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### U.S. Department of Energy

Commercial and Industrial Pumps Negotiated Rulemaking Working Group Meeting Summary—Third Meeting Forrestal Building, Washington, D.C. March 4-5, 2014

Members in Attendance (Day 1) Lucas Adin U.S. Department of Energy Tom Eckman (by phone) Northwest Power a nd Conservation Council (ASRAC Member) Robert Barbour TACO, Inc. Charles Cappelino ITT Industrial Process Greg Case Pump Design, Development and Diagnostics (Hydraulic Institute) Gary Fernstrom California IOUs Mark Handzel Xylem Corporation Albert Huber Patterson Pump Company Paul Lin Regal Beloit (alter nate for Howard Richardson) Joanna Mauer Appliance Standards Awareness Project Doug Potts American Water Charles Powers Flowserve Corporation, Industrial Pumps

Steve Rosenstock Edison Electric Institute Louis Starr Northwest Energy Efficiency Alliance Greg Towsley Grundfos USA Meg Waltner (by phone) Natural Resources Defense Council

Doug Brookman Facilitator, Public Solutions, Inc.

Additional Attendees Robert Boteler, Daniel Cohen, Ch arles Foster, Jeremiah Freeman, Elizabeth Kohl, Laura PetrilloGroh, Callie Reis, Steve Thompson, Daniel We intraub, Sarah Widder and Alison Williams

Day 1—Working Group Meeting #3, March 4, 2014 Facilitator Doug Brookman called the Working Gr oup (WG) meeting to order and welcomed all present at 9:20AM. The facilitator noted that ba d winter weather had disr upted travel for some members. As a result, a few members were la te and Tom Eckman and Meg Waltner joined via

teleconference.

The WG proceeded with introductions around the room. The facilitator referred to the handout packet and the listed agenda elements co mpiled by DOE and the consultant team.

 Federal preemption & feasibility timeline if DOE does a follow-on rulemaking

 Define the scope of the negotiation

 Define Covered Product

 Metrics2 Page | 2 The discussion started on the question of Federa l preemption and the feasibility timeline if DOE does a follow-on rulemaking. Betsy Kohl had prepared a memo on these subjects that was sent

to members in advance. She confirmed th at the memo was DOE’s official position.

On the feasibility/timeline of a DOE follow-on rulemaking (a key issue in establishing the WG’s scope) Lucas Adin described that DOE could not predict whether ASRAC would approve a follow-on rulemaking, although the most expeditious process would be for ASRAC to approve the continuation of this WG (if a follow- on rulemaking should be necessary)—and ASRAC would need to give that approval for this WG to proceed with a new rulemaking. He continued, if that did not happen DOE would proceed with its regular process and conduct a rulemaking, conceivably following-on immediatel y from this WG’s rulemaking.

Discussion turned to questions about what ASRAC might do and when. Tom Eckman, via phone, stated that ASRAC was schedul ed to meet in either March 19 th or April 14 th . He continued, that he could take a proposal from the WG to ASRAC and he expected that he could get “rapid consideration of that option”.

One member asked what DOE’s thinking was that would lead to two separated rulemakings. Lucas Adin responded that, “it is, in large part, a matter of timing,” that Lot 11 seemed feasible to accomplish within the WG’s rulemaking timeline....”that with circulators there might be additional data to gather or just a lot less that we know .” A member of the manufacturing caucus

contributed that circulators are just “so different”, that “the language would be difficult maybe confusing and may cause issues”. Discussion turn ed to the feasibility of a follow-on rulemaking.

A manufacturer member contributed that the “i ndustry was willing to do this and invest the time”.....concluding ”there will be no problem in us supporting whatever time is necessary to do a rulemaking on circulators.”

Exclusions Exclusions would be those pump types that are categorically, by definition, excluded from the scope of the rulemaking. Discussion began with a detailed definitional memo authored by Chuck Powers. Chuck clarified several points, some of which was raised at the last WG meeting, and offered corrective language, including:

 Fire pumps: NFPA 20 compliance, not certificati on, is the key issue. After considerable discussion, the WG approved the following la nguage: ‘Compliant with NFPA 20 and UL-listed and/or FM approved.

 Navy pumps: required to be ‘MIL specifi cation compliant’ (with Mil specification numbers listed). The WG gave prelimin ary approval, pending a review by DOE.

 Nuclear pumps: code or non-code compliant safety related, ASME Section III or 10 CFR

50

 Marine pumps: one manufacturer member co mmented that he had not seen any one definition that separated mari ne pumps from pumps included in the Lot 11 group. After discussion, another manufacturer member suggested that, since there was no one definition that seemed to be adequate, marine pumps be removed from the exclusions list.3 Page | 3 The discussion turned to additiona l pump types that were listed a nd considered previously on the Scope of Negotiation slide (page #3). The firs t was ‘food-grade’ (or sa nitary) pumps. HI had previously offered to ‘look into the differences ’. The issue requires further investigation.

