Date: April 29, 2015

Case: Commercial and Industrial Pumps Standard Meeting

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Commercial and Industrial Pumps Standard Meeting

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U.S. DEPARTMENT OF ENERGY PUBLIC MEETING 

 COMMERCIAL AND INDUSTRIAL PUMPS 

 STANDARDS MEETING 

 U.S. Department of Energy 

 Forrestal Building, Room 6E-066 

 1000 Independence Avenue, SW 

 Washington, DC 20585 

 2:24 p.m. 

 Wednesday, April 29, 2015 
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1 Appearances for Department of Energy Meeting 

2

3 Doug Brookman, Chair 

4 John Cymbalsky, DOE 

5 Ashley Armstrong, DOE 

6 Sarah Widder, Pacific Northwest National Laboratory 

7 Albert F. Huber, Patterson Pumps 

8 Jiangang Hu, Rockwell Automation 

9 Joanna Mauer, Appliance Standards Awareness Project 

10 Mark Menzer, Danfoss 

11 Brent Ross, Armstrong Fluid Technology 

12 Aniruddh Roy, Goodman Manufacturing Company, L.P. 

13 Paul Ruzicka, Xylem 

14 Mark W. Handzel, Xylem 

15 Meg Waltner, NRDC 

16 Prem Vuppuluri, Pacific Northwest National Laboratory 

17 Mary Anderson, Pacific Gas and Electric Company 

18 Robert R. Barbour, TACO, INC. 

19 Mark J. Chaffee, TACO, INC. 

20 Alex Boesenberg, NEMA 

21 Rob Boteler, Nidec Motor Corporation 

22 Daniel E. Delaney, Regal Beloit America, Inc. 
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1 Peter Gaydon, Hydraulic Institute 

2 Daniel Weintraub, Navigant 

3 Jason Lai, Navigant 

4 Chris Lau, Navigant

5 Alison Williams, Lawrence Berkeley National Laboratory 

6 Gary Fernstrom, CA IOU's 

7 Glenn Harrison, USDOJ - ATR 

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1 P R O C E E D I N G S 

2 (2:24 p.m.) 

3 CHAIR BROOKMAN: So apologies for the 

4 delay. We're about to resume, and you can tell your 

5 -- anybody that's joining us, that you have contact 

6 with via the web. They should be able to sign back 

7 on to the new web address and access the slide. It's 

8 up here no the screen now, and they should be able to 

9 join the conversation. So we're going to start. 

10 We're going to commence. Ready? Lets do this. 

11 Good afternoon everyone. Good to see you 

12 still here. This is the Notice of Proposed 

13 Rulemakings for Pumps, the energy conservative 

14 standards portion of this meeting. We had the test 

15 procedures portion of the NOPR this morning. Glad to 

16 see so many of you still here. We're going to launch 

17 right straight into this content, since virtually all 

18 of the individuals that were here this morning. Do 

19 you want to do introductions? 

20 MS. ARMSTRONG: We have a new transcript. 

21 MALE PARTICIPANT: A different transcript. 

22 MS. ARMSTRONG: Different transcript. 
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1 CHAIR BROOKMAN: This is a different 

2 transcript. Yes, thank you for clarifying that. 

3 This will be a different transcript and different 

4 entire record of this meeting commencing now, and one 

5 or two individuals did not get a chance to introduce 

6 themselves this morning. Louis and 

7 Tom Eckman. You want to say hello? 

8 MR. STARR: So this is Louis Starr with 

9 Northwest Energy Efficiency Alliance. 

10 MR. ECKMAN: Tom Eckman, Northwest Power 

11 and Conservation Council. 

12 CHAIR BROOKMAN: Chris, I don't think you 

13 were here this morning, were you? 

14 MS. ARMSTRONG: That's Chris Lau from 

15 Navigant. 

16 CHAIR BROOKMAN: Okay. So thanks all of 

17 you for hanging in here. Apologies again for the 

18 delay caused by our -- 

19 MS. ARMSTRONG: I'm going to actually ask 

20 everyone, because he's going to create a whole new 

21 record, and so he doesn't have to pull. We do need 

22 it for -- 
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1 CHAIR BROOKMAN: Okay. Let's do this. 

2 Let's do introductions as we did first thing this 

3 morning. Name and organization affiliation 

4 immediately to my left. 

5 MR. DELANEY: Okay. Dan Delaney from 

6 Regal Beloit, also MG-1 section chair. 

7 CHAIR BROOKMAN: Thank you. 

8 MR. FERSTROM: Gary Ferstrom, representing 

9 the California Investor-Owned Utilities, PG&E, 

10 Southern California Edison, San Diego Gas and 

11 Electric and the Southern California Gas Company. 

12 MR. BOTELER: Rob Boteler, Nidec Motor 

13 Company and chairman of the NEMA Energy Committee. 

14 MR. BARBOUR: Bob Barbour representing 

15 TACO. Actually, from TACO representing HI. 

16 MR. HANDZEL: Mark Handzel from Xylem, 

17 representing HI as well. 

18 MR. HUBER: Al Huber from Patterson Pump, 

19 representing HI. 

20 MR. RUZICKA: Paul Ruzicka from Xylem, 

21 representing HI. 

22 MR. GAYDON: Peter Gaydon, Hydraulic 
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1 Institute. 

2 MR. ROSS: Brent Ross, Armstrong Fluid 

3 Technology. 

4 MS. MAUER: Joanna Mauer, Appliances 

5 Standards Awareness Project. 

6 MS. WALTNER: Meg Waltner, Natural 

7 Resources Defense Council. 

8 MS. KOHL: Betsy Kohl, DOE General 

9 Counsel's Office. 

10 MS. ARMSTRONG: Ashley Armstrong, DOE. 

11 MR. CYMBALSKY: John Cymbalsky, DOE. 

12 MS. WILLIAMS: Alison Williams, Lawrence 

13 Berkeley National Labs. 

14 MR. WEINTRAUB: Daniel Weintraub, 

15 Navigant. 

16 MR. LAI: Jason Lai, Navigant. 

17 MS. WIDDER: Sarah Widder, Pacific 

18 Northwest National Laboratory. 

19 CHAIR BROOKMAN: Just as a matter of 

20 courtesy as -- 

21 (Off mic comments.) 

22 MR. BOESENBERG: Alex Boesenberg, NEMA. 
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1 MR. CHAFFEE: Mark Chaffee, TACO. 

2 (Off mic introductions.) 

3 MR. HARRISON: Ron Harrison, DOJ. 

4 MS. ANDERSON: Mary Anderson, PG&E. 

5 CHAIR BROOKMAN: Great. Thanks to all of 

6 you. We're going to pick up where we left off, and I 

7 believe that was Slide No. 95. You can see the 

8 agenda for the rest of the afternoon. 

9 We'll do a few overview slides, and then 

10 moving from there, Market Technology, Screening, 

11 Engineering, Markets Analysis and Energy Use, and 

12 then following on, Life Cycle Cost and Payback Period 

13 Analysis, Shipments, Historical Analysis, 

14 Manufacturer Impact Analysis, NOPR Analyses, plural 

15 and closing remarks, closing out with a description 

16 of the proposed status certification, and an 

17 additional opportunity for anybody that wishes too to 

18 make a closing statement, closing remarks, as we move 

19 toward the end of the day today. 

20 It's now about 2:30. We'll probably take 

21 a break around about 3:30-3:45, or as needed when we 

22 get there. So we're going turn it back to Ashley 
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1 Armstrong. 

2 MS. ARMSTRONG: So hi everyone. Good 

3 afternoon. I'm going to go through some of the 

4 slides pretty quickly here, to talk about reference 

5 to the working group, which we discussed this 

6 morning. 

7 One of the things that's not in this 

8 afternoon's presentation, for those of you that are 

9 just joining us, either via the web are in person, 

10 are the definitions, and how those definitions 

11 establish both scope of coverage, as well as the 

12 applicability of the test procedures and the 

13 standards. 

14 Since we're not re-reviewing those this 

15 afternoon, we got a lot of great feedback and some 

16 clarifications that were requested from this morning, 

17 I encourage anyone who's just joining us to go back 

18 and look at that section from this morning's 

19 presentation, if they are interested, as well as the 

20 NOPR on that. 

21 Those definitions and that discussion is 

22 what's also impacting and reflected here, as part of 
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1 the actual applicability of the standards discussion. 

2 So just to go through the overview of how we got 

3 here, as we discussed this morning, a working group 

4 was commenced and they did a lot of the heavy lifting 

5 and hard work to come up with some negotiated levels, 

6 that were then passed on to the ASRAC Committee and 

7 voted out favorably and sent to the Department for 

8 consideration and ultimately inclusion in this NOPR. 

9 DOE believes that the standards that you 

10 see in the proposed rule reflect wholeheartedly 

11 those levels that were negotiated by the working 

12 group, and then we conducted the analysis there. 

13 We're going to give you a high level overview of that 

14 analysis that reflected those levels and ultimately 

15 what you saw in the energy conservation standards 

16 proposal. 

17 So this is just an overview of our 

18 statutory requirements. These are the seven factors 

19 that DOE is required to consider when promulgating 

20 and considering rules, and on the right is the 

21 corresponding DOE analysis that we conduct, in order 

22 to assess those seven criteria. I'm not going to go 
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1 into detail, but throughout the presentation today, 

2 we are going to highlight each one. 

3 So next we're going to talk about the 

4 detailed analysis, and first we're going to talk 

5 about a minimally compliant pump. 

6 CHAIR BROOKMAN: Daniel Weintraub. 

7 MR. WEINTRAUB: So Daniel Weintraub with 

8 Navigant. Thank you Ashley for getting us set up 

9 here. So the first slide we have here is just a 

10 reminder of what we're looking at here with the 

11 standards. So we've gone through this in detail. 

12 PEI is the metric. PEI is made up of PER and PER 

13 standard, and a compliant pump is less than or equal 

14 to one. 

15 What we have down here with the equations, 

16 they're highlighting the fact that when it all comes 

17 down to it, it's the C value that you vary to see -- 

18 to change the level of efficiency that we were 

19 looking at in this analysis, which is consistent with 

20 what we went through with the working group. 

21 So now I'm going to take you through the 

22 Market and Tech and Screening Analysis. So again, as 
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1 Ashley mentioned, we're going to keep this very high 

2 level, because everything here reflects what was 

3 discussed in detail with the working group. So we'll 

4 go through the methods and then briefly through 

5 results and move forward. 

6 So the purpose here for the market and 

7 tech was to develop scope of coverage for the 

8 rulemaking. Ashley discussed the scope and the 

9 definitions identical to what was discussed this 

10 morning. Beyond that, we define equipment classes. 

11 I'll go through those in detail in the next slide. 

12 We have a table to show them. 

13 We characterize the manufacturing 

14 industry. So that means identifying manufacturers 

15 and industry groups and associations. That's all 

16 presented in the TSD. We got our historical 

17 shipments and other relevant market data. We 

18 discussed that at the working group, and that's also 

19 in the TSD. We characterize efficiency distributions 

20 of the current market. We also went through that. 

21 We identify existing regulatory and 

22 voluntary efficiency programs. So obviously the key 
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1 one here was what was done in the European Union, and 

2 there's a lot of parallels there between this 

3 regulation and that one. We've discussed that also. 

4 Finally, we identify technology options for improving 

5 efficiency. So we'll move on and go through some of 

6 these. 

7 So first up here, these were the final 

8 equipment classes that DOE is proposing. So it comes 

9 out to 20 of them, and as kind of discussed earlier 

10 in the definition stage, we broke it up. You first 

11 look at -- what we have up here is category on the 

12 left, the type of pumps. So whether it be end 

13 suction close couple, end suction frame-mounted, 

14 inline, RSV or VTS. Then the sale-configured. Oh 

15 sorry. 

16 MR. GAYDON: Peter Gaydon with the 

17 Hydraulic Institute. On the last slide, you 

18 mentioned the technical support document? 

19 MR. WEINTRAUB: Yes. 

20 MR. GAYDON: Is that different than the 

21 preamble and where is it and how is it available to 

22 us? 
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1 MR. WEINTRAUB: You want to take this? 

2 MS. ARMSTRONG: Sure. It is different. 

3 The preamble is just the writing in the beginning of 

4 the notice. What we call Reg Text is the bottom of 

5 the notice that implements the regulations in the 

6 Code of Federal Regulations in our CFR. The TSD is a 

7 separate stand-alone document. It's about 1,000 

8 pages or so, and it has all the analytical data and 

9 analysis, assumptions, results. 

