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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 and Conservation Council (ASRAC Member) 

Robert Barbour TACO, Inc. 

Charles Cappelino ITT Industrial Process 

Greg Case Pump Design, Development and Diagnostics (Hydraulic Institute) 

Gary Fernstrom California IOUs 

Mark Handzel Xylem Corporation 

Albert Huber Patterson Pump Company 

Paul Lin Regal Beloit (alternate 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, Charles Foster, Jeremiah Freeman, Elizabeth Kohl, Laura PetrilloGroh, Callie Reis, Steve Thompson, Daniel Weintraub, Sarah Widder and Alison Williams 

Day 1—Working Group Meeting #3, March 4, 2014 

Facilitator Doug Brookman called the Working Group (WG) meeting to order and welcomed all 

present at 9:20AM. The facilitator noted that bad winter weather had disrupted travel for some 

members. As a result, a few members were late 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 compiled 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 

 Metrics 
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The discussion started on the question of Federal 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 that 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 immediately from this WG’s rulemaking. 

Discussion turned to questions about what ASRAC might do and when. Tom Eckman, via 

phone, stated that ASRAC was scheduled to meet in either March 19th or April 14th. 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 turned to the feasibility of a follow-on rulemaking. 

A manufacturer member contributed that the “industry 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 certification, is the key issue. After considerable 

discussion, the WG approved the following language: ‘Compliant with NFPA 20 and 

UL-listed and/or FM approved. 

 Navy pumps: required to be ‘MIL specification compliant’ (with Mil specification 

numbers listed). The WG gave preliminary 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 commented that he had not seen any one 

definition that separated marine 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. 
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The discussion turned to additional pump types that were listed and considered previously on the 

Scope of Negotiation slide (page #3). The first was ‘food-grade’ (or sanitary) 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 parameters listed (the clean 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 clarified 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 disqualify different pump types. Applying the decision 

tree (slide #7), those pump types that were not disqualified as excluded products 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 continued that this approach had benefits from a 

compliance and verification perspective. 

A member of the manufacturers’ caucus described the importance of having a clean water 

definition: “clean water is what defines the engineering of the pump. So we have engineered the 

pump differently for clean water than we would for solids handling or slurries.....petroleum 

products or anything else. So we would feel more comfortable 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 definition is fundamental to this. It was in your original request 

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

clean water definition. So I believe 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 going 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 standard. A manufacturer reiterated that the clean 

water definition was the starting point for all communication and data collection with the entire 

industry. Another member clarified that the clean 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 would solve the problem. Lucas Adin replied that 

DOE relies on self-certification by manufacturers. Alison Williams reported that one early 

thought process for the decision tree was for the first question to ask would be “is this pump for 

clean water?” She continued, “from an enforcement end, the answer to that question is always, 

‘not sure’. And then you move on to the other ones (boxes on the decision tree to answer the 
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question).” A member restated his understanding 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 the 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 water application.” Lucas clarified 

that DOE regulates at the product manufacturer level. Another member referenced the EU’s 

approach—that its combination of definitions, paperwork and required disclosure 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 member asked if the WG could proceed with votes 

on previously covered material. Lucas Adin suggested 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 clarified that the accompanying graphic was intended to show that 

the definition is inclusive of four distinctive elements: controls, driver, mechanical equipment 

and bare pump. After a ‘wordsmithing’ discussion 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 definition would affect other states ability to 

create efficiency standards for non-DOE regulated 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 elements. Members expressed an interest and desire 

in having the ‘four-element’ graphic included in the regulation. Lucas said this kind of 

explanatory material could and would 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 may 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 (while in transit), registered 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 previous discussion (p.177). 
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In an additional comment, Lucas stated that Gary 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 seventeen as originally composed. 

One member inquired about record keeping. He wanted to ensure that someone was keeping 

very accurate records of the voting and the language/content that the WG had adopted. Alison 

Williams responded that she was doing real-time 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 the 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 unanimously to keep the ground rules the same 

(15 yeses; Meg Waltner voted via phone; Tom Eckman, 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’. The facilitator confirmed that no one objected to 

that definition, but members requested that the WG vote on definitions as a group. 