The discussion turned to ‘pumps outside certain parameters of power, flow head, temperature, speed, and bowl diameter. One member referred to the parameters list (page 5) and stated that the manufacturers caucus was satisfied with the pa rameters listed (the cl ean water definition was to be addressed separately):

 1-200 horsepower (shaft power at BEP)

 25 gpm and greater

 459 maximum head

 Temperature range from -10 to 120 degrees C In discussion, the members clarif ied that “shaft power at BEP” should also include “applies to the number of stages required for testing for the standard”.

Definition of Clean Water (p.73) Lucas Adin laid out DOE’s preliminary thinking on an approach to the definition, which was to employ a decision tree-like approach to disqualif y different pump types. Applying the decision tree (slide #7), those pump types that were not disqualified as excluded pr oducts or fell outside the pump design or application parameters would be considered in scope. Further, the approach would list and define those pump types that were specifically included in scope, such as Lot 11. In discussion, Alison Williams clarified that with this approach, the WG would not need a definition of clean water (p.82). Alison continue d that this approach had benefits from a compliance and verification perspective.

A member of the manufacturer s’ caucus described the importa nce of having a clean water definition: “clean water is what defines the engin eering of the pump. So we have engineered the pump differently for clean water than we w ould for solids handling or slurries.....petroleum products or anything else. So we would feel more comfortabl e if we had a definition of clean water.” After a manufacturers’ caucus, a member speaking on behalf of the caucus reported that

“we believe that the clean water de finition is fundamental to this. It was in your original request

for information on this. All of the data that ha s been provided to you has been based on that, that

clean water definition. So I believ e we do need to have it in one of the basic parameters that says this is what this is going to cover, what this rulemaking is go ing to cover (p.89).”

Discussion continued on whether some labelling regime could solve the potential problem of using the clean water definition to evade the stan dard. A manufacturer re iterated that the clean water definition was the starting point for all co mmunication and data coll ection with the entire industry. Another member clarified that the clea n water definition was important because it is consistent with industry’s expectation about a regulatory regime similar to Lot 11.

A manufacturer asked if a certification regime woul d solve the problem. Lucas Adin replied that DOE relies on self-certification by manufacturer s. Alison Williams reported that one early thought process for the decision tree was for the firs t question to ask would be “is this pump for clean water?” She continued, “from an enforcemen t end, the answer to th at question is always, ‘not sure’. And then you move on to the other on es (boxes on the decision tree to answer the4 Page | 4 question).” A member restated his understand ing of the dilemma: we can regulate and write rules around a product, but you can’t necessarily regulate the application. Another member

contributed that clean water is an application. A manufacturer clarified that any pump on the colorful ‘Scope’ slide could pump clean water, just that it was very impractical. Another member added that she thought the entire WG had th e same intent in trying to cover clean water pumps (p.120). Other members agreed that the members all had the same intent. Another member asked if it was possible to say “installed in a clean wate r application.” Lucas clarified that DOE regulates at the produc t manufacturer level. Another member referenced the EU’s approach—that its combination of definitions, paperwork and required di sclosure seemed to

work. The definitional issues were not resolved at that point (p.133).

Definition of a Pump (slide #22; p.146) The discussion returned briefly to the issue of various parameters and whether the WG had voted to accept all of them. After discussion, one memb er asked if the WG could proceed with votes on previously covered material. Lucas Adin sugg ested that the WG take up definition of a pump, with the following as the starting point: "Pump is a device that moves liquids by physical or mechanical action and includes a bare pump and as -manufactured mechanical equipment, driver

and controls." The facilitator cl arified that the accompanying gr aphic was intended to show that

the definition is inclusive of f our distinctive elements: controls, driver, mechanical equipment and bare pump. After a ‘wordsmithing’ discus sion the facilitator asked if the members were ready for a vote. A member of energy efficiency caucus requested time for its members to

caucus and the WG broke for lunch.

Returning from lunch, the discussion on definition of a pump resumed. One member restated his concern about the preemption issue, how a broad de finition would affect other states ability to create efficiency standards for non-DOE regulat ed products (p.154). Lucas Adin asked if the definition would be inclusive of solids-handling pumps. In extensive discussion the definition was refined many times to include entrained solids, gases and liquids and to clarify that the pump could include any combination of the four elemen ts. Members expressed an interest and desire in having the ‘four-eleme nt’ graphic included in the regula tion. Lucas said this kind of explanatory material could and w ould be included in DOE’s detailed Preamble to the regulation.

The facilitator asked for a vote on the following definition of ‘pump’: Pumps is a device that moves liquids (which ma y include entrained gases, solids and totally dissolved solids) by physical or mechanical action and includes a bare pump and, if included by the manufacturer, the mechanical equipment, driver and controls.

By a show of hands, thirteen members present voted to approve the definition. On the phone Meg Waltner, holding Tom Eckman’s vote proxy (wh ile in transit), regi stered two votes to approve the definition for a total of fifteen ‘Yea’ votes. One member cast a no vote. There were

no abstentions. The WG achieved a consensus on the definition of pump.

