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 U.S. DEPARTMENT OF ENERGY 

 + + + + + 

ELECTRIC MOTORS ENERGY CONSERVATION STANDARDS 

 NOTICE OF PROPOSED RULEMAKING 

 + + + + + 

 PUBLIC MEETING 

 + + + + + 

 WEDNESDAY 

 DECEMBER 11, 2013 

 + + + + + 

 The Public Meeting was held in Room 

8E-089, 1000 Independence Avenue, S.W., 

Washington, D.C., at 9:00 a.m., Doug Brookman, 

Meeting Facilitator, presiding. 

PRESENT 

DOUG BROOKMAN, Meeting Facilitator, Public 

 Solutions, Inc. 

JERRY ALLEN, Metglas, Inc. 

KIRK ANDERSON, UL LLC 

TIMOTHY BALLO, Earthjustice 

DALE BASSO, WEG Electric Corp. 

TOM BISHOP, Electrical Apparatus Service 

 Association 

ALEX BOESENBERG, National Electrical 

 Manufacturers Association (NEMA) 

ROBERT BOTELER, Nidec Motor Corporation 

NED BRUSH, Consultant 

RICK BUDZYNSKI, Baldor Electric Company/ABB 

JEFF CASEY, Brook Crompton Americas 

BRIAN COFFEY, Navigant Consulting, Inc. 

HAYDEN COOK, Navigant Consulting, Inc. 
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JOHN CYMBALSKY, U.S. Department of Energy 

DAN DELANEY, Regal Beloit 

ANDREW deLASKI, Appliance Standards 

 Awareness Project 

NEAL ELLIOTT, American Council for an 

 Energy-Efficient Economy (ACEEE) 

GARY FERNSTROM, California Investor Owned 

 Utilities 

BILL FINLEY, Siemens 

AMI GRACE-TARDY, U.S. Department of Energy 

WILLIAM HOYT, National Electrical 

 Manufacturers Association (NEMA) 

SANAEE IYAMA, Lawrence Berkeley National 

 Laboratory 

VIJETA JANGRA, Navigant Consulting, Inc. 

MICHAEL KIDO, U.S. Department of Energy 

FRANK LADONNE, UL LLC 

DONALD LANSER, Nidec Motor Corporation 

PAUL LIN, Regal Beloit 

JOHN MALINOWSKI, Baldor Electric Company/ABB 

 Group 

JAMES RABA, U.S. Department of Energy 

DOUG RAWALD, U.S. Department of Energy 

STEVE ROSENSTOCK, Edison Electric Institute 

STEVE RUFFING, Nidec Motor Corporation 

CHARLIE STEVENS, Northwest Energy Efficiency 

 Alliance 

ATTENDING VIA WEBINAR 

HOWARD E. JORDAN, Consultant 

AUSTIN BONNETT, Austin Bonnett Engineering, LLC 

ROGER DAUGHERTY, Baldor Electric Company/ABB 

EMMANUEL AGAMLOH, Advanced Energy 

JAMES ALT, NORD Drivesystems 

JUN ASAI, Sumitomo Machinery Corp. of America 

JEAN-PIERRE BOIVIN, CSA Group 

TERRY BRENNAN, Natural Resources Canada 

BRUNET D. BROWN, GreenTech Motors Corp. 

MICHAEL BRUIN, General Electric 

KITT BUTLER, Advanced Energy 

KRISTEN DRISKELL, California Energy Commission 

CHAD GALLINAT, U.S. Department of Energy 
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ERIN HOPE, Bonneville Power Administration 

RONALD MARTIS, Metglas, Inc. 

DAVID MILLURE, Metglas, Inc. 

RICK MORRISON, CSA Group 

TUAN NGO, California Energy Commission 

AL PADILLA, UL LLC 

ROBERT PAULEY, Hitachi America 

BRAM PONIVAS, UL LLC 

WERNER RAUER, Compressed Air and Gas Institute 

 (CAGI) 

TOMAS RINCON, Xylem 

PAUL RYAN, HMA 

LINDA WILSON, NYS Office of the Attorney General 

MICHAEL WOODFORD, Air-Conditioning, Heating & 

 Refrigeration Institute (AHRI) 
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S 

 PAGE 

Welcome 

 Doug Brookman 

 ........................... 

 5 

 John Cymbalsky 

 .......................... 

 5 

Introductions, Agenda Review, 

Ground Rules 

 Doug Brookman 

 ........................... 

 7 

Opening Remarks, Background 

 Jim Raba ...............................15 

Opening Comments from Participants 

 Doug Brookman 

 ..........................18 

Regulatory History 

 Jim Raba ...............................28 

Market and Technology Assessment 

 Brian Coffey ...........................39 

Engineering Analysis 

 Brian Coffey ...........................85 

Markups and Energy Use Analysis and 

Life Cycle Cost Analysis 

 Sanaee Iyama ......................... 132 

Shipments, National Impact and Regulatory 

Impact Analysis 

 Sanaee Iyama ......................... 147 

Manufacturer Impact Analysis 

 Hayden Cook .......................... 168 

Environmental Impact, Utility Impact and 

Employment Impact Analysis 

 Sanaee Iyama ......................... 188 
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S 

Summary of Results and Proposed Standards 

 Sanaee Iyama ......................... 191 

Closing Comments from Participants 

 Doug Brookman 

 ........................ 192 

Closing Remarks 

 Jim Raba ............................. 196 
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1 P-R-O-C-E-E-D-I-N-G-S 

2 (9:45 a.m.) 

3 MR. BROOKMAN: Good morning, 

4 everyone, and welcome. This is the U.S. 

5 Department of Energy's public meeting about the 

6 Proposed Rulemaking for Electric Motor Energy 

7 Conservation Standards. Today is Wednesday, 

8 December 11th, 2013, here in the Forrestal 

9 Building in Washington, D.C. 

10 My name's Doug Brookman. I'm from 

11 Public Solutions in Baltimore. So glad to see you 

12 here. Many apologies for our late start. We've 

13 had some A/V problems for weeks now and I think 

14 maybe we've fixed it. So far it's sounding good 

15 here in the room, knock on wood, at the moment. 

16 We're going to start this morning 

17 with welcoming remarks from John Cymbalsky. 

18 MR. CYMBALSKY: Thank you, Doug. My 

19 name's John Cymbalsky. I am the Program Manager 

20 for the Appliance Standards Program here at DOE. 

21 Let me welcome you to beautiful, 

22 cold, snowy Washington, D.C. So for those of you 
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1 who didn't know, we had a shutdown yesterday so 

2 little bit disorganized this morning but I think 

3 we're on track. And welcome to all of you on the 

4 webinar as well. 

5 I know this rule has been a long time 

6 coming but I hope what you see presented here is 

7 something that everybody can find some happiness 

8 and joy with for the holiday season. 

9 I'd particularly like to thank those 

10 of you in the Motor Coalition who has presented 

11 the Department a pretty nice proposal for 

12 standards for motors. 

13 And, as always, I'd like to thank the 

14 team here at DOE that really worked very hard, 

15 both our consultants, our attorneys, our PM-Jim 

16 Raba. We put a lot of work and effort into this. 

17 I think we did the rule twice, based 

18 on the information we received from the Motor 

19 Coalition, but at the end of the day, I 

20 personally think a little extra time was worth 

21 what we perceive to be one of the biggest 

22 energy-saving rules the Department may ever 
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1 issue as a final rule if it stays intact the way 

2 it is here presented today. 

3 So again, welcome everyone and thank 

4 you for coming. 

5 MR. BROOKMAN: It's typical for us to 

6 start with introductions, so I'll start to my 

7 immediate left. You can get used to turning these 

8 microphones on and off, just leave them off 

9 unless you're speaking. Your name and 

10 organizational affiliation, please. 

11 MR. BASSO: Dale Basso, WEG Electric and 

12 also the Vice Chairman of Motor/Generator 

13 Section, NEMA. 

14 MR. FERNSTROM: Gary Fernstrom 

15 representing the California Investor Owned 

16 Utilities and the millions of customers they 

17 serve. That would be Pacific Gas and Electric 

18 Company, Southern California Edison, San Diego 

19 Gas & Electric and the Southern California Gas 

20 Company. 

21 We're authorized by the California 

22 Public Utilities Commission to advocate for 
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1 improved state and federal standards. The energy 

2 savings stemming from that part of our 

3 operation, our portfolio, amounts to about a 

4 third of the energy savings that we attain. 

5 MR. BOTELER: Rob Boteler, Nidec 

6 Motor Corporation, St. Louis, Chairman of the 

7 NEMA Energy Committee. 

8 MR. RUFFING: Steve Ruffing, Nidec 

9 Motor Corporation, which is a NEMA member. 

10 MR. LANSER: Don Lanser, Nidec Motor 

11 Corporation. 

12 MR. BOESENBERG: Alex Boesenberg, 

13 Manager of Regulatory Affairs for the National 

14 Electrical Manufacturers Association. 

15 MR. ELLIOTT: Neal Elliott, American 

16 Council for an Energy-Efficient Economy 

17 representing the Motor Coalition of energy 

18 efficiency advocates and motor manufacturers in 

19 NEMA. 

20 MR. DELANEY: Dan Delaney from Regal 

21 Beloit, as well a NEMA member. 

22 MR. MALINOWSKI: John Malinowski, 
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1 Baldor Electric Company, Fort Smith, Arkansas, 

2 and also ABB Incorporated and I am the Chairman 

3 of the NEMA Motor and Generator Committee. 

4 MR. FINLEY: Bill Finley with Siemens 

5 and I'm also Chairman of the International 

6 Standardization Section of NEMA. 

7 MR. deLASKI: Andrew deLaski, 

8 Appliance Standards Awareness Project. 

9 MR. LADONNE: Frank Ladonne, UL. 

10 MR. ROSENSTOCK: Steve Rosenstock, 

11 Edison Electric Institute. 

12 MR. RAWALD: Doug Rawald, Department 

13 of Energy's Office of General Counsel. 

14 MR. KIDO: Michael Kido, Department 

15 of Energy, Office of the General Counsel. 

16 MS. GRACE-TARDY: Ami Grace-Tardy, 

17 DOE, Office of the General Counsel. 

18 MR. RABA: Jim Raba, Project Manager 

19 for Motors and today's presiding officer, DOE. 

20 MR. CYMBALSKY: John Cymbalsky, DOE. 

21 MR. BROOKMAN: Please stand up. 

22 MR. COFFEY: Brian Coffey with 
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1 Navigant. 

2 MS. JANGRA: Vijeta Jangra with 

3 Navigant. 

4 MR. COOK: Hayden Cook with Navigant. 

5 MS. IYAMA: Sanaee Iyama with the 

6 Lawrence Berkeley National Lab. 

7 MR. BROOKMAN: And let's start, 

8 please, yes, in the back. 

9 MR. BUDZYNSKI: Rick Budzynski, 

10 Baldor Electric. 

11 MR. BRUSH: Ned Brush, consultant. 

12 MR. BROOKMAN: It'll just be 

13 sufficient to stand. Just speak loudly. 

14 MR. ALLEN: Jerry Allen, Metglas. We 

15 make amorphous metals for magnetic 

16 applications. 

17 MR. BROOKMAN: Thank you. 

18 MR. HOYT: Bill Hoyt. I'm Industry 

19 Director with the National Electrical 

20 Manufacturers Association. 

21 MR. BISHOP: Tom Bishop with the 

22 Electrical Apparatus Service Association. 
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1 MR. ANDERSON: Kirk Anderson, UL. 

2 MR. CASEY: Jeff Casey, Brook 

3 Crompton Americas. We're a NEMA member. 

4 MR. STEVENS: Charlie Stevens, 

5 Northwest Energy Efficiency Alliance. 

6 MR. LIN: Paul Lin with Regal Beloit. 

7 MR. BALLO: Tim Ballo with 

8 Earthjustice. 

9 MR. BROOKMAN: Again, welcome to 

10 everyone. Glad you're here. Thanks for coming. 

11 All of you received a packet of 

12 information as you checked in this morning. I'm 

13 going to do a very brief agenda review. Following 

14 the agenda review and meeting norms is an 

15 opportunity for anyone that wants to make brief 

16 summary remarks about issues that matter to you 

17 here at the outset. 

18 And following those opening 

19 remarks, we're going to hear from Jim Raba, 

20 background and regulatory history. Oh, I got the 

21 sequence wrong. Following Jim's opening remarks 

22 and background on regulatory history, then 
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1 we're going to take opening remarks from 

2 everyone here present. 

3 Moving on from there, market and 

4 technology assessment and then we'll take a 

5 break midmorning right about 10:15 or 10:30 or 

6 so. From there, we're going to hear about 

7 engineering analysis, and then following on from 

8 there markups and energy use analysis, 

9 life-cycle cost analysis. We'll take lunch 

10 midday, around about noon-ish or so. 

11 Shipments, national impact 

12 analysis, regulatory impact analysis when we 

13 return, and then following that, manufacturer 

14 impact analysis, environmental impact, utility 

15 impact and employment impact analyses. And then 

16 directly following on, summary of results and 

17 proposed standards. 

18 And then get another opportunity at 

19 the end of the day, closing remarks from anyone 

20 present, any other issues you wish to raise that 

21 you don't think have been fully described and 

22 covered at that point. Question here? 
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1 MR. RUFFING: Doug, sorry for the 

2 interruption. 

3 MR. BROOKMAN: Yes. 

4 MR. RUFFING: I just realized when I 

5 checked in this morning I neglected to receive 

6 a packet. Is there an extra copy -- 

7 MR. BROOKMAN: I'm sure there is, 

8 yes. Here's one right here and we'll find more. 

9 MR. RUFFING: Thank you. 

10 MR. BROOKMAN: Anybody else need 

11 materials? Okay. Many of you have been to these 

12 meetings previously. I would ask for your 

13 consideration to observe the following, what I 

14 think is simple courtesy. 

15 If you would speak one at a time, if 

16 you'd say your name for the record each time 

17 before you speak. There'll be a complete 

18 transcript of this meeting posted on the DOE 

19 website. Keep the focus here, please. Turn your 

20 cell phones on silent mode. Limit sidebar 

21 conversations. 

22 If you could try to be concise, share 
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1 the air time. There have been a few times 

2 recently when there's been a lot of additional 

3 comment and it hasn't been exactly on point and 

4 we've ended up at the end of the day being a 

5 little pressed for time. 

6 So I'm going to try and enforce a 

7 germaneness rule as we're going along today. Be 

8 concise if you would. Please share the air time. 

9 I'm going to be cuing individuals by 

10 name as best I can. Wish to also encourage 

11 follow-on comment. That's very helpful to the 

12 Department sometimes. 

13 For those of you joining us via the 

14 web, so glad to have you here. Welcome. The 

15 Department of Energy is trying hard to make these 

16 meetings accessible via the web. 

17 And if you would keep your 

18 telephones on mute and then raise your hand using 

19 the software available and then the webmaster 

20 here will notify me and we'll insert you in the 

21 conversation. We've already tested the system 

22 this morning. Seems to be working, that we can 
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1 hear you loud and clear if you wish to speak in 

2 the course of the meeting today. 

3 And I think that's all the 

4 preliminary stuff. I think we're going to hear 

5 from Jim Raba, opening remarks. 

6 MR. RABA: Good morning everyone and 

7 welcome, whether you're attending today's 

8 public meeting in person or via the webinar. 

9 I'm Jim Raba, Project Manager for 

10 Motors, today's presiding officer, and I will 

11 echo John Cymbalsky's remarks about thanking 

12 you, the participants in this public rulemaking 

13 process, to arrive at a very worthwhile idea for 

14 efficiency standards, and certainly the people 

15 who put this together, the team put the 

16 rulemaking together and the people in the 

17 logistics area who are supporting this meeting 

18 today. So thank you to them. 

19 Where the Energy Policy and 

20 Conservation Act as amended prescribes energy 

21 conservation standards for certain commercial 

22 and industrial electric motors, the Department 
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1 of Energy proposes amendments to those 

2 standards. 

3 Today's public meeting will address 

4 the proposed amendments in view of public 

5 comments and other information received thus far 

6 and the analyses that would substantiate any 

7 amended efficiency levels. 

8 DOE's analyses indicate that the 

9 proposed standards would save a significant 

10 amount of energy. Estimated lifetime savings for 

11 electric motors purchased over the 30-year 

12 period that runs 2015 through 2044 would amount 

13 to 7 quads full-fuel-cycle energy. The 

14 annualized energy savings are equivalent to one 

15 percent of the total U.S. primary energy 

16 consumption in 2011. 

17 Estimated cumulative net present 

18 value of total consumer costs and savings 

19 attributed to the proposed standards ranges from 

20 $8.7 billion at seven percent discount rate to 

21 $23.3 billion at three percent discount rate. 

22 As we move forward, the Department 
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1 of Energy encourages you and other interested 

2 parties -- 

3 (Off-microphone discussion) 

4 MR. RABA: As we move forward, the 

5 Department of Energy encourages you and other 

6 interested parties to consider the proposed 

7 efficiency levels, underlying analyses, and 

8 submit written comments with supporting 

9 information and data. 

10 MR. BROOKMAN: Okay, great. So then 

11 now, as we had mentioned at the outset, opening 

12 statements here at the outset, and Neal Elliott. 

13 MR. ELLIOTT: Thank you, Doug and 

14 Jim. I'm delivering some opening remarks on 

15 behalf of the Motor Coalition, which is made up 

16 of the energy efficiency advocate groups led by 

17 the Appliance Standards Awareness Project and 

18 NEMA and its members. 

19 First, I want to commend the 

20 Department. This, as Jim already noted, is one 

21 of the most important energy efficiency 

22 standards activities that the Department has 
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1 enacted in a number of years. 

2 We also want to acknowledge and 

3 extend our appreciation to the Department for 

4 accepting the petition that the Motor Coalition 

5 made to the Department now a little more than 

6 three years ago. The members of the Motor 

7 Coalition came together with the goal of trying 

8 to simplify compliance and ease enforcement for 

9 polyphase induction motors. We've gone through 

10 several rule cycles now and feel that this 

11 approach that was made as part of the petition 

12 moves us to a much better place and we are pleased 

13 to see that the Department agreed with the 

14 petition on this. 

15 We also appreciate the acceptance of 

16 the concept of broadening the scope rather than 

17 trying to raise the level of efficiency and the 

18 acceptance of the TSL 2 efficiency levels. We 

19 think this process worked very well and would 

20 encourage the Department to engage in similar 

21 processes as other products move forward. We 

22 feel that the opportunity for energy efficiency 
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1 advocates and manufacturers to collaborate and 

2 work on what is both a market-acceptable 

3 procedure that also looks at societal benefits 

4 that accrue from energy efficiency ends up 

5 producing a product that is both easier from the 

6 compliance perspective, easier from the 

7 enforcement perspective and has the benefits of 

8 maximizing societal benefits from this. 

9 As you work forward toward a final 

10 rule and over the next, I guess six, seven weeks 

11 moving to the comment deadline, we would offer 

12 to assist the Department as it moves to the final 

13 rule. 

14 One part of the request for that is 

15 that we have a number of different rules, a 

16 number of different documents that have moved 

17 forward that relate to motors and I would 

18 emphasize the issuance of the final rule last 

19 week with respect to the motor test procedures. 

20 One of the concerns that the coalition has is 

21 that there are a proliferation of documents that 

22 exist in different places. 
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1 And as you move to the final rule, 

2 we would ask that the Department consider 

3 consolidating the materials associated with 

4 motors in Section 431 of the Code of Federal 

5 Register so that there is a one-stop shop, if you 

6 will, for people both on the consumer side and 

7 the manufacturers, both domestically and 

8 internationally, where they can go to obtain 

9 information related to this rule. There's a lot 

10 of good information that has been assembled. A 

11 lot of that is in these various rulemaking 

12 documents. Having it in one place is, we feel, 

13 going to make the compliance and market impacts 

14 much more tenable moving forward. 

15 Finally I wanted to note that in our 

16 original petition, the motor manufacturers and 

17 the efficiency advocates had agreed that 24 

18 months was a reasonable time frame for achieving 

19 compliance with the rule as proposed. And in 

20 review and conversation among NEMA members and 

21 the advocates, we continue to feel that a 

22 24-months compliance deadline following the 
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1 issuance of final rule represents a reasonable 

2 time frame for implementation of the rule going 

3 forward. 

4 Again, on behalf of all the parties 

5 that represent the Motor Coalition, we 

6 appreciate the opportunity to work with the 

7 Department on this and appreciate the 

8 Department's willingness to entertain the 

9 comments from the coalition members. And we look 

10 forward, moving forward, to working with the 

11 Department on other future rulemakings in a 

12 similar manner. With that, thank you very much. 

13 MR. BROOKMAN: Thank you. Other 

14 opening remarks? Steve Rosenstock. 

15 MR. ROSENSTOCK: Steve Rosenstock, 

16 Edison Electric Institute. I'd like to thank you 

17 for this time, the opportunity to make quick 

18 opening remarks. 

19 I think it's great that the 

20 advocates and the manufacturers were able to 

21 agree to standards. I think it's always a good 

22 thing. I think it does help the Department in its 
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1 work. However, not to be the fly in the ointment, 

2 but having had a chance to review the technical 

3 support document, I do have some concerns. 

4 One of the concerns I'll talk about 

5 is process. The other concern I'll try to 

6 highlight because I don't want to take up too 

7 much time since we started late in terms of some 

8 of the analysis that's shown in the technical 

9 support document. 

10 First, process. I'm lucky to be on 

11 the email list of DOE in terms of getting 

12 notification about upcoming standards and 

13 public meetings. I received my email the day 

14 before Thanksgiving, Wednesday afternoon, as 

15 I'm sure most people around the table did, and 

16 fortunately I was able to forward that email. I 

17 was in the office. I was able to forward that 

18 email to members of our Codes and Standards 

19 Group. 

20 However, for those people who aren't 

21 on the email list or aren't on the DOE's list, 

22 the notice didn't appear in the Federal Register 
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1 until December 6th, five days ago. Now, if we're 

2 in D.C., it's probably no problem. But for other 

3 stakeholders, other people, five days' official 

4 notice or even two weeks' notice can be kind of 

5 tough, especially this time of year. 

6 So I would urge the Department in the 

7 future, if possible, to provide at least three 

8 or four weeks' notice between issuing of a big 

9 NOPR and the public meeting because the 

10 Department does want feedback and it can make it 

11 tough for certain stakeholders to provide that 

12 feedback. 

13 Now, in terms of some of the 

14 analysis, some of my concerns deal with -- and 

15 again, I might not be here later because of other 

16 meetings, but I have some concerns about part of 

17 the process. 

18 One of the issues is for covered 

19 products, giving a two-year compliance lead time 

20 is probably no problem since a lot of the 

21 manufacturers were probably expecting that, 

22 especially after EISA 2007. However, for the 
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1 newly covered products, for the products that 

2 have never been covered before, providing them 

3 only two years' time to comply with a brand-new 

4 standard has not been done with other products. 

5 Usually there's a three- to five-year lead time 

6 for products that are newly covered by DOE to 

7 give the manufacturers time to upgrade their 

8 plants, to make the conversion capital 

9 expenditures. 

10 At this point, especially looking at 

11 technical support document, if DOE comes out 

12 with a final rule in the spring and the final rule 

13 takes effect in December of 2015, you're talking 

14 less than a year and a half for many of these 

15 manufacturers who've never been covered by a 

16 standard before. I think for those 

17 manufacturers, again, I think it's not really a 

18 long enough time and I think that they should be 

19 given at least three years, at least for the 

20 newly covered products. That would be 

21 consistent with other rulemakings and other 

22 products. 
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1 I'm also concerned about, again, I 

2 just want to highlight, the use of EL 0 for 

3 products in the analysis. The use of EL 0, 

4 especially for Equipment Class Group 1, tends to 

5 significantly overstate the savings. As a former 

6 utility person, if I went into a PUC saying I want 

7 to do a motors efficiency program but I want to 

8 use as my baseline, motors that haven't been 

9 available on the marketplace for 16 years to 

10 calculate my savings and benefits, I'd be kicked 

11 out of the room. However, it's showing up in the 

12 technical support document and I just find it 

13 hard to believe that those motors are being used 

14 as a baseline for the analysis, for the energy 

15 savings and the economic analysis. 

16 Other issues I have in terms of some 

17 of the utility impacts and some of the shipments. 

18 Again, I think the combination of all those tends 

19 to overstate the national impacts, both in terms 

20 of energy savings and economic benefits. 

21 One other thing I also want to point 

22 out, I'm a member of ASHRAE, especially for the 
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1 motors energy usage, basically since, 

2 especially since 2010, any fan motor in a 

3 commercial building, whether it's a ventilation 

4 fan or cooling tower fan, has to be controlled 

5 by either variable-speed drive or two-speed 

6 drive. That's going to have a significant impact 

7 on the energy usage of those motors in those 

8 commercial buildings. 

9 I did not see anything like that in 

10 the technical support document. I saw about the 

11 loading factor, which I thought was good, but I 

12 didn't see anything about the fact that many of 

13 these, especially fan motors, are going to be 

14 controlled, which will have the benefit of 

15 reducing the energy usage and also reducing the 

16 baseline usage and possibly the post-standards 

17 case usage as well. It has to do with the delta 

18 in terms of kilowatt hours. 

19 So, again, I think it's great that 

20 people were able to agree to the actual 

21 efficiency levels, but I think there are some 

22 concerns in terms of the final numbers in terms 
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1 of the impacts and as well as possible impacts 

2 on newly covered products. Thank you very much 

3 for your time. 

4 MR. BROOKMAN: Thank you. Other 

5 comments here at the outset? If not, let's move 

6 straight to the content. 

7 (Off-microphone discussion) 

8 MR. RABA: The Energy Policy and 

9 Conservation Act, EPCA, as amended and in 

10 particular by the Energy Policy Act, EPACT 1992, 

11 adds definitions, test procedures, energy 

12 efficiency standards, labeling and compliance 

13 certification requirements for certain 

14 commercial/industrial electric motors. 

15 Thereafter, the Energy Independence 

16 and Security Act amended the energy conservation 

17 standards prescribed under EPACT 1992 and 

18 established standards for a broader scope of 

19 motors. More recently, the American Energy 

20 Manufacturing Technical Corrections Act of 2012 

21 added coverage to other motors. 

