller diameter only—sold in10 Page | 10 whatever configuration they are sold in”

“So this is just for the bare pump case. We wo uld be assigning for every size; the standard motor assumption is the same. But it has no bearing on th e 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 deta iled 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 e qual loading was beneficial for manufacturers.

Sarah continued, summarizing the approach for applying a metric to ba re 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 manuf acturer motor data not DOE minimum standard data or you can do a wire to water test for the calcul ations -- we are just talking about calculations. We are just talking about A right now. We wi ll 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 fract ional 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 Gr oup (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 th e 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 a nd equations. The following is an attempt to lift and summarize, mostly at a conceptual level, the most descriptive content.11 Page | 11 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 appli cable 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 equi pment 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 sa me 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, refe rring to an equation, “We talked about how the test procedure for establishing BEP, and just in general pump characteri stics being consistent with 40.6, essentially running the load curve cap turing 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 pr ocedure would be the repeatability of that and ensuring that then when you found BEP flow, yo u would actually capture your 100 percent point near to what you thought would be BEP flow [b ased on the rated performance of the pump].”

Bare Pump Sarah continued, “for the bare pump option...the pump performa nce data would come from 40.6 at the specific load points....and then multiply ing 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 ac count for motor losses,” continued Sarah.” “ So we can look up a default full-load motor effici ency in the tables at CFR 431.25, which is the section for motors. In this case, we have a sp ecific 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 fu ll-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 calcu late 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 le ss 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 horse power losses at each load point for the pump.12 Page | 12 Note that the motor losses equation is repres entative of the worst performing, or most conservative, motor in the data base, so that any tested pum p and motor combination would always receive a better rating than this default calculation. And th is table just represents that data. So there are four flow points on the le ft-hand side: 110, 100, 75, and 50, and these are the bare pump shaft power. Then we calculated th e load fraction on the motor for each of those cases: the part-load loss factor , which is plugging in that x i term into the y i quadratic equation that was on the previous slide; and then the frac tional-load loss is a hors epower [term],where we multiplied the y i 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 effici ency, 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 cal culated 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 th e 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 consid er for rating a bare pump that's sold combined

with motor and controls....This is the same equation that we sa w 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 th ese 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 appl ied 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 examples13 Page | 13 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 consid ered 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 th e 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 powe r input to the system at those reduced loadings, you would get a better rating than you would us ing the calculation approach. (So this is our load curve. One point is th at 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 wh ere 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 th e load points that we

calculated these -- basica lly these values in the right-ha nd 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 t op as input power to the motor, and then we divided that by the drive, or assumed drive, effici ency. And so that would give us essentially a PER that is accounting for the efficiency of the motor, the e fficiency 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 se lling 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 an d motor that it's pack aged with, and then depending on the type of controls, look up the load control factor that wo uld 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 co mparing to full wire-to-water test method for pumps sold with motors or pumps sold with motors and controls, “One thi ng to consider with the two options, the calculation-based default and th en testing methods that will result in better ratings, is we can allow that manufacturers or parties certifying equipm ent have the option to14 Page | 14 test, or we can require the calcu lation method for all pumps. Th ese 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 calculati on method is less burdensome and very repeatable because we all have the same calculation. The physical te st 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 f unction of speed and flow, and you also have larger numbers, which makes it easier to differentia te changes in efficiency. So when I put the efficient motor on, my PER was reduced by 2 point s 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 oppos ed 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 sta ndard level. We could also look at tying it to a market average, so comparing that pump to so me 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 ma rket 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 me thod, but it also does result in valu es 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 ra tio at each load point as a norma lization 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 th e 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 ju st went through, and then the denominator is whatever, is the value, is hydrau lic power, is shaft power of th e 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. The15 Page | 15 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 rela tive efficiency of the product.

 How would we use the scale to implement a u tility energy efficiency program? We will need some metric to characterize the energy efficiency performance and drive choices.

 What is the process for actually setting th e value? Answer: it will be set based on efficiency, improvements of the pump/the hydra ulic 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 l ook at how the pump shaft power could be decreased at a given flow and head condition.

