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 U.S. DEPARTMENT OF ENERGY

 + + + + +

 PUBLIC MEETING ON TEST PROCEDURES FOR

 SMALL ELECTRIC MOTORS AND ELECTRIC MOTORS

 + + + + +

 THURSDAY,

 JANUARY 29, 2009

 + + + + +

 The Meeting convened at 9:00 a.m.

in Room 1E-245 of the Forrestal Building of

the U.S. Department of Energy, 1000

Independence Avenue, S.W., Washington, D.C.,

James Raba, Facilitator.

PRESENT:

JAMES RABA, Facilitator, Department of Energy

RONALD LEWIS, Presiding Officer, Department of

 Energy

MICHAEL KIDO, Department of Energy 

MICHAEL McCABE, Department of Energy

BRENDA EDWARDS, Department of Energy

MARK FRIEDRICHS, Department of Energy

ROBERT VAN BUSKIRK, Lawrence Berkeley National

 Laboratory

ASA HOPKINS, Lawrence Berkeley National

 Laboratory

MICHAEL SCHOLAND, Navigant Consulting

MATTHEW NARDOTTI, Navigant Consulting

MAHIMA GUPTA, Navigant Consulting

EMMANUEL AGAMLOH, Advanced Energy

JOHN ANDRLE, Emerson Motor Company

JEFF BARTH, A.O. Smith Corporation

DALE BASSO, Weg Electric Corporation

ROB BOTELER, Emerson Motor Company

KITT BUTLER, Advanced Energy

BELINDA CARR, Energetics Inc.

ROGER DAUGHERTY, Baldor

EERE-2008-BT-TP-0008 COMMENT 08
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PRESENT: (CONT.)

DAIN M. HANSEN, National Electrical

 Manufacturers Association 

TOM HINK, Regal-Beloit Corporation

DOUG HOFMANN, General Electric

EDWIN A. HORNQUIST, Southern California Edison

WILLIAM HOYT, National Electrical

 Manufacturers Association

FRANK LADONNE, Lawrence Berkeley National

 Laboratory

GLORIA PUMPUNI, Air Conditioning, Heating &

 Refrigeration Institute

CHARLIE STEPHENS, Adjuvant Consulting

DAN TROMBLEY, American Council for an Energy-

 Efficient Economy

MOLLY TROMBLEY-McCANN, Energy-Solutions

EERE-2008-BT-TP-0008 COMMENT 08
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 A-G-E-N-D-A

Welcome, Introductions, Opening Statements. . .4

Ron Lewis, Presiding Officer, Supervisor,

Regulatory, Building Technologies Program

 Jim Raba, Facilitator

Small Electric Motors Test Procedure. . . . . 15

Electric Motor Test Procedure . . . . . . . . 88

Other Issues. . . . . . . . . . . . . . . . .160

Closing Remarks . . . . . . . . . . . . . . .181

Adjourn

EERE-2008-BT-TP-0008 COMMENT 08
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1 P-R-O-C-E-E-D-I-N-G-S

2 9:03 a.m.

3 FACILITATOR RABA: Everybody sign

4 in at the front table or the back table there. 

5 Your meeting materials today are on your

6 seats. Get comfortable, we have a good

7 turnout. Welcome to today's public meeting on

8 test procedures for motors. My name is Jim

9 Raba. I'll be your facilitator for today. 

10 We'll go over some items here on the agenda,

11 some housekeeping things, ground rules and the

12 like. But before I begin, I'd like to

13 introduce Ron Lewis, presiding officer of

14 today's meeting, to welcome you also.

15 MR. LEWIS: Good morning. 

16 FACILITATOR RABA: And when you

17 speak, we have some new microphones here. 

18 Notice the green light is dull. That's the

19 center of the ellipse. Press on, it brightens

20 up. Speak clearly into the microphone, state

21 your name and your organization please for the

22 record, the court reporter. When you're done,

EERE-2008-BT-TP-0008 COMMENT 08
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1 please turn off. It will alleviate any

2 shuffling of papers we might overhear. Thank

3 you very much for your patience, sir. Go

4 ahead.

5 MR. LEWIS: Good morning, again. 

6 That's a little bit better. Welcome

7 everybody. We really appreciate - the weather

8 has been kind of tough the last couple of days

9 with the icing and everybody making the trip

10 to be here. We appreciate it. We're looking

11 forward to a robust discussion today and

12 getting input from everybody. As many of you

13 may be aware, we have a very aggressive

14 program, and in fact we have six public

15 meetings in the next two weeks. And the

16 activity in this office is just incredible

17 right now, the number of rule-makings that

18 we're pumping out. So we appreciate the

19 input. That's very important to us to make

20 sure that we're on track, and especially all

21 of you in the process. So thanks again for

22 being here and we hope you'll express your

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1 viewpoints and give us helpful hints along the

2 way. So Jim will be facilitating and back to

3 you, Jim.

4 FACILITATOR RABA: Thank you very

5 much, Ron. As facilitator today I'll be

6 acting as an honest broker to encourage

7 discussion, all points of view, people being

8 heard and participating as much as possible to

9 get all different views on this table, to be

10 addressed. The Department of Energy can

11 address them later on so that they can see

12 your comments. And as such, again, I say that

13 as you speak, speak clearly into the

14 microphone, say your name, organization for

15 whom you're representing and so the court

16 reporter can pick that up. And as such, my

17 job really is to keep the meeting on track,

18 make sure your time is well spent and your

19 voice is heard as well. Again, I understand

20 there will be no decisions made today, but

21 rather we're gathering information about the

22 subject matter for today's meeting and I

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1 understand the Department will take it under

2 advisement, examine the comments for later on. 

3 So, at that point I would like to go around

4 the room and ask you to introduce yourself. 

5 Just say self, start here, say your name,

6 organization into the microphone clearly and

7 push the Start. 

8 MR. BARTH: I'm Jeff Barth and I

9 work for A.O. Smith Electrical Products. 

10 MR. DAUGHERTY: Roger Daugherty,

11 Baldor Electric Company.

12 MR. HINK: My name is Tom Hink,

13 chief electrical design engineer, Regal14 Beloit.

15 MR. BOTELER: Rob Boteler,

16 Emerson, St. Louis.

17 MR. ANDRLE: John Andrle, Emerson,

18 St. Louis.

19 MR. BASSO: Dale Basso, Weg

20 Electric.

21 MR. HOFMANN: Doug Hoffman,

22 General Electric.

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1 MR. HOYT: Bill Hoyt, NEMA.

2 MS. TROMBLEY-MCCANN: I'm Molly

3 Trombley-McCann with Energy Solutions on

4 behalf of PG&E.

5 MR. HORNQUIST: Edwin Hornquist,

6 Southern California Edison.

7 MR. STEPHENS: I'm Charlie

8 Stephens. I'm here representing the Northwest

9 Energy Efficiency Alliance.

10 MR. HANSEN: Dain Hansen with the

11 National Electrical Manufacturers Association.

12 MS. PUMPUNI: Gloria Pumpuni, Air

13 Conditioning, Heating & Refrigeration

14 Institute.

15 MR. TROMBLEY: I'm Dan Trombley

16 with the American Council for an Energy

17 Efficient Economy.

18 MR. LADONNE: Frank Ladonne,

19 Underwriters Laboratories.

20 MR. AGAMLOH: Emmanuel Agamloh,

21 Advanced Energy.

22 MR. BUTLER: Kitt Butler, Advanced

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1 Energy.

2 MR. KIDO: Michael Kido, DOE,

3 Office of the General Counsel.

4 MR. LEWIS: Ron Lewis, DOE.

5 FACILITATOR RABA: On the back

6 side, please.

7 MR. NARDOTTI: Matthew Nardotti,

8 Navigant Consulting.

9 MR. VAN BUSKIRK: Robert Van

10 Buskirk, Lawrence Berkeley National Lab.

11 MR. HOPKINS: Asa Hopkins,

12 Lawrence Berkeley National Lab.

13 FACILITATOR RABA: Also, if

14 anybody doesn't have a microphone and wish to

15 say other remarks or have an opening

16 statement, we ask for that at this time. But

17 there's a microphone in the back, stand-up

18 type if you have any short presentations, any

19 positions or points of view, maybe a short one

20 for the record, if you so desire at this time. 

21 Is there anybody? 

22 (No response.)

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1 FACILITATOR RABA: None seeing,

2 we'll continue on. The purpose of the meeting

3 today really is to go over the test procedure

4 for motors, that is, the small electric motors

5 rather than the medium or larger sizes, but

6 the ones that are integral horsepower motors

7 as well. Then also to look at definitions. 

8 And these were given by the Energy

9 Independence and Security Act of 2007. And

10 finally, I understand from what - I've been

11 talking to - that there are updates in the

12 standard that have to be taken into account. 

13 Old things being referenced now looking - the

14 public is looking at new things as well. So

15 those will be discussed today in our public

16 meeting. Okay.

17 Thereafter we will have a comment

18 period which will end up being more tonight,

19 and then following that written comments will

20 all come through transcript. Your

21 consideration in this because I understand

22 that the proposed rule meeting is today. Next

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1 there will be a final rule later on. They'll

2 be getting your comments on most data that's

3 very important and other information that will

4 move the process forward. Any questions so

5 far? 

6 I see some old faces, not

7 chronologically, but familiar, and some new

8 ones so welcome to everybody, friends and

9 otherwise. And some housekeeping things for

10 you. We'll kind of pace the meeting today and

11 we'll take an appropriate break sometime in

12 the morning about mid-morning maybe if it's

13 appropriate, and then lunch break, and then an

14 afternoon break if we go that far. Having

15 said that, also would ask that the breaks -

16 you can probably go downstairs. You don't

17 have to leave the building. Stairwells at

18 either end. The elevator bank right next door

19 here. You go downstairs below us, there's a

20 snack bar you can get coffee, doughnuts, you

21 know, pick-me-ups, things like that. Very

22 nice snack bar, a lot of food down there. And

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1 for lunch break around the noon hour there's

2 downstairs also serving lunch, but also

3 there's a large cafeteria. You go down to the

4 next level, the ground floor, that way, west,

5 long corridor, up the escalator which you kind

6 of run into with the rest of the herd going up

7 there, and around and there's a cafeteria as

8 well to eat for lunch. We'll take an

9 appropriate lunch break as we see. Having

10 said that, also those who may want to get up

11 in the middle of the meeting because they had

12 too much coffee, there's restrooms in that

13 direction at the far end on the left, in that

14 direction the far end on the right as well. 

15 Any questions so far about things like that?

16 MR. LEWIS: Jim?

17 FACILITATOR RABA: Yes, sir.

18 MR. LEWIS: Need to add in here,

19 if you leave the room, make sure you're

20 wearing the badge. As I came in this morning

21 they were stopping everybody and making them

22 go through the security that even people with

EERE-2008-BT-TP-0008 COMMENT 08
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1 badges that normally swipe through they were

2 stopping. So make sure you've got them on

3 there at all times, please. Thanks.

4 FACILITATOR RABA: They stop us at

5 random too, us being people who wear badges

6 otherwise. And I think, you know, there's

7 certainly a reason for it, a rationale, but we

8 appreciate your cooperation. Tomorrow when

9 you come, if you're here tomorrow for the

10 other meeting you'll still have to get a new

11 visitor's badge. These are good for one day

12 only. So just drop it off when you leave. 

13 You can - out the door too. 

14 So, as far as the role of

15 facilitator, some ground rules I might add

16 here that we want to put in place to show you. 

17 Yes, sir? Ground rules, we do have ground

18 rules. Yes, we're really - the Department you

19 understand is looking more for information,

20 data or comments to guide its direction toward

21 a rule-making for test procedures, and so we

22 ask you to listen as an ally. Listen as an

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1 ally. You know, positive, constructive, to

2 the point, succinct, and clearly so we can

3 capture it for the record, for everybody's

4 benefit. Short, succinct statements we

5 mentioned, clear. If there's a sidebar

6 conversation, if you want to confer with your

7 colleagues or just friends you haven't seen

8 for awhile, take it outside please so there's

9 no interruption. And for your cell phones, I

10 please ask you to set them on either vibrate

11 or stun or simply silent so as not to

12 interrupt the proceedings and someone who's

13 maybe speaking otherwise. One person speak at

14 a time, and I will recognize you - I recognize

15 you - to speak if you have to - you know, if

16 you want to raise your hand or acknowledge -

17 and there may be several at one time. I'll

18 try to queue you up in the order that I see

19 and be sure that everybody has a chance to

20 speak and be heard for the record. We've had

21 the housekeeping items. Any other opening

22 remarks that we might want to present at this

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1 time? 

2 None hearing, the agenda is pretty

3 straightforward. The Department has tried to

4 structure it so it goes in kind of a logical

5 flow. You'll see that as we proceed with the

6 meeting as well. And that's pretty much all

7 I have for today. Any questions so far of

8 what we've talked about, or will talk about? 

9 Or you will talk about, not me. Okay. I'd

10 like to turn it over to our presenter, our

11 first presenter, Michael Scholand who has been

12 working very hard, doing yeoman's work as with

13 our team, the Department's team over here on

14 these test procedures and other things too. 

15 So Mike, turn it over to you.

16 MR. SCHOLAND: Thank you, Jim. 

17 Are you picking me up okay? Okay, great. My

18 name is Mike Scholand from Navigant Consulting

19 and we are supporting the Department in its

20 work on this test procedure for small electric

21 motors and the update to the electric motors

22 test procedure. I've just held it on the

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1 meeting agenda slide here for a second. Jim

2 did kind of highlight this, but the plan for

3 today, we're kind of starting now in the 9:30

4 slot reviewing the small motors test

5 procedure. We'll have a break after that,

6 about 15 minutes, and then move into electric

7 motors. This structure is based on how the

8 Notice appears in the NOPR itself. The first

9 part of the preamble discusses small electric

10 motors, and then the updates and additions to

11 the electric motors test procedure. So that's

12 our flow for today on the slides.

13 And Jim highlighted this already,

14 but as you know we are at the Notice of

15 Proposed Rulemaking (NOPR) stage for electric

16 motors. The NOPR was actually published in

17 the Federal Register on December 22 last year. 

18 Today is our public meeting and comments, the

19 docket is open for comments through March 9. 

20 So there's still, what is that, about 6-7

21 weeks to go. Today's transcript, this meeting

22 is being recorded and it will be translated or

EERE-2008-BT-TP-0008 COMMENT 08
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1 written down into a transcript. That will be

2 entered into the docket and become part of the

3 official record of this proceeding. So any

4 comments you make today, that's why it's

5 important that you identify your name when you

6 speak. And DOE obviously is also accepting

7 written comments and we have a slide at the

8 end of the stack today that shows you how to

9 submit comments. It's also in the Federal

10 Register notice itself. 

11 The final rule is scheduled for

12 June 30, 2009. As Ron said, there's a ton of

13 work being done by his office right now, but

14 we do intend to make that deadline, so that's

15 the expectation, to have this test procedure

16 final by then. 

17 One of the things which we have in

18 the notice about seven comments, or issues

19 rather, that the Department is explicitly

20 soliciting comments on. All aspects of the

21 Department's proposal are open for comment,

22 but these are seven particular areas that DOE

EERE-2008-BT-TP-0008 COMMENT 08
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1 wanted to make sure stakeholders did address

2 and consider. So they're kind of given, you

3 know, highlighted in Section IV.E of the NOPR. 

4 As we go through the slides today I've put

5 those seven issues for comment in comment

6 boxes and we will actually stop the slides and

7 open the floor for discussion as they come up. 

8 So we'll try and get as much feedback from you

9 as possible. This is an example of the issue

10 box so you see what it'll look like when we

11 get to those in the slides. Okay.

12 So this test procedure as we were

13 saying is actually two test procedures bundled

14 together. There's the small electric motors

15 which is an entirely new proposed test

16 procedure for measuring performance of small

17 electric motors, both single-phase and

18 polyphase. And then it is updating the

19 existing test procedure that's in the Code of

20 Federal Regulations for electric motors, the

21 1 to 200 horsepower, and it's extending it to

22 clarify that it will also apply to 201 to 500

EERE-2008-BT-TP-0008 COMMENT 08
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1 horsepower, fire pump motors and the other

2 motors that were added by the Energy

3 Independence and Security Act of 2007. 

4 So I'm going to start with small

5 motors. Now, as you're probably aware, it was

6 the Energy Policy Act of 1992 that directed

7 the Department to consider energy conservation

8 standards for small electric motors. DOE

9 completed that analysis and published a

10 positive determination on July 10, 2006, and

11 at that time initiated two rulemakings. One

12 is the test procedure which we're discussing

13 today and then the other is an energy

14 conservation standards rulemaking which is

15 considering potential efficiency standards for

16 electric motors. Those are two separate

17 rulemakings. Today's is about the test

18 procedure. Tomorrow's public meeting is about

19 the energy conservation standard. So they're

20 running in parallel. Anyone have a question?

21 MR. DAUGHERTY: Roger Daugherty. 

22 You're indicating that you're going to include

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1 in the rules and regulations the test

2 procedure for small motors. In the present

3 rules and regulations, it not only contains

4 the test procedures for many motors, but it

5 also contains the standards. Why are you not

6 including the standards in the rules and

7 regulations with the test standards for the

8 small?