22 As to the current rulemaking, EPCA 
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1 requires DOE to periodically determine by rule 

2 whether to amend energy conservation standards 

3 for electric motors. Any standards that DOE 

4 prescribes would require compliance not earlier 

5 than December 2015. At this point would invite 

6 comments on the proposed compliance date, 

7 December 19th, 2015, knowing that we would not 

8 be able to prescribe compliance earlier than 

9 that. 

10 (Off-microphone discussion) 

11 MR. BOTELER: This is Rob Boteler 

12 with Nidec. The members of NEMA feel that that 

13 date is too soon and we would agree with what 

14 Steve said, that we need 24 months minimum from 

15 the final rule to achieve compliance because we 

16 do have many bills of material, thousands of 

17 bills of material that need to be addressed and 

18 changed. 

19 And he is correct, in some cases we 

20 have product which, at this point, has never been 

21 covered where we'll have to not only change the 

22 bill of material but do some corrective measures 
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1 to the design, so -- 

2 MR. BROOKMAN: Rob, you're speaking 

3 on behalf of NEMA? 

4 MR. BOTELER: I'm speaking on behalf 

5 of NEMA, yes. 

6 MR. BROOKMAN: Other comments about 

7 the compliance date. John Malinowski. 

8 MR. MALINOWSKI: John Malinowski and 

9 I'm going to speak on behalf of NEMA and add to 

10 what Rob said. Twenty-four months for sure. 

11 But the other thing that we need to 

12 look at, in previous rulings where third-party 

13 certification was required, the manufacturers 

14 and the OEMs received additional time to get 

15 those motors through third-party agencies. 

16 In this case, we have motors that 

17 might be going into a machine, that might be 

18 listed UL, CSA, some third-party organization. 

19 The motor itself might be UL, CSA, third-party 

20 listed. So there needs to be additional time on 

21 top of the 24 months for those cases as well. 

22 MR. BROOKMAN: Okay, thank you. Yes, 
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1 Dan. 

2 MR. DELANEY: Dan Delaney speaking on 

3 behalf of NEMA. Just to clarify again, we're 

4 talking about after the final rule, this 24 

5 months, an additional time, typically been 48 

6 months following the final rule for the 

7 certification of final end product. 

8 MR. BROOKMAN: Okay, thank you. Gary 

9 Fernstrom. 

10 MR. FERNSTROM: Gary Fernstrom. The 

11 California Investor Owned Utilities support two 

12 years, but not longer than that after the final 

13 rule goes into effect. 

14 MR. BROOKMAN: Thank you. Frank. 

15 MR. LADONNE: UL also, from a 

16 practical standpoint, supports no sooner than 24 

17 months. 

18 MR. BROOKMAN: Okay, thank you. 

19 Additional comments here on compliance date? 

20 Andrew deLaski. 

21 MR. deLASKI: I think in the NOPR the 

22 Department says, you know, proposed the December 
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1 19, 2015, and says, you know, solicit comment on 

2 this, recognizing that the Department missed its 

3 statutory deadline to complete the final rule, 

4 which I think was last December, right, was the 

5 statutory deadline. 

6 So I think the point is that if the 

7 manufacturers are telling you, we can do this in 

8 24 months from the final rule date, that gives 

9 the Department pretty strong indication that 

10 that's an appropriate date because they're 

11 saying, look, we can do this in 24 months, guys, 

12 from the final rule. 

13 And that should be given a lot of 

14 consideration if you've got experts like the 

15 manufacturers themselves who do the testing and 

16 the certification and independent groups like UL 

17 who also do testing and certification. Should be 

18 given a lot of weight in this process and they're 

19 the folks who have to make the investments and 

20 make the changes to do the compliance and that 

21 seems to me like a significant point to be made 

22 today. Thank you. 
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1 MR. BROOKMAN: Okay, thank you. Final 

2 comments here? Steve Rosenstock. 

3 MR. ROSENSTOCK: Steve Rosenstock, 

4 EEI. I would still suggest that some 

5 consideration be made for newly covered products 

6 in terms of that deadline. Thank you. 

7 MR. BROOKMAN: Thank you. 

8 MR. DELASKI: Follow-up on Steve's 

9 comment. I think the folks who are commenting on 

10 behalf of the manufacturers can speak for 

11 themselves, but they are talking about 

12 newly-covered products so invite them to respond 

13 to that. 

14 MR. BROOKMAN: Any other -- Rob. 

15 MR. BOTELER: Rob Boteler, Nidec. 

16 Yes, I think, you know, on the newly covered 

17 product, the minimum that it would take us to get 

18 that done in some cases is going to be the 24 

19 months from the final rule. 

20 But I think the critical thing is 

21 what John Malinowski mentioned, is we may have 

22 it ready and launched but our customer, who is 
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1 the OEM, then has to go through. He's a pump or 

2 a fan manufacturer or whatever piece of 

3 equipment. He may have to go through the UL 

4 component recognition, so we would be able to 

5 provide the motor, but he would not be able to 

6 provide the piece of equipment that he builds. 

7 So the U.S. economy, the U.S. end 

8 user would be void of that piece of equipment 

9 until he would work through the process through 

10 UL to get recognition, the component recognition 

11 of his product, which could be a disadvantage to 

12 us as a society, that we would lose out on 

13 equipment that would then be brought in from 

14 offshore or just wouldn't be available. 

15 MR. BROOKMAN: Dan Delaney. 

16 MR. DELANEY: Yes, Dan Delaney, 

17 Regal. Just to reiterate that fact, in the past, 

18 general-purpose product would be much more of a 

19 stock type of product, would not have as much of 

20 that cycle time. With a special-purpose, 

21 definite-purpose product coming into this 

22 range, you have more of an OEM product being put 
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1 into this. That's why we've stated the 48 months 

2 as Rob pointed out there. 

3 You know, those OEM applications 

4 that take that additional time, manufacturers to 

5 produce our component with our certification, 

6 now to incorporate that into OEM equipment 

7 certification, so. 

8 MR. BROOKMAN: Final comments here? 

9 Okay, we're moving on. 

10 MR. RABA: EPCA directs DOE to 

11 consider seven factors: economic impact on 

12 consumers and manufacturers, lifetime operating 

13 cost savings, projected energy savings, utility 

14 or impact on performance, any lessening of 

15 competition, the need for national energy 

16 conservation and other factors considered 

17 relevant by the Department Secretary, and you 

18 can see how the analyses for each follows those 

19 different factors to consider. 

20 So here we are, December 11th, in 

21 today's public meeting. The comment period for 

22 the proposed rule ends February 4th and 
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1 projected publication of the final rule is May 

2 2014. DOE's proposed rule closely mirrors a 

3 consensus agreement between a coalition of motor 

4 manufacturers and energy efficiency advocates. 

5 The proposal, as recommended by the coalition, 

6 would bring many currently uncovered motors to 

7 NEMA's Premium levels while retaining current 

8 levels for other electric motors. DOE's proposal 

9 would set higher standards than the coalition 

10 recommendation for U-frame motors and would 

11 expand coverage to integral brake motors. 

12 DOE recently published or issued a 

13 test procedure final rule on December 6, 2013. 

14 The new test procedure final rule adopts 

15 definitions which determine the applicability 

16 of DOE's regulations to various types of 

17 electric motors and amends energy efficiency 

18 test procedures for electric motors to allow 

19 currently unregulated motors to be tested by 

20 clarifying the test setup and to facilitate 

21 testing of these types of motors. I understand 

22 that the rule will be published Friday the 13th. 
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1 Next, Brian Coffey will do the 

2 market and technology assessment. 

3 MR. BROOKMAN: Thank you. Brian, 

4 before you do, Roger Daugherty has a comment. 

5 Roger, unmute your phone and let's hope we can 

6 hear you in the room. 

7 MR. DAUGHERTY: This is Roger 

8 Daugherty with Baldor Electric. With respect to 

9 the effective date of any revised standards, I'd 

10 like to call the Department's attention back to 

11 the language as it’s stated in EPCA as amended 

12 by EPACT. 

13 The particular language that's 

14 under discussion states that the Secretary shall 

15 publish a final rule no later than 24 months 

16 after the effective date of the previous final 

17 rule to determine whether to amend the standards 

18 in effect for such product. Any such amendment 

19 shall apply to electric motors manufactured 

20 after a date which is five years after the 

21 effective date of the previous amendment. 

22 When I look through Tables 1 through 
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1 8 of the standards that are proposed at the end 

2 of the NOPR, the only standards that I find that 

3 are being amended are those standards for 

4 general-purpose electric motors of Subtype II 

5 and certain NEMA Design B motors graded greater 

6 than 200 horsepower and up to 500 horsepower. 

7 It would appear that the language as 

8 stated in EPCA does not apply to when standards 

9 are established for newly covered products, only 

10 those standards that have been amended by the 

11 rule. Thank you. 

12 MR. BROOKMAN: Thank you, Roger. 

13 Brian Coffey. 

14 MR. COFFEY: Good morning, everyone. 

15 I'm Brian Coffey with Navigant and I'm here to 

16 discuss DOE's market and technology assessment 

17 and engineering analysis before turning the 

18 floor over to Sanaee Iyama of Lawrence Berkeley 

19 National Laboratory to cover some of the 

20 downstream analyses. 

21 I think some of you noticed we just 

22 had a test procedure slide up front. That was 
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1 originally later in the presentation, so we'll 

2 just skip it when we come to it, having addressed 

3 it here at the outset. 

4 I did also want to mention, we have 

5 a schedule here and the comment period for this 

6 notice ends on February 4th of 2014 and so that's 

7 pretty soon, as you can see, relative to the 

8 projected final rule publication date. 

9 Of course, DOE considers all 

10 comments received but in light of the compressed 

11 schedule, I think that the earlier they're the 

12 submitted, the more time DOE would have to 

13 consider them. 

14 So that brings us to the market and 

15 technology assessment. Here's a map of where the 

16 market and technology assessment fits 

17 conceptually with the other NOPR analyses. Along 

18 with the screening analysis, it's an input to the 

19 engineering. The purpose of the market and 

20 technology assessment is to characterize the 

21 market and industry, define scope of coverage 

22 for standards, identify technology options for 
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1 improving efficiency and establishing equipment 

2 classes, which are groups of motors that receive 

3 the same standard level. 

4 Here's how the market and technology 

5 assessment interfaces with the screening and 

6 engineering analyses. It generates equipment 

7 classes used in the engineering and technology 

8 options which go to the engineering analysis as 

9 design options after meeting the screening 

10 criteria. 

11 Here's a quick look at current 

12 standards for electric motors which became 

13 effective in 2010. General-purpose Subtype I are 

14 already at NEMA Premium and everything else in 

15 this table is at MG 1 Table 12-11. 

16 For scope of coverage, DOE is 

17 proposing an entirely new vocabulary from that 

18 of those standards which are in effect today. I 

19 think most people in the room know this, but 

20 instead of terms such as special- and 

21 definite-purpose, DOE is proposing that motors 

22 be subject to coverage if they meet the following 
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1 nine criteria and are not specifically excluded, 

2 so a little bit different method of 

3 categorization. 

4 I'll read them just because I think 

5 these are important. It's a single-speed 

6 induction motor. It's rated for continuous duty 

7 or duty type S1, contains a squirrel-cage or a 

8 cage rotor, operates on polyphase alternating 

9 current 60-hertz sinusoidal line power, has a 

10 2-, 4-, 6- or 8-pole configuration, is rated 600 

11 volts or less, has a three-digit NEMA frame size 

12 or IEC equivalent or an enclosed 56 NEMA frame 

13 size or IEC metric equivalent, has no more than 

14 500 horsepower but greater than or equal to one 

15 horsepower and meets all the performance 

16 requirements of a NEMA Design A, B or C electric 

17 motor or an IEC Design N or H. 

18 So these nine criteria are kind of 

19 the gatekeepers for what would be considered in 

20 scope. 

21 MR. BROOKMAN: Steve. 

22 MR. RUFFING: Steve Ruffing speaking 
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1 on behalf of NEMA. With regard to the frame size 

2 designation, I believe in some cases there may 

3 not be a one-to-one correspondence between NEMA 

4 frame sizes and IEC metric equivalents, so it may 

5 be helpful to add an additional clause including 

6 IEC frame sizes that fall between two NEMA frame 

7 sizes. 

8 MR. BROOKMAN: Okay, thank you. John 

9 Malinowski. 

10 MR. MALINOWSKI: Yes, do we want to 

11 talk about these seven now or do you want to 

12 postpone those and talk later? 

13 MR. BROOKMAN: Do the expanded now 

14 or, is now the time or should -- 

15 MR. COFFEY: These criteria? Yes, we 

16 can certainly discuss them. 

17 MR. MALINOWSKI: I mean, it's Issue 

18 30, kind of down the road. 

19 MR. COFFEY: Yes. 

20 MR. MALINOWSKI: Okay. John 

21 Malinowski. I guess I'm speaking on behalf of 

22 NEMA in this respect. 
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1 If our intent is to expand the scope 

2 of coverage up through 500 horsepower and 

3 include 6- and 8-pole motors, those motors are 

4 larger than NEMA three-digit frames. And in our 

5 tables within MG 1, there's a table that 

6 describes them as three- or four-digit NEMA 

7 frame sizes. They may be 5810s or 6809s or 5010s, 

8 so they're larger than the 440 frame cap that 

9 we've used in the past, so that part here needs 

10 to be amended. 

11 And as Steve said, in your test final 

12 rule, there was a clause that talked about IEC 

13 frames and Roger can probably hear in and add the 

14 exact verbiage. There was a correct statement 

15 within the test final rule that explained that 

16 about IEC frames, including frames in between 

17 normal frames. What we needed to do is have some 

18 verbiage that would include the IEC 100 frame 

19 which today is exempted, so our intent was to 

20 include that as well. 

21 The other last point there is NEMA 

22 Designs A, B and C and Designs N and H for IEC, 
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1 it's a common practice within the IEC that they 

2 don't necessarily stamp the motor design on the 

3 motor, particularly in the larger sizes. So we 

4 need to have some verbiage that would still 

5 include that motor up through 500 horsepower or 

6 equivalent kilowatt rating. 

7 MR. BROOKMAN: Doug. 

8 MR. RAWALD: And John, this is Doug 

9 Rawald from Department of Energy's Office of 

10 General Counsel. Can I just ask you to clarify 

11 the point regarding the four-digit frame series? 

12 Are you saying that we should amend that criteria 

13 that says has a three-digit NEMA frame size to 

14 also say a NEMA three- or four-digit frame size? 

15 MR. MALINOWSKI: Yes. 

16 MR. RAWALD: Okay. 

17 MR. BROOKMAN: As I read through 

18 these characteristics, I was thinking that they 

19 were kind of descriptive and illustrative but 

20 not necessarily fully specific. And so I was 

21 thinking that those good comments, to have those 

22 specific and extensive comments in writing would 
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1 be especially helpful to the Department. Alex. 

2 MR. BOESENBERG: Alex Boesenberg, 

3 NEMA. I'll give my usual statement. We will -- 

4 MR. BROOKMAN: Thank you. 

5 MR. BOESENBERG: -- give further 

6 detail in our written comments on that. 

7 MR. BROOKMAN: Thank you, and several 

8 individuals approached me this morning and said 

9 we're going to be submitting a lot of comments, 

10 detailed written comments, and so some of our 

11 comments during the meeting today will be kind 

12 of short, noting that full written comments are 

13 in the offing. Rob. 

14 MR. BOTELER: Rob Boteler, Nidec. If 

15 you go back to the charts in the Advanced NOPR, 

16 it's Chart Number IV, and you look at the higher 

17 horsepower, you'll see those ratings that aren't 

18 covered today and those are the ratings that are 

19 what John mentioned. They're above the current 

20 three-digit frame size, so those are the ones 

21 that would need to be added. 

22 MR. BROOKMAN: And, Alex, you had a 
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1 follow-on. 

2 MR. BOESENBERG: Yes. Alex 

3 Boesenberg, NEMA. I want to, I guess, reassure 

4 the Department that I think the vast majority of 

5 the comments that I have started gathering are 

6 ones sort of like John already mentioned. We'll 

7 make some more comments again later today on 

8 definitions. 

9 What we're hoping to do or what we 

10 need to accomplish with this, as John's example 

11 illustrated, was clarify and alleviate any 

12 potential for misunderstanding. You know, the 

13 fact that there's just a couple frame sizes in 

14 the four-digit, we want to make sure we can 

15 squeeze that in there so that it doesn't become 

16 a loophole later. And we'll have a similar 

17 discussion when we get back to the definitions 

18 due to the fact that a lot of the definitions as 

19 we submitted them were kind of truncated in the 

20 NOPR. 

21 And that's something I'll go into 

22 detail in, more in our written comments, but our 
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1 previous written comments were kind of 

2 excruciatingly long already. I'm not sure how 

3 much more information I can give. I want to 

4 reassure the Department, the reason why we 

5 suggested things like that is because while 

6 everyone at this table is very familiar with the 

7 subject we're especially concerned about people 

8 who haven't been following it day to day. 

9 It's the same vein as what Neal said 

10 about trying to make the final rule a one-stop 

11 shopping for all the stuff that's been put out 

12 in the different -- the test rule has definitions 

13 in it which usually is in the standards rule, 

14 things like that. We're trying to eliminate the 

15 confusion for the people who haven't been 

16 following it. 

17 And also we're concerned about, 

18 again, offshore suppliers and things like that 

19 who don't look at it until it's time to fill out 

20 the forms to shove the stuff on a boat and want 

21 to make sure it's as clear as can be. 

22 MR. BROOKMAN: Okay, thank you. Steve 
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1 Ruffing. 

2 MR. RUFFING: Steve Ruffing speaking 

3 on behalf of NEMA. Alex indicated that we will 

4 provide detailed written comments. There's one 

5 additional point of potential conflict or 

6 confusion that I think I can cover succinctly 

7 here, relatively quickly and that relates to the 

8 larger ratings that Rob and John mentioned. 

9 If you look in the proposed language 

10 for Part 431 in the NOPR, the Table 4, that shows 

11 the present standards for the Type 1. Obviously 

12 it doesn't include ratings up to 500 horsepower 

13 for some poles, eight and six in particular, 

14 whereas the new proposed Tables 5 through 7 do 

15 and that would be consistent with the 

16 second-to-last point on there up to 500 

17 horsepower. 

18 So these ratings that I've talked 

19 about, potentially four-digit frame numbers, 

20 those ratings, the ones that are not presently 

21 in Table 4 but which are in the new proposed 

22 Tables 5 through 7, do not have a NEMA Design 
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1 letter defined for them, so they would not fall 

2 under that last criteria that's listed where 

3 they must be NEMA Design A, B or C. 

4 MR. BROOKMAN: Okay. 

5 MR. RUFFING: And that's because in 

6 NEMA MG 1, they're classified as large motors as 

7 opposed to medium motors and large motors do not 

8 have the NEMA Design letter definition. 

9 MR. BROOKMAN: Okay, thank you. Doug. 

10 MR. RAWALD: Steve, to follow up on 

11 that, this is Doug Rawald again, Department of 

12 Energy. So would you want us to amend the ninth 

13 criteria to somehow incorporate that term of 

14 large-scope motors? How would you want us to 

15 address that issue? 

16 MR. RUFFING: Well, there's two ways 

17 to do it. One would be to simply in the Tables 

18 5 through 7, to continue to exclude those 

19 ratings. That would be one viable option, the 

20 other alternative, if the decision was made, to 

21 include those ratings. 

22 I think this is something we should 
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1 probably address in our written comments, how to 

2 particularly define that. I have an idea about 

3 that but I want to make sure we have consensus 

4 on that. 

5 MR. BROOKMAN: Okay, yes. Any final 

6 comments on this subject? Okay, Brian. 

7 MR. COFFEY: So here are the motors 

8 for which DOE is proposing standards that may not 

9 currently be subject to standards. These would 

10 be covered under DOE's proposal if they met up 

11 to nine criteria listed under the previous 

12 slide. 

13 So coverage is not being specified 

14 in these terms, but these are just examples of 

15 things that may not have been previously covered 

16 that may be in the future. 

17 I will also note, as has been noted 

18 already, that the recently issued test procedure 

19 final rule tweaked some of these definitions a 

20 bit, for example combining integral and 

21 non-integral brake motors into just brake 

22 electric motors, but the effect of coverage 
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1 doesn't change. 

2 MR. BROOKMAN: Steve Rosenstock. 

3 MR. ROSENSTOCK: Steve Rosenstock, 

4 Edison Electric Institute. Just a quick 

5 follow-on, does this mean that, well again, with 

6 the eight tables in the NOPR, do those eight 

7 tables cover all of these products that are 

8 listed here? 

9 MR. COFFEY: Yes, they do. So nowhere 

10 will you see in the CFR that electric motors with 

11 special shafts are subject to these standards. 

12 It's not outlined in those terms. These are just 

13 for clarification when someone says, okay, well, 

14 these weren't covered before. Are they covered 

15 now? Anything that you see here could 

16 potentially now be covered under the newly 

17 proposed standards. 

18 MR. ROSENSTOCK: And, again, you'll 

19 have to forgive me. I'm not a motors expert. What 

20 is meant by a partial electric motor? I'm not 

21 familiar with that term. Sorry. 

22 MR. COFFEY: There's a definition of 
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1 it. I don't have it in memory, but essentially 

2 it's a motor that arrives without an end shield 

3 and bearing. So you need to add some parts to it 

4 in order to create an operable electric motor. 

5 MR. BROOKMAN: Doug. 

6 MR. COFFEY: Yes, maybe someone has 

7 the definition. Doug. 

8 MR. RAWALD: And just to refer those 

9 who are going to make written comments on that, 

10 the partial electric motor definition will be 

11 included in the notice that'll be out this Friday 

12 on the final rule for the test procedure 

13 regarding electric motors. 

14 MR. DELASKI: I also would add it was 

15 defined -- 

16 MR. BROOKMAN: Andrew deLaski. 

17 MR. deLASKI: It also was defined in 

18 the NOPR for the test method published many, many 

19 months ago. 

20 MR. BROOKMAN: Okay, thank you. 

21 Additional comments on these listed motor types, 

22 electric motor types? We have comment boxes. Do 
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1 you wish to cue those? I think we're in the 

2 process of covering them. 

3 MR. COFFEY: So I did one slide as a 

4 counterpoint to what we just saw. 

5 MR. BROOKMAN: Oh, please. 

6 MR. COFFEY: Here are the motor types 

7 for which DOE is not proposing standards in 

8 today's NOPR. There are five of them. 

9 MR. BROOKMAN: That's useful. 

10 MS. IYAMA: Those are not in here 

11 then. 

12 MR. BROOKMAN: Yes. 

13 MR. COFFEY: Yes, those are not in the 

14 packet, so this is one I wanted to add because 

15 I thought it fit well after what we just saw. 

16 MR. BROOKMAN: Yes. So let's leave it 

17 up there. Everybody can take a peak. Motors that 

18 are not covered. Hang on. 

19 MR. COFFEY: And, yes. I do have in 

20 backup slides the full definitions of these 

21 terms. 

22 MR. BROOKMAN: Steve Ruffing. 
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1 MR. RUFFING: Steve Ruffing, Nidec 

2 Motor Corporation. There was one comment made in 

3 the NOPR related to air-over motors that I was 

4 hoping for a little clarification on. 

5 It notes that these motor types are 

6 excluded but then it makes an additional 

7 statement about air-over motors that I was 

8 curious about. 

9 It says, "In addition, DOE is 

10 proposing not to set standards at this time for 

11 air-over motors, but intends to address these 

12 types of motors in a separate rulemaking." I just 

13 wanted to inquire what was meant by that. 

14 MR. BROOKMAN: Doug. 

15 MR. RAWALD: And, Steve, once again 

16 if you refer to the final rule, preamble in that, 

17 also discuss that similar point, that the 

18 Department's going to continue to look at the 

19 possibility of testing those types of motors in 

20 the future. 

21 And if a test procedure becomes 

22 available, we would then possibly consider or 
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1 discuss going down the path of developing 

2 standards for those types of motors. 

3 MR. BROOKMAN: Okay, I guess we're 

4 ready to move on. 

5 MR. COFFEY: Great. So now we have 

6 those requests for comment, Doug, that you 

7 mentioned. 

8 MR. BROOKMAN: Pardon me. One of our 

9 webinar participants has a question. This is 

10 from Tuan Ngo or No. "Is pool pump motors subject 

11 to the proposed standard?" 

12 MALE PARTICIPANT: No. 

13 MR. COFFEY: So coverage isn't listed 

14 in those terms. They could be covered if they met 

15 all the criteria for coverage as listed. 

16 However, it's also DOE's 

17 understanding that many pool pump motors have 

18 additional features which would exclude them 

19 from coverage. 

20 MR. BROOKMAN: Gary Fernstrom. 

21 MR. FERNSTROM: So this is Gary 

22 Fernstrom on behalf of the California IOUs. This 
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1 has been an issue for us and the California 

2 Energy Commission as the CEC regulates 

3 residential filtration, pool pumps and motors as 

4 well as pool pump motors. 

5 These products are typically 

6 single-phase; therefore, they do not meet the 

7 three-phase requirement. The variable-speed 

8 versions are inverter fed; therefore, they do 

9 not meet the requirements. 

10 So in general, the type of pool pumps 

11 which California are regulating which are 

12 single-phase, one- to five-horsepower are not 

13 subject to this rulemaking. 

14 MR. BROOKMAN: Okay, thank you. Steve 

15 Rosenstock. 

16 MR. ROSENSTOCK: Steve Rosenstock, 

17 EEI. I know that there was a separate small 

18 electric motor rule that was finalized in April 

19 2010. It goes in effect April 2015. Didn't that 

20 one cover, I know it covered some of the PSC 

21 motors in the, I think, didn't that cover some 

22 of the single-phase motors as well? 
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1 MALE PARTICIPANT: Not PSCs. 

2 MR. ROSENSTOCK: Not PSCs? I'm just 

3 wondering, did pool pumps fall into that 

4 category of -- 

5 MR. BROOKMAN: I see Rob. Please, 

6 Rob. 

7 MR. BOTELER: Yes, the small motor 

8 rule covers general purpose open drip-proof 

9 motors and it does cover cap start/cap run and 

10 cap start/induction run but it doesn't cover 

11 variable speed ECMs. So to Gary's point, they're 

12 not covered, no. 