10 It's also in the docket and on our web 

11 page, and I can send you a link directly, if you just 

12 tell me your email address offline. 

13 MR. GAYDON: Okay. 

14 MS. ARMSTRONG: Yep. 

15 MR. WEINTRAUB: Thank you, Ashley. All 

16 right. So we'll go forward. So again, we're talking 

17 about equipment classes. So you're broken out by 

18 what we have up there as category, and then your sale 

19 configuration is an excess. Whether it's bare pump 

20 or pump with motor without controls, or a pump with 

21 motor and with controls. So that creates whether 

22 you're going to be a constant load pump or a variable 
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1 load pump, and then we had design speed, which we've 

2 discussed, 1,800 or 3,600. 

3 That brings you over to the right side, 

4 which ends up being the designation, the final 

5 designation for all 20, and you see three terms. 

6 You're going to have that category, you're going to 

7 have the speed and you're going to have whether 

8 you're constant load or variable load. 

9 So the next topic to discuss would be the 

10 technology assessment. So here DOE identified 

11 technology options for improved energy efficiency 

12 from publicly available literature, comments, input 

13 from stakeholders and manufacturer interviews. So 

14 here we've listed out what was originally identified. 

15 So this is -- this started back with the 

16 framework. We worked through all of these within the 

17 working group meetings. So what we presented at the 

18 working groups, to the working group and within the 

19 TSD and the NOPR were improved -- improved 

20 components, reduced running clearances, reduced 

21 mechanical friction, reduction of other volumetric 

22 losses, improved hydraulic design, addition of 
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1 variable speed drive, improvement of VSD efficiency 

2 and reduced VSD standby power. 

3 So again, these were just explored before. 

4 The next step is the screening analysis. So these 

5 were the initial exploration, and the TSD goes 

6 through all this in detail. We quantify that the 

7 gains that we found or the lack of gains that we 

8 found. 

9 So that brings us on to the screening 

10 analysis. So here, as it kind of sounds, the purpose 

11 here to screen out technologies that do not save 

12 energy, or do not meet all of the following four 

13 criteria which we have listed there: technological 

14 feasibility, practicability to manufacture, impacts 

15 on product utility or availability to customers or 

16 impacts on health and safety. 

17 So TSD goes through the detailed reasons 

18 why each one was screened out, and that mirrors what 

19 was discussed at the working group. We worked 

20 through all of these, and you'll see up there that 

21 after the screening analysis, the only technology 

22 option that was passed on to the next phase, which is 
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1 the engineering analysis, was hydraulic redesign. 

2 So there are some caveats that are out 

3 there in the TSD, but overall, the only design that 

4 was considered in the engineering was hydraulic 

5 redesign. 

6 So that takes us to engineering. So the 

7 purpose of the engineering analysis to establish 

8 efficiency levels and determine the incremental 

9 changes in manufacturer selling prices, which we term 

10 -- we use MSP commonly, at each efficiency level 

11 which is analyzed. 

12 So to do this, a brief overview of the 

13 methods. The efficiency levels were established 

14 using a market distribution approach. So this means 

15 that the levels were based on current market 

16 available ranges of efficiency. So the baseline 

17 represents the bottom of the market, max type 

18 represented the top of the market, and our efficiency 

19 levels were scattered in between, based on input from 

20 the working group. We established all those levels 

21 based on what the working group was interested in 

22 analyzing. 
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1 So base case and incremental MSPs were 

2 determined using confidential market-wide revenues, 

3 shipments, markup data as well as manufacturer input, 

4 again all -- we go through it all in detail in the 

5 TSD, Chapter 5 for this section. 

6 So here, here we have our final efficiency 

7 levels and corresponding C values. As we discussed, 

8 the C values determine or define the efficiency 

9 level. We have from Efficiency Level 0, which is 

10 baseline up to Efficiency Level 5, which is max tech, 

11 and Efficiency Level 2 was the 25th efficiency 

12 percentile, commonly known as PR-25 to the working 

13 group, and that represents the 25th -- the lower 25th 

14 percentile of efficiency. 

15 So next we have the base case MSP 

16 efficiency relationship. So this kind of represents 

17 today's market, so price versus efficiency 

18 relationship in today's market is what I call it. 

19 It's a bit complex, but there are four steps to get 

20 to this relationship. We went through all this again 

21 in detail with the working group, but at a high 

22 level. DOE found a relationship between manufacturer 
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1 markup and efficiency. 

2 DOE also determined that improved 

3 efficiency does not increase manufacturer production 

4 costs. DOE modeled the average manufacturer 

5 production cost for pumps within the scope. So it is 

6 basically cost versus pump size. 

7 We established a model for costs all 

8 across, from the lowest horsepower to the highest 

9 horsepower, and then to get to this final 

10 relationship, the base case MSP for a pump of a given 

11 size and efficiency, it's found using the average MPC 

12 models, and we have a graphic of that on the left, 

13 and the markup versus efficiency model on the right. 

14 You can work those two together for any given pump 

15 and you can find out what any given pump's MSP was, 

16 given its size and its efficiency. 

17 So next we're going to briefly talk about 

18 conversion costs. So typically conversion costs are 

19 covered in detail in the manufacturer impact 

20 analysis. But here, we've moved them up in the 

21 analysis for a few specific reasons. Namely that 

22 hydraulic redesigns are known to result in 
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1 significant conversion costs, and it's possible that 

2 those conversion costs can lead to increased markups 

3 to recover those conversion costs. So manufacturers 

4 may increase the markups to try and get back some of 

5 those investments. 

6 Those markups affect pricing. So that's 

7 why we're looking at them up front. We want to make 

8 sure we have an accurate understanding of pricing. 

9 So to find the conversion costs, we determine 

10 basically a very high level three-step approach. We 

11 went through this with the working group also. 

12 We determined the industry average cost 

13 per model to redesign a pump of varying sizes, to 

14 meet each of the proposed efficiency levels. This 

15 data was in part based on what HI provided in their 

16 redesign survey, as well as confidential interviews. 

17 We then modeled the distribution of unique 

18 pumps that would require a redesign at each 

19 efficiency level, and then for each efficiency level 

20 you multiply the number of unique failing models by 

21 the associated cost to redesign each of those pumps, 

22 and you come out with a total conversion cost for the 
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1 industry at each one of your levels. 

2 Down here we have the results presented 

3 for the groupings that we looked at. You can see we 

4 combined end suction close couple and frame-mounted, 

5 and we looked at inline and VTS and we've summed up 

6 the industry down there. These are the same numbers 

7 that were presented to the working group. 

8 All right. Finally, we have the standards 

9 case MSP efficiency relationship. So we've already 

10 shown the base case, which was kind of business as 

11 usual, and now this is -- this is what we're looking 

12 at to evaluate the standards case, if we were to 

13 implement the standard. 

14 So here DOE evaluated two standards case 

15 MSP efficiency scenarios, and this is to represent 

16 the uncertainty of -- the uncertainty of the 

17 potential impact of standards on pricing in the 

18 market. So we looked into the first one is flat 

19 pricing. The pricing structure here would not be 

20 modified to recover conversion costs. 

21 So basically this is the same markup 

22 structure as in the base case, same as today's 
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1 industry. This scenario is considered the lower 

2 bound for revenues, no new additional markups. The 

3 second is cost recovery pricing. So this pricing 

4 structure is modified to recover the conversion cost 

5 over the analysis period. 

6 So that means markups are increased, even 

7 if the MPC, the manufacturer's cost to produce the 

8 product stays the same. They're going to charge a 

9 higher markup to try and make back some of their 

10 investments on their conversion costs. So this 

11 scenario is considered an upper bound for revenues. 

12 This scenario provided the highest cost to the 

13 consumer, so it was used in the LCC analysis as a -- 

14 for conservative, to be conservative. 

15 The results of these pricing scenarios are 

16 incorporated into the LCC and MIA analysis, and is 

17 all documented in the TSD. So with that, I'll move 

18 on. 

19 MS. WILLIAMS: Okay. You guys have never 

20 been so silent before. It's weird. 

21 (Off mic comment.) 

22 MS. WILLIAMS: Okay, I'm ready. So I'm 
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1 going to go through the markups and energy use. As 

2 with Dan, this is high level, so stop me if you have 

3 any questions. This is basically the same as what 

4 was presented during the working group, with a few 

5 minor changes that I'll point out. 

6 So the markups is basically to 

7 characterize the pump distribution channels and 

8 determine how those affect the consumer prices, based 

9 on the markups in each section of those channels. So 

10 we analyzed company direct cost, expenses and 

11 profits, and the sources for those are listed here. 

12 It's basically some Census Bureau data, some 

13 information from RS Means, and we also include sales 

14 taxes from the Sales Tax Clearinghouse. 

15 So we calculate both baseline and 

16 incremental markups. The baseline markups are 

17 applied to the manufacturer's selling price in the 

18 base case, and the incremental markups apply just to 

19 the incremental difference in MSP between the base 

20 case and the standards case, and that's just covering 

21 the expenses that vary with MSP. 

22 So this is the summary. Across the top, 
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1 those are the five different distribution channels we 

2 used along with other category and their market 

3 shares, and then the baseline and incremental markups 

4 for each of those entities in the channel and the 

5 overall markups. These are applied to the MSPs that 

6 Dan just talked about. 

7 Okay. So for energy use analysis, 

8 basically what we're doing is trying to determine the 

9 unit energy consumption of pumps at each of the 

10 considered efficiency levels, to put into the life 

11 cycle cost analysis. This is the general equation 

12 for this. It's power times operating hours, and here 

13 we're characterizing the power as the hydraulic 

14 output power divided by the pump and motor 

15 efficiencies. This is a variable load profile that 

16 I'll talk about in a moment. 

17 So these are the main inputs to the energy 

18 use analysis. The duty points -- for this, as we've 

19 discussed in the working group, there's not a lot of 

20 data out there for duty points. So we relied 

21 primarily on the shipments data that we collected. 

22 This just notes that we binned those data, and so 
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1 we're analyzing some representative units in these 

2 nine power bins, nine by nine power and flow bins. 

3 So then in order to account for the 

4 difference between, you know, the BEP of a pump 

5 that's actually shipped and what is used in the 

6 field, we use this BEP offset to account for pump 

7 sizing, which basically assumes that people are 

8 generally choosing a pump between --for a duty point 

9 between 75 percent and 110 percent of BEP flow. 

10 We discussed the annual hours of operation 

11 in the working group, those distributions based on 

12 application that we went through, and we're using 

13 four generalized load profiles that represent a 

14 variety of conditions, like a flat load that's mostly 

15 at BEP, an oversize load and some variable over- and 

16 under-sized loads. So those are distributed 

17 according to the percentages here. 

18 So in addition to those, which basically 

19 determines how much power the pump is actually 

20 producing, we need to calculate its input power. So 

21 we need pump losses, which we get using the 

22 efficiency curves for the representative units, which 
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1 were basically determined from the data we received 

2 from all the manufacturers. The motor losses, 

3 basically in this analysis we assume that all pumps 

4 are bare pumps to some extent, and we're just 

5 assigning motor losses based on the default values in 

6 the test procedures. 

7 So though it's not taking into account 

8 anything to do with motors. And in this analysis, we 

9 did not account for control losses. We basically 

10 assumed that everyone was throttling their pump, and 

11 then we did a separate LCC subgroup analysis for VFD 

12 users, because it's -- although not intuitive, but 

13 because they use less energy to start with, they 

14 actually save less with the standard. So they, to 

15 some extent, could be disproportionately impacted. 

16 So we looked at them there. 

17 Okay. So those all go into the life cycle 

18 cost analysis, just basically looking at the 

19 economics from the consumer's perspective. Life 

20 cycle cost is just summing the consumer cost over the 

21 life of the equipment, whereas payback period is how 

22 long it takes to recover the increased purchase price 
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1 of the more energy efficient equipment. 

2 So for each pump equipment cost, we do 

3 10,000 pump installations, which is basically the 

4 combination of a pump user and a pump, and then 

5 there's many variables associated with the user and 

6 the pump, and a lot of these are characterized by 

7 distributions, so that we can evaluate the full 

8 extent of the population. So that things like 

9 discount rate, operating hours, lifetime, load 

10 profiles is all distributions. 

11 The user characteristics are the same for 

12 all efficiency levels, and then what happens as we go 

13 up in efficiency level is that basically in the base 

14 case, we have the distribution of efficiency that 

15 came from the manufacturer data, that has all the 

16 different pump performance data. 