9 MR. SCHOLAND: I can take a stab

10 at responding. The reason for that is it's a

11 separate rulemaking - for the Department to

12 establish a mandatory minimum efficiency level

13 standard for any product it has to go through

14 a series of analyses, including a market and

15 technology assessment, an engineering

16 analysis, a lifecycle cost assessment,

17 national impacts, manufacturer's impact

18 analysis. There's actually 14 analyses and

19 two reports that have to be completed for the

20 Department to demonstrate that it has analyzed

21 all possible appropriate efficiency

22 requirements for a product under seven factors

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1 that are listed in EPCA, and then the

2 Department says okay, here's a level. They

3 propose that level and get comment on it, and

4 then hopefully go to a final and say okay,

5 here's the level we want. So it's a much more

6 involved rulemaking than a test procedure,

7 generally. Test procedures, DOE typically

8 looks to what is used by industry. Is it

9 repeatable, is it accurate, is it subject to,

10 you know, circumvention in some way, and so

11 the test procedure rulemaking like today's

12 we're proposing to incorporate by reference,

13 IEEE test methods. A lot more

14 straightforward. You don't have to justify it

15 as much. You have to show that it's

16 reasonable and repeatable and accurate, and

17 DOE believes that. But the standards rule is

18 more analysis.

19 FACILITATOR RABA: We have a

20 comment from Ron Lewis, Department of Energy,

21 and the previous speaker was Roger Daugherty

22 of Baldor. Go ahead, sir.

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1 MR. LEWIS: The test procedure is

2 simply a mechanisms and means for you to

3 establish that you're in compliance. So the

4 standard is a separate entity that says this

5 is the minimum efficiency that you need to hit

6 in your manufacturing. You're not allowed to

7 make anything less efficient. A test

8 procedure is a procedure that you use to then

9 submit and verify that you're in compliance

10 with the product. So they're two separate

11 activities, they're closely connected, but

12 they're two separate publications in the

13 Federal Register, they're two separate

14 activities. Is that helpful?

15 MR. DAUGHERTY: But within the

16 NOPR it has the section in it for the

17 standards. Does that mean that at a later

18 date you're going to be inserting those into

19 the same rules and regulations?

20 MR. LEWIS: Well, there are two

21 separate standards that are applicable. One

22 was legislated in EISA for the medium - I

EERE-2008-BT-TP-0008 COMMENT 08
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1 think they call them medium-sized motors. 

2 There is a standards rulemaking underway on

3 the small electric motors and the test

4 procedures covering both of those. Am I

5 correct, team?

6 MR. SCHOLAND: Yes, and Mike

7 Scholand here. Just to add to that, Ron. We

8 do create a heading, we'll call it Energy

9 Conservation Standards, for small electric

10 motors, and it just has the word "Reserved." 

11 And DOE may come to a conclusion that their

12 standard level is appropriate and then it will

13 just stay there reserved until at some point

14 DOE comes back, revisits and changes its mind. 

15 But nothing will go in that Reserved until DOE

16 completes that rulemaking and makes a decision

17 whether to establish standards or not. So the

18 test procedure is simply creating a number, a

19 box, and reserving a section so that that

20 number doesn't get used somewhere else. Does

21 that help?

22 MR. DAUGHERTY: Roger Daugherty. 

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1 Then could you please clarify why the

2 Department may be creating test standards if

3 there's a chance that they may make a

4 determination that there are no efficiency

5 standards that would apply? And therefore,

6 what's the purpose of DOE creating the test

7 standards?

8 MR. SCHOLAND: Michael McCabe?

9 MR. MCCABE: I'm Michael McCabe,

10 I'm staff here with the Department of Energy. 

11 The procedures which are being laid out are

12 fairly well established in the legislation. 

13 The legislation requires that in order for us

14 to consider standards, energy conservation

15 standards for a product we must first

16 establish the metric for measuring the

17 efficiency of the product. Once that metric

18 is established, we are then required to use

19 that metric in our evaluation of the energy

20 efficiency savings potential, the economic

21 impact and the other impacts of standards. So

22 in order to conduct a standards rulemaking, we

EERE-2008-BT-TP-0008 COMMENT 08
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1 need to have the metric. We need to

2 understand - you need, interested parties need

3 to understand how the motors or other products

4 are getting measured for their performance. 

5 So the test procedure is the first step in the

6 process. Those regulations like all of our

7 regulations are published in the Code of

8 Federal Regulations. The structure of the CFR

9 is laid out and one would see that the test

10 procedures, for each product there's a section

11 for test procedures, separate section for

12 standards. We've - once we adopt the test

13 procedures we are then in the position to

14 complete the engineering and economic analysis

15 for the standards, and then make the

16 determination whether or not standards are

17 technically feasible and economically

18 justified.

19 MR. SCHOLAND: Does that answer

20 your question?

21 MR. DAUGHERTY: Roger Daugherty. 

22 I hate to keep making this point, but back in

EERE-2008-BT-TP-0008 COMMENT 08
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1 EPAct, the statement in EPAct published in

2 1992 was that the Department is to prescribe

3 testing requirements for those small electric

4 motors for which the Secretary makes a

5 determination that energy conservation

6 standards would be technically feasible and

7 economically justified and result in

8 significant savings. I guess my

9 interpretation of that was that once you've

10 established what the standards were, then you

11 needed to publish the test by which they would

12 be done. It seems now you're publishing a

13 test requirement without having established

14 any standards. That's the reverse of what it

15 says in EPAct.

16 MR. SCHOLAND: Okay. Mike

17 Scholand. I can clarify that as what I'm

18 trying to say on this slide. The Secretary

19 published a positive determination on July 10,

20 2006, that he believes that energy

21 conservation standards are technologically

22 feasible, economically justified and would

EERE-2008-BT-TP-0008 COMMENT 08
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1 result in significant energy savings for small

2 electric motors. That's what triggered DOE

3 initiating these two rulemakings in parallel:

4 the test procedure which gives us the metric

5 to measure the efficiency, and the energy

6 conservation standards rule which says here's

7 the level, if any level is appropriate.

8 FACILITATOR RABA: Ron Lewis.

9 MR. LEWIS: I might suggest if you

10 take a look at our website at the page for

11 electric motors, and you'll see the history

12 and the evolution and all the pertinent

13 documents there that show how we got to where

14 we are, and this is all the process that we're

15 required to go through and we've met all the

16 steps. So I think we need to move along here,

17 but I think you need to take a look at that

18 page and it'll fill you in with any blanks,

19 things that you may not be aware of.

20 FACILITATOR RABA: Does that help

21 your question, your concern? Well, thank you

22 very much. It's a good comment. It probably

EERE-2008-BT-TP-0008 COMMENT 08
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1 clarifies for many people that thought. Let's

2 move on now. Michael, go ahead.

3 MR. SCHOLAND: Thanks, Jim. So

4 what specifically are small electric motors? 

5 We are given a definition in the statute. A

6 small electric motor is a NEMA general purpose

7 alternating-current single-speed induction

8 motor built in the two-digit frame number

9 series in accordance with NEMA Standards

10 Publication MG1-1987, and we have the U.S.

11 Code citation there for that definition. 

12 That's what a small electric motor is in DOE's

13 mind, and that's what is being subject to the

14 test procedures we're discussing today. How

15 DOE is interpreting all those terms we are

16 actually going to address tomorrow in the

17 energy conservation standards rule. So I just

18 wanted to make that point today. And another

19 sort of important point is that DOE only

20 evaluates small electric motors incorporated

21 into products that are not regulated by other

22 federal standards. So for example, air

EERE-2008-BT-TP-0008 COMMENT 08
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1 conditioners or refrigerators, small motors

2 used in those products are not subject to the

3 efficiency regulations that would be passed

4 under a small electric motor rulemaking

5 because they are incorporated into a system,

6 a product that is otherwise already regulated

7 federally. So it's an important detail for

8 small motors. 

9 Okay. Let's take a step back to

10 get an overview of what's being proposed for

11 small electric motors. There are three

12 industry test procedures that are being

13 proposed to incorporate by reference: IEEE

14 114-2001 which is for single-phase, IEEE 112-

15 2004 for the polyphase, and then the CSA C747-

16 1994 which was reaffirmed in 2005 which is a

17 test method for both single- and they use the

18 term three-phase small motors. So DOE is

19 proposing to allow manufacturers to test

20 single-phase using either 114 or the C747, and

21 for polyphase the 112 or the 747. Basically

22 manufacturers would have a choice which

EERE-2008-BT-TP-0008 COMMENT 08
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1 procedure to follow. And I just mention here

2 that DOE is proposing to create this test

3 method in Subpart T of Part 431 of the Code of

4 Federal Regulations. Okay?

5 Just reviewing DOE's proposal to

6 allow manufacturer's a choice. This is

7 actually what the Department does right now

8 for 1-200 horsepower electric motors. There's

9 a choice of testing using either 112 or the

10 CSA C390. And so DOE thought it would be

11 appropriate to have a similar option for small

12 electric motors. So this little matrix shows

13 you that if you are a single-phase, you're one

14 of the top two rows, capacitor-start

15 induction-run, or capacitor-start capacitor16 run, that motor may be tested using either 114

17 or 747. And then the polyphase could be

18 tested using either 112 or 747. Okay? 

19 FACILITATOR RABA: Roger

20 Daugherty.

21 MR. SCHOLAND: Okay, go ahead.

22 MR. DAUGHERTY: Roger Daugherty. 

EERE-2008-BT-TP-0008 COMMENT 08
Page 31

1 IEEE Standard 114 and the CSA standard contain

2 a single test method. IEEE 112 contains about

3 eight different test methods. Is the

4 Department of Energy going to restrict the

5 testing to a particular method in 112, or just

6 leave 112 open to using any test method that's

7 in there?

8 MR. SCHOLAND: That's a good

9 question. I would imagine that (B) is the one

10 that's used for - so, Ron?

11 MR. LEWIS: I think we need to

12 take a look at that, but for today we're

13 looking for input based on the premises that

14 we've got at this point, but as far as making

15 declarative statements of, you know, what's

16 our final outcome from this. Today it's to

17 have the dialogue that ought to be considered. 

18 So I think we need to go back and take a look

19 at it before somebody makes a definitive

20 statement and says we're limiting something to

21 one thing or another. But that input, that

22 dialogue is important so we thank you for

EERE-2008-BT-TP-0008 COMMENT 08
Page 32

1 that.

2 MR. SCHOLAND: Maybe Roger you

3 want to make a recommendation?

4 MR. DAUGHERTY: Yes. Roger

5 Daugherty. Because I did hear a comment that

6 maybe you'd just recommend (B), but in the

7 standard itself it recommends method (A) for

8 at least fractional horsepower motors. It

9 recommends that you use method (B) for those

10 motors rated from 1 to - one time it's 400,

11 another time I think it's 300-kilowatt. IEEE

12 standard insists on kilowatts instead of

13 horsepower unit, but about equivalent to 500

14 horsepower. So, within this polyphase small

15 motors, it would appear that you would need to

16 adopt both method (A) and method (B), and then

17 method (A) is similar to that which is in 114

18 testing the single-phase motors. So it would

19 be almost equivalent test methods applied to

20 polyphase as single-phase for fractional

21 horsepower.

22 FACILITATOR RABA: Good comment

EERE-2008-BT-TP-0008 COMMENT 08
Page 33

1 and certainly we'd like to - I think the

2 Department would want to get that in a written

3 statement or otherwise follow-up comments from

4 the interested parties. Yes, sir, your name

5 and your affiliation.

6 MR. AGAMLOH: Emmanuel Agamloh,

7 Advanced Energy. I tend to agree with Roger

8 on the method. I found some significant

9 differences between the method (B) which is a

10 loss segregation method and then input-output

11 method which is the method (A) which just

12 calculates the efficiency based on the output,

13 measured output power and then the measured

14 input power. CSA 747 and IEEE 114 are almost

15 identical in terms of the way they calculate

16 the efficiency. So for polyphase, the

17 polyphase part of the regulations or the

18 procedures, if you adopt method (B) side by

19 side the CSA 747, based on what, the data that

20 I have, there might be some differences. 

21 Moreover, method (A) is applicable to 1

22 kilowatt and less, so that will be probably

EERE-2008-BT-TP-0008 COMMENT 08
Page 34

1 the appropriate method in 112 to be adopted

2 for polyphase.

3 FACILITATOR RABA: Well, thank you

4 very much. Any further comments on the

5 methodology for testing the small motors? And

6 again, I'm sure you'd be invited to submit

7 written comments on your views, please. That

8 helps the Department a lot in gathering

9 information and data which I understand it's

10 seeking for this rulemaking. No decisions

11 now, but input's very important like both

12 speakers this morning. Any other comments on

13 testing? We have one here.

14 MR. KIDO: Michael Kido, DOE. I

15 just wanted to sort of follow up with that,

16 just to emphasize when you do submit written

17 comments, please make sure that you explain

18 why it is that you view a particular approach

19 as being more desirable than others. That

20 would be extremely helpful to the Department

21 in promulgating this final rule.

22 FACILITATOR RABA: Did everybody

EERE-2008-BT-TP-0008 COMMENT 08
Page 35

1 hear that? Get that? Okay, good. Michael?

2 MR. SCHOLAND: So why has DOE

3 selected the industry standards to incorporate

4 by reference today? The IEEE test methods

5 were chosen for three reasons. They are the

6 most current versions in use by industry today

7 and reflect best approaches for measuring the

8 efficiency of small electric motors. The

9 Department feels that they give accurate and

10 repeatable measurements and that they are

11 consistent with test methods that DOE has

12 today for the 1 to 200 horsepower electric

13 motors in the CFR. DOE is proposing to allow

14 the CSA standard C747 as an alternate because

15 it also finds that this test method is

16 accurate and consistent in measuring the

17 energy efficiency of small electric motors. 

18 It's consistent with the objectives of the

19 North American Free Trade Agreement and also

20 consistent with how DOE allows 1 to 200

21 horsepower electric motors to be tested today. 

22 Okay. I'll take - this is the

EERE-2008-BT-TP-0008 COMMENT 08
Page 36

1 first of our issue boxes and we have discussed

2 these a little bit, but let's take a minute to

3 look at these two key issues for discussion. 

4 The first one DOE invites comment on is

5 proposed test procedure for small electric

6 motors based on IEEE Standard 114-2001 and

7 IEEE 112-2004. This is discussed in detail in

8 Section III A of the Notice of Proposed

9 Rulemaking and - we have had some good input

10 this morning that it should be test method

11 (A). And is there anything else anybody wants

12 to say about either of these test methods of

13 IEEE? 

14 Key issue number two. DOE is

15 inviting comment on its proposal to allow a

16 manufacturer to choose as an alternate the CSA

17 C747-94 instead of the IEEE standards. DOE

18 may reserve the option of promulgating that

19 standard. It may or may not allow that

20 flexibility in the final rule, so it would be

21 good if stakeholders could comment that this

22 is a good thing and why, or why not, why

EERE-2008-BT-TP-0008 COMMENT 08
Page 37

1 should it only be the IEEE standards and not

2 the CSA standard. Does anybody have any

3 comments on this option that DOE is offering?

4 MR. BOTELER: Rob Boteler with

5 Emerson. My only comment I think is we would

6 prefer to see that we do have both, really

7 both in the regulation because we also as

8 global manufacturers will be building product

9 for all of North America and at some point

10 will be likely that the Canadians will be part

11 of the party too, so it would make sense to

12 remain and leave that flexibility. 

13 MR. SCHOLAND: Any other comments? 

14 MR. AGAMLOH: Emmanuel Agamloh,

15 Advanced Energy. That alternative is good

16 only if we adopt method (A) and not method

17 (B).

18 FACILITATOR RABA: And you'll

19 submit in your written comments, also.

20 MR. AGAMLOH: Yes, I will submit a

21 written comment and supporting data.

22 FACILITATOR RABA: - for

EERE-2008-BT-TP-0008 COMMENT 08
Page 38

1 consideration of course. Thank you. Any

2 others? Any other views? Move on.

3 MR. SCHOLAND: Okay. Now let's

4 take a look at a few terms that DOE is

5 proposing to define in Subpart T for the test

6 procedure. The terms are "alternative

7 efficiency determination method," AEDM for

8 short, "average full load efficiency," the

9 term "basic model," and the term, "small

10 electric motor," which we discussed earlier. 

11 So we'll just walk through. I've got one

12 slide on each of these. So what is an AEDM,

13 an alternative efficiency determination

14 method? It's essentially a mathematical model

15 enabling manufacturers to calculate total loss

16 and average efficiency of a particular basic

17 model without conducting testing. The AEDM is

18 an optional alternative to alleviate testing

19 burden, but it must be substantiated through

20 actual testing of a number of basic models. 

21 So essentially a manufacturer may have this

22 mathematical model that can predict the

EERE-2008-BT-TP-0008 COMMENT 08
Page 39

1 efficiency of its products that are sold. It

2 has to demonstrate compliance, or the ability

3 of that software to have an accurate

4 prediction by testing real units made and

5 predicted by the software. Once that's

6 substantiated then the Department would accept

7 output from the software that indicates what

8 the efficiency levels are of new basic models

9 made with that software. So that's how the

10 AEDM is meant to work. DOE currently allows

11 the use of an AEDM on two products that are

12 covered and regulated federally, the 1-200

13 horsepower electric motors and distribution

14 transformers are the two places that the AEDM

15 exists today. And the AEDM definition

16 proposed which is - talking about definitions

17 here - is identical to what's in there for

18 electric motors. The only difference is DOE

19 inserts the word "small" in front of "electric

20 motor" to make it clear that, you know, it

21 applies to this product. So an AEDM means

22 with respect to a small electric motor a

EERE-2008-BT-TP-0008 COMMENT 08
Page 40

1 method of calculating the total power loss and

2 average full load efficiency. Do you have any

3 questions or comments on AEDM? I do visit

4 this issue again later in the slides. 

5 Okay. And what about the term

6 "average full load efficiency?" Again, it's

7 a very minor modification to the existing

8 definition for average full load efficiency

9 that's in the Code of Federal Regulations now

10 for 1 to 200 horsepower. DOE inserts the word

11 "small" in front of "electric motor" so it

12 reads, "Average full load efficiency means the

13 arithmetic mean of the full load efficiencies

14 of a population of small electric motors of

15 duplicate design where the full load

16 efficiency of each motor in the population is

17 the ratio, expressed as a percentage, of the

18 motor's useful power output to its total power

19 output when the motor is operated at its full

20 rate load, rated voltage and rated frequency." 

