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U.S. Department of Energy 

Commercial and Industrial Pumps Negotiated Rulemaking Working Group 

Meeting Summary—Second Meeting 

Forrestal Building, Washington, D.C. 

January 30-31, 2014 

Members in Attendance 

Lucas Adin U.S. Department of Energy 

Tom Eckman 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 Natural Resources Defense Council 

Doug Brookman Facilitator, Public Solutions, Inc. 

Additional Attendees 

Bob Asdal, Robert Boteler, Abigail Chingas, Daniel Cohen, Charles Foster, Elizabeth Kohl, John 

Masters, Laura Petrillo-Groh, Douglas Potts, Doug Rawland, Callie Reis, Steve Thompson, 

Daniel Weintraub, Benjamin White, John White, Jr., John White III, Sarah Widder, Alison 

Williams 

Day 1—Working Group Meeting #2, January 30, 2014 

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

present at 10:25AM. 

The WG proceeded with introductions around the room. The facilitator described the proposed 

agenda for the next two days, with the following agenda elements compiled by DOE and the 

consultant team: 

 Definition of covered product 

 Scope of the negotiation 

 Metric for pump efficiency 
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 Data requests and data needs 

 Agenda-setting looking ahead (logistics, etc.) 

In opening remarks, one member made appreciative comments about the information packet that 

DOE had sent to members in advance. He continued, asking whether this information 

represented ‘recommendations’ from DOE. Lucas Adin clarified that this information was not to 

be “characterized specifically as recommendations, but more as general proposals for the 

purposes of stimulating discussion”, not a predetermination on the part of DOE. He continued 

that the presentation slides were intended as informational, a starting point for discussion based 

on both research and the Framework meeting. What followed was discussion on the quality and 

importance of the data and a request that any pre-meeting send-out material be sent earlier if 

possible. 

Definition of a Covered Product (p.20) 

Discussion turned to the definition of covered product and whether the definition should be 

broad or narrow. DOE presented a draft proposed definition on the screen: “Pump is a device, 

inclusive of mechanical equipment, driver, and—when present—controls, that moves fluids by 

physical or mechanical action”. 

One member advocated for a narrow definition because DOE’s definition of a covered product 

could preempt states from implementing their own energy efficiency regulations. Another 

member raised the issue of scope of inclusion, whether, for example, distributors could 

effectively buy parts of pumps and, in an assembly process, create functioning pumps but evade 

regulation. Betsy Kohl clarified that DOE’s regulatory authority applies to manufacturers. 

Alison Williams clarified that “the definition of the covered product does not necessarily refer to 

what you’re (the WG) is going to set standards on”. Lucas Adin laid out DOE’s general approach 

to definitions: typically DOE creates a broad definition but then chooses various classes or types 

of products for which standards will apply. 

Discussion continued on the array of possible pump configurations, variations and definitions. 

One member suggested that a helpful approach might be to determine the scope of coverage first, 

then create a definition that fits with the products included in that scope. Returning, the 

discussion turned to the definition being centered on clean water vs. fluids. Several individuals 

clarified, again, that the definition of covered product (pump) could be quite broad—and there is 

a utility in that approach—and that would not pre-determine the product classes that the WG 

would or could set standards for. Detailed discussion continued on various approaches and 

configurations and how they would be included in a definition. Several members indicated that 

they were probably not ready to vote for a definition during this meeting. A member raised 

again the concern that a broad definition of a covered product could preempt or prohibit state 

action. 

Returning to the previous issue of whether a distributor independently doing assembly would be 

subject to standards, Betsy Kohl clarified that the definition of ‘manufacture’ could be 

interpreted broadly. She continued, “the definition of ‘manufacture’ in Section 6291 of EPCA 

means to manufacture, produce, assemble, or import. So we would have some additional 

flexibility”. 
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Discussion continued referring to DOE’s list of proposed definitions. One member stated, and 

other members of manufacturer’s caucus confirmed, that ‘bare pump’ was term both useful and 

acceptable. Next the WG confirmed the use of term ‘driver’ as the mechanical mover and 

generally confirmed the proposed definition for ‘controls’. Both general and more specific 

discussion ensued, however, this was a still preliminary discussion and there was no more than 

general agreement. The WG returned to making specific edits to the draft definitions. The 

specific edits were sent to members for their review over the lunch hour. 