17 If then as we step through each efficiency 

18 level, if the pump assigned to a customer in each 

19 standards case does not pass the efficiency criteria, 

20 then that user is assigned a redesigned pump that 

21 just meets the standard level in question. So 

22 nothing changes, unless the pump doesn't meet the 
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1 proposed level. 

2 This is just a diagram of the LCC inputs 

3 and calculations. So on the left you see the MSPs 

4 and the markups that we've been talking about, and 

5 the energy use, and then there's a few other 

6 variables, lifetime, discount rate, electricity price 

7 trends that go into the calculations. So this is a 

8 summary of those inputs. Basically we -- for the 

9 10,000 installations, it's a weighted sample of pump 

10 -- of speed, power, flow, sector and application. 

11 So we had several different databases that 

12 we sort of merged together to get these sample 

13 weights, to try to reflect the population as best we 

14 could. The equipment price in the base case is 

15 determined, as Dan discussed, with the MSP and 

16 distribution channel markups. In each standards 

17 case, because of these conversion costs that Dan was 

18 discussing, we have to allocate those conversion 

19 costs to the pumps that fail and get redesigned at 

20 each standard level. 

21 So every time we look at a different 

22 efficiency level, we're increasing the prices of 
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1 those pumps that have to get redesigned. So we're 

2 basically assuming all the cost gets passed on to the 

3 customer, because that's the most conservative 

4 approach for the customer. This is all consistent 

5 with what we did during the working group. 

6 There's a couple of things we're not using 

7 in here, basically installation, maintenance and 

8 repair costs are not expected to change with 

9 efficiency levels, so they're not included in this 

10 analysis. So it basically doesn't impact the change 

11 in LCC between base case and standards case. So 

12 those are ignored. The energy, as I just discussed, 

13 from the energy use analysis, and that's paired with 

14 the electricity prices that we're using from AEO 

15 2014, along with trends into the future. 

16 The lifetime we discussed in pretty good 

17 detail with the working group. We started with 

18 service lifetime in years, and then we related the 

19 mechanical lifetime to operating hours, so that pumps 

20 that are used more have a shorter lifetime, and 

21 similarly pumps that are -- run faster have a shorter 

22 lifetime. The average lifetime across all the pump 
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1 equipment classes is approximately 15 years, but it 

2 does vary by equipment class, depending on where it's 

3 used and design and that kind of thing. 

4 Discount rates are basically used to 

5 convert annual operating expenses to the year of 

6 purchase. For all the sectors except for municipal 

7 we used weighted average cost of capital from equity 

8 and debt financing. So the equity is determined 

9 using the capital asset pricing model, and debt 

10 financing is using data from Damodaran online. 

11 For municipal, it's done a little 

12 differently. It's based on state and local bonds 

13 issued by the Federal Reserve. And then as I 

14 mentioned previously, we do start with an efficiency 

15 distribution in the base case, and that was all based 

16 on the shipments data provided by the manufacturers 

17 and HI. 

18 So this is just an example of the LCC 

19 results for one of the equipment classes. So you can 

20 see on the right the average savings for each 

21 customer, and the percent of customers who actually 

22 end up paying more under standards than in the base 
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1 case. So you can see for the chosen, the proposed 

2 efficiency level, there's positive average savings 

3 and a very low percent net cost. 

4 So all the other results for the other 

5 equipment classes are available in the NOPR and the 

6 TSD. Okay. So shipments has basically -- this is an 

7 input for the National Impact Analysis and the 

8 Manufacturer Impact Analysis, estimating shipments 

9 over a 30-year analysis period. 

10 So for this rulemaking, this is all 

11 exactly as we discussed during the working group. 

12 It's a fairly simple shipments model. We started 

13 with the 2012 shipments from the Hydraulic Institute 

14 and manufacturers. We distributed those in the four 

15 sectors based on our weighting estimates from the 

16 LCC, and then we projected shipments by sector using 

17 these indicator variables in the Annual Energy 

18 Outlook, which are commercial floor space, which we 

19 used for the commercial sector; value of 

20 manufacturing shipments, which we used for the 

21 industrial sector; value of agriculture, mining and 

22 construction, used for agriculture; and population, 
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1 which we used for the municipal. 

2 So we project shipments across those four 

3 sectors, total them together and then disaggregate 

4 them into equipment classes based on the 2012 market 

5 shares. So this is just a graph on the left of the 

6 projection by sector. This is basically tying the 

7 2012 shipments to the AEO forecast, and on the right 

8 is the final shipments projections. 

9 There's a reference, low and high case. 

10 The reference case is what we talk about mostly, but 

11 we do run some scenarios in the TSD with the high and 

12 low cases, in case you're interested. 

13 Okay. The National Impact Analysis is 

14 used to determine the projected National Energy 

15 Savings and National Net Present Value. So it's 

16 taking into account an annual series of energy and 

17 economic impacts, and it's using the shipments model 

18 to calculate the stock of pumps in service each year 

19 that are affected. 

20 So the NES is basically the difference 

21 between standards case energy use and base case 

22 energy use over this 30-year period, and the National 
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1 Net Present Value compares the cumulative operating 

2 cost savings, which in this case is really energy 

3 cost, to the cumulative installed cost increases, and 

4 it also uses a discount rate. 

5 So that's used to determine whether 

6 there's national savings or cost from each proposed 

7 -- each potential standard level. Yes. 

8 MR. BOTELER: Rob Boteler with Nidec. So 

9 what -- at the end of the day, what was the terawatt 

10 hours that we estimate will be? 

11 MS. WILLIAMS: Well, I'm not quite there. 

12 MR. BOTELER: Oh, I'm sorry. 

13 MS. WILLIAMS: So it's a surprise. So the 

14 inputs to the National Impact Analysis, most of them 

15 are weighted average values that come out of the 

16 LCCs. So they take into account the whole 

17 population. So there's the installed cost, which in 

18 this case is really just the equipment cost, because 

19 again, installation costs were assumed not to vary 

20 with efficiency level. 

21 Same thing with repair and maintenance 

22 costs. They're not taken into account here, because 
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1 we'll assume they're the same. Annual Energy Use is 

2 again taken from the LCC. One thing that is 

3 different here that we talked in the working group 

4 about us needing to do, but hadn't actually 

5 implemented it yet, was to make these adjustments for 

6 trimmed impellers and for pumps using VFDs. 

7 So we basically made some assumption about 

8 impellers being trimmed on average to 85 percent, and 

9 that some percentage of pumps without trimmed 

10 impellers are run off VFDs, and there's a penetration 

11 rate that increases over time with the VFDs. So 

12 these things basically serve to reduce the potential 

13 energy savings from this rule, because they're 

14 already using less power than just looking at all 

15 pumps as full impeller and throttling. 

16 So those details of how we made those 

17 adjustments are available in both the NOPR and the 

18 TSD if you guys want to take a look, and we did 

19 request comment on those. There's certainly some -- 

20 potentially some refinements we can make to that if 

21 anybody has inputs on those factors that affect the 

22 energy use. Again, the base case efficiencies are the 
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1 same. 

2 MR. ROY: I'm Aniruddh Roy with Goodman. 

3 Just one question on the repair and maintenance 

4 costs. Was there any evaluation done on if there 

5 would be any variation in repair and maintenance 

6 costs on applied products, if these were installed in 

7 other equipment, and how that could vary for pumps in 

8 those applications? 

9 MS. WILLIAMS: Yeah. So we did not 

10 actually look at that. We are focusing just on the 

11 pump itself, and whether or not the characteristics 

12 of the pump that would have to change as a result of 

13 the standard would impact those repair and 

14 maintenance. We understand them to be -- essentially 

15 if you looked at them, they would almost always look 

16 pretty much the same, and would just have a 

17 redesigned impeller and volute. We screened out 

18 changes that might affect the reliability and 

19 performance. 

20 So there's specific reasons that we 

21 believe maintenance and repair wouldn't change, and 

22 it doesn't -- again, we didn't analyze that 
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1 specifically. It doesn't seem to me that it would 

2 impact what you're talking about. But we would 

3 certainly welcome comment if you have anything to 

4 suggest differently. 

5 MR. ROY: Okay. 

6 MS. WILLIAMS: So the base case and 

7 standards case efficiencies, again base case is the 

8 same as we used in the LCC. We did not project any 

9 growth. Sometimes in other rulemakings, we assume 

10 that even without a standard, the efficiency will 

11 change over time. We discussed with the working 

12 group, but no one was really sure about this. So we 

13 just maintained constant efficiency distribution in 

14 the base case. 

15 In the standards case, what happens is a 

16 roll up scenario, which means that pumps that don't 

17 meet the standard don't -- rolled up just to the 

18 standard. So the minimum they have to. There was 

19 some discussion over whether, you know, would assume 

20 that some actually go up higher. But what the 

21 working group basically settled on was that this was 

22 sufficient for this analysis. So that's what we 
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1 carried forward here. 

2 Again, the energy prices are used based on 

3 the AEO 2014 forecast. We do incorporate full fuel 

4 cycle energy savings. So there's a multiplier to 

5 convert the site energy to the full fuel cycle 

6 energy. The discount rate for the NIA is seven 

7 percent and three percent, and this is based on 

8 guidance from OMB, and we're discounting all expenses 

9 to year 2015. 

10 MR. FERSTROM: Alison, this is Gary. Do 

11 you know what the site full cycle multiplier is? 

12 MS. WILLIAMS: I don't know off the top of 

13 my head. It would be in Chapter 10 of the TSD. It's 

14 based on the sector in use here, and it doesn't 

15 differ significantly from other rules that we're 

16 using. 

17 MR. FERSTROM: Okay, thank you. 

18 CHAIR BROOKMAN: Yes, Paul. 

19 MR. RUZICKA: Paul Ruzicka. Alison, in 

20 the quest of getting these higher efficiencies, you 

21 mentioned that the repair and maintenance cost would 

22 not be impacted. However, in many frequent 
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1 instances, the drive to get higher efficiencies 

2 impacts suction performance, and we're trying to 

3 retrofit into existing applications and other 

4 industrial sites. 

5 Those products will wear our prematurely 

6 as a result of cavitation damage and erosion, because 

7 of the quest for higher efficiency, and there's 

8 several markets that are going to be directly 

9 impacted, especially condensate type return products, 

10 which would also tend to slide into this product mix. 

11 MS. WILLIAMS: Okay. So if you have data 

12 or information on sort of at what efficiency level 

13 those changes might happen, where we could implement 

14 them or some estimates of what the increased repair 

15 cost or frequency would be. You don't need to know 

16 them now, but that would be helpful. 

17 MR. RUZICKA: I can just make a general 

18 statement, that as you increase in efficiency, you 

19 decrease your suction performance. So in other 

20 words, you're going to need a more -- you need to 

21 increase your NPSH required by the system. That can 

22 also cause the customers themselves to incorporate 
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1 systems that are going to offset more than the energy 

2 savings they would reap. 

3 CHAIR BROOKMAN: Can you quantify those 

4 changes, because that would be sort of a proxy? 

5 MS. WILLIAMS: Yeah. So it's very 

6 difficult for us -- so I mean I guess I should say, I 

7 can't remember which on either repair or 

8 maintenance costs, we did hear from the working group 

9 that it's possible at some higher efficiency level, 

10 that the cost increases, but no one was able to 

11 quantify when that might occur or how much it might 

12 be, and I think in the most part, people felt it was 

13 probably above the level at which you negotiated. 

14 But so I think what Doug's basically 

15 asking is, short of actual data and information, it's 

16 really hard for us to implement that. So feel free 

17 to, you know, think about it and see what you can 

18 come up with. 

19 MR. RUZICKA: What I'll try to do is we'll 

20 try to come up with the correlation between increased 

21 efficiency versus decreased suction performance. 

22 CHAIR BROOKMAN: Thank you. Yeah, that 
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1 would be good, yeah. 

2 MS. WILLIAMS: Okay. So basically when we 

3 do the -- 

4 MR. FERSTROM: So this is Gary. I have a 

5 quick comment on that. Admittedly, the suction 

6 performance probably decreases as efficiency 

7 increases. However, I would think specifiers and 

8 engineers would be aware of that relationship, and 

9 would not use a pump in a situation where the suction 

10 pressure wasn't adequate to assure operation without 

11 damage and significant deterioration. 