21 That's DOE's proposal for that term. Any

22 questions or comments? Everyone's okay? All

EERE-2008-BT-TP-0008 COMMENT 08
Page 41

1 right. And what about the term basic model?

2 MR. HORNQUIST: I have a question.

3 MR. SCHOLAND: Okay. Your name

4 and organization.

5 MR. HORNQUIST: Edwin Hornquist,

6 Southern California Edison. Just a question

7 about the previous slide.

8 MR. SCHOLAND: Which one, this

9 one?

10 MR. HORNQUIST: Yes, right. 

11 MR. SCHOLAND: AEDM.

12 MR. HORNQUIST: I was just

13 wondering what "basic models" mean?

14 MR. SCHOLAND: Oh, that's the term

15 I'm about to define in my next slide.

16 MR. HORNQUIST: All right.

17 MR. SCHOLAND: Sorry.

18 MR. HORNQUIST: Good, thank you.

19 MR. SCHOLAND: Slide 19 for the

20 definition of "basic model." There is

21 actually a minor typographical error on this

22 slide which I discovered as I was preparing my

EERE-2008-BT-TP-0008 COMMENT 08
Page 42

1 notes. The heading says that the definition

2 for "basic model" is identical to that under

3 10 CFR 431.12 except the term "small" is

4 inserted with "electric motor." But actually

5 it's a slightly modified version because DOE

6 is in this rulemaking proposing to modify the

7 definition of "basic model" for 1 to 200

8 horsepower electric motors as well. So DOE's

9 proposal for basic model for the 1 to 200

10 horsepower is what's been adapted and proposed

11 here for small electric motors. And in

12 essence it's a minor change. The existing

13 definition makes reference to 113 combinations

14 of horsepower ratings, number of poles, types

15 of construction, but of course with the

16 passage of the Energy Independence and

17 Security Act of `07 there's many more

18 combinations than 113. So DOE is proposing to

19 remove that number and simply say a

20 combination of these factors. So that

21 definition that's being proposed in the NOPR

22 for the medium motors has been adapted here

EERE-2008-BT-TP-0008 COMMENT 08
Page 43

1 and proposed for small motors. So a little

2 issue with my heading there. But in essence

3 a basic model is a blueprint design. It's one

4 design that's made en masse and if you change

5 any aspect of that design, if you add more

6 core steel or more windings, make any changes

7 that affect the efficiency, it's a new basic

8 model. And so any changes to design that

9 affect the metric that is being regulated such

10 as design changes, material changes, et

11 cetera, make that a new basic model. That

12 basic model would then either have to be

13 tested or certified under an AEDM.

14 MR. HORNQUIST: Edwin Hornquist

15 again. So the basic model change would be -

16 that would determine a new model would be

17 something like a horsepower change?

18 MR. SCHOLAND: Oh, absolutely.

19 MR. HORNQUIST: For sure.

20 MR. SCHOLAND: Absolutely.

21 MR. HORNQUIST: Because you said

22 efficiency, and I was just thinking if it

EERE-2008-BT-TP-0008 COMMENT 08
Page 44

1 changes the efficiency. Any of these

2 windings, horsepower, et cetera would trigger

3 a new testing.

4 MR. SCHOLAND: Correct.

5 MR. HORNQUIST: Okay.

6 MR. SCHOLAND: DOE is proposing,

7 and tomorrow's workshop will be discussing a

8 matrix that will have number of poles across

9 the top and horsepower ratings down the left10 hand side. And then there will be, you know,

11 basically a series in that matrix of

12 combinations of poles and horsepower ratings

13 for the capacitor-start induction-run,

14 capacitor-start capacitor-run and polyphase. 

15 So three separate tables, and then within each

16 of those there will be an efficiency rating

17 that must be complied with. Now, each of

18 those boxes is not just a basic model. You

19 could have many different basic models that

20 are 1-horsepower 4-pole CSIR motors, right? 

21 You could have thousands of basic models

22 within that one box. So any time you make a

EERE-2008-BT-TP-0008 COMMENT 08
Page 45

1 one horsepower four pole CSIR motor, that's

2 one basic model. Now you make a design change

3 to that motor because copper gets more

4 expensive, so you change your design. That's

5 a new basic model because that affects the

6 efficiency. Then you add more stack because

7 your client wants higher efficiency. That's

8 a new basic model. So, and they're all one

9 horsepower, four pole. So does that help?

10 MR. HORNQUIST: So the question

11 was - Edwin Hornquist - in the context of the

12 alternative efficiency determination method?

13 MR. SCHOLAND: Yes.

14 MR. HORNQUIST: That that would

15 apply as well.

16 MR. SCHOLAND: Correct, and that's

17 why the Department is proposing an AEDM

18 approach because any given manufacturer could

19 have tens of thousands of basic models and

20 then the compliance costs on a time basis and

21 a cost basis become prohibitive. So, okay.

22 FACILITATOR RABA: I saw a hand

EERE-2008-BT-TP-0008 COMMENT 08
Page 46

1 over here. Roger?

2 MR. DAUGHERTY: Roger Daugherty,

3 Baldor Electric. I have two questions, deal

4 with the first one. That has to do with

5 you're saying that if I make any design change

6 using the term that affects efficiency,

7 however it's possible for me to make design

8 changes, as you say, maybe trade copper for

9 iron or whatever, but still arrive at the same

10 nominal efficiency. And so as far as the

11 motor is concerned it has the same efficiency. 

12 It may look different, it may have different

13 components and materials and in different

14 proportion, but it's still the same

15 efficiency. Are you saying that those are

16 really two different basic models even though

17 they have the same efficiency?

18 MR. SCHOLAND: Yes, those would be

19 two different basic models. As I understand

20 the term. Do you want to add to that?

21 FACILITATOR RABA: I think I

22 understand too that if it affects efficiency.

EERE-2008-BT-TP-0008 COMMENT 08
Page 47

1 MR. SCHOLAND: Even if the

2 efficiency arrives at the same numerical value

3 it's still a different basic model because

4 you're trading off different aspects.

5 MR. DAUGHERTY: Roger Daugherty

6 again. But how is anyone going to tell? I

7 mean, the motor has a nameplate on it, it has

8 an efficiency value. The item has to be

9 stated in this definition of basic model is

10 just an efficiency value, so why would there

11 be a different basic model? I mean, suppose

12 a year goes by and yes, I decide to do

13 improvements to my motor to my benefit, but I

14 maintain the same efficiency. Why would that

15 be a different basic model? I'm not aware

16 that that's been true under medium motors, so

17 why would we apply it under small motors?

18 MR. SCHOLAND: All I can suggest

19 is that you make a comment to the Department

20 along the lines that you believe they

21 shouldn't be different basic models if they

22 have the same efficiency value. My

EERE-2008-BT-TP-0008 COMMENT 08
Page 48

1 understanding is that they would be because

2 they are different blueprint designs. You

3 could, for example, completely change the core

4 steel in the stack - have a better grade of

5 core steel but not as much stack and still

6 arrive at the same efficiency. You may have

7 a different torque curve, you may have, you

8 know, different locked-rotor currents, we have

9 other aspects of that. They are different

10 blueprint designs and my understanding is the

11 Department has traditionally interpreted -

12 FACILITATOR RABA: Michael?

13 MR. LEWIS: A comment from our

14 general counsel.

15 MR. KIDO: Right, just briefly. 

16 We can take another look at this. I'm taking

17 a look at the definition right now and if

18 you're talking about a, say, materials change

19 that doesn't have any effect on the energy

20 consumption or efficiency of that particular

21 item, according to our proposed definition

22 that, I would think, and I'd have to go back

EERE-2008-BT-TP-0008 COMMENT 08
Page 49

1 and double-check, but I would think that that

2 would not necessarily create a separate basic

3 model. So if your energy efficiency rating is

4 still going to be the same and your only

5 difference is, say, moving from one type of

6 material to another, it should still be within

7 the same basic model class. I'll double-check

8 that.

9 MR. BASSO: This is Dale Basso,

10 Weg. The question: in current EPAct we have

11 to report to the DOE and put on file a list of

12 our basic models. I guess depending on how

13 this is interpreted that list could get

14 unmanageable. I think we need to keep that in

15 mind as we go forward with this.

16 FACILITATOR RABA: Thank you very

17 much. In the back there, please?

18 MS. TROMBLEY-MCCANN: This is

19 Molly Trombley-McCann from PG&E. It sounds,

20 just in my reading it sounds to me like you're

21 saying that any change that has the potential

22 to affect the energy efficiency of the motor

EERE-2008-BT-TP-0008 COMMENT 08
Page 50

1 would constitute a different basic model. Is

2 that a correct interpretation, or am I missing

3 something?

4 MR. KIDO: Michael Kido, DOE. 

5 Essentially, according to what we've got here

6 in our proposed definition I would imagine

7 that you'd have to have some sort of basis for

8 saying that there is some sort of change in

9 efficiency. So when you mean potential, I

10 assume that you're meaning that it's somehow

11 been measured, or it hasn't been measured? 

12 You just have some sort of theoretical inkling

13 that there's going to be a change?

14 MS. TROMBLEY-MCCANN: I guess my

15 question would be if you make change and

16 you're saying that it doesn't affect the

17 efficiency, but you're not testing it because

18 you're claiming it's the same basic model, how

19 do you know that it's still the same

20 efficiency?

21 MR. KIDO: Right. It would seem

22 to me then that you'd have to somehow

EERE-2008-BT-TP-0008 COMMENT 08
Page 51

1 establish the fact that the efficiency is

2 still going to be the same. I imagine that

3 would be something the manufacturer would

4 normally do. Maybe that's something that

5 manufacturers over here can respond to.

6 MR. BOTELER: This is Rob Boteler

7 with Emerson. Yes, the way we would do that

8 is by use of the AEDM that we've been talking

9 about. And we make changes every day. Our

10 design engineers achieve the efficiency levels

11 and one manufacturer uses more copper and less

12 steel, and another manufacturer uses less

13 copper and more steel. We change the air gap. 

14 We do all sorts of things to the designs. 

15 Within our own design work within a given

16 company we make changes to meet the other

17 parameters that customers need. I mean, we're

18 here talking about efficiency, but when we

19 sell you a motor in the community that uses

20 motors we're looking at the torque

21 requirements, we're looking at power factor,

22 we're looking at inertia, we're looking at

EERE-2008-BT-TP-0008 COMMENT 08
Page 52

1 probably 15 or 20 different facets that if we

2 don't achieve you won't have a product that

3 accomplishes what we need to accomplish. So

4 we make changes within the design of the motor

5 to meet those requirements for the

6 marketplace, but when we do that we maintain

7 the efficiency level and we are able to do

8 that by using our calculation programs which

9 are based on correlation coming from our

10 actual test methods to make sure that we

11 maintain the efficiency levels that we've

12 agreed to. Our understanding is that the

13 basic model will follow the same or similar

14 definition that we have on the integral side

15 and that we'll end up with something, actually

16 probably less than the 113 basic models that

17 we deal with today. 

18 FACILITATOR RABA: Comments? Over

19 here, please.

20 MR. LADONNE: Frank Ladonne,

21 Underwriters Laboratories. I would read that,

22 you know, with my colleague from Emerson, and

EERE-2008-BT-TP-0008 COMMENT 08
Page 53

1 certainly this is probably true of all the

2 manufacturers represented here, that when

3 changes are made to motors they're not made in

4 a haphazard fashion. There's calculation and

5 there's, you know, evaluation technology that

6 goes into it and so on, but I don't know that

7 that's universally true in the industry. As

8 a matter of fact, I know it's not. I know

9 that there are manufacturers, small motor

10 manufacturers who will change motors in an

11 effort to take cost out of the motor without

12 due regard for performance or efficiency. So

13 I think that the Department has a challenge

14 here to define, you know, what sort of a

15 change, or what sort of a change is allowed,

16 what sort of a change is not allowed, and you

17 know, how the manufacturer needs to

18 substantiate that the change is in fact not

19 going to affect the efficiency of the basic

20 model.

21 FACILITATOR RABA: DOE, Ron Lewis.

22 MR. LEWIS: The principle of using

EERE-2008-BT-TP-0008 COMMENT 08
Page 54

1 the AEDM is to try and relieve some of the

2 load that you're using software to use the

3 confirmed tested data to try to save the

4 burden of having to test every single product. 

5 However, there are some things like changing

6 from copper that potentially could have a huge

7 impact on efficiency. So looking at the -

8 being able to substantiate the nameplate,

9 being able to have the confidence factor that

10 the nameplate represents the actual efficiency

11 to the comment just made is - we'll take all

12 this into consideration. We want all the

13 input to know, you know, what the factors are. 

14 However, we have to have some kind of

15 confidence factor that somebody doesn't have

16 a basic model and make changes for economic

17 reasons or whatever that impacts the

18 efficiency but think that just because you're

19 using an AEDM that you can just make that

20 change without the responsibility of

21 accounting for the efficiency. So in our rule

22 and our responsibilities we have to have a

EERE-2008-BT-TP-0008 COMMENT 08
Page 55

1 confidence factor that it is being reflected

2 in the nameplate and that it's accurate and

3 that somebody is certifying to the actual

4 efficiency of those products. So it's not

5 meant to create more burden or expand the

6 number of products that you have to report on,

7 a real burden. In fact, that we're

8 considering this is showing that we're trying

9 not to do that. So the balance in that of

10 trying to make sure. We'd be anxious to get

11 any input from anybody that reflects that so

12 we know how that relates and how to account

13 for that. So you've got a level playing field

14 that you don't have somebody that's doing

15 things out there that do not live up to the

16 requirements of the regulation and also become

17 a problem for you competitively. So we're

18 looking to get it right and we're looking for

19 input from any and all that - how this impacts

20 and what ought to be considered as we

21 establish this alternate path to save you the

22 burden of having to test every single unit.

EERE-2008-BT-TP-0008 COMMENT 08
Page 56

1 FACILITATOR RABA: Comment over

2 here, please.

3 MR. LADONNE: Frank Ladonne,

4 Underwriters Laboratories. With due respect

5 to the gentleman from the Department, but

6 rather to amplify what's being said on the

7 part of the manufacturers and to illustrate

8 the other side of this issue, as has been said

9 manufacturers make subtle changes to motors

10 every day. And so for example, you may change

11 the metallurgy of, you know, the laminations. 

12 If the model number remains the same and all

13 of the nameplate ratings remain the same, how

14 would you ever know that a change was made? 

15 Okay, so that's really the other side of it. 

16 So it's a challenging issue, and that's really

17 all I want to say.

18 FACILITATOR RABA: Very

19 interesting. First Dale, then Roger, then

20 Charlie, then Bob.

21 MR. BASSO: Dale Basso, Weg

22 Electric. I guess if we are interpreting this

EERE-2008-BT-TP-0008 COMMENT 08
Page 57

1 right, a basic model only has certain

2 parameters, to Frank's point. If we make a

3 bunch of changes but the efficiency is the

4 same and the other parameters are the same, we

5 don't believe that would constitute a

6 different model. To your concern of meeting

7 efficiency levels, that's our goal. I mean,

8 that's part of the basic model is the

9 efficiency level. So if we're not going to

10 drop below the guideline as far as efficiency,

11 then I guess I wouldn't see a need for an

12 additional model no matter what we do to the

13 design as long as those parameters that define

14 the basic model are met and the efficiency is

15 the same.

16 FACILITATOR RABA: Roger? Pass? 

17 Okay Charlie, you're next.

18 MR. STEPHENS: Charlie Stephens,

19 Northwest Energy Efficiency Alliance. It

20 seems to me that the challenge is going to

21 come in the interpretation of the phrase in

22 this definition that says "have electrical

EERE-2008-BT-TP-0008 COMMENT 08
Page 58

1 characteristics that are essentially

2 identical." Efficiency is one metric of the

3 electrical characteristics of the motor, but

4 as has been pointed out there's a whole lot of

5 other ones, and those can vary even if the

6 efficiency happens to come out at the same

7 level. So I think DOE's strictness of

8 interpretation of that one phrase right there

9 could have a lot to do with just how much of

10 a burden this is on the manufacturers. So to

11 me I think that's where I'd focus my effort on

12 just what does that mean, "essentially

13 identical in electrical characteristics."

14 MR. KIDO: Michael Kido, DOE. 

15 Could you elaborate on some of those items,

16 like some of the electrical characteristics

17 that might come into play?

18 MR. STEPHENS: Well, so there's -

19 for instance, the loss - where are the motor's

20 efficiency losses? Do they occur, are they

21 core losses, you know, are they winding

22 losses, you know. There are torque

EERE-2008-BT-TP-0008 COMMENT 08
Page 59

1 characteristics that change as people have

2 pointed out. There's different rotor

3 characteristics that might cause it to behave

4 differently electrically while still

5 delivering the same efficiency. That

6 efficiency is just one number and it's going

7 to be the same for a lot of motors, even

8 motors that are radically different than one

9 another. They may still by chance come out

10 with the same efficiency rating. But there

11 are other characteristics that define how a

12 motor performs for a customer for an end use,

13 and those things are, you know, what is

14 essentially identical? I mean, that's the

15 question. What is "essentially identical."

16 FACILITATOR RABA: We have a

17 couple responses just waiting anxiously. 

18 First Robert, gentleman over here and I'll

19 give Rob the last word there. Robert Van

20 Buskirk? Come to the microphone, please. 

21 State your name for the record and your

22 affiliation.