13 MR. BROOKMAN: Okay. Gary, you want 

14 to follow on? 

15 MR. FERNSTROM: Excuse me. Yes, I'd 

16 like to ask for a clarification from Rob now. The 

17 California Energy Commission regulations do 

18 affect cap start/induction run permanent split 

19 capacitor and cap start/cap run in that there is 

20 a design regulation covering those single-phase 

21 motors in a range up to five horsepower. So going 

22 back to Steve's point, does that prior rule 
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1 create a conflict or no? 

2 MR. BOTELER: This is Rob. I would 

3 have to defer that one to the lawyers from the 

4 Department that are sitting at the table. I can't 

5 answer that one. 

6 MR. FERNSTROM: Okay, well, we would 

7 collectively then, including Tuan from the CEC, 

8 ask for a clarification on this because it may, 

9 with regard to that prior rule, still represent 

10 a point of confusion. 

11 MR. BROOKMAN: Doug. 

12 MR. RAWALD: So the procedure for 

13 currently in place rulemaking that we follow is 

14 to request guidance from the public in writing 

15 so we could then research and give you a good 

16 answer. 

17 So if you want to submit that to us, 

18 you can and we could provide you the email 

19 address outside the meeting here to do that and 

20 we could consider that and then get back to you. 

21 MR. FERNSTROM: Okay, thanks so much. 

22 MR. BROOKMAN: Okay. So now we're 
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1 moving on. 

2 MR. COFFEY: So yes, now we have our 

3 request for comment. DOE seeks data on any other 

4 subsets of 56-frame motors so these have overlap 

5 with possibly the small motors rule, 

6 particularly those motors that are, one, 

7 enclosed general purpose electric motors that 

8 have a rating of under one horsepower and, two, 

9 open or special, definite purpose inclusive 

10 electric motors. 

11 The types of data that DOE seeks 

12 includes, but is not limited to the following 

13 categories, efficiency distribution, shipment 

14 breakdown between horsepower ratings, open and 

15 enclosed motors and between general, special and 

16 definite purpose motors as well as typical 

17 applications that use these motors. 

18 MR. BROOKMAN: Rob. 

19 MR. BOTELER: Yes, Rob Boteler 

20 speaking on behalf of NEMA. I think NEMA is not 

21 in a particularly good position to give you 

22 information on this in the future. Today we don't 
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1 collect a lot of this data. 

2 But one of the issues that we have 

3 is going back to the small motor regulations is 

4 some of the definitions are not clear to us and 

5 we've asked for some of those definitions to be 

6 clarified on the small motor that are currently 

7 covered. 

8 And I think before we would be able 

9 to address anything going forward on, you know, 

10 56-frame and enclosed or open, definite/special 

11 purpose, we would need to have clear definitions 

12 from the Department of what really we're looking 

13 at in terms of the definition of an electric 

14 motor. 

15 Our standards are not as concise, 

16 perhaps, as you might think they would be 

17 compared to what we talk about on the medium 

18 motors and we need to address that with DOE 

19 before we could help out. 

20 MR. BROOKMAN: Okay, thank you. Dan 

21 Delaney. 

22 MR. DELANEY: Yes, Dan Delaney on 
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1 behalf of NEMA as well. Just to clarify again, 

2 the 56-frame product as we get into a two-digit 

3 frame does take us into a little bit more of a 

4 realm of an OEM-specific type product. 

5 So there are kind of two realms of 

6 that product, a distribution type style product 

7 which we feel is covered within this rule and 

8 then as you get into special and definite 

9 purpose, which this rule does get into with 

10 enclosed one horsepower and greater, that 

11 product on the OEM side does not follow the same 

12 type of, you know, we'll say designs today. 

13 The OEM specific is built, you know, 

14 for that customer's application for the torque, 

15 for the speeds, and is not built around typically 

16 efficiency as one of the criteria. 

17 So that's something else to note in 

18 the respect we do not have data as an 

19 organization but another reason where confusion 

20 begins obviously at the one horsepower and 

21 greater as well as the below one horsepower which 

22 we've been seeking clarification on, both with 
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1 this current rule, so. 

2 MR. BROOKMAN: Yes, Dale Basso. 

3 MR. BASSO: Dale Basso, WEG Electric. 

4 I guess one question we sort of also have is this 

5 question is asking about motors below one 

6 horsepower but our understanding is that this 

7 regulation specifically listed that as one 

8 horsepower and above. So is that something we 

9 should ignore at this point or are you trying to 

10 expand this regulation? 

11 MR. COFFEY: Well, it sounds as 

12 though people are commenting on some terms that 

13 have been defined in maybe the small motors rule 

14 and some other rulemakings. I think Doug 

15 mentioned that there's always the opportunity to 

16 request some guidance which DOE may then 

17 consider and respond to. 

18 MR. BASSO: I'm not sure I understood 

19 that. 

20 MR. RAWALD: Dale, this is Doug 

21 Rawald from DOE. So once again, one of the nine 

22 criteria would be the rule applies to motors that 
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1 are more or at least one horsepower, so that's 

2 not the intent of this question. 

3 But the 56-frame are a different 

4 animal than the other types of motors so we want 

5 to have data from you folks so we could better 

6 make sure the rule meets those particular 

7 situations. Does that make sense? We're not 

8 seeking to expand the scope beyond the nine 

9 criteria about this question. 

10 MR. BASSO: You want data below one 

11 horsepower? 

12 MR. BROOKMAN: Microphone. 

13 MR. BASSO: This is Dale Basso. 

14 You're requesting data below one horsepower? 

15 MR. RAWALD: Unique to the 56-frame 

16 because the 56-frame, as I said, a different type 

17 of motor than the average motors that we're 

18 dealing with and has been subject of a lot of 

19 discussions in the past rulemakings. 

20 MR. BROOKMAN: You all set? Okay. Are 

21 there still comments here, this issue? Did you 

22 set them both up, Brian, for us? 
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1 MR. COFFEY: So I haven't read the 

2 second, although we've certainly heard some 

3 comments on it already. 

4 MR. BROOKMAN: Right. 

5 MR. COFFEY: DOE's requesting 

6 comment on the nine characteristics of electric 

7 motors and their appropriateness for outlining 

8 scope of standards. 

9 MR. BROOKMAN: Any additional 

10 comments here? Because we're about to move on. 

11 Roger Daugherty, please make your 

12 comment. 

13 MR. DAUGHERTY: Roger Daugherty. I 

14 had a follow-up question on something that I 

15 heard from the presenter in response to the 

16 question about pool pump motors. I believe what 

17 I heard was that there may be some other 

18 characteristics of those motors which would 

19 exempt them. 

20 In trying to look at the proposed 

21 language that goes into Part 431 at the end of 

22 the NOPR, I can't find anything that would 
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1 indicate that some other characteristic other 

2 than the nine that are listed would be used for 

3 making a determination as to whether or not 

4 something's a covered product. Could you please 

5 expand on that comment? 

6 MR. COFFEY: Yes, I can clarify. Gary 

7 mentioned, for example, that many of these pool 

8 pump motors would be single phase, and so by 

9 virtue of that, they would not be considered 

10 covered under this particular rulemaking. 

11 But I only mention that to clarify 

12 that a motor meeting these nine criteria would 

13 not be excluded solely by virtue of being used 

14 in a pool pump. 

15 MR. BROOKMAN: Doug. 

16 MR. RAWALD: And this is Doug Rawald. 

17 So, Roger, I think what you're referring to, as 

18 Brian said, there are additional features to the 

19 pool pump motors that put them outside of this. 

20 And what he meant by that simply were 

21 there are additional features that would make 

22 them not meet the nine criteria. He was not 
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1 articulating that there are actually exceptions 

2 beyond the nine criteria that we established. 

3 MR. BROOKMAN: Okay, thank you. So 

4 then this test procedure modification slide, we 

5 already saw that. Are there any comments on -- 

6 go to Slide 26. 

7 MR. ROSENSTOCK: Doug. 

8 MR. BROOKMAN: Oh, yes, Steve. 

9 MR. ROSENSTOCK: Steve Rosenstock. I 

10 hate to do this but because of the feedback, I 

11 might want to ask people in the room to turn off 

12 their electronic devices because I know when I'm 

13 in public speaking they always tell me to turn 

14 off my device before I move near a microphone. 

15 MR. BROOKMAN: Well, we could try it. 

16 See if that helps. We've got a guy here working 

17 on it so hopefully we'll gain some ground. 

18 And I'm going to suggest in a little 

19 bit we're about to take a break and maybe he can 

20 make some headway during our break. But maybe we 

21 could try that. Just actually turn off the 

22 devices. Maybe that'll make a difference. 
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1 We'll try it. Maybe it'll work. 

2 Okay, so and apologies for everyone in the room 

3 and also online for all this feedback here. We're 

4 working on it and hopefully our A/V guys can do 

5 some good here. 

6 This test procedure modification 

7 slide was, I guess, the first -- 

8 MR. COFFEY: Yes, so we already saw 

9 the test procedure slide. It was transplanted to 

10 earlier. 

11 MR. BROOKMAN: And no one had any 

12 comments on the test procedure modifications 

13 slide at that point. Okay, so we are moving on 

14 then. 

15 MR. COFFEY: Okay, so that bring us 

16 to equipment classes and groups. Once scope is 

17 established, DOE divides covered equipment into 

18 classes by type of energy used, the capacity of 

19 the equipment or other performance-related 

20 features that justify different standard levels 

21 such as features affecting consumer utility. 

22 For this rulemaking, equipment 
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1 classes are based on the combination of NEMA 

2 design type, brakes and fire pump rating, 

3 horsepower rating, pole configuration and 

4 enclosure type. 

5 So an equipment class group is a 

6 collection of, yes, motors with the same design 

7 type. So even though there may be a large number 

8 of standards within an equipment class group 

9 based on horsepower, number of poles and whether 

10 the motor is open or enclosed, each equipment 

11 class group is held to the same, you know, NEMA 

12 band, the same table within MG 1. 

13 So DOE created equipment class 

14 groups, as I think most people know, as follows. 

15 It's NEMA Design A or B in Equipment Class Group 

16 1, NEMA Design C in Equipment Class Group 2 and 

17 their IEC equivalents, fire pump motors in 

18 Equipment Class Group 3 and electric motors with 

19 brakes in Equipment Class Group 4, so those 

20 haven't changed. 

21 Here, again, is a summary of DOE's 

22 equipment class structure. There are four 
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1 groups, as I just mentioned, and within a group 

2 standards vary by horsepower, pole count and 

3 enclosure type, so just a little bit more detail 

4 on what we just saw. 

5 Request for comments on all that. 

6 DOE seeks comments on its decision to analyze 

7 brake motors in a separate equipment class 

8 group. 

9 And then Issue 15, DOE seeks comment 

10 on its decision to limit standards for brake 

11 motors to one to 30 horsepower and to 4-, 6- and 

12 8-pole configurations. 

13 DOE selected these ratings after 

14 reviewing manufacturer catalogs and finding 

15 brake motors in only these configurations. 

16 MR. BROOKMAN: John Malinowski. 

17 MR. MALINOWSKI: Yes, John 

18 Malinowski. I'm going to put my NEMA hat on for 

19 this one. 

20 I think I've got really two 

21 questions here. We skipped over earlier the idea 

22 that the DOE NOPR included U-frame motors along 
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1 with T-frame motors and raised the efficiency 

2 requirements from Table 12-11 to Table 12-12. I 

3 didn't see that included in anything here. 

4 The petition put forth by the 

5 coalition proposed that U-frames remain as Table 

6 12-11. So, in essence, they would be in Equipment 

7 Class Group 3 and be the same horsepower ratings 

8 as, well, I'm sorry. They would be one to 200 

9 horsepower at Table 12-11. Certainly they could 

10 go higher in horsepower. 

11 If the DOE would have looked at the 

12 U-frames separately from T-frames and looked at 

13 the financial impact of redesigning those 

14 motors, very small sales in those. 

15 The cost to redesign those and the 

16 effort to redesign a product line that's on its 

17 way out is probably unjustified in NEMA's eyes. 

18 We still would strongly recommend that the DOE 

19 reconsider moving those to Table 12-11. 

20 Also with regard to brake motors, I 

21 think you've captured most standard stock 

22 available brake motors, certainly are in the one 
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1 to 30 horsepower range. 

2 Most manufacturers offer larger 

3 motors but generally in those cases many 

4 applications are such that they are Design D or 

5 intermittent-duty motors for cranes and hoists 

6 and they would be out of the scope of coverage. 

7 MR. COFFEY: So in your opinion this 

8 is sufficient as written? 

9 MR. MALINOWSKI: Yes. 

10 MR. COFFEY: Thank you. 

11 MR. BROOKMAN: Thank you, John. Yes, 

12 Bill. 

13 MR. FINLEY: Bill Finley. I believe 

14 I'm speaking for NEMA here too. As far as 

15 Equipment Class 1, NEMA will comment back on how 

16 to maybe word that that includes other products 

17 that don't have an A and a B as we talked about 

18 earlier, that are not defined for the product. 

19 The larger ratings, assuming we 

20 intend on going up to 500 horsepower and the 

21 slower speeds, we'll come back with a proposed 

22 comment from NEMA. 
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1 MR. BROOKMAN: Okay, thank you. Yes, 

2 Dale Basso. 

3 MR. BASSO: Dale Basso, WEG. Just a 

4 little more on the brake motor issue. I guess I'm 

5 not sure the reason for breaking them into a 

6 different class unless you're going to put a 

7 different energy value or efficiency value on 

8 those. 

9 So in the test standard, you were 

10 talking about the test you did said that there 

11 was no significant difference and you were 

12 keeping the same test procedure. 

13 You know, potentially there's a 

14 slight friction and windage adder that you'd 

15 like to say you got to take into account when 

16 you've got a brake on a motor. 

17 But if you're not going to set a 

18 different level of efficiency, then breaking 

19 them out actually adds a category you don't need. 

20 The other part of that is the larger 

21 brake motors do exist, but they're really just 

22 a motor with a brake. And so I really would be 
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1 careful that people don't take exception, you 

2 know, see that as, oh, they're only covered up 

3 to 30 horsepower and then say that they don't 

4 have to have the efficiency on the bigger ones. 

5 It's a really small market. I mean, 

6 there's not really an energy picture. As John 

7 said, most of them are special and most of them 

8 probably won't fall under the regulations for 

9 other reasons. 

10 But if they did, you're just 

11 creating a loophole that's not really necessary, 

12 so I guess I'd just ask why you created the 

13 additional category. 

14 MR. BROOKMAN: Doug first. 

15 MR. RAWALD: Dale, I'm not going to 

16 answer your question. I think it's a good 

17 question for us to consider. 

18 But what I want to ask you to do in 

19 your written comments if you could, to help us, 

20 is come up with ways that would be better for us 

21 to enforce motors that are with a brake added so 

22 that they would not be able to fit in that 
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1 loophole because that is going to be helpful to 

2 us as we're trying to do this over time. Thank 

3 you. 

4 MR. BROOKMAN: Andrew. 

5 MR. DELASKI: I'll just follow on and 

6 concur with Dale. It just seems to me that if it's 

7 the same standard, you don't need a separate 

8 class and that you wouldn't -- there probably are 

9 other motors that are covered that have most of 

10 their market share in some horsepower range, 

11 right, but we aren't limiting those motors based 

12 on horsepower range, right, it's put in the 500 

13 horsepower range. 

14 And I just think that that's a layer 

15 of complexity that set the ceiling for a 

16 particular class that could result in 

17 misunderstandings like Dale just described, 

18 someone thinks they're out of scope when they're 

19 in scope. It would just seem to me it's the same 

20 level. You don't need a separate class when it's 

21 one to 500 horsepower. 

22 MR. BROOKMAN: Okay. Yes, Dale. 
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1 MR. BASSO: Dale Basso. From our 

2 perspective as manufacturers, you know, 

3 electrical design-wise, you know, if it's just 

4 a standard motor with a brake, you know, we want 

5 to use the same standard electrical design. 

6 We don't want to have to create a 

7 special one to maybe take into account a few 

8 extra watt losses or something, so we need to be 

9 able to consider the exclusion of the brake 

10 losses in the criteria. 

11 But other than that, you know, 

12 unless it's a special electrical design which 

13 falls outside this anyhow, you would struggle 

14 with the reason to add it. 

15 MR. BROOKMAN: Okay. 

16 MR. COFFEY: So here's the technology 

17 assessment and the list of the technology 

18 options that DOE identified for improving motor 

19 efficiency. 

20 It's worth mentioning, of course, as 

21 has been pointed out before, that many of these 

22 are not completely independent of each other 
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1 but, rather, part of a larger optimization 

2 process of which efficiency is only one input, 

3 so we've seen these before. I won't read them but 

4 here they are. 

5 And that brings us to the 

6 engineering analysis. 

7 MR. BROOKMAN: At this point I think 

8 we should take a break. Let me say before we go 

9 to break a couple of individuals approached me 

10 this morning and said we're going to submit a lot 

11 of written comments and maybe we can move rather 

12 rapidly through this meeting today, we're now on 

13 Slide 32 and there are 117 slides, the thought 

14 being that maybe we could push through lunch and 

15 get it done. That doesn't seem likely to me at 

16 this point. 

17 However, we're due for a break. So 

18 it's now 11 o'clock. We'll come back at 11:15. 

19 Well, let's just see how it turns out, how long 

20 our endurance stays with us. 

21 Yes, apologies again for the delay 

22 at the outset. But we'll resume here at 11:15. 
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1 You must wear a badge inside the Forrestal 

2 building. There are restrooms on both ends of the 

3 hall. There's a water fountain at that end. If 

4 you're going to go to the coffee shop, please go 

5 quickly and we'll see you back here to resume at 

6 11:15. 

7 (Whereupon, the above-entitled 

8 matter went off the record at 11:01 a.m., and 

9 resumed at 11:19 a.m.) 

10 MR. BROOKMAN: Okay, as a way of 

11 starting off, and we've got an A/V person working 

12 on the feedback again so maybe we'll make 

13 progress on that. 

14 I've had a request that we revisit 

15 the pool pump issue briefly and so let me go 

16 straight to Gary Fernstrom. 

17 MR. FERNSTROM: So this is Gary 

18 representing the California IOUs. I think we 

19 pretty well determined that there's not a 

20 conflict with this regulation covering pool pump 

21 motors for a number of reasons, one key one being 

22 polyphase versus single phase. Reference was 
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1 made to a prior regulation which is 431.441 and 

2 -- 

3 MR. BROOKMAN: Small motors. 

4 MR. FERNSTROM: Yes, small electric 

5 motors. This regulation applies to small general 

6 purpose motors, not small definite purpose 

7 motors as defined by NEMA, and pool pump motors 

8 are defined special purpose motors. 

9 So I would submit for DOE's 

10 consideration that this regulation does not 

11 apply to pool pump motors either because it 

12 applies to general purpose motors, not defined 

13 purpose motors. 

14 MR. BROOKMAN: Okay, thank you. 

15 Always nice to gain clarity where we can, okay. 

16 So then we're going to proceed with the 

17 engineering analysis and, Brian, are you going 

18 to introduce our, what's his name? Howard 

19 Jordan. 

20 MR. COFFEY: I will, but not at this 

21 slide. 

22 MR. BROOKMAN: Okay, so then we're 
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1 proceeding, engineering analysis and Brian 

2 Coffey. 

3 MR. COFFEY: Yes, so here we are at 

4 the engineering analysis. Here's the diagram you 

5 saw before showing the engineering analysis is 

6 an important input for several downstream 

7 analyses. 

8 And the purpose of the engineering 

9 analysis is really to evaluate design options 

10 that improve efficiency and to characterize 

11 manufacturer selling price versus efficiency 

12 for all equipment classes in the rulemaking. 

13 So that cost/efficiency 

14 relationship is an important input into the 

15 life-cycle cost, the payback period analysis, 

16 national impact analysis as well as the 

17 manufacturer impact analysis. 

18 Because it's not possible to 

19 directly analyze all covered designs, DOE 

20 chooses certain units to be representative of 

21 the rest. 

22 In this rulemaking, DOE selected 
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1 three representative units for Equipment Class 

2 Group 1 and two for Equipment Class Group 2, so 

3 here's a table showing how those are structured. 

4 And then here's a graphical overview 

5 of where the representative units fall relative 

6 to the scope of horsepower coverage, similar 

7 information just presented in a slightly 

8 different way. 

9 MR. BROOKMAN: Steve Rosenstock. 

10 MR. ROSENSTOCK: Hi. Question. Steve 

11 Rosenstock, EEI. The slide says average 

12 efficiency available, and then I'll just say for 

13 Equipment Class 1, is that for covered as well 

14 as non-covered, currently covered products as 

15 well as not currently covered products? 

16 MR. COFFEY: Well, this is just sort 

17 of heuristic to show graphically where the use 

18 would fall and what would be kind of a typical 

19 efficiency for that horsepower range. 

20 So I don't know, to be honest, the 

21 data set that was filtered to limit it but many 

22 of these motors would have minimum standards so 
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1 effectively they would be covered. 

2 MR. ROSENSTOCK: Thank you. 

3 MR. COFFEY: Okay, so in each 

4 equipment class, DOE identifies efficiency 

5 levels that range from baseline to the maximum 

6 technologically feasible level. 

7 Factors considered in setting ELs 

8 include commercially available and software 

9 modeled efficiencies, NEMA standard nominal 

10 efficiencies, for example Table 12-10, as well 

11 as benchmark industry efficiency levels such as 

12 NEMA Premium. 

13 Here are the actual efficiency 

14 levels analyzed for Equipment Class Groups 1, 3 

15 and 4 and then 2 is on the next slide. 

16 MR. BROOKMAN: Steve Rosenstock. 

17 MR. ROSENSTOCK: Steve Rosenstock, 

18 EEI. I kind of alluded to this in my opening 

19 statement, but especially for EL 0 when I look 

20 in the technical support document it says the 

21 lowest observed efficiency under expanded 

22 scope. 
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1 And using this value, especially 

2 for, like, a five horsepower value, it looks 

3 like, and again this spills over into all the 

4 other economic and national impact analysis, it 

5 looks like for a baseline that the motor with the 

6 absolute worst deficiency was chosen as a, 

7 quote, "baseline," not the average efficiency or 

8 shipment weighted average or median but the 

9 worst possible efficiency. 

10 The reason I mention that, obviously 

11 it spills over. You start out with the worst 

12 deficiency motor. Then your energy efficiency 

13 and your economic numbers look a lot better when 

14 you're comparing against the worst absolute 

15 motor out there. 

16 I'm very surprised that this unit 

17 was chosen for the baseline because it's not 

18 reflective of the market, especially for covered 

19 products. Covered products are EL 1 or EL 1-1/2, 

20 whatever the EISA 2010 value is. 

21 So, again, maybe for non-covered 

22 products, there are some motors that are 82.5 for 
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1 example, but that could be just the outlier, the 

2 extreme, when most motors are going to be much 

3 more efficient, especially for applications in 

4 the industrial sector where they do try to 

5 typically use higher efficiency motors. 

6 MR. COFFEY: So I might defer that to 

7 Sanaee to explain the methodology of how the 

8 energy savings are calculated. 

9 MS. IYAMA: This is Sanaee from the 

10 Lawrence Berkeley National Lab. So when we 

11 calculate the life-cycle cost savings, for 

12 example, we look at the difference between a base 

13 case situation and a standards case situation. 

14 And in the base case, we account for 

15 those motors that are already at NEMA Premium, 

16 for example, by using efficiency distributions. 

17 So if you look at the efficiency 

18 distributions that were used, and here I only 

19 have the table for the year 2012 for example, 

20 about ten percent of the motors are at EL 0 in 

21 Equipment Class Group 1, and we already have over 

22 35 percent of motors that are at Premium, for 
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1 example. 

2 MR. BROOKMAN: Andrew. Oh, Steve, did 

3 you finish? Go ahead, Andrew. 

4 MR. DELASKI: I just wanted to follow 

5 on Steve. So, Steve, you and I have sat in these 

6 hearings for 15 years or longer and this is the 

7 way it's always been done until, I mean, the 

8 Department should weigh in here, help me out for 

9 that. 

10 This is not a divergence from any 

11 practice, any rulemaking. It's the way it's 

12 always been done, what Sanaee just described, 

13 for every rulemaking that I've been involved in 

14 for nearly 20 years. 

15 MS. IYAMA: This is Sanaee. The only 

16 difference I think in this rule is that we have 

17 an equipment class where we have covered and 

18 non-covered products, so products -- 

19 MR. DELASKI: But that's not that 

20 unusual a circumstance. There are many dockets 

21 in which we're covering a product newly covered. 

22 GSFL, we cover new categories of lamps. There are 
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1 dockets right now for wine chillers. There are 

2 lots of dockets. 

3 MS. IYAMA: I agree. 

4 MR. DELASKI: So this is a standard 

5 practice the Department has been doing and to 

6 handle it by weighted average by looking at a 

7 distribution of efficiencies -- 

8 MR. BROOKMAN: Let's hear from the 

9 Department. Doug. 

10 MR. RAWALD: I was at a past meeting 

11 where our colleague from Northeast Energy 

12 Alliance did a very good job of explaining this 

13 point. I thought that was helpful for folks that 

14 were not familiar with this so if you wouldn't 

15 mind explaining that here, that would be, I 

16 think, helpful. 

17 MR. BROOKMAN: Charlie Stevens. 

18 MR. STEVENS: Doug, you may have to 

19 remind me what I said. 

20 (Laughter) 

21 MR. STEVENS: Which one of the last 

22 seven meetings that I attend did I say it in? The 
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1 way I understood this is we are newly covering 

2 products here that have never been covered 

3 before. So many of them are going to be at exactly 

4 as it was described, the lowest efficiency 

5 available or seen or you can buy in the 

6 marketplace. 

7 But as we always do, as Andrew just 

8 pointed out, not all of the market is there and 

9 so when you actually look at cost and efficiency 

10 distributions later in the analyses, you account 

11 for how many are already at that efficiency that 

12 you're proposing at any given TSL and those 

13 people will be unaffected by the standard. 

14 But there's also some at the bottom 

15 that will be impacted by the standard and the 

16 savings are larger there, the costs are larger 

17 there. But this is all, you know, as Andrew says, 

18 this is how the analysis works. 

