i

PRELIMINARY TECHNICAL SUPPORT DOCUMENT EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF CURRENT ACTIVITIES ...................................................................... 1

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSES AND THE PRELIMINARY 

TECHNICAL SUPPORT DOCUMENT............................................................................ 3

ES.3 KEY RESULTS FROM THE ANALYSES....................................................................... 4

ES.3.1 Market and Technology Assessment..................................................................... 4

ES.3.2 Screening Analysis................................................................................................ 5

ES.3.3 Engineering Analysis ............................................................................................ 5

ES.3.3.1 Equipment Classes Analyzed ................................................................. 5

ES.3.3.2 Engineering Analysis Results................................................................. 6

ES.3.4 Markups Analysis................................................................................................ 17

ES.3.5 Energy Use Characterization............................................................................... 18

ES.3.6 Life-Cycle Cost and Payback Period Analysis.................................................... 19

ES.3.6.1 Results of Life-Cycle Cost and Payback Period Analysis ................... 21

ES.3.7 Shipments Analysis............................................................................................. 26

ES.3.8 National Impact Analysis.................................................................................... 27

ES.3.8.1 Analysis of National Energy Savings................................................... 28

ES.3.8.2 Analysis of Consumer Net Present Value ............................................ 29

ES.3.9 Preliminary Manufacturer Impact Analysis........................................................ 31

ES.3.10 Other Analyses.................................................................................................... 32

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT............................................. 32

ES.4.1 Scope of Coverage of Electric Motors................................................................ 32

ES.4.2 Screening Analysis.............................................................................................. 33

ES.4.3 Engineering Analysis Methodology.................................................................... 33

ES.4.4 Engineering Analysis Results.............................................................................. 33

ES.4.5 Motor Distribution Across Sectors...................................................................... 33

ES.4.6 Motor Distribution Across Applications............................................................. 33

ES.4.7 Data on Operating Hours and Loading................................................................ 33

ES.4.8 Product Price Determination ............................................................................... 33

ES.4.9 Repair Costs ........................................................................................................ 34

ES.4.10 Frequency of Repair............................................................................................ 34

ES.4.11 Maintenance Costs .............................................................................................. 34

ES.4.12 Installation Costs................................................................................................. 34

ES.4.13 Motor Lifetimes................................................................................................... 34

ES.4.14 Product Energy Efficiency in the Base Case....................................................... 34

ES.4.15 Efficiency Trends ................................................................................................ 34

ES.4.16 Estimated Shipments........................................................................................... 34

ES.4.17 Purchase Price Elasticity ..................................................................................... 35

ES.4.18 Scaling Methodology for Manufacturer Selling Price ........................................ 35

ES.4.19 Scaling Methodology for Motor Weights ........................................................... 35

ES.4.20 Trial Standard Levels .......................................................................................... 35
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LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Electric Motor Rulemaking Analyses ........................................ 2

Figure ES.3.1 NEMA Design B, 5 Horsepower, 4-Pole, Enclosed Frame Motor Engineering 

Analysis Curve........................................................................................................ 8

Figure ES.3.2 NEMA Design B, 30 Horsepower, 4-Pole, Enclosed Frame Motor Engineering 

Analysis Curve...................................................................................................... 10

Figure ES.3.3 NEMA Design B, 75 Horsepower, 4-Pole, Enclosed Frame Motor Engineering 

Analysis Curve...................................................................................................... 12

Figure ES.3.4 NEMA Design C, 5 Horsepower, 4-Pole, Enclosed Frame Motor Engineering 

Analysis Curve...................................................................................................... 14

Figure ES.3.5 NEMA Design C, 50 Horsepower, 4-Pole, Enclosed Frame Motor Engineering 

Analysis Curve...................................................................................................... 16

LIST OF TABLES

Table ES.3.1 Design Characteristics of the Five Representative Units Analyzed ....................... 6

Table ES.3.2 NEMA Design B Motor Candidate Standard Levels.............................................. 6

Table ES.3.3 Design C 5 Horsepower Motor Candidate Standard Levels................................... 7

Table ES.3.4 NEMA Design C 50 Horsepower Motor Candidate Standard Levels.................... 7

Table ES.3.5 Efficiency and Manufacturer Selling Price Data for the NEMA Design B 5 

Horsepower Motor.................................................................................................. 9

Table ES.3.6 NEMA Design B 5 Horsepower, 4-Pole, Enclosed Frame Motor Characteristics. 9

Table ES.3.7 Efficiency and Manufacturer Selling Price Data for the NEMA Design B 30 

Horsepower Motor................................................................................................ 10

Table ES.3.8 NEMA Design B 30 Horsepower, 4-Pole, Enclosed Frame Motor Characteristics

............................................................................................................................... 11

Table ES.3.9 Efficiency and Manufacturer Selling Price Data for the NEMA Design B 75 

Horsepower Motor................................................................................................ 12

Table ES.3.10 NEMA Design B 75 Horsepower, 4-Pole, Enclosed Frame Motor Characteristics

............................................................................................................................... 13

Table ES.3.11 Efficiency and Manufacturer Selling Price Data for the NEMA Design C 5 

Horsepower Motor................................................................................................ 14

Table ES.3.12 NEMA Design C 5 Horsepower, 4-Pole, Enclosed Frame Motor Characteristics15

Table ES.3.13 Efficiency and Manufacturer Selling Price Data for the NEMA Design C 50 

Horsepower Motor................................................................................................ 16

Table ES.3.14 NEMA Design C 50 Horsepower, 4-Pole, Enclosed Frame Motor Characteristics

............................................................................................................................... 17

Table ES.3.15 Summary of Markups for the Three Primary Distribution Channels for Medium 

Electric Motors...................................................................................................... 18

Table ES.3.16 Average Annual Energy Consumption by Efficiency Level for Representative 

Units...................................................................................................................... 19
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Table ES.3.17 Representative Units for Preliminary Analysis.................................................... 22

Table ES.3.18 Life-Cycle Cost and Payback Period Results for Representative Unit 1: NEMA 

Design B, T-Frame, 5 Horsepower, 4-Pole, Enclosed Motor............................... 22

Table ES.3.19 Life-Cycle Cost and Payback Period Results for Representative Unit 2: NEMA 

Design B, T-Frame, 30 Horsepower, 4-Pole, Enclosed Motor............................. 23

Table ES.3.20 Life-Cycle Cost and Payback Period Results for Representative Unit 3: NEMA 

Design B, T-Frame, 75 Horsepower, 4-Pole, Enclosed Motor............................. 23

Table ES.3.21 Life-Cycle Cost and Payback Period Results for Representative Unit 4: NEMA

Design C, T-Frame, 5 Horsepower, 4-Pole, Enclosed Motor............................... 24

Table ES.3.22 Life-Cycle Cost and Payback Period Results for Representative Unit 5: NEMA 

Design C, T-Frame, 50 Horsepower, 4-Pole, Enclosed Motor............................. 24

Table ES.3.23 Life-Cycle Cost and Payback Period Results for Representative Unit 6: Fire 

Pump, NEMA Design B, T-Frame, 5 Horsepower, 4-Pole, Enclosed Motor....... 25

Table ES.3.24 Life-Cycle Cost and Payback Period Results for Representative Unit 7: Fire 

Pump, NEMA Design B, T-Frame, 30 Horsepower, 4-Pole, Enclosed Motor..... 25

Table ES.3.25 Life-Cycle Cost and Payback Period Results for Representative Unit 8: Fire 

Pump, NEMA Design B, T-Frame, 75 Horsepower, 4-Pole, Enclosed Motor..... 26

Table ES.3.26 Annual and Cumulative Shipments Projection for Electric Motors (AEO 

reference case) ...................................................................................................... 27

Table ES.3.27 Summary of Cumulative National Energy Savings in Quads (2015-2044)......... 29

Table ES.3.28 Net Present Value of Customer Impacts (billion 2011$)..................................... 30

Table ES.3.29 Cumulative National Energy Savings and Net Present Value Results ................ 31
1

ES.1 OVERVIEW OF CURRENT ACTIVITIES 

The Energy Policy and Conservation Act (EPCA), 42 U.S.C. § 6311, et seq., as amended 

by the Energy Policy Act of 1992 (EPACT) established energy conservation standards and test 

procedures for certain commercial and industrial electric motors manufactured (alone or as a 

component of another piece of equipment) after October 24, 1997. Then, in December 2007, 

Congress passed into law the Energy Independence and Security Act of 2007 (EISA 2007) (Pub. 

L. No. 110–140). Section 313(b)(1) of EISA 2007 updated the energy conservation standards for 

those electric motors already covered by EPCA and established energy conservation standards 

for a larger scope of motors not previously covered. (42 U.S.C. 6313(b)(2)) 

EPCA also directs the Secretary of Energy to publish a final rule no later than 24 months 

after the effective date of the previous final rule to determine whether to amend the standards in 

effect for such product. Any such amendment shall apply to electric motors manufactured after a 

date which is five years after –

(i) the effective date of the previous amendment; or 

(ii) if the previous final rule did not amend the standards, the earliest date by which a 

previous amendment could have been effective. (42 U.S.C. 6313(b)(4)(B)) 

EISA 2007, which went into effect on December 19, 2010, constitutes the most recent 

amendment to EPCA and energy conservation standards for electric motors. DOE will 

determine whether to promulgate amended energy conservation standards for electric motors 

and, if so, what level the new standards should be set at based on an in-depth consideration of the 

technological feasibility, economic justification, and energy savings of candidate standards levels 

as required by section 325 of EPCA. (42 U.S.C. 6295(o)-(p), 6316(a)) Any such amended 

standards that DOE establishes would take effect December 19, 2015.