After the vote, Lucas clarified that minor edits may be necessary to accomplish the inclusivity intended and reflected in the pr evious discussion (p.177).5 Page | 5 In an additional comment, Lucas stated that Ga ry Witt—an originally-named member of the WG

that had withdrawn from the WG—would not be replaced. That would make the official membership of WG sixteen, not seve nteen as originally composed.

One member inquired about record keeping. He wanted to ensu re that someone was keeping very accurate records of the voting and the langu age/content that the WG had adopted. Alison Williams responded that she was doing real-tim e edits, as the conversation progressed, and saving those power-point slides at the end of each presentation/session. The facilitator added that this content, would be fully captured in the meeting summary.

Continuing, the facilitator asked if losing a member would have any substantial impact on the ground rules: “Okay. So, then, now scanning th e room here, to me losing a member is

unfortunate but doesn't seem to have a lot of bearing on the ground rules, which we discussed laboriously for over a day. So is everybody comfortable with keeping the ground rules as they are, the decision-making rules remaining the same, the quorum-setting rules being the same, the delegation rules all being the same ? It's just one person different . Yes? We're all okay with

that?” In a show of hands, the WG voted unanimo usly to keep the ground rules the same (15 yeses; Meg Waltner voted via phone; Tom Eckm an, in transit, was listed as an abstention).

General Description of ‘Pump’ Components (handout p.23; p.182) Discussion turned to component definitions, starting with bare pump. With several members contributing, the WG arrived at the following definition: ‘a bare pump is a pump excluding mechanical equipment, driver and controls’. Th e facilitator confirmed th at no one objected to that definition, but members requested that the WG vote on definitions as a group.

Moving to the definition of mech anical equipment, a member i ndicated the listed definition was good: ‘mechanical equipment if any component that transfers energy from the driver to the bare pump’. The facilitator confirmed members were comfortable with that.

Discussion continued with the definition of driver . Several members questioned if the breadth of

the listed fuel-sources was sufficient or if the descriptor ‘mechanical equipment’ was necessary. After back and forth among members, the WG arri ved at the following: ‘driver is the machine providing mechanical input to drive the bare pump directly or through the mechanical equipment, and may include an electric motor, in ternal combustion engine or gas/steam turbine.’

The definition of controls was discussed next. After considerable di scussion on the array of control possibilities, the WG arrived at the following definition: ‘controls means any device that

can be used to c ontrol the driver’.

The facilitator asked the WG for a vote on definitions as refine d and listed on the power point slide on the screen (and as listed above). By a show of hands, the members present voted unanimously to accept these four definitions (15 yeses; Meg Waltner voted via phone; Tom Eckman, in transit, was liste d as an abstention) (p.199).

Parameters (handout p.5; p.201)6 Page | 6 One member suggested the next topic be paramete rs. The facilitator st ated that the WG had covered these issues quite completely in the la st meeting. Alison Willia ms clarified that the listed parameters were meant to apply only to the HI recommended (proposed) pumps. Responding to a member’s question, she interprete d that if the scope of considered pumps expanded beyond the HI proposed pumps, “we woul d have to have another....discussion about parameters.” Specifically, a member questio ned the status VTS/HI, VSO model pumps.

Another member restated Alison’s earlier comme nt, that if the scope expands beyond the HI proposal, more discussion on parameters may be needed (p.203).

Members questioned the meaning of ‘nominal 2 a nd 4 pole motor speeds’: what speeds or range of speeds where meant to be included? And what types of motors (PM, ECM) would be

included? Another member aske d how the listed parameters compar ed to those of the EU, what

the differences were and whether the differences made sense (corresponding to the proposed HI scope)? A very detailed discus sion continued on the implications of the motor speed, head and shaft power parameters and describing a broad array of pump configur ations. One member commented that the proposed parameters meant, effectively, that the proposed HI scope would be broader than that of the EU (p.237). As the discussion continued, a member clarified that the parameters correspond to ‘catalog’ pumps and not ‘engineered’ products.

After more discussion and clarifi cation, members suggested the WG take a vote. The facilitator and members clarified the vote was for paramete rs on the HI pumps proposal. The parameters

included:

 Full impeller diameter

 1 to 200 horsepower (shaft power at BEP)

 25 gpm and greater (at BEP)

 459 of head maximum (at BEP)

 Design temperature range from -10 to 120 degrees C.

 Pumps designed for nominal 3,600 or 1,800 rpm driver speeds,

 6 inches or smaller bowl diameter

The facilitator asked for a vote. By a show of hands, the members present voted unanimously to accept these seven parameters (15 yeses; Meg Waltner voted via phone; Tom Eckman, in transit, was listed as abstaining).

Returning from an afternoon break, the facilitato r recounted that Alison Williams reminded him

that the WG had not taken final votes on fire pumps, navy pumps and nuclear pumps. Chuck Powers’ memo was discussed in the morning se ssion and the definitions were fully vetted. Alison clarified that fire pumps had been voted on previously but the defi nition had been revised.