19 But when you've got products in this 

20 class that are unregulated right now, then you 

21 just look at the marketplace to see what the 

22 least efficient product is and that's EL 0 here. 
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1 MR. DELASKI: If I could just follow 

2 on, Doug, for a moment. That goes back to Neal's 

3 opening statement. This was the idea behind the 

4 petition made by the joint stakeholders, was 

5 that there's a lot more efficiency to be gained 

6 at the delta there, help me out there, it was 

7 seven points of efficiency on that 

8 five-horsepower motor. 

9 That's why this is such a big 

10 rulemaking. The potential there was to bring 

11 motors that have been basically not covered by 

12 any standards and capture that large efficiency 

13 delta. 

14 Even for a small portion of the 

15 market would drive some significant savings in 

16 this docket in comparison to one of the paths 

17 that was considered early in this rulemaking 

18 which was to go from EL 2 to EL 3 for also a good 

19 portion of the market. 

20 But that EL 2 to EL 3 data there shows 

21 it's 0.7 points so it's ten times the savings 

22 just for that one sample, that one number or that 
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1 one motor. 

2 So I think that slide kind of 

3 encapsulates some of the principles behind the 

4 joint recommendation made by the Motor 

5 Coalition. 

6 MR. BROOKMAN: Okay, thank you. 

7 Steve, you want to follow on? 

8 MR. ROSENSTOCK: Steve Rosenstock, 

9 EEI. I understand all that. It's just especially 

10 the way the language is written in the technical 

11 support document. Maybe it's semantics. 

12 Especially for Equipment Class 

13 Group 1 it makes it appear that, again, the way 

14 it's looking is that all motors, covered and 

15 non-covered, are at Efficiency Level 0. That's 

16 the problem I have with it. 

17 MR. COFFEY: Yes. It's -- 

18 MR. ROSENSTOCK: And therefore, it's 

19 overstating the potential energy savings that 

20 actual consumers would actually find in the 

21 marketplace unless you're at that actual worst 

22 motor. That's the issue I have. 
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1 The savings for an uncovered motor 

2 at that efficiency is no problem. The problem I 

3 have is the way it looks. And, again, in terms 

4 of possible spillover, it's showing as if 

5 Efficiency Level 0 was for both the covered and 

6 non-covered products. That's the worry I have. 

7 It's -- 

8 MR. BROOKMAN: Okay, so we hear you 

9 and -- 

10 MR. ROSENSTOCK: Thank you. 

11 MR. BROOKMAN: -- that was what you 

12 said in your opening comments as well. Okay. 

13 Additional comments here? Okay. 

14 MR. COFFEY: Great. So then I 

15 mentioned here are the efficiency levels for 

16 Equipment Class Group 2. Same table we saw, just 

17 different numbers. 

18 Okay, to characterize cost and 

19 efficiency, DOE did a few things. First, they 

20 purchased, tested and tore down five electric 

21 motors spanning ELs 0 to 3 for Equipment Class 

22 Group 1 and EL 0 for Equipment Class Group 2, then 
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1 supplemented those findings with data made 

2 publicly available by manufacturers as well as 

3 through interviewing manufacturers directly. 

4 For the max-tech ELs for which there 

5 were no offerings on the market, again this is 

6 maximum technologically feasible is what DOE's 

7 attempting to characterize, DOE used software 

8 modeling with a proprietary program called VICA. 

9 They purchased and tore down 5- and 

10 30-horsepower copper rotor motors in order to 

11 calibrate the software results which appear in 

12 the table shown here. 

13 And at this point I would also invite 

14 a participant on the webinar, Howard Jordan, who 

15 served as a subject matter expert for us to talk 

16 a little bit about the modeling process and how 

17 it pertains to these high efficiency designs. 

18 Howard, are you there? Can you introduce 

19 yourself? 

20 MR. JORDAN: Can you hear me? 

21 MR. BROOKMAN: Yes, we can hear you, 

22 Howard. There's feedback in the room but we can 
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1 hear you quite clearly if you speak loudly. 

2 MR. JORDAN: Okay. Do you have the 

3 view graphs that I sent or -- 

4 MR. BROOKMAN: We have them loaded. 

5 Can you advance those slides, Brian? 

6 MR. COFFEY: Well, is it a separate 

7 presentation? Everyone in the room has got a 

8 copy. 

9 MR. BROOKMAN: We all have a copy. 

10 MR. JORDAN: Okay, so I will be happy 

11 to refer to slide numbers or some way or another 

12 coordinate with what you have. 

13 I'm very pleased with the 

14 opportunity to talk with you today about 

15 software modeling that we have performed as part 

16 of this rulemaking program. 

17 About this program we got a number 

18 of comments and questions relative to the 

19 robustness of the software used for modeling so 

20 I thank you for the chance to submit some of this 

21 background on software. 

22 I have been asked to try to 
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1 abbreviate this discussion in order to help with 

2 the time situation so I will certainly try to do 

3 that. As King Henry VIII said to each of his six 

4 wives, I won't keep you long. 

5 (Laughter) 

6 MR. JORDAN: Okay, just a minute, 

7 please. 

8 MR. COFFEY: All right, this is 

9 Brian. Just let me know if you want me to advance 

10 the slide. 

11 MR. JORDAN: All right. I'm sorry for 

12 the interruption. Can you skip one slide and go 

13 to Number 3? Okay, that's where I wanted to start 

14 here. 

15 I'm going to start out with a brief 

16 history of the modeling. As I indicated, the 

17 program I'm using is VICA. It was originally 

18 developed by Dr. Cyril Veinott, a well-known 

19 pioneer in induction motor design. 

20 And I've been using it for quite a 

21 number of years, I think back end of the 1990s 

22 when I helped him with a course on that program. 
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1 I've made several changes in it as I've gone 

2 forward. 

3 We go now to Slide 5. I'm going to 

4 skip some slides here and probably skip around 

5 in the slides just as a matter of shortening our 

6 talk. Yes, that's the one that I want. 

7 We are aware of at least two motor 

8 manufacturers that have used VICA as their 

9 principle design tool, Lincoln Electric in 

10 Cleveland and Eberle in Brazil. I have really 

11 only talked with Eberle once and that was many 

12 years ago so I can't comment on their use. 

13 I have some better information on 

14 Lincoln and they used the software in the design 

15 of their energy efficient line of motors which 

16 is a very competitive line of motors so it must 

17 have worked pretty well for them. 

18 And now if we can go to I believe it's 

19 the following slide. Okay. The reason that I'm 

20 putting this one and one other application slide 

21 in here is to indicate specifically how some of 

22 the designs that we made with VICA have been 
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1 built and tested and done quite well. 

2 The first one that I'm going to talk 

3 about is the EMALS. That's the Navy's 

4 Electromagnetic Aircraft Launching System. I 

5 was working at that time with the University of 

6 Texas Research Center and they had the contract 

7 to build the energy storage systems for EMALS. 

8 I'm not going to go into much of the 

9 detail regarding the EMALS program but it 

10 basically was comprised of a linear motor 

11 located underneath the deck to provide traction 

12 force to give the aircraft liftoff speed. EMALS 

13 was intended and will replace the catapult 

14 systems. And then the following slide. 

15 The second component after the 

16 linear motor is the energy storage system and 

17 that's what we were responsible for at UT. 

18 The launching of the aircraft 

19 requires so much power that it exceeds the power 

20 capability of the ship's generators, and power 

21 was provided by the energy storage system. Next 

22 slide, please. 
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1 The energy storage system is a high 

2 inertia generator driven by induction motor and 

3 the purpose of the motor is to drive the 

4 generator up to top speed. 

5 During a launch, it loses speed as 

6 it delivers energy to the bus, and then at the 

7 end of the launch you have to drive it back up. 

8 This all takes place in less than a minute so it's 

9 a very rapid situation. And the next slide, 

10 please. 

11 The purpose of my relating all this 

12 is that it was a place where we had to design a 

13 motor to a very stringent set of specifications 

14 that were established by the Navy and General 

15 Atomics, the prime contractor. 

16 These specifications very clearly 

17 were quite different from the NEMA Design B motor 

18 spec, but they still required the accurate 

19 prediction of torques, currents and 

20 efficiencies and so forth. Next slide, please. 

21 We also were subjected to a very 

22 stringent test to prove that we met all of our 
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1 requirements. It was a week-long witness test 

2 witnessed by both the Navy and General Atomics 

3 and the motor passed it completely. We didn't 

4 have to make any modifications to it whatsoever, 

5 so VICA did a pretty good job for us. 

6 The equipment was then sent on to the 

7 Naval Air Test Station in Lakehurst, New Jersey, 

8 and it served for about two years while the 

9 initial system tests on EMALS had taken place. 

10 Okay, can I have the next slide, please? 

11 The second program where we have had 

12 a similar experience is the Advanced Locomotive 

13 Propulsion System. The acronym for that is ALPS. 

14 And this was a program that was sponsored by the 

15 Federal Railroad Administration. 

16 The portion of ALPS system that was 

17 developed was a flywheel energy storage unit 

18 which was part of the locomotive power 

19 generator. 

20 The main generating plant was a gas 

21 turbine and a plain generator and then this 

22 storage system was used to provide boost power 
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1 during acceleration and then extra power to 

2 maintain it on grades and this allowed the main 

3 generating plant that was powered to run to full 

4 speed which is very good for gas turbine power 

5 plant. 

6 The induction motor that we used, 

7 which will be on the next slide, the induction 

8 motor that we designed was both the motor and 

9 induction generator in this, which delivered 

10 power during the acceleration period and then 

11 accepted the return power during braking. It was 

12 two megawatt running at a top speed of 12,000 

13 rpm. We built this, we tested it and all of the 

14 measured electrical parameters were confirmed 

15 in our calculations. 

16 The other point I did want to bring 

17 up, in both of these situations they were copper 

18 rotors. Some of the questions in the 

19 correspondence related to suitability of VICA 

20 for copper motors. Can I have the next slide, 

21 please? 

22 Okay, we'll leave outside examples 
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1 now and go to [the motor teardowns] done 

2 internally in the program here for this 

3 rulemaking project. 

4 As has already been mentioned in the 

5 previous slide, Navigant purchased a number of 

6 motors built by different manufacturers and they 

7 were torn down and the measurements made used 

8 primarily for cost estimating purposes. 

9 But a subset of these motors was 

10 tested prior to tear down and we acquired enough 

11 data so that we could duplicate the 

12 electromagnetic design. 

13 And using this data, we made VICA 

14 calculations to take the performance of the 

15 motor. Next slide, please. 

16 This is a summary of the results that 

17 we got. I summarized here three important 

18 parameters, efficiency, locked-rotor current 

19 and locked-rotor torque. 

20 The results are very encouraging, 

21 but I call your attention particularly to the 

22 efficiency which is a minus number and this is 
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1 calculated minus test which means that the test 

2 results for efficiency were not only pretty 

3 close but they were higher, so our efficiency 

4 predictions based on this are on the 

5 conservative side. Okay, let's go to the 

6 following slide. 

7 We only had three motors and I'm well 

8 aware that that's not enough for a very good 

9 statistical distribution and the variation in 

10 locked-rotor torque in one case was up to 14 

11 percent. 

12 So it looked like we probably should 

13 do a little bit more with regard to default and 

14 correlation factors than simply use the average. 

15 I did that on the locked-rotor torque. 

16 We took the step of adding one sigma 

17 bandwidth to the average difference for 

18 locked-rotor torque which gave us a design goal 

19 of 12 percent higher locked-rotor torque. 

20 That would mean for a motor that had 

21 150 percent NEMA requirement, we would design to 

22 meet 1.12 times 150 or 168 percent. The next 
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1 slide, please. 

2 We applied this to all of the motors 

3 after this correlation study was done. However, 

4 in terms of a timeline, that was well along in 

5 the program so it certainly raises the question, 

6 well, if we have motors we've designed which 

7 didn't meet this revised locked-rotor torque 

8 spec, what would changing that design do with 

9 regard to the motor efficiency? 

10 To sort of answer that question I 

11 took two specific ratings that were in one of the 

12 previous tables, one was the max tech 30 

13 horsepower Design B and the other, the max tech 

14 5 horsepower Design C and we went back through. 

15 We really optimized those two designs to meet our 

16 new locked-rotor torque requirements and so the 

17 results are on the following slide. 

18 For the 30 horsepower motor, the 

19 optimized design with increased locked-rotor 

20 torque reduced the efficiency by one tenth 

21 percentage point, a very significant reduction. 

22 We used the same core length and used the same 
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1 original optimized design. 

2 For the five horsepower, I did 

3 increase the core length 5.7 percent but the 

4 copper weight was decreased 3.3 percent, so it 

5 has a rather minimal effect on the motor cost and 

6 the efficiency actually increased by one tenth 

7 of a percent. 

8 So the conclusion that I would reach 

9 out of that is at least for the cases that we 

10 studied and looked at, we can change the 

11 locked-rotor torque if we have to get a little 

12 bit higher value. It has a relatively small 

13 effect on the motor efficiency. Can I have the 

14 next slide, please? 

15 We did have one cast Design B cast 

16 copper rotor that was tested and we got all the 

17 results from that. In terms of time, you may 

18 wonder why I didn't incorporate that in the 

19 previous presentation. Well, this five 

20 horsepower came in quite a bit later, after we'd 

21 done the original correlation study. And these 

22 are the results. I'll call your attention again 
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1 to the fact that the efficiency calculated lower 

2 than test, which is good. 

3 The big miss that we had here was in 

4 power factor, and I'm quite sure that that 

5 discrepancy is due to the fact that we don't have 

6 the correct magnetization curve for the steel 

7 used in this particular motor, and I'd like to 

8 elaborate: This is a foreign motor that was 

9 tested and my suspicion is that they probably 

10 used some pretty low-loss steels, high silica 

11 and that tends to provide much more 

12 magnetization being required for those 

13 particular grades of steel. So this is the 

14 results that we got on that copper bar rotor. 

15 It's at a place where we are able to match our 

16 correlation of the VICA program with copper for 

17 our rotor. And the next slide, please. 

18 Okay, we've summarized here several 

19 techniques that we used to validate the software 

20 for this rulemaking program and we've given you 

21 some real-world examples where VICA has produced 

22 motor designs which have been built and tested 
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1 and they've satisfied the needs of the 

2 application. We've also described test 

3 correlation for a limited number of commercial 

4 motors where VICA has been able to duplicate the 

5 motor's performance using teardown data. VICA 

6 software has demonstrated credibility in these 

7 situations. And the final slide, please. Well, 

8 thank you for your attention. 

9 MR. BROOKMAN: Howard, thank you. 

10 Well done. Hang on in case we have questions. 

11 Steve Ruffing. 

12 MR. RUFFING: Steve Ruffing, Nidec 

13 Motor Corporation. Thank you for that 

14 explanation, Howard. I have a few questions for 

15 you about the methodology that the program uses. 

16 In order to obtain a calculated efficiency, you 

17 need to first calculate all the components of 

18 loss, sum them together and then from there you 

19 can derive what the efficiency is. 

20 My question relates to how some of 

21 these components were calculated. My first 

22 question relates to the friction and windage 
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1 component, which is a mechanical loss as opposed 

2 to an electrical loss. 

3 Did it actually make a prediction 

4 for what these losses would be, based on the 

5 information of what bearing size was used, what 

6 the diameter of the rotor was, what the diameter 

7 of the fan was or was that just a value that was 

8 input later after you got the measured value? 

9 That's my first question. 

10 MR. JORDAN: It's not sophisticated 

11 enough to take into account bearing sizes and 

12 fans, no. It is an input item into the program. 

13 If you have information which I was able to on 

14 some designs look at the test data that we had 

15 taken and use the friction and windage that was 

16 available. Otherwise, I had to use some average 

17 values of friction and windage that I took from 

18 my own data for various frame sizes. 

19 MR. RUFFING: Thank you. My second 

20 question relates to the I-squared-R losses. 

21 Those vary as a function of the conductor 

22 temperature, so many programs will make an 
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1 initial prediction for that, then calculate the 

2 temperature rise of the conductor that would 

3 result based on those losses, then readjust the 

4 I-squared-R loss prediction based on your new 

5 temperature, then readjust the temperature rise 

6 based on the new loss prediction and continue to 

7 do that in an iterative fashion until you 

8 basically got a convergence. 

9 A less sophisticated program would 

10 not attempt to make a temperature prediction. 

11 You would input a temperature that you either 

12 estimated or got from a test, and then use that 

13 number to just make a single calculation for the 

14 I-squared-R losses. Which method did this 

15 program use? 

16 MR. JORDAN: The latter method is the 

17 one we used. This program is not, again, the most 

18 sophisticated to the point that it has thermal 

19 analysis attached with it. I've used thermal 

20 analysis as a separate program. 

21 But it's an input item. I took the Design B 

22 temperature rise and added something to that. 
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1 These being energy-efficient motors, you expect 

2 that the temperature's going to be lower than the 

3 absolute temperature. So I estimated it, 

4 hopefully on the conservative side. But the 

5 direct answer to your question is it is an input 

6 item. 

7 MR. RUFFING: And my third question 

8 related to loss breakdown is: does the program 

9 attempt to make a prediction for the stray losses 

10 or is that also an input value? 

11 MR. JORDAN: That is an input item and 

12 that's, of course, a tough one always to get to. 

13 I estimated as a percentage of the full load 

14 value, and I did get some correlation with that 

15 estimate. I did that back when I started the 

16 program and I looked at the test data that was 

17 available from the various tests that had been 

18 run over time in this program and my estimate was 

19 very close to an average of those. But again, the 

20 answer is it is an input item. 

21 MR. RUFFING: Thank you, and then I 

22 had one additional question not related to 
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1 losses. In the NOPR there's a list of technology 

2 options that are considered in order to increase 

3 efficiency and some of these were screened out 

4 by DOE and some were not. And one that was not 

5 screened out was the option of increasing the 

6 copper cross sectional area and the stator 

7 losses. 

8 And in the supporting document, it 

9 describes the method that was used to calculate 

10 the slot fill and it talks about how the slot area 

11 was determined and then a certain number was 

12 subtracted for that to account for insulation 

13 and then the area of the conductors was 

14 calculated and divided into that and that's what 

15 the slot fill is resulting. 

16 My question is: when you determined 

17 the area of the conductors, did you assume that 

18 the conductors are round as they actually are or 

19 did you instead calculate it by assuming the 

20 conductors were square in shape, with the length 

21 of the sides of the square being equal to the 

22 diameter of the conductors? Manufacturers do it 
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1 in either of those two methods and when you use 

2 one, the square method as opposed to the round 

3 method, you'll get an answer that is larger than 

4 the round method by a ratio of four divided by 

5 the number pi. 

6 MR. JORDAN: The answer to your 

7 question is we used the square method. 

8 MR. RUFFING: Okay. 

9 MR. JORDAN: We calculated the square 

10 and we simply take the number of conductors in 

11 the slot times the diameter squared, so we do not 

12 put the pi over four into the slot fill 

13 calculation. 

14 MR. RUFFING: Thank you. I'm 

15 reassured by that answer because the maximum 

16 space factors that were allowed in the study, 

17 which I believe was 85 percent, that would be a 

18 reasonable number if you're using the square 

19 method but it would not be a reasonable method 

20 if you're using the round -- 

21 MR. JORDAN: Yes, that issue has come 

22 up before and I've attempted to define it and 
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1 make it clear in an equation, some of the 

2 responses, but that's the one that I've used and 

3 I think it is, let's call it the more pessimistic 

4 of the two, and that's the way all the slot fills 

5 were calculated. 

6 MR. RUFFING: Thank you. 

7 MR. BROOKMAN: We have a question on 

8 line from Tuan Ngo, pardon me for not knowing how 

9 to pronounce your name. "Why is the baseline EL 

10 0 chosen, not meeting existing standards, i.e., 

11 for the five horsepower the existing standards 

12 require 89.5 percent." 

13 MR. COFFEY: That gets to a little bit 

14 what we were talking about before. The reason for 

15 that is for Equipment Class Group 1 you have a 

16 mix of products that is currently subject to 

17 standards and some that is not currently subject 

18 to standards. 

19 MR. BROOKMAN: Okay, thank you. Dan 

20 Delaney. 

21 MR. DELANEY: Just one more comment 

22 regarding the study here from Howard Johnson 
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1 [Jordan]. Certainly what I heard from Howard, 

2 which was positive, obviously most of AEDM 

3 programs, the most important part obviously is 

4 both the calculation, ensuring you're using the 

5 right method, but also that correlation between 

6 test and the calculation method, which it was 

7 good to see the method in the data that was 

8 presented so I thank Howard for doing that. 

9 I just wanted to note, the VICA 

10 program, Lincoln Electric being a part of the 

11 Regal Company over ten years ago incorporated 

12 through acquisition. I didn't find anyone in 

13 current use. Just wanted to make sure that was 

14 clear today, so I'm not sure what was done in the 

15 past obviously there but -- 

16 MR. JORDAN: If you'll excuse me, 

17 Lincoln exited the motor business, oh, I don't 

18 know, more than five years ago and I think it went 

19 to Marathon, so Lincoln Electric is somewhat 

20 older data, but I'm quite sure that they were 

21 using the program at the time they did their 

22 energy-efficient motor design. And, again, 
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1 that's five years ago. 

2 MR. DELANEY: It would be greater 

3 than five years ago, but just wanted to make sure 

4 that was clear within the business, that, you 

5 know, again, not sure as to what basis of time, 

6 but it would be greater than five years ago that 

7 would have been used as an active program. 

8 Lincoln is still an active line, however, you 

9 won't see it, probably as a standalone line as 

10 much as you did maybe when that was done but 

11 probably over ten years ago. 

12 MR. BROOKMAN: Okay, thank you. Are 

13 we finished with this subject now? Howard, thank 

14 you for the presentation. 

15 MR. JORDAN: Thank you for the 

16 opportunity. 

17 MR. BROOKMAN: Okay, now we're moving 

18 on. An update on the schedule. It turns out that, 

19 I guess the feedback's doing a little better here 

20 at the moment, the Secretary is having his annual 

21 Department holiday luncheon today so they're 

22 closing the cafeteria early. They're closing the 
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1 cafeteria, in fact, at 1 o'clock. So I'm going 

2 to suggest we break for lunch at 12:15, okay, so 

3 that everybody can get lunch and get back here 

4 to finish out the meeting. So that's the plan for 

5 now. 

6 MR. BOTELER: We're not invited to 

7 the Secretary's luncheon? 

8 (Laughter) 

9 MR. BROOKMAN: No, when we conclude 

10 this meeting, as expeditiously as possible, you 

11 can wander on down there and take your chances. 

12 (Laughter) 

13 MR. ROSENSTOCK: They have security 

14 guards down there. 

15 MR. BROOKMAN: Okay, so let's 

16 proceed, Brian. 

17 MR. COFFEY: So, great. We just 

18 talked about high-efficiency modeling. Now that 

19 brings us to how the Department develops 

20 material cost inputs. To estimate electric motor 

21 costs, DOE uses information gathered via 

22 teardowns and from interviewing manufacturers. 
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1 Bills of material tend to catalog all the 

2 component and labor costs involved in 

3 manufacturing a particular motor, and to 

4 characterize markups and labor rates, DOE uses 

5 information gathered from public data as well as 

6 also from manufacturer interviews. 

7 Once these markups are developed, 

8 DOE uses them to create manufacturer selling 

9 prices, or MSPs, for manufacturing production 

10 costs, or MPCs, and here on the table are DOE's 

11 estimates for those figures. Here's an example 

12 of what results look like for three of the 

13 representative units. These are cost efficiency 

14 curves. I can certainly show larger versions if 

15 we need them, and they're also available in the 

16 technical support document on DOE's website. So 

17 here are the other two for the Design C 

18 representative units. 

19 Couple of requests for comment. DOE 

20 seeks comment on its estimation for labor hours 

21 for each representative unit, DOE seeks comment 

22 on the cost to manufacturers to change their 
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1 product lines to meet EL 3, and DOE seeks comment 

2 on the cost to manufacturers in order to change 

3 their product lines to meet EL 4. 

4 MR. COFFEY: Don't see any comments 

5 so maybe we'll keep going. 

6 MR. BROOKMAN: No comments at this 

7 point? Rob. 

8 MR. BOTELER: Yes, this is Rob 

9 Boteler. I'm from Nidec. I have a question 

10 actually. On the, I guess it would be the EL 4 

11 level with copper bar. In the presentation that 

12 Howard just made, he notes that your test 

13 example, that the power factor dropped from 84.9 

14 down to 77 percent, 77.2. When the Department 

15 would do a cross comparison, would you redesign 

16 the product to maintain the level of power 

17 factor, or would you just let that drop and not 

18 worry about that or how would that be addressed? 

19 MR. COFFEY: So I think this is just 

20 for one unit. Certainly, and Howard can back me 

21 up here, but the Department attempts to make sure 

22 that the motor would meet all required 
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1 specifications. So he also mentioned an example 

2 with locked-rotor torque where his initial 

3 estimate came in a little bit high and so then 

4 he made an adjustment in the program and said, 

5 well, how much does this really affect 

6 efficiency? So there is a calibration process, 

7 but the end results are intended to represent 

8 something that would meet market specification. 

9 MR. BROOKMAN: Gary Fernstrom. 

10 MR. FERNSTROM: So this is Gary. We 

11 wouldn't want the energy saved in the motor to 

12 show up as energy lost in the building and 

13 utility distribution systems. 

14 MR. BROOKMAN: Got you. Bill Finley. 

15 MR. JORDAN: Brian, could I comment 

16 on that? 

17 MR. BROOKMAN: Please comment, 

18 Howard. 

19 MR. JORDAN: That miss on power 

20 factor was the one case that I've seen throughout 

21 all of the correlation and it doesn't represent 

22 the way we design motors at all. When I did the 
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1 design, I had the magnetization curve in VICA for 

2 the steel that I was intending to use and we hit 

3 the power factor almost as close as we did the 

4 efficiency. 

5 That particular unit is one that 

6 came from another country. I'm sure that they 

7 were using a high silicon steel, which I used a 

8 moderately high silicon steel in my design, and 

9 my program just didn't have the right 

10 magnetization curve for that one unit. So it's 

11 an isolated case. 