This executive summary describes current activities and key results from the preliminary

analyses that DOE conducted in its review of potential amendments to the energy conservation 

standards for electric motors. Furthermore, the executive summary identifies issues about which 

DOE seeks comments from interested parties. These issues are addressed in more detail in 

chapter 2 of the preliminary technical support document (preliminary TSD) and will be discussed 

in a future public meeting.

To evaluate and consider impacts under the seven EPCA factors for economic 

justification (42 U.S.C. 6295(o)(2)(B)(i), 6316(a)), DOE conducts a detailed analysis of 

regulatory impacts on a product and presents them in a technical support document (preliminary 

TSD). Figure ES.1.1 summarizes the analytical components of this regulatory analysis 

methodology. The focus of this figure is the center column, identified as “Analyses.” The 

columns labeled “Key Inputs” and “Key Outputs” show how the analyses fit into the rulemaking 

process, and how the analyses relate to each other. Key inputs are the types of data and other 

information that the analyses require. Some key inputs exist in public databases; DOE collects 

other inputs from interested parties or persons with special knowledge and expertise. Key 
2

outputs are analytical results that feed directly into the standards-setting process. Arrows 

connecting analyses show types of information that feed from one analysis to another.

Figure ES.1.1 Flow Diagram of Electric Motor Rulemaking Analyses

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Revise Preliminary

Analyses

Consumer

Sub-Group Analysis

Manufacturer Impact 

Analysis

Shipments

Analysis

Employment Impact

Analysis 

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Advance Notice of Proposed Rulemaking (ANO)

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Emissions

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

Direct Employment 

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life-Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy-Efficiency 

Levels

• Department of Justice Review

Product Designs

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Analys

-Group Analysis

Manufacturer Impact 

Analysis

Shipments

Analysis

Employment Impact

Analysis 

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Publication of Preliminary Analyses

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Analysis

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

Direct Employment 

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life-Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy-Efficiency 

Levels

• Department of Justice Review

Product Designs
3

ES.2 OVERVIEW OF THE PRELIMINARY ANALYSES AND THE PRELIMINARY 

TECHNICAL SUPPORT DOCUMENT 

DOE is publishing a notice of public meeting (NOPM) in the Federal Register, which 

announces the availability of the preliminary TSD, the date of the public meeting, and 

information pertaining to the public meeting. In addition, the NOPM highlights the major 

preliminary analyses DOE has developed at this stage of the rulemaking. 

The preliminary TSD describes each analysis in detail, providing detailed descriptions of 

inputs, sources, methodologies, and results. Chapter 2 of the preliminary TSD provides an 

overview of each preliminary analysis, the comments DOE received in response to the 

framework document, and DOE’s responses to those comments. The remaining chapters of the 

preliminary TSD, which are described later, address the preliminary analyses performed:

Chapter 3: A market and technology assessment that characterizes the relevant product 

markets and technology options, including prototype designs.

Chapter 4: A screening analysis that reviews each technology option to determine 

whether it (1) is technologically feasible, (2) is practicable to manufacture, install, and service, 

(3) would adversely affect product utility or product availability, or (4) would have adverse 

impacts on health and safety.

Chapter 5: An engineering analysis that develops cost-efficiency relationships estimating

the manufacturer’s cost of achieving increased efficiency. DOE determines the increased cost to 

the consumer through an analysis of engineering markups, which convert manufacturer 

production cost to manufacturer selling price (MSP).

Chapter 6: A markups analysis that converts the estimated MSPs derived from the 

engineering analysis to installed prices.

Chapter 7: An energy use analysis that determines the annual energy use of the 

considered products.

Chapter 8: Life-cycle cost (LCC) and payback period (PBP) analyses that calculate, at the 

consumer level, the discounted savings in operating costs (less maintenance and repair costs) 

throughout the estimated average life of the covered products, compared to any increase in the 

installed cost for the products likely to result directly from the imposition of a given standard.

Chapter 9: A shipments analysis that projects product shipments, which are then used to 

calculate the national impacts of standards on energy, net present value (NPV), and future 

manufacturer cash flows.

Chapter 10: An assessment of the aggregate impacts at the national level of potential 

energy conservation standards for the considered products, as measured by the NPV of total 

consumer economic impacts and the national energy savings (NES).
4

Chapter 11: A customer subgroup analysis that evaluates the impacts of standards on 

identifiable groups of customers, such as customers of different business types, which may be 

disproportionately affected by an energy conservation standard.

Chapter 12: A preliminary manufacturer impact analysis (MIA) that assesses the potential 

impacts of energy conservation standards on manufacturers, such as effects on expenditures for 

capital conversion, marketing costs, shipments, and research and development costs.

Chapter 13: An employment impact analysis that examines the effects of energy 

conservation standards on national employment.

Chapter 14: A utility impact analysis that examines impacts of energy conservation 

standards on the generation capacity of electric utilities.

Chapter 15: An emissions analysis that evaluates the reduced power plant emissions 

resulting from reduced consumption of electricity. 

Chapter 16: A monetization of emission reduction benefits resulting from reduced 

emissions associated with potential amended standards.

Chapter 17: A regulatory impact analysis that: (1) identifies and seeks to mitigate 

overlapping effects of regulations on manufacturers and (2) addresses the potential for nonregulatory approaches to supplant or augment energy conservation standards.

ES.3 KEY RESULTS FROM THE ANALYSES

The following sections describe in detail the key analyses DOE performed in support of 

the preliminary TSD.

ES.3.1 Market and Technology Assessment

When initiating an energy conservation standards rulemaking, DOE develops information 

on the present and past industry structure and market characteristics for the equipment 

concerned. This activity assesses the industry and equipment both quantitatively and 

qualitatively, based on publicly available information. For the equipment in the preliminary 

analyses, DOE addressed the following: (1) manufacturer market share and characteristics, 

(2) existing regulatory and non-regulatory initiatives to improve the efficiency of the equipment, 

and (3) trends in the equipment’s characteristics and retail markets. This information serves as 

resource material throughout the rulemaking.

DOE reviewed literature and interviewed manufacturers to get an overall understanding 

of the electric motors industry in the United States. Industry publications, trade journals, 

government agencies, and trade organizations provided the bulk of the information obtained 

regarding: (1) manufacturers and their market shares, (2) shipments by equipment class, 

(3) equipment information, and (4) industry trends. The appropriate sections of preliminary TSD

chapters 2 and 3 describe the analyses and resulting information. 
5

DOE typically uses information about existing and past technology options and prototype 

designs to determine which technologies and combinations of technologies manufacturers use to 

attain higher performance levels. In consultation with interested parties, DOE develops a list of 

technologies for consideration. Initially, these technologies encompass all of those options that 

might for improve equipment efficiency. DOE developed its list of technology options for 

electric motors from its examination of technical documents and through consultation with 

manufacturers and industry experts.

ES.3.2 Screening Analysis

The screening analysis (chapter 4) examines whether various technologies: (1) are 

technologically feasible; (2) are practicable to manufacture, install, and service; (3) have an 

adverse impact on product utility or availability; or (4) have adverse impacts on health and 

safety. DOE develops an initial list of efficiency-enhancement options (i.e., technology options) 

from those identified as “technologically feasible” in the technology assessment. In consultation 

with interested parties, DOE then reviews the list to determine if these technologies are 

practicable to manufacture, install, and service; would adversely affect product utility or 

availability; or would have adverse impacts on health and safety. DOE removes from the list 

those technology options for which no energy consumption information is available and 

technology options whose energy consumption could not be adequately measured by the existing 

DOE test procedure. After DOE examines all of the technology options and pares them down in 

the screening analysis, it uses the remaining design options as inputs to estimate the 

characteristics and the cost of higher efficiency equipment in the engineering analysis.

ES.3.3 Engineering Analysis

The engineering analysis (chapter 5) establishes the relationship between the MSP and 

product efficiency. This relationship serves as the basis for cost/benefit calculations in terms of 

individual consumers, manufacturers, and the Nation. This chapter discusses the equipment 

classes DOE analyzed, the representative baseline units, the incremental efficiency levels, the 

methodology DOE used to develop the MSP, the cost-efficiency curves for equipment classes 

analyzed, and the methodology DOE used to scale those results to other equipment classes of 

electric motors that were not analyzed.

ES.3.3.1 Equipment Classes Analyzed

Because of the large number of electric motor equipment classes, DOE did not analyze 

each one in the engineering analysis. Instead, DOE analyzed five representative equipment 

classes: three from equipment class group 1 (NEMA Design A and B motors) and two from 

equipment class group 2 (NEMA Design C motors). The equipment class group 3 (fire pump 

motors) analysis will be based on the data from equipment class group 1 representative units

because of the similarities between fire pump electric motors and NEMA Design B motors. 

When selecting these groups, DOE used catalog data, discussions with industry experts, and the 

Framework Document. After analyzing this information, DOE reached the tentative conclusion

that the selected motor groups were representative of the commercial and industrial electric 
6

motor market which made them reasonable selections for the purposes of conducting the 

engineering analysis. The motors presented in Table ES.3.1 are the five representative units DOE 

analyzed. The left three columns provide the three characteristics of an electric motor that define 

its equipment class – namely, motor category, horsepower and number of poles. The fourth 

column denotes the frame series of the analyzed motor.