12 CHAIR BROOKMAN: Al Huber. 

13 MR. HUBER: Al Huber, HI. It's highly 

14 possible that in future installations where they have 

15 an opportunity to do so, that may be possible. But 

16 it may not be possible for retrofits or replacements, 

17 and it may not be possible that you can get away from 

18 it. I mean if -- there just may be no product 

19 available with that higher NPSH. It's possible. 

20 MR. FERSTROM: Okay, I understand. I 

21 wasn't thinking about the retrofit application so 

22 much. But being that we're not really increasing the 
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1 efficiency very much, you know, I wouldn't think 

2 there'd be a very significant impact on suction 

3 pressure operation. But it would be good to get a 

4 data. 

5 CHAIR BROOKMAN: Mark, Mark. 

6 MR. HANDZEL: So Gary, just to give you, 

7 and I think we've talked about the point in the 

8 working group that, you know, if we're redesigning a 

9 pump, we're not just going for a little bit of 

10 efficiency improvement. We're going for as much as 

11 we can get. So just don't forget that please, okay? 

12 We're not going to try to do this again in five 

13 years. We're doing it once and we're going to get 

14 everything we can. 

15 MS. WILLIAMS: So I will comment on that 

16 though, is that when we do the analysis, it will be 

17 tied to the minimum level. So even if you're 

18 overshooting that, we're not necessarily capturing 

19 that. Okay. 

20 MR. FERSTROM: Okay. So thank you so much 

21 for reminding me Mark, and good for you all. 

22 (Laughter.) 
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1 MR. HANDZEL: Good for you too. 

2 MR. STARR: So this flows from that. 

3 I do have a question about it. Just intuitively, it 

4 seems like you have more power being transmitted to 

5 the working fluid, right? You'd have more 

6 efficiency. It's not being burned up. It's 

7 transmitting to the working core. So there you have 

8 more available head and flow, right? 

9 MALE PARTICIPANT: No. 

10 (Off mic comment.) 

11 CHAIR BROOKMAN: Paul. 

12 MR. RUZICKA: Paul Ruzicka. That's 

13 absolutely true, but that's on the output side. The 

14 problem we're experiencing is at the entrance of the 

15 impeller, the suction. What happens when you drive 

16 for higher efficiencies, you're using smaller 

17 impeller inlet areas, smaller watering clearances to 

18 reduce those volumetric clearance losses, slightly 

19 tighter tolerances as not to affect reliability. 

20 But when you make all those changes, these 

21 velocity increases manifest themselves into poor 

22 suction performance, requiring higher NPSH available, 
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1 and it may or may not be available in a retrofitted 

2 situation. 

3 CHAIR BROOKMAN: Thank you, Paul. Well 

4 said. 

5 MS. WILLIAMS: Okay. So we'll -- 

6 CHAIR BROOKMAN: That's a good summary. 

7 MS. WILLIAMS: We'll certainly review 

8 those comments when we get them for this, and 

9 implement something if we can. So when we look at 

10 the results of the National Impact Analysis, we 

11 typically look at these things called trial standard 

12 levels, which is basically a combination of potential 

13 efficiency levels for each equipment class. 

14 In this case, these are the same as we 

15 looked at in the working group, and we've made them 

16 consistent across all equipment classes. So at 

17 TSL-1, every equipment class moves up one efficiency 

18 level. At TSL-2, they each move up two. The 

19 exception for this is RSV, which as you all know from 

20 the working group, we didn't actually analyze, we 

21 used the -- because they are global, sorry, a 

22 product with a global platform. 
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1 We're using the baseline as the EU minimum 

2 standard for these pumps, and that's the proposed 

3 standard for them, and we didn't actually conduct 

4 analysis for them. So those remain at baseline for 

5 each of the TSLs. 

6 And I'll just finish this thought. So 

7 this is just a summary of the TSLs. I know this 

8 chart's really hard to read, but for your reference 

9 later it has the efficiency level and the 

10 corresponding C value for each equipment class by 

11 TSL. 

12 CHAIR BROOKMAN: Wayne Spritz, who is 

13 joining us online, has a question, and the question 

14 is: has there been any analysis of how many end users 

15 actually operate at the BEP? There is more waste in 

16 this area, because pumps are often ordered oversized, 

17 and when the system curve changes, how do you take 

18 into account of the actual change in energy 

19 consumption? 

20 MS. WILLIAMS: Okay. So going back to 

21 Slide 116, which is the energy use analysis input 

22 slides, we have a pump sizing variable and a load 
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1 profile variable. So the pump sizing corresponds to 

2 pumps being operated away from BEP, generally 

3 somewhere between 75 percent and 110 percent, and 

4 this is a uniform distribution. So we're taking in 

5 account variability of people generally sizing their 

6 pumps away from BEP. 

7 And then a load profile takes into account 

8 8 -- I don't actually have a slide on this, but 

9 there's four -- there's generally I think four load 

10 points, 50 percent, 75 percent, 100 percent, 110 

11 percent, and each of these load profiles has a 

12 different time spent at each of those loads relative 

13 to the main duty point. So we are taking into 

14 account -- and then we have pump curves and 

15 efficiency curves. 

16 So we're taking into account the 

17 performance based on sizing away from BEP and based 

18 on operating away from BEP. So I think we have 

19 captured that in the analysis. Okay. 

20 So these trial standard levels, and then 

21 these are the results by trial standard level. These 

22 are slightly different from what you saw in the 
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1 working group. As I said, we implemented those 

2 adjustments for impeller trim and VFD performance. 

3 So these might not be exactly the same as you have 

4 before. 

5 For TSL-2, we're looking at .28 quads, and 

6 then these are the consumer National Net Present 

7 Values by TSL and equipment class. So you can see 

8 that it's positive at TSL-2, the proposed level, at 

9 both three percent and seven percent. 

10 MALE PARTICIPANT: Is that annual? 

11 MS. WILLIAMS: This is -- no. This is 

12 cost over a 30-year period. Okay. So I'm going to 

13 turn it over to Chris to do the MIA, unless anyone 

14 has any final questions. 

15 CHAIR BROOKMAN: Chris Lau. 

16 MR. LAU: Hello. My name's Christopher 

17 Lau. I'll be presenting the Manufacturer Impact 

18 Analysis. So the purpose of the MIA is to assess the 

19 impacts of the standard on pump manufacturers 

20 evaluated as an industry. The second purpose is to 

21 identify a qualified impact on the manufacturers 

22 subgroups, such as small business manufacturers, and 
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1 the final portion of MIA involves discussion of 

2 direct employment, potential capacity constraints and 

3 other federal regulations that go into effect around 

4 the compliance at this standard. 

5 Our slides don't cover all this content 

6 today, but all these issues are reviewed and analyzed 

7 in the notice, as well as in the TSD. The primary 

8 tool used in the MIA is the Government Regulatory 

9 Impact model, also known as the GRIM. It is a cash 

10 flow model used to represent the industry as a whole. 

11 The major output of the model is the 

12 Industry Net Present Value or INPV. It's a metric 

13 used to succinctly quantify the impacts of the 

14 standard on the industry. We also conduct interviews 

15 to validate inputs and refine assumptions using the 

16 GRIM, and to better understand qualitative issues. 

17 Here we present the GRIM and INPV results. 

18 The second row shows the INPV for the base case or 

19 the no standards case and the five trial standard 

20 levels that were considered. We see a range of 

21 results, because of two different manufacturer 

22 markups. As Dan had described earlier, there's the 
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1 flat pricing scenario as well as the cost recovery 

2 scenario. 

3 In general, the lower bound is the flat 

4 pricing scenario and the higher number in that range 

5 is the cost recovery scenario, because manufacturers 

6 raise their prices and that results in more revenue, 

7 and their attempt to recover their conversion 

8 investments. 

9 The bottom row of this is the change in -- 

10 percent change in INPV. It's the same numbers show 

11 as percent change from the base case. TSL-2 is 

12 highlighted, today's proposed standard as you can 

13 see. The range of potential results is a negative 30 

14 percent to a 7 percent, positive 7 percent increase 

15 in industry value. 

16 DOE identified 25 domestic small 

17 manufacturers that produced covered equipment. Most 

18 of these companies produced covered pumps as well as 

19 pumps that fall outside the scope of coverage. On 

20 average, DOE found that roughly 24 percent of product 

21 offerings from small manufacturers were covered 

22 equipment. 
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1 DOE did identify at least one small 

2 manufacturer that produced, exclusively produced 

3 pumps covered by today's proposed rule. We located 

4 the portions of business that were -- that produced 

5 covered pumps. DOE found that impacts were 

6 comparable for small versus large manufacturers. 

7 This conclusion was based on available public data, 

8 which in many cases was a little bit limited. 

9 In the notice, we request comment on the 

10 number of small manufacturers producing covered 

11 equipment on the market share and product offerings 

12 from these manufacturers, on the cost of their 

13 hydraulic redesign and their cost of the capital, to 

14 help us refine the analysis further. 

15 In addition to MIA, there were several 

16 other downstream analyses done at the NOPR stage. 

17 They're listed here and they include the LCC subgroup 

18 analysis, the emissions impact analysis, the emissions 

19 monetization analysis, utility impact, employment 

20 analysis - which is indirect employment, as well as 

21 the regulatory impact analysis that looks at 

22 alternatives to today's regulation, proposed 
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1 regulation. 

2 I think at this point, I hand the baton 

3 off to Ms. Armstrong. 

4 CHAIR BROOKMAN: Ashley Armstrong. 

5 MS. ARMSTRONG: Okay. We're on the home 

6 stretch, what everyone's been waiting for. Here are 

7 the proposed standard levels for the various 

8 equipment classes of pumps. We'll show them on the 

9 slide. These are the standard levels specifically 

10 that were negotiated by the committee without change. 

11 As you can see, the index is the one value and 

12 obviously that's dependent upon the C values in the 

13 table. 

14 So I will ask for comments on the actual 

15 proposed standard, fully supportive comments or any 

16 concerns you might want to raise at this time. 

17 MR. HANDZEL: See, you're kind of going at 

18 this a little bit differently Ashley. We were 

19 expecting all the questions like we did this morning, 

20 and we had answers prepared on the questions, and 

21 we're not really reviewing the questions so -- 

22 MS. ARMSTRONG: Okay, we can get there. 
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1 You can chime in if you have answers. But don't you 

2 want to first state at the outset that you may 

3 support these levels as they're shown on the slide? 

4 MR. FERSTROM: So this is Gary for the 

5 California IOUs. Being that what you recommended 

6 aligns with what the working group recommended, we 

7 support it. 

8 CHAIR BROOKMAN: Thank you. Mark Handzel. 

9 MR. HANDZEL: And I think you heard from 

10 Al's statement this morning, his opening comments, 

11 that we do as well. 

12 MS. ARMSTRONG: Great, thank you. 

13 CHAIR BROOKMAN: Thank you. 

14 MR. ECKMAN: Tom Eckman. To echo Gary's 

15 endorsement from the advocate's position, we think 

16 you wrote down the same numbers we agreed to. So 

17 that's a good thing. 

18 MS. ARMSTRONG: That isn't always going to 

19 happen. 

20 (Simultaneous speaking.) 

21 MR. ECKMAN: It doesn't always happen that 

22 way, so great follow through. 
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1 CHAIR BROOKMAN: Okay, thank you. 

2 MS. ARMSTRONG: Thank you. 

3 CHAIR BROOKMAN: I think it's worth noting 

4 that Tom and Al were kind of leaders of caucus groups 

5 that represented the majority of the negotiators. So 

6 their specific comments today are relevant, even in 

7 this proceeding. Ashley. 

8 MS. ARMSTRONG: Okay. So just moving 

9 forward to the next one, which is the labeling 

10 requirements. So this is a recommendation that came 

11 out of the working group, which is a request for DOE 

12 to actually propose a label for equipment. So these 

13 are the labeling requirements, and are proposed to be 

14 applied to marketing materials, as well as the name 

15 plates on the actual pump itself. 

16 They include different things for whether 

17 it's a bare pump, a bare pump plus motor, I guess 

18 it's more or less the same thing, or a bare pump, 

19 motor and controls, depending on what is shipped. 

20 All essentially start from a pump. 

21 CHAIR BROOKMAN: Mark Handzel. 

22 MR. HANDZEL: So Ashley, I'm not sure if 
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1 you were in the working group when this was 

2 discussed, but we just want to just reconfirm that we 

3 sell pumps to our distributors, and typically it's 

4 common for them to rebuild, rework that pump and trim 

5 the impeller. So we just want to make it known that 

6 we have occasions when we sell pumps without an 

7 impeller diameter noted, because when it's, you know, 

8 officially prepared to be sold, the distributor notes 

9 the impeller diameter that he's actually providing. 