 We will be establishing a metric and then us ing the metric. As a WG, we will evaluate and decide base case levels of efficiency a nd 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 di fferent pump configurations/syste ms. 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 thi ng 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, a nd this group could pick whatever MEI levels that you want to look at, and Dan and I will use those in our anal yses and present the results for each of those levels. And what we would do is just -- you kno w, we would agree on how we were going to do the default motor and agree on what the default cont rols is, maybe it's 1, a nd 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 th ing, it's just a mathematical translation of the MEI to a PER. That's how potentially you would set th e 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 ce rtainly look at that for your pumps and see what happens, but it should be pretty much the sa me 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 si milar to the MEI feeding into PER, which is what we were looking at.”16 Page | 16 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 sy stem 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 ME I 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 si mple factor that I can use, so that it's really a fairly simple approach once you've gotten the MEI straightened out? I mea n, 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 determin e 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 pl ug 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 re presentative of the bett er performance you get with controls. So after you rated your pump, all you do is some calculations.”

A member indicated his discomfo rt in making a decision on metrics today because of insufficient data. Alison clarified, “we nee d, 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 c ould both be on a requi red label (p.98)

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

Another member said he did not want a system th at 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, includ ing: power or pump effi ciency or pump hydraulic power—some representation of pump performance with load points and weighting (p.115). The17 Page | 17 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/standard s—stay with a MEI at 75, 100 and 110. And “if we want another index, we th ink it should be EEI and probably .....should be 25, 50, 75 and 100

and that would take into consid eration the system.” That creat es alignment with Europe. He

continued that there was confus ion 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 weighti ng (on the MEI) and “equal weighti ng on the VFD is fine.” Other caucus members contributed that they wanted to encourage pump manufacture rs to operate in the preferred operating range and gi ve them a clear value “to shoot for, just on the pump.”

Betsy Kohl responded to questi ons about labelling and the pot ential for two measures, “The

label -- we have a standard that we would de velop 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 coul d be one of those. But it woul d 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 va lue for the motor and control efficiency, so it would all be EEI. That's why we kind of underst ood that there wouldn't be an issue. I mean, I don't know why there would necessarily be a prob lem 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 broa d. 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, A lison 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 wa s a promising approach, in part because manufacturers design pumps w ith an operating range between 75 and 110 percent

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

Members requested some new calculations: a PE R calculation with zero weight on 50 percent and a PER calculation with pump, motor a nd control at 100, 75, 50 and 25—with equal weighting.

To provide time for the calculations, the facilita tor asked for confirmation on a member’s earlier request that the metric reflect ‘bigger is bett er’—restating the observati on that this framework helps drive consumer behavior. Tom Eckman sai d, “I think all sides of the table agree with18 Page | 18 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 ca lculation request, a member indicat ed 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 i nquired 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 di stribution values were relevant. Another

member clarified that all the ma nufacturers wanted to see was th e bare pump, or bare pump and motor with their values judged at 75, 100, a nd 110 percent; and, the variable speed only—pump,

motor and control.

After a brief review of the numbers, where the pu mp-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 combinati on. There was considerable back and forth

about what the numbers meant. A member clar ified the presented numbers, “your intent with this table is not to compare what's more efficien t, a bare pump or a bare pump with a VFD, your intent is to compare the mathematical options; ri ght?” 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 sh aft 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 wa y, 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 t eam to proceed with their analysis. Al Huber stated that they (the manufactur ers ) were okay with the team pr oceeding, “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 so rt of the equation construct we'v e 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 memb er asked if this set up an apples-to-apples comparison since

the test conditions were so diffe rent. Another member compared it to car mileage estimates, highway and city. Members asked clarifying ques tions and made some specific requests to be

included in the next roun d of analysis (p.211).

Alison continued that it might be useful exerci se 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 for19 Page | 19 MEI would be. She replied that we are pr obably going to do something like 10, 25, 40, 55, 70 and max tech. Following on, Sarah said she had st arted to make a spreadsheet that we can send out to the group. You can plug in flow at BEP a nd 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 tim e. The other options we had

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

better.”

A member of the manufacturer’s caucus indicated that the load poi nts would be okay, as well as equal weighting. The EE advocates caucused du ring 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 conf irmed that was what the team would move forward on with its analysis. Th e facilitator confirmed that this was a preliminary, not a final,

vote.

Final Issues (p.249) The WG considered taking up the issue of denomin ators, 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 some where between zero and one.

Another member asked if another name coul d 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 produc ts 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 me mber requested data be made available that showed sales, weighted average, what the distri bution 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 br ief 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 circ ulator energy use savings and payback, and

that led to a useful discu ssion and a vote—circulators were excluded from the scope of20 Page | 20 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 exclusi ons 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 applie s 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