Table ES.3.1 Design Characteristics of the Five Representative Units Analyzed

Motor Category Horsepower Number of Poles Frame Series

NEMA Design B 5 4 184T

NEMA Design B 30 4 286T

NEMA Design B 75 4 365T

NEMA Design C 5 4 184T

NEMA Design C 50 4 326T

DOE requests comment on its selection of representative units for equipment class group

1, Design A and B motors from 1-500 horsepower, and equipment class group 2, Design C 

motors from 1-200 horsepower. DOE also requests comment on basing its analysis of equipment 

class group 3, fire pump electric motors, on the analysis of equipment class group 1 

representative units.

ES.3.3.2 Engineering Analysis Results

For each NEMA Design B representative unit, DOE purchased four electric motors at 

four increasing efficiency levelsa

Table ES.3.2

. The purchased motors included a baseline design at the 

minimum efficiency commercially available, while considering the expanded scope of coverage, 

a design at the EPACT 1992 level, a design at the NEMA Premium level, and a design at the 

maximum efficiency commercially available for that motor rating. DOE then used software 

modeling to create a fifth and sixth motor design for each of the three NEMA Design B electric 

motors. These additional designs had efficiencies corresponding to an incremental efficiency 

level and a maximum technologically feasible (“max tech”) efficiency level. DOE assigned each 

of these efficiency levels a candidate standard level (CSL) number from 0-5 with the baseline 

motor being assigned CSL 0 and the max-tech software modeled motor being assigned CSL 5. 

See for a layout of the CSLs and their efficiency representations.

Table ES.3.2 NEMA Design B Motor Candidate Standard Levels

Motor Designation Efficiency Level

CSL 0 Minimum Commercially Available

CSL 1 EPACT 1992

CSL 2 NEMA Premium

CSL 3 Maximum Commercially Available

 a For the 30 horsepower representative unit, DOE purchased three electric motors at different efficiency levels, and 

used software modeling to simulate motors at the remaining efficiency levels.
7

CSL 4 Incremental 

CSL 5 Maximum Technology

For the NEMA Design C representative units, DOE purchased one baseline motor and 

used software to model three additional designs with higher efficiencies than the efficiency of the 

baseline motor. DOE used this approach because NEMA Design C motors constitute a small 

portion of the electric motor market with limited product selection and DOE was unable to locate 

any commercially available units with increased efficiency levels. The NEMA Design C motors 

were assigned CSL numbers from 0-3 with CSL 0 representing EPACT 1992 efficiency levels 

and CSL 3 representing the max-tech efficiency level. See Table ES.3.3 and Table ES.3.4 for a 

layout of the CSLs and their efficiency representations.

Table ES.3.3 Design C 5 Horsepower Motor Candidate Standard Levels

Motor Designation Efficiency Level

CSL 0 EPACT 1992

CSL 1 NEMA Premium

CSL 2 Incremental

CSL 3 Maximum Technology

Table ES.3.4 NEMA Design C 50 Horsepower Motor Candidate Standard Levels

Motor Designation Efficiency Level

CSL 0 EPACT 1992

CSL 1 Incremental

CSL 2 NEMA Premium

CSL 3 Maximum Technology

DOE used a consistent methodology and pricing scheme including material, labor costs 

and manufacturer markups to develop MSPs for the baseline and incrementally more efficient 

electric motor designs. This methodology included tearing down the motors, weighing 

components, and estimating the material costs based on material pricing. DOE used this bottomsup derived and manufacturer marked-up selling prices throughout this section. The engineering 

analysis results are a series of MSP-versus-efficiency curves that represent the five motor types

analyzed from the representative equipment classes. The five graphs shown in Figure ES.3.1

through Figure ES.3.5 provide the MSP-versus-efficiency curves and Table ES.3.6 through 

Table ES.3.14 present the tabulated results. 

In determining the relationship between MSP and energy efficiency for electric motors, 

DOE estimated the increase in MSP associated with technological changes that increase the 

efficiency of the baseline models. DOE developed cost estimates for the engineering analysis 

from information received from subject matter experts with many years experience in the field, 

manufacturers’ suggestions, and input from other industry-related experts, including material 

suppliers.
8

NEMA Design B, 5 Horsepower, 4-Pole, Enclosed Frame Motor

Figure ES.3.1 presents the relationship between the MSP and full-load efficiency for the 

5 horsepower, Design B, 4-pole enclosed polyphase motor analyzed. Using tear-down results for

CSLs 0-3, DOE determined that the manufacturer of those motors used various combinations of 

stack length increases, electrical material such as copper or electrical steel, and rotor cage design 

changes to increase the electric motor’s efficiency level. The max-tech software modeled CSL 5 

and utilized a die-cast copper conductor in the rotor. Also, DOE assumed a hand-wound labor 

hour amount for the two software modeled CSLs (CSL 4 and 5). The increased labor hour 

amounts account for the larger than usual increase in the MSPs for the higher CSLs as illustrated 

in Figure ES.3.1.

Figure ES.3.1 NEMA Design B, 5 Horsepower, 4-Pole, Enclosed Frame Motor 

Engineering Analysis Curve

Table ES.3.5 presents the same engineering analysis results in tabular form, including the 

nominal full-load efficiency values and the MSPs. From CSL 0 to 3, DOE found that the fullload efficiency would increase 7.7 nominal percentage points over the baseline, CSL 0, which 

represents a 49 percent reduction in motor losses. When moving from CSL 3 to 4 and from CSL 

4 to 5, MSP increases by 41 percent and 11 percent, respectively, for consecutive loss reductions 

of roughly 10 percent. Again, the large price increases when getting to CSLs 4 and 5 are a result 

of the use of hand-wound labor hour assumptions and the use of low-loss electrical steels.
9

Table ES.3.5 Efficiency and Manufacturer Selling Price Data for the NEMA Design B 5 

Horsepower Motor

CSL Nominal Full-Load Efficiency (%) MSP ($)

0 82.5 324

1 87.5 326

2 89.5 358

3 90.2 370

4 91.0 523

5 91.7 579

Table ES.3.6 presents some of the design and performance specifications associated with 

the six 5-horsepower NEMA Design B motors presented in Table ES.3.5 including stator copper 

weight, rotor conductor weight, and electrical steel weight.

Table ES.3.6 NEMA Design B 5 Horsepower, 4-Pole, Enclosed Frame Motor 

Characteristics

Parameter Units CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 CSL 5

Efficiency % 82.5 87.5 89.5 90.2 91.0 91.7

Line Voltage V 460 460 460 460 460 460

Full Load Speed RPM 1,745 1,745 1,760 1,755 1,773 1,776

Full Load Torque Nm 20.3 20.4 20.3 20.4 20.1 20.1

Current A 6.9 6.5 6.3 6.2 6.3 6.0

Steel - M56 M47 M47 M47 M36 M36

Rotor Conductor 

Material - Aluminum Aluminum Aluminum Aluminum Aluminum Copper

Approximate 

Slot Fill % 43.5% 57.2% 70.0% 68.6% 82.4% 85.2%

Stator Wire 

Gauge AWG 19 19 19 20 20 20

Stator Copper 

Weight lbs 8.4 10.1 10.1 12.2 14.4 14.4

Rotor Conductor 

Weight lbs 2.63 2.87 2.6 3.42 2.7 9.1

Stack Length In 2.8 3.47 5.14 4.65 5.32 5.32

Housing Weight lbs 8 9 22 12 14 14

NEMA Design B, 30 Horsepower, 4-Pole, Enclosed Frame Motor

Figure ES.3.2 presents the relationship between the MSP and full-load efficiency for the 

30 horsepower, Design B, 4-pole enclosed polyphase motor analyzed. Using tear-down results 

for CSLs 0 through 3, DOE determined that the manufacturer of these motors used a 

combination of material grade, material quantities, and design changes to increase the electric 

motor’s efficiency. 

DOE used software modeling to develop CSL 4. For this design, DOE used a copper 

rotor and low-loss electrical steel to achieve efficiencies higher than the most efficient purchased 
10

motor, CSL 3. DOE was unable to increase the efficiency a full NEMA band greater than CSL 4 

and therefore the 30 horsepower Design B representative equipment class does not have a CSL 5.

Figure ES.3.2 NEMA Design B, 30 Horsepower, 4-Pole, Enclosed Frame Motor 

Engineering Analysis Curve

Table ES.3.7 presents the same engineering analysis results in a tabular form, including 

the full-load efficiency values and the MSPs. From CSL 0 through 3, DOE found that the fullload efficiency would increase 4.6 nominal percentage points over the baseline, CSL 0, which 

represents about a 47 percent reduction in motor losses. The increase in MSP to move from CSL 

0 to CSL 3 is $377, or about a 46 percent increase in MSP over CSL 0. Moving from CSL 3 to 

CSL 4 provides a 7 percent reduction in motor losses for a MSP increase of $732 or about a 61

percent MSP increase over CSL 3.

Table ES.3.7 Efficiency and Manufacturer Selling Price Data for the NEMA Design B 

30 Horsepower Motor

CSL Nominal Full-Load Efficiency (%) MSP ($)

0 89.5 827

1 92.4 1,044

2 93.6 1,193

3 94.1 1,204

4 94.5 1,936
11

Table ES.3.8 presents some of the design and performance specifications associated with 

the four 30 horsepower designs presented in Table ES.3.7. 