10 So it's just a small exception. It's one 

11 that's covered, and we discussed the fact that some 

12 of our distributors, you know, manufacture as well. 

13 So it's just a point of clarification, that we aren't 

14 always the one putting that impeller diameter on the 

15 name plate. 

16 CHAIR BROOKMAN: Are they going to put the 

17 impeller diameter -- 

18 MR. HANDZEL: Absolutely, absolutely. 

19 CHAIR BROOKMAN: --on the name plate? 

20 MR. HANDZEL: Absolutely, yes. 

21 CHAIR BROOKMAN: Okay. 

22 MS. ARMSTRONG: Okay. I think that's an 
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1 important clarification. My mind's kind of working 

2 on how that might be implemented. 

3 MR. HANDZEL: Yeah, and just to give you, 

4 you know, end suction close coupled for examples. We 

5 sell kits, Ashley, so we don't, you know, we put all 

6 the pump parts in a box, and our distributor would 

7 buy a motor locally and put it together, to maybe 

8 satisfy a quick lead time request. So in that case, 

9 you know, they would be stamping the name plate to 

10 put the actual impeller diameter that they -- they 

11 will trim the impeller, you know. So they would put 

12 the actual impeller diameter on it. 

13 You know, so we would supply them a name 

14 plate in there that would have, for example, the full 

15 diameter PEI/CL on it, and then they would indicate 

16 the actual impeller diameter that they supply. 

17 CHAIR BROOKMAN: As they are your 

18 distributors and you have this relationship with 

19 them, you can expect them to be consistent and 

20 uniform in the application? 

21 MR. HANDZEL: Yeah. We give them our name 

22 plates, you know, with the blank spot on it for the 
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1 impeller diameter. 

2 CHAIR BROOKMAN: That's everything in DOE 

3 rules, right? 

4 MR. HANDZEL: Uh-huh. 

5 CHAIR BROOKMAN: Gary Ferstrom. 

6 MR. FERSTROM: So this is Gary. I think 

7 this all revolves around the term "sold." So sold by 

8 whom, and I'm sure that all the necessary information 

9 will be there when the product is sold to the 

10 ultimate consumer or user. 

11 CHAIR BROOKMAN: Okay, okay. Louis. 

12 MR. STARR: So this is less about the 

13 technical aspects of it, but one of the things I 

14 would like to say that in terms in the standards that 

15 we came up with, also combined with this labeling 

16 requirements is, I think, an opportunity for utility 

17 programs and standards to work together, to get a lot 

18 more energy savings. 

19 So I think it -- and also I would also say 

20 Hydraulics Institute, without their support, in kind 

21 of how a pump is defined is very important. So I 

22 think in this particular rulemaking, this is a pretty 
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1 good example of where all the parties came together 

2 in the interest of saving energy, but also that works 

3 with industry in terms of the outcome. I think it's 

4 a good precedent for other rulemakings as well. 

5 CHAIR BROOKMAN: Thank you Louis. 

6 MR. FERSTROM: So this is Gary. I second 

7 that. 

8 CHAIR BROOKMAN: Thanks to both of you. 

9 Okay. So additional comments on the labeling 

10 requirements? That was a useful comment, Mark. 

11 Additional thoughts on this? 

12 MR. HANDZEL: We found the labeling 

13 requirements to be consistent to the agreement in the 

14 working, you know, from the working groups to the 

15 term sheet. So we're good. 

16 MS. ARMSTRONG: Okay, thank you. Okay. 

17 Lastly, we're going to talk about certification 

18 requirements, and what this includes, and it's a 

19 topic that Louis brought up earlier, and we haven't 

20 -- I haven't put all the data specifically on the 

21 screen. But there is a substantial number of 

22 paragraphs in Part 429. But what this includes is 
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1 the data that you will actually report to the 

2 Department once you have to comply with standards. 

3 So as you know, we used an Excel-based 

4 template. You have to submit electronically through 

5 CCMS, and these certification requirements would be 

6 applicable to all the models that you're distributing 

7 in commerce in the U.S., and you would have to submit 

8 them before distribution in commerce in this case, 

9 with compliance date with standards, and then 

10 annually thereafter. 

11 So here are some of the elements of the 

12 certification report. Like I said, they're not all 

13 on there. You can look at the red text. But this is 

14 generally the type of information that you would be 

15 submitting to the Department. 

16 CHAIR BROOKMAN: Mark. 

17 MR. HANDZEL: Ashley, I mean this is like 

18 you said. It's all per the term sheet. So I mean 

19 there's no issue. Obviously, none of us work with 

20 this database now, have no experience with it. So 

21 certainly we would expect some training or something 

22 in the future as to what -- 
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1 MS. ARMSTRONG: We're going to become good 

2 friends. 

3 MR. HANDZEL: Right, good. I'm afraid of 

4 that. 

5 CHAIR BROOKMAN: Louis. 

6 MR. STARR: So this is Louis Starr. 

7 MR. HANDZEL: And let's just ask one 

8 question, and we've kind of heard this a little bit 

9 from Louis this morning. When we were talking about 

10 the calculator, you know, do we put the data in and 

11 your system calculates the PEI/CL? Or are we 

12 supposed to calculate it and we manually input it? 

13 MS. ARMSTRONG: Yes. 

14 MR. HANDZEL: Okay, so you can understand 

15 why we want the calculator then, okay? 

16 MS. ARMSTRONG: Okay. So we might as well 

17 just jump right to that issue. 

18 MR. HANDZEL: We need to get there, so -- 

19 MS. ARMSTRONG: So let's discuss the 

20 calculator. 

21 CHAIR BROOKMAN: Louis had a question. 

22 MS. ARMSTRONG: Oh, you wanted to talk 
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1 about certain -- 

2 MR. STARR: Yeah. Well, just a little 

3 bit. But we can get into calculator right after 

4 that. 

5 MS. ARMSTRONG: That's going to be a hot 

6 topic. 

7 MR. STARR: Yeah, the one thing is the 

8 inputs that -- so it sounds like basically just a 

9 blank sheet that they're putting their information 

10 in. It really would be helpful for the driver input, 

11 HP at each load point, that that to show up in the 

12 certification database, so when Gary or someone else 

13 runs their program, they can look at those load 

14 points. 

15 Because they may be how they rebate. It 

16 depends upon the values at each one of those load 

17 points. So they need to know that information, and 

18 we need to have 500 pumps. You don't want to go out 

19 and manually do that. So if you can just point them 

20 out of the DOE manual or to the DOE certification 

21 database, and then the program manager can also go 

22 and get that same information, pull it down, run it 
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1 through his utility program. So that was one thing 

2 I saw. But we'll look -- 

3 CHAIR BROOKMAN: Joanna, you had a comment 

4 earlier that's consistent, and going in this 

5 direction I believe. 

6 MS. MAUER: And I would just add, I think 

7 that was certainly our intent. I don't remember the 

8 exact language that we put in the term sheet. But of 

9 course it doesn't do utilities any good to just have 

10 it in the certification reports if it's not also 

11 publicly available. 

12 MS. ARMSTRONG: So I will clarify that on 

13 Part 429, the information that we propose to collect 

14 for certification would be public. So if there's 

15 elements of that should or shouldn't be, if there are 

16 any issues with that information that we would 

17 collect broadly, at least the product-specific 

18 information would be public. There are certain, I 

19 think, across the board information that does not get 

20 passed through. 

21 MS. MAUER: Okay, thank you. 

22 CHAIR BROOKMAN: Mark Handzel. 
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1 MR. HANDZEL: Well I just, you know, 

2 coming back to the calculator, you know obviously 

3 this group of manufacturers and our HI members that 

4 participated worked with previous versions of the 

5 calculator. As we were working through the working 

6 group, we found it very useful. We found it 

7 eliminated a lot of, you know, questions, 

8 interpretations. 

9 It was very straightforward. So we have 

10 been working under the assumption that we were going 

11 to get those calculators since last July and, you 

12 know, so we're saying, we still expect them. 

13 MS. ARMSTRONG: I'm going to come sit at 

14 the table for this discussion, take the jacket off a 

15 little. So calculator. So DOE's general approach to 

16 calculators -- well, let's talk about DOE's general 

17 approach to development of ratings is the accuracy of 

18 those ratings is on the onus of the manufacturer, you 

19 know. 

20 When you send in that cert report, you are 

21 signing a statement, a legally binding statement at 

22 that, saying you know, this information is accurate. 
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1 I have tested in accordance with the test procedure, 

2 etcetera, etcetera. 

3 Now DOE does not provide DOE-approved 

4 simulation models, calculation models, calculators or 

5 anything like that, that it's willing to say, you 

6 know, all manufacturers use this specific tool to 

7 calculate your ratings, and then send it back to us. 

8 That's not -- that's something we've 

9 declined to do. We've been asked to provide, in 

10 other contexts what we call AEDMs, which are actual 

11 simulations of our test procedure rather than actual 

12 testing, and we decline to do that as well. 

13 That onus is -- the regs allow their use, 

14 but that onus is on the manufacturer. They can 

15 develop them as they want. They must be done in 

16 accordance with the regs, etcetera, etcetera. That 

17 being said, I think DOE is willing to entertain 

18 providing a public version of the calculator in this 

19 instance. However, if you are to use that 

20 calculator, there will be some caveats on it that 

21 says, you know, its accuracy in determining your 

22 ratings is on you, you know. 
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1 It's not going to be a DOE kind of 

2 calculator that you're thinking of, in terms of you 

3 put in your test data, it outputs something and it's 

4 DOE approved as a rating. DOE does not approve certs 

5 per say or the accuracy of ratings. You submit the 

6 ratings, you submit the certification report and we 

7 go from there. 

8 I think DOE understands the value of the 

9 calculator. Obviously we, the collective we, worked 

10 hard on developing the calculator. We would like to 

11 work with you, to make sure that the calculator is 

12 QC'd from our perspective and your perspective. We 

13 are willing to provide a version for use, just like 

14 we do -- so I don't know if you're familiar with our 

15 test data templates. 

16 If we test a product for verification or 

17 enforcement at a third party lab, we make them use 

18 our test data templates, which has some execution of 

19 our procedures in it, and those are publicly 

20 available online. So it would be similar. If you go 

21 ahead and use those though, the accuracy of those 

22 ratings is still going to be on you. 
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1 CHAIR BROOKMAN: Mark. 

2 MR. HANDZEL: Thank you. Ashley, I mean 

3 we worked closely with the DOE and your consultants 

4 to develop those calculators, and this group around 

5 the table, we're not the ones we're worried about, 

6 okay. We want to make this simple and easy for 

7 everyone in this business to understand, and we just 

8 feel that that's a very straightforward way to 

9 communicate. 

10 So I mean understand we're not trying to 

11 be difficult. We're just saying help us communicate 

12 this. There are many, many pump manufacturers 

13 outside of our membership that we have tried to get 

14 involved and to communicate with on what was going on 

15 here, and they aren't paying attention. So we think 

16 it will help you communicate with them as well, and 

17 get them to pay attention. So thank you. 

18 MS. ARMSTRONG: So I think we'll work 

19 through that with you guys, specifically offline and 

20 then once we do make it available, you will see some 

21 language crafted by my dear friend sitting next to 

22 me, with some caveats around it, in terms of it's 
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1 commercial use types of things. Okay. 

2 CHAIR BROOKMAN: We have a few questions 

3 from those joining us online. Rob Mulaney asks when 

4 is the revised PEI calculator Excel going to be made 

5 available to pump manufacturers? We didn't establish 

6 a time frame, I don't think. 

7 MS. ARMSTRONG: I mean I think we are 

8 doing our due diligence in terms of some QC first. I 

9 think what we will also do before we make it publicly 

10 available is maybe share a version with HI, to ask 

11 them to do the same, go back and forth I guarantee 

12 about an issue or two probably before we make it 

13 public. 

14 But it will be in the near term. I don't 

15 know that you necessarily -- well, I guess the 

16 question for you, do you really need it to comment on 

17 the standards, since you in theory negotiated it? 

18 MR. HUBER: If by saying yes we'll get it 

19 sooner, yes. But -- 

20 (Laughter.) 

21 MR. HUBER: But we want to be clear. What 

22 we're looking for is a CL calculator and a VL 
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1 calculator. So there will be two separate ones. 