12 MR. BROOKMAN: Bill Finley. 

13 MR. FINLEY: Yes, Bill Finley, 

14 Siemens, and I have a comment here and the way 

15 Howard described the calibration design, the 

16 testing, the calibration is pretty much normal 

17 and the way it's done today, which in many cases 

18 it comes to the conclusion that you truly don't 

19 know what your performance is, particularly 

20 efficiencies, because windage and friction is 

21 many times an input and stator loss is many times 

22 an input and they will change dependent upon your 
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1 configuration in that. So in the end, you need 

2 to test it and then recalibrate it and then you'd 

3 know your efficiency from there on. 

4 MR. BROOKMAN: Okay, thank you. 

5 Steve, did you have a follow-on comment? Steve 

6 Ruffing. 

7 MR. RUFFING: Steve Ruffing, Nidec 

8 Motors. It relates to what Bill was just 

9 touching. You know, so we mentioned there was 

10 some uncertainty with the steel model, which in 

11 this case affected the power factor calculation. 

12 The steel data also affects the core 

13 loss component of the motor losses. And when we 

14 think about it, there's only five components of 

15 loss that go into determining your efficiency, 

16 the core loss. So there's one of them and, of 

17 course, now there's been some question raised 

18 about that. The remaining four are the stray 

19 losses which, again, we determined was input to 

20 the program as opposed to calculated. The 

21 friction losses would be the third one which 

22 we've determined was input as opposed to 
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1 calculated. 

2 And the remaining two are 

3 I-squared-R losses, one being the stator, the 

4 other being the rotor, and it was determined that 

5 those were kind of pseudo-input because the 

6 temperature was not calculated. It was told to 

7 the program by the user and then those two 

8 I-squared-R losses were calculated result. So 

9 all five components of losses that are 

10 calculated in order to determine the efficiency, 

11 either required some user input to determine or 

12 they had some sort of an uncertainty due to the 

13 steel characteristics. 

14 MR. BROOKMAN: Okay. Yes, John 

15 Malinowski. 

16 MR. MALINOWSKI: John Malinowski, 

17 Baldor Electric Company. When we start 

18 redesigning motors for higher efficiency, we 

19 start playing around with quite a number of 

20 different characteristics of the motor. Power 

21 factor, efficiency goes up. Power factor usually 

22 goes down. We also have to be careful with our 
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1 design so we don't lose starting torque. 

2 The other problem with redesigning 

3 for higher efficiency is sometimes the inrush 

4 current gets raised up and it changes from a 

5 Design B to a Design A motor. So, you know, a 

6 designer must be careful with all these limits. 

7 You can't get everything. You can't get the 

8 higher efficiency along with good power factor 

9 and along with low inrush current. It just kind 

10 of defies laws of physics to do many of these 

11 things. 

12 With regard to EL 4 and reaching 

13 these levels, I think the coalition and 

14 individual motor manufacturers have previously 

15 made comments to the feasibility and use of 

16 copper rotors. We don't have the capacity to do 

17 copper rotors in 5 million units a year 

18 production today. 

19 And then there's question on 

20 previous tests that our company has done in 

21 conjunction with the DOE and with the Army, that 

22 the results of those tests haven't been what have 
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1 been calculated. 

2 Everything looks great on paper, but 

3 in production the process of casting the copper, 

4 we believe might damage the insulation on the 

5 lamination, therefore creating more losses 

6 there that aren't captured in the design 

7 program. So if someone were to use the design 

8 program and model it, you always think you're 

9 going to get better than what you actually do in 

10 production. 

11 And when you start getting the 

12 rotors back from these companies that are 

13 casting them in prototype quantities, the 

14 ability to get good rotors to be used for 

15 production is very small. 

16 MR. BROOKMAN: Okay, thank you. Steve 

17 Rosenstock. 

18 MR. ROSENSTOCK: Steve Rosenstock, 

19 Edison Electric Institute. Just to kind of 

20 follow up with Gary's comments. In terms of the 

21 power factor, this spills over into the economic 

22 analysis, especially for the larger motors and 
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1 industrial applications. 

2 Larger customers tend to be metered 

3 for the kVA, so there can be power factor 

4 penalties if their facility, not motor but the 

5 facility power factor goes below a certain level 

6 at the facility level. Typically the range is 85 

7 percent power factor to 90 percent, depending on 

8 the utility. That's based on a survey that we did 

9 several years ago. 

10 So I think that for the individual 

11 motor it doesn't make a difference but for, I'll 

12 say a heavily motor population, especially 

13 industrial facilities, if the higher efficiency 

14 requirement, you know, obviously there's no 

15 power factor requirement, if it leads to lower 

16 power factors, there will be a possible economic 

17 ding on that industrial customer in terms of 

18 their cost will be higher because of lower power 

19 factor. Thank you. 

20 MR. BROOKMAN: Okay. Can you do the 

21 next four slides in ten minutes or should we -- 

22 MR. COFFEY: I can certainly try. 
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1 MR. BROOKMAN: Should we break for 

2 lunch? Let's break for lunch. It's now 12:10. The 

3 main cafeteria which is about, to the ground 

4 floor about 100 yards that a way, will close at 

5 1:00 so go quickly to there. The other 

6 alternative would be the Subway shop which is 

7 where the coffee shop is. They will also be 

8 serving lunch and maybe there'll be a big crowd 

9 going through here so you should go quickly and 

10 expeditiously get lunch. 

11 And we'll see you back here at ten 

12 minutes after 1:00 to resume. Make sure you have 

13 your badge. This room will be locked. It'll be 

14 secured so you can leave your stuff. You might 

15 need an ID to get back through the security 

16 portal. Okay? See you back here at ten after 

17 1:00. 

18 (Whereupon, the foregoing matter 

19 went off the record at 12:10 p.m. and went back 

20 on the record at 1:20 p.m.) 

21

22
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1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

2 (1:20 p.m.) 

3 MR. BROOKMAN: Please take your 

4 seats. We're going to resume and I'm happy to 

5 report for everyone present and those joining us 

6 online, we had the A/V folks in here over lunch 

7 and we think, knock on wood, that they've 

8 resolved the bulk of the problem and I, myself, 

9 took copious notes on how they did it. 

10 MR. RABA: Did you miss lunch? 

11 MR. BROOKMAN: No, no. I just caught 

12 them on the way to the elevator. It was a fairly 

13 brief description, which I'm about to commit to 

14 the record here. Are you ready? No, just kidding. 

15 So hopefully we won't encounter this problem in 

16 the future, but I'm eager to resume. 

17 MR. RABA: What was the problem? 

18 Explain how it was solved, please, sir. 

19 MR. BROOKMAN: I'll tell you offline. 

20 (Simultaneous speaking.) 

21 MR. RABA: For future. 

22 MR. BROOKMAN: Yes. No, no, for sure. 
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1 I'm not fooling. I mean, we really -- 

2 MR. RABA: I understand. Thank you 

3 very much. 

4 MR. BROOKMAN: I dragged it out of 

5 them. Okay, so we're going to proceed with Brian 

6 and we left off I believe on 47. 

7 MR. COFFEY: So I think we read these 

8 requests for comment. 

9 MR. BROOKMAN: We did and we did not 

10 receive any comment from industry on EL 3 and EL 

11 4. I thought that was purposeful and that they're 

12 going to supply written comments. Maybe there 

13 are some others at this point, John. 

14 MR. MALINOWSKI: I made comments on 

15 it. 

16 MR. BROOKMAN: Yes, thank you, John. 

17 You did. I apologize, yes. Any additional 

18 comments on these comment boxes before we move 

19 on? Okay, we're moving on. 

20 MR. COFFEY: Okay. So after, we had 

21 just finished talking about representative 

22 units and then in order to get results for all 
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1 the covered units, DOE does scaling. So, yes, it 

2 scales the results from the representative 

3 units, the equipment classes which were not 

4 analyzed directly. And so here you can just see 

5 a summary of how that scaling took place for each 

6 equipment class group. 

7 DOE considered using mathematical 

8 regressions to establish efficiency standard 

9 equations, you know, across horsepower, but 

10 ultimately decided to use NEMA's MG 1 tables as 

11 a basis for the efficiency levels and then NEMA 

12 bands to go incrementally higher as the expanded 

13 range of efficiencies and are already familiar 

14 to the industry. So next slide. 

15 Here's a summary of efficiency 

16 levels by equipment class. As mentioned earlier, 

17 they're based on tables from MG 1 or on 

18 incremental NEMA bands above those levels. 

19 And then finally this is the end of the 

20 engineering analysis. Here's just a graphical 

21 representation of scaling as it pertains to each 

22 equipment class by horsepower and by pole count, 
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1 so you can kind of just see, yes, graphically how 

2 those representative units might cover the 

3 space. 

4 And that's the end of the engineering analysis, 

5 so I'll invite up Sanaee Iyama to talk about the 

6 markups and energy use analysis. 

7 MR. BROOKMAN: I would invite any 

8 additional comments or questions about the 

9 market and technology assessment and 

10 engineering analysis before we move on. Bill, 

11 did you have something? No, nothing at this 

12 point? Okay, then we are moving on. Sanaee. 

13 MS. IYAMA: Good afternoon. I'm 

14 Sanaee Iyama with the Lawrence Berkeley Lab, and 

15 I'll start by presenting the markups analysis. 

16 So the purpose of this analysis is to determine 

17 consumer motor prices based on the manufacturer 

18 selling prices, both for baseline and higher 

19 efficiency motors. 

20 We used the same method as used in 

21 the preliminary analysis. We first identified 

22 distribution channels from the manufacturer to 
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1 the end user and then for each party involved in 

2 those distribution channels we establish the 

3 markup, and then we used those to convert the MSP 

4 into consumer prices. 

5 Same as in the preliminary analysis, 

6 DOE identified six primary distribution 

7 channels which are listed in this table, 

8 together with the share of annual shipments 

9 which are sold through either of these channels 

10 and these numbers are the same as the ones used 

11 in the preliminary. 

12 So as a next step, for each of the 

13 parties in those distribution channels DOE 

14 established both a baseline markup and an 

15 incremental markup. The baseline markup relates 

16 the consumer price to the cost of goods sold 

17 prior to a change in efficiency. It covers all 

18 the business's expenses and profit. 

19 The incremental markup relates the 

20 change in consumer price to the incremental 

21 increase in the cost of goods sold due to 

22 efficiency. And the basis for using such 
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1 approach is that the selling price of a piece of 

2 equipment is not strictly proportional to its 

3 purchase price. 

4 So when the cost of goods sold 

5 increases due to efficiency, only a fraction of 

6 the business's expenses increases, and so the 

7 incremental markup relates the change in 

8 consumer price to the incremental change of the 

9 cost of goods sold only, and only covers those 

10 expenses that scale with the increase in 

11 efficiency. And, again, that's the same method 

12 that was used in the preliminary analysis and 

13 that led to a weighted average baseline markup 

14 across all distribution channels of 1.63 and an 

15 overall incremental markup of 1.5. 

16 MR. FERNSTROM: Sanaee, can we ask a 

17 question? 

18 MR. BROOKMAN: Gary Fernstrom. 

19 MR. FERNSTROM: Gary Fernstrom, 

20 California IOUs. Could you go back to the prior 

21 slide, please? In looking at share of shipments, 

22 is this in terms of horsepower or in terms of 
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1 individual motor units? 

2 MS. IYAMA: Units. 

3 MR. FERNSTROM: It surprises me that 

4 OEM to end user would be so high relative to 

5 products provided through distribution. I would 

6 think OEM to end user would be the larger motors. 

7 Do you have a thought on that or this is just what 

8 you found? Okay. 

9 MR. BOTELER: This is Rob Boteler 

10 with Nidec. I think these are percentages that 

11 we've kind of discussed as a trade association 

12 and individual members from our interviews that 

13 we provided to Navigant. And, you know, our sales 

14 to OEMs are roughly 50 percent. Some 

15 manufacturers it might be more. Some it might be 

16 a little bit less. 

17 And then our sales to distributors, about 50 

18 percent of those end up going to small OEMs and 

19 then the remainder ends up going, you know, 

20 either to a contractor or direct to the end user. 

21 MR. FERNSTROM: Okay thank you, Rob. 

22 I misread this. This says from manufacturer to 
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1 OEM to end user. 

2 MR. BOTELER: Right. 

3 MR. FERNSTROM: I was reading it from 

4 OEM, meaning the manufacturer, to end user. 

5 Thank you for that. 

6 MS. IYAMA: Okay, sorry. 

7 MR. BASSO: Dale Basso, WEG Electric. 

8 I'm assuming that the OEM to end user includes 

9 OEM to their distributor to end user, and that 

10 your markup is calculated based on potentially 

11 either a direct or a distribution of that 

12 equipment. So there's a combination, because if 

13 it goes through their distributor it's going to 

14 get marked up additionally. And I guess the 

15 question is: have you considered that in the 

16 numbers that you put out as far as impact? 

17 MS. IYAMA: So you're saying there 

18 might be an extra step between the OEM and the 

19 end user? 

20 MR. BASSO: Oh yes, definitely. 

21 MS. IYAMA: Okay. 

22 MR. BASSO: And maybe you've taken 
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1 that into account in the overall. 

2 MR. BROOKMAN: And, Sanaee, I'm not 

3 sure, I may have missed it. Did you say what the 

4 source for this markup analysis was, or the 

5 multiple sources? 

6 MS. IYAMA: For just characterizing 

7 the distribution channels, it was a combination 

8 of research performed at LBNL with the help of 

9 a motor expert, Austin Bonnett, and then a 

10 combination also of the responses we got from the 

11 manufacture interviews. 

12 MR. BROOKMAN: Okay, excellent. 

13 Charlie Stevens. 

14 MR. STEVENS: Yes, I was going to say 

15 the same thing. I think the 50 percent number 

16 might actually end up being split into two where 

17 there's a distributor of an OEM product between 

18 the end user and the OEM. But it still would fall 

19 within the 50 percent of to OEM to end user. 

20 MS. IYAMA: Okay. 

21 MR. BROOKMAN: Okay. Thanks, 

22 Charlie. Yes, please, Brian. 
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1 MR. COFFEY: Sanaee, I was just going 

2 to say I don't know if your -- 

3 MR. BROOKMAN: You're on. 

4 MR. COFFEY: I don't know if your 

5 footnote at all addresses any of what people have 

6 been suggesting, that just there are some other 

7 channels, but she found that they were small. I'm 

8 not sure if that's what folks were commenting 

9 about. 

10 MR. BROOKMAN: Okay, thank you. 

11 MS. IYAMA: So next, after the 

12 markups, I'm going to talk about the energy use 

13 analysis. The purpose is to develop annual 

14 electricity consumption data for electric 

15 motors based on field operating condition at the 

16 baseline and higher efficiency levels. We used 

17 the same method as in the preliminary analysis. 

18 We developed average energy use values by using 

19 typical motor operating profiles associated 

20 with different applications within different 

21 sectors. 

22 And we accounted for variability in 
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1 the field by using statistical distributions to 

2 characterize inputs such as operating hours and 

3 motor loading. On this slide, we’re just showing 

4 the equation used to calculate the energy use. 

5 For electric motors, the actual energy used by 

6 the motor itself refers to the energy losses. The 

7 remaining energy is converted to useful 

8 mechanical shaft power. 

9 The annual energy use which combines 

10 the motor losses and mechanical horsepower is 

11 given in this first equation, and the bottom 

12 equation provides the calculation for the motor 

13 losses. On this slide, we show the main changes 

14 that have happened since the preliminary 

15 analysis for some of the inputs to the energy use 

16 calculation. 

17 And in the next slides, I'll go 

18 through them in further details, but basically 

19 we have adjusted the distribution across sectors 

20 to account for the fact that we now include 

21 56-frame size motors in the scope and those are 

22 mainly used in commercial applications. 
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1 And then we also revised the 

2 distributions across applications by sector, 

3 the operating loads and operating hours to 

4 account for additional motor information from 

5 The Northwest Industrial Motors Database as well 

6 as to account for information coming from the 

7 U.S. Agriculture Census. On this slide I present 

8 the data used for the distribution of shipments 

9 across sectors, so that varies by horsepower 

10 range and each row here equals to 100. You know, 

11 we're talking about shipments in units. 

12 On the next slides, I show an example 

13 of the distributions across applications that 

14 were used as an input to the energy use analysis. 

15 So we established for each sector and equipment 

16 class, a distribution of shipments across 

17 applications. 

18 Here we show an example for the 

19 industrial sector and for Equipment Class Group 

20 1 and that distribution varies by horsepower 

21 range and, again, here each row equals to 100 

22 percent. On the next slide, I show the annual 
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1 operating hours by application. So these were 

2 revised again to account for additional motor 

3 information collected during the NOPR and we 

4 have different operating hour assumptions 

5 depending on the sector, the application and the 

6 horsepower range. 

7 DOE also determined average values 

8 for load and here we show the average load for 

9 each of the considered application and that load 

10 data was used to calculate the part-load 

11 efficiency based on test data from the 

12 engineering analysis. So we actually used 

13 part-load efficiency values in that calculation 

14 and not the nominal full-load efficiencies. And 

15 on this slide, we have the resulting annual 

16 energy consumption for each of the 

17 representative units at each of the efficiency 

18 levels. 

19 MR. BROOKMAN: So that was a lot of 

20 content, a lot of analysis. Any of the foregoing 

21 slides of this section, any questions or 

22 comments here? Okay, nothing additional at this 
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1 time. Go ahead. 

2 MS. IYAMA: Okay. So next I'll 

3 continue with the life-cycle cost and payback 

4 period analysis. The purpose of this analysis is 

5 to assess the life-cycle cost impacts and 

6 payback period for the consumers of electric 

7 motors under each considered efficiency level. 

8 And results are expressed in terms of life-cycle 

9 cost difference between a base case and a 

10 standards case situation. 

11 The life-cycle cost equals the total 

12 installed cost plus the sum of annual operating 

13 cost discounted to a particular base year. And 

14 here we modeled the uncertainty and variability 

15 of the inputs using a Monte Carlo approach which 

16 characterizes each input by using a probability 

17 distribution and that was implemented in Excel 

18 using a little software called Crystal Ball. 

19 This chart presents the calculation 

20 for the life-cycle cost and payback period, so 

21 the top part of the chart represents the 

22 different step that allows us to calculate the 
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1 total installed cost and the bottom part of the 

2 chart represents the calculations for the 

3 lifetime operating expenses. 

4 Both combined are used to calculate 

5 the life-cycle cost and the payback period is the 

6 total installed cost divided by the first year 

7 of operating expenses. So in gray we have all the 

8 different inputs used, in green the intermediate 

9 results, in yellow the final results. 

10 And in the next slides I'll go 

11 through the inputs that we haven't yet covered 

12 in the engineering, markup, or energy use, and 

13 I'll focus on those inputs that have changed 

14 since the preliminary analysis, and I'll start 

15 with the mechanical lifetimes. 

16 So in the preliminary analysis we 

17 used a single set of mechanical lifetimes across 

18 all sectors, and in the NOPR we used 

19 sector-specific mechanical lifetime and these 

20 are presented here on this slide. And we used the 

21 same method after to calculate the motor 

22 lifetime in years using the operating hours. And 
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1 on the next slide we have the estimated weighted 

2 average lifetime in years, and here I'm just 

3 showing as an example the Equipment Class Group 

4 1 lifetimes. 

5 The other input that has changed is 

6 the repair frequency. Actually the frequency 

7 itself hasn't changed. We're still assuming 

8 either the motors are not repaired, repaired at 

9 half lifetime or at a third of the lifetime, but 

10 since lifetime has changed, those frequency 

11 expressed in hours have changed and that's 

12 pretty much all the main changes that have 

13 happened in the NOPR. 

14 And here I'm showing the results for 

15 the life-cycle cost and payback period for 

16 Representative Unit 1. We see that the 

17 life-cycle cost savings are positive 

18 throughout, up to Efficiency Level 3. However, 

19 for another representative unit here, the 

20 Representative Unit 3, we have positive results 

21 of up to Efficiency Level 2. 

22 MR. BROOKMAN: Yes please, Bill. 
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1 MR. HOYT: Bill Hoyt with NEMA. 

2 Question for you, Sanaee. When you refer to 

3 average repair frequency, what type of repairs 

4 are you referring to? 

5 MS. IYAMA: So here we're just 

6 considering a rewind as a repair. 

7 MR. BROOKMAN: Do you want to cue 

8 these comment boxes? 

9 MS. IYAMA: Sure, so we have three 

10 requests for comments on the life-cycle cost and 

11 payback period. First, DOE seeks comments on any 

12 additional sources for determining the 

13 frequency of motor repair depending on the 

14 equipment class group and sector. DOE seeks 

15 comment on any additional sources of information 

16 for motor lifetime and any information to help 

17 estimate the base case efficiency 

18 distributions. 

19 MR. BROOKMAN: Comments on these 

20 three request boxes? Okay, I see none at this 

21 time. Okay. 

22 MS. IYAMA: So, next I'll talk about 
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1 the shipments, national impact analysis, and 

2 regulatory impact analysis, and I'll start with 

3 the shipments section. So the purpose of this 

4 analysis is to estimate electric motor shipments 

5 in the base case and standard cases. 

6 Here we relied on the same method as 

7 in the preliminary. We used current and 

8 historical shipments data and then projected 

9 those shipments over the analysis period, 

10 assuming that shipments are driven by economy 

11 growth and fixed investment in equipment 

12 including motors. We used the exact same 

13 shipments model and I haven't provided more 

14 details on this since this hasn't changed. 

15 And what has changed are the annual 

16 shipments because the scope has been expanded to 

17 include, for example, the 56-frame size motors. 

18 Here we have a breakdown of the 2011 shipments 

19 in thousand units by horsepower range, so we have 

20 a total of about 5.4 million units. 

21 And on the next slide I'm showing the 

22 shipment projections, and here just to note that 
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1 for the purpose of the analysis we modeled the 

2 compliance date of December 19th, 2015, by using 

3 January 1st, 2016, so that's why you see here 

4 2016. 

5 And here I have two requests for 

6 comments. DOE seeks comments on any additional 

7 source of information that could be used to 

8 establish the distribution of electric motors 

9 across each equipment class group as well as the 

10 distribution of motors across each horsepower 

11 range within each equipment class group. 

12 MR. BROOKMAN: Rob. 

13 MR. BOTELER: Hi. Rob Boteler with 

14 Nidec. I would just comment that I think if you 

15 go back, one more chart I think, right here, I 

16 think the numbers that LBNL has come up with in 

17 your analysis are very consistent with what NEMA 

18 would believe are market numbers based on the 

19 scope of the product that we're talking about 

20 today. 

21 MR. BROOKMAN: Thank you, that's 

22 helpful, useful. Okay, additional comments 
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1 here. 

2 MS. IYAMA: Thank you. So next I'll 

3 present the national impact analysis. So the 

4 purpose is to estimate the national energy 

5 savings and the national economic impacts for 

6 electric motor users, and we do this at each of 

7 the considered standard levels. DOE calculates 

8 the national energy savings by multiplying unit 

9 lifetime energy savings by projected shipments 

10 and accumulating this projected value over 30 

11 years. 

12 And DOE calculates the net present 

13 value by accumulating the difference each year 

14 between energy bill savings and increased 

15 equipment cost for all motors shipped over the 

16 30-year period. And in the next slides, I'll 

17 highlight the main changes that have happened 

18 since the preliminary analysis and these relate 

19 to the base case efficiency distribution and the 

20 standard case efficiency distribution projected 

21 over the 30 year. 

22 So first the base case efficiency 
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1 projection. This depicts the current and 

2 projected mix of electric motor efficiencies 

3 sold in the absence of a new regulation. For the 

4 year 2012, DOE used the number of models meeting 

5 the requirements of each efficiency level from 

6 six major manufacturer catalog data and one 

7 distributor to develop the base case efficiency 

8 distribution and we did this by equipment class 

9 group and for each of the horsepower range. 

10 Beyond 2012, DOE assumed the 

11 efficiency distributions for Equipment Class 

12 Groups 1 and 4 varied over time based on 

13 historical data for the market penetration of 

14 NEMA Premium motors within the market for 

15 integral AC induction motors. 

16 For Equipment Class Group 2 and 3, 

17 we kept the base case efficiency distribution in 

18 the compliance year equal to the 2012 level and 

19 did not assume any trend beyond 2012. And here 

20 we have just an illustration of what those trends 

21 look like for Equipment Class Group 1 and here 

22 we're looking at the one to five horsepower 
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1 range. 

2 So we have the NEMA Premium level in 

3 green, the Efficiency Level 2, and you see that 

4 the market share slightly increases over time, 

5 taking over EL 0 and EL 1 motors. So that's for 

6 the base case which is in the absence of any new 

7 regulation. 

8 Next, and this slide differs 

9 slightly from what you have in the handouts, but 

10 for the standard case efficiency projection, 

11 which depicts the projected mix of electric 

12 motor efficiencies sold for the different 

13 efficiency standards case, we used the following 

14 steps to estimate that distribution. So in the 

15 compliance year, we just did a roll up, a roll 

16 up of the base case efficiencies, which means 

17 that all equipment with efficiencies below the 

18 standard level roll up to the standard level. 

19 Beyond the compliance year for 

20 Equipment Class Groups 1 and 4, DOE assumed that 

21 the level immediately above the standard would 

22 show similar increase in market penetration as 
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1 the NEMA Premium motors in the base case. And for 

2 Equipment Class Group 2 and 3, we kept the 

3 standards case efficiency distribution constant 

4 and equal to that of the compliance year. 

5 Next, here I'll present the trial 

6 standard levels, so in the preliminary analysis 

7 we presented results in terms of efficiency 

8 levels. Here in the NOPR we present results in 

9 terms of trial standard level, which are a 

10 combination of efficiency levels. 

11 DOE established four TSLs, from 

12 max-tech all the way down to TSL 1. TSL 1 

13 represents a level where all equipment classes 

14 move up one efficiency level above the baseline 

15 except fire pumps, which remain at the baseline 

16 level. 

17 TSL 2 represents a level equal to 

18 NEMA Premium for all equipment class groups 

19 except for fire pumps, which remain at the 

20 baseline. 

21 TSL 3 is one NEMA band above NEMA 

22 Premium for all equipment class groups except 
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1 fire pumps, which now move up to NEMA Premium, 

2 and TSL 4 is the maximum level, max-tech level, 

3 for all of the equipment class groups. 