Table ES.3.8 NEMA Design B 30 Horsepower, 4-Pole, Enclosed Frame Motor 

Characteristics

Parameter Units CSL 0 CSL 1 CSL 2 CSL 3 CSL 4

Efficiency % 89.5 92.4 93.6 94.1 94.5

Line Voltage V 230 460 460 460 460

Full Load Speed RPM 1,755 1,765 1,768 1,770 1,784

Full Load Torque Nm 121.6 121.4 120.8 120.6 119.6

Current A 37 37 36 36 37

Steel - M56 M56/M47 M47 M47 M36

Rotor Conductor Material - Aluminum Aluminum Aluminum Aluminum Copper

Approximate Slot Fill % 48.4 84.0 70.0 70.0 83.2

Stator Wire Gauge AWG 18 17 16 18 18

Stator Copper Weight lbs 20.2 43.5 45.2 47.7 74.5

Rotor Conductor Weight lbs 8.25 9.5 7.5 13.66 42.6

Stack Length In 7.88 5.53 6.00 6.74 7.00

Housing Weight lbs 21 130 131 147 79

NEMA Design B, 75 Horsepower, 4-Pole, Enclosed Frame Motor

Figure ES.3.3 presents the relationship between the MSP and full-load efficiency for the 

75 horsepower, Design B, 4-pole enclosed polyphase motor analyzed. 

Using tear-down results for CSLs 0 through 3, DOE determined that the manufacturer of 

these electric motors increased the stack length and other material amounts to increase the 

electric motor’s efficiency levels from 93.0 percent to 95.8 percent. The torn-down electric 

motor representing CSL 3 used increased rotor aluminum and stator copper as well as an 

increased stack length to achieve 95.8 percent efficiency. To develop CSL 4 and 5, DOE used 

die-cast copper conductors in the rotors and increased the stack lengths for each CSL 4 and 5.

The use of die-cast copper rotors and change from machine winding to hand winding labor hours

account for the larger-than-typical price increases for CSL 4 and 5 when compared to lower 

CSLS for the 75 horsepower Design B representative units.
12

Figure ES.3.3 NEMA Design B, 75 Horsepower, 4-Pole, Enclosed Frame Motor 

Engineering Analysis Curve

Table ES.3.9 presents the same engineering analysis results in a tabular form, including 

the nominal full-load efficiency values and the MSPs. Moving from CSL 0 to CSL 3, DOE found 

that the full-load efficiency would increase 2.8 nominal percentage points over the baseline, CSL 

0, which represents about a 42 percent reduction in motor losses. The increase in MSP to move 

from CSL 0 to CSL 3 is about $748 or about a 41 percent increase in MSP over CSL 0. Moving 

from CSL 3 to CSL 4 provides a 10 percent reduction in motor losses for a MSP increase of 

$772 or about a 30 percent MSP increase over the CSL 3 electric motor, and to increase the 

efficiency from CSL 4 to the max-tech efficiency of CSL 5 there is a 10 percent reduction in 

motor losses for a 11 percent increase in MSP of $359.

Table ES.3.9 Efficiency and Manufacturer Selling Price Data for the NEMA Design B 

75 Horsepower Motor

CSL Nominal Full-Load Efficiency 

(%) MSP ($)

0 93.0 1,833

1 94.1 1,994

2 95.4 2,270

3 95.8 2,581

4 96.2 3,353

5 96.5 3,712
13

Table ES.3.10 presents some of the design and performance specifications associated 

with the six 75-horsepower designs presented in Table ES.3.9. 

Table ES.3.10 NEMA Design B 75 Horsepower, 4-Pole, Enclosed Frame Motor 

Characteristics

Parameter Units CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 CSL 5

Efficiency % 93.0 94.1 95.4 95.8 96.2 96.5

Line Voltage V 460 460 460 460 460 460

Full Load Speed RPM 1,775 1,785 1,781 1,785 1,788 1,789

Full Load Torque Nm 299.8 299.8 302.3 300.8 299.6 299.6

Current A 88 91.8 89.4 88.6 89.8 91.9

Steel - M56 M47 M47 M47 M36 M36

Rotor Conductor 

Material - Aluminum Aluminum Aluminum Aluminum Copper Copper

Approximate Slot 

Fill % 48.0 44.5 70.0 70.0 85.1 83.4

Stator Wire Gauge AWG 17 12 12 15 14 14

Stator Copper 

Weight lbs 77.8 71 82 136 127 160

Rotor Conductor 

Weight lbs 31.0 20.7 27.3 38.5 79 84.3

Stack Length In 8.15 10.23 10.58 11.37 12.00 13.00

Housing Weight lbs 130 79 168 180 190 206

NEMA Design C, 5 Horsepower, 4-Pole, Enclosed Frame Motor

Figure ES.3.3 presents the relationship between the MSP and full-load efficiency for the 

5 horsepower, NEMA Design C, 4-pole enclosed polyphase motor analyzed. DOE purchased one 

NEMA Design C electric motor for a tear-down analysis. The remaining three CSLs were based 

on software modeled motors. To achieve higher efficiency levels, the software modeling expert 

used various combinations of higher grade electrical steel, increased slot fill, increased stack 

length, changed from aluminum to copper die-cast conductors in the rotors. Figure ES.3.4 shows 

the efficiency versus MSP curve for the 5 horsepower NEMA Design C electric motor CSLs.
14

Figure ES.3.4 NEMA Design C, 5 Horsepower, 4-Pole, Enclosed Frame Motor 

Engineering Analysis Curve

Table ES.3.11 presents the same engineering analysis results in a tabular form, including 

the nominal full-load efficiency values and the MSPs. Moving from CSL 0 to CSL 2, DOE found 

that the nominal full-load efficiency would increase 2.7 percentage points over the baseline CSL 

0 which represents a 24 percent reduction in motor losses. The increase in MSP to move from 

CSL 0 to CSL 2 is $198, or about a 61 percent increase in MSP over CSL 0. To increase from 

CSL 2 to CSL 3 would result in a 10 percent reduction in motor losses and a 7 percent increase 

in MSP.

Table ES.3.11 Efficiency and Manufacturer Selling Price Data for the NEMA Design C 5 

Horsepower Motor

CSL Nominal Full-Load Efficiency (%) MSP ($)

0 87.5 324

1 89.5 348

2 90.2 522

3 91.0 559

Table ES.3.12 presents some of the design and performance specifications associated 

with the four Design C 5 horsepower motors presented in Table ES.3.11. 
15

Table ES.3.12 NEMA Design C 5 Horsepower, 4-Pole, Enclosed Frame Motor 

Characteristics

Parameter Units CSL 0 CSL 1 CSL 2 CSL 3

Efficiency % 87.5 89.5 90.2 91.0

Line Voltage V 460 460 460 460

Full Load Speed RPM 1,750 1,762 1,767 1,776

Full Load Torque lb-ft 15 14.9 14.9 14.8

Current A 7.1 8.4 7.1 6.5

Steel - M47 M36 M36 M36

Rotor Conductor Material - Aluminum Aluminum Aluminum Copper

Approximate Slot Fill % 67.9 79.9 83.9 82.9

Stator Wire Gauge AWG 18 18 18 18

Stator Copper Weight lbs 10 9.9 15 12.8

Rotor Conductor Weight lbs 2.2 2.0 2.4 7.8

Stack Length in 4.75 4.25 5.32 5.32

Frame Weight lbs 12 11 14 14

NEMA Design C, 50 Horsepower, 4-Pole, Enclosed Frame Motor

Figure ES.3.5 presents the relationship between the MSP and full-load efficiency for the 

5 horsepower, NEMA Design C, 4-pole enclosed polyphase motor analyzed. DOE purchased 

only one NEMA Design C electric motor for tear-down analysis. The remaining three CSLs were 

based on software modeled motors. To achieve higher efficiency levels, the software modeling 

expert used various combinations of higher grade electrical steel, increased slot fill, increased 

stack length, and copper rotors. Figure ES.3.5 shows the efficiency versus MSP curve for the 50 

horsepower NEMA Design C electric motor CSLs.
16

Figure ES.3.5 NEMA Design C, 50 Horsepower, 4-Pole, Enclosed Frame Motor 

Engineering Analysis Curve

Table ES.3.13 presents the same engineering analysis results in a tabular form, including 

the nominal full-load efficiency values and the MSPs. Moving from CSL 0 to CSL 2, DOE found 

that the nominal full-load efficiency would increase 1.5 nominal percentage points over the 

baseline, CSL 0, which represents about a 23 percent reduction in motor losses. The increase in 

MSP to move from CSL 0 to CSL 2 is $540, or about a 37 percent increase in MSP over CSL 0. 

To increase from CSL 2 to CSL 3, a 10 percent reduction in motor losses, results in an 8.8 

percent increase in MSP.

Table ES.3.13 Efficiency and Manufacturer Selling Price Data for the NEMA Design C 

50 Horsepower Motor

CSL Nominal Full-Load Efficiency (%) MSP ($)

0 93.0 1,452

1 94.1 1,664

2 94.5 1,992

3 95.0 2,168

Table ES.3.14 presents some of the design and performance specifications associated 

with the four 50 horsepower electric motor designs presented in Table ES.3.13. 
17

Table ES.3.14 NEMA Design C 50 Horsepower, 4-Pole, Enclosed Frame Motor 

Characteristics

Parameter Units CSL 0 CSL 1 CSL 2 CSL 3

Efficiency % 93.0 94.1 94.5 95.0

Line Voltage V 460 460 460 460

Full Load Speed RPM 1,770 1,775 1,775 1,782

Full Load Torque lb-ft 148 148 148 147.3

Current A 59.4 63.9 63.7 61.3

Steel - M47 M36 M36 M19

Rotor Conductor Material - Aluminum Aluminum Aluminum Copper

Approximate Slot Fill % 79.6 74.8 85.3 81.3

Stator Wire Gauge AWG 17 17 17 17

Stator Copper Weight lbs 66 78 90 85

Rotor Conductor Weight lbs 16.5 11 11 36.6

Stack Length In 8.67 9.55 9.55 9.55

Frame Weight lbs 125 138 138 138

ES.3.4 Markups Analysis

The markups analysis (chapter 6 of the preliminary TSD) develops appropriate markups 

in the distribution chain to convert the estimates of manufacturer cost derived in the engineering 

analysis to installed prices for medium electric motors. The engineering analysis (chapter 5 of 

the preliminary TSD) identifies eight representative units and develops the MSP for each. The

eight representative units are evaluated in the LCC analysis (chapter 8 of the preliminary TSD). 