EERE-2008-BT-TP-0008 COMMENT 08
Page 60

1 MR. VAN BUSKIRK: Robert Van

2 Buskirk, Lawrence Berkeley Lab. Our

3 organization is responsible for the analysis

4 of losses for the standard. So in terms of

5 electrical characteristics, that can affect

6 energy consumption. In addition to the rated

7 efficiency at full load, the efficiency

8 ratings at partial load is the next most

9 important. The next most important

10 characteristic is the power factors

11 characteristics of the motor, and then the

12 next characteristic below that is inertia

13 parameter. That's my ranking so far of the

14 electrical characteristics that have the most

15 importance on the energy consumption of the

16 motor.

17 FACILITATOR RABA: Thank you. 

18 Over here please, General Electric?

19 MR. HOFMANN: Doug Hofmann,

20 General Electric. Yes, when we talk about

21 what are the electrical characteristics when

22 we design a motor, we get - a design engineer

EERE-2008-BT-TP-0008 COMMENT 08
Page 61

1 will get an output, maybe five pieces of

2 paper. There will be hundreds of

3 characteristics that could be considered

4 electrical characteristics of a motor and the

5 question here is from a regulation perspective

6 I think we need some kind of definition of

7 which electrical characteristics the

8 government is really concerned about

9 regulating or evaluating.

10 MR. LEWIS: Ron Lewis, DOE. This

11 is all very helpful and I think it's as well

12 constructive. It will all be taken into

13 consideration. Other thoughts would be

14 helpful as well. The essence of that is to

15 make sure that the consumer buying a model

16 that's got a nameplate under a number, that

17 the efficiency is correct and they can use

18 that with confidence that it's reflecting the

19 actual efficiency. And if we are going this

20 ultimate path to save the testing to make sure

21 that this process doesn't have a giant

22 loophole that's going to become a headache for

EERE-2008-BT-TP-0008 COMMENT 08
Page 62

1 all of us downstream. So as much information

2 as you can provide. I assure you that we

3 aren't looking for more work to consider more

4 aspects, more characteristics and to get into

5 the fine granularity of the design aspects

6 beyond the confidence of the efficiency that

7 we have an obligation to maintain a level

8 playing field and show that everybody is in

9 compliance and in fact you are certifying we

10 believe to us that you're in compliance. So

11 that's the essence of it, that's what our goal

12 is, so in giving us information where we can

13 accomplish that with that high confidence it

14 will be very helpful to get that input as

15 we're looking at final decision, before the

16 final notice.

17 MR. HOFMANN: Doug Hofmann,

18 General Electric. So it sounds like you're

19 really meaning here, the intent is that the

20 nameplate characteristics are essentially

21 identical. That really sounds like what

22 you're getting at in this definition. 

EERE-2008-BT-TP-0008 COMMENT 08
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1 FACILITATOR RABA: I saw Rob

2 Boteler's hand before. Proceed.

3 MR. BOTELER: I just want to

4 comment that it's the nameplate characteristic

5 for efficiency. I mean, and there are other

6 nameplate characteristics like power factor

7 that are not under consideration here, or

8 torque requirements that are not under

9 consideration. And I think Ron you made the

10 comment about, you know, how accurate the

11 numbers are and what the reliability is, and

12 I think we covered this ground in the IHP in

13 the integral horsepower discussions years ago

14 and that's where we came up with the 113 basic

15 models. And using our AEDMs and then

16 demonstrating through a sample of five units

17 and five ratings that the correlation between

18 that test method and the calculation method

19 was accurate. And in doing so we were able to

20 then establish those 113 ratings and today we

21 build thousands of iterations of those 113

22 ratings where we make changes and we've not

EERE-2008-BT-TP-0008 COMMENT 08
Page 64

1 had issues that I know of not being in

2 compliance because our correlation is

3 accurate. And I think what our point is we're

4 able to do the same thing in the fractional

5 world. We really don't need to dig into the

6 level of detail of our electrical designs that

7 every time we change an electrical design that

8 we would go back and do any retesting because

9 we've already tested and we know the

10 correlation that exists.

11 FACILITATOR RABA: Good comments

12 all. Roger, you had your hand up.

13 MR. DAUGHERTY: Yes. Roger

14 Daugherty, Baldor Electric. I'd just like to

15 comment about a couple of things I've heard,

16 and this has to do with the reporting aspect. 

17 One comment was made that say I had one

18 horsepower two pole motor, that - but I had

19 different levels of efficiency for different

20 designs and all those are obviously different

21 basic models. And I may have different

22 electrical designs all of which have the same

EERE-2008-BT-TP-0008 COMMENT 08
Page 65

1 efficiency. And the statement was made that

2 all those would have to be reported. I also

3 heard the statement that reporting should not

4 be a burden on the manufacturers. We went

5 through this with the medium motors over

6 several years at which we arrived at the 113

7 items that was just being referred to in the

8 reporting structure with the recognition and

9 I think you'll find it in the rules and

10 regulations, that the manufacturer could

11 report the basic model that had the lowest

12 level of efficiency that met the standards of

13 which he was making. That's what had to be

14 sent in to the Department of Energy. And that

15 if he ever created a new basic model that was

16 lower than a level that he reported, then he

17 had to send in a new certification for that

18 basic model as long as it still met the

19 standard. And that's where these 113 ratings

20 came from to get into the DOE report. My

21 comment is just that I'd recommend that for

22 small motors pursue the same method of

EERE-2008-BT-TP-0008 COMMENT 08
Page 66

1 reporting and not require a reporting of every

2 model motor that a manufacturer made.

3 FACILITATOR RABA: Would you

4 clarify. Off the same method of reporting,

5 are you suggesting it to be 113 plus some

6 other number? Or what - could you clarify

7 that, either now or in written comments later

8 on so that the Department can get some idea to

9 get arms around what you're saying there. 

10 MR. DAUGHERTY: Roger Daugherty,

11 Baldor Electric. Just a brief comment to try

12 to address your question. It's probably not

13 113 obviously, so the point is that if you

14 look at that table structure it has open

15 motors and it has enclosed, so that's part of

16 the 113. Only open apply here. So here we

17 have polyphase, we have the capacitor-start

18 capacitor-run and the capacitor-start

19 induction-run. So those start to identify the

20 basic models. Then you have the pole numbers. 

21 And then - so if you set a structure up like

22 that, then manufacturer reports within that

EERE-2008-BT-TP-0008 COMMENT 08
Page 67

1 table, the basic model that has the lowest

2 level efficiency of all basic models that he

3 manufactures under that classification or

4 basic model and that that's what is sent into

5 the Department of Energy.

6 FACILITATOR RABA: Okay. Also -

7 MR. LEWIS: Excuse me. Is that

8 the understanding and interpretation of other

9 manufacturers, that you only report it on the

10 lowest basic model? Is that how you've been

11 interpreting it?

12 MR. BOTELER: This is Rob Boteler

13 with Emerson. Yes, that's exactly how we

14 report.

15 MR. LEWIS: Okay. This is all

16 good input and general counsel and legal

17 issues and interpretations and the scope has

18 changed. We've got EISA that's happened last

19 year, we've got other sizes, so we have to

20 look at a whole lot of factors here, but this

21 is all good input so we appreciate the input

22 that you gave us. And if you could send us

EERE-2008-BT-TP-0008 COMMENT 08
Page 68

1 additional comments of your thoughts, your

2 interpretation of how this has played out

3 would be very helpful to us.

4 FACILITATOR RABA: I might add too

5 that I think a very good point that Ron makes

6 in the Department of Energy. The reason, I

7 understand, from what the rulemaking has up

8 here, the 113 is because EISA is affecting

9 those horsepower ranges for those motors. 

10 This discussion of small motors I believe is

11 sort of like a parallel discussion so that

12 your comments are on the table to understand

13 would there be levels or not, and what they

14 would be, and I'm sorry, the basic models,

15 like the ratings, the 113. Would there be an

16 analogous or comparative for the small motors

17 family over here. So the reason I believe,

18 correct me if I'm wrong Michael, but 113 was

19 considered for those finite number of motors

20 that were one and two in horsepower instead of

21 separate in definition from EPCA amended by

22 EPAct in `92. However, having the industry

EERE-2008-BT-TP-0008 COMMENT 08
Page 69

1 arrived at years ago, EISA is open to

2 interpretation in a different discussion today

3 about those size motors. So I think this

4 discussion about the basic model is very

5 productive and the comments are well taken all

6 around and request written comments I believe

7 back to the Department to clarify what your

8 thoughts are on both sides of the table,

9 Underwriters Laboratories, Manufacturers and

10 Northwest power. Yes? So again, your

11 comments will be most appreciated on this

12 matter. Roger, your hand up.

13 MR. DAUGHERTY: Roger Daugherty,

14 Baldor Electric. I'm getting the impression

15 that there seems to be some concern that maybe

16 because the manufacturers are reporting on

17 just 113 that those are the only ones that

18 give the impression that they've been looked

19 at and certified and everything. That's not

20 the intent. Our motors that are covered

21 products are certified either by the

22 manufacturer or through a third party

EERE-2008-BT-TP-0008 COMMENT 08
Page 70

1 certification program. It's just that the

2 only report that is sent in says that that

3 manufacturer is not actually manufacturing any

4 motor that has an efficiency level lower than

5 what he has sent in on his report, but that

6 all motors that he manufactures actually do

7 comply with the law. And so it just gives DOE

8 a record that should that manufacturer put a

9 motor out that has an efficiency level that's

10 lower than he reported, then that becomes an

11 issue with the manufacturer. 

12 MR. LEWIS: One of the things that

13 concern me is the potential framing of this

14 just based on the 113 that was appropriate in

15 EPAct `92 when this was originally discussed,

16 and the scope may have changed, the motors

17 that are under consideration, et cetera, so I

18 don't think we're locked into 113. There's

19 nothing sacred about that number, but I'm

20 interested in the approach and interpretation

21 of what was the basis of that. That number

22 may change as the legislative requirements

EERE-2008-BT-TP-0008 COMMENT 08
Page 71

1 have changed. So all your input is important

2 to us to understand how that's played out, how

3 you've actually shown compliance with the

4 statute, the requirements, et cetera. It's

5 important for us to understand how that's been

6 incorporated into the logistics of your

7 business. 

8 MR. SCHOLAND: Mike Scholand. I

9 just want to steal the floor for a second to

10 make one comment. In Appendix C, the Subpart

11 B of Part 431, this is compliance

12 certification section of the Code of Federal

13 Regulations, this - what's being described by

14 industry is exactly right. It says there that

15 for each rating of electric motor for which

16 the listing specifies the nominal full load

17 efficiency of a basic model, the company

18 distributes no less efficient basic models

19 with that rating - all basic models -sorry20 with that rating and all basic models with

21 that rating comply with the applicable energy

22 efficiency standard. So I guess -

EERE-2008-BT-TP-0008 COMMENT 08
Page 72

1 MR. LEWIS: We have general

2 counsel here. So you are a technical support

3 contractor to help us so making a statement

4 that is exactly right, I think we need to make

5 sure that general counsel is having that

6 voice, not a support contractor, okay? So

7 just - it's important to point out the section

8 and the language and that's helpful, but

9 that's beyond your responsibility, okay?

10 MR. SCHOLAND: Could I add that

11 the Department has adopted the same language

12 for distribution transformers, an industry

13 that is also faced with multiple basic models

14 within a combination of KVA rating and number

15 of phases. So this language and certification

16 compliance is not being proposed today in the

17 Notice of Proposed Rulemaking for Small

18 Electric Motors. It's not in the NOPR right

19 now so that's probably why I was kind of

20 searching when you first raised the question. 

21 It's not in our NOPR at this stage. This is

22 something that if it looks like the Department

EERE-2008-BT-TP-0008 COMMENT 08
Page 73

1 is going to be adopting energy efficiency

2 standards for small electric motors, DOE would

3 then initiate a process to create compliance

4 certification requirements at that time, and

5 it would be in either that proceeding or

6 another proceeding, so. Any other comments? 

7 Charlie?

8 MR. STEPHENS: Charlie Stephens,

9 Northwest Energy Efficiency Alliance. I might

10 have a clarification. I'm assuming from what

11 I'm hearing from the manufacturers that number

12 that you report for each of the 113 basic

13 models is not the number that's on the

14 nameplate of all of the motors that you

15 produce in that box. Is that true or is that

16 not true? There could be a higher number, a

17 higher efficiency number on a nameplate? 

18 Okay, just checking.

19 FACILITATOR RABA: I see

20 affirmative nods of heads to agree with

21 Charlie's statement for the record. And

22 having said it, thank you very much Michael

EERE-2008-BT-TP-0008 COMMENT 08
Page 74

1 for reading that and clarifying that, Ron. Is

2 this a segue for general counsel for this

3 point?

4 MR. KIDO: Well, it's - what we

5 could do is certainly with respect to any

6 written comments that come in we'll review

7 them. I don't disagree with anything that

8 Michael has pointed out and that's all I have

9 to say on that unless someone's got some

10 clarification questions on that.

11 FACILITATOR RABA: Sounds good. 

12 Kind of ratchets it up perhaps. And again, as

13 Michael has invited your comments written so

14 we can make a very clear understanding of how

15 the stakeholders, the interested parties feel

16 about that too. Wow. So far so good. Should

17 we move on? Want to? Okay, good. Thank you.

18 MR. SCHOLAND: Okay, the next

19 slide is hopefully non-controversial. This is

20 the statutory definition of a small electric

21 motor. This is the definition that was in the

22 Energy Policy Act of 1992. A small electric

EERE-2008-BT-TP-0008 COMMENT 08
Page 75

1 motor means a NEMA general purpose alternating

2 current single-speed induction motor both in

3 a two-digit frame number series in accordance

4 with NEMA Standards Publication MG1-1987. Go

5 ahead, question. 

6 MR. DAUGHERTY: Roger Daugherty,

7 Baldor Electric. Now, keeping in mind that

8 this definition that you're looking at was

9 passed in 1992, in that same EPAct covered the

10 medium motors which had a similar definition

11 in its references to NEMA. This definition

12 refers to NEMA and it refers to general

13 purpose. However, as the DOE was working on

14 rules and regulations, it was made very clear

15 that there are foreign motors of the IEC

16 standard that are brought into the U.S. that

17 are used in the same applications that NEMA

18 motors are. And so DOE made an interpretation

19 that IEC motors should be included within the

20 coverage of the requirements. And so you'll

21 find that in the present 10 - the Part 431. 

22 So I just encourage the DOE make a similar

EERE-2008-BT-TP-0008 COMMENT 08
Page 76

1 interpretation that IEC motors of equivalent

2 ratings and use also be covered by any rules

3 and regulations and standards.

4 MR. SCHOLAND: Thank you. Other

5 comments?

6 MR. LADONNE: Frank Ladonne,

7 Underwriters Laboratories. Just curious why

8 multi-speed motors were exempted. 

9 MR. SCHOLAND: Sorry, I can't

10 respond to that. This is the definition that

11 Congress passed so that's what the Department

12 has to work with. Yes. Feel free to make a

13 comment why you think multi-speed should be

14 included and the rationale for it, please, in

15 writing.

16 MR. LADONNE: Frank Ladonne,

17 Underwriters Laboratories. I just think that

18 especially in the case of small motors we

19 ought to consider multi-speed motors.

20 FACILITATOR RABA: Other comments,

21 please. Proceed.

22 MR. SCHOLAND: Thanks, Jim.

EERE-2008-BT-TP-0008 COMMENT 08
Page 77

1 FACILITATOR RABA: Thank you,

2 Frank.

3 MR. SCHOLAND: I just want to

4 revisit - I mentioned earlier we'd come back

5 to this, the alternative efficiency

6 determination method that first came up when

7 we were discussing the definition of it. But

8 I wanted to have one slide on this and then

9 have an issue for comment on the next slide to

10 kind of talk about it. So why is the

11 Department proposing an AEDM? Basically

12 because the DOE is concerned about the

13 regulatory testing burden. Manufacturers do

14 produce large numbers of small electric motor

15 basic models, and testing an electric motor

16 typically requires 10-12 hours and can cost as

17 much as $2,000 a unit. So DOE is proposing to

18 adopt procedures to allow manufacturers to

19 certify using the AEDM. The AEDM as was also

20 discussed earlier requires substantiation from

21 actual test data. Five basic models of which

22 at least five units have to be tested. It's

EERE-2008-BT-TP-0008 COMMENT 08
Page 78

1 a minimum of 25 motors must be tested and the

2 AEDM has to predict total power loss within 10

3 percent of the mean total power loss from

4 actual testing. That requirement is the same

5 as is required for the 1 to 200 horsepower

6 motors today. So DOE is proposing that same

7 requirement for small electric motors. And

8 then the AEDM would be allowed to be used to

9 certify compliance in lieu of testing. 

10 So the next slide. We just have

11 an issue for comment number three and I won't

12 read it. We'll just go right to discussion. 

13 FACILITATOR RABA: Roger?

14 MR. DAUGHERTY: Roger Daugherty,

15 Baldor Electric. Just to try to help the

16 Department out, I realize it's a result of

17 copy and pasting, but within this selection of

18 the five basic models for the accreditation,

19 whatever, of the AEDM, the present statement

20 says that the basic models should be a

21 different frame number series without

22 duplication. The problem is that in the small

EERE-2008-BT-TP-0008 COMMENT 08
Page 79

1 motors that we're talking about there are only

2 three two-digit frame sizes that are being

3 covered, 42, 48 and 56, so it's not possible

4 to satisfy that kind of requirement. So the

5 Department may wish to rewrite that particular

6 item and just be more clear and recognize the

7 present frame sizes.

8 MR. SCHOLAND: Very helpful

9 comment, thank you. 

10 FACILITATOR RABA: Other

11 observations or comments?