4 And here we see the national energy 

5 savings for each of the TSL considered. You see 

6 that for all classes, they range between about 

7 one quad up to almost 14 quads with about seven 

8 quads at TSL 2. 

9 And on the next two slides, I have 

10 the net present value results, first at three 

11 percent discount rate. We see that we have 23.3 

12 billion at TSL 2, minus 42.4 at TSL 4 and here 

13 we have the results with a discount rate of seven 

14 percent. 

15 Next I have a few requests for 

16 comments. DOE seeks comments on the decision to 

17 use efficiency trends for Equipment Class Groups 

18 1 and 4 and constant efficiencies for Equipment 

19 Class Groups 2 and 3. Specifically DOE would like 

20 comments on additional sources of data on trends 

21 in efficiency improvements. 

22 Issue Number 9, DOE seeks comments 
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1 on any source of data that could be used to 

2 establish the elasticity of electric motor 

3 shipments with respect to changes in purchase 

4 price. 

5 And then we have four additional 

6 request for comments. The first one is on the way 

7 the MSP values were scaled across all horsepower 

8 range and poles and enclosures. The second is 

9 similar comment but this time related to weight. 

10 Then we get to Issue Number 12, DOE 

11 seeks comments on the TSL developed for the NOPR. 

12 And Issue Number 25, currently DOE's reference 

13 case project that prices for future shipments of 

14 motors will remain constant. DOE's seeking input 

15 on the appropriateness of this assumption. 

16 MR. BROOKMAN: Several different 

17 comment boxes. Let's start with 8 and 10. Any 

18 comments here? Nothing here. Okay. 

19 MR. DELASKI: I have a comment. 

20 MR. BROOKMAN: Yes, please. Andrew 

21 deLaski. 

22 MR. DELASKI: So I wanted to comment 
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1 on the impact analysis and I know there's a 

2 certain art in projecting something over 30 

3 years and beyond. I think what you've done here 

4 is -- 

5 MR. BROOKMAN: Andrew, would you get 

6 that closer to your face, please? 

7 MR. DELASKI: Yes, the roll up 

8 scenario is a typical scenario for the 

9 Department to model and a rulemaking often also 

10 is a model to shift scenario. 

11 I think in this situation where 

12 we're getting up against the top of the 

13 physically possible efficiency levels that a 

14 roll up is probably an appropriate approach. 

15 But I also think we should 

16 acknowledge that it's inherently conservative 

17 and that it seems to me quite likely that you 

18 would see market share at EL 3 and EL 4 grow when 

19 the standards are at EL 2. Manufacturers will 

20 seek to sell value-added products, not just at 

21 EL 3/EL 4 but in other advanced motor types. 

22 So as this becomes the standard, we 
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1 will see market share for even more efficient 

2 motors grow and that's not captured in this 

3 analysis. And I think that's okay, but I think 

4 it's an inherent conservatism in the savings 

5 that are being projected. 

6 MR. BROOKMAN: Okay. Yes, Bill. 

7 MR. HOYT: Yes, I want to make a note 

8 about the use of NEMA Premium. When the EISA went 

9 into effect in 2010, in the 2011 version of MG 

10 1, Table 12-12, we used to be titled NEMA 

11 Premium. It was changed to just indicate Premium 

12 motors and take the word NEMA out of it. NEMA 

13 Premium is still a registered trademark with 

14 NEMA. 

15 However, there are additional 

16 verification requirements to be able to use that 

17 label, so I would request that the Department use 

18 Premium level motors as opposed to NEMA Premium 

19 in future references. Thank you. 

20 MR. BROOKMAN: Thank you, Bill. 

21 MS. IYAMA: Thank you. 

22 MR. BROOKMAN: Okay, additional 
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1 comments related to these comment boxes? Steve 

2 Ruffing. 

3 MR. RUFFING: Steve Ruffing, Nidec 

4 Motors. Regarding Issue 12, maybe I'm misreading 

5 something but I thought I see just a very small 

6 error, conflict in the trial standard levels. 

7 If you go back several slides, that 

8 one right there. So the Trial Standard Levels 2 

9 and 3 both makes the statement with the exception 

10 of fire pump motors. If I'm reading the NOPR 

11 correctly, it would really be with the exception 

12 of fire pump motors and Design C motors. 

13 If you look at Table IV.11 in the 

14 NOPR for Equipment Class Group 2, which is Design 

15 C motors, it defines EL 1 to be the EPACT '92 

16 level and EL 2 to be the NEMA Premium level. So 

17 if that's true, then TSL 2 would be EPACT level 

18 for Design C and EL 2 would be NEMA Premium. 

19 So in that case, I think that the 

20 small conflict is that the Design C motors are 

21 at the same levels as the fire pump motors for 

22 TSL 2 and 3 even though it doesn't indicate it 
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1 there on that slide, nor does it indicate it on 

2 the comparable table in the NOPR. 

3 MS. IYAMA: I have a copy of the NOPR 

4 over there. 

5 MR. BROOKMAN: She's got it. 

6 MR. RUFFING: It says everything in 

7 TSL 2 is at NEMA Premium level. 

8 MS. IYAMA: Sorry, you were 

9 referencing a table in the NOPR? 

10 MR. RUFFING: Yes, it's on Page 

11 73627. It's Table IV.11. 

12 MR. BROOKMAN: 73627. 

13 MS. IYAMA: No. I think on this table 

14 the EPACT '92 should read EL 0. Premium should 

15 read EL 1, yes. 

16 MR. RUFFING: Okay, that would 

17 resolve the conflict. Okay, thank you. 

18 MS. IYAMA: It starts at 1. It should 

19 start at 0. 

20 MR. RUFFING: Okay. Thank you. 

21 MR. BROOKMAN: Andrew deLaski. 

22 MR. DELASKI: I also just want to make 
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1 another clarifying question. From reading the 

2 NOPR, I believe, make sure I understood it 

3 correctly, that the savings from 56-frame motors 

4 are not included in the estimates that are put 

5 on the screen. Is that correct? 

6 MS. IYAMA: We included the enclosed 

7 56-frames only above one horsepower so those 

8 values are in the results. 

9 MR. DELASKI: Maybe I'll take it 

10 offline, but there was a part of the NOPR that 

11 had there's 0.58 quads of savings over 30 years 

12 from some motors that I thought the NOPR said had 

13 not been yet wrapped into total analysis, and we 

14 don't have to answer this right now. 

15 MS. IYAMA: Yes, I believe those were 

16 the 56 open, definite and special purpose. 

17 MR. DELASKI: Okay. 

18 MS. IYAMA: But the enclosed 56 are 

19 in. 

20 MR. BROOKMAN: Yes, Dan Delaney. 

21 MR. DELANEY: Dan Delaney on behalf 

22 of NEMA. Back to the Issue Question 12 just a note 
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1 that, I'm sorry, Question 11, Issue 11, question 

2 about scaling of the weights or different 

3 considerations for enclosures, cast iron versus 

4 aluminum versus, let's say, rolled steel 

5 construction, considered in the weight scale. 

6 I know it was an aspect that we 

7 talked about that didn't appear that would be an 

8 easy scaling factor that we could come up with, 

9 NEMA could do. Just curious to see how you 

10 address that. 

11 MS. IYAMA: So in the engineering we 

12 didn't take that into account, like the change 

13 in material for those components that don't 

14 affect efficiency. 

15 And here it's sort of the same idea, 

16 where things that don't impact the efficiency 

17 we're not taking into account in the scaling, so 

18 we assume that it would be the same construction 

19 types that whatever was assumed for the 

20 engineering. And so we try to scale 

21 independently of those variations and just 

22 accounting for horsepower and enclosures. 
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1 MR. DELANEY: So just to clarify 

2 again, the base case would be the constructions 

3 that were looked at from the teardowns, so most 

4 likely cast iron? Or I'm not sure what all the 

5 constructions were, but from the teardown 

6 construction that construction was used as the 

7 scaling. 

8 MS. IYAMA: Right, we actually looked 

9 at a pretty large set of weight data for couple 

10 of thousand motors that we collected through 

11 those six manufacturer catalog data and one 

12 distributor and then we filtered that to arrive 

13 at those scaling indices. 

14 So first, we looked at the four poles 

15 and scaled that across horsepower by using only 

16 the data for enclosed four-pole motors and the 

17 representative units weights for where we had 

18 data. 

19 So for the five horsepower unit, the 

20 30 horsepower unit and the 75 horsepower unit, 

21 we looked at the population of motors and the 

22 weight data we had. 
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1 We made a regression. I think it was 

2 a power law regression, which is more detailed 

3 in the Chapter 10 of the TSD. We actually have 

4 the different equations that we used for scaling 

5 across horsepower for four-pole enclosed 

6 motors. 

7 And then for each horsepower, we 

8 derived through a statistical analysis 

9 different indices to scale that weight to the 

10 different enclosures and poles. 

11 MR. BROOKMAN: John Malinowski. 

12 MR. MALINOWSKI: John Malinowski, 

13 Baldor Electric. First of all, I just want to 

14 amend what Bill said. The Table 12-12 is called 

15 Premium Efficiency Motors, not NEMA Premium any 

16 longer. 

17 And with respect to these issues 

18 here on Slide 91, I think you have to be very 

19 careful with regard to weights in catalogs. Some 

20 manufacturers use the weight of the motor with 

21 its packaging materials, so it would be a 

22 shipping weight, and other manufacturers have 
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1 the weight of the motor alone, so you're 

2 comparing apples and oranges in that respect. 

3 Then if you go to another realm, you 

4 almost have to compare one manufacturer to his 

5 own motors rather than Manufacturer A to 

6 Manufacturer B, because one manufacturer might 

7 have a practice of over-designing, maybe using 

8 thicker castings as a practice than another who 

9 might use finite element analysis and, you know, 

10 design it down to the nth degree and just use 

11 enough material in the frames to do what needs 

12 to be done. 

13 So in that case, you know, comparing 

14 Manufacturer A at one rating to Manufacturer B 

15 at another rating, the scaling factor there 

16 becomes inaccurate because of the inconsistency 

17 of design practices. We don't like scaling. You 

18 know, it kind of gets it to a motor by pound, you 

19 know, horsepower by pound or rating by pound. 

20 And we are not allowed to talk about 

21 price here but when you look at the manufacturing 

22 of motors by poles, the labor changes by pole 
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1 count and the labor changes by the size of the 

2 motor as to how much automation can be used in 

3 the manufacture of that motor and how much hand 

4 labor has to be done. So scaling doesn't work in 

5 that respect as far as sell price or anything 

6 there. 

7 Again, we can't comment on prices of 

8 future shipments but, of course, one could 

9 assume that our motors are manufactured with 

10 copper, steel and aluminum and one could look at 

11 the futures for those commodities and what those 

12 are expected to do in the future and, frankly, 

13 I doubt that you could assume that they're going 

14 to be level for the next umpteen years. 

15 MR. BROOKMAN: Thank you. Several 

16 comment boxes here. These last comments very, 

17 very useful. Additional comments here before we 

18 move on? Okay, we're moving on. 

19 MS. IYAMA: Next I have a short slide 

20 on the regulatory impact analysis. The purpose 

21 is to evaluate non-regulatory alternatives to 

22 proposed standards. 
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1 And in order to do so, DOE uses a 

2 modified NIA spreadsheet to evaluate whether 

3 those non-regulatory options would lead to equal 

4 or greater benefits. There is more detail in 

5 Chapter 17. 

6 MR. BROOKMAN: Sanaee, pardon me for 

7 interrupting. I received a comment from someone 

8 who's online, just before you move on. 

9 This is from Tuan Ngo, again, 

10 saying, "Since EL 0 includes motors that are not 

11 meeting existing standards, the TSL developed 

12 for the NOPR may be low?" I see some heads nodding 

13 but no response yet. Dale. 

14 MR. BASSO: This is Dale Basso, WEG. 

15 I think that's kind of along the same lines of 

16 what was addressed earlier, that there are 

17 motors that exist that are not covered today, and 

18 when they weighted the ones that were in the 0, 

19 it was to cover ones that were in that category 

20 of unregulated product that exist today. 

21 The new regulation as proposed will 

22 cover products that have never had any standard 
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1 listed before and so they would fall into that 

2 0 category. 

3 MR. BROOKMAN: Okay. Okay, thank you. 

4 I'm sorry to interrupt. 

5 MR. LANSER: I have one comment. 

6 MR. BROOKMAN: Yes, please -- 

7 MR. LANSER: Don Lanser from Nidec. 

8 MR. BROOKMAN: Don. 

9 MR. LANSER: On that Item 25, the 

10 Department of Labor does measure producer price 

11 index for integral horsepower motors, so if you 

12 project that out you might get a different 

13 answer. 

14 MS. IYAMA: Right. So we actually 

15 looked into different sources of data to try to 

16 get to price trends. We looked at commodity 

17 prices. It was a little bit all over the place 

18 to be honest. We couldn't really conclude. 

19 We looked at price indices, both in 

20 AEO and from the Bureau of Labor Statistics. One 

21 trend was going up, one trend was going down, so. 

22 And this is in one of the appendices to Chapter 
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1 10. 

2 MR. BROOKMAN: Okay. 

3 MS. IYAMA: So on the regulatory 

4 impact analysis, we used the NIA spreadsheet to 

5 evaluate the impact of several different options 

6 that are listed here, consumer rebate, tax 

7 credit, manufacturer tax credits, voluntary 

8 targets, early replacement program and bulk 

9 government purchase and, again, those results 

10 are in Chapter 17. 

11 And with that, I'll let Hayden 

12 continue with the manufacturer impact analysis. 

13 MR. BROOKMAN: Let me remind those of 

14 you that are joining us via the web that if you 

15 have questions or comments, we welcome your 

16 participation in this meeting. Raise your hand 

17 and we'll fit you in. Hayden, you're up. 

18 MR. COOK: Hi. My name's Hayden Cook 

19 from Navigant Consulting and I'll be discussing 

20 the manufacturer impact analysis, or the MIA 

21 that was conducted for this NOPR. 

22 The MIA slides present three things. 
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1 First, they'll present an overview of how the MIA 

2 was conducted, second, they'll briefly discuss 

3 the manufacturer impacts at the proposed 

4 standard levels and, third, they'll introduce 

5 the MIA topics DOE is seeking comment on. 

6 The main purpose of the MIA is to 

7 assess the impacts of standards on manufacturers 

8 of electric motors. 

9 A second purpose is to identify and 

10 estimate the impacts on manufacturer subgroups. 

11 In the upcoming slides, I'll discuss the impacts 

12 of standards on the small business manufacturer 

13 subgroup. 

14 And the final portion of the MIA 

15 involves a discussion of direct employment, 

16 manufacturing capacity and other federal 

17 regulations that impact the same manufacturers 

18 around the compliance date for this standard. 

19 The main tool DOE uses to evaluate 

20 the impacts of standards on manufacturers is a 

21 discounted cash flow model called the Government 

22 Regulatory Impact Model, or GRIM. 
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1 The major output from the cash flow 

2 model is industry net present value, or INPV, a 

3 metric used to represent the quantitative 

4 impacts of new and amended standards on 

5 manufacturers of the covered equipment. 

6 For the MIA, DOE also conducted 

7 interviews with manufacturers to refine the 

8 inputs of the cash flow model and to understand 

9 the qualitative impacts of standards. 

10 So this slide shows the basic MIA 

11 process which takes place in three phases. In the 

12 first phase, which occurred during the 

13 preliminary analysis, DOE used publicly 

14 available information such as manufacturers' 

15 annual reports to develop a profile of the 

16 industry. 

17 Phases 2 and 3 were conducted as part 

18 of the NOPR analyses. In Phase 2, DOE developed 

19 the cash flow spreadsheets that are used to 

20 estimate the impacts on the industry and the 

21 interview guide that was used to gather 

22 information from manufacturers during these 
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1 interviews. 

2 In Phase 3, DOE conducted interviews 

3 with manufacturers and used this information to 

4 further develop the analysis and to finalize the 

5 inputs that ultimately went into the GRIM. 

6 Switching from the MIA methodology 

7 to the specifics about this rulemaking, this 

8 slide presents the key issues that we learned 

9 from manufacturers during interviews that they 

10 are concerned with for these electric motor 

11 standards. 

12 First, manufacturers are very 

13 concerned if any motor standards require motor 

14 efficiency levels beyond Premium efficient 

15 motors, especially if these efficiency levels 

16 require the use of copper rotors. 

17 Manufacturers stated that 

18 efficiency levels beyond Premium efficient 

19 motors would require a significant level of 

20 capital investment in R&D resources and this 

21 would cause U.S. motor manufacturers to 

22 manufacture motors that would be out of sync with 
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1 the rest of the world standards. 

2 If standards were to require the use 

3 of copper motors, manufacturers would 

4 experience further difficulties due to the 

5 potential increase in copper price, the 

6 volatility of the copper market and any 

7 potential safety concerns regarding the higher 

8 melting temperatures of copper compared to 

9 aluminum. 

10 The second issue is if standards for 

11 motors increase, consumers are more likely to 

12 rewind older, less efficient motors as opposed 

13 to purchase newer, more efficient motors that 

14 comply with standards. 

15 Therefore, if motor standards 

16 significantly increase the price of motors, 

17 manufacturers believe that rewinding older, 

18 less efficient motors might become a more 

19 attractive option for some customers and thereby 

20 prolong the use of these motors that consume more 

21 energy. 

22 Lastly, manufacturers are concerned 
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1 about the enforcement of current in any 

2 potential new motor standards. In general, 

3 domestic motor manufacturers have stated that 

4 they will comply with any electric motor 

5 standards. 

6 However, these manufacturers 

7 believe that there are several foreign 

8 manufacturers that may not comply with any 

9 future standards if they were significantly 

10 increased. 

11 This could cause compliant 

12 manufacturers to be placed at a competitive 

13 disadvantage since complying with any increase 

14 in standards could be costly. 

15 While I don't have a comment box 

16 here, I'd like to pause at this time to request 

17 any statements about the key issues that are 

18 presented here or any issues that are not 

19 presented here. 

20 MR. BROOKMAN: Rob. 

21 MR. BOTELER: Rob Boteler with Nidec. 

22 I would just comment on your second bullet that 
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1 one of the things that we discussed, we came in 

2 and had an ex parte meeting, I don't know, a year 

3 ago. 

4 In the category of motors that were 

5 talked about, there is a huge population of used 

6 motors and all one has to do is go on eBay, 

7 Craigslist or any one of dozens of websites to 

8 find out that there's thousands, if not 

9 millions, of used motors available that as the 

10 initial up-front cost of motors goes up they 

11 become more attractive to the end user. 

12 MR. BROOKMAN: Before they're on the 

13 market, are they refurbished? 

14 MR. BOTELER: They may or may not be. 

15 MR. BROOKMAN: Okay. Additional 

16 comments on these or perhaps elaborations on 

17 these concerns, issues that are raised here in 

18 97? Nothing additional, okay. 

19 MR. COOK: Okay. This slide presents 

20 an overview of the shipment and markup scenarios 

21 that DOE ran for the MIA. DOE analyzed three 

22 different markup scenarios for electric motors, 
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1 a flat or preservation of gross margin markup 

2 scenario, a preservation of operating profit 

3 markup scenario and a two-tiered markup 

4 scenario. 

5 Each markup scenario produces a 

6 unique set of cash flows. For the flat markup 

7 scenario, manufacturers earn the same gross 

8 margin markup as a percentage as they do in the 

9 base case as they would in any increase in the 

10 motor production cost due to standards. 

11 For the preservation of operating 

12 profit markup scenario, manufacturers earn the 

13 same operating profit in absolute dollars in the 

14 base case as they do in the standards case in the 

15 year after standards go into effect. 

16 And for the two-tiered markup 

17 scenario, DOE modeled the situation in which 

18 portfolio reduction caused by standards 

19 squeezes the higher margins of the most 

20 efficient motors as they become the minimally 

21 compliant motors due to increases in standards. 

22 The least severe markup scenario for 
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1 manufacturers is the flat markup scenario since 

2 manufacturers are able to pass on their costs to 

3 customers due to standards. 

4 The most severe markup scenario is 

5 either the preservation of operating profit or 

6 the two-tiered markup scenario, depending on 

7 which TSL is analyzed. 

8 For both these markup scenarios, 

9 manufacturers are not able to fully pass through 

10 the additional cost due to standards, thereby 

11 potentially reducing manufacturers' profit 

12 compared to the flat markup scenario. 

13 Here are the INPV results for the 

14 flat markup scenario, which represents the least 

15 severe impacts to manufacturers. And, again, TSL 

16 2 was the TSL that is proposed in the NOPR and 

17 these represent the results for all equipment 

18 class groupings. 

19 This next slide shows the results 

20 for the preservation of operating profit and the 

21 two-tiered markup scenarios, which represent 

22 the most severe impacts to manufacturers. And, 
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1 again, TSL 2 is the TSL that's being proposed in 

2 the NOPR. So if there are any comments on the 

3 results of the MIA, I'd be open to that. 

4 MR. BROOKMAN: No comments here. 

5 MR. COOK: Okay. 

6 MR. BROOKMAN: Andrew deLaski. 

7 MR. DELASKI: This may be time for 

8 kind of an offline conversation with the 

9 Department, but do you know if the Department's 

10 ever tried to -- we had an earlier discussion 

11 about calibrating motor modeling. The 

12 Department ever tried to calibrate the GRIM? 

13 MR. COOK: What do you mean by 

14 calibrate? 

15 MR. DELASKI: What I mean is has the 

16 Department ever tried to do an after-the-fact 

17 analysis to see what actually happened? 

18 (Simultaneous speaking.) 

19 MR. DELASKI: Today, where the motor 

20 manufacturers support this proposal, right, so 

21 I'm guessing that it's more likely to have a 

22 positive impact on their business, conducting 
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1 their business, because they support it, right, 

2 but that's a guess, right? I'm just drawing a 

3 conclusion based on their position and their 

4 sense of their business. 

5 It would be, I think, useful for the 

6 Department to do after-the-fact, at some point 

7 in the future to go back and look at the GRIM and 

8 say how well is it doing as a predictive tool? 

9 Is there a way to go back after the fact and say, 

10 you know, which of these models was correct? 

11 So it's not really a question for 

12 you. I know it's probably one that should be 

13 taken up by the Department. I guess more for the 

14 Department than it is for the consultant to 

15 consider. 

16 MR. BROOKMAN: Doug. 

17 MR. RAWALD: And that's my thoughts 

18 too. We'll pass it on to the right people. 

19 MR. BROOKMAN: Thank you. Charlie 

20 Stevens. 

21 MR. STEVENS: Yes, along those same 

22 lines I'm not necessarily suggesting that you do 
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1 this right away, but it seems to me motors, 

2 especially when you had as many distribution 

3 channels as you saw up there and the enormous 

4 range of horsepower that you're dealing with 

5 here, all the way from some fairly regular 

6 off-the-line into distributor stock-type 

7 motors, all the way up to custom, you know, we'll 

8 build it when you order it and pay for it kinds 

9 of motors, it seems like different ones of these 

10 markup scenarios might apply to different motor 

11 sizes and different markets and distributor 

12 channels. 

13 But that would complicate your 

14 analysis quite a bit and I'm not necessarily 

15 recommending that you do that right now. But in 

16 some case in the future when you see this kind 

17 of thing it might actually be useful to 

18 investigate whether that would be a factor. 

19 MR. BROOKMAN: Okay, thanks. 

20 MR. COOK: I think that's a fair point 

21 and I think it's important to keep in mind that 

22 these markup scenarios kind of represent the 
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1 bounds of what we believe will happen. 

2 And we're not necessarily saying 

3 it's either going to be A, B or C as much as here 

4 are the upper and lower bounds that we think are 

5 reasonable and each manufacturer could be, you 

6 know, on different places, each motor could be 

7 on different places. 

8 But these are more kind of an 

9 uncertainty range to provide estimates as 

10 opposed to we think it's going to be X or we think 

11 it's going to be Y. 

12 MR. BROOKMAN: It's a true reflection 

13 of the meaning of scenarios. 

14 MR. COOK: Correct. 

15 MR. BROOKMAN: Yes. Okay, additional 

16 comments here? Okay. 

17 MR. COOK: So next I want to talk 

18 about the small business impact. One of the 

19 criteria DOE looks at is the impacts of standards 

20 on small businesses. 

21 To be considered an electric motor 

22 small business manufacturer, the Small Business 
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1 Administration, or SBA, sets a limit of 1,000 

2 total employees or less for those manufacturers. 

3 DOE used publicly available 

4 information to identify potential small 

5 business manufacturers, such as SBA's database, 

6 DOE's Compliance Certification Management 

7 System, trade association lists and Hoover's 

8 website. 

9 Also during interviews, DOE asked 

10 manufacturers if they were aware of any 

11 potential small businesses in their market. 

12 After refining the list of potential 

13 small businesses based on DOE's initial 

14 research, DOE directly contacted the remaining 

15 potential small businesses to determine if they 

16 met SBA's definition of a small business 

17 manufacturer. 

18 DOE found 13 small business motor 

19 manufacturers. Based on interviews and the 

20 review of the products offered by these 13 small 

21 businesses, DOE determined that five of the 13 

22 small businesses manufacture specialty motors 
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1 not currently subject to motor standards but 

2 would be under the proposed expanded scope. 

3 DOE believes that this group could 

4 potentially be significantly impacted by the 

5 proposed standards. 

6 A different five small businesses 

7 only manufacture a small amount of covered 

8 motors and primarily focus on other types of 

9 motors that are not covered by this rulemaking. 

10 Therefore, DOE believes that the 

11 proposed standards would not significantly 

12 impact these businesses since less than ten 

13 percent of their revenue comes from motors 

14 covered by this rulemaking. 

15 The remaining three small 

16 businesses primarily manufacture motors that 

17 already meet the proposed efficiency levels and, 

18 therefore, DOE does not believe the proposed 

19 standards would significantly impact these 

20 businesses. 

21 At this time I would like to request 

22 comment on both the number of small businesses 
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1 that DOE identified as well as the potential 

2 impact of new and amended standards on these 

3 small business manufacturers. 