DOE derived a set of prices for each representative unit by applying markups to the MSP. Those 

markups represent all the costs associated with bringing a manufactured motor into service as an 

installed piece of electrical equipment at a customer’s site.

For medium electric motors (those built in a three-digit frame number series), DOE 

defined six distribution channels and estimated their respective shares of shipments. The six 

channels are:

(1) from manufacturers to original equipment manufacturers (OEMs) and then to endusers (50 percent of shipments); 

(2) from manufacturers to distributors and then to end-users (24 percent of 

shipments);

(3) from manufacturers to distributors to OEMs and then to end-users (23 percent of 

shipments); 

(4) from manufacturers to end-users through contractors (less than 1 percent of 

shipments); 

(5) from manufacturers to distributors to contractors and then to end-users (less than 

1 percent of shipments); and 

(6) directly to end-users (less than 2 percent of shipments).
18

Table ES.3.15 summarizes the markups at each stage in the distribution channel and the 

overall baseline and incremental markups, as well as sales taxes, for each of the primary 

channels (see items 1 through 3 above). 

Table ES.3.15 Summary of Markups for the Three Primary Distribution Channels for 

Medium Electric Motors

Markup

OEM to End-User 

(50%)

Distributor to End-User 

(24%)

Distributor to OEM to 

End-User (23 %)

Baseline Incremental Baseline Incremental Baseline Incremental

Distributor - - 1.35 1.20 1.35 1.20

OEM 1.44 1.39 - - 1.44 1.39

Contractor/Installer - - - - - -

Sales Tax 1.0712 1.0712 1.0712 1.0712 1.0712 1.0712

Overall 1.54 1.49 1.45 1.29 2.08 1.79

Weighting the markups in all six channels by each channel’s share of shipments yields an 

average overall baseline markup of 1.63 and an overall incremental markup of 1.50. DOE used 

those markups for each equipment class. Applying the markups, DOE generated end-user motor 

prices for each efficiency level it considered, assuming that each level represents a new 

minimum efficiency standard. 

ES.3.5 Energy Use Characterization

The energy use characterization (chapter 7 of the preliminary TSD) produces energy use 

estimates for electric motors. Those estimates enable DOE to evaluate the energy savings from 

the operation of electric motors at the efficiency levels associated with amended efficiency 

standards. The energy use characterization provides the basis for developing the energy savings 

used in the LCC and subsequent analyses.

The energy use by electric motors equals the end-use load plus any energy losses 

associated with motor operation. Energy use is derived from three components: useful 

mechanical shaft power, motor losses, and reactive power.b Motor losses consist of I2

R 

(resistance heat) losses, core losses, stray-load losses, and friction and windage losses. For a 

motor having a given nominal efficiency, the annual energy consumption depends on the motor’s 

annual operating hours and loading, which are determined by the motor’s sector (industry, 

agriculture, and commercial) and application (compressor, fans, pumps, material handling and 

processing, fire pumps, and others).

DOE developed estimates of motor losses and reactive power at full load and part-load 

for various nominal efficiency levels based on estimates of the specific motor designs that it 

 b In an alternating current power system, the reactive power is the root mean square (RMS) voltage multiplied by the 

RMS current, multiplied by the sine of the phase difference between the voltage and the current. Reactive power 

occurs when the inductance or capacitance of the load shifts the phase of the voltage relative to the phase of the 

current. Although reactive power does not itself consume energy, it can increase losses and costs for the electricity 

distribution system. Motors tend to create reactive power because the windings in the motor coils have high 

inductance.
19

developed in the engineering analysis. DOE then characterized the energy use of motors within 

horsepower ranges according to the end-use sector and application. Motor distribution across 

sectors varied depending on a motor’s horsepower range. Motor distribution across applications 

varied depending on the motor’s horsepower range and equipment class group.

Table ES.3.16 shows the results of the energy use analysis for the eight representative 

units at each considered energy efficiency level. Results are given for baseline units (CSL 0) and 

the additional candidate standard levels (CSLs) being considered. Chapter 7 provides greater 

detail regarding the methods, data, and assumptions used for the energy use analysis.

Table ES.3.16 Average Annual Energy Consumption by Efficiency Level for 

Representative Units 

ES.3.6 Life-Cycle Cost and Payback Period Analysis

New and amended equipment standards result in changes in customer operating expenses 

(usually a decrease) and changes in initial customer price (usually an increase). DOE performed 

the LCC analysis to evaluate the net effect of new and amended standards on customers based on 

the cost-efficiency relationship derived from the engineering analysis, as well as the energy costs 

derived from the energy use characterization. Inputs to the LCC calculation include the installed 

cost to the customer (purchase price plus installation cost), operating costs (primarily energy 

expenses), expected lifetime of the equipment, and discount rate.

Because the installed cost of equipment typically increases while operating costs 

typically decrease in response to new or amended standards, there is a period when the net

Representative 

Unit Description kilowatt-hours per year

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 CSL 5

1

Design B, Tframe, 5 hp, 4 

poles, enclosed

10,448 9,869 9,691 9,616 9,567 9,487 

2

Design B, Tframe, 30 hp, 4 

poles, enclosed

57,642 55,912 55,021 54,492 54,326 -

3

Design B, Tframe, 75 hp, 4 

poles, enclosed

204,834 202,540 198,496 197,697 197,194 196,604 

4

Design C, Tframe, 5 hp, 4 

poles, enclosed

9,987 9,808 9,738 9,630 - -

5

Design C, Tframe, 50 hp, 4 

poles, enclosed

89,523 88,507 88,119 87,444 - -

6 Fire pump, 5 hp, 4 

poles, enclosed 19.6 19.2 19.1 19.0 18.8 -

7 Fire pump, 30 hp, 

4 poles, enclosed 1,601 1,577 1,562 1,558 - -

8 Fire pump, 75 hp, 

4 poles, enclosed 97,791 95,934 95,554 95,313 95,033 -
20

operating-cost benefit (in dollars) since the time of purchase of the more efficient equipment 

equals the incremental first cost of purchasing the higher efficiency unit. The length of time 

required for equipment to reach this cost-equivalence point is known as the PBP.

DOE conducted the LCC and PBP analysis using Monte Carlo simulation methods and 

probability distributions to model both the uncertainty and variability in the inputs. Inputs to the 

LCC and PBP analysis are:

• motor application and sector

• annual energy use,

• electricity prices and price trends,

• operating hours,

• motor lifetime,

• motor efficiency, and

• a discount rate.

These variables, and the interactions among them, are discussed in the following 

paragraphs.

DOE characterized a set of end-use applications for electric motors that determine motor 

use profiles. In each Monte Carlo simulation, one application is identified by sampling a 

distribution of applications for each equipment class. The selected application determines the 

number of operating hours per year as well as the motor loading (i.e. output power as a 

percentage of rated power). DOE used the operating hours and the motor loading for each 

application to estimate motor energy use.

For electricity prices, DOE derived sector-specific average electricity prices for four 

census regions (Northeast, Midwest, South, and West) using data from the Energy Information 

Administration (EIA Form 861). For each sector, DOE assigned electricity prices using a Monte 

Carlo approach that incorporated weightings based on the estimated number of motors in each 

region. The regional quantities were derived based on indicators specific to each sector (e.g., for 

industry, the value of shipments by census region from the Manufacturing Energy Consumption 

Survey). To estimate future trends in energy prices, DOE used projections from the EIA’s 

Annual Energy Outlook 2011 (AEO 2011). 

Because of the wide range of applications and motor use characteristics considered in the 

LCC and PBP analysis, the range of annual energy use is quite broad. Although the annual 

energy use and/or energy pricing are generally known for a given application, the variability 

across all applications contributes to the range of LCCs and PBPs calculated for any particular 

CSL. There is also an energy use and/or energy pricing distribution between the sectors 

(industry, agriculture, and commercial) associated with each application. The sector to which an

application belongs determines the energy price and discount rate DOE used in each simulation 

performed for calculating the LCC.
21

DOE estimated the mechanical lifetime of motors in hours (i.e., the total number of hours 

a motor operates throughout its lifetime, including repairs) depending on its horsepower (hp) 

size. DOE then developed Weibull distributions of mechanical lifetimes. (Weibull distributions 

are statistical models used to predict the likelihood of failure over time.) The lifetime in years 

for a sampled motor was calculated by dividing the sampled mechanical lifetime by the sampled 

annual operating hours of the motor. This model produces a negative correlation between annual 

hours of operation and motor lifetime: motors operated many hours per year are likely to be 

retired sooner than motors that are used for only a few hundred hours per year. DOE considered 

that motors of less than 75 hp are most likely to be embedded in another piece of equipment (i.e., 

an application). For such applications DOE developed Weibull distributions of application 

lifetimes expressed in years, then compared the sampled mechanical lifetime (in years) with the 

sampled application lifetime. DOE assumed that the motor would be retired at the younger of the 

two ages.