The facilitator asked for a vote on these exclus ions, with definitions, as revised, from the morning session. By a show of hands, the members p resent voted unanimously to accept the definitions and exclude Navy pumps and nucle ar pumps (fire pumps excluded previously but with a new definition) (14 yeses; Meg Waltner was report ed as temporarily absent; Tom Eckman, in transit, was listed as abstaining).7 Page | 7 Pool Pumps (p.258) Discussion turned to details on poo l pumps: if the definitions meant they were still preempted; how they are configured and ut ilized; whether they are consid ered self-priming. Betsy Kohl clarified that the preemption existed even before the federal standard takes effect. Continuing, she said: “But the way we read the California p ool pump regulations is th at they impacted the motor. So right now there's no preemption of th eir regulations from...” In discussion, members clarified that pool pumps, at this point, were still considered within the scope of the rulemaking.

Scope of Negotiation Chart (handout p.3, p.282) A member inquired whether any ne w data had been collected. A lison Williams reported that HI volunteered to collect data from 25 pump companie s and they expect to receive that data by

March 15. Alison continued that the team did ha ve some new circulator data. Regarding the data collection effort, a manufacturer caucus memb er described the signifi cant effort they had

undertaken. He said that the new data should re present about 80 percent of the market in the United States and it was going to be analyzed by NEMA BIS.

One member offered that radial split verti cal, in practice, is called VS1, which is HI

nomenclature. What followed was a detailed disc ussion to clarify which pumps belong in what categories, and arriving at a shared nomenclatu re. In discussion, me mbers clarified that:

 ‘Multistage’ should be inserted in front of ‘radial split’ and ‘axially split’

 Vertical turbine including RS-V (not VS2)

 Immersibles are included only in VS1 Members clarified that these descriptors and clas sifications needed to be consistent, in part, because they correspond to the industry survey that HI had initiated.

Circulator Pumps (p.301)

Alison Williams described new data that the cons ultant team had analyzed. The data were segmented into 1/25 th to one-quarter horsepower and then greater than one-quarter to 3 horsepower. She continued that the majority of shipments were small circulators. There were about 90,000 in the above one-quarter to three horsepower category and 1.6 million circulators total. She described the following calculation: using 2160 operating hours as an annual load the total is approximately 0.46 terawatt hours (T Wh) per year. Discussion continued on

characteristics of circulators and the implicit assumptions in the calculation.

Continuing the calculation, Alison described how, using 0.46 TWh, we can save potentially 0.13 TWh for small pumps and 0.03 TWh for the larg er pumps—a total 0.16 TWh. Taking 30 years of shipments with an assumed 5-year life, 2.5 site-to-source conversion factor, which gives you approximately 0.2 quads. A member questioned the life-span estimate.

Members asked if residential vs. commercial ap plications made a difference. Betsy Kohl

clarified that the definition of industrial was inclusive: “It' s the definition in 6311.2 is the definition of industrial. It's to any significant extent distribute d in commerce for industrial or commercial use. And it's of a type. The pump is the type. And the pump is distributed to a significant extent in commercial use. So if there is some subset th at is used in residential, the

statute doesn't care.”8 Page | 8 A member gave a detailed descrip tion of the circulator experience in the EU and extrapolated to the US market (p.325). Gary Fernstrom presented some information that he had obtained testing

1/25 th horsepower, 3-speed circulators on a test stand in California (p.334). Referring to power point slides, he wanted to compare permanen t magnet products with induction motor products and created data plots showing three different speeds. Amid questions, other members helped interpret the curves. A very detailed discussi on ensued. Gary’s preliminary conclusions from this detailed exchange were that:

 PM motors pump more water per watt hou r consumed than an induction motor

 The “savings opportunities are all associat ed with the motor”, there is not much difference in the pumps

Day 1 ended with a scan of topics to be cove red on Day 2. Including re visiting the clean water definition, and potentially, the deci sion-tree approach; and test metr ics. The meeting recessed at

4:52PM.

Day 2—Working Group Meeting #3, March 5, 2014 Facilitator Doug Brookman called the Working Gr oup (WG) meeting to order and welcomed all present at 8:09AM. All members present on Day 1 were also present on Day 2. After introductions, the facilitator welcomed To m Eckman and acknowledged Meg Waltner, who joined via teleconference.

On Day 1 Tom Eckman had reported that ASRAC had tentative meeting dates in either midMarch or mid-April. Also on Day 1, and in previous meetings, members had inquired about

whether and how ASRAC could establish another WG to consider circulator pumps, should this

WG decide not to include circulators in the cu rrent rulemaking scope. Lucas Adin stated that this WG would probably have to make a r ecommendation to ASRAC. Tom clarified that ASRAC met regularly and had the capacity to meet as needed to consider a proposal or the work

of the WG. He confirmed that ASRAC woul d be prepared to take up this issue.