Scope of the Negotiation (p.104) 

Discussion began on the scope of the negotiation. One member suggested that the discussion 

start with the list of exclusions and parameters on slide page 6 & 7 and then return to the more 

detailed listing of pump types on page 5. 

As an overview, Lucas Adin provided a general sense of DOE’s thinking about the types of 

pumps that might be included or excluded in the draft Scope for Negotiation chart on page 5. He 

continued, that what DOE was offering for the WG’s review for coverage “was a group of 

pumps that are in relatively wide use that have significant energy consumption for which we 

could likely achieve cost-justifiable energy savings”. 

The discussion turned to the listed potential exclusions (handout p.6) with specific comments and 

edits to list. Lucas Adin clarified that the purpose of this discussion was to get some general 

agreement on whether the WG agreed to categorically include or exclude certain types of pumps. 

In detailed discussion, the WG generally agreed to the listed exclusions (although specific 

definitions were still needed), including: 

 Wastewater, sump, slurry, solids handling 

 API 610 pumps 

 ASME/ISO Chemical pumps 

 UL& FM Fire Pumps (which meet FPA 20) 

 Self-priming pumps 

 Prime-assisted pumps 

One member reminded the WG that the Hydraulic Institutes (HI) original recommendations were 

focused on harmonizing with the EU Lot 11 and clean water pumps. 

Parameters (p.140) 

Upon returning from lunch the Working Group reviewed handout slide p. 7. One member added 

that he wanted to add positive displacement pumps to list of exclusions. A member of the energy 

efficiency caucus confirmed they agreed with adding it to the list of exclusions. Discussion 

returned to slide 7. The listed parameters were consistent with HI’s proposal (for Lot 11 pumps). 

One member noted that harmonizing with the EU’s lot 11 made sense where possible. With a 

brief survey, the facilitator confirmed that members generally accepted harmonization as a 

concept/goal. A member noted that the EU approach would not adequately account for/include 

circulators, which he had stated earlier could be a possible covered product. 

The discussion turned to clarifications and edits to each specific parameter. After considerable 

discussion one member clarified that these parameters applied only to Lot 11 pumps, “we can 
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decide if there’s another parameter list for other things”. There was lengthy discussion on 

whether 3 inch pumps or other non-four inch or non-six inch pumps would be covered based on 

this list of parameters. That lead to a reiteration of the possibility of a phased approach: the 

scope of this rulemaking would be largely consistent with the HI proposal (and remain aligned 

with Lot 11); then, given a schedule and a commitment from DOE, commence a second 

rulemaking to take up other products, such as circulators, not included in the HI proposal. 

Members of the EE caucus expressed concern about the time lapse, and energy savings lost, 

between the two proceedings. Adding on, another member suggested that the WG be guided by 

the greatest opportunities for savings, as DOE would typically do. 

The discussion turned to the adequacy of coverage for 3 inch pumps, whether “6 inch and 

smaller” covers it and/or whether the speed needs to be modified. Sarah Widder clarified that 

these parameters have important implications for the test procedure. One member suggested that 

Best Efficiency Point (BEP) needed to be inserted. The manufacturer’s caucus requested an 

opportunity to meet and the meeting paused for its afternoon break. 