2 MS. ARMSTRONG: Needy. Okay. I mean fair 

3 enough. We'll work through it. I understand that 

4 there's -- it's not going to be tomorrow, it's not 

5 going to be next year either. So we'll work through 

6 those issues. 

7 CHAIR BROOKMAN: Okay. Now we have 

8 another question from online. Thomas Haan asks is 

9 there a payback analysis for the end user, who will 

10 pay a higher price for the increased pump efficiency? 

11 MS. ARMSTRONG: The answer is yes. The 

12 specific results to that payback analysis are in the 

13 NOPR and in the TSD. 

14 CHAIR BROOKMAN: Okay. Yes, Peter. 

15 MR. GAYDON: Just a comment from the 

16 Hydraulic Institute, that we would be, you know, 

17 willing to convene a committee to work on the 

18 calculator with the Department of Energy, to aid in 

19 that process. 

20 MS. ARMSTRONG: Great. How fast does your 

21 committee work? 

22 MR. GAYDON: That -- it depends. 
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1 (Laughter.) 

2 MS. ARMSTRONG: I know the feeling. 

3 CHAIR BROOKMAN: Okay. 

4 MS. ARMSTRONG: So I did want to note one 

5 thing, and this has to do with some language, some 

6 general language that well, it is not necessarily 

7 directly applicable to this particular proceeding; 

8 is part of the working group kind of recommendations 

9 and scope. 

10 So DOE did just, you know, issue a request 

11 for information, starting the process for dedicated 

12 purpose pool pumps. We specifically asked for 

13 comments about voluntary programs, regulatory 

14 programs, scope, test procedures, ratings, metrics 

15 and data need. So this would be the first you're 

16 seeing, the kickoff for that process starting, and we 

17 plan to move forward with that. 

18 So we just wanted to bring it to your 

19 attention, and just acknowledge that we held up our 

20 end of the bargain here. 

21 CHAIR BROOKMAN: Thank you. 

22 MR. FERSTROM: So this is Gary. As we 
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1 discussed earlier, the presence or absence of the 

2 integrated basket strainer may not be the key 

3 differentiating feature here. 

4 MS. ARMSTRONG: Correct. So we look 

5 forward to getting those comments and, like I said 

6 earlier, I fully expect that definition to be revised 

7 in this process, as we learn more about all the 

8 different aspects of pool pumps. Really the purpose 

9 of or the need for some type of definition now is to 

10 establish that kind of carve-out. 

11 CHAIR BROOKMAN: Yes, Rob. 

12 MR. BOTELER: Rob Boteler, NEMA. In 

13 looking at your definitions, it's going to be the 

14 suction pump that you're going to be regulating. Are 

15 you planning to also include the motor and the 

16 control? 

17 MS. ARMSTRONG: I think generally 

18 speaking, that was the intent of the working group. 

19 MR. BOTELER: So it really becomes -- 

20 MS. ARMSTRONG: Because the pump as a 

21 whole is defined as the pump, motor and controls for 

22 purposes of coverage. So any definitions falling out 
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1 from that would also -- would fall back to that 

2 coverage definition, which include all three. 

3 MR. BOTELER: So NEMA could -- should 

4 probably treat this really as a motor regulation, as 

5 much as I -- 

6 MS. ARMSTRONG: NEMA can treat this 

7 however they'd like to characterize it. It is a pool 

8 pumps rulemaking. 

9 MR. FERSTROM: This is Gary. We're 

10 probably getting ahead of ourselves here, but some 

11 products will be just pumps and motors, and some 

12 products will be pumps, motor and integral drives or 

13 controls. 

14 MS. ARMSTRONG: Just like they were today. 

15 CHAIR BROOKMAN: Yes, Paul. 

16 MR. RUZICKA: I just wanted to mention the 

17 fact that the testing at 40.6 doesn't care whether 

18 it's a pool pump or any other pump. 

19 So depending on how the regulation is 

20 written and what are the output metrics, and I would 

21 assume they're similar or going to be quite similar 

22 to what was worked with on the industrial clean water 
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1 pumps, that we would have no problem with using 40.6. 

2 CHAIR BROOKMAN: Yes, Mark. 

3 MR. HANDZEL: But just to follow on, that 

4 just much like we found with the circulator product 

5 description, you know, the Hydraulic Institute has no 

6 definition for pool pumps. We have no product 

7 classification, we do not collect data on pool pumps. 

8 So you know, this is going into another 

9 one of those new frontiers that will require, you 

10 know, a committee, and you don't necessarily have the 

11 right people at the table, you know, to be having 

12 that discussion. We tried to get them interested in 

13 HI membership, but wasn't fully successful. 

14 MS. ARMSTRONG: So I will say one thing. 

15 Sorry Gary, let me chime in here. So this shows you 

16 our intent to initiate a rule and to go forth with 

17 our analysis independent of a working group. That 

18 being said, we're always open to working group 

19 formations, but we would need the parties, if they 

20 were interested, to come together and formally 

21 request that. 

22 But this shows you that our, you know, 
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1 two-three year process has started. That time clock 

2 has started. 

3 MR. FERSTROM: So this is Gary. 

4 California, EnergyStar and other states have already 

5 adopted some pool pump efficiency regulations that 

6 really aren't very consistent with what's been 

7 adopted for commercial-industrial pumps in general. 

8 So I wouldn't want to preclude considering 

9 the approach that has already been taken by others, 

10 in addition to alternative approaches that DOE might 

11 consider. 

12 CHAIR BROOKMAN: Okay. 

13 MR. HANDZEL: Gary, just a question on 

14 that. I thought you clarified for us in the working 

15 group that they weren't pump efficiency-related. 

16 They were pool pump motor-related. Is that my 

17 misunderstanding? 

18 MR. FERSTROM: No. It's the whole thing. 

19 It's gallons per watt hour. So you've got a metric 

20 that includes both the pump performance and the motor 

21 performance in a prescribed system. So the system 

22 curve on which those measurements are taken is 
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1 specified. 

2 CHAIR BROOKMAN: Rob, did you want to 

3 comment here? 

4 MR. BOTELER: Yeah. I would just say as 

5 someone who worked with the working group, it's nice 

6 to see the Department of Energy crosses their T's and 

7 dotting their I's, and really following through on 

8 some important issues for the working group. That's 

9 excellent. 

10 CHAIR BROOKMAN: So then moving to, I 

11 believe, closing remarks. 

12 MS. ARMSTRONG: So I'm going to put this 

13 up, but I know you have a list of questions and 

14 potentially clarifications that you may want to do 

15 it. This would be a good time to walk through those 

16 if you'd like to now. 

17 MR. HANDZEL: So Ashley, we've reviewed 

18 our list. Mark Handzel, Xylem, and you know, we've 

19 covered the key ones that we felt were important to 

20 cover today. 

21 MS. ARMSTRONG: Okay. 

22 MR. HANDZEL: So certainly we will cover 
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1 all of them in our written comments. But I think the 

2 key items have been addressed. 

3 MS. ARMSTRONG: Okay, great. Well, I'm 

4 going to open the floor for any closing remarks for 

5 anyone that would like to make them, and then 

6 obviously we would like to thank you all for coming. 

7 CHAIR BROOKMAN: And then just to clarify 

8 Mark, those -- all those items, you're going to 

9 include those in your written comments? 

10 MR. HANDZEL: Yes. 

11 CHAIR BROOKMAN: Okay. So let's take 

12 closing remarks at this time. Tom Eckman. 

13 MR. ECKMAN: Yeah. I'd like to thank the 

14 Department for moving forward on pool pumps. That 

15 certainly was another element that we had hoped that 

16 we could address through this rulemaking process, and 

17 we have pretty much concluded, touched base on every 

18 one of the elements of the term sheet, save for one. 

19 We're still working on circulators. 

20 I'd like to make sure that we and the 

21 manufacturers continue to pursue that with haste. I 

22 understand from both our side of the table and your 
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1 side of the table, we have great empathy for the 

2 bandwidth limitations you have. You see here before 

3 you more than half of the advocates, and we are 

4 called in every one of these rulemakings. So we 

5 understand the problem. 

6 MS. ARMSTRONG: If it makes you feel 

7 better, I'm involved in every one of these 

8 rulemakings. 

9 MR. ECKMAN: Yes, but this turned out to 

10 be your full-time job. We have many others. 

11 MS. ARMSTRONG: That could be argued. 

12 MR. ECKMAN: So I want to make sure that, 

13 you know, we move with haste on that one. We would 

14 recommend that the manufacturers, you know, take 

15 advantage of the contractor assistance that DOE's 

16 made available, to help move things as quickly as 

17 possible, and we had hoped that we could be in better 

18 and closer communication with you on where things 

19 stand on a more regular basis. 

20 I know you have multiple meetings and 

21 things like that, and this clearly, for the ones in 

22 the -- for the folks in the room dominate your 
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1 agenda, and we have sympathy for that. But we'd like 

2 to see, you know, we were hoping that we'd have 

3 something by early this year to start talking about 

4 in detail. It's getting to be a year from the time 

5 we agreed on the last one, and that to us is -- it's 

6 not that we're thinking you're laggards. 

7 It's just we'd like to move on this and 

8 get it done, so that we can get as close as possible 

9 synchronization between this rulemaking and what 

10 might come out of circulators. So that's sort of our 

11 hope, that we move forthwith on this agenda and not 

12 to impugn your integrity. I think it's where we 

13 understand the depth of discussion they'd have to go 

14 through to make this happen. 

15 But we'd like to be -- have engagement 

16 move as fast as possible on it and be done with it. 

17 I'm sure you would too. 

18 CHAIR BROOKMAN: Al. 

19 MR. HUBER: Well on behalf of the 

20 Hydraulic Institute, I would like to thank the EE 

21 NGOs and the Department of Energy for their 

22 cooperation, and I think this is a very good effort for 
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1 our industry, and I think it is for the country as a 

2 whole. I think we'll all benefit from it in the end. 

3 It hasn't been easy, but I think it's been 

4 profitable. 

5 I would like to say Tom that we certainly 

6 are pursuing this. It's not that we're not pursuing 

7 this on the circulators, and actually we're meeting 

8 no less than twice a month and sometimes more than 

9 that. We're starting with a product that we had no 

10 data on, a product that we had no definition on, and 

11 now we find out our definition that we finally after 

12 months of work is not satisfactory to DOE. 

13 So I, you know, we're working on it, and 

14 we'll continue to do that, and we will commit to try 

15 to give you at least monthly updates, at a minimum 

16 exactly where we are and what we're doing. Right 

17 now, we're in a data acquisition mode, to try to get 

18 some additional data that we think would be 

19 beneficial to be able to come up with a rulemaking. 

20 So we're after that. So I mean we do have 

21 the key players in the industry. Some of them are at 

22 the table today. So we'll get there, but it does 
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1 take time. When we were faced with two NOPRs that 

2 are over 400 pages apiece, and we had to concentrate 

3 on trying to get ready for this and we'll have to 

4 concentrate now on writing our letters and doing our 

5 thing. 

6 So we should have a little extra time 

7 maybe, after we get through this. Thank you. 

8 MR. FERSTROM: So this is Gary. I'd like 

9 to thank DOE and everybody involved in the process 

10 coming at this conclusion for commercial-industrial 

11 pumps. I second Tom's point. I'm delighted that 

12 DOE's moving forward with swimming pool pumps. We 

13 need to get going on circulators, and I think the 

14 whole collective effort will be more efficient and 

15 productive if we have DOE and its consultants' 

16 assistance with it. 

17 So we'll work with HI, to see if we can't 

18 collectively request of ASRAC a working group to 

19 address this. I fear that if we proceed on our own, 

20 there will be a little miscommunication and a little 

21 wasted effort, and when we all get together 

22 collectively, we'll have to redo some things. So 
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1 best to get together as a group sooner rather than 

2 later. 

3 CHAIR BROOKMAN: Yes, Louis Starr. 

4 MR. STARR: This is Louis Starr of NEEA. 

5 Actually that was kind of one of my concerns, what 

6 Gary brought up. I'm concerned that if we come up 

7 with a regulatory frame that doesn't really meet what 

8 it needs, we get into collecting a lot of data that 

9 you just have to go back out and recollect. 

10 So I'm kind of wondering if some more 

11 structure inside of what we're trying to do, similar 

12 to when we're setting levels for the other ones. It 

13 was -- there was problems with the calculator right, 

14 and then we went back and forth. But without that 

15 interaction on what could be done, it's sort of 

16 there's so many what-ifs that if you proceed down the 

17 road too far, you're pretty easy to get astray. 