Definition of Clean Water (p.14)

A member of the manufacturer cau cus offered that the caucus had met last night and “it is our opinion the definition (of clean wate r) needs to be there, but if it's not going to be there, then there is going to have to be a lot of pumps moved into the red category, but there's a lot of pumps that could possibly pump clean water, but are not used for clean water that are not on any of

these lists.”

He continued, “So either we're going to have to go back and delineate each and every pump, or else we're going to have to have a clean water de finition, and I want to make this clear so that everybody understands. We star ted all of these negotiations and all these things around a

definition of clean water. It was in the fram ework document, and now it has been changed, and we think it, from our side, that's a major change . So now we've got to go back and make sure that we don't miss anything. We weren't too worri ed about it as long as there was the definition of clean water, but if you remove that, then we'v e got to go back and do a lot of study, and then we're going to have to come back and do a presen tation at the next meeti ng about the long list of pumps you've got to exclude.”9 Page | 9 Lucas Adin replied that he didn’t think there was any disagreement about the intended scope— the question is how best to identify it clea rly in regulatory langua ge, thinking ahead to

enforcement situations. A member asked if the WG could take a vote today to resolve the issue. Lucas replied that he was not sure DOE was ready to vote, they needed some more time. What

followed was considerable discussion on the merits of a clear, clean water definition and possible alternatives, such as a decision tree, which would have the same intent (and hope to elicit the same meaning). Another manufacturer contin ued, “we have been following this path for over two and a half, three years, and that's the direction we've communicated to all of our membership. So this is a significant change that we cannot make without a lot of time to consider.” Lucas Adin concluded this segmen t of the discussion sayi ng that DOE would give this some additional thought and make some proposals at the next meeting.

Test Metric (p.35) Sarah Widder began with presen ted material, showing a general, high-level framework of the pump efficiency rating. She noted that one di fference between this metric (PER) and the EEI metric or the HI proposed metric is that there is no denominator. The units of the metric would be horsepower. In this scheme, a lower number would be a better rating. A member commented that a higher number being better would be better.

Members questioned if the 25, 50, 75 and 100 percen t of BEP flow rates were the right load points. A member asked of there could be two metrics rather than one and contributed that 25 percent was not a good load point because at full speed you won’t operate a pump at 25 percent. Continuing, a member added that a 110 percent load point woul d be good. A member asked how these measures would be applied to meet a standard. Lucas Adin cl arified that passing or failing would not rely on one individual point; rather, the pump would have to pass an overall weighted value. He continue d that DOE wanted something that reflects the range of conditions under which the pumps would be used in the real world. Another member qualified that the advantage of this approach is that it enab led the WG to consider the pump as a system.

Sarah continued with where the variables come from (p.59). She began with a description of pluses and minuses of having a denominator. She described four options for the WG to consider

because the WG does not have an MEI. The fi rst was power consumption of the same pump in an uncontrolled system. The second was referenc e shaft power for a minimally compliant bare pump with a minimally compliant motor (as it’s d one in the EU). The third would be to set the reference to be a market average. The final opt ion was having a denominator of just the tested pump’s hydraulic power output at BEP. She discussed the merits of each approach.

A member suggested an approach that was similar to EU’s, u tilizing an MEI (p.68). Members made clarifying comments and suggested other alternative approaches . A member of the manufacturer’s caucus stated that the “pump indu stry prefers to stay as closely aligned as possible with what the EU has......for a lot of re asons. One of the large ones is that we all manufacture on both continents or many of us do.” He continued, “what we are trying to do here, I think, is come up with a metric that is good for all applications , and what this does, it compares the same pump type with the same pump type.”

Sarah Widder continued, describi ng “details of where the MEI fits in and where some of these10 Page | 10 variables are coming from (p.78).” Continuing, she described how various pump combinations would use standard values for things like motor efficiency, plugging the standard value into each of the motor efficiency variables, then add it a ll up and that is the PER for a bare pump (p.81).

She went on to describe how a ba re pump-motor (drive) and contro ls metric could work, with a description of the pluses and limitations. Sarah summarized: “So that is how we've been thinking about the metric and where the variable s would come from. One thing I will say about

how MEI fits into this is the way MEI -- I mean, aside from the fact that we might have a reference MEI in the denominator, in the numerator MEI is essentially pump efficiency at three load points (p.88).”

In discussion, one member listed a series of ad ditional metric options. Another member inquired about the practicalities—how th is could be communicated to an array of users in themarketplace. He favored the use of something like MEI that was both familiar and also regulateable. Lucas Adin responded, listing three broad objectives: “ One of them is supplying useful

information to consumers in the metric. One is comparing to a standard, and then the other is having a metric that is minimally burdensome to obtain.” A member inquired about labelling. Betsy Kohl and Lucas clarified that DOE, as au thorized by EPCA, has labelling authority for commercial products—whatever metric is chosen fo r the standard, that metric, by statute, would

have to be on the label if DOE a dopts a labeling requirement for pumps.