Returning from the break, a member of the manufacturer’s caucus confirmed their agreement 

that horsepower be defined as one to two hundred horsepower at BEP and also confirmed that 

the measure should be shaft power. The member also clarified that flow and head are also at 

BEP. In extensive extended discussion members described the differences and gaps between the 

parameters that HI proposed (and DOE listed) and the possible/real disconnects with the EU’s 

technical specifications. Members agreed that the parameter listing on page 7 was more 

categorical, maybe not specific enough and clearly not as specific/descriptive as the detailed EU 

documentation. Greg Case representing HI volunteered to “take on the task of recreating this 

document with the correct speeds for the U.S. industry and we will submit to the DOE 

consultants”....to be uploaded on the SharePoint site. He indicated the task will be completed by 

the middle of February. Following on, a member of the manufacturer caucus made another 

appeal for the WG to use the HI nomenclature in the future. Alison Williams responded that, to 

date, the consultant team had not done that because the HI labels would not be inclusive enough. 

She suggested for the time being the consultant team would need to continue to ‘dual label’ 

individual pump types. 

Continuing the review of the presentation slides, Alison Williams described how the GreenYellow-Red Chart labelled Scope for the Negotiation (handout page 5) was created. The green 

items are essentially HI’s proposed scope; the yellow items were pumps that DOE has 

considered for coverage in the Framework Document, including a few recent clarifications; and, 

the red items, generally, did not fit into the general scope of clean water centrifugal pumps 

and/or were on the exclusions list. Members questioned the inclusion of the item ‘non-clean 

water pumps’ in the red list. After discussion that item was removed and ‘clean water pumps’ 

was added to the list of parameters on page 7 of the handout. 

Circulator Pumps (p.264) 

Alison Williams began to describe the data that DOE had compiled on circulators, comparing 

HI’s estimate with information submitted by the California IOUs. The consultant team arrived at 

an estimate of 1.5 million wet rotor units shipped annually and, maybe, annual operating hours of 

2,160 hours. She summarized these data as .57 terawatt hours annual energy use “based on 1.7 
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million shipments, 2,160 hours, one-tenth horsepower hydraulic and assumed 50 percent motor 

and pump efficiency”. One member commented that these estimates alone of annual energy use 

make circulators comparable to some other prominent pump categories, and, therefore, “it strikes 

me we’re in a range of being very careful about excluding it”. Another member added, that it 

seemed “there’s a lot of opportunity in these smaller type pumps”. 

Another member commented that he had fourteen circulators on a test stand, so “in the next 

month or two we’ll have some actual performance measurements”. A member asked for 

clarification, if testing circulators was easy or even possible. Sarah Widder replied that the EU 

had a test method and the consultant team was utilizing it to do some measurements on the 

hydraulic output and power input to the motor, sort of a wire to water test. Continuing, she 

clarified that “there’s probably intricacies to the test procedure to design a representative test 

procedure for circulators versus clean water pumps.....but it is certainly feasible to” do these 

measurements. 

Continuing, a member asked if an ‘official’ test procedure was established or could be 

established during the time frame of the rulemaking? A manufacturer confirmed that “HI does 

not currently have a circulator test standard”, but work is underway to create one. The member 

estimated that it would take four years to complete one. Lucas Adin confirmed that DOE 

expected that a test procedure would need to be completed during the negotiation, that a test 

procedure was necessary to establish a cost-justifiable standard. The manufacturer clarified that 

HI was in the process of finishing its pump test procedure standard (40.6) and that would address 

the pumps included in HI’s proposed scope. 

Returning to circulators, a manufacturer said that an EU test procedure is not workable for the 

U.S. because the applications are so different. In considerable discussion, several members 

described the complexities, the multiple variables and issues involved in establishing an effective 

test procedure. 

Following on, there was considerable discussion the number of hours that circulators would 

typically be in use. Estimates ranged from 2,160 hours (HI estimate) to one European study 

which documented 2,250 of use, to 4,000 hours for commercial applications (P. 299). The 

discussion expanded to include estimates of terawatt hours saved. Greg Case clarified that HI’s 

estimates were for 1.9 terawatt hours per year savings for the MEI (HI proposal) and an 

additional 9.7 terawatt hours per year based on the extended product approach; a total of 14 

terawatt hours savings per year by 2035. 