Moving to the definition of mechanical equipment, a member indicated 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 arrived 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, internal combustion engine or gas/steam turbine.’ 

The definition of controls was discussed next. After considerable discussion on the array of 

control possibilities, the WG arrived at the following definition: ‘controls means any device that 

can be used to control the driver’. 

The facilitator asked the WG for a vote on definitions as refined 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 listed as an abstention) (p.199). 

Parameters (handout p.5; p.201) 
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One member suggested the next topic be parameters. The facilitator stated that the WG had 

covered these issues quite completely in the last meeting. Alison Williams clarified that the 

listed parameters were meant to apply only to the HI recommended (proposed) pumps. 

Responding to a member’s question, she interpreted that if the scope of considered pumps 

expanded beyond the HI proposed pumps, “we would have to have another....discussion about 

parameters.” Specifically, a member questioned the status VTS/HI, VSO model pumps. 

Another member restated Alison’s earlier comment, 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 and 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 asked how the listed parameters compared to those of the EU, what 

the differences were and whether the differences made sense (corresponding to the proposed HI 

scope)? A very detailed discussion continued on the implications of the motor speed, head and 

shaft power parameters and describing a broad array of pump configurations. 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 clarification, members suggested the WG take a vote. The facilitator 

and members clarified the vote was for parameters 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 facilitator 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 session and the definitions were fully vetted. 

Alison clarified that fire pumps had been voted on previously but the definition had been revised. 

The facilitator asked for a vote on these exclusions, with definitions, as revised, from the 

morning session. By a show of hands, the members present voted unanimously to accept the 

definitions and exclude Navy pumps and nuclear pumps (fire pumps excluded previously 

but with a new definition) (14 yeses; Meg Waltner was reported as temporarily absent; Tom 

Eckman, in transit, was listed as abstaining). 
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Pool Pumps (p.258) 

Discussion turned to details on pool pumps: if the definitions meant they were still preempted; 

how they are configured and utilized; whether they are considered 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 pool pump regulations is that they impacted the 

motor. So right now there's no preemption of their 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 new data had been collected. Alison Williams reported that HI 

volunteered to collect data from 25 pump companies and they expect to receive that data by 

March 15. Alison continued that the team did have some new circulator data. Regarding the 

data collection effort, a manufacturer caucus member described the significant effort they had 

undertaken. He said that the new data should represent 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 vertical, in practice, is called VS1, which is HI 

nomenclature. What followed was a detailed discussion to clarify which pumps belong in what 

categories, and arriving at a shared nomenclature. In discussion, members 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 classifications 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 consultant team had analyzed. The data were 

segmented into 1/25th 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 (TWh) 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 larger 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 applications 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 distributed 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 that is used in residential, the 

statute doesn't care.” 
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A member gave a detailed description 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 

1/25th horsepower, 3-speed circulators on a test stand in California (p.334). Referring to power 

point slides, he wanted to compare permanent 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 discussion ensued. Gary’s preliminary conclusions from 

this detailed exchange were that: 

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

 The “savings opportunities are all associated with the motor”, there is not much 

difference in the pumps 

Day 1 ended with a scan of topics to be covered on Day 2. Including revisiting the clean water 

definition, and potentially, the decision-tree approach; and test metrics. The meeting recessed at 

4:52PM. 

Day 2—Working Group Meeting #3, March 5, 2014 

Facilitator Doug Brookman called the Working Group (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 Tom 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 current rulemaking scope. Lucas Adin stated that 

this WG would probably have to make a recommendation 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 would be prepared to take up this issue. 

Definition of Clean Water (p.14) 

A member of the manufacturer caucus offered that the caucus had met last night and “it is our 

opinion the definition (of clean water) 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 definition, and I want to make this clear so that 

everybody understands. We started all of these negotiations and all these things around a 

definition of clean water. It was in the framework 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 worried about it as long as there was the definition 

of clean water, but if you remove that, then we've got to go back and do a lot of study, and then 

we're going to have to come back and do a presentation at the next meeting about the long list of 

pumps you've got to exclude.” 
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Lucas Adin replied that he didn’t think there was any disagreement about the intended scope—

the question is how best to identify it clearly in regulatory language, 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 continued, “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 segment of the discussion saying that DOE would give 

this some additional thought and make some proposals at the next meeting. 