4 MR. BROOKMAN: John Malinowski. 

5 MR. MALINOWSKI: John Malinowski 

6 from Baldor. I think you've done a good job at 

7 your analysis here. However, you've looked at 

8 only businesses within the United States and 

9 we're affecting a standard on motors that are 

10 manufactured globally for use in the United 

11 States. 

12 So one of the comments that the 

13 coalition has made and that our company has made 

14 is, you know, not to set the efficiency limits 

15 up so high that it might be viewed as a trade 

16 barrier. 

17 With respect to the efficiency 

18 levels going to NEMA 12-12 level, that is a 

19 global harmonization. Europe, the EU, will be 

20 there in 2015 on motors 10 horsepower and larger. 

21 They'll be there in 2017 on 1 through 10 

22 horsepower. So with that idea, you know, we've 
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1 harmonized globally and not gone astray. 

2 There's a lot of small motor 

3 manufacturers globally, a lot of little niche, 

4 you know, $2 to $5 million companies, many of 

5 them in southern Europe but, nonetheless, 

6 there's many worldwide. 

7 So you really need to look at this 

8 more than just affecting U.S. manufacturers. 

9 It's really a global standard, global 

10 manufacturers and it has effect beyond our 

11 borders. 

12 MR. BROOKMAN: Thanks, John. 

13 MR. COOK: Just one final 

14 clarification. I do want to say that in terms of 

15 the manufacturer impacts or in terms of the INPV 

16 results, those would include global motor 

17 manufacturers. 

18 But specifically in terms of small 

19 businesses, you are correct. It's only looking 

20 at U.S. small businesses, but I just want to make 

21 that clarification. 

22 MR. BROOKMAN: Gary. 
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1 MR. FERNSTROM: Gary Fernstrom. So, 

2 John, I thought the whole objective of the 

3 industry impact/small business impact analysis 

4 was to look at the effect that a proposed 

5 regulation might have on our economy. 

6 And I kind of fail to see why it's 

7 important that we consider the effect on small 

8 businesses outside of this country. Can you help 

9 me understand your reasoning better? 

10 MR. BROOKMAN: John. 

11 MR. MALINOWSKI: John Malinowski, 

12 Baldor. I think the whole idea is global 

13 harmonization. When we were looking at 

14 efficiency levels above Table 12-12, nobody else 

15 in the world was going to that level and we didn't 

16 want to go there. We wanted to harmonize. 

17 There are some other efforts going 

18 along with the IECEE to come up with a global 

19 marking of motors so that we don't have to do 

20 separate compliance testing and approvals for 

21 each country, so we all want to get to one level 

22 and one test method and such. 
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1 So with respect to companies 

2 overseas, if we were to set a higher limit on 

3 efficiency, let's say one or two bands above 

4 Premium, might other countries perceive that we 

5 are setting up some sort of a trade barrier so 

6 that their companies can't freely trade into 

7 this country? 

8 You know, they've not gone there 

9 with their efficiency standards. They offer them 

10 as optional, you know, IE3 is equivalent to where 

11 we're proposing this goes and that's where the 

12 EU is going in 2015 and 2017 and we're going to 

13 be in harmony. 

14 At the same time, they've identified 

15 another level, IE4, which is that NEMA Premium 

16 plus level that is an optional level that some 

17 companies, you know, offer in their product 

18 line. 

19 So we think a voluntary level on a 

20 global level is a good thing, but then have the 

21 advanced technology available just as we've 

22 talked all day about having other technologies 
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1 available above that level. 

2 MR. FERNSTROM: Okay, thank you. I 

3 understand that point of view and the benefit of 

4 global harmonization, but I think perhaps with 

5 some other products Europe and maybe in some 

6 cases Asia are ahead of us with respect to 

7 efficiency. 

8 MR. MALINOWSKI: Not on motors. 

9 MR. FERNSTROM: No, not on motors. 

10 And, you know, I just wonder how we might 

11 extrapolate your thinking to other products 

12 where we might be behind and not ahead. Thank 

13 you. 

14 MR. BROOKMAN: Right, thank you. 

15 Okay. 

16 MR. COOK: Okay, if there's no more 

17 comments on my section, I'll return it to Sanaee. 

18 MS. IYAMA: Okay, so I'll continue 

19 with the environmental, utility, and employment 

20 impacts, and I'll start with the environmental 

21 impact analysis which combines the emissions 

22 analysis and the monetized values of emissions. 
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1 The purpose of the emissions impact 

2 analysis is to estimate the emission reductions 

3 resulting from the national energy savings, 

4 including changes in power plant emissions and 

5 full fuel cycle emissions. 

6 DOE used the National Energy 

7 Modeling System, the NEMS model, to derive 

8 emission factors for carbon dioxide and other 

9 gasses like nitrogen oxide and sulfur dioxide. 

10 And here on this slide I'm just 

11 showing the results at the proposed standard TSL 

12 2 of about almost 400 million metric tons of CO 

 2

13 savings. 

14 That's cumulative over the 30 years. 

15 As a next step, we look at those emission savings 

16 and convert those into monetized values. 

17 And in order to do so, we used the 

18 most current Social Cost of Carbon values at 

19 different rates that you see on this slide and 

20 we also did this for NO emission reductions. And 

 x

21 here on this next slide we have the results in 

22 million dollars and that's over the 30-year 
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1 analysis period. 

2 Next I'll go through the utility 

3 impact analysis. The purpose is to assess the 

4 impacts of the different standard level 

5 considered on domestic electricity suppliers. 

6 We used a modified version of the 

7 NEMS model to generate forecasts that deviate 

8 from the reference case. And here again we have 

9 results at TSL 2 and there's more detailed 

10 results in the TSD. 

11 Next I'll talk about the employment 

12 impact analysis. The purpose is to assess the 

13 overall impact on indirect national employment 

14 from standard that results from shifting 

15 consumer expenditures amongst goods and 

16 services and changing equipment and energy 

17 costs. 

18 So Hayden just talked about the 

19 direct employment impacts and in this section 

20 we're only looking at the indirect national 

21 employment. 

22 And the impacts were determined 
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1 using the ImSET model and results showed that the 

2 impacts were actually pretty negligible over 

3 time, and we actually have quantified results in 

4 the TSD chapter. 

5 Now we get to the last section of 

6 this presentation. Just a quick summary of all 

7 the results we saw today. 

8 I'll start with an overview of the 

9 NIA and MIA results, so here we have all the TSL 

10 represented. In bold we have the results at TSL 

11 2. We see that we have national energy savings 

12 of seven quads, NPV of $23 or $9 million dollars 

13 depending on the discount rate and here you have 

14 the range of the manufacturer impacts as well. 

15 On the next slide we have the summary 

16 of the emission impacts. So again, about almost 

17 400 million metric tons of CO and this is over 

 2

18 the 30-year period. Below we have the value of 

19 emission reduction in dollar values. 

20 On the next slide we have a summary 

21 of the life-cycle cost and payback period 

22 results, and here we calculated within each 
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1 equipment class group a shipment weighted 

2 average of the LCC results using the 

3 representative units to provide a number for the 

4 entire class. So we have a TSL 2 weighted average 

5 LCC savings of about $139 and a payback period 

6 of about three years. 

7 And here we have the consumer 

8 impact. And to go back to what we were talking 

9 earlier, a TSL 2, if you look at the last three 

10 rows, you see that about 58 percent of the 

11 population would not be impacted by the 

12 regulation and that's because a lot of motors are 

13 already at NEMA Premium or Premium efficiency 

14 levels, and you see that almost 34 percent of the 

15 population would benefit from the standard. 

16 And here we have the same table as 

17 presented in the notice, which are the 

18 annualized results, and here we only show the 

19 results for TSL 2 and that's -- 

20 MR. BROOKMAN: Comments on the 

21 foregoing summaries, summary tables? Nothing 

22 additional at this time. Okay, thank you. 
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1 So as we promised at the outset, now 

2 is another opportunity for anyone that wishes to 

3 make closing remarks, raise other issues that 

4 you wish to raise that haven't been fully covered 

5 during the course of the day to make sure this 

6 record is complete. John Malinowski. 

7 MR. MALINOWSKI: John Malinowski. 

8 I'm going to, I guess, put my NEMA hat on and 

9 probably my Motor Coalition hat as well and just 

10 basically say that we appreciate working with 

11 you through this and coming to a common 

12 conclusion. 

13 I want to restate our offer to work 

14 in ex parte mode with the DOE and Navigant 

15 between now and the final rule to perhaps vet the 

16 words of the final rule into understandable 

17 motor language so it's most clear for all to 

18 interpret. 

19 The success of previous rules such 

20 as EISA and EPACT, we've not had any problems 

21 with those as the verbiage in those was authored 

22 by the motor people, NEMA and people from the 
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1 coalition. So we'd like to take that good 

2 practice and move that forward into this so that 

3 we have fewer problems with enforcement on the 

4 new rule as it comes out. Thank you. 

5 MR. BROOKMAN: Okay, thank you. Gary 

6 Fernstrom. 

7 MR. FERNSTROM: This is Gary 

8 Fernstrom. I'd just like to say on behalf of the 

9 California Investor Owned Utilities, we're very 

10 supportive of this rule with the minor technical 

11 adjustments that NEMA's in the process of making 

12 and very appreciative of the cooperative work 

13 which took place in the coalition and with the 

14 Department of Energy. 

15 MR. BROOKMAN: Thank you. Other 

16 concluding remarks as we round out the day here? 

17 MR. RAWALD: Doug, I do have a -- 

18 MR. BROOKMAN: Yes, Doug, please. 

19 MR. RAWALD: This is Doug Rawald. So, 

20 John, the beginning of the day you mentioned that 

21 you felt that the U-frame motor specifically 

22 should be kept either to the standard they 
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1 currently have if they were covered because 

2 they're general purpose or those that are not 

3 covered because they are special/definite 

4 purpose would be at that level that's there now 

5 for Subtype II motors that are U-frame. 

6 So in your comments if you could 

7 explain to us that, because that would be 

8 creating a different class that we don't have 

9 right now and assessing the cost and benefit of 

10 that in real data terms so we can look at that 

11 issue. 

12 I think just you describing to us is 

13 important but helping us understand the scope of 

14 how many U-frame motors there are out there, how 

15 many we're talking about, how expensive it would 

16 be to make those go to the higher level versus 

17 keeping them at the level that is currently set 

18 for the U-frame folks, that would be very helpful 

19 for our analysis I think. 

20 MR. BROOKMAN: Okay, thanks. Any 

21 additional comments here? Then for my part I 

22 thank you all. A very constructive meeting, 
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1 wonderful comment, very balanced and on point 

2 and productive. I'll turn it back to Jim Raba for 

3 our closing remarks. 

4 MR. RABA: We conclude today's public 

5 meeting in great appreciation for your 

6 participation. This has been a very productive 

7 meeting. Thank you. 

8 Thank you to our motors team, Brian 

9 Coffey, Sanaee Iyama, Vijeta Jangra, Hayden Cook 

10 who virtually worked 24/7 for several weeks to 

11 prepare the proposed rule, the analyses, slide 

12 presentation and much more in time for today's 

13 public meeting. 

14 Thank you to our guest speaker, 

15 long-time leading motor expert Dr. Howard Jordan 

16 and his work on motor software to correlate test 

17 results with calculated results. 

18 And plus many thanks to our 

19 technical crew, Emily Marchetti and Brenda 

20 Edwards, who made this event logistically 

21 possible, and to Facilitator Doug Brookman. 

22 We look forward to receiving your 
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1 comments. Safe travels. 

2 (Whereupon, the meeting in the 

3 above-entitled matter was concluded at 2:36 

4 p.m.) 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22
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132:9

Bonneville 3:1

boost 96:22

borders 177:11

Boteler 1:19 9:5,5

29:11,11 30:4

33:15,15 45:14,14

57:7 58:2 59:19

59:19 112:6 114:8

114:9 130:9,9

131:2 142:13,13

166:21,21 167:14

bottom 86:14

134:11 138:1

bounds 173:1,4

box 166:15

boxes 52:22 125:18

140:8,20 148:17

151:1 158:16

brake 36:11 50:21

50:21 69:7,10,15

70:20,22 72:4,16

72:21,22 73:21

75:4,9

brakes 68:2,19

braking 97:11

BRAM 3:4

brand-new 25:3

Brazil 93:10

break 13:5 66:19

66:20 76:8,9,17

112:2 122:1,2

breakdown 59:14

106:8 141:18

breaking 72:5,18

Brenda 188:19

BRENNAN 2:20

Brian 1:21 4:15,17

10:22 37:1,3

38:13,15 50:6

63:22 65:18 78:17

79:1 91:5 92:9

112:16 115:15

125:5 132:22

188:8

brief 12:13,15

92:15 124:13

briefly 77:15 162:2

bring 36:6 67:15

87:10 97:16

brings 39:14 76:5

112:19

broadening 19:16

broader 28:18

Brook 1:21 12:2

Brookman 1:12,14

4:3,8,12 5:5 6:3

6:10 8:5 10:21

11:7,12,17 12:9

14:3,7,10 18:10

22:13 28:4 30:2,6

30:22 31:8,14,18

33:1,7,14 34:15

35:8 37:3 38:12

41:21 42:8,13

44:7,17 45:4,7,22

47:22 49:4,9 50:5

51:2 52:5,16,20

53:5,9,12,16,22

54:14 55:3,8,20

56:14 57:5,13

58:11,22 59:18

60:20 62:2 63:12

63:20 64:4,9

65:15 66:3,8,15

67:11 69:16 71:11

72:1 73:14 74:4

74:22 75:15 76:7

77:10 78:3,14,22

80:9 81:16 84:2

85:8,17 88:6 89:8

89:11 90:21 91:4

91:9 103:9 109:7

109:19 111:12,17

112:9,15 114:6

115:9,14,17

116:12 117:4

118:14 120:16

121:20 122:1

124:3,11,19,22

125:4,9,16 127:7

129:18 132:2,12

132:21 133:3,10

136:19 139:22

140:7,19 142:12

142:21 148:16,20

149:5 150:6,20,22

152:5,12,21

153:20 156:11

158:15 159:6

160:3,6,8 161:2

161:13 166:20

167:12,15 170:4,6

171:16,19 172:19

173:12,15 176:4

177:12,22 178:10

180:14 184:20

186:5,15,18

187:20 188:21

brought 34:13

BROWN 2:20

BRUIN 2:21

BRUNET 2:20

Brush 1:20 11:11

11:11

Budzynski 1:20

11:9,9

build 94:7 172:8

building 6:9 27:3

77:2 115:12

buildings 27:8

builds 34:6

built 61:13,15 94:1

97:13 98:6 102:22

bulk 124:8 161:8

bullet 166:22

Bureau 160:20

bus 95:6

business 110:17

111:4 162:12

170:22 171:1,4

173:18,22,22

174:5,16,18 176:3

178:3

business's 128:18

129:6

businesses 173:20

174:11,13,15,21

174:22 175:6,12

175:16,20,22

176:8 177:19,20

178:8

BUTLER 2:21

buy 86:5

C

C 41:16 43:22 49:3

68:16 100:14

113:17 151:12,15

151:18,20 173:3

C-O-N-T-E-N-T-S

4:1 5:1

cafeteria 111:22

112:1 122:3

cage 41:8

CAGI 3:5

calculate 26:10

83:11 103:17

105:1 107:9,19

134:4 136:10

137:22 138:4,21

calculated 83:8

99:1 102:1 103:16

103:21 107:14

108:9 109:5

117:20 118:1,6,8

118:10 120:1

131:10 183:22

188:17

calculates 143:7,12

calculation 105:13

108:13 110:4,6

117:11 134:12,16

136:13 137:19

calculations 97:15

98:14 138:2

calibrate 90:11

170:12,14

calibrating 170:11

calibration 115:6

116:15,16

California 2:4,22

3:3 8:15,18,19,21

31:11 55:22 56:1

56:11 57:17 77:18

129:20 186:9

call 37:10 98:21

101:22 109:3

called 90:8 137:18

156:14 162:21

Canada 2:20

cap 43:8 57:9,10,18

57:19

capability 94:20

capacitor 57:19

capacity 67:18

119:16 162:16

capital 25:8 164:20

capture 87:12

captured 70:21

120:6 150:2

carbon 181:8,18

careful 73:1 118:22

119:6 156:19
202-234-4433

Neal R. Gross and Co., Inc.

Page 193

Carlo 137:15

case 27:17 30:16

83:13,13,14 99:10

103:10 115:20

116:11 117:11

137:9,10 140:17

141:5 143:19,20

143:22 144:7,17

145:6,10,13,16

146:1,3 148:13

151:19 155:2

157:13 168:9,14

168:14 172:16

182:8

cases 29:19 30:21

33:18 42:2 71:3

101:9 116:17

141:5 180:6

Casey 1:21 12:2,2

cash 162:21 163:1,8

163:19 168:6

cast 101:15,15

154:3 155:4

casting 120:3,13

castings 157:8

catalog 113:1 144:6

155:11

catalogs 69:14

156:19

catapult 94:13

categories 59:13

84:22

categorization 41:3

category 57:4

72:19 73:13

159:19 160:2

167:4

caught 124:11

cause 164:21

166:11

caused 168:18

CEC 56:2 58:7

ceiling 74:15

cell 14:20

Census 135:7

Center 94:6

certain 16:21 24:11

28:13 38:5 79:20

107:11 121:5

149:2

certainly 16:14

42:16 64:2 70:9

70:22 92:2 100:5

110:1 113:14

114:20 121:22

certification 28:13

30:13 31:7 32:16

32:17 35:5,7

174:6

CFR 51:10

CHAD 2:22

Chairman 8:12 9:6

10:2,5

chance 23:2 91:20

chances 112:11

change 29:21 51:1

101:10 113:22

114:2 116:22

128:17,20 129:7,8

154:12

changed 29:18

68:20 138:13

139:5,7,10,11

141:14,15 150:11

changes 32:20 93:1

119:4 134:13

139:12 143:17

148:3 157:22

158:1 181:4

changing 100:8

182:16

channels 127:22

128:2,7,9,13

129:14 132:7

133:7 172:3,12

chapter 156:3

159:5 160:22

161:10 183:4

characteristic 65:1

characteristics

44:18 64:6,18

118:13,20

characterize 39:20

79:10 89:18 90:7

113:4 134:2

characterizes

137:16

characterizing

132:6

Charlie 2:13 12:4

85:17 132:13,22

171:19

chart 45:16 137:19

137:21 138:2

142:15

charts 45:15

checked 12:12 14:5

chillers 85:1

chooses 79:20

chosen 82:6,17

109:10

circumstance 84:20

clarification 51:13

54:4 57:16 58:8

61:22 177:14,21

clarified 60:6

clarify 31:3 44:10

46:11 61:1 65:6

65:11 155:1

clarifying 36:20

153:1

clarity 78:15

class 26:4 68:5,8,11

68:13,15,16,18,19

68:22 69:7 70:7

71:15 72:6 74:8

74:16,20 80:1,2

80:13 81:4,14

83:21 84:17 86:20

88:12 89:16,21,22

109:15 126:6,16

126:22 135:16,19

139:3 140:14

142:9,11 144:8,11

144:16,21 145:20

146:2,18,22 147:3

147:17,19 151:14

169:18 184:1,4

187:8

classes 40:2,7 67:16

67:18 68:1 79:12

126:3 146:13

147:6

classified 49:6

clause 42:5 43:12

clear 16:1 47:21

60:4,11 109:1

110:14 111:4

185:17

clearly 91:1 95:16

Cleveland 93:10

close 99:3 106:19

116:3 122:4

closely 36:2

closer 149:6

closing 5:4,6 13:19

111:22,22 185:3

188:3

coalition 7:10,19

9:17 18:15 19:4,7

20:20 22:5,9 36:3

36:5,9 70:5 88:5

119:13 176:13

185:9 186:1,13

Code 21:4

Codes 23:18

coffee 77:4 122:7

Coffey 1:21 4:15,17

10:22,22 37:1

38:13,14,15 42:15

42:19 50:7 51:9

51:22 52:6 53:3,6

53:13,19 55:5,13

59:2 62:11 64:1,5

65:6 67:8,15 71:7

71:10 75:16 78:20

79:2,3 80:16 81:3

83:6 88:17 89:14

91:6 92:8 109:13

112:17 114:4,19

121:22 125:7,20

133:1,4 188:9

cold 6:22

collaborate 20:1

colleague 85:11

collect 60:1

collected 136:3

155:10

collection 68:6

collectively 58:7

combination 26:18

68:1 131:12 132:7

132:10 146:10

combined 138:4

combines 134:9

180:21

combining 50:20

come 39:2 71:21

73:20 76:18

108:21 142:16

154:8 178:18

comes 25:11 116:18

175:13 186:4

coming 7:6 8:4

12:10 34:21 135:6

185:11

commend 18:19

comment 15:3,11

20:11 32:1 33:9

35:21 37:4 39:5

52:22 54:2 55:6

59:3 64:6,12 65:5

69:9 71:15,22

93:12 109:21

113:19,20,21

114:1 115:15,17

116:14 117:5

125:8,10,18 140:8

140:15 142:14

148:9,17,19,22

151:1 158:7,16

159:7 160:5 162:5

166:15,22 175:22

188:1

commenting 33:9

62:12 133:8

comments 4:11 5:4

17:5 18:8 22:9

28:5 29:6 30:6

31:19 33:2 35:8

39:10 44:21,22

45:6,9,10,11,12

46:5,7,22 47:1

48:4 50:1,6 52:9

52:21 63:21 64:3
202-234-4433

Neal R. Gross and Co., Inc.

Page 194

64:10 66:5 67:12

69:5,6 73:19

76:11 89:12,13

91:18 114:4,6

119:15 120:20

125:12,14,18

127:8 136:22

140:10,11,19

142:6,6,22 147:16

147:16,20,22

148:6,11,18 151:1

158:16,17 161:15

167:16 170:2,4

173:16 176:12

180:17 184:20

187:6,21 189:1

commercial 16:21

27:3,8 103:3

134:22

commercial/indu...

28:14

commercially 81:8

Commission 2:22

3:3 8:22 56:2

57:17

commit 124:13

Committee 9:7

10:3

commodities

158:11

commodity 160:16

common 44:1

185:11

companies 120:12

177:4 179:1,6,17

company 8:18,20

10:1 110:11

118:17 119:20

176:13

Company/ABB

1:20 2:10,17

comparable 152:2

compare 157:4

compared 60:17

165:8 169:12

comparing 82:14

157:2,13

comparison 87:16

114:15

competition 35:15

competitive 93:16

166:12

complete 14:17

32:3 185:6

completely 75:22

96:3

complexity 74:15

compliance 19:8

20:6 21:13,19,22

24:19 28:12 29:4

29:6,8,15 30:7

31:19 32:20 142:2

144:18 145:15,19

146:4 162:18

174:6 178:20

compliant 166:11

168:21

complicate 172:13

comply 25:3 165:14

166:4,8

complying 166:13

component 34:4,10

35:5 94:15 104:1

113:2 117:13

components 103:17

103:21 117:14

118:9 154:13

compressed 3:5

39:10

comprised 94:10

concept 19:16

conceptually 39:17

concern 23:5

concerned 26:1

47:7,17 164:10,13

165:22

concerns 20:20

23:3,4 24:14,16

27:22 165:7

167:17

concise 14:22 15:8

60:15

conclude 112:9

160:18 188:4

concluded 189:3

concluding 186:16

conclusion 101:8

116:18 171:3

185:12

concur 74:6

condition 133:15

conducted 161:21

162:2 163:6,17

164:2

conducting 170:22

conductor 104:21

105:2

conductors 107:13

107:17,18,20,22

108:10

configuration

41:10 68:3 117:1

configurations

69:12,15

confirmed 97:14

conflict 48:5 58:1

77:20 151:6,20

152:17

confusion 47:15

48:6 58:10 61:19

conjunction 119:21

consensus 36:3

50:3

conservation 1:3

6:7 16:20,21 28:9

28:16 29:2 35:16

conservatism 150:4

conservative 99:5

106:4 149:16

consider 18:6 21:2

35:11,19 39:13

54:22 58:20 62:17

73:17 75:9 171:15

178:7

consideration

14:13 32:14 33:5

78:10

considerations

154:3

considered 35:16

41:19 65:9 81:7

87:17 107:2 126:7

131:15 136:9

137:7 143:7 147:5

154:5 173:21

182:5

considering 140:6

considers 39:9

consistent 25:21

48:15 142:17

consolidating 21:3

constant 146:3

147:18 148:14

construction 154:5

154:18 155:6,6

constructions

155:2,5

constructive

187:22

consultant 1:20

2:16 11:11 171:14

consultants 7:15

Consulting 1:21,22

2:8 161:19

consume 165:20

consumer 17:18

21:6 67:21 127:17

128:4,16,20 129:8

161:6 182:15

184:7

consumers 35:12

88:20 137:6

165:11

consumption 17:16

133:14 136:16

contacted 174:14

contains 41:7

content 28:6

136:20

continue 21:21

49:18 54:18 105:6

137:3 161:12

180:18

continuous 41:6

contract 94:6

contractor 95:15

130:20

controlled 27:4,14

convergence 105:8

conversation 15:21

21:20 170:8

conversations

14:21

conversion 25:8

convert 128:3

181:16

converted 134:7

Cook 1:22 4:22

11:4,4 161:18,18

167:19 170:5,13

172:20 173:14,17

177:13 180:16

188:9

cooling 27:4

cooperative 186:12

coordinate 91:12

copious 124:9

copper 90:10 97:17

97:20 101:4,16

102:14,16 107:6

114:11 119:16,17

120:3 158:10

164:16 165:3,5,6

165:8

copy 14:6 91:8,9

152:3

core 100:22 101:3

117:12,16

Corp 1:17 2:19,20

Corporation 1:19

2:9,13 9:6,9,11

54:2 103:13

correct 29:19 43:14

102:6 153:5

171:10 173:14

177:19

Corrections 28:20

corrective 29:22

correctly 151:11

153:3

correlate 188:16

correlation 99:14

100:3 101:21

102:16 103:3

106:14 110:5
202-234-4433

Neal R. Gross and Co., Inc.