Mark Handzel gave a brief overview presentation on circulator pumps (p.313) providing: a 

definition, which referenced residential and commercial uses; potential applications/uses; 

differentiating between a typical American and European system and pump types; typical wet 

rotor systems range from 40 – 240 watts motor output, single or multi-speed, flange sizes from 

three-quarters to one and a half inches and flow range about 130 gpm to a maximum foot head of 

55 feet. He described a second type: dry rotor pumps, not as widely used, with more limited 

horsepower. A third type is CP3, also a dry rotor that requires lubrication. He described the 

European market and regulatory scheme, implemented in 2013, on rotor circulators up to 2,500 

watts. He closed by urging that circulators be considered in a separate rulemaking. 
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In a discussion about the potential for switching to ECMs, a manufacturer said that domestic 

manufacturers were moving toward ECMs; however, he cautioned that switching, even over a 5 

– 7 year period, would create a large burden on manufacturers and would result in closing 

manufacturing facilities in U.S. and importing pumps from overseas. Another manufacturer 

echoed this statement (p.337) 

The discussion turned to timing of a prospective rulemaking. Lucas Adin confirmed that once a 

rule was finalized manufacturers would have five years to meet the new standard. He did not 

know whether it was possible for DOE to extend the start of the compliance period beyond five 

years. A member asked if the WG decided to pursue a limited scope for this rulemaking, could 

DOE initiate another rulemaking in within the next year for product classes not covered? Lucas 

replied that he thought that was possible, but needed to get confirmation. A manufacturer 

advocated for the WG to consider a ‘tiered’ approach to standard setting. In this case, like the 

EU, a standard would be set and also establish a schedule for the efficiency levels to increase 

over time. 

The discussion turned to a review of some additional slides and clarifications on descriptions of 

individual pumps and the nomenclature (labelled Lot 11+ Parts 1 & 2—pages 9 & 10) that the 

WG might consider for inclusion. Manufacturers made detailed comments about specific pump 

types and how they would be characterized and categorized. 

The focus turned to a preliminary estimate of shipments (handout page 12) (page 363). Alison 

Williams described that the estimates were derived from individual manufacturer’s estimates of 

their market shares on different pump types. Alison described other features of the estimates 

and acknowledged that there were ‘huge ranges’ for some of the estimates. Members expressed 

many concerns about the numbers presented and detailed why these estimates could be 

significantly flawed. 

Moving to slide 13 Shipment Distribution by HP, one member commented that the distribution 

looked “reasonably accurate”. Two additional manufacturers agreed with that statement (p.390). 

Then Alison reviewed slide 15, referring to them as “super-rough estimates” and detailed the 

methodology and some of the anticipated deficiencies. There was detailed and lengthy 

discussion on gaps and potential errors in the estimates. 

The facilitator and Lucas Adin both made remarks looking ahead to Day 2. Both referred to 

Page 5 of the handout as being a significant place holder and reference point for the discussion 

on scope. The Day 2 Agenda will also include discussions on a potential metric to rate pump 

efficiency as well as the test procedure. 

The WG adjourned at 6PM. 

Day 2—Working Group Meeting #2, January 31, 2014 

Attendance: All members present for Day 1 were also present for Day 2 
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Meeting facilitator Doug Brookman welcomed the WG members at 8:05AM. All members and 

attendees present introduced themselves. The facilitator reviewed the Day 2 Agenda: 

 Opening remarks 

 Testing overview 

 Test procedures 

 Data requests 

 Agenda setting looking ahead 

 Closing remarks 

In opening remarks, one member commented that yesterday’s conversation was beneficial—

‘some of it was tough and frank but we made progress’. 

Testing Overview (p.9) 

Lucas Adin provided a brief conceptual overview: how a metric to measure efficiency will be 

used and the linkage between the metric to the actual testing to comply with a standard. One 

member expressed a specific interest in understanding “the testing opportunities and complexity 

relative to circulators”. 