DOE made several assumptions regarding motor repair based on stakeholder inputs and 

on information found in the literature. First, DOE assumed that NEMA Design A, B and C 

medium electric motors are repaired on average after 32,000 hours of operationc

,and that repair 

costs vary depending on motor size, configuration, and efficiency. Second, DOE assumed that 

one-third of repairs are performed competently and according to recommended practice as 

defined by the Electrical Apparatus Service Associationd and therefore do not adversely affect 

the efficiency of the motor (i.e., there is no degradation of efficiency after repair). Third, DOE 

assumed that the remaining two-thirds of repairs are not performed in a similar manner and result 

in a slight decrease in efficiency. Finally, DOE assumed the efficiency drops by 1 percent in the 

case of motors of less than 40 hp, and by 0.5 percent in the case of larger motors. 

For each representative unit, DOE developed a projection of base case (no amended 

standards) efficiency distribution in 2015. DOE based the projection on the percentage of models 

at different levels using recent manufacturer catalogs. Applying the base case distribution of 

equipment efficiencies for each representative unit, DOE randomly assigned an equipment 

efficiency to each unit based on the market share. If a motor was assigned an equipment 

efficiency greater than or equal to the efficiency of the CSL under consideration, the LCC 

calculation would show that the motor unit would not be affected by that standard level.

ES.3.6.1 Results of Life-Cycle Cost and Payback Period Analysis

Table ES.3.17 describes the eight representative units that DOE analyzed. The 

engineering analysis examined units 1 through 5, but did not directly analyze fire pump electric 

motors. Instead, the engineering outputs for representative units 1, 2, and 3 were assumed to also 

be valid to characterize representative units 6, 7, and 8.

 c Based on the annual operating hours by sector and application, this corresponds, on average, to a repair frequency 

of 5, 16, and 15 years in the industrial, commercial and agricultural sectors, respectively. 

d Good practice in motor repair is defined in the joint EASA AEMT study at 

http://www.easa.com/sites/default/files/rwstdy1203.pdf
22

Table ES.3.17 Representative Units for Preliminary Analysis

Representative 

Unit

Equipment Class 

Group Specifications Horsepower

1

NEMA Designs

A & B

Design B, T-frame, enclosed, 

4-pole

5

2 30

3 75

4

NEMA Design C Design C, T-frame, enclosed, 

4-pole

5

5 50

6

Fire Pump Uses same engineering 

outputs as units 1, 2, and 3

5

7 30

8 75

Table ES.3.18 through Table ES.3.25 present key findings from the LCC and PBP 

analysis performed for this preliminary TSD. Most of the values in the tables are average or 

median values, although the tables also show the percentage of end-users expected to experience

a net cost (negative LCC savings) or net benefit (positive LCC savings) at each CSL. The 

average LCC savings are calculated relative to a base case efficiency distribution. Chapter 8 of 

the preliminary TSD presents distributions of LCC and PBP results for each representative unit

analyzed.

For representative unit 1 (Table ES.3.18), the highest CSL that provides positive average 

LCC savings is CSL 3. DOE estimates that 67.8 percent of end-users would experience a net 

benefit (i.e., LCC decrease) at this CSL and that the increase in average total installed cost 

(relative to the base case) would be $81, or a 13.9 percent increase, while operating costs 

decrease by $46, or a 4.6 percent decrease.

Table ES.3.18 Life-Cycle Cost and Payback Period Results for Representative Unit 1: 

NEMA Design B, T-Frame, 5 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost 

%

Net 

Benefit 

%

0 82.5 584 1,006 5,926

1 87.5 588 969 5,649 16 0.1 5.8 0.1

2 89.5 651 963 5,631 25 18.9 26.4 5.1

3 90.2 665 960 5,608 45 20.5 67.8 4.7

4 91.0 909 960 5,831 -169 89.3 6.5 28.2

5 91.7 998 958 5,883 -220 93.3 5.4 26.9
23

For representative unit 2 (Table ES.3.19), the highest CSL that provides positive average 

LCC savings is CSL 3. DOE estimates that 86.6 percent of end-users would experience a net 

benefit (i.e., LCC decrease) at this CSL and that the increase in average total installed cost 

(relative to the base case) is $718, or a 45.7 percent increase, while operating costs decrease by 

$234, or a 4.3 percent decrease.

Table ES.3.19 Life-Cycle Cost and Payback Period Results for Representative Unit 2: 

NEMA Design B, T-Frame, 30 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 89.5 1,570 5,489 44,182

1 92.4 1,986 5,358 43,376 45 0.6 4.9 3.5

2 93.6 2,277 5,295 43,035 177 5.7 32.9 5.3

3 94.1 2,288 5,255 42,666 511 4.0 86.6 0.7

4 94.5 3,468 5,249 43,735 -558 87.1 12.9 23.8

For representative unit 3 (Table ES.3.20), the highest CSL that provides positive average 

LCC savings is CSL 3. DOE estimates that 47.5 percent of end-users would experience a net 

benefit (i.e., LCC decrease) at this CSL and that the increase in average total installed cost 

(relative to the base case) is $1,313, or a 37.9 percent increase, while operating costs decrease by 

$481, or a 2.8 percent decrease.

Table ES.3.20 Life-Cycle Cost and Payback Period Results for Representative Unit 3: 

NEMA Design B, T-Frame, 75 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 93.0 3,463 17,168 124,170

1 94.1 3,831 17,033 123,348 40 0.8 4.5 2.9

2 95.4 4,296 16,733 121,510 663 1.4 32.9 1.5

3 95.8 4,776 16,687 121,590 597 35.1 47.5 6.5

4 96.2 6,044 16,661 122,598 -340 66.9 25.9 15.5

5 96.5 6,640 16,631 122,905 -639 73.6 23.7 16.0

For representative unit 4 (Table ES.3.21), the highest CSL that provides positive average 

LCC savings is CSL 1. DOE estimates that 59.9 percent of end-users would experience a net 
24

benefit (i.e., LCC decrease) at this CSL and that the increase in average total installed cost 

(relative to the base case) is $44, or a 7.5 percent increase, while operating costs decrease by 

$10, or a 1.0 percent decrease. 

Table ES.3.21 Life-Cycle Cost and Payback Period Results for Representative Unit 4: 

NEMA Design C, T-Frame, 5 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 87.5 583 984 5,807

1 89.5 627 974 5,771 34 32.3 59.9 4.6

2 90.2 903 971 6,007 -203 97.8 2.2 25.0

3 91.0 961 966 6,011 -207 95.6 4.4 20.2

For representative unit 5 (Table ES.3.22), the highest CSL that provides positive average 

LCC savings is CSL 3. DOE estimates that 57.8 percent of end-users would experience a net 

benefit (i.e., LCC decrease) at this CSL and that the increase in average total installed cost 

(relative to the base case) is $1164, or a 41.8 percent increase, while operating costs decrease by 

$150, or a 1.8 percent decrease. 

Table ES.3.22 Life-Cycle Cost and Payback Period Results for Representative Unit 5: 

NEMA Design C, T-Frame, 50 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 93.0 2,786 8,459 69,419

1 94.1 3,173 8,383 69,098 236 18.3 55.6 5.9

2 94.5 3,673 8,360 69,329 5 59.6 40.4 12.7

3 95.0 3,950 8,309 69,104 229 42.3 57.8 9.8

For representative unit 6 (Table ES.3.23), all CSLs other than the baseline result in 

negative average LCC savings.
25

Table ES.3.23 Life-Cycle Cost and Payback Period Results for Representative Unit 6: Fire 

Pump, NEMA Design B, T-Frame, 5 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 87.5 588 106 632

1 89.5 651 115 697 -62 95.1 0.0 NA

2 90.2 665 119 706 -70 99.9 0.1 NA

3 91.0 909 124 949 -314 100.0 0.0 NA

4 91.7 998 128 1,038 -403 100.0 0.0 NA

For representative unit 7 (Table ES.3.24), all CSLs other than the baseline result in 

negative average LCC savings.

Table ES.3.24 Life-Cycle Cost and Payback Period Results for Representative Unit 7: Fire 

Pump, NEMA Design B, T-Frame, 30 Horsepower, 4-Pole, Enclosed Motor 

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 92.4 1,986 347 3,869

1 93.6 2,277 363 4,131 -213 78.8 2.5 104.9

2 94.1 2,288 371 4,124 -207 78.7 8.1 79.2

3 94.5 3,468 380 5,295 -1,378 100.0 0.0 433.6

For representative unit 8 (Table ES.3.25), the highest CSL that provides positive average 

LCC savings is CSL 3. DOE estimates that 27.0 percent of end-users would experience a net 

benefit (i.e., LCC decrease) at this CSL and that the increase in average total installed cost 

(relative to the base case) is 2,213, or a 57.8 percent increase, while operating costs decrease by 

$126, or a 1.6 percent decrease. 
26

Table ES.3.25 Life-Cycle Cost and Payback Period Results for Representative Unit 8: Fire 

Pump, NEMA Design B, T-Frame, 75 Horsepower, 4-Pole, Enclosed Motor

Candidate 

Standard 

Level

Efficiency 

%

Life-Cycle Cost Life-Cycle Cost Savings

Payback 

Period 

years

Average 

Installed 

Price $

Average 

Annual 

Operating 

Cost $

Average 

LCC $

Average 

Savings 

$

Customers with

Median

Net 

Cost

%

Net 

Benefit

%

0 94.1 3,831 8,050 110,032

1 95.4 4,296 7,937 108,445 1,274 55.4 25.3 1.1

2 95.8 4,776 7,927 108,544 1,193 56.7 26.0 1.9

3 96.2 6,044 7,924 109,522 215 73.0 27.0 4.5

4 96.5 6,640 7,920 109,826 -89 72.0 28.0 5.3

Chapter 8 of the preliminary TSD provides more details on the methods, data, and 

assumptions used for the LCC and PBP analyses

ES.3.7 Shipments Analysis

An important component of any estimate of future impacts from energy efficiency 

standards is equipment shipments (chapter 9). DOE uses projections of shipments for the base 

case and each potential standards case as inputs to the calculation of national energy savings 

(NES). 