12 MR. LEWIS: Just a question on

13 that. The existence right now of three

14 different frame sizes, I guess the

15 sustainability of it that we have to look at

16 the options of the frame sizes ever being

17 introduced, but not have the five that was

18 there with five appropriate. So I think

19 somehow we need to consider the limitation,

20 the parameters of it right now, but also look

21 forward trying to not have something become

22 obsolete, when it becomes effective if there

EERE-2008-BT-TP-0008 COMMENT 08
Page 80

1 ever is another frame size introduced. So

2 somehow or other in your suggestions and

3 recommendations if you've got any wisdom you

4 can give us on how we could accomplish that at

5 the same time of recognizing the three that

6 are in existence, but not loading it to that

7 where the frame sizes come into play. 

8 MR. DAUGHERTY: Roger Daugherty,

9 Baldor Electric. Since you're using the 1987

10 version of MG1 as the reference standard, and

11 that that standard only contains three two12 digit frame sizes, if others were introduced,

13 how would the Department include those? I can

14 only note that those three two-digit frame

15 sizes have been around 40 or 50 years, and

16 there's been no others introduced because the

17 next logical series went right into the three18 digit. So I don't see the practicality of

19 that happening, but I'd also wonder since

20 everything is tied to the 1987 version exactly

21 how the Department would try to cover some new

22 frame size.

EERE-2008-BT-TP-0008 COMMENT 08
Page 81

1 MR. LEWIS: It would have failed

2 on a whole bunch of different appliance

3 standards and test procedures. One of the

4 difficulties have been with the acceleration

5 of technologies and changes going on, and how

6 do we stop things from becoming obsolete so

7 quickly. So it's a thought to try to embed in

8 things to look forward at trying to cover as

9 many circumstances as we can so that you don't

10 have a change later on, that looking forward

11 there's some clarity. So it's a positive

12 thought of trying to give you the assurance

13 and the comfort of knowing what the mechanisms

14 are and the regulations would be as well. So,

15 it's not meant to be introducing new

16 complexities, it's trying to keep things more

17 consistent which I think would be helpful to

18 industry.

19 FACILITATOR RABA: In the back,

20 Charlie.

21 MR. STEPHENS: Charlie Stephens,

22 Northwest Energy Efficiency Alliance. I'm

EERE-2008-BT-TP-0008 COMMENT 08
Page 82

1 assuming that this will all, given the

2 manufacturer comments, will also apply to IEC

3 motors and their equivalents. The equivalent

4 frame sizes and all the same numbers will

5 apply to them as well, assuming that the

6 Department finds that they're covered?

7 MR. LEWIS: I believe there's a

8 slide in here that says something about IEC,

9 and so we'll have that discussion when that

10 slide comes up.

11 MR. SCHOLAND: Yes. In fact,

12 actually, thanks Ron. The discussion of

13 coverage and interpretation of the statutory

14 definition of small motors is actually for

15 tomorrow. And DOE is taking the position of

16 extending coverage to the IEC motors and that

17 is discussed in tomorrow's proceeding as part

18 of the energy conservation standards rule

19 rather than the test procedure rule.

20 MR. STEPHENS: Okay. So I just

21 assume that all of these procedures will apply

22 equally well to those motors.

EERE-2008-BT-TP-0008 COMMENT 08
Page 83

1 FACILITATOR RABA: And if you'd

2 like to reinforce that with written comments,

3 submit them too. Roger?

4 MR. DAUGHERTY: Roger Daugherty,

5 Baldor Electric. However, today the issue

6 we're dealing with is a NOPR that is

7 suggesting the definition that will be in 10

8 CFR Part 431. I'm not aware that that

9 definition is on the agenda for tomorrow. So

10 it's - the IEC issue is an issue of today's

11 proposed definition. It's not an issue with -

12 necessarily in that manner with respect to

13 tomorrow's meeting as far as I'm aware.

14 FACILITATOR RABA: In your

15 comment, Roger, would you want to propose

16 language the Department should consider on

17 something like that? Written comments. Thank

18 you. 

19 MR. SCHOLAND: I won't make any

20 more jokes about non-controversial slides for

21 the rest of today's meeting.

22 (Laughter.)

EERE-2008-BT-TP-0008 COMMENT 08
Page 84

1 FACILITATOR RABA: I thought this

2 was easy so far.

3 MR. SCHOLAND: The last slide

4 before the coffee break. DOE wants to raise

5 this issue to make sure everyone is clear on

6 a departure from a requirement that exists for

7 1 to 200 horsepower for the small electric

8 motors. So in essence, EPCA requires the

9 electric motors, and that's the 1 to 200, the

10 integral horsepower to certify through an

11 independent testing or certification program

12 nationally recognized in the United States

13 that any electric motor subject to EPCA

14 efficiency standards meets the applicable

15 standard. DOE codified that language in 10

16 CFR 431.17(a)(5) which directs manufacturers

17 to establish compliance either through a

18 certification program that's nationally

19 recognized or an accredited laboratory. And

20 the requirements are spelled out in 431.18. 

21 Now, because small electric motors are

22 actually in a different part of EPCA, those

EERE-2008-BT-TP-0008 COMMENT 08
Page 85

1 same certification requirements are not there

2 for small electric motors. DOE at its

3 discretion could adopt those same

4 requirements, but because DOE generally

5 doesn't for other products in its program, its

6 fairly regulated program, it's erring on the

7 side of not having that requirement for small

8 electric motors, the requirement of a third

9 party certification. So DOE wants comment on

10 this and this is the last topic on small

11 electric motors before the break.

12 FACILITATOR RABA: I saw a hand

13 from Underwriters Laboratories. Frank?

14 MR. LADONNE: Frank Ladonne,

15 Underwriters Laboratories. Without intending

16 to seem self-serving, I just thought I'd

17 mention that we should consider that opening

18 the door to self-certification also in my

19 opinion opens the door to creating unfair

20 market advantage on the part of less reputable

21 motor manufacturers. So something to

22 consider.

EERE-2008-BT-TP-0008 COMMENT 08
Page 86

1 FACILITATOR RABA: Rob Boteler.

2 MR. BOTELER: Speaking on behalf

3 of Emerson, I think the process that we went

4 through in the medium motors with the third

5 party - or I'm sorry, with the lab

6 accreditation was a step that we felt we

7 needed for those reasons, to make sure that

8 the AEDM and the way we achieved our data and

9 then correlated was accurate. And I think

10 from Emerson's perspective, we'd like to stay

11 with the lab accreditation process for sure. 

12 FACILITATOR RABA: A point of

13 clarification too. A lab accreditation

14 process and nationally recognized

15 certification body also. Is that what you're

16 saying?

17 MR. LADONNE: Yes.

18 FACILITATOR RABA: That was easy. 

19 Thank you. Any other comments on that

20 interesting point. I understand the

21 Department wanted to bring that up very

22 particularly to get your input from both sides

EERE-2008-BT-TP-0008 COMMENT 08
Page 87

1 of the table. And it sounds like both sides

2 are really in agreement to some degree. We

3 appreciate comments from Underwriters and your

4 colleagues there in mid-field, and certainly

5 the manufacturers and the advocacy groups too. 

6 Anything else? I saw general counsel nodding

7 his head. Do you want to speak now? Okay,

8 just pass on. Okay. Any other comments? 

9 Please. 

10 We're on schedule. So you've

11 earned a break. Before you go just a reminder

12 that if you would like a copy of today's

13 transcript please see the court reporter at

14 some time during or after the meeting today

15 and perhaps tomorrow too. But today, if you

16 want a copy of the transcript of today's

17 proceeding. Remember that the restrooms at

18 both ends. Small snack bar directly below.

19 MR. LEWIS: Jim?

20 FACILITATOR RABA: Yes, Ron?

21 MR. LEWIS: Clarification. We are

22 posting the transcripts on our website now, so

EERE-2008-BT-TP-0008 COMMENT 08
Page 88

1 it will be available on our website.

2 FACILITATOR RABA: New

3 information, thank you very much for pointing

4 that out. Everybody got that? Okay. Ten

5 minutes. We're going to start again in -

6 MR. SCHOLAND: Fifteen, Jim.

7 FACILITATOR RABA: You've been so

8 good that you may have 15 minutes. Back at

9 quarter of-ish. Nominally quarter of.

10 (Whereupon, the foregoing matter

11 went off the record at 10:31 a.m. and resumed

12 at 10:50 a.m.)

13 FACILITATOR RABA: We're pretty

14 much on schedule so far. So here we are. I

15 believe our break is over. We'll go to

16 Electric Motors Test Procedures and turn it

17 over once again to our presenter Michael

18 Scholand.

19 MR. SCHOLAND: Great. Are we

20 recording? Excellent. Okay, thank you. 

21 Well, welcome back. We are now shifting

22 gears. As Jim mentioned, we're going to be

EERE-2008-BT-TP-0008 COMMENT 08
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1 talking about the integral horsepower electric

2 motors test procedure. First slide, Number

3 25. There's just three things I want to flag

4 here as a sort of overview. One is that DOE

5 is proposing to modify and add definitions to

6 the test procedure for electric motors. 

7 Modifying is updating the references, the

8 industry standard reference and definitions,

9 and adding our new definitions that are

10 required because of the Energy Independence

11 and Security Act, adding new types of motors

12 that they didn't define. So second thing, DOE

13 is proposing to update the citations to

14 industry standards, the NEMA MG1 citation, the

15 IEEE 112 and the CSA C390. And then finally,

16 DOE wishes to clarify that this updated test

17 procedure will apply to electric motors

18 federally regulated, both the integral

19 horsepower 1 and 200, but also the new motors

20 that have been covered by the Energy

21 Independence and Security Act such as 201 to

22 500 horsepower motors. Okay?

EERE-2008-BT-TP-0008 COMMENT 08
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1 So let's talk about definitions. 

2 I grouped them in two groups. The first group

3 of four are terms with references that were

4 updated or corrected, and then the second

5 group are terms with proposed either new terms

6 or they're substantive revisions that are

7 being considered. And you'll notice in that

8 second group the term "basic model" which we

9 talked about earlier with respect to small

10 electric motors. It's also on the table here

11 for electric motors. So we'll have some

12 discussion on that a little later.

13 So the first slide is

14 accreditation. Basically the Department is

15 proposing to update the citations in the

16 definition of accreditation from IEEE 112-1996

17 to 112-2004, and from CSA C390-93 to the 98-

18 R2005 version. Now, the result of that change

19 means that accreditation will now require

20 laboratories to be certified for these new and

21 actually our current industry standards. 

22 That's the result of the change, just so

EERE-2008-BT-TP-0008 COMMENT 08
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1 everybody is clear. Any questions on this

2 before I move to the next definition? Okay. 

3 Seeing none, next -

4 FACILITATOR RABA: I see a hand up

5 from Roger, please.

6 MR. SCHOLAND: Oh, sorry. Go

7 ahead, Roger.

8 MR. DAUGHERTY: Okay. Just before

9 we move into these definitions, I'd like to

10 know why Department of Energy did not include

11 the Subtype II in the proposed definitions.

12 MR. SCHOLAND: I believe Subtype

13 II was defined in the Independence and

14 Security Act which means it'll be codified in

15 a separate rulemaking. But I can - Matt, can

16 you check that for me? Or do you know,

17 Michael?

18 MR. KIDO: Yes, actually - Michael

19 Kido, DOE - that's - there is a definition

20 that EISA 2007 included for Subtype II so if

21 you'd like I can share it with you during the

22 break or after the meeting.

EERE-2008-BT-TP-0008 COMMENT 08
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1 MR. DAUGHERTY: Roger Daugherty,

2 Baldor Electric. But my question is why

3 aren't you proposing to include that in the 10

4 CFR Part 431 definitions. Under the

5 definition of electric motor you refer to it,

6 but you did not include any definition for it.

7 MR. LEWIS: There are two

8 different procedures that tie together,

9 synchronous together. What we're proposing is

10 within our jurisdiction, authority, et cetera,

11 to develop and put out. What EISA, what

12 Congress declares and has in a statute we

13 don't have any ability to change what was

14 there, and I think it was mentioned that that

15 would be put into place. It's already a

16 requirement, it's already a law, it's already

17 - the definition is legally - once it's in the

18 statute it becomes the lay of the land. What

19 we are doing, the next step in codifying that

20 somebody mentioned is only to put that into

21 the CFR. That becomes incorporated into the

22 CFR. So you're correct of wanting to have it

EERE-2008-BT-TP-0008 COMMENT 08
Page 93

1 in the CFR, but that is not our authority to

2 change that or propose that we accept this or

3 not because we have to live with it and it is

4 already the definition. So we have no

5 flexibility to change that definition. We

6 would then be putting it into the CFR through

7 a codification and there would be a rulemaking

8 to do that.

9 MR. SCHOLAND: Mike Scholand. 

10 Just to say that it's a procedural question I

11 believe you're asking. The Department has -

12 because this definition is in the statute and

13 cannot be modified by the Department, the term

14 is defined in the Act. DOE has a separate

15 rulemaking that is simply codifying

16 definitions and standards that are in the Act. 

17 So it will appear in the CFR when that

18 rulemaking goes final. This procedure where

19 we're proposing definitions are definitions

20 that are in DOE's purview to modify, adapt, or

21 propose as necessary that Congress didn't

22 define. And that's why accreditation for

EERE-2008-BT-TP-0008 COMMENT 08
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1 example, that's a DOE definition and now DOE

2 is saying we want to update the reference

3 standards. That's not a - if Congress had

4 written accreditation into the statute we

5 would not be proposing changes to the

6 standards in there because DOE couldn't do

7 that. They don't have the authority to change

8 a congressional definition. 

9 FACILITATOR RABA: In some of the

10 reconnaissance I've done in the meantime, I

11 recall that - thank you, Michael. It's a good

12 point you're all making here and Ron, that the

13 particular definitions we're looking at where

14 we can look at them are ones we have some

15 latitude to work with. We the Department,

16 that is, has to be the Department. But

17 however, there's another rulemaking play now

18 which is at the Federal Register and has been

19 there for some time called the "En Masse," and

20 there is a technical amendment which is takes

21 with EISA had directed the Department to do

22 and is simply codify word for word, it's all

EERE-2008-BT-TP-0008 COMMENT 08
Page 95

1 the Department can do, hands are tied, to

2 bring it into the federal regulations. So

3 with that in mind we'll go back and

4 investigate one more time to be sure you

5 brought it up. We'll take a look, they will

6 take a look to see if it's applicable here. 

7 Otherwise, I understand the Department has

8 examined this already previously and has

9 essentially taken the EISA language and put it

10 right into regulatory language as we are

11 directed to do by the Congress. So the

12 Department will take it under advisement. You

13 might want to comment on that in your comments

14 besides oral or written to be sure it's swept

15 up, but I'd just invite your thoughts about

16 that. But on the other hand, that rulemaking

17 is in process, it's at the Federal Register

18 for publication soon we hope, they hope, and

19 I think that it should be - has been taken

20 into account.

21 MR. SCHOLAND: Okay. Next slide

22 is the definition of a general purpose

EERE-2008-BT-TP-0008 COMMENT 08
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1 electric motor Subtype I. Again, there's the

2 very minor change to this definition. 

3 Essentially we're updating the NEMA reference

4 standard from MG1-1993 to MG1-2006. The

5 Department did a comparison and found

6 referenced Paragraph 14.2 usual service

7 conditions and Paragraph 14.3 unusual service

8 conditions are the same in both MG1 documents. 

9 So in making this update to 2006, the

10 Department sees no impact or change to the

11 definition of a general purpose electric motor

12 Subtype I. Any comments? Okay. 

13 Seeing none, the term general

14 purpose motor. The same, essentially the same

15 as what we've just discussed in general

16 purpose electric motors Subtype I. Here DOE

17 is proposing to update the MG1-1993 to MG1-

18 2006 and reference Paragraphs 14.2 and 14.3

19 are the same in both documents. So there's no

20 impact for that update.

21 Okay. And then the last of these

22 reference update definitions, nominal full

EERE-2008-BT-TP-0008 COMMENT 08
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1 load efficiency. Here the NEMA citation is

2 updated from 1993 to 2006. The reference

3 Table 12-10 has a slightly different label on

4 it, but the numerical values in Table 12-10

5 which are the efficiency values are the same

6 in 1993 and 2006. So the Department discusses

7 that. There's no substantive change and

8 therefore the definition is essentially

9 identical for nominal full load efficiency. 

10 We have a comment, question?

11 MR. HOFMANN: Doug Hofmann,

12 General Electric. If we could go back a page

13 to the previous one. Am I right in assuming,

14 I'm just asking that, the way that's written,

15 the IEC kind of motor would still be caught by

16 that because you're not - you're saying such

17 as specified in NEMA MG1? Just generally

18 asking. Is that a correct interpretation of

19 that definition that an IEC motor, a general

20 purpose IEC motor would still be covered by

21 that definition of general purpose motor?

22 MR. SCHOLAND: The Department is

EERE-2008-BT-TP-0008 COMMENT 08
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1 on record interpreting 1 to 200 horsepower

2 integral motors, which is what this definition

3 is making reference to, as including IEC. So

4 these changes I, you know, the Department

5 should weigh in, but I can't see why now they

6 wouldn't be.

7 MR. LEWIS: I'm not - the record

8 is or the history and what was in the prior

9 version, but if we are saying nothing has

10 changed in the sense that what was in place is

11 - we're going forward and we're saying there's

12 no reason to change what was in existence if

13 IEC and that was the interpretation that,

14 check with general counsel here to see, then

15 for sure we would continue that. So it's not

16 meant to be a change.

