From: Roger Daugherty at Baldor-Engineerin g [mailto:RHDaugherty@baldor.com]

Sent: Monday, March 09, 2009 10:59 AM

To: Raba, Jim Subject: RE: C-face and D-flange mounting motors

And Good Morning to you Jim,

The definition of “general purpose motor” in NEMA MG1-1.6 (2006-Rev 1) does not contain any specified condition with respect to foot-mounted no r footless. Under that definition a “general purpose motor” could incorporate C-face or D-flange mounting.

Yes, C-face or D-flange are two types of mounting t hat could be used with footless motors. They are also two types of mounting that can be used wi th foot-mounted motors or motors that have provisions for foot-mounting.

When discussing foot-mounted or footless one might consider which element of the structure is

mounted to a base. A foot-mounted motor attached to a base may have a C-face or D-flange for supporting an attachment, such as a gear box or pump. A footless motor may have a C-face or D-flange for supporting the motor when mounted to another piece of equipment, such as a gearbox or pump, that is attached to a base. Likewise, a motor with feet for mounting may have a Cface or D-flange for supporting the motor when mounted to another piece of equipment, such as a gear box or pump, that is attached to a base.

I am not clear why you want to introduce the t opics of C-face and D-flange into the topic of “footless” versus “foot-mounted” or “having provis ions for foot-mounted”. “footless” just means that the motor does not have feet nor provisions fo r feet for mounting. Who cares what the actual method of mounting is?

As for your relating “footless” to EISA: EISA cr eates its own confusion as to what efficiency standard applies to “footless”. As pointed out at the public meeting on January 29, 2009 the way in which EISA was written, and was incorporated into the NOPR, created a problem with deleting

the definition of “electric motor” in EPCA from the definition in EPAct of 1992. Since the EISA definition of “general purpose electric motor (subtyp e I)” makes no distinction with respect to footmounted nor footless the inclusion of “footless” u nder the topic of “general purpose electric motor (subtype II)” is confusing. DOE is faced with the problem of being able to distinguish between “general purpose electric motors (subtype I)” an d “general purpose electric motors (subtype II)” when according to the EISA definition all “genera l purpose electric motors (subtype II)” appear to be “general purpose electric motors (subtype I)”.

There is only one logical conclusion as to what was actually intended in EISA based on the list of seven characteristics supposedly used to identify a motor as a “general purpose electric motor (subtype II)”. Each of the seven characteristics is a deviation from one of the characteristics that

defines an “electric motor” in EPCA as defined in EPAct of 1992 and expanded on in 10 CFR Part

431: (i) U-frame is not T-frame (ii) Design C is not Design A or B (iii) Definite purpose (per Appendix A to Subpart B) close-coupled pump motor is not a general
purpose motor (iv) Footless motor is not a foot-mounted motor (v) Special purpose (per Appendix A to Subpart B) ve rtical solid shaft normal thrust motor is not a general purpose motor (vi) 8-pole motor is not a 2, 4, nor 6 pole motor for which efficiency standards were specified in

EPAct of 1992 (vii) poly-phase motor with a voltage of not more than 600 volts (other than 230 or 460 volts) is

not rated at 230/460 voltsThe definition of “general purpose electric motor (subtype II)” obviously relies on the definition of

“electric motor“ from EPAct of 1992 to have any clear meaning.

It is only by considering that what the language of EISA should have stated was to retain the definition of “electric motor” from EPCA, add “gen eral purpose electric motor (subtype I)” as a type of electric motor containing all of the ty pes covered by the standards from EPAct of 1992 and delineated in Appendix A of Subpart B in 10 CFR Part 431, and add “general purpose electric motor (subtype II)” as new types of electric motors that fit the definition of “general purpose electric motor (subtype I)” except for 1 feature, such as footless or U-frame.

It remains unclear as to why DOE can not present a sound decision that the definition of “general purpose electric motor (subtype II)” must be built upon the definition of “electric motor” from

EPAct and that that definition of “electric motor” must then form the basis of the definition of “general purpose electric motor (subtype I)”.

The only hope to get the confusion cleared up appears to be for Congress to pass the proposed technical corrections to EISA. If that gets passed it will essentially make the portion of the NOPR discussed at the January 29, 2009 public meeti ng relative to “electric motors” obsolete.

Roger H. Daugherty, Ph.D Consulting Engineer Baldor Electric Company

6040 Ponders Court Greenville, SC 29615-4617

864.382.2728

864.382.2718 fax mailto:rhdaugherty@baldor.com http://www.baldor.com/

From: Raba, Jim [mailto:Jim.Raba@ee.doe.gov]

Sent: Monday, March 09, 2009 8:21 AM

To: Roger Daugherty at Baldor-Engineering Subject: C-face and D-flange mounting motors

Good morning Roger!

Question: Is a C-face mounting or D-flange mounting motor considered a "general purpose

motor"?

Otherwise, I note that section 313(a) of EISA 2007 includes "footless" motors, which I presume can be either C- or D- mounting.

Jim

James Raba Building Technologies Program Office of Energy Efficiency & Renewable Energy U.S. Department of Energy Telephone: (202) 586-8654