Alison Williams started with presentation material (handout slide 20), noting that a metric for 

DOE must describe energy efficiency or energy use and must be a single descriptor. She 

continued referring to various possible pump configurations, potentially including a bare pump, a 

bare pump + motor, or a bare pump + motor + controls combination. One member stated that 

manufacturers typically don’t test every pump. Alison clarified that a manufacturer would not 

need to test every pump, but would have to take data on the ‘whole or basic model’ so that then 

you can ‘certify’ that you have complied. She went on to describe many possible ways to 

measure based on the different pump configurations—one of which would be to take your pump 

model data an combine it with, for example, the efficiency of the motor you are pairing it with. 

Members raised several issues regarding the complexity of making these measurements, 

especially when pairing takes place—when going beyond a stand-alone bare pump configuration. 

A wide-ranging discussion followed, which covered practicalities. Members raised the issue of 

integration—should these units be tested as a whole unit? Would wire to water testing be a 

practical way, with an understood margin of error, to diminish the testing burden and still get 

reliable results? Could you use a standardized value to represent motor efficiency so you could 

then make comparisons across different pumps? How would extended product be measured? 

In discussion, the members and the consultant team described the elements of a basic testing 

construct: a manufacturer would test a bare pump by whatever means are established; then, you 

would assume a motor efficiency (for some compliant, certified motor) and calculate a combined 

efficiency. You would pull that efficiency rating for the motor out of the DOE tables. (DOE 

would probably specify the kind of motors to be used in the calculation if this method is used.) 

This would be an accurate test for the bare pump because every other aspect of the test is 

standardized (p.60). There was lengthy discussion on how this construct would or could work 

and the impacts on HI’s MEI/EEI proposal, domestic manufacturing jobs and many other issues. 

The manufacturers requested a caucus. 
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Returning from caucus, the manufacturers requested more information. A member of the EE 

caucus reiterated that their principal goal is significant energy savings and there seems to be 

significant potential in encouraging extended product applications with variable speed drives 

(VSD). 

Referring to slides, Sarah Widder described a basic extended product testing construct, as 

follows (p.94): “you set up a pump; you’re measuring the energy use of a pumping system, 

including the driver and controls at 100 percent of BEP flow; then, measure that same energy use 

at 75 percent of BEP flow, allowing the VSD to reduce the speed of the motor and attain a lower 

energy use condition......and then measure again at the energy use of the system at 50 flow 

condition and 25 percent flow condition...not actually measuring every single combination of 

motors, controls and pumps, (but rather,) “all those three components at these four rating points. 

And we are considering doing that with a calculation method, so that the different combinations 

of motors and drivers and controls and pumps can be considered analytically or be a calculation. 

You don’t have to test every....all the thousands of combinations you might have”. 

Sarah continued “theoretically, you would just measure the shaft horsepower provided to the 

pump at these rating points. Then you would have your standardized motor nameplate efficiency 

that would be applied to that brake horsepower supplied to the pump, and then a determination of 

VSD efficiency that would need to be accounted for. So additional, you know, losses that are 

associated with the controls (p.97)..... And then for an uncontrolled system, so if we take it back, 

we have a motor and a pump, or a driver and a pump with no controls, you would start at the 

same location, but you would be moving on the pump curve, not on the system curve, at those 

same four load points. And this would just be what -- essentially what you would achieve if you 

throttled the system back to those same four flow conditions”. In the bare pump case, it could be 

sold with any number of motors, and you are just certifying the bare pump and then using a 

number that is provided as part of the test procedure (p.99). Continuing, she explained that the 

idea is to capture input power to the input energy to the pump which includes a motor/driver and 

controls (p.102). Sarah confirmed that this proposal was based on HI’s EEI metric. 

