MEMORANDUM 

RE: Ex Parte Communication In Connection with 

DocketNo.EERE-201D-BT-STD-D027 

Energy Efficiency Program for Certain Commercial and Industrial Equipment: Public Meeting and 

Availability of the Framework Document for Commercial and Industrial Electric Motors, 

75 Fed.Reg. 59657 (September 28, 2010). 

To: expartecommunications@hg.doe.gov 

From: Clark R. Silcox, General Counsel 

National Electrical Manufacturers Association 

Date: April 18, 2012 

cc: Bill Hoyt, Alex Boesenberg, Rob Boeteler, John Malinowski, Andrew DeLaski, Neil Elliott, Dan 

Delaney, Michael Bruin, Tim Schumann 

This memorandum memorializes another communication involving a follow-up to our previous 

communications in connection with this proceeding and documented in a memorandum dated March 9, 

2012. 

On April 12, 2012, an email was transmitted to Jim Raba and John Cymbalsky of DOE staff by Rob Boteler 

of Nidec Motor Corp. on behalf of the Motor Coalition. At the meeting referenced in the March 9, 2012 

memorandum, we discussed the scope of the Motor Coalition's proposal for future energy conservation 

standards and questions were asked about specific motor types and whether they were included or not. 

The Motor Coalition agreed to provide a written response to these questions. The April 12, 2012 email 

stated as follows: 

{(The Motor Coalition (Me) started our initial discussions of expanded scope with the idea of identifying 

only those motor categories that would not be covered. But in the course of our discussions and 

interactions with DOE it has become apparent that more clarity of the categories is needed to help 

communicate and understand. In response to your request for greater clarification of expanded motor 

scope, the NEMA MG section has put together the attached table, which has been reviewed by the 

motor efficiency advocates. This table is a working document to help DOE and the MC better 

communicate, but not intended to be included in rule language. In addition we have noted the nine 

motor categories that may need better test configuration information. We would like you to review this 

and let us know if you have any questions specific regarding testing. 

{(The table is meant to represent a general definition building off of the definition from EISA relating to 

types of electric motors that are {(general purpose alternating current induction motors rated for 

continuous duty operation on 60 Hz electrical power at 600 volts or less." Clarification ofthe EISA 

definition of "electric motor" along the lines ofthe EPAct definition is used. The table is structured 
completely around the EISA definition as it stands, with further definition of subtype I and subtype II 

[see section C] covering the two remaining type 2 categories that do not move to type one. The table 

has four parts: 

"A. Covered electric motors are designed in accordance with all of the following characteristics 

"B. The NEMA nominal efficiency of a motor with the characteristics of section A above and having any 

of the following characteristics and none of the characteristics listed under sections C and 0 below is 

required to be not less than the NEMA nominal efficiency in the appropriate NEMA MG1 Table 12-12 or 

Table 20-B 

"e. The NEMA nominal efficiency of motors with the characteristics of Section A and some of Section B 

above and having any of the following characteristics and none of the characteristics listed under 

Sections 0 below is required to be not less than the NEMA nominal efficiency in the appropriate NEMA 

MG1 Table 12-11 or Table 20-A 

"d. Motors with any of the following characteristics are exempt from efficiency standards. 

"I will let you forward to Navigant and the others on the DOE team. I have not sent this to them." 

On April 12, 2012, Mr. Raba responded as follows: 

"Thank you, Rob. 

We will take a look. 

Jim 

James Raba 

Appliances & Commercial Equipment Standards 

Building Technologies Program 

Office of Energy Efficiency & Renewable Energy 

U.S. Department of Energy 

Telephone: (202) 586-8654" 

A .pdf of the spreadsheet attachment that accompanied Mr. Boteler's email is annexed hereto. 
Item # Characteristic ~G:I - C ts there is a comment embedded in cell G11 

1 ;-1; ommen that should be moved to where it applies 

A. Covered Electric Motors Are Designed In Accordance With All OF The Following Characteristics 

15 General ur ose motor X As defined in 431.12 of 1 0 CFR Part 431 431.12 defines "g p motor" not "g pOI, DOE pointed this out as problem with EISA 

Three-phase X Drop use of polvphase since onlv talking about 3 phase 

Used on 60 Hz power supply X Includes motors typically marked 60Hz or 50/60Hz "Used on" Is DOE text as DOE did not like Just "marked for" 

Rated volta e u to 600 VAC X 

Continuous duty X 

2.4.6. or 8 poles X I I prefer using specific pole numbers 

Sin le-s eed 

NEMA Desi n A.B,C; IEC Design N, H X dropped "and" to remove ambiguity 

Random wound stator 

Includes IEC 100 frame 

10 NEM~E~6 :~a~aems:~~~a~~~~~~~:;tiotrf:~ !~~::~~~:o70~~ors or X NEMA 56 frame and IEC 80 fr:~~;~ena~~~;s are covered by Subpart X of I IGrouped NEMA and IECtogether because tlela above refers to "All", so can't be separate Items. 