17 FACILITATOR RABA: Roger?

18 MR. DAUGHERTY: Roger Daugherty,

19 Baldor Electric. Let me try to understand

20 exactly then what's in the NOPR. The NOPR has

21 a new definition of electric motor specified

22 in it. The present, and I assume this is the

EERE-2008-BT-TP-0008 COMMENT 08
Page 99

1 language that will go into 10 CFR Part 431. 

2 The present language in 10 CFR Part 431, the

3 issue of the IEC is covered under the

4 definition of electric motor. So if there is

5 no definition, no inclusion here in any

6 reference to IEC, then how are you bringing

7 forth the present definition into the new

8 version? It was my understanding as what has

9 been proposed in the NOPR completely replaces

10 the definition that's presently in 10 CFR Part

11 431.

12 MR. LEWIS: I'd ask the - this was

13 - the parallelism between what was and what is

14 in the definition, is this in fact so as he's

15 questioning?

16 MR. SCHOLAND: Sure, Ron. Mike

17 Scholand here. What happened, Roger, in the

18 Energy Independence and Security Act of 2007,

19 in Section 313(a)(2) Congress directs that

20 EPCA Paragraph 13(A) be striked, okay? 13(A)

21 is the definition of electric motor. So with

22 that stroke of a pen the definition of

EERE-2008-BT-TP-0008 COMMENT 08
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1 electric motor is gone and went from the CFR

2 because Congress has said delete that

3 definition. And so now there's a void because

4 the term "electric motor" is no longer defined

5 in the CFR. DOE felt what might be

6 appropriate would be to take the four integral

7 horsepower motors that are now covered, four

8 types, and create a definition for electric

9 motor that simply encompassed those four. And

10 so that's the solution that's proposed in

11 today's NOPR a slide or two ahead of where I

12 am now. And if you look at those definitions

13 and you look at the definition of electric

14 motor and you don't see that IEC motors are

15 covered, then by all means please submit a

16 comment and give the Department language that

17 it should use and just in its definition,

18 propose a definition and give the Department

19 a rationale and a justification for your

20 proposal. That would be the most helpful

21 comment to receive at this stage. 

22 MR. LEWIS: That is exactly why we

EERE-2008-BT-TP-0008 COMMENT 08
Page 101

1 have these meetings that we are really looking

2 for new sets of eyes to look at it and see if

3 there's something like this. By all means

4 we're looking for all the wisdom you can give

5 us on that to really get the essence of what

6 was in the definition. Congress has struck

7 that. As we're proposing a new definition

8 that's required. If it was covered in the old

9 definition it's not there now. We're looking

10 for the best way to go to have that in the

11 definition. So the decision hasn't been made

12 to put that in yet, but I can't see why we

13 wouldn't do that if it was in the prior

14 definition. So your input will be very

15 helpful as we proceed forward.

16 MR. DAUGHERTY: Roger Daugherty,

17 Baldor Electric. Then to try to address some

18 of the things that you just raised, and trying

19 to look through here fast, and maybe I missed

20 it. But I don't see a slide here that deals

21 with the actual change in the definition of

22 electric motor. By bringing in those four

EERE-2008-BT-TP-0008 COMMENT 08
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1 things that were in EISA and be moved up as

2 the definition of electric motor which is a

3 replacement of the present definition in 10

4 CFR Part 431 as it's been moved in as

5 specified in the NOPR. Obvious concerns to

6 the manufacturers are that this striking of

7 the present definition of electric motors does

8 eliminate all this recognition that up to date

9 we've been talking about single-speed motors. 

10 By striking that definition and using only

11 general purpose you start to bring in multi12 speed motors. By striking foot-mounted you

13 bring up any kind of mounting configuration

14 now as being covered product. By striking the

15 voltage ratings you bring up any voltage

16 ratings and our concern now is not necessarily

17 up to 600 volts, but you've now brought in

18 higher voltage-rated motors. And that in

19 those higher voltage-rated motors you have the

20 potential - well, EISA specifies efficiency

21 levels you have to meet, and now we've moved

22 into form-wound motors and it's very difficult

EERE-2008-BT-TP-0008 COMMENT 08
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1 to meet those efficiency levels. And if you

2 look at the NEMA tables, you will see that we

3 specify that form-wound motors can't meet the

4 efficiency levels of the random-wound motors,

5 but no difference is made within the standard. 

6 Then you've lumped - in this

7 proposed definition now you've defined an

8 electric motor as being of four types, and

9 that by bringing in the fire pump motors and

10 bringing in NEMA Design B motors of higher

11 ratings, I'd like to make a distinction

12 between EISA which defines really two types,

13 a Subtype I and Subtype II. That a NEMA

14 Design B motor is a subgroup of a Subtype I. 

15 NEMA Design B motors are in this definition

16 Subtype I. The distinction in EISA was to

17 establish a different efficiency requirement

18 for those particular - that particular group

19 of motors that fell under that subtype. And

20 we don't feel that NEMA Design B should be

21 moved up into the basic definition. The other

22 concern is that by moving it up into the basic

EERE-2008-BT-TP-0008 COMMENT 08
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1 definition you have now pulled that group of

2 motors out of the definition of Subtype I. So

3 they stand alone as their own definition. 

4 Then EISA only specified efficiency levels for

5 NEMA Design B motors that are above 200

6 horsepower and not greater than 500. There

7 are no longer any standards in EISA, if that's

8 the interpretation that that's a defined type,

9 for 1 to 200 horsepower for those motors, and

10 that's the most common motor that's

11 manufactured. And that was covered under

12 EPAct. 

13 The fire pump motors that EISA

14 covered those under the standards area because

15 they are presently covered motors under EPAct

16 and under present rules. And under those

17 present rules they meet Table 12-11 in NEMA

18 MG1. But when the other motors of Subtype I

19 were to be elevated to what we call the

20 premium efficiency levels in Table 12-12,

21 Congress made the definition that was not

22 necessary for this particular grouping of

EERE-2008-BT-TP-0008 COMMENT 08
Page 105

1 motors of the Subtype I and stated that those

2 were to remain at Table 12-11 values. So

3 those two particular ones that are in the

4 standards area of EISA are related to groups

5 of motors that are actually under the

6 definition of Subtype I. And in the standards

7 area, it actually says in Paragraph A that

8 except for those motors in Paragraph B which

9 are the fire pump, then the efficiency level

10 shall be increased to Table 12-12. So that

11 those become an exception within standards,

12 but we don't feel those should be moved up

13 into a definition.

14 And our most serious concern is

15 moving the standards for the NEMA Design B

16 large horsepower and making that a general

17 definition of a general term and dropping

18 standards for 1 to 200 horsepower. Once

19 you've moved them up - at least, that's our

20 interpretation of what happens when you move

21 those up into its own definition.

22 MR. KIDO: Michael Kido, DOE. 

EERE-2008-BT-TP-0008 COMMENT 08
Page 106

1 Just for clarification since I'm probably one

2 of the few non-technical people here, do you

3 mean then that the Department should somehow -

4 are you saying that we should clarify or

5 deviate from what Congress has specifically

6 prescribed in EISA? Because it's my

7 understanding that the definitions that we've

8 got are being incorporated based on what

9 Congress has provided for. I just need some

10 clarification from you on what you're

11 suggesting.

12 MR. DAUGHERTY: Roger Daugherty,

13 Baldor. The - I guess just my interpretation

14 and others' interpretation, okay, again, that

15 there's a definition section of EPCA and that

16 that was modified by EISA by changing the

17 definition of electric motor by introducing

18 Subtype I and Subtype II. Then there's the

19 standards area, and in the standards area you

20 can establish efficiency levels that are

21 different for different groupings of motors

22 that fall within the definitions. So to us as

EERE-2008-BT-TP-0008 COMMENT 08
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1 manufacturers, and if you look at the present

2 definition of electric motor from EPAct of

3 1992, the definition of electric motor is a

4 NEMA Design A and B, so it's a NEMA Design B

5 and it's general purpose, okay? So those -

6 motors of those types have always been within

7 the definition of an electric motor, and now,

8 when you look at it that way, then this

9 Subtype I which is now totally general

10 purpose, encompasses everything, whether it's

11 Design A, Design B. If someone makes a Design

12 C and calls it general purpose, they make a

13 multi-speed motor and call it general purpose,

14 you make any kind of mounting, vertical

15 motors, anything now fall under this general

16 classification. So then the purpose of the

17 standards area was to establish different

18 standards, efficiency standards for different

19 types of Subtype I motors. And like I said,

20 the big concern is that when you take this

21 grouping out of the establishment of just

22 specifying standards and make it a definition,

EERE-2008-BT-TP-0008 COMMENT 08
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1 then at least to us it indicates that NEMA

2 Design B general purpose motor is a different

3 defined motor than a Subtype I motor. And

4 therefore, the only thing you're left with,

5 the only standards that were established for

6 NEMA Design B motors are 201 to 500

7 horsepower. There are no standards any longer

8 for 1 to 200 horsepower. So we encourage you

9 to not move fire pump motors nor NEMA Design

10 B motors up into the definition of electric

11 motor.

12 MR. LEWIS: Ron Lewis, DOE. Thank

13 you for that input and I can't remember

14 another meeting where rather than asking for

15 input and dialogue from the manufacturers and

16 the stakeholders we asked the team if they've

17 got any questions from what you just said to

18 make sure that we understand your comments. 

19 And I'm hoping you'll give these to us in

20 writing with as much specificity to be

21 helpful, to make sure that we're synchronized

22 here. But I want to make sure that the team

EERE-2008-BT-TP-0008 COMMENT 08
Page 109

1 in hearing what you just said, that we don't

2 leave this meeting, if they've got any

3 questions of what you're saying in how to

4 proceed forward from here. This is not a

5 commitment that, okay, what you said is our

6 interpretation, et cetera, but it's very

7 important we understand that and I want to

8 make sure they've got your thoughts. So if

9 you've got any questions, team?

10 MR. SCHOLAND: Mike Scholand. I

11 guess where we were coming - where the

12 Department was coming from in proposing a

13 definition for fire pump motor and some of the

14 other ones that are added that are not defined

15 was essentially the problem that you've

16 already mentioned, that there's a definition

17 section which has the design Subtype I and

18 Subtype II and then there's a standards

19 section which has, right, four tables of

20 efficiency standards and fire pump is called

21 out separately. Now, if fire pump is a subset

22 of Subtype I, right, perhaps the simple

EERE-2008-BT-TP-0008 COMMENT 08
Page 110

1 solution is to clarify - I mean, what we were

2 concerned about is that someone would open the

3 Code of Federal Regulations and look at

4 standards for fire pump motors and say, well,

5 what's a fire pump motor? Go to the

6 definition section and it's not there. So in

7 this NOPR a definition for fire pump motor is

8 being suggested for comment. It sounds like -

9 we do have a slide where we will talk about

10 the definition of electric motor - it's Slide

11 32. It's still coming up - where we explain

12 the sort of thought behind the four motors

13 being bundled into one. That definition is

14 completely open to being fixed and corrected

15 as of all the definitions that we're

16 discussing here, including fire pump motor. 

17 So I think this is exactly the

18 input we need, and I guess I would say again,

19 as much as possible in your written

20 submissions - all of what you've said is on

21 the record now with our transcript. But if

22 you can put in writing how you would structure

EERE-2008-BT-TP-0008 COMMENT 08
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1 the definition section to make sure that it's

2 clear, that you know, what is a fire pump

3 motor. If I go into the efficiency standards,

4 I see a fire pump motor, well what kind of

5 motor is that? Let me go back to the

6 definition. That's what the Department is

7 trying to make sure, that there's clarity in

8 coverage, clarity in scope and that's what the

9 NOPR was trying to achieve but has missed the

10 mark. So the more clarity you can give us in

11 your comments and justifications that would

12 help.

13 MR. LEWIS: One of the things that

14 you got my attention on was it sounded like we

15 had the 1 to 200 horsepower motors weren't

16 covered. It sounded like there was a big

17 void. And so in these definitions one of the

18 things that I would want to make sure is we

19 don't have any problems like that, potential

20 problems. So to the extent that the

21 organizational structure - I hear you making

22 suggestions on how to correlate that with what

EERE-2008-BT-TP-0008 COMMENT 08
Page 112

1 - how you read EISA and your interpretation of

2 how that's structured. And that's very

3 important, very helpful. But if there are any

4 glitches or potential unintended consequences

5 of something that gets overlooked as a result

6 of that that becomes even more important to us

7 than the structure.

8 MR. DAUGHERTY: Roger Daugherty,

9 Baldor Electric. To answer your question,

10 well both of them, as how to structure. I

11 guess I would recognize that it's possible to

12 put a definition in, but the concern is that -

13 with the definition of electric motor, that -

14 you can have a definition of fire pump motor

15 and you can have a definition of NEMA Design

16 B general purpose motor if you need it, but

17 those should not be a part of the definition

18 of electric motor. Because lumping them into

19 there that you specified specific, delineated

20 definition, and NEMA Design B became a

21 specifically defined electric motor apart from

22 the Subtype I, Subtype II and fire pump. 

EERE-2008-BT-TP-0008 COMMENT 08
Page 113

1 Whereas if the definition remained at what

2 EISA has in the bill, then - and you define

3 NEMA Design B general purpose outside of that

4 definition for the convenience of the reader

5 of 10 CFR Part 431 then that would satisfy a

6 lot of concern. And then when you go to the

7 standards, then one could recognize that the

8 standards say that for a NEMA Design B general

9 purpose of above 200 horsepower not greater

10 than 500, these efficiency values apply. But

11 the manufacturers certainly still understand

12 that a NEMA Design B motor is a Subtype I

13 motor. And therefore, for 1 to 200 horsepower

14 would apply under the first Paragraph A

15 standards in EISA that they were being

16 elevated from the present values at Table 12-

17 11 to 12-12. So the concern was that you move

18 these in making the basic definition while you

19 were trying to maybe have some reason why you

20 had to provide your individual. But you could

21 have the individual with - without having it

22 within the basic definition. 

EERE-2008-BT-TP-0008 COMMENT 08
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1 And while we're on that, some of

2 the other complexity that's involved is that

3 if you interpret the EISA strictly by the way

4 it's written, then a Subtype I motor as I said

5 makes no reference to its mounting position,

6 it makes no reference to voltage, it makes no

7 reference to frame size, it makes no reference

8 to whether it has a feet or not, it makes no

9 reference to design type. So the problem is

10 that under that interpretation this definition

11 Subtype II which you did not include in this

12 proposal but you included as part of the

13 definition of electric motor, there is no

14 reason for Subtype II because a U-frame motor

15 is already a Subtype I under the over umbrella

16 definition. A motor up to 600 volts is

17 already a Subtype I. A Design C motor is

18 already a Subtype I. And so the purpose, our

19 interpretation of the intent within EISA was

20 that a Subtype I was the present covered

21 product under the present definition of

22 electric motor. And I understand having to go

EERE-2008-BT-TP-0008 COMMENT 08
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1 with exactly what EISA says, but it presents

2 a problem of how to interpret a Subtype II if

3 a Subtype I already embodies all the

4 components of Subtype I. 

5 MR. KIDO: Michael Kido, DOE. And

6 I think you hit the nail on the head. I mean,

7 we're sort of stuck with what Congress has

8 already prescribed. So again, we're sort of

9 limited, we don't really have a whole lot of

10 authority to go beyond what Congress has

11 already written in the statute. So even

12 though it seems like you've got a number of

13 very legitimate and significant concerns, and

14 maybe those are things that you could sort of

15 elaborate on in your written comments to the

16 agency to flesh those issues out. But again,

17 we are limited by the confines of the statute

18 itself and that's what we're dealing with.

19 MR. LEWIS: Ron Lewis, DOE. Is

20 the object - here the close synchronization

21 with NEMA and - either some of these things

22 are handled since it is referenced in that,

EERE-2008-BT-TP-0008 COMMENT 08
Page 116

1 the tables in there. Is the structure that

2 was in existence before still carried through

3 by we're just updating to that? Is - since

4 that's reflected in what we're doing here, is

5 that part of the simplification and

6 clarification here, that through that

7 structure that we're just carrying that

8 through in the definition section? Is that

9 already embedded in those standards in the law

10 that are being incorporated here. Is any

11 definition in there at all that shows these

12 distinctions, that make up for some of the

13 deficiencies where the statute did not perhaps

14 get right?

15 MR. DAUGHERTY: Roger Daugherty,

16 Baldor Electric. No, I guess the problem is

17 that, and I understand what happened, that

18 EISA replaced the definition of electric motor

19 from EPAct with a new definition, rather than

20 use that original definition and then classify

21 Subtype I under that definition of electric

22 motor. So once that definition has now been

EERE-2008-BT-TP-0008 COMMENT 08
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1 stricken by EISA, then we're left with this

2 overall concern that this umbrella of general

3 purpose motor Subtype I is so encompassing

4 that it encompasses all the Subtype II and it

5 makes you wonder well, what was Congress

6 thinking? And it will be interesting exactly

7 how you're going to interpret Subtype II and

8 how you're going to write the standards for

9 Subtype II because they're under the umbrella

10 of Subtype I. So that's why I was surprised

11 it wasn't within this whole discussion and in

12 the NOPR. 

13 Our best attempt is to try to

14 influence, and I know it has to be done on the

15 Congressional level, to try to get the

16 original definition restored and then build

17 off of it so that Subtype I and Subtype II

18 actually build. Because when you start with

19 the basic definition everything makes sense. 