DOE used motor shipment data from multiple sourcese to develop a set of shipment 

projections for all motors by horsepower covered by the rulemaking. The shipments represent the 

sum of U.S. production and imports minus exports and include motors imported as part of larger 

equipment. DOE then used estimates of market distributions to redistribute the shipments across 

pole configurations and enclosures to provide shipment values for each electric motor equipment 

class and sector. 

DOE’s shipments projection assumes that motor sales are driven by machinery 

production growth for equipment including motors. DOE assumed that growth rates for motor 

shipments correlate to growth rates in fixed investment in equipment and structuresf including 

motors, as provided by the U.S. Bureau of Economic Analysis’s (BEA)g

 e DOE based its shipments estimates on the following sources of data: market research report (IMS Research 

(February 2012), The World Market for Low Voltage Motors, 2012 Edition, Austin), stakeholder inputs, and 

responses to the Request for Information (RFI) published in the Federal Register (76 FR 17577 (March 30, 2011)).

. This correlation was 

developed based on historical data on growth rates for motor shipments and fixed investment 

f Heating, ventilation, and air conditioning (HVAC) equipment which incorporates motors is typically included in 

“structures” and not in equipment.

g Bureau of Economic Analysis (March 01, 2012), Private Fixed Investment in Equipment and Software and 

structure by Type. http://www.bea.gov/iTable/iTable.cfm?ReqID=12&step=1
27

data. Additional data on “real gross domestic product” (GDP) from AEO2011 for 2011–2035 

was used to project fixed investments in the selected equipment and structures.

Table ES.3.26 presents DOE’s estimate of projected shipments of electric motors

following an AEO reference growth case. Additional detail on the shipments analysis, as well as 

alternate AEO growth cases can be found in chapter 9 of the preliminary TSD.

Table ES.3.26 Annual and Cumulative Shipments Projection for Electric Motors (AEO 

reference case)

Annual Shipments thousands

Equipment 

Class Group 2015 2025 2035 2044 Cumulative 2015–2044

Designs A & B 5,072 7,254 9,958 13,005 256,846

Design C 10 15 20 26 515

Fire Pump 6 9 12 16 309

Total* 5,089 7,278 9,990 13,047 257,671

*Total may not precisely match the sum of all numbers in the column due to rounding.

Chapter 9 of the preliminary TSD provides more details on the methods, data, and 

assumptions used for the shipments analysis.

ES.3.8 National Impact Analysis

The national impact analysis (NIA) quantifies the following national impacts from CSLs: 

(1) NES, (2) monetary value of the energy savings attributable to new or amended standards, (3) 

increased total installed costs of the considered equipment due to new or amended standards, and 

(4) NPV of energy savings (difference between value of energy savings and increased total 

installed costs). DOE prepared a spreadsheet model to project energy savings and national 

customer economic costs and savings resulting from potential new standards. 

The cumulative NES and NPV are calculated by equipment class. Results are calculated 

by sector for each equipment class. These results are then aggregated across sectors using 

weighted averages. DOE used weighted average operating hours and loading data across motor 

applications in each sector, and assigned a range in lifetime data by horsepower based on usage 

data from the energy use characterization (chapter 7).

For each equipment class that was not directly analyzed in the engineering analysis and 

the LCC, DOE specified CSLs using scaled, full-load, nominal efficiency data from the 

engineering analysis. Adjustment factors were derived from the engineering analysis to estimate 

part-load nominal efficiencies. Further, relationships were developed to estimate MSP data for 

all equipment classes. The relationships were derived from analyzing how listed prices in six

manufacturers and distributors catalogs vary depending on horsepower, poles, and enclosures at 

a given efficiency level. A similar method, based on advertised weights in catalog listings, was 

used to estimate weights for all equipment classes as a necessary input to shipping costs. 
28

ES.3.8.1 Analysis of National Energy Savings

DOE calculated cumulative NES for motors shipped in the analysis period, 2015-2044 as 

the difference between the cumulative national energy consumption in the base case (without 

new or amended energy conservation standards) and under each CSL. In the base case, DOE 

estimated a distribution of equipment efficiencies for each equipment class and assumed this 

distribution remained constant throughout the analysis period. In the standards case, DOE used a 

roll-up scenario to determine the distribution of equipment efficiencies at each CSL.

DOE estimated cumulative energy consumption and savings based on site energy, and 

then converted those values to primary (source) energy using factors that account for losses in 

transmission, distribution, and generation of electricity. 

DOE estimated energy consumption and savings based on site energy and converted the 

site energy values to primary (source) energy using factors that account for losses in transmission 

and distribution and in electricity generation. These site-to-source factors are derived from the 

National Energy Modeling System (NEMS). DOE also estimated full-fuel-cycle (FFC) energy 

savings for each CSL. The full-fuel-cycle measure includes the energy consumed in extracting, 

processing, and transporting primary fuels.

Table ES.3.27 summarizes results of the NES for each of the three equipment class 

groups by horsepower range. NES results are given in quadrillion British thermal units (quads). 
29

Table ES.3.27 Summary of Cumulative National Energy Savings in Quads (2015-2044)

Motor 

Size hp All 1-5 6-20 21-50 51-100 101-200 201-500

Designs A & B

CSL 1 0.972 0.270 0.284 0.161 0.108 0.078 0.071

CSL 2 4.414 0.954 1.211 0.668 0.527 0.410 0.644

CSL 3 7.527 1.509 1.980 1.179 0.937 0.831 1.090

CSL 4 10.836 2.123 2.855 1.704 1.378 1.265 1.511

CSL 5 13.005 2.701 3.201 1.704 1.789 1.680 1.929

Design C

CSL 1 0.012 0.003 0.004 0.002 0.001 0.001 -

CSL 2 0.018 0.004 0.006 0.003 0.002 0.002 -

CSL 3 0.024 0.006 0.008 0.004 0.003 0.003 -

Fire Pumps

CSL 1 0.003 0.000 0.000 0.000 0.001 0.001 0.001

CSL 2 0.005 0.000 0.000 0.000 0.002 0.001 0.001

CSL 3 0.006 0.000 0.000 0.000 0.002 0.002 0.002

CSL 4 0.008 0.000 0.000 0.000 0.003 0.002 0.002

ES.3.8.2 Analysis of Consumer Net Present Value

DOE calculated net monetary savings each year as the difference between total savings in 

operating costs and increases in total equipment costs in the base case and each CSL. DOE 

calculated savings over the life of the equipment purchased during the analysis period. The NPV 

is the difference between the present value of operating cost savings and the present value of 

increased total installed costs. DOE used discount rates of 7 percent and 3 percent to discount 

future costs and savings to the present.

Table ES.3.28 summarizes NPV results for each of the three equipment class groups by 

horsepower range.
30

Table ES.3.28 Net Present Value of Customer Impacts (billion 2011$)

Discount 

Rate %

All 

hp

1-5 

hp

6-21 

hp

21-50 

hp

51-100 

hp

101-200 

hp

201-500 

hp

Designs A & B

CSL 1 3 5.53 1.67 1.78 0.94 0.54 0.35 0.25

7 2.32 0.73 0.76 0.38 0.22 0.13 0.09

CSL 2 3 18.42 3.57 5.52 2.98 2.27 1.68 2.41

7 7.07 1.39 2.15 1.13 0.90 0.63 0.87

CSL 3 3 30.19 5.65 8.50 4.91 3.71 3.25 4.16

7 11.42 2.24 3.25 1.80 1.43 1.20 1.50

CSL 4 3 -6.63 -6.29 -4.67 -1.32 0.57 1.73 3.34

7 -10.37 -4.47 -4.37 -1.90 -0.50 0.10 0.77

CSL 5 3 -8.63 -8.81 -5.92 -1.32 0.64 2.38 4.40

7 -12.71 -6.09 -5.26 -1.90 -0.70 0.19 1.05

Design C

CSL 1 3 0.05 0.01 0.02 0.01 0.00 0.00 -

7 0.02 0.01 0.01 0.00 0.00 0.00 -

CSL 2 3 0.01 -0.01 0.00 0.01 0.01 0.01 -

7 -0.01 -0.01 0.00 0.00 0.00 0.00 -

CSL 3 3 0.02 -0.01 0.00 0.01 0.01 0.01 -

7 -0.01 -0.01 0.00 0.00 0.00 0.00 -

Fire Pumps

CSL 1 3 -0.02 -0.01 -0.01 0.00 0.00 0.00 0.00

7 -0.01 0.00 0.00 0.00 0.00 0.00 0.00

CSL 2 3 -0.03 -0.02 -0.01 -0.01 0.00 0.00 0.00

7 -0.01 -0.01 -0.01 0.00 0.00 0.00 0.00

CSL 3 3 -0.10 -0.04 -0.04 -0.02 0.00 0.00 0.00

7 -0.05 -0.02 -0.02 -0.01 0.00 0.00 0.00

CSL 4 3 -0.11 -0.05 -0.05 -0.02 0.00 0.00 0.00

7 -0.06 -0.02 -0.02 -0.01 0.00 0.00 0.00

Table ES.3.29 summarizes both NES and NPV results for each of the three equipment 

class groups. 
31

Table ES.3.29 Cumulative National Energy Savings and Net Present Value Results

Equipment Group and 

Analysis

Discount 

Rate %

Candidate Standard Level

1 2 3 4 5

Designs A & B

Cumulative Source 

Savings 2015–2044 quads 0.97 4.41 7.53 10.84 13.00

Net Present Value billion 

2011$

3 5.53 18.42 30.19 -6.63 -8.63

7 2.32 7.07 11.42 -10.37 -12.71

Design C

Cumulative Source 

Savings 2015–2044 quads 0.01 0.02 0.02 - -

Net Present Value billion 

2011$

3 0.05 0.01 0.02 - -

7 0.02 -0.01 -0.01 - -

Fire Pumps

Cumulative Source 

Savings 2015–2044 quads 0.00 0.00 0.01 0.01 -

Net Present Value billion 

2011$

3 -0.02 -0.03 -0.10 -0.11 -

7 -0.01 -0.01 -0.05 -0.06 -

Chapter 10 of the preliminary TSD provides more details on the methods, data, and 

assumptions used for the NIA analyses.