11 IEC 80 frame or larger, except for 80 frame open motors X Includes IEC 100 frame 

1 9 I Altitude I X I When larger size frame!!lQtor is not required for hkJ.h altitudes 

20 I Ambient I X I When larger size frame motor is not required for low or high ambient 

12 

13 

,. 

17 

21 

22 

23 

24 

25 

26 

27 

28 

30 

31 

32 

33 

34 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

Standard Hp or kW rating§> 

Squirrel-cage rotor Cast or fabricated 

B. The NEMA Nomnal Efficiency of A Motor With The Characteristics of Section A Above and Having any of the Following Characteristics and None of the 

Characteristics Listed Under Sections C and 0 Below Is Required to Be Not Less Than The NEMA Nominal Efficiency In The Appropriate NEMA MG1 Table 12-12 or 

Table 20·B 

Broad voltage range 

Marked "Usable at 200 volts" 

Open 

TEFC 

TENV 

Example: 208-230; Required to meet efficfency standards at ali voltages In the 

marked range 

X Not required to meet efficiency standard at the ~Useable at" voltage (208 

considered an unusual service condition] NEMA MG1 standard marking Is "200", not "208" 

Excludes 56 frame Open for Smail Motor Rule (General Purpose. 1-3HP), aU 

other 56 frame Open construction t~es must meet 12-12 Table levels 

x U~lIlIll~ ~_~~nite purpose 051:1 X Some products ma be exem t, review a ainst exem t list Review yet to be completed???? 

C!_A~:AI ~ciaLp_lJ_rp_ose _.. -~- X Some roducts rna be exam I. review s slnst exem t list 

Special leads X This option does not vary the status of basic motor 

Special insulation X I This option does not vary the status of basic motor 

Hi h S.F. X I This option does not vary the status of basic motor 

Space heaters X I This option does not vary the status of basic motor 

WveDelta X I This option does not vary the status of basic motor 

Part Winding This option does not vary the status of basic molar 

Tel!'perature Rise This .2.2.~c:tfl_does not v~ the status of basic motor 

ThermostaUthermistor x This option does not varv the status of basic motor 

Thermally Protected x T~icailythis product requires a 3rd Party safety certffication (ex: Ul. CSA. etc.). 

Do we need 2 extra years for OEM designs to be approved? 

Hazardous location - Division 1 x TWically this product requires a 3rd Party safety certification (ex: Ul, CSA. etc.). 

Oa we need 2 extra years for OEM designs to be approved? 

Fungus/trap protection x This option do not vary the status of basic motor 

Special balance x This option do noi-~e status of basic motor 

Special Conduit Box This option do not vary the status of basic motor 

Motors operated from inverters x 

NEMA Design A or B motors that are single speed, meet aU other criteria under 

the definitions in EPCA for covered equipment, and can be used with an 

inverter in variable speed applications as an additional feature, are covered 

equipment under EPCA. In other words, being suitable for use on an inverter by 

itself does not exempt a motor from EPCA requirements. 

_________ +_-+ ____ -+ ___ +~=================::::_......,f_---__lpart30Isnot "Inverter Duty" motors 

X The HP should be rounded up or down to next closet HP for efficiency Non-standard HP or kW ratings requirement per the rules defined in 10 CFR Part 431 

Aux Conduit Box x I This option does not vary the status of basic motor 

Soecial Paint X I This option does not vary the status of basic motor 

Drains X I This option does not vary the status of basic motor 

Dd Cover This option d~EI:l;_nClt ;'!!Y...the status of basic motor 

Ground lualhole This option does not vary the status of basic motor 

Screens x This ~p~()I1<1oes not va.ir..the status of basic motor 

MountinQ F1.F2;W1-4;C1,2 x This option does not vary the status of basic motor 

Bearing caps x This option does not vary the status of basic motor 

Shielded bearino x This option does not vary the status of basic motor 

Sealed bearings x This option does not vary the status of basic motor 

Clamped bearings x This ~~()_El~ __ not~.ir.. the status of basic motor 

C Face This option does not vary the status of basic motor 

o Flange This option does not vary the status of basic motor 

Contact seals x This option does not vary the status of basic motor 
51 Flanged special X This option does not vary the status of basic motor 