Page 195

115:21

correspondence

42:3 97:19

cost 4:18 13:9

35:13 70:15 79:15

83:11 86:9 89:18

98:8 101:5 112:20

113:13,22 114:2

121:18 128:16,21

129:4,9 137:3,5,9

137:11,12,13,20

138:1,5,6 139:15

139:17 140:10

143:15 167:10

168:10 169:10

181:18 183:21

187:9

cost/efficiency

79:13

costly 166:14

costs 17:18 86:16

112:21 113:2,10

169:2 182:17

Council 2:3 9:16

Counsel 10:13,15

10:17 44:10

count 69:2 126:22

158:1

counterpoint 53:4

countries 179:4

country 116:6

178:8,21 179:7

couple 46:13 76:9

113:19 155:9

course 16:2 39:9

75:20 92:22

106:12 117:17

158:8 185:5

courtesy 14:14

cover 38:19 48:6

51:7 56:20,21

57:9,10 84:22

127:2 159:19,22

coverage 28:21

36:11 39:21 40:16

40:22 43:2 50:13

50:22 55:13,15,19

71:6 80:6

covered 13:22

24:18 25:1,2,6,15

25:20 28:2 29:21

33:5,16 38:9

45:18 50:10,15

51:14,14,16 53:18

55:14 56:20 57:12

60:7 61:7 65:4,10

67:17 73:2 74:9

79:19 80:13,14,15

81:1 82:18,19

84:17,21 86:2

87:11 88:14 89:5

126:1 138:11

159:17 163:5

175:7,9,14 185:4

187:1,3

covering 53:2

57:20 77:20 84:21

86:1

covers 57:8 128:17

129:9

Craigslist 167:7

cranes 71:5

create 52:4 58:1

75:6 113:8

created 68:13

73:12

creating 73:11

120:5 187:8

credibility 103:6

credit 161:7

credits 161:7

crew 188:19

criteria 40:10 41:1

41:18 42:15 44:12

49:2,13 50:11

55:15 61:16 62:22

63:9 65:12,22

66:2 75:10 173:19

critical 33:20

Crompton 1:21

12:3

cross 107:6 114:15

crowd 122:8

Crystal 137:18

CSA 2:19 3:2 30:18

30:19

cue 53:1 140:7

cuing 15:9

cumulative 17:17

181:14

curious 54:8 154:9

current 28:22 36:7

40:11 41:9 45:19

62:1 98:18 110:13

119:4,9 141:7

144:1 166:1

181:18

currently 36:6,19

50:9 58:13 60:6

80:14,15 109:16

109:17 148:12

175:1 187:1,17

currents 95:19

curve 102:6 116:1

116:10

curves 113:14

custom 172:7

customer 33:22

121:17

customer's 61:14

customers 8:16

121:2 165:19

169:3

cycle 4:18 34:20

181:5

cycles 19:10

Cymbalsky 2:1 4:5

6:17,18,19 10:20

10:20

Cymbalsky's 16:11

Cyril 92:18

D

D 2:20 71:4

D.C 1:12 6:9,22

24:2

Dale 1:17 8:11 62:2

62:3,20 63:13

72:2,3 73:15 74:6

74:17,22 75:1

131:7 159:13,14

damage 120:4

Dan 2:1 9:20 31:1,2

34:15,16 60:20,22

109:19 153:20,21

data 18:9 59:3,11

60:1 61:18 63:5

63:10,14 80:21

87:20 90:1 98:11

98:13 103:5

104:14,18 106:16

110:7,20 113:5

117:12 133:14

135:8 136:10,11

141:8 144:6,13

147:20 148:1

155:9,11,16,18,22

160:15 187:10

database 135:5

174:5

date 29:6,13 30:7

31:19 32:8,10

37:9,16,20,21

39:8 142:2 162:18

Daugherty 2:17

37:4,7,8 64:11,13

64:13

DAVID 3:2

day 7:19 13:19 15:4

23:13 47:8,8

179:22 185:5

186:16,20

days 24:1,3

deadline 20:11

21:22 32:3,5 33:6

deal 24:14

dealing 63:18 172:4

December 1:8 6:8

24:1 25:13 29:5,7

31:22 32:4 35:20

36:13 142:2

decided 126:10

decision 49:20 69:6

69:10 147:16

deck 94:11

decreased 101:4

default 99:13

defer 58:3 83:6

deficiency 82:6,12

defies 119:10

define 39:21 50:2

108:22

defined 49:1 52:15

52:17 62:13 71:18

78:7,8,12

defines 151:15

definite 59:9,16

61:8 78:6 153:16

definite-purpose

34:21 40:21

definite/special

60:10

definitely 131:20

definition 49:8

51:22 52:7,10

60:13 174:16

definitions 28:11

36:15 46:8,17,18

47:12 50:19 53:20

60:4,5,11

degree 157:10

Delaney 2:1 9:20

9:20 31:2,2 34:15

34:16,16 60:21,22

60:22 109:20,21

111:2 153:20,21

153:21 155:1

deLASKI 2:2 10:7

10:7 31:20,21

33:8 52:14,16,17

74:5 84:4,19 85:4

87:1 148:19,21,22

149:7 152:21,22

153:9,17 170:6,7

170:15,19

delay 76:21

delivered 97:9

delivering 18:14

delivers 95:6

delta 27:17 87:6,13

demonstrated

103:6

Department 1:1

2:1,5,8,11,12,22

6:5 7:11,22 10:12
202-234-4433

Neal R. Gross and Co., Inc.

Page 196

10:14 15:12,15

16:22 17:22 18:5

18:20,22 19:3,5

19:13,20 20:12

21:2 22:7,11,22

24:6,10 31:22

32:2,9 35:17 44:9

45:1 46:4 47:4

49:11 58:4 60:12

84:8 85:5,9

111:21 112:19

114:14,21 149:9

150:17 160:10

170:9,12,16 171:6

171:13,14 186:14

Department's 22:8

37:10 54:18 170:9

dependent 116:22

depending 121:7

136:5 140:13

169:6 183:13

depicts 144:1

145:11

derive 103:19

181:7

derived 156:8

described 13:21

74:17 84:12 86:4

103:2 116:15

describes 43:6

107:9

describing 187:12

description 124:13

descriptive 44:19

design 30:1 38:5

40:9 41:16,17

44:2 48:22 49:3,8

57:20 68:2,6,15

68:16 71:4 75:5

75:12 79:9 92:19

93:9,14 95:12,17

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metals 11:15

metered 121:2

Metglas 1:15 3:1,2

11:14

method 41:2 52:18

105:14,16 107:9

108:2,3,4,7,19,19

110:5,6,7 127:20

129:11 133:17

138:21 141:6

178:22

methodology 83:7

103:15 164:6

methods 108:1

metric 41:13 42:4

163:3 181:12

183:17

MG 40:15 43:5

49:6 68:12 126:10

126:17 150:9

MIA 161:20,22

162:1,5,6,14

163:6,10 164:6

167:21 170:3

183:9

Michael 2:8,21 3:7

10:14

microphone 63:12

66:14

microphones 8:8

midday 13:10

midmorning 13:5

million 119:17

141:20 177:4

181:12,22 183:12

183:17

millions 8:16 167:9

MILLURE 3:2

mind 85:15 172:21

minimal 101:5

minimally 168:20

minimum 29:14

33:17 80:22

minor 186:10

minus 98:22 99:1

147:12

minute 92:6 95:8

minutes 121:21

122:12

mirrors 36:2

misread 130:22

misreading 151:4

missed 32:2 132:3

misunderstanding

46:12

misunderstandings

74:17

mix 109:16 144:2

145:11

mode 14:20 185:14

model 117:10 120:8

141:13 149:9,10

162:21,22 163:2,8

181:7 182:7 183:1

modeled 81:9

137:14 142:1

168:17

modeling 90:8,16

91:15,19 92:16

112:18 170:11

181:7

models 144:4

171:10

moderately 116:8

modification 66:4

67:6

modifications

67:12 96:4

modified 159:2

182:6

moment 6:15 87:2

111:20

monetized 180:22

181:16

Monte 137:15

months 21:18

29:14 30:10,21

31:5,6,17 32:8,11

33:19 35:1 37:15

52:19

morning 6:3,16 7:2

12:12 14:5 15:22

16:6 38:14 45:8

76:10

MORRISON 3:2

motor 1:19 2:9,13

6:6 7:10,18 9:6,9

9:10,17,18 10:3

18:15 19:4,6

20:19 21:16 22:5

27:2 30:19 34:5

36:3 41:6,17 44:2

44:3,5 51:20 52:2

52:4,10,21,22

53:6 54:2,5 56:18

57:7 60:3,6,14

63:17 65:12 68:10

72:4,16,22 75:4

75:18 82:5,12,15

87:8 88:1,4,22

89:1 92:19 93:7

94:10,16 95:2,3

95:13,17 96:3

97:6,8,8 98:1,15

99:20 100:9,18

101:5,13 102:7,8

102:22 103:13

110:17,22 112:20

113:3 114:22

115:11 117:13

118:20 119:5,14

121:4,11,12

127:17 130:1

132:9 133:19

134:3,6,10,12

135:4 136:2

138:21 140:13,16

141:4 143:6 144:2

145:12 148:2

149:21 156:20

157:1,18 158:2,3

164:10,13,13,21

165:15 166:2,3,4

168:10 170:11,19

172:10 173:6,21

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motor's 103:5

Motor/Generator

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51:19 52:13 53:17

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56:21,22 57:9,21

59:4,5,6,7,10,15

59:16,17 60:18

62:5,13,22 63:4

63:17 64:7,16,18

65:8,19 68:6,17

68:18 69:7,11,15

69:22 70:1,14,20

70:22 71:3,5

72:21 73:21 74:9

74:11 77:21 78:3

78:5,6,7,7,8,11,12

78:13 80:22 82:22

83:2,5,15,20,22

87:11 88:14 89:21

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N 41:17 43:22

name 8:9 14:16

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name's 6:10,19

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national 1:18 2:6,7

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Natural 2:20

Naval 96:7

Navigant 1:21,22

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Navy 95:14 96:2

Navy's 94:3

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need 14:10 29:14

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113:15 117:1

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needs 30:20 43:9

103:1 157:11

neglected 14:5

negligible 183:2

NEMA 1:19 2:6

8:13 9:7,9,19,21

10:3,6 12:3 18:18

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30:5,9 31:3 38:5

40:14 41:11,12,16

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61:1 68:1,11,15

68:16 69:18 71:14

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81:9,12 83:15

95:17 99:21

126:11,18 140:1

142:17 144:14

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146:21 147:1

150:8,10,12,12,14

150:18 151:16,18

152:7 153:22

154:9 156:15

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NEMA's 36:7

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NEMS 181:7 182:7

net 17:17 143:12

147:10 163:2

never 25:2,15 29:20

86:2 159:22

new 36:14 40:17

48:14,21 84:22

96:7 100:16 105:4

105:6 144:3 145:6

159:21 163:4

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newer 165:13

newly 25:1,6,20

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newly-covered

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NIA 159:2 161:4

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niche 177:3

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nine 41:1,18 50:11

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ninth 49:12

nitrogen 181:9

nodding 159:12

nominal 81:9

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NOPR 24:9 31:21

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Northwest 2:13

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nth 157:10

number 19:1 20:15

20:16 45:16 68:7

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105:13 107:11

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118:19 132:15

144:4 147:22

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184:3

numbers 27:22

48:19 82:13 89:17

91:11 128:10

131:16 142:16,18

NYS 3:7

O

o'clock 76:18 112:1

O-F 4:1 5:1

objective 178:2

observe 14:13

observed 81:21

obtain 21:8 103:16

obviously 48:11

61:20 82:10 110:2

110:3,15 121:14

occurred 163:12

OEM 34:1,22 35:3

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operating 35:12

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opposed 49:7 104:1

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optimization 76:1

optimized 100:15

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option 49:19 107:5

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optional 179:10,16

options 39:22 40:8

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107:2 159:3 161:5

oranges 157:2

order 52:4 90:10

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114:2 118:10

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organization 30:18

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organizational 8:10

original 21:16

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originally 39:1

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outlier 83:1

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outlining 64:7

output 163:1

outset 12:17 18:11

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outside 58:19 65:19

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over-designing

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overall 129:15

132:1 182:13

overlap 59:4

overseas 179:2

overstate 26:5,19

overstating 88:19

overview 80:4

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Owned 2:4 8:15

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part 9:2 19:11

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Paul 2:10 3:6 12:6

PAULEY 3:4

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pay 172:8

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people 16:14,16

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155:21 167:5

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portfolio 9:3

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portion 87:14,19

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94:19,19,20 96:18

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114:13,16 115:19

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26:7 90:8 91:16

91:17 92:17,22

94:9 96:11,14

98:2 100:5 102:16

102:20 103:15

104:12 105:9,15

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117:20 118:7

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programs 104:22

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progress 77:13

project 2:2 10:8,18

16:9 18:17 98:3

148:13 160:12

projected 35:13

36:1 39:8 141:8

143:9,10,20 144:2

145:11 150:5

projecting 149:2

projection 144:1

145:10

projections 141:22

proliferation 20:21

prolong 165:20

promised 185:1

pronounce 109:9

proportional 129:2

proposal 7:11 36:5

36:8 50:10 170:20

proposed 1:3 5:3

6:6 13:17 17:4,9

17:19 18:6 21:19

29:6 31:22 35:22

36:2 38:1 48:9,14

48:21 51:17 55:11

64:20 70:5 71:21

158:22 159:21

162:3 169:16

170:1 175:2,5,11

175:17,18 178:4

181:11 188:11

proposes 17:1

proposing 40:17,21

50:8 53:7 54:10

86:12 179:11

proprietary 90:8

Propulsion 96:13

prototype 120:13

prove 95:22

provide 24:7,11

34:5,6 48:4 58:18

94:11 96:22

102:11 173:9

184:3

provided 94:21

130:5,13 141:13

provides 134:12

providing 25:2

PSC 56:20

PSCs 57:1,2

pseudo-input 118:5

public 1:5,11,14

6:5,11 8:22 16:8

16:12 17:3,4

23:13 24:9 35:21

58:14 66:13 113:5

188:4,13

publication 36:1

39:8

publicly 90:2

163:13 174:3

publish 37:15

published 36:12,22

52:18

PUC 26:6

pump 34:1 55:10

55:17 56:4 64:16

65:8,14,19 68:2

68:17 77:15,20

78:7,11 151:10,12

151:21

pumps 56:3,10 57:3

146:15,19 147:1

purchase 129:3

148:3 161:9

165:13

purchased 17:11

89:20 90:9 98:5

purpose 39:19 57:8

59:7,9,16 60:11

61:9 78:6,6,8,12

78:13 79:8 95:3

95:11 127:16

133:13 137:4

141:3 142:1 143:4

153:16 158:20

162:6,9 181:1

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purposeful 125:11

purposes 98:8

push 76:14

put 7:16 16:15,15

34:22 47:11 65:19

69:18 70:4 72:6

74:12 108:12

131:16 153:4

185:8

putting 93:20

Q

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quads 17:13 147:7

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qualitative 163:9

quantified 183:3

quantitative 163:3

quantities 120:13

question 13:22 55:9

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questions 69:21

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103:10,14 127:8

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quick 22:17 40:11

51:4 183:6

quickly 48:7 77:5

122:5,9

quite 91:1 92:20

94:1 95:17 101:20

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118:19 149:17

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R

R&D 164:20

Raba 2:11 4:10,14

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12:19 16:5,6,9

18:4 28:8 35:10

124:10,17,21

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Railroad 96:15

raise 13:20 15:18

19:17 161:16

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raised 70:1 117:17

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raises 100:5

ran 167:21

range 34:22 57:21

71:1 74:10,12,13

80:19 81:5 121:6

126:13 135:10,21

136:6 141:19

142:11 144:9

145:1 147:6 148:8

172:4 173:9

183:14

ranges 17:19

rapid 95:9

rapidly 76:12

rate 17:20,21

147:11,13 183:13

rated 41:6,10

rates 113:4 181:19

rating 44:6 59:8

68:2,3 157:14,15

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ratings 45:17,18

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Refrigeration 3:8

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Regal 2:1,10 9:20

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regard 42:1 58:9

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regarding 44:11

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Register 21:5 23:22

registered 150:13

regression 156:1,2

regressions 126:8

regular 172:5

regulates 56:2

regulating 56:11

regulation 57:20

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regulations 36:16

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regulatory 4:13,20

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related 21:9 54:3

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relationship 79:14

relative 39:7 80:5

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relied 141:6

remain 70:5 146:15

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remainder 130:19

remaining 117:18

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remarks 4:10 5:6

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repair 139:6 140:3

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report 124:5

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representative

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representing 8:15

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request 20:14

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required 30:13

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requirement 56:7

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requirements

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research 58:15

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residential 56:3

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respond 33:12

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response 64:15

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responses 109:2

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responsible 94:17

rest 79:21 165:1

restate 185:13

restrooms 77:2

result 74:16 105:3

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resulting 107:15

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right 13:5 14:8 32:4

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road 42:18

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Roger 2:17 37:4,5,7

38:12 43:13 64:11

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roll 145:15,15,18

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rolled 154:4

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room 1:11 6:15

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66:11 67:2 90:22

91:7 122:13

Rosenstock 2:12

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22:15 33:2,3,3

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56:16,16 57:2

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rotor 41:8 90:10

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roughly 130:14

round 107:18 108:2

108:4,20 186:16

row 135:10,21

rows 184:10

rpm 97:13

Ruffing 2:13 9:8,8

14:1,4,9 41:22,22

48:1,2,2 49:5,16

53:22 54:1,1

103:11,12,12

104:19 106:7,21

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rulemaking 1:3 6:6

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28:22 54:12 56:13

58:13 65:10 67:22

79:12,22 84:11,13

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98:3 102:20 149:9

164:7 175:9,14

rulemakings 22:11

25:21 62:14 63:19

rules 4:7 7:22 20:15

185:19

rulings 30:12

run 57:9,10,18,19

97:3 106:18

running 97:12

runs 17:12

RYAN 3:6

S

S-E-S-S-I-O-N

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S.W 1:11

S1 41:7

Safe 189:1

safety 165:7

sales 70:14 130:13

130:17

sample 87:22

San 8:18

Sanaee 2:7 4:19,21

4:24 5:3 11:5

38:18 83:7,9

84:12,15 127:5,12

127:14 129:16

132:2 133:1 140:2

159:6 180:17

188:9

sat 84:5

satisfied 103:1

save 17:9

saved 115:11

savings 9:2,4 17:10

17:14,18 26:5,10

26:15,20 35:13,13

83:8,11 86:16

87:15,21 88:19

89:1 139:17 143:5

143:8,9,14 147:5

150:4 153:3,11

181:3,13,15

183:11 184:5

saw 27:10 53:4,15

66:5 67:8 69:4

79:5 89:16 172:3

183:7

saying 26:6 32:11

44:12 131:17

159:10 173:2

says 31:22 32:1

44:13 51:13 54:9

80:11 81:20 86:17

130:22 152:6

SBA 174:1

SBA's 174:5,16

scale 129:10 154:5

154:20 156:9

scaled 148:7 155:15

scales 126:2

scaling 126:1,5,21

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scenario 149:8,8,10

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schedule 39:5,11

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scope 19:16 28:18

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screened 107:3,5

screening 39:18

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season 7:8

seats 124:4

second 64:2 94:15

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second-to-last

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Secretary 35:17

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Secretary's 112:7

section 8:13 10:6

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183:5

sectional 107:6

sector 83:4 135:2

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sector-specific

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sectors 133:21

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secured 122:14

security 28:16

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see 6:11 7:6 19:13

27:9,12 35:18

39:7 45:17 51:10

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ship's 94:20

shipment 59:13

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shop 21:5 77:4

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shortening 93:5

shove 47:20

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115:12 134:13

135:12,18,22

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showing 26:11 79:5

80:3 89:4 134:3

139:3,14 141:21

181:11

shown 23:8 90:12

shows 48:10 87:20

163:10 169:19

shutdown 7:1

side 21:6 61:11

99:5 106:4

sidebar 14:20

sides 107:21

Siemens 2:5 10:4

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sigma 99:16

significant 17:9

27:6 32:21 72:11

87:15 100:21

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significantly 26:5

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175:4,11,19

silent 14:20

silica 102:10

silicon 116:7,8

similar 19:20 22:12

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96:12 145:22

148:9

simple 14:14

simplify 19:8

simply 49:17 65:20

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Simultaneous

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single 65:8 77:22

105:13 138:17

single-phase 56:6

56:12,22 57:20

single-speed 41:5

sinusoidal 41:9

sir 124:18

sitting 58:4

situation 83:13,13

92:2 95:9 137:10

149:11 168:17

situations 63:7

97:17 103:7

six 20:10 48:13

92:3 128:6 144:6

155:11

size 41:11,13 42:1

44:13,14 45:20

104:5 134:21

141:17 158:1

sizes 42:4,6,7 43:7

44:3 46:13 104:11

104:18 172:11

skip 39:2 92:12

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skipped 69:21

slide 38:22 50:12

53:3 66:4,6 67:7,9

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80:11 81:15 88:2

91:11 92:10,12

93:3,19,20 94:14

94:22 95:9,20

96:10 97:7,20

98:5,15 99:6

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126:14 129:21

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slides 53:20 76:13

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slight 72:14

slightly 80:7 145:4

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slot 107:10,10,15

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slower 71:21

small 56:17 57:7

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Smith 10:1

snowy 6:22

Social 181:18

societal 20:3,8

society 34:12

software 15:19

81:8 90:7,11

91:15,19,21 93:14

102:19 103:6

137:18 188:16

sold 128:9,16,21

129:4,9 144:3

145:12

solely 65:13

solicit 32:1

Solutions 1:15 6:11

solved 124:18

something's 65:4

somewhat 110:19

soon 29:13 39:7

sooner 31:16

sophisticated

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sorry 14:1 51:21

70:8 92:11 131:6

152:8 154:1 160:4

sort 46:6 62:4

80:16 100:10

118:12 154:15

179:5

sounding 6:14

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source 132:4 142:7

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special/definite

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specific 44:20,22

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specifications

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speed 57:11 94:12

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speeds 61:15 71:21

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spills 82:3,11

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spreadsheet 159:2

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spreadsheets

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spring 25:12

square 107:20,21

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squeeze 46:15

squeezes 168:19

squirrel-cage 41:7

St 9:6

stakeholders 24:3

24:11 87:4

stamp 44:2

stand 10:21 11:13

standalone 111:9

standard 25:4,16

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135:20 139:4,16

144:12,21 145:5

145:20 146:12,12

147:18 150:10

151:15 152:15,18

176:21

1-1/2 82:19

1,000 174:1

1.12 99:22

1.5 129:15

1.63 129:14

1:00 122:5,12,17

1:20 122:20 124:2

10 148:17 156:3

161:1 176:20,21

10:15 13:5

10:30 13:5

100 43:18 122:4

135:10,21

1000 1:11

11 1:8 76:18 154:1

154:1

11:01 77:8

11:15 76:18,22 77:6

11:19 77:9

117 76:13

11th 6:8 35:20

12 99:19 148:10

151:4 153:22

12-10 81:10

12-11 40:15 70:2,6

70:9,19

12-12 70:2 150:10

156:14 176:18

178:14

12,000 97:12

12:10 122:2,19

12:15 112:2

13 174:18,20,21

132 4:19

13th 36:22

14 99:10 147:7

147 4:21

15 4:10 69:9 84:6

150 99:21,22

16 26:9

168 4:22 99:22

17 159:5 161:10

18 4:12

188 4:24

19 32:1

191 5:3

192 5:5

196 5:7

1990s 92:21

1992 28:10,17

19th 29:7 142:2

1st 142:3

2

2 19:18 41:10 68:16

80:2 81:15 87:18

87:20 89:16,22

139:21 144:16

145:3 146:2,17

147:8,12,19

149:19 151:8,14

151:16,17,18,22

152:7 163:17,18

169:16 170:1

181:12,12 182:9

183:11,17 184:4,9

184:19

2:36 189:3

20 84:14

200 38:6 70:8

2007 24:22

2010 27:2 40:13

56:19 82:20 150:9

2011 17:16 141:18

150:9

2012 28:20 83:19

144:4,10,18,19

2013 1:8 6:8 36:13

2014 36:2 39:6

2015 17:12 25:13

29:5,7 32:1 56:19

142:2 176:20

179:12

2016 142:3,4

2017 176:21 179:12

2044 17:12

23.3 147:11

24 21:17 29:14

30:21 31:4,16

32:8,11 33:18

37:15

24-months 21:22

24/7 188:10

25 148:12 160:9

26 66:6

28 4:14

3

3 68:18 70:7 81:14

87:18,20 89:21

92:13 114:1

125:10 139:18,20

144:16 146:2,21

147:19 149:18

151:9,22 163:17

164:2

3.3 101:4

3/EL 149:21

30 42:18 69:11 71:1

73:3 100:12,18

143:10,21 149:2

153:11 155:20

181:14

30-horsepower

90:10

30-year 17:11

143:16 181:22

183:18

32 76:13

34 184:14

35 83:22

39 4:15

4

4 41:10 48:10,21

68:19 69:11 81:15

114:3,10 119:12

125:11 144:12

145:20 147:2,12

147:18 149:18,21

400 181:12 183:17

42.4 147:12

431 21:4 48:10

64:21

431.441 78:1

440 43:8

47 125:6

48 31:5 35:1

4th 35:22 39:6

5

5 4:4,6 48:14,22

49:18 90:9 93:3

100:14 119:17

5.4 141:20

5.7 101:3

50 130:14,17

132:15,19

500 38:6 41:14 43:2

44:5 48:12,16

71:20 74:12,21

5010s 43:7

56 41:12 153:16,18

56-frame 59:4

60:10 61:2 63:3

63:15,16 134:21

141:17 153:3

56-frames 153:7

58 184:10

5810s 43:7

6

6 36:13 41:10 43:3

69:11

60-hertz 41:9

600 41:10

6809s 43:7
202-234-4433

Neal R. Gross and Co., Inc.

Page 217

6th 24:1

7

7 4:9 17:13 48:14

48:22 49:18

73627 152:11,12

75 155:20

77 114:14

77.2 114:14

8

8 38:1 148:17

8-pole 41:10 43:3

69:12

82.5 82:22

84.9 114:13

85 4:17 108:17

121:6

89.5 109:12

8E-089 1:11

9

9 147:22

9:00 1:12

9:45 6:2

90 121:7

91 156:18

92 151:15 152:14

97 167:18
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

218

Electric Motors Energy

Conservation Standards

US DOE

12-11-13

Washington, DC