Test Metric (p.35) 

Sarah Widder began with presented material, showing a general, high-level framework of the 

pump efficiency rating. She noted that one difference 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 percent 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 would be good. A member asked 

how these measures would be applied to meet a standard. Lucas Adin clarified that passing or 

failing would not rely on one individual point; rather, the pump would have to pass an overall 

weighted value. He continued 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 enabled 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 first was power consumption of the same pump in 

an uncontrolled system. The second was reference shaft power for a minimally compliant bare 

pump with a minimally compliant motor (as it’s done in the EU). The third would be to set the 

reference to be a market average. The final option 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, utilizing an MEI (p.68). Members 

made clarifying comments and suggested other alternative approaches. A member of the 

manufacturer’s caucus stated that the “pump industry prefers to stay as closely aligned as 

possible with what the EU has......for a lot of reasons. 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, describing “details of where the MEI fits in and where some of these 
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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 all up and that is the PER for a bare pump (p.81). 

She went on to describe how a bare pump-motor (drive) and controls 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 variables 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 additional metric options. Another member inquired 

about the practicalities—how this could be communicated to an array of users in the 

marketplace. 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 authorized by EPCA, has labelling authority for 

commercial products—whatever metric is chosen for the standard, that metric, by statute, would 

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

The discussion turned to a description of overarching characteristics/goals. A member listed 

some: 

 “One of them is we want to be able to compare 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 trying to educate the consumer that taking a 

pump and throttling it with a valve 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 characteristics emerged: 

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

accurate results 

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

Several members gave detailed descriptions of some of the realities, complexities and questions 

in trying to apply this metric (p.100). Another person asked about enforcement, if enforcement 

will follow the formula? Sarah Widder clarified that “enforcement will follow the exact same 

procedure that the pump was certified under.” 

Another member commented on the benefits of the 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 AHRI representative confirmed that test procedure 

was available and test data was being collected. A manufacturers’ representative indicated that 

there would be advantages to having the option to either test a product or rely on default values. 

Another member indicated that there may be benefits to having multiple metrics, especially if the 

majority of bare pumps are shipped as such. 
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How MEI Could be Involved in the Metric (p.118) 

Alison Williams began presenting how a manufacturer could set a minimum efficiency level. 

“Hydraulic power is a measured value for each pump. So just as the MEI is a function of flow 

and specific speed, the PER would also be a function probably of flow and specific speed.....the 

motor we would use to set a standard would probably be the efficiency of a minimally compliant 

motor with rules on how they're sized, so that everyone'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 speed, 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 BEP. 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 efficiency at BEP as a target value exactly the same 

way that the MEI does.” 

She continued to describe the EU approach, concluding “So in this equation we have “n” pump 

BEP, again, would be a function of just like MEI is. The .785 and 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 sized 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....the only thing changing is the MEI. The motor efficiency is 

going to be the same. The percentage 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 going through this example and this explanation is really to drive 

home the point that the only variable 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 motor 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 was 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 next WG meeting with specific questions and 

concerns. 

Load Points in the Equation (p.138) 

Sarah Widder inquired about the manufacturers’ perspective on the listed load points. A 

manufacturer responded that 50, 75, 100 and 110 percent were the load points data that had been 
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requested from the manufacturers. No one will be reporting 25 percent. Another member 

suggested that data could be collected “over the whole range of the curve and grade over the 

normal.” Sarah clarified that for a test procedure, manufacturers need a specific number and 

specific load points. What followed was detailed discussion about application: compliance 

testing versus enforcement testing; how ECM motors 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 had 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 system. He continued, to 

have a fair comparison of product, equal weighting assures no one is favored. 

Another member restated that the WG is not trying to account for the performance of the system, 

just the pump, so the equal loading will work. Continuing, 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 analysis nor the performance.” The member continued that for 

‘integrated’ products you would have to be careful about the weightings. A manufacturer added 

that the information on load factors is not available “and you will never get agreement with 

anybody on load factors (p.175).” 