52 Foolless X This 0 tion does nol vary the status of basic motor 

53 Insulated bearin $ X This 0 tion does not vary the status of basic motor 

54 Non-contact seals X This 0 tion does not vary the status of basic moior 

55 Sid ShaftslNEMA X This 0 lion does not vary the status of basic moior 

60 Non-standard Shaft dimensions or additions X This 0 lion does not varylhe status of basic mOior 

56 Special fan material X This 0 lion does not vary the status of basic moior 

57 Quiet or special fans X This 0 lion does not vary the status of basic moior 

58 All Washdown including stainless steel consluclion X This 0 tion does not vary the status of basic motor 

5. Shaft special material X This option does not vary the status of basic moior 

81 Double shaft X This option does not vary the status of basic motor 

82 Wound Stator I Squirrel-cage Rotor Sets: Motors X Stator I Rotor Sets that are made into electric motors mustcomplywith this 

sea e ex ansion motor reoulations. 

The term 'partial motor' means any electric motor sold without one or both 

64 Integral shaft partial motors (3/4 Partial Motors) X endplates. Would need 10 show compliance by testing an electrically "similar 

com lete model". 

65 Close-Coupled Motors incl. Hydraulic pump molors X M. of an electrically similar motor. 

68 ' /"'" SDooiaftiaint ; .. ' . ';X' • 

67 Dripcowr. .; .·X 

88 RTD's X This option does not vary the status of basic motor 

70 Brake motor X Srake mounted to the motor so that the motor may operate as a general 

urpose motor with the brake removed 

71 Special mounting or base X May need to show compliance by testing a "similar model" that could be more 

easil attached to a dynamometer. 

TWicallyan enclosed motor that can be immersed in water bul it is twically 

77 Immersible X operated after immersionlflooding is cleared. Motor should be tested with 

contact seals removed. 

82 Encapsulated Stator Windings This option does not vary the status of basic motor 

83 Motors with sleeve bearings May need to show compliance by testing a "similar model" with anti-friction ball 

bearings that could be more easily altached to a dynamometer. 

84 Vertical Pump Motor (P-Sase) May need to show compliance by testing a "similar model" with anti-friction ball 

bearings thai could be more easily attached to a dynamometer. 

85 Motors with Ihrust bearings May need to show compliance by testing a "similar model" with anti-friction ball 

bearings thai could be more easily attached to a dynamometer. 

C. The NEMA Nominal Efficiency of Motors With The Characteristics of Section A and Some of Section B Above and Having Any of the Following Characteristics and 

None of the Characteristics Listed Under Sections 0 Below Is Required to Be Not Less Than The NEMA Nominal Efficiency In The Appropriate NEMA MG1 Table 12-

11 or Tabale 20·A 

Next frame larger for automotive industry. ACTION ITEM: NEMA MG1 

18 U-Frame definition needs to be Inserted (180,210, 250U-440U). NEMA to repast 

the U-Frame pdf document that dimensionally defines this construction. 

29 Fire Pump Special purpose motor requiring UL 1004 approval for fire pump use. Defined as 

general purpose motor in NFPA. this should be changed there. 

D. Motors With Any Of The Following Characteristics Are Exempt From Efficiency Standards 

NEMA Desi n 0; X 

14 TEAO or Open Air Over X Re uires air flow from external drive air source 

Special purpose motor intented to be operated on a variable frequency inverter 

35 Definite Purpose Inverter-Fed [Part 31] moiors X drive with a specific stator winding that allows wide speed range or high lorque 

at low speed. 

83 Wound Slalor I Squirrel-cage Rotor Sets: End Use Equipment X Customers that apply these sets into their end use equipment. Le. submersible 

umps would be exempt to the motor reoulations. 

8. Integral Brake motor X Integral brake design factory buill cannot operate at its rating if the brake were 

removed 

72 Multispeed motors X Uses special single or multiple stator windings 10 achieve more than one speed 

73 DC motors X not alternating current 

74 SinQle phase motors X not oiyphase - Qenerallycovered bvSub art X of 10 CFR Part 431 

Liquid-cooled electric motor is any electric moior which is cooled by circulating 

75 Liquid Cooled X liquid, the liquid or liquid conductors coming in direct contact with the electric 

motor Darts. 

76 Submersible X Submersible electric motor is any electric motor designed for operation while 

continuousl submersed in a _fiquid. 

78 Electronicall Commutated Molars ECM X requires special control for operation 

7. Switched Reluctance motors SR X requires special control for operation 

80 Permanent Magnet Motors X 

81 Intermittent or Non-Continuous Dutymotors X t~icalJy special desi ns in small package size for high energy density 

Looked II 

was "sl 

already 11 

already 11 

corected 

How doe 

'Wound" also applied to Rotor 

d" - modified comments I 

to mathc title of Part 31 

differ from Item #62?