The discussion turned to a desc ription of overarching character istics/goals. A member listed

some:

 “One of them is we want to be able to co mpare one pump to some metric so that you can

choose or the consumer can choose which is the best”

 “The other thing we're trying to do is we're tr ying to educate the consumer that taking a pump and throttling it with a va lve is going to cost him energy, and we've got to be able to compare that somehow or communicate that somehow to the consumer, that a -- that comparing that to a variable speed drive unit is more efficient” In discussion, more ch aracteristics emerged:

 The metric’s ease of applicat ion, not too burdensome, with sufficient rigor to assure

accurate results

 A method where you can accurately know the ‘real’ savings

Several members gave detailed desc riptions of some of the realities, complexities and questions in trying to apply this metric (p.100). Anothe r person asked about enforcement, if enforcement

will follow the formula? Sarah Widder clarifie d that “enforcement will follow the exact same procedure that the pump was certified under.”

Another member commented on the benefits of th e approach: using the new AHRI test procedure will, ultimately, enable accurate information on how VFDs perform over a variety of loads—this is setting a framework for the future. An AH RI representative confir med that test procedure was available and test data was being collected. A manufacturers’ representative indicated that there would be advantages to havi ng the option to either test a product or rely on default values. Another member indicated that there may be benef its to having multiple metrics, especially if the majority of bare pumps are shipped as such.11 Page | 11 How MEI Could be Involved in the Metric (p.118) Alison Williams began presenting how a manufacture r could set a minimum efficiency level. “Hydraulic power is a measured va lue for each pump. So just as the MEI is a function of flow and specific speed, the PER would also be a func tion probably of flow a nd specific speed.....the motor we would use to set a standard would proba bly be the efficiency of a minimally compliant motor with rules on how they're sized, so that ev eryone's sizing the motor the same way. It may be full load efficiency or we may use some other loads as well....the key part of this is that the pump efficiency at BEP is a target value, but is a function of specific sp eed, flow and potentially C values. So this would basically be how the MEI is rolled into this.”

Alison continued, “we could evaluate different levels of MEI, basically, by setting different target values for the “n” pump BE P. You wouldn't have to meet that. You only have to meet the PER. So it wouldn't be, you know, a standard that we're setting. We're just looking at different efficiency levels....we could calculate pump efficien cy at BEP as a target value exactly the same way that the MEI does.”

She continued to describe the EU approach, c oncluding “So in this equation we have “n” pump BEP, again, would be a function of just like MEI is. The .785 a nd the .95 are percentages for the 75 percent and 50 percent load points, and the motor efficiency value would be the federal minimum compliance level for an appropriately si zed motor. So and then the hydraulic power just is different for every pump that you test. So basically you can look at different levels of pump efficiency, which is basically different levels of MEI and just use this equation to make an equivalent PER for every MEI....t he only thing changing is the ME I. The motor efficiency is going to be the same. The percen tage part load is going to be the same. The weights are going to be the same. The hydraulic power is going to be the same. You’re just changing the different MEI levels essentially (p.120).”

After the presentation and some brief question and answer, Lucas Adin confirmed “the main point we're trying to make in goi ng through this example and this ex planation is really to drive home the point that the only va riable that under this construct we would be considering for the purposes of setting a standard is a pump efficiency.”

In discussion, several questions emerged: how does this apply to a VFD? Alison responded, the example was for the pump only, but the PER consists of the control, the mo tor and pump. In the example, she was changing MEI levels for the pump, the motor remains at some default value (p.128). A member asked if ‘driver’ could be a substitute for motor. Alison clarified that while the definition of covered product wa s broad and would include more driver types, the format for the presented metric assumes an electric motor as a first step (and a convenience) for the WG to

consider. As the discussion on metrics drew to a close, Lucas Adin requested that the manufacturers’ caucus come prepared for the ne xt WG meeting with specific questions and

concerns.

Load Points in the Equation (p.138) Sarah Widder inquired about the manufacturers’ perspective on the list ed load points. A manufacturer responded that 50, 75, 100 and 110 percent were the load points data that had been12 Page | 12 requested from the manufacturers. No one w ill be reporting 25 percent. Another member suggested that data could be collected “over th e whole range of the cu rve and grade over the normal.” Sarah clarified that for a test pro cedure, manufacturers need a specific number and specific load points. What followed was deta iled discussion about a pplication: compliance testing versus enforcement testing; how ECM mo tors would be tested; how part-load should be

considered. Sarah summarized, “I think we're going to have to discuss the way we account for controls and motor losses more”. After more discussion, the facilitator obtained a preliminary confirmation that ‘everyone is comfortable’ with these load points.

Weighting in the Equation (p.163) Sarah Widder led off, restating that the WG ha d initially discussed equal weighting. Another member had suggested a more normal distribution that would more heavily weight certain load points—probably 50 & 75 percent load points. A manufacturer commented that the problem with the load profile approach is it varies with the application and the sy stem. He continued, to have a fair comparison of product, equal weighting assures no one is favored.