ES.3.9 Preliminary Manufacturer Impact Analysis

The preliminary MIA focuses on manufacturers of electric motors. Potential impacts 

include financial effects, both quantitative and qualitative, that might result from new energy 

conservation standards and consequently lead to changes in the manufacturing practices for 

electric motors. DOE identified these potential impacts through interviews with manufacturers 

and interested parties, as well as through the gathering of publicly available data on products, 

methods, and practices used in the electric motors industry. 

Next, DOE determined how energy efficiency improvements affect cost, production, and 

various other manufacturing metrics. 

Finally, DOE interviewed manufacturers for feedback. DOE developed a questionnaire 

and distributed it for use during the interviews. Highlights of the questionnaire and topics of 

focus include production and product mix, compliance costs, exports, foreign competition and 

outsourcing, market shares and industry consolidation, and cumulative burden.

Perhaps the most important aspect of the preliminary MIA is the opportunity to identify 

key manufacturer issues early in the development of new standards. During the series of 

preliminary interviews with manufacturers, DOE assessed concerns about the potential impact of 

a regulatory standard for electric motors. In general, manufacturers identified three major issues 
32

of concern: (1) capital expenditure to retool in response to the standards, (2) maintaining product 

availability and consumer-oriented features, and (3) enforcement of the new standards.

ES.3.10 Other Analyses

The remaining chapters of the preliminary TSD address the analyses to be performed for 

the notice of proposed rulemaking (NOPR). 

• The customer subgroup analysis evaluates the effects of potential new or amended 

energy conservation standards on various subgroups (chapter 11).

• The employment impact analysis examines the effects of potential new or amended 

energy conservation standards on national employment (chapter 13).

• The utility impact analysis examines impacts of potential new or amended energy 

conservation standards on the generation capacity of electric utilities (chapter 14).

• The emissions analysis examines the effects of potential new or amended energy 

conservation standards on various airborne emissions (chapter 15)

• The monetization of emission reduction benefits examines the monetary value of 

benefits resulting from reduced emissions associated with potential new or amended 

standards (chapter 16).

• The regulatory impact analysis examines the national impacts of nonregulatory 

alternatives to mandatory energy conservation standards (chapter 17).

ES.4 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT 

DOE is interested in receiving comments on all aspects of the preliminary analyses 

described in this TSD. DOE especially invites comments or data to improve DOE’s analyses, 

including information that will respond to the following questions and concerns that were raised 

during DOE’s preliminary interviews with manufacturers and in the preparation of this 

preliminary TSD. 

ES.4.1 Scope of Coverage of Electric Motors

DOE invites comments on the scope of motors covered as part of this analysis. Chapter 2 

of this TSD presents a list of general purpose motors without energy conservation standards 

prescribed under EISA 2007 or DOE regulations. These motors generally bear no 

electromechanical differences from those general purpose motors that are currently regulated. 

Because of the close similarity between these two sets of motors, DOE tentatively concludes that 

these currently unregulated motors can achieve the same standards as equipment class group 1 or 

equipment class group 2 if manufacturers use similar tooling. Refer to chapter 3 of the 

preliminary TSD for more information on the motors DOE is considering. 
33

ES.4.2 Screening Analysis

DOE invites comments on the two technology options that were screened out of the

analysis: plastic bonded iron powder and amorphous core steels for electric motors. Please refer 

to section 2.4.1 of chapter 2 of the preliminary TSD.

ES.4.3 Engineering Analysis Methodology

DOE invites comments on the methodology followed for the preliminary TSD, namely 

use of engineering software to design more efficient versions of the five representative units 

analyzed. DOE is also interested in comments on the estimated manufacturer markups and labor 

rates that enable the conversion of input costs to selling prices. Please refer to chapter 5 of the 

preliminary TSD for more detailed information on material prices and markups used.

ES.4.4 Engineering Analysis Results

DOE invites comments on the findings of the engineering analysis. Specifically, DOE 

requests comment on the derived MSP for its respective motor rating.

ES.4.5 Motor Distribution Across Sectors

DOE seeks comment on any additional sources of data that could be used to establish the 

distribution of motors across sectors by horsepower range.

ES.4.6 Motor Distribution Across Applications

DOE seeks comment on any additional sources of data that could be used to establish the 

sector-specific distribution of motors across applications. In its preliminary analysis, DOE 

assumed that the share of motors in each application is similar across all sectors and equal to the 

distribution of motors across applications in the industry sector.

ES.4.7 Data on Operating Hours and Loading

DOE seeks comment on any additional sources of field data on operating hours and 

loading for motors, that could be used to improve field use characterization in the commercial 

and agricultural sectors. 

ES.4.8 Product Price Determination

DOE derived the product prices cited in this TSD by applying markups to the MSP it 

determined in the engineering analysis. DOE defined six distribution channels and estimated 

each one’s share of shipments. DOE calculated an average overall baseline markup and an 

overall incremental markup by weighting the markups in all six channels by each channel’s share 

of shipments. DOE requests stakeholder input regarding any viable alternative approach or

source of information that could be used to develop product prices.
34

ES.4.9 Repair Costs

DOE welcomes comment on the current method used to determine motor repair costs.

ES.4.10 Frequency of Repair

DOE seeks comment on any additional sources for determining the frequency of motor 

repair depending on equipment class, sector, and application. 

ES.4.11 Maintenance Costs

DOE seeks comment on any additional sources of data on motor maintenance costs. 

Specifically, DOE invites comment on how amended efficiency requirements may affect 

maintenance costs. 

ES.4.12 Installation Costs

For the engineering analysis performed for the NOPR, DOE will consider technology 

options that could affect a motor’s mechanical configuration. DOE invites comment on how

changes in motor mechanical configurations that may accompany more efficient motors may 

affect installation costs. 

ES.4.13 Motor Lifetimes

DOE seeks comment on any additional sources of data on motor lifetime that could be 

used to validate DOE’s estimates of motor mechanical lifetime and its method of estimating 

lifetimes.

ES.4.14 Product Energy Efficiency in the Base Case

For the LCC analysis, DOE analyzed CSLs relative to a base case. This analysis requires 

estimating the distribution of product efficiencies in the base case (i.e., what customers would 

purchase in 2015 in the absence of new standards). For the preliminary TSD, the distribution of 

product efficiencies that DOE estimated in the base case was based on nominal efficiency data 

collected from six major manufacturer catalogs. DOE seeks comment on the estimated base case 

distribution of product efficiencies and on any additional sources of data. 

ES.4.15 Efficiency Trends

DOE seeks further comment on its decision to use constant efficiencies for the analysis 

period. Specifically, DOE would like comments on additional sources of data on trends in 

efficiency improvement.

ES.4.16 Estimated Shipments

DOE seeks comment on any additional sources of data on motor shipments that could be 

used to validate its shipments model and estimates.
35

ES.4.17 Purchase Price Elasticity

If the installed cost of electric motors increases, end-users could decide to repair or 

rewind motors instead of purchasing new ones, thereby reducing purchases of new motors. 

DOE, however, has found no data that would enable it to estimate the elasticity of electric motor 

shipments with respect to changes in purchase price. DOE seeks comment on any sources of data 

that could be used to quantitatively estimate motor price elasticity. DOE also seeks comments on 

any additional sources of data on the share of motor shipments which are for new installation, 

and the share of shipments which are for replacement.

ES.4.18 Scaling Methodology for Manufacturer Selling Price

DOE seeks comment on its scaled values for MSPs. In particular, DOE seeks comments 

on its methodology for scaling MSP data from the representative equipment classes to the 

remaining equipment classes.

ES.4.19 Scaling Methodology for Motor Weights

DOE seeks comment on the scaled values for motor weights. In particular, DOE seeks 

comments on its methodology for scaling weight data from the representative equipment classes 

to the remaining equipment classes.

ES.4.20 Trial Standard Levels

For the NOPR, DOE will develop trial standard levels (TSLs) based on the CSLs selected 

for electric motors. DOE is considering developing TSLs by equipment class group (i.e., all 

equipment classes in the same equipment class group would be at the same CSL level within this 

TSL). Further, DOE is considering several criteria in developing the TSLs, including, but not 

limited to, minimum LCC, maximum NPV, and "max tech" efficiency. The TSLs may include 

combinations of CSLs. From the TSLs it develops, DOE will select one as its proposed standard 

for each equipment class group in the NOPR. DOE invites comment on the criteria it should use 

as the basis for selecting TSLs.