Lucas Adin, answering a question about whether this method simply confirms affinity laws, 

summarized: “we are providing a standardized way to quantify the difference, and understanding 

that specific installations and systems are going to be different in actual application. But it 

provides a numerical energy savings estimate of what that actual difference is for those two 

different” (conditions). 

Detailed discussion continued on the metric and how it would be applied. One member laid out 

several limitations/problems, both measurement issues and cost, that could emerge in real world 

usage (p.120). Another member questioned how testing could be done with VFDs since no 

standards exist for them. An AHRI staff member contributed that AHRI 1210 does provide a 

way to find the VSD or VFD efficiency. Lengthy discussion continued on the difficulties of 

applying VFDs. 

Definitions and Scope (p.157) 
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In discussion, members raised several pump types that they thought should be on the exclusions 

list (handout p. 6) but were not. They included marine/Navy/nuclear and food and beverage 

plant pumps. HI volunteered to do some research and come back with more information. 

The facilitator offered an approach for further consideration of scope: following Tom Eckman’s 

suggestion, that “everything is guilty until proven innocent”, consider that all pump types are in 

scope until the WG decides, using our decision rules, they should not be in scope. After 

discussion, the facilitator offered the same fundamental scoping concept/logic as a proposal for a 

vote. 

Noting that a quorum was present, the WG voted unanimously to accept the proposal. 

Returning to handout slide 6, the WG reviewed the list of pumps (included in red) that were 

discussed on Day 1 as possible items to be excluded from the WG’s scope. The facilitator 

offered that these pump types seemed fully vetted on Day 1 and were probably ready for a vote 

to see if they should all be excluded. One member offered that the categories seemed ready to be 

excluded but that more detailed definitions were needed so the WG knew what specifically 

would be excluded. After more discussion, the facilitator identified the pump types in red that 

were proposed to be excluded, including**: 

 Axial/mixed flow 

 Positive displacement 

 (The non-clean water was moved to the parameter slide) 

 Wastewater, sump, slurry, solids handling pumps 

 API 610 and ANSI chemical process pumps 

 Fire pumps 

 Self-priming/prime assist pumps 

Not included for exclusion at this point were other pump types listed or added: 

marine/Navy/nuclear, sanitary pumps and pumps outside certain parameters of power, flow head, 

temperature etc. 

Next Betsy Kohl, from DOE GC, described two legal issues. Regarding preemption, she 

reported that the issue was complicated enough that individuals outside of the WG need to be 

consulted. As a result, DOE did not have an answer today but will convey something prior to the 

next meeting. She continued on the issue of a distributor potentially serving as a manufacturer: 

the definition in EPCA of manufacture includes assembly. However, DOE wants to get more 

information from members about the nature and numbers of individuals/groups who might be 

doing the assembling—the ramifications of including them in the definition. She requested that 

members provide DOE with more information. The discussion that followed was a detailed 

description of manufacturers experience, and the roles their distributors play. (p.204) 

Next, Gary Fernstrom gave a brief presentation on testing work underway on some circulator 

pumps. The slides showed the pumps mounted on pump stands. Gary said that they would 

measure all the electrical variables: voltage, current, watts, power factor, volt-amps, harmonics, 

etc. and that they were planning to use the EU control test and determine the intrinsic efficiency 

of the pump and motor. 
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Possible Definition of a Covered Product (handout p. 3, p.218) 

Lucas Adin provided context for the definition: it is intended to be broad, to encompass the range 

of pumps DOE has the authority to regulate. One member raised objections to establishing a 

very broad definition, as it would preempt the states from regulating any pump type for which 

DOE did not specifically set standards. He was in favor of a definition that would conform more 

precisely to what DOE chooses to regulate. A member of the manufacturer caucus restated that 

their preference was “commonality across the market, so we don’t have to deal with different 

requirements from one state to the next to the next”. 

The discussion turned to the definition of clean water and a review of the EU definition which 

clarified that various additions could be made. Gray water, sea water and glycol, etc. would still 

be covered in clean water definition, but to limit the inclusion of solids-handling pumps. 