Another member restated that the WG is not tr ying to account for the performance of the system, just the pump, so the equal loading will work. Con tinuing, he said “as long as we're just talking about isolating the effect of improving the pump itself and holding those others constant, that doesn’t change the economic anal ysis nor the performance.” The member continued that for ‘integrated’ products you would ha ve to be careful about the we ightings. A manufacturer added

that the information on load factors is not available “and you will neve r get agreement with anybody on load factors (p.175).”

On the application of the weighting, Sarah contin ued “we will account for, to the extent possible and the extent we have any scraping s of data, real load shapes in the energy use analysis and will account for energy use and use thes e load...the efficiency at the load points, not the PER in general, to represent the energy use for pum ps. And so even though we're applying equal weighting in terms of determining the metric, that doesn't limit us to assume equal weighting in the load profiles that we apply for the energy use an alysis to determine the impacts of standards.”

A member talked about the implications of this framework: evaluating the variance with the EU approach, employment impacts on domestic manufact urers, the costs associated with changes in design and the need to balance all of these. A contributor asked how DOE intended to weight pump-motor-drive combinations with two differe nt, sophisticated contro l strategies (p.182). A member responded that “your factor is the same for both because they both have a drive. Okay? So you're not factoring in any sort of efficiency improvement based on the control type. You're just saying there's a drive. So this control fact or goes in here.” Sarah gave a very detailed explanation, discussing how diffe rent methods would respond to different load control types (p.186).

A member asked “are you envisi oning a regulation that would actually drive more use of variable speed drives or adjustable speed drives with the approach that we're taking here?....how does the work you’re doing move us in the dire ction of energy savings and more adoption of adjustable speed drives when it makes sense?” Lucas Adin answered that there would be two13 Page | 13 parts, an efficiency standard part and a labelling component —both of which could have an impact. A manufacturer asked “we’re still...struggli ng....is there a requirement to put a drive with all pumps (that) are being sold or what's the definition of when a drive needs to be used with a pump.”

Lucas replied “you could write a sta ndard that just uses assumptions for those configurations that use a drive. So really at the end of the day you' re just driving the pump efficiency to improve.

The metric would allow for the use of other com ponents, the motor or the drive, that are above that assumed baseline, and you could still repres ent a number that's better than whatever the standard would compel you to do. But you wouldn't be in this particular case setting a standard that compels someone who only manufactures a pu mp or pump with a motor to put a drive on it to meet the standard. You'd be comparing a pump that's already sold with a drive to a standard that's based on the use of a drive, not across those configurations.”

Updated Circulator Pump Data (p.205)

Alison Williams stated that “the manufacturers said they were going to collect an estimated delta price for switching from AC induction to ECM moto rs for the circulator. So for the 1/25th to one- quarter horsepower, they came up with $112.50 as the current price differential. Using the terawatt hour savings and 11 cents per kilowatt hour, that's appr oximately $10 annual electricity cost savings. So with a $113 delta price it's a 12-year payback. However, just to note that the delta price is the current market price, and it may be that... if we did anal ysis for this, we would

look at actual cost differentials. We would look at how it might change over time as the market matures a little bit more. So this is sort of just a snapshot in time and does not necessarily mean that that 12-year payback woul d hold for a long-term period.”

The facilitator reported that Alison Williams had noted that she did not anticipate any new data would be forthcoming for circulat or pumps. A member of the EE caucus reported that he might be able to get a little more cl arification on the market in California (p.210). The conversation shifted to an inquiry about wh at additional information or da ta would be useful for those members that were undecided on including circul ators in this rulemaking. Another EE caucus member said the new and revised data—to be pr ovided by the manufacturers at the next meeting, perhaps with DOE’s new analysis—would provide relative energy savings estimates that could be the basis for comparisons.

The facilitator asked if doing analysis on ci rculators would diminish DOE’s capacity to do analysis on the other pump types being considere d. Alison Williams reported that “specifically for circulators from an analyt ical standpoint, we would conduct separate engineering analysis, separate energy use analysis, separate LCC. Many of the other pump types in yellow we could probably fold into the existing stru cture of the analyses that we already have planned for the ones in green. So the circulators are a little bit di fferent of an animal analytically to pursue and potentially with the test pro cedure as well.” EE caucus member s clarified that they did not expect a full-blown Life-Cycle Cost (LCC) Analysis. EE caucus members volunteered to discuss their desired analysis out comes with the consultant team before the next meeting.

The facilitator asked if the WG should consider voting on excludi ng circulator pumps today. An EE caucus member said no, we should wait for ne w and better information. Another EE caucus14 Page | 14 member continued that it is the energy savi ngs that was important—DOE would need that information to consider a separate rulemaking anyway, and DOE has limited resources. A member suggested the WG consider a straw vote on the question of circul ators. The facilitator

also asked if the WG would consider a straw vot e on whether to decide th e issue of circulators today.