18 So I'm wondering if the context of the 

19 negotiations around the circulators might make sense 

20 to be inside of more of a feedback loop with DOE. 

21 But I think we can discuss that. But also, I don't 

22 really know what DOE's, what's the word, bandwidth on 
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1 doing anything more, or what their capabilities are 

2 or are not around this, and would be interested in 

3 knowing that. 

4 MR. FERSTROM: Well just to add to your 

5 point, I think we identified in the working group the 

6 enormous, relatively speaking, savings potential 

7 associated with circulators. So we should not let 

8 that opportunity go unrecognized. 

9 CHAIR BROOKMAN: Okay. Rob Boteler. 

10 MR. BOTELER: Yeah. I would just comment. 

11 We are -- we have started down the path of what we 

12 finally refer to as Small Motor II, and Small Motor 

13 II is a regulation that we wanted -- well we think; 

14 these guys don't know this yet -- the discussion, 

15 right, one-sixth through three horsepower and it's -- 

16 we haven't really locked in on the technology. 

17 So I think there's going to be an awful 

18 lot of overlap if we start to look at PFCs and SCs 

19 and ECMs and some of these other products that are 

20 used in pool pumps and in circulators. John has had 

21 some comments with us, some conversations about 

22 double regulation, and we at Nidec are not 
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1 necessarily opposed to double regulation. 

2 But I think we need to be really paying 

3 attention to what's going on in both rulemakings, to 

4 make sure that when we regulate the product in the 

5 small motors, the second round of small motors, that 

6 we're consistent with what we want to see in the pool 

7 pumps and the circulators. 

8 CHAIR BROOKMAN: Okay. 

9 MR. FERSTROM: So this is Gary, and the 

10 work on motors is good and we're delighted to see it. 

11 But when motors are applied with pumps and fans, I 

12 think especially in those small horsepower ranges, we 

13 see system effects that are important, and the 

14 circulator pump work and the pool pump work I think 

15 is better able to capture those system effects than a 

16 motor regulation alone. 

17 CHAIR BROOKMAN: Okay. Final remarks 

18 then. 

19 MS. ARMSTRONG: Yeah, I'm going to answer 

20 your question. 

21 MALE PARTICIPANT: Oh no. 

22 MS. ARMSTRONG: I was going to let Doug go 
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1 with it. So it's your question about bandwidth. I 

2 mean I think that we've initiated it for pool pumps. 

3 So you know that with that RFI, you see DOE's 

4 commitment to start that process. 

5 So to the extent that becomes a request 

6 for a negotiated rule, obviously we fully support 

7 that effort. If you are going to request that, we 

8 would provide the associated stuff that goes along 

9 with that, assuming that ASRAC also agrees and 

10 there's a general support from both sides. 

11 In the cases where ASRAC hasn't agreed, 

12 typically it's been because there's not a general 

13 support from multiple sides from multiple angles at 

14 the table. Do you want to say something, because 

15 it's really your program? 

16 MR. CYMBALSKY: Not really -- 

17 MS. ARMSTRONG: I'm just speaking for you. 

18 MR. CYMBALSKY: This is John from DOE. 

19 But what I will say regarding the circulators, my 

20 recollection was that that effort was going to be 

21 held outside the bounds of negotiated rulemaking, but 

22 more of a consensus among the manufacturers and the 
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1 stakeholders. That was my recollection. 

2 However, if you want to take a different 

3 path through ASRAC in the formal negotiation, of 

4 course DOE supports that sort of behavior. 

5 MR. FERSTROM: So this is Gary. I concur 

6 with your recollection. However, I think we're 

7 finding that pursuing this without DOE's assistance 

8 could lead to inefficiencies and be more difficult 

9 than maybe we originally thought. So it would again 

10 probably be better and more efficient if we could get 

11 DOE's assistance. 

12 MR. CYMBALSKY: I mean, and so by 

13 assistance, there's, you know, we can have our 

14 consultants help out on technical expertise outside 

15 of the formal negotiation, where FACA rules come into 

16 play and DOE is at the table. So either way, but 

17 that's up to you guys to decide. We support either 

18 path. 

19 MR. FERSTROM: Thank you. 

20 MS. ARMSTRONG: Yeah. So I'm just going 

21 to -- does anybody else want to say anything in 

22 closing? 
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1 MR. GAYDON: Yeah. Peter Gaydon with the 

2 Hydraulic Institute. You know, I echo the sentiments 

3 from everyone. Thank you. I think it was a good 

4 meeting and a good process. One final request is 

5 that we can have access to the slide deck from today. 

6 MS. ARMSTRONG: It will be in the docket, 

7 that same docket where you can find the TSD. So 

8 we'll connect after, and I'll show you. 

9 (Off mic comments.) 

10 MS. ARMSTRONG: We usually put it in there 

11 tonight or tomorrow. 

12 FEMALE PARTICIPANT: It's already up. 

13 MS. ARMSTRONG: Oh, it's already up. 

14 CHAIR BROOKMAN: It's already in there. 

15 MR. GAYDON: Thank you. 

16 CHAIR BROOKMAN: Okay, good. 

17 MS. ARMSTRONG: So I just want to close by 

18 saying thank you all for participating today. I know 

19 there were a couple of sticky issues in the morning, 

20 especially with regards to the test procedure and 

21 definitions, that you guys are going to take back and 

22 look in. As you discuss some of those, if you want 
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1 to have more discussions with the Department about 

2 that, let me know. We'd welcome such opportunity. 

3 You know, we have procedures in place for 

4 doing that stuff. So I just wanted to close with 

5 this, is how to submit written comments. We look 

6 forward to getting all of your written comments and 

7 any other suggestions you may have. So safe travels 

8 home. 

9 (Whereupon, at 3:46 p.m., the afternoon 

10 meeting was adjourned.) 

