Department of Energy

Washington, DC 20585

MAR 15 2002

Mr. James Beyreis

Vice President, Global Engineering

Underwriters Laboratories Inc.

333 Pfingsten Road

Northbrook, IL 60062-2096

'IL copy

Dear Mr. Beyreis:

This is in response to your letter dated March 5, 2002, which addresses recognition of the

Underwriters Laboratories Inc. (UL) Energy Verification Service (EVS) for electric motor

efficiency as a nationally recognized certification program under the provisions of section 431.27

of Title 10 Code of Federal Regulations Part 431 (10 CFR 431), and your concern about

completion of the recognition process.

I understand your concern and I can assure you that the Department of Energy (the Department)

has been diligent in properly handling all documents and information provided by UL to ensure

the integrity of the process. In general, the Department has been supportive of the UL EVS for

motor efficiency and hks been working with UL in the mutual hope of a satisfactory

determination. Notwithstanding, the evidence provided by UL to support its petition for national

recognition has been weak and has contained defects. Also, public comments received as a result

of publication of the UL Petition in the Federal Register (66 FR 50355 (October 3, 2001)) were

critical of the UL EVS for motor efficiency. The Department pointed out to UL these defects in

an effort to correct them. Examples are as follows:

• Section 431.27(b)(1) of 10 CFR 431 requires "satisfactory standards and procedures for

conducting and administering a certification system." Initial EVS motor efficiency guides

and manuals submitted by UL contained inaccurate information concerning compliance

with the energy efficiency levels contained in 10 CFR 431 and cited an obsolete test

.procedure.

• Section 431(b)(3) of 10 CFR 431 requires a certification system to "operate in a highly

competent manner." On September 20, 20002, UL submitted to the Department an

automated spreadsheet program as an example of its ability to take test data and enter it

into a software program that would be used to calculate energy efficiency, and thereby

"avoid errors common to data-intensive calculations." The Department examined the

spreadsheet and found that the data sheet failed to correctly report a number of critical

data points required to properly determine the efficiency of a motor. UL acknowledged

the errors, made corrections and resubmitted its spreadsheet. Again, the Department

found errors. This problem with the data sheet has caused concern as to whether UL has

:satisfactory standards and procedures in place for conducting and administering its EVS

for motors. Further, we would expect technical staff familiar with the IEEE Standard

Pnnted with soy ink on recycled paper

EE-RM-96-400-UL COMMENT 29
Mr. James Beyreis

Vice President, Global Engineering

Underwriters Laboratories Inc.

333 Pfingsten Road

Northbrook, IL 60062-2096

Dear Mr. Beyreis:

This is in response to your letter dated Marc 5, 2002, which addresses recognition of the

Underwriters Laboratories Inc. (UL) Energy Verification Service (EVS) for electric motor

efficiency as a nationally recognized certification program under the provisions of section 431.27

of Title 10 Code of Federal Regulations Part 431 (10 CFR 431), and your concern about

completion of the recognition process.

I understand your concern and I can assure you that the Department of Energy (the Department)

has been diligent in properly handling all documents and information provided by UL to ensure

the integrity of the process. In general, the Department has been supportive of the UL EVS for

motor efficiency and has been working with UL in the mutual hope of a satisfactory

determination. Notwithstanding, the evidence provided by UL to support its petition for national

recognition has been weak and has contained defects. Also, public comments received as a result

of publication of the UL Petition in the Federal Register (66 FR 50355 (October 3, 2001)) were

critical of the UL EVS for motor efficiency. The Department pointed out to UL these defects in

an effort to correct them. Examples are as follows:

• Section 431.27(b)(1) of 10 CFR 431lrequires "satisfactory standards and procedures for

conducting and administering a certification system." Initial EVS motor efficiency guides

and manuals submitted by UL contained inaccurate information concerning compliance

with the energy efficiency levels contained in 10 CFR 431 and cited an obsolete test

procedure.

• Section 43 1 (b)(3) of 10 CFR 431 requires a certification system to "operate in a highly

competent manner ." On September 20, 20002, UL submitted to the Department an

automated spreadsheet program as an example of its ability to take test data and enter it

into a software program that would be used to calculate energy efficiency, and thereby

"avoid errors common to data-intensive calculations." The Department examined the

spreadsheet and found that the data sheet failed to correctly report a number of critical

data points required to properly determine the efficiency of a motor . UL acknowledged

the errors, made corrections and resubmitted its spreadsheet . Again, the Department

found errors. This problem with the4ata sheet has caused concern as to whether-UL has

satisfactory standards and procedures in place for conducting and administering its EVS

for motors. Further, we would expect technical staff familiar with the IEEE Standard

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EE-RM-96-400-UL COMMENT 29