20 But once you throw that basic one away that

21 we've been working with, then it just becomes

22 totally confusing and it starts bringing in

EERE-2008-BT-TP-0008 COMMENT 08
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1 all kinds of products and I notice that within

2 the NOPR Appendix A to Subpart B you place it

3 in removed and reserved status. Well, the

4 problem's going to be that the manufacturer is

5 probably going to look upon DOE to have to

6 expand that appendix tremendously to provide

7 guidance as to all these definitions of what

8 you're interpreting the Subtype I products to

9 be. And so that could have the potential of

10 becoming very large and additional

11 determinations, should multi-speed motors

12 really be included because that's going to be

13 a big hindrance on manufacturers who do a two14 speed motor using two different windings to be

15 able to meet premium efficiency levels. These

16 are things that just technologically become

17 very, very difficult. But I realize it's

18 because we're stuck with this definition and

19 unless we can get something through Congress

20 DOE is still going to have to step in and

21 provide guidance to manufacturers when it's

22 technologically not feasible to meet these

EERE-2008-BT-TP-0008 COMMENT 08
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1 requirements. And so, but can NEMA provide

2 guidance? Well no, because NEMA just defines

3 a general purpose motor and it's very basic

4 and it's the basic definition that we just use

5 for the small motors. That can't settle this

6 issue. But we'd be very interested in how

7 you're going to cover Subtype II within - once

8 you understand what Subtype I really means.

9 MR. LEWIS: We thank you for

10 helping us to understand the problem. To the

11 degree that you can help us with the solution

12 we'd appreciate that as well and your

13 suggestions in written statements. So thanks

14 very much for that.

15 MR. SCHOLAND: Just on that point,

16 Roger - Mike Scholand, again. The definition

17 of electric motor now stricken from

18 regulation, puts it in play for the Department

19 of Energy. And this NOPR proposes a

20 definition for electric motor that simply

21 cites those four motors that are - have tables

22 of efficiency requirements for. Right? DOE

EERE-2008-BT-TP-0008 COMMENT 08
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1 could propose something different. DOE could

2 propose the old definition for electric motor. 

3 DOE could propose, you know. So the

4 definition of electric motor is something that

5 DOE may propose to codify, and your

6 recommendations for what that definition

7 should be - right now, DOE has a proposal on

8 the table on Slide 32 which says it means any

9 of the following four types of motor: a

10 general purpose electric motor Subtype I, fire

11 pump motor, general purpose Subtype II, or a

12 NEMA Design B general purpose electric. DOE

13 could have proposed something else. So please

14 give us your recommendations on how that

15 definition should be structured for electric

16 motor.

17 MR. DAUGHERTY: Roger Daugherty,

18 Baldor Electric. I guess all the

19 manufacturers I believe I can speak for, or

20 NEMA can step in, but I'm sure that they would

21 support getting the old definition back in and

22 building off of that. And if there is a way

EERE-2008-BT-TP-0008 COMMENT 08
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1 that DOE can do that we would certainly

2 encourage it. As I said, our expectation

3 right now is trying to do it through

4 congressional action, but if it's entirely

5 possible that you aren't locked in to just the

6 definition that was in EISA and had to copy

7 that over the way it's presently done -

8 MR. SCHOLAND: There was no

9 definition in EISA for electric motor.

10 MR. DAUGHERTY: Well, okay, I need

11 clarification on that because in EISA Section

12 313(a) Definitions it says the definition is

13 amended by striking Paragraph 13(A) which

14 actually came from EPAct 1992 and replacing

15 that with 13(A) Electric Motor and then it

16 gave Subtype I and Subtype II. Okay, which is

17 the way that it appears the NOPR was created

18 and then during the process DOE moved this

19 fire pump motor and NEMA Design B up which I

20 think I've already covered. I think that

21 should be removed from there. But if there is

22 the opportunity here that we can work with you

EERE-2008-BT-TP-0008 COMMENT 08
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1 to try to get the present covered product

2 definition in and build off of that which is

3 what we're trying to do through Congress then

4 I think it would be everyone's benefit, plus

5 if it does make its way through Congress it's

6 going to make mute everything we've been

7 discussing here today in trying to cover

8 things in abstract ways that will then become

9 much clearer. So I mean, if it's open to us

10 working with you then we're certainly most

11 willing to do so.

12 FACILITATOR RABA: In the back,

13 please? Thank you, Roger.

14 MR. HORNQUIST: Yes, this is Edwin

15 Hornquist, Southern California Edison. I'm

16 just wondering, and this is a question to the

17 manufacturers I suppose. Not understanding

18 the - not knowing specifically what the

19 definition is and trying to come up with the

20 definition the DOE has made a recommendation. 

21 I'm hearing from Roger concerns about the

22 implications of it being a broader definition. 

EERE-2008-BT-TP-0008 COMMENT 08
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1 And you've quoted - I heard you say something

2 about multi-speed motors. In that particular

3 instance I'm curious, should it be expanded to

4 multi-speed motors? Are there any standards,

5 or test standards that a motor, a multi-speed

6 motor could be tested to that could give you

7 an indication of the efficiency that could be

8 - that is technically feasible? So that,

9 again, I'm just trying to - it may not be a

10 bad thing to have a broader definition that

11 includes other motors that are - other than

12 the ones that are currently covered under

13 EPAct. 

14 FACILITATOR RABA: Roger?

15 MR. DAUGHERTY: Roger Daugherty,

16 Baldor Electric. If I could just respond to

17 the questions that were just asked. With

18 respect to multi-speed, the issue is not

19 whether or not you can measure the efficiency. 

20 The efficiency can be measured by IEEE 112

21 Method B the same as it is on a single-speed. 

22 You can do it at both speeds. The issue is

EERE-2008-BT-TP-0008 COMMENT 08
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1 the technological feasibility of being able to

2 create a two-speed motor with the two windings

3 in it so that you only have one winding active

4 at a time. So the amount of copper you can

5 have for that winding is very low in

6 relationship to a normal single-speed motor

7 and be able to achieve a premium efficiency

8 level. So testing efficiency is not an issue

9 here. I mean, we just use the same standard

10 and the manufacturers do that anyway and put

11 a nominal efficiency on it. The problem is

12 bringing those in. So let's say you brought

13 in the multi-speed. Suddenly, since 1992

14 we've had a requirement that a single-speed

15 five-horsepower motor had to meet what we call

16 energy efficient levels, those standards that

17 were published in EPAct. And now in 2007 it's

18 being elevated to premium efficiency, natural

19 course of events as technology advances. 

20 Multi-speed motor which was never covered till

21 2007 potentially now suddenly has to make the

22 whole big jump all the way up to premium

EERE-2008-BT-TP-0008 COMMENT 08
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1 efficiency without having ever going through

2 any lower levels which even themselves would

3 have been difficult to meet. So that's why

4 I'm trying to point out that this thing of

5 all-encompassing general purpose Subtype I is

6 so encompassing, and the requirement that all

7 those have to meet premium efficiency levels

8 is so great that it's going to put a

9 tremendous burden and it may even move

10 products from manufacturer's lists if you have

11 to meet it. And so that becomes a big problem

12 in the marketplace and for users to be able to

13 get motors for their applications.

14 That's why this thing of Subtype

15 II when you try to look at it from present

16 product to what happened with Subtype I being

17 elevated to premium efficiency, now scope of

18 present covered product is increased by

19 including U-frame and Design C and other

20 voltages in 230 or 460. But those have only

21 been brought in to the energy efficient level

22 value. They haven't been required to make the

EERE-2008-BT-TP-0008 COMMENT 08
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1 jump to premium efficiency. They've never

2 been covered product before and now they are

3 being brought in. So it's just the whole

4 concept that there's a lot of designs and

5 motors that one could argue are Subtype I

6 motors that are just out on the fringes and

7 that's where the concern is. And so, yes, if

8 there's the opportunity to work to try to get

9 into 10 CFR Part 431 a structure of definition

10 that builds on the present definition and

11 present covered product and makes this logical

12 progression of efficiency values, then sure,

13 we'll work with you day and night to get that

14 done. 

15 MR. HORNQUIST: Just a follow-up

16 question. This is Edwin Hornquist, Southern

17 California Edison again. Just a question in

18 my mind. Is what you're saying is that you're

19 limited by what EISA says, that the attainable

20 levels of efficiency assuming that the multi21 speed motors cannot attain those efficiencies

22 for a variety of reasons, that including those

EERE-2008-BT-TP-0008 COMMENT 08
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1 would - there's a limitation somewhere in the

2 legislation that would prevent you from

3 creating let's say a separate efficiency level

4 for that category of motors. Is that clear? 

5 In other words, could you have two ratings for

6 two different types of motors, like a multi7 speed rating versus a single-speed rating?

8 MR. LEWIS: Ron Lewis, DOE. The

9 way I understood the input was that the - it

10 comes into the definition and the scope of

11 what's covered here in looking at the

12 parameters or the constraints of the prior

13 definition and that opening it up to just

14 anything and everything was the issue. It

15 wasn't a matter of having separate tables to

16 populate everything. It was a matter of what

17 is covered here, the scope of this. What was

18 the intention of the legislation, the language

19 in there. I'm a little bit curious that

20 legislation doesn't normally happen by

21 accident. If there's any understanding why

22 the definition was struck? Is there - have

EERE-2008-BT-TP-0008 COMMENT 08
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1 you had any background with that in your

2 history of where we are today?

3 MR. BOTELER: This is Rob Boteler

4 from Emerson. I think when we initially

5 started down a path with some of the

6 environmental groups to raise the level to

7 NEMA premium, we did it through legislation

8 and at the time we thought that was the way to

9 do it. And I think we talked about this a

10 little bit amongst ourselves this morning. 

11 Being motor manufacturers, we're all very

12 close to this and we sometimes don't really

13 think a whole lot about these definitions

14 because we live with them every day. And in

15 the course of working with ACEEE and others to

16 draft the language we've kind of followed that

17 same path that everybody knows what a U-frame

18 motor is and everybody understands what a

19 general purpose motor is and we didn't pay

20 attention enough to the details as Roger has

21 pointed out so well of what some of the things

22 would happen. And you know, as manufacturers

EERE-2008-BT-TP-0008 COMMENT 08
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1 and technical people we looked at these

2 definitions and then we passed them along to

3 those people who write legislative language

4 who, kind of to Michael's point a minute ago. 

5 You know, you're not technical people, but you

6 know how to write legislative language, and

7 the language was written, and now we're kind

8 of suffering the results of that because we

9 didn't maybe pay attention to it quite like we

10 should have.

11 FACILITATOR RABA: I have a

12 comment over here from Robert?

13 MR. VAN BUSKIRK: Robert Van

14 Buskirk, Lawrence Berkeley Lab. What I'd like

15 to do is I'd like to try to reframe Mr.

16 Daugherty's question.

17 FACILITATOR RABA: Reframe or

18 rephrase?

19 MR. VAN BUSKIRK: Reframe. 

20 FACILITATOR RABA: Reframe. 

21 Reframe.

22 MR. VAN BUSKIRK: In a way where

EERE-2008-BT-TP-0008 COMMENT 08
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1 it might open up a path forward for DOE. So

2 the way I understand his question is the law

3 as it is currently written has an

4 inconsistency in it. So the definition of a

5 Subtype I because it also includes Subtype II

6 because the definition is so broad it would be

7 inconsistent with the fact that the law sets

8 two different standard levels for Subtype II

9 and Subtype I. That inconsistency - the

10 question is does that inconsistency give the

11 Department leeway to add specificity to the

12 definition of Subtype I for the sake of

13 interpreting the law so that the differences

14 in efficiency levels can make practical sense.

15 MR. KIDO: Michael Kido, DOE. 

16 Certainly if there were elements of vagueness

17 within an existing statute that the agency is

18 responsible for there would be some room for

19 the agency to fill in those gaps. I'm not

20 saying necessarily that's the case here. I'm

21 just saying that's just a general principle of

22 administrative law. And Roger, going back to

EERE-2008-BT-TP-0008 COMMENT 08
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1 your earlier points about the merits of having

2 some sort of addition to the CFR or perhaps

3 having some sort of legislative change, I

4 think that's obviously up to the industry

5 groups to decide what the best and cleanest

6 method is for them to effect whatever change

7 they think is going to be necessary for the

8 agency to promulgate clear efficiency

9 standards for these products.

10 FACILITATOR RABA: Thank you,

11 Michael. Dain?

12 MR. HANSEN: Dain Hansen with

13 NEMA. I just wanted to comment briefly on how

14 we kind of mentioned the vagueness or the

15 unintended consequences of quickly drafted

16 legislation. EISA as we know, this wasn't -

17 there's a lot of portions that need to be

18 corrected within that bill. It's not just

19 this. I mean, there's many, many other

20 pieces. And we've been working with the Hill

21 extensively. So I wanted to make sure the DOE

22 knows that the Hill is working on a technical

EERE-2008-BT-TP-0008 COMMENT 08
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1 corrections bill which would affect the motor

2 provisions. We are working on - the timing of

3 it is unsure. They do want to get it done. 

4 They were hoping to get it done last year, but

5 politically other things came in. But we've

6 actually seen a most recent draft as of last

7 week of what they're going to try to make some

8 further corrections on that.

9 FACILITATOR RABA: Wow. 

10 MR. SCHOLAND: I need to make a

11 correction because I might have misled Roger

12 here, and I want Michael Kido to have a look

13 at Section 313 from EISA and look at

14 definition 13(A) for electric motor. And my

15 question here is in essence to Michael Kido,

16 is that the definition of electric motor? Two

17 parts to the definition, Subtype I and Subtype

18 II? And therefore, what was in our Notice of

19 Proposed Rulemaking proposing four things,

20 actually DOE doesn't have authority to modify

21 what's in the statute and we shouldn't have

22 put that in. What do you think about that?

EERE-2008-BT-TP-0008 COMMENT 08
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1 MR. KIDO: We'll certainly take a

2 closer look at that.

3 MR. SCHOLAND: Okay.

4 FACILITATOR RABA: Good comment,

5 good answer. Molly?

6 MS. TROMBLEY-MCCANN: In the

7 discussion so far - this is Molly Trombley8 McCann for PG&E - we've been talking about

9 this broadening of scope as though it was

10 inadvertent in the writing of EISA. And I'm

11 just wondering particularly to the gentleman

12 from NEMA, do you know if they've been talking

13 about this particular part of the bill and

14 rewriting this particular part of the bill? 

15 Because I don't want to assume it was

16 inadvertent if we don't know that it was.

17 MR. HANSEN: Dain Hansen with

18 NEMA. I'll let Roger mention that because he

19 actually just recently was reviewing portions

20 of the technical corrections bill.

21 MR. DAUGHERTY: Roger Daugherty,

22 Baldor Electric. Yes, the bill that's before

EERE-2008-BT-TP-0008 COMMENT 08
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1 Congress at the present time reinstates the

2 present definition of electric motor that's in

3 EPCA and adds to it the Subtype I and Subtype

4 II underneath of its encompassing definition. 

5 So the Subtype I motor is actually an

6 identification of what we presently just call

7 an electric motor under EPCA and under the

8 present 10 CFR Part 431. So that if we

9 interpreted the language correctly this - the

10 new language then, the present definition

11 would be retained and in its interpretation in

12 10 CFR Part 431, it includes all the IEC stuff

13 and things so that that falls into place. 

14 Then essentially defines that those electric

15 motors now are identified as a Subtype I. And

16 then the standards section says that the

17 efficiency level of a Subtype I, which are

18 really presently covered product, would be

19 elevated to the higher efficiency level. 

20 Then, it broadens the coverage of the present

21 EPCA definition by adding a Subtype II that

22 now pulls in that - while the EPCA definition

EERE-2008-BT-TP-0008 COMMENT 08
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1 says it's T-frame, Subtype II will pull in U2 frame. While the EPCA definition says 230,

3 460 volts, the Subtype II will cover any

4 voltage up to 600 volts. While EPCA says

5 Design A and B, Subtype II will pull in the

6 Design C, et cetera. So the idea was that

7 present covered product that has been

8 certified since the 1997, five years after

9 EPAct was passed, that all those present

10 products and present covered products would be

11 elevated to NEMA premium efficiency levels

12 which is the first paragraph of the standards

13 section in EISA, or EISA, whichever it is. 

14 And then the scope of product would be

15 expanded by pulling in the U-frame and the

16 Design C et cetera under the Subtype II, and

17 that those would be re-carved out in

18 efficiency level. That's what the present

19 levels are for the present covered product,

20 the energy efficient or NEMA Table 12-11. And

21 then the issue of fire pump and the higher

22 NEMA Design B would just stay down in the

EERE-2008-BT-TP-0008 COMMENT 08
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1 standard section. Those are not up in the

2 definition. 

3 So essentially it says the hope is

4 the way the language is written that you just

5 take the present definition, you now identify

6 those as basically a Subtype I, raise the

7 efficiency level, expand the scope with

8 Subtype II, give those efficiency levels. 

9 First pump motors are an exception to the

10 present covered product of raising its

11 efficiency level. Those are to stay where

12 they're presently at and the NEMA Design B for

13 larger horsepower motors that were not

14 presently covered but are a Subtype I. 

15 They're not covered in the standards, they're

16 covered under the definition. So then

17 standards would be established for the larger

18 horsepower levels. But as far as the NEMA

19 Design B general purpose motor goes, it's

20 already under the present EPCA definition. So

21 that's what we're trying to do.

22 FACILITATOR RABA: Sounds like

EERE-2008-BT-TP-0008 COMMENT 08
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1 that EISA has left us with a big challenge and

2 hope we're up to the task to resolve this, but

3 good discussion all around, very helpful. 

4 Deep breath and is it time to move on then? 

5 Please? All right. 

6 MR. SCHOLAND: Okay. We're still

7 in the definition section of the slides and

8 I'm looking at the clock. It's about 15

9 minutes till lunch and I've got seven or eight

10 definitional slides. I'm thinking if we can

11 finish the definitions, take a break for

12 lunch, then come back and pick up on materials

13 incorporated by reference maybe that's a good

14 objective for us. Being cognizant of time and

15 these are great comments.