11

12

13

14

15

16

17

18

19

20

21

22
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A

able 4:6,8 39:10

76:19 80:15

absence 68:1

absolutely 42:13

53:18,18,20

access 4:7 83:5

account 25:3,6 26:7

26:9 32:16 33:16

33:22 44:18 45:5

45:7,14,16

accuracy 61:17

62:21 63:5,21

accurate 20:8 61:22

acknowledge 67:19

acquisition 76:17

actual 10:1 39:15

44:18 50:14 52:15

54:10,12,16 62:10

62:11

add 60:6 79:4

addition 15:22

25:18 49:15 71:10

additional 8:17 22:2

56:9,11 76:18

address 4:7 14:12

73:16 77:19

addressed 73:2

adequate 40:10

adjourned 84:10

adjustments 34:5

34:17 46:2

Admittedly 40:5

adopted 71:5,7

advantage 74:15

advocate's 51:15

advocates 74:3

AEDMs 62:10

AEO 29:14 32:7

37:3

affect 20:6 23:8

34:21 35:18 42:19

affiliation 6:3

afraid 58:3

afternoon 4:11 8:8

9:3,15 84:9

afternoon's 9:8

agenda 8:8 75:1,11

agreed 51:16 75:5

81:11

agreement 56:13

agrees 81:9

agriculture 31:21

31:22

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aid 66:18

Al 6:18 40:12,13

52:4 75:18

Al's 51:10

Albert 2:7

Alex 2:20 7:22

aligns 51:6

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37:10,19

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allow 62:13

alternative 71:10

alternatives 49:22

America 2:22

analyses 8:14 49:16

analysis 8:11,13,13

8:14 10:12,14,21

11:4,19,22 14:9

16:4,10,21 17:1,7

19:20,21 22:5,13

22:16 24:7,11,18

26:3,8,11,18

29:10,13 31:7,8,9

32:13 33:14 36:22

41:16 43:10 44:4

44:14,21 45:19

46:18 49:14,18,18

49:19,20,21 66:9

66:12 70:17

analytical 14:8

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analyzed 17:11

23:10 47:6

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25:1

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8:4

angles 81:13

Aniruddh 2:12 35:2

annual 25:10 30:5

31:17 32:16 34:1

46:10

annually 57:10

answer 66:11 80:19

answers 50:20 51:1

anybody 4:5 8:17

34:21 82:21

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apologies 4:3 5:17

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applicability 9:12

10:1

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67:7

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28:10 40:21 54:20

applications 35:8

38:3

applied 23:17 24:5

35:6 52:14 80:11

apply 23:18

approach 17:14

20:10 29:4 61:15

61:17 71:9

approaches 71:10

approve 63:4

approved 63:4

approximately 30:1

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areas 42:17

argued 74:11

Armstrong 2:5,11

4:20,22 5:14,19

7:2,10,10 9:1,2

14:2,14 50:3,4,5

50:22 51:12,18

52:2,8 53:22

56:16 58:1,13,16

58:19,22 59:5

60:12 61:13 64:18

65:7 66:2,11,20

67:2,4 68:4,17,20

69:6,14 70:14

72:12,21 73:3

74:6,11 80:19,22

81:17 82:20 83:6

83:10,13,17

Ashley 2:5 7:10

8:22 11:8 12:1,8

14:15 50:4,18

52:7,22 54:5

57:17 64:2 72:17

asked 62:9 67:12

asking 39:15

asks 65:3 66:8

aspects 55:13 68:8

ASRAC 10:6 77:18

81:9,11 82:3

assess 10:22 46:18

assessment 15:10

asset 30:9

assigned 27:18,20

assigning 26:5

assistance 74:15

77:16 82:7,11,13

associated 20:21

27:5 79:7 81:8

associations 12:15

assume 26:3 34:1

36:9,19 69:21

assumed 26:10

33:19

assumes 25:7

assuming 29:2 81:9

assumption 34:7

61:10

assumptions 14:9

47:15

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astray 78:17

ATR 3:7

attempt 48:7

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67:19 80:3

Automation 2:8

availability 16:15

available 13:21

15:12 17:16 31:5

34:17 40:19 42:8

42:22 43:1 49:7

60:11 63:20 64:20

65:5,10 74:16

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average 19:4,11

20:12 29:22 30:7

30:20 31:2 33:15

34:8 48:20

aware 40:8

Awareness 2:9 7:5

awful 79:17

B

back 4:6 8:22 9:17

15:15 20:4 22:9

44:20 61:2 62:7

65:11 69:1 78:9

78:14 83:21

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78:22 81:1

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6:14

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52:17,17,18

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base 18:1,15 19:10

21:10,22 23:18,19

27:13 28:14 29:11

30:15,22 32:21

34:22 36:6,7,14

47:18 48:11 73:17

based 17:15,19,21

20:15 23:8 25:11

26:5 30:12,15

31:15 32:4 37:2,7

37:14 45:17,17

49:7

baseline 17:16

18:10 23:15,16

24:3 44:1,4

basically 19:6 20:10

21:21 23:3,6,12

24:8 25:7,18 26:1

26:3,9,18 27:3,13

28:8 29:2,7,10

30:4 31:6 32:6,20

34:7,12 36:21

39:14 40:2 43:12

59:8

basis 74:19

basket 68:2

baton 50:2

beginning 14:3

behalf 75:19

behavior 82:4

believe 8:7 35:21

60:5 72:11

believes 10:9

Beloit 2:22 6:6

beneficial 76:19

benefit 76:2

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44:15 45:2,6,17

45:18

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best 28:13 78:1

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better 47:16 74:7,17

80:15 82:10

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binding 61:21

binned 24:22

bins 25:2,2

bit 18:19 41:9 49:8

50:18 58:8 59:3

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board 60:19

Bob 6:14

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7:22,22

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Boteler 2:21 6:12,12

33:8,8,12 68:12

68:12,19 69:3

72:4 79:9,10

bottom 14:4 17:17

48:9

bound 22:2,11 48:3

bounds 81:21

box 54:6

break 8:21

Brent 2:11 7:2
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brief 17:12

briefly 12:4 19:17

bring 67:18

brings 15:3 16:9

broadly 60:17

broke 13:10

broken 14:17

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5:1,12,16 6:1,7

7:19 8:5 11:6

37:18 39:3,22

40:12 41:5 42:11

43:3,6 44:12

46:15 50:4 51:8

51:13 52:1,3,21

53:16,19,21 54:17

55:2,5,11 56:5,8

57:16 58:5,21

60:3,22 64:1 65:2

66:7,14 67:3,21

68:11 69:15 70:2

71:12 72:2,10

73:7,11 75:18

78:3 79:9 80:8,17

83:14,16

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46:22 49:4 64:7

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C

C 4:1 11:17 18:7,8

44:10 50:12

CA 3:6

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25:20 32:18 58:12

62:7

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calculations 28:3,7

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58:20 59:3 61:2,5

61:15 62:18,20

63:2,9,10,11 65:4

65:22 66:1,18

78:13

calculators 61:11

61:16 62:4 64:4

California 6:9,10,11

51:5 71:4

call 14:4 18:18

62:10

called 43:11 74:4

capabilities 79:1

capacity 47:2

capital 30:7,9 49:13

capture 80:15

captured 45:19

capturing 41:18

care 69:17

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carve-out 68:10

case 18:1,15 19:10

21:9,10,12,14,22

23:18,20,20 27:14

27:19 28:14,17

29:11,11 30:15

31:1 32:9,10,12

32:21,21 33:2,18

34:22 36:6,7,7,14

36:15 43:14 47:18

47:19 48:11 54:8

57:8

cases 32:12 49:8

81:11

cash 47:9

category 13:11

14:18 15:6 24:2

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cause 38:22

caused 5:18

caveats 17:2 62:20

64:22

cavitation 38:6

CCMS 57:5

Census 23:12

cert 61:20

certain 59:1 60:18

certainly 34:19 36:3

43:7 57:21 60:7

72:22 73:15 76:5

certification 8:16

56:17 57:5,12

59:12,20 60:10,14

63:6

certs 63:4

CFR 14:6

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chair 2:3 4:3 5:1,12

5:16 6:1,6,7 7:19

8:5 11:6 37:18

39:3,22 40:12

41:5 42:11 43:3,6

44:12 46:15 50:4

51:8,13 52:1,3,21

53:16,19,21 54:17

55:2,5,11 56:5,8

57:16 58:5,21

60:3,22 64:1 65:2

66:7,14 67:3,21

68:11 69:15 70:2

71:12 72:2,10

73:7,11 75:18

78:3 79:9 80:8,17

83:14,16

chairman 6:13

chance 5:5

change 11:18 29:8

29:10 35:12,21

36:11 44:18 48:9

48:10,11 50:10

changes 17:9 23:5

27:22 35:18 38:13

39:4 42:20 44:17

channel 24:4 28:16

channels 23:7,9

24:1

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characteristics

27:11 35:11

characterize 12:13

12:19 23:7 69:7

characterized 27:6

characterizing

24:13

charge 22:8

chart's 44:8

chime 51:1 70:15

choosing 25:8

chosen 31:1

Chris 3:4 5:12,14

46:13,15

Christopher 46:16

circulator 70:4

80:14

circulators 73:19

75:10 76:7 77:13

78:19 79:7,20

80:7 81:19

CL 65:22

clarification 53:13

54:1

clarifications 9:16

72:14

clarified 71:14

clarify 60:12 73:7

clarifying 5:2

class 30:2 43:13,17

44:10 46:7

classes 12:10 13:8

14:17 30:1,19

31:5 32:4 43:16

50:8

classification 70:7

clean 69:22

clear 65:21

clearance 42:18

clearances 15:20

42:17

Clearinghouse

23:14

clearly 74:21

clock 71:1

close 13:13 21:4

54:4 75:8 83:17

84:4

closely 64:3

closer 74:18

closing 8:15,15,18

8:18 72:11 73:4

73:12 82:22

Code 14:6

collect 60:13,17

70:7

collected 24:21

collecting 78:8

collective 63:9

77:14

collectively 77:18

77:22

combination 27:4

43:12

combined 21:4

55:15

come 10:5 20:22

33:15 39:18,20

61:13 70:20 75:10

76:19 78:6 82:15

comes 11:16 13:8

coming 61:2 73:6

77:10

commence 4:10

commenced 10:4

commencing 5:4

comment 22:21

34:19 36:3 40:5

41:15 42:10 49:9

56:10 60:3 65:16

66:15 72:3 79:10

comments 7:21

15:12 43:8 50:14

50:15 51:10 52:6

56:9 67:13 68:5

73:1,9 79:21 83:9

84:5,6

commerce 57:7,8

commercial 1:2

31:18,19 65:1

commercial-indus...

71:7 77:10

commit 76:14

commitment 81:4

committee 6:13

10:6 50:10 66:17

66:21 70:10

common 53:4

commonly 17:10

18:12

communicate 64:9

64:11,14,16

communication

74:18

companies 48:18

company 2:12,17

6:11,13 23:10

comparable 49:6

compares 33:1

complex 18:19

compliance 47:4

57:9

compliant 11:5,13

comply 57:2

components 15:20

concentrate 77:2,4

concerned 78:6

concerns 50:16 78:5

concluded 73:17

conclusion 49:7

77:10

concur 82:5

condensate 38:9

conditions 25:14

conduct 10:21 44:3

47:14

conducted 10:12

confidential 18:2

20:16

configuration 14:19

connect 83:8

consensus 81:22

conservation 5:11

10:15

conservative 4:13

22:14,14 29:3

consider 10:19

71:11

consideration 10:8

considered 17:4

22:1,11 24:10

47:20

considering 10:20

71:8

consistent 11:19

29:4 43:16 54:19

56:13 60:4 71:6

80:6

constant 14:22 15:8
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36:13

constraints 47:2

construction 31:22

consultants 64:3

82:14

consultants' 77:15

consumer 22:13

23:8 26:20 46:6

55:10

consumer's 26:19

consumption 24:9

44:19

contact 4:5

content 4:17 47:5

context 78:18

contexts 62:10

continue 73:21

76:14

contractor 74:15

control 26:9 68:16

controls 14:20,21

52:19 68:21 69:13

convene 66:17

conversation 4:9

conversations 79:21

conversion 19:18,18

20:1,2,3,9,22

21:20 22:4,10

28:17,18 48:7

convert 30:5 37:5

cooperation 75:22

core 42:7

Corporation 2:21

Correct 68:4

correlation 39:20

corresponding

10:21 18:7 44:10

corresponds 45:1

cost 8:12 19:5,6

20:12,21,22 22:3

22:4,7,12 23:10

24:11 26:18,20,20

27:2 29:2 30:7

31:3 33:2,3,3,6,17

33:18 37:21 38:15

39:10 46:12 48:1

48:5 49:12,13

costs 19:4,7,18,18

20:1,2,3,9 21:20

22:10 28:17,19

29:8 33:19,22

35:4,6 39:8

Council 5:11 7:7

Counsel's 7:9

country 76:1

couple 13:13 21:4

29:6 83:19

coupled 54:4

course 60:9 82:4

courtesy 7:20

cover 47:5 72:20,22

coverage 9:11 12:7

48:19 68:22 69:2

covered 19:19 48:17

48:18,21 49:3,5

49:10 53:11 72:19

covering 23:20

crafted 64:21

create 5:20

creates 14:21

criteria 10:22 16:13

27:19

crosses 72:6

cumulative 33:1,3

current 12:20 17:15

curve 44:17 71:22

curves 25:22 45:14

45:15

customer 27:18

29:3,4 30:21

customers 16:15

30:21 38:22

cycle 8:12 24:11

26:17,20 37:4,5

37:11

Cymbalsky 2:4 7:11

7:11 81:16,18

82:12

D

D 4:1

damage 38:6 40:11

Damodaran 30:10

Dan 6:5 23:2 24:6

28:15,17 47:22

Danfoss 2:10

Daniel 2:22 3:2 7:14

11:6,7

data 12:17 14:8

18:3 20:15 23:12

24:20,21,22 26:1

27:15,16 30:10,16

38:11 39:15 41:4

49:7 56:20 57:1

58:10 63:3,15,18

67:15 70:7 76:10

76:17,18 78:8

database 57:20

59:12,21

databases 28:11

date 57:9

day 8:19 33:9

DC 1:9

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diameter 53:7,9,14

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echo 51:14 83:2

Eckman 5:7,10,10

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April 29, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

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electricity 28:6

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fans 80:11

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fast 66:20 75:16

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favorably 10:7

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frequency 38:15

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given 19:10,14,15

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Glad 4:15

Glenn 3:7

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April 29, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

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I

I's 72:7

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60:13,16,18,19

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initial 16:5

initiate 70:16

initiated 81:2

inlet 42:17

inline 13:14 21:5

input 15:12 17:19

18:3 25:20 31:7

44:21 58:12 59:10

inputs 24:17 28:2,8

33:14 34:21 47:15

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installation 29:7

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instances 38:1

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66:16 70:5 75:20

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interest 56:2

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investments 20:5

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involved 64:14 74:7

77:9

involves 47:1

IOU's 3:6

IOUs 51:5

issue 57:19 58:17

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Commercial and Industrial Pumps Standard Meeting

April 29, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

Page 90

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jacket 61:14

Jason 3:3 7:16

Jiangang 2:8

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job 74:10

John 2:4 7:11 79:20

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join 4:9

joining 4:5 9:9,17

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keep 12:1

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18:16 21:10 30:3

50:17 52:4 54:1

55:20 58:8 63:1

67:8 68:10 78:5

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43:19 44:7 53:7

53:12 54:4,5,9,11

54:13,22 56:14

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61:1,2,7,12,19,22

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81:3 82:13 83:2

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L

L.P 2:12

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label 52:12

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3:5 7:18

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language 60:8

64:21 67:5,6

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30:18 31:16 34:2

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18:10,11,22 20:10

20:19,19 23:2

27:13,18,21 28:1

28:20,22 31:2

33:7,20 38:12

39:9,13 41:17

43:18 44:9 45:21

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levels 10:5,11,14

17:8,13,15,19,20

18:7 20:14 21:1

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22:7 23:17

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12:14 20:3 26:2

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61:3 62:6 64:12

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market 8:10 11:22

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17:15,17,18 18:17

18:18 21:18 24:2

32:4 49:11

market-wide 18:2

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markets 8:11 38:8

markup 18:3 19:1

19:13 21:21 22:9

markups 20:2,4,6

22:2,6 23:1,6,9,16

23:16,18 24:3,5

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Mary 2:17 8:4

materials 52:14

matter 7:19

Mauer 2:9 7:4,4

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max 17:17 18:10

mean 39:6 40:18

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meeting 1:1,3 2:1

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meetings 15:17

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meets 27:21

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members 61:3

membership 64:13

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mention 69:16

mentioned 12:1

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merged 28:12

methods 12:4 17:13

metric 11:12 47:12

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metrics 67:14 69:20

MG-1 6:6

MIA 22:16 46:13

46:18 47:1,8

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mic 7:21 8:2 22:21

42:10 83:9

mind's 54:1

minimally 11:5

minimum 36:18

41:17 44:1 76:15

mining 31:21

minor 23:5

mirrors 16:18

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misunderstanding

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mix 38:10

mode 76:17

model 19:7,13 20:13

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modeled 19:4 20:17

models 19:12 20:20

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modified 21:20 22:4

moment 24:16

monetization 49:19

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moved 19:20

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MPC 19:11 22:7

MSP 17:10 18:15

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MSPs 18:1 24:5

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Mulaney 65:3

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N

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Natural 7:6

Navigant 3:2,3,4

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near 65:14

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NEEA 78:4

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NEMA 2:20 6:13

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NES 32:20

net 31:3 32:15 33:1

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never 22:19

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NGOs 75:21

NIA 37:6

nice 72:5

Nidec 2:21 6:12

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nine 25:2,2,2

NOPR 4:15 8:14

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Northwest 2:6,16

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noting 52:3

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offerings 48:21

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offset 25:6 39:1

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overall 17:3 24:5

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PARTICIPANT

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pay 64:17 66:10

payback 8:12 26:21

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paying 30:22 64:15

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PEI 11:12,12 65:4

PEI/CL 54:15 58:11

penetration 34:10

people 25:7 39:12

45:5 70:11

percent 25:9,9

30:21 31:3 34:8

37:7,7 45:3,3,10

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percentages 25:17

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performance 27:16

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person 9:9

perspective 26:19

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PFCs 79:18

PG&E 6:9 8:4

phase 16:22

pick 8:6

place 84:3

plan 67:17

planning 68:15

plate 53:15,19 54:9

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plates 52:15 54:22

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play 82:16

players 76:21

please 41:11

plural 8:14

plus 52:17

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pool 67:12 68:8 69:7

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pull 5:21 59:22

pump 6:18 11:5,13

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pursue 73:21

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question 27:21 35:3

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running 15:20

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savings 30:20 31:2

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scenario 22:1,11,12

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shipments 8:13

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short 39:15

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stamping 54:9

stand 74:19

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standard 11:13

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strainer 68:2

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Commercial and Industrial Pumps Standard Meeting

April 29, 2015

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

Page 95

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