General Description of Pump Components (handout p.4, p.234) 

The members returned briefly to a discussion on definitions of pump components, although they 

were discussed quite thoroughly on Day 1. A member raised again whether marine, Navy and 

nuclear could be excluded. Various members said they were receptive but wanted more 

information. A HI representative said they would create more complete definitions for the next 

meeting. 

The discussion returned to the table listing pumps in red on handout page 5. The WG considered 

whether to exclude almost all of those listed. Three classes of pumps were removed from 

consideration at this point, waiting on more information: marine/Navy/nuclear, sanitary pumps 

and pumps outside certain parameters of power, flow head, temperature etc. 

The facilitator asked the WG members to vote on the listed pump types, to exclude them from 

the scope of the negotiation. The WG unanimously agree to exclude the six items listed (see 

** above).

The discussion turned to items listed in yellow on table on handout page 5. One member 

suggested the WG adopt/accept the green listed pumps as being in scope and wait on more data 

before it considers the yellow listed items. Another member, reflecting on the shipments data, 

said there was so much variation for both yellow and green categories, that he was reluctant to 

decide on any of it until better shipments data emerged. Other members agreed that more data 

was needed before a decision could be made. Two members asked DOE about their capacity to 

conduct the necessary analysis: if asking for information on both yellow and green items would 

slow down getting some part of the analysis done? Another member provided a lot of very 

detailed comments on definitions (p.264). Several members commented on deficiencies of data 

and wondered about whether the survey provided sufficient detail. The consultant team 

described difficulties in obtaining data. 

A member of the manufacturer’s caucus said that data would continue to be an issue because 

much of the industry does not track data in the way DOE requested it. He reiterated that if DOE 

could say they would support a ‘phased approach’ (and accept as scope HI’s proposal for this 

rulemaking) 
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and commit to start another rulemaking “starting next year for all the other items here we can’t 

seem to get to, then I think we can reach an agreement and get moving with this thing and get 

something accomplished”. 

Lucas Adin responded, “that at least from legal standpoint there is no problem with that, we can 

do that” (commit to doing a phased approach)....”we can finish this rulemaking and immediately 

go into that one. It is really a question of the practical aspects, the feasibility for the program and 

our resources. That is something we would need to look at more carefully”.....before we could 

make some kind of commitment (p.275). 

Exclusions & Parameters (p.283) 

The discussion turned the list of potential excluded items on page 6 of the handout. Alison 

confirmed that she had been making edits to the handout as the conversation had proceeded and 

that the revised document would be posted. In discussion, there was further clarification on how 

to accurately describe fire pumps. In addition, members returned to the other elements that could 

be a part of clean water and whether they would affect the test procedure. 

In summarizing, the facilitator concluded that after these very detailed discussions a lot had been 

accomplished. While some definitional work still need to be done and the definition of a 

covered product may not be resolved, the other subsequent slides: the general description of the 

pump components, exclusions and parameters are quite close to resolution. 

The discussion continued on the definition of clean water and whether it was suitable as a 

parameter. Discussion included the that on purpose of an effective definition was verification and 

enforcement. Several manufacturers noted that there was no confusion in the industry and 

among their customers about what a clean water pump is and what is not a clean water pump. 

Following up from the last meeting, the WG considered changing its meeting times. One 

member said the manufacturers were all in DC the night prior to the meeting, so starting at 9AM 

would work for them. In surveying the room everyone agreed that subsequent meetings should 

start at 9AM on end at 5PM on Day 1 and start at 8AM and end at 3PM on Day 2. 

Finally, at the WG’s last meeting a few individuals offered to host meetings of the WG, specifically 

in San Francisco or Chicago. The WG decided it would discuss this further in its March 4-5 

meeting. 

The WG adjourned at 3PM 

Meeting summary prepared by Doug Brookman 

publicsolutions@earthlink.net 

March 1, 2014