A member stated that in “a pr ior presentation where you had sort of a back-of-the-envelope estimate of what the potential usage was but not necessarily savings...there are things in Lot 11 that are order of magnitude simila r to the circulators. So the question is...why take them off if there's things in Lot 11 we're going to deal with th at are comparable in size?” He continued that because it is sold as an integrated product, and the opportunity for improvement is fairly substantial, it is worth considering the ‘resource allo cation going forward’.

A manufacturer followed that the industry was willing to wait for all the data, but it appeared that DOE “can’t get the analysis done for circulators” . Lucas Adin confirmed the thrust of that comment “you're basically correct...there's not a w hole lot more we can do with what we have right now. We can do some tweaki ng based on changes to the assump tions that are being used to generate, you know, some of thes e basic life cycle costs and payb ack period for circulators, but there's not a whole lot more that we're going to get without doing a much more involved analysis which, as Allison stated, would be potentially quite a bit different for circulators than it would be for other types of pumps.”

The facilitator asked “if the consultant team of DOE were to devote its resources to doing that analysis in circulators, would that detract from its ability to do th e analysis on the other classes of pumps that are here?” Lucas replied, “Yes.” Another member continued, “this is why we were discussing the potential for an adjunct (follow-on rulemaking) to follow this to deal with that,

because the work load could be le veled out a little bit and still ge t to it, and so I think we still have that as an option (p.241).”

A manufacturer asked if DOE takes into considerat ion an estimate of the costs to manufacturers to ‘switch over’ or potentially go overseas? Dan Weintraub responded that there is whole ‘manufacturing impact analysis’ section that will be performed, which is essentially a discounted cash flow model of the industry as a whole, looking to see how manufacturers will be affected. Lucas Adin said that DOE could provide some detailed information on the broader framework for establishing a rule.

A manufacturer asked if DOE would be making its analysis available on the cost-related data industry members had provided. Continuing, he st ated that the industry had not done estimates of the costs of tooling and design for the pumps in yellow and th ey would be “much higher than Lot 11”. Lucas answered that all the analysis w ould be fully available before the WG proceeds to setting a standard. Lucas cl arified the process going forward “w e put our proposal into a term

sheet and submit it to the ASRAC. The ASRAC ha s to take it up and consider it. Then the

ASRAC has to submit it to DOE. Then it has to go through our full internal process of translating that into a notice.”

Members inquired about how the WG product beco mes a rule. Betsy Kohl clarified that a15 Page | 15 consensus agreement from a negotiated rulemaking will turn into a proposal. The proposed rule would reflect what was proposed by the WG.

The discussion returned to data and analysis. Alison Williams clarified that one thing that characterized typical ne gotiated rulemakings was detailed review and ‘back -and-forth discussion about the analysis. Continuing, she said that detailed analysis that is planned cannot get underway until the WG establishes a scope for the rulemaking (p.255). Members inquired about the industry data request that wa s underway and how to align the fo rmats so the results could be interpreted by the DOE team. It was agreed that some coordination was ne cessary. In discussion, Alison agreed to create a list of ‘wants’ to s ubmit to the manufacturers to begin a back-and –

forth discussion.

Definition of Clean Water (p.264) As the meeting moved toward closure, a manufactu rer caucus member restated the importance of retaining the definition of clean water for the indust ry. The facilitator restated his sense, from the earlier discussion, “that everyone intends to carry forward th e concept of clean water.”

SharePoint Access (p.274)

Lucas Adin raised the issue of whether non-wo rking group members should have access to the WG’s SharePoint data source. In discussion, a member suggested that read-only access for nonmembers would be beneficial. Another memb er asked about access for alternates. The facilitator clarified that alternates, according to the WG’s ground rules, had the same privileges as members—so they should probably be allowe d full access. After disc ussion, the facilitator asked if anyone objected to read-only access being provided to non-members. The WG unanimously approved the proposal.

Looking ahead to the next meeting, the facilita tor noted several items to be considered:

 Metrics—be prepared to go another layer d eeper and some examples as a follow-on

 Begin work on the test procedure, with an HI member to present on balloted 40.6

 DOE to provide a general process overview —the major steps the WG will undertake to complete its work

Summary of Progress (p.281) The facilitator summarized the progress made ov er the last two days, including the following:

 Related to scope, clarified the rule s regarding federal preemption

 Discussed the feasibility and timeline if DOE did a follow-on rulemaking, with further clarification today

 Progress on defining the scope of the negotiati on in the pump types, but did not clearly define the scope for negotiation and coverage

 Considerable discussion on clean water definition, and a decision making tree

 Finished, at this stage, exclusions and parameters

 Completed the definition of a covered product

 Obtained more clarity on the range of options on metrics

 Described a general plan for th e analysis for the pump types n green and yellow, with the possible exception of circulators16 Page | 16 The WG meeting adjourned at 2:30PM

Meeting summary prepared by Doug Brookman publicsolutions@earthlink.net March 23, 2014