On the application of the weighting, Sarah continued “we will account for, to the extent possible 

and the extent we have any scrapings of data, real load shapes in the energy use analysis and will 

account for energy use and use these load...the efficiency at the load points, not the PER in 

general, to represent the energy use for pumps. 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 analysis 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 manufacturers, 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 different, sophisticated control 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 factor goes in here.” Sarah gave a very detailed 

explanation, discussing how different methods would respond to different load control types 

(p.186). 

A member asked “are you envisioning 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 direction of energy savings and more adoption of 

adjustable speed drives when it makes sense?” Lucas Adin answered that there would be two 
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parts, an efficiency standard part and a labelling component—both of which could have an 

impact. A manufacturer asked “we’re still...struggling....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 standard 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 components, the motor or the drive, that are above 

that assumed baseline, and you could still represent 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 pump 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 motors 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 approximately $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 analysis 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 would 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 circulator pumps. A member of the EE caucus reported that he might 

be able to get a little more clarification on the market in California (p.210). The conversation 

shifted to an inquiry about what additional information or data would be useful for those 

members that were undecided on including circulators in this rulemaking. Another EE caucus 

member said the new and revised data—to be provided 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 circulators would diminish DOE’s capacity to do 

analysis on the other pump types being considered. Alison Williams reported that “specifically 

for circulators from an analytical 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 structure of the analyses that we already have planned for the ones 

in green. So the circulators are a little bit different of an animal analytically to pursue and 

potentially with the test procedure as well.” EE caucus members clarified that they did not 

expect a full-blown Life-Cycle Cost (LCC) Analysis. EE caucus members volunteered to 

discuss their desired analysis outcomes with the consultant team before the next meeting. 

The facilitator asked if the WG should consider voting on excluding circulator pumps today. An 

EE caucus member said no, we should wait for new and better information. Another EE caucus 
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member continued that it is the energy savings 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 circulators. The facilitator 

also asked if the WG would consider a straw vote on whether to decide the issue of circulators 

today. 

A member stated that in “a prior 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 similar to the circulators. So the question is...why take them off if 

there's things in Lot 11 we're going to deal with that 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 allocation 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 whole lot more we can do with what we have 

right now. We can do some tweaking based on changes to the assumptions that are being used to 

generate, you know, some of these basic life cycle costs and payback 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 the 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 leveled out a little bit and still get to it, and so I think we still 

have that as an option (p.241).” 

A manufacturer asked if DOE takes into consideration 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 stated that the industry had not done estimates 

of the costs of tooling and design for the pumps in yellow and they would be “much higher than 

Lot 11”. Lucas answered that all the analysis would be fully available before the WG proceeds 

to setting a standard. Lucas clarified the process going forward “we put our proposal into a term 

sheet and submit it to the ASRAC. The ASRAC has 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 becomes a rule. Betsy Kohl clarified that a 
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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 negotiated 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 was underway and how to align the formats so the results could be 

interpreted by the DOE team. It was agreed that some coordination was necessary. In discussion, 

Alison agreed to create a list of ‘wants’ to submit to the manufacturers to begin a back-and – 

forth discussion. 

Definition of Clean Water (p.264) 

As the meeting moved toward closure, a manufacturer caucus member restated the importance of 

retaining the definition of clean water for the industry. The facilitator restated his sense, from the 

earlier discussion, “that everyone intends to carry forward the concept of clean water.” 

SharePoint Access (p.274) 

Lucas Adin raised the issue of whether non-working 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 member 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 allowed full access. After discussion, 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 facilitator noted several items to be considered: 

 Metrics—be prepared to go another layer deeper 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 over the last two days, including the following: 

 Related to scope, clarified the rules 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 negotiation 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 the analysis for the pump types n green and yellow, with the 

possible exception of circulators 

 
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The WG meeting adjourned at 2:30PM 

 

Meeting summary prepared by Doug Brookman 

publicsolutions@earthlink.net 

March 23, 2014