16 Slide 30, nominal full load

17 efficiency. Here, the change in essence was

18 to update the citation from MG1-1993 to 2006

19 as I had mentioned a little bit earlier before

20 we stepped back. The efficiency values

21 referenced in the table are the same even

22 though the table is slightly reformatted. So

EERE-2008-BT-TP-0008 COMMENT 08
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1 DOE sees no substantive change to the content

2 or the definition here. It's just an update. 

3 Next slide is our good friend

4 basic model which we discussed earlier in the

5 context of small electric motors. Obviously

6 this definition exists for electric motors and

7 DOE is proposing a revision here where the

8 language had previously said one of the 113

9 combinations. You'll see in the definition

10 below I've underscored the new language

11 inserted there - it says "a combination of." 

12 The Department is proposing this change

13 because the changes from EISA coming into

14 effect, there are more than 113. I haven't

15 taken the time to count them, by the way, but

16 I guess that could be done. If having a

17 numerical value is important then we could do

18 that. But we thought the simpler solution,

19 more flexible one, might be to say means a

20 combination of horsepower or standard kilowatt

21 equivalent, number of poles and open or

22 enclosed construction. The same root, as I

EERE-2008-BT-TP-0008 COMMENT 08
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1 understand, not being a lawyer, an engineer,

2 the same legal requirement in terms of the

3 application of the definition of basic model

4 without saying the number 113. We have - Mike

5 Kido, did you want to say something and we'll

6 go to the gentleman from GE?

7 MR. KIDO: You're on the right

8 track, Mike. 

9 MR. HOFMANN: Doug Hofmann, GE. 

10 I'm just wondering, "means a combination of." 

11 Would it maybe be clearer in terms of defining

12 the intent to say, "means one of every - one

13 of each possible combination of?" Just to

14 imply that you're wanting to capture every

15 combination possible of the characteristics. 

16 That it's not necessarily a subset. If that's

17 the intent of what you're wanting to codify

18 here.

19 MR. SCHOLAND: Means each and

20 every combination.

21 MR. HOFMANN: Well, one of each

22 and every combination. So a basic model is

EERE-2008-BT-TP-0008 COMMENT 08
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1 one of each and every combination possible. 

2 FACILITATOR RABA: I see nods for

3 just acceptance of the comment. We will take

4 it under advisement. Okay, thank you. Thank

5 you very much. 

6 MR. SCHOLAND: Other comments on

7 basic model before we move on? I might point

8 out just for the record that this does include

9 the language, you know, electrical

10 characteristics that are essentially

11 identical. That was a little bit

12 controversial in small electric motors and if

13 you're making comments on that definition,

14 obviously they would apply here too. So, both

15 definitions are in play in this rule. Okay,

16 let's look at the definition for electric

17 motor. We have already spent some time

18 discussing this. The NOPR proposes a

19 definition that we thought would fill a gap,

20 and DOE is going to look at again whether

21 there is a definition of the statute that

22 actually would apply here instead. So that's

EERE-2008-BT-TP-0008 COMMENT 08
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1 going to be - go ahead, Michael Kido.

2 MR. KIDO: Just briefly. I have

3 taken a quick look at the statutory provisions

4 for electric motor and from what I could tell

5 it's defining particular classes of electric

6 motors. So to the extent that, you know,

7 folks here have comments concerning what DOE

8 should do about the definition of electric

9 motor, if you have suggested definitions and

10 how we should go about it, I would strongly

11 encourage you to submit those in your written

12 comments.

13 MR. SCHOLAND: Okay. Slide 33 is

14 the issue for comment where we say what

15 Michael just said.

16 FACILITATOR RABA: A comment

17 first. Excuse me, Michael. 

18 MR. BASSO: Yes, this is Dale

19 Basso, Weg. Does Slide 32 imply that there's

20 another column on Slide 31's definition? 

21 Meaning subtype? When you're trying to define

22 what the basic model is. Does the basic model

EERE-2008-BT-TP-0008 COMMENT 08
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1 also have multiple basic models depending on

2 the subtype now?

3 FACILITATOR RABA: Slide 32 is -

4 MR. BASSO: Oh okay, never mind. 

5 The basic model - the basic model didn't have

6 subtype referenced. It was only horsepower,

7 speed and enclosure. That would now - if, and

8 maybe I'm thinking ahead to the definition

9 that's coming, but when that definition comes

10 and you've got a Subtype I, Subtype II, there

11 would have to be another column in that table

12 to define it, correct?

13 MR. SCHOLAND: That seems to make

14 sense.

15 FACILITATOR RABA: I see nods

16 also. Roger Daugherty, over there in the

17 back.

18 MR. DAUGHERTY: Roger Daugherty,

19 Baldor Electric. I would suggest that if you

20 look at what you proposed for the small motors

21 in what a basic model was, that you included

22 an item that was called a group as being a

EERE-2008-BT-TP-0008 COMMENT 08
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1 polyphase or capacitor-start induction-run, or

2 capacitor-start capacitor-run. That it may be

3 worthwhile here that you include a group and

4 within that group identification, that's a

5 good place to enter this issue of the fire

6 pump and NEMA Design B general purpose, that

7 those are a grouping under the same identity

8 as that term is used in the small motors

9 proposal. And that may be all you need to add

10 to this, the group item.

11 MR. SCHOLAND: Thank you. 

12 MR. HOPKINS: Asa Hopkins,

13 Lawrence Berkeley Lab. I think that there's

14 a little bit of confusion between the

15 difference between basic model and rating. 

16 The definition change that we're discussing

17 was defining rating rather than basic model,

18 and the difference between Subtype I and

19 Subtype II might come up in the phrase, "that

20 do not have any differing physical or

21 functional characteristics which affect energy

22 consumption or efficiency." That Subtype II

EERE-2008-BT-TP-0008 COMMENT 08
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1 may have such differing physical or functional

2 characteristics, so they might end up covered

3 there. But I agree with Roger that a group

4 idea might make sense.

5 MR. SCHOLAND: Okay. Slide 32 we

6 did. Issue 4, DOE is looking for comments. 

7 Fire pump motor. DOE in recognizing that

8 there was a table of efficiency standards for

9 fire pump motors and no definition in the

10 definition section is proposing in today's

11 notice to have a definition. DOE was unable

12 to locate a definition for fire pump motor

13 that was sort of commonly used in industry,

14 IEEE or otherwise. And we found a scope

15 statement in a UL document about fire pump

16 motors, UL Standard 1004A-2001. And it seemed

17 like a reasonable definition and that's how it

18 ended up in the NOPR with a couple of minor

19 revisions. DOE added a reference year to the

20 National Fire Protection Association Standard

21 20 to make sure that was locked in, and I seem

22 to recall that the title of that standard in

EERE-2008-BT-TP-0008 COMMENT 08
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1 the UL document was slightly different, was

2 not the 2007 title, and so the title was also

3 changed. But otherwise that's the definition

4 on the table and we invite comment. It's Key

5 Issue Number 5 on fire pump motor. Roger?

6 MR. DAUGHERTY: Roger Daugherty,

7 Baldor Electric. I'd just like to make the

8 Department aware that while this proposed

9 definition goes up to 500 horsepower, again

10 it's open to interpretation, but since the

11 fire pump motors are included in the standards

12 as an exception to the standards of the

13 Subtype I, it would appear that the standards

14 are only establishing efficiencies for 1 to

15 200 horsepower, and it's not establishing

16 standards for up to 500 horsepower. 

17 FACILITATOR RABA: Thank you for

18 the observation. Mike?

19 MR. SCHOLAND: Okay. Any other

20 comments on fire pump motor? The lunch bell

21 is ringing.

22 FACILITATOR RABA: We have a

EERE-2008-BT-TP-0008 COMMENT 08
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1 comment over here.

2 MR. SCHOLAND: Thank you.

3 MR. LADONNE: Frank Ladonne,

4 Underwriters Laboratories. This is just more

5 of an editorial comment. The reference to UL

6 1004A, actually that standard has been

7 replaced by 1004-5 and what we did to - one of

8 the changes that was made, certainly not the

9 only change that was made, to get away from

10 the problem of needing to update the standard

11 every time NFPA 20 changed was that we don't

12 reference the revision. We're assuming that

13 NFPA 20 is always going to be the guiding

14 standard for fire systems, so it's simply

15 referenced as NFPA Standard 20. 

16 MR. SCHOLAND: Oh, I see. That's

17 why you didn't include the year.

18 MR. LADONNE: Right.

19 MR. SCHOLAND: Okay. I think for

20 the Department of Energy because this becomes

21 a regulatory definition, they do need to lock

22 in on a year. Otherwise they would be

EERE-2008-BT-TP-0008 COMMENT 08
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1 extending regulatory authority to the NFPA and

2 then if the NFPA modified something then that

3 could affect what was covered or not covered

4 as the fire pump. So DOE does lock in on a

5 year intentionally. 

6 MR. LADONNE: Okay.

7 MR. SCHOLAND: Just so you know.

8 FACILITATOR RABA: Comment from

9 GE.

10 MR. HOFMANN: Doug Hofmann, GE. 

11 Noticing Slide 34 the definition of fire pump

12 motor says rated 500 horsepower, less than on

13 Page 35. In the box it says 200 horsepower. 

14 So I'm getting a little lost in the NOPR here. 

15 Which is it?

16 MR. SCHOLAND: I know, I know, I'm

17 sorry for that typo. That actually appears in

18 our Notice too, embarrassingly enough. I wish

19 it hadn't happened.

20 MR. HOFMANN: So what is the

21 actual rating?

22 MR. SCHOLAND: Well, the - I think

EERE-2008-BT-TP-0008 COMMENT 08
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1 that right now - I guess I'd have to ask

2 someone who is familiar with the en masse

3 standard what does the table look like for

4 fire pump motor efficiency standards that's

5 being put out in the Federal Register now for

6 passage? Because when I went back and looked

7 at the NEMA table of - Table 12-11 it does go

8 up through 500. And so - and you know, I

9 don't see any language in the EISA paragraph

10 here that constrains fire pump motors to 200

11 horsepower unless you interpret it as a subset

12 of Subtype I which I don't know that that

13 happened. And that's why I say we might want

14 something familiar, maybe during lunch someone

15 can check with the draft that's over there and

16 we can respond to that question after the

17 break.

18 MR. BASSO: Let me - I may comment

19 in that the fire pumps were held back to the

20 current EPAct level was the intention because

21 it's a pump that never runs, hopefully. But

22 the whole point is it was only covered in 200

EERE-2008-BT-TP-0008 COMMENT 08
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1 horsepower in the past. Under the new way

2 we're also now including motors above 200 to

3 500 horsepower. They're at an EPAct level. 

4 So the truth is it doesn't matter which way

5 you interpret it, the level is going to be the

6 same. It's the old EPAct level and the new

7 EPAct level going up is not the NEMA premium

8 level on new product. 

9 MR. DAUGHERTY: Roger Daugherty,

10 Baldor Electric. But to answer your question

11 about what's presently being proposed. What's

12 presently being proposed is no change in the

13 standards section, the proposals in the

14 definition section. So it still applies that

15 fire pump motors are in the standards because

16 they're called forth by EISA paragraph (A)

17 that says, "Except as provided in subparagraph

18 (B), each general purpose electric motor rated

19 1 horsepower to 200 horsepower." So it

20 depends on your interpretation that the

21 purpose of the fire pump was to define a

22 different efficiency level for that same range

EERE-2008-BT-TP-0008 COMMENT 08
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1 of horsepowers for which the efficiency level

2 was being increased in Paragraph A. So one

3 interpretation would be that that limits them

4 to the 200 horsepower level.

5 MR. LADONNE: I wasn't going to

6 make this comment, but my colleague from Weg

7 opened the door. I was kind of scratching my

8 head. I'm not sure why we're considering fire

9 pump motors at all. It seems to me that,

10 again, this is a product that is designed to

11 operate when a building catches fire. So we

12 may be adding cost to these products without

13 having any significant effect on national

14 energy consumption.

15 MR. LADONNE: Well, the problem is

16 they're already covered -

17 MR. LEWIS: Excuse me. Will you

18 please give your name so that the transcript

19 here is - we need to identify who's speaking.

20 MR. LADONNE: Sorry. That was

21 Frank Ladonne, Underwriters Laboratories. 

22 MR. BASSO: And Dale Basso.

EERE-2008-BT-TP-0008 COMMENT 08
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1 FACILITATOR RABA: One thing about

2 the fire pump motors. I hear a lot of

3 concern, a good discussion, very enlightening

4 in many respects. Would also encourage

5 perhaps looking at it circumspectly that while

6 we're looking at standards and levels and

7 coverage under EISA, maybe look also, just a

8 thought, to what both NFPA and UL say about

9 that particular piece of equipment so that

10 they all include what EISA, the other safety11 minded standards have in place. Plus we have

12 here in the table - to make it work

13 effectively. Roger? I'm sorry, who's first. 

14 Okay.

15 MR. KIDO: Michael Kido, DOE. I

16 just wanted to point out in response to the

17 comment earlier about why we're including fire

18 pump motors. It just happens to be one of

19 those things that's in the statute, so we're

20 just going through the process. I think as

21 Roger had pointed out earlier and with respect

22 to another provision, well, why isn't this

EERE-2008-BT-TP-0008 COMMENT 08
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1 particular statutory provision being codified,

2 you know, within this particular rulemaking. 

3 That's actually what we're doing here with

4 respect to fire pump motors. We're just

5 essentially taking what Congress has given us

6 and adding clarification to the CFR.

7 MR. DAUGHERTY: Roger Daugherty,

8 Baldor Electric. Just to respond as to why

9 they're covered. Remember, this is back in

10 1992 when EPAct was passed and modified EPCA. 

11 And it specified that it's NEMA Design A and

12 B general purpose motors. And at that time a

13 fire pump motor specified to be a NEMA Design

14 B general purpose motor. That's the motor

15 that is being put in the application. So that

16 motor was automatically covered under the

17 basic definition. So the concern here was in

18 2007 of not requiring those motors which were

19 covered by the basic definition of having to

20 be elevated to the NEMA premium levels because

21 as everyone knows hopefully these things never

22 run. So there's really no reason to have to

EERE-2008-BT-TP-0008 COMMENT 08
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1 elevate them to the premium levels.

2 FACILITATOR RABA: Two more

3 slides. Keep going?

4 MR. SCHOLAND: Okay.

5 MR. HORNQUIST: Just, can I make

6 just a comment?

7 MR. SCHOLAND: Yes, please. We

8 need your name.

9 MR. HORNQUIST: Edwin Hornquist,

10 Southern California Edison. I guess the

11 concern in my mind would be that because it is

12 pretty much a standard motor that if it's not

13 covered it would, for some reason it wouldn't

14 be covered by virtue of the way the

15 definitions come about, and if it's not called

16 out specifically, that you could potentially

17 use that motor in a different application and

18 it would be a lower efficiency motor that

19 would be in the market. It would be -

20 potentially being used. Is that a

21 possibility?

22 MR. HOFMANN: Doug Hofmann at GE. 

EERE-2008-BT-TP-0008 COMMENT 08
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1 The way I'm reading this we're going to have

2 Design B motors with a UL 1004-5 certification

3 which might cost you an extra fifty bucks

4 that's able to be used in any application. So

5 you'll have a - you'll be able to buy probably

6 a cheaper motor that's called a fire pump

7 motor and use it anywhere. That's what's

8 going to happen under the new EISA

9 regulations. You'll be able to buy an EPAct

10 level efficiency when NEMA premium is now

11 being required everywhere else. And you can't

12 avoid that with the way the legislation is

13 written.

14 FACILITATOR RABA: Comment from

15 UL?

16 MR. LADONNE: Yes. I recognize

17 the potential loophole that exists. I mean,

18 I think it's very small because typically fire

19 pump motors are designed for a specific

20 purpose. But that same sort of loophole I

21 think potentially exists when we talk about

22 motors. There's an exemption up in the very

EERE-2008-BT-TP-0008 COMMENT 08
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1 front of the document that's an exemption for

2 motors that are covered by appliance standards

3 such as, you know, air conditioning motors and

4 so on and so on. Very possible for

5 manufacturers to manufacture motors, you know,

6 without knowing what the intended end use is

7 going to be, okay? So that same kind of

8 loophole potentially exists. But I think it's

9 less of a risk on the fire pump side because

10 those are typically, you know, purpose-built. 

11 FACILITATOR RABA: Okay, thank

12 you. Now, two slides. Oh, sorry. One more.

13 MR. LEWIS: Ron Lewis, DOE. Just

14 to address that comment. Hopefully in our

15 development of appliance standards, the

16 standards are stringent enough for the overall

17 system efficiency that it closes that loophole

18 for the component to not be efficient. So I'm

19 not sure that that's a great concern. We're

20 considering the efficiency of the entire

21 system and those appliances that are covered.

22 FACILITATOR RABA: So we

EERE-2008-BT-TP-0008 COMMENT 08
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1 extinguish the fire, we save the structure and

2 we save energy. Rob then Roger.

3 MR. BOTELER: This is Rob Boteler. 

4 I'd just comment on Ron's comment on appliance

5 motors. Those are really sold to the

6 appliance manufacturer. They're really not

7 sold into the open market. So the likelihood

8 that - we're talking about fractional

9 horsepower motors. So the motor that's used

10 in your washing machine is not going to go

11 into some other application. We're going to

12 sell that to the Maytags of the world.

13 MR. DAUGHERTY: Roger Daugherty,

14 Baldor Electric. If you go back to EPAct and

15 you look at the present standards as they're

16 written in 10 CFR Part 431 with regards to the

17 medium electric motors EPAct was very clear

18 including the statement that the standards

19 cover each electric motor manufactured alone

20 or as a component of another piece of

21 equipment. That became a very contentious

22 issue as DOE was writing rules and regulations

EERE-2008-BT-TP-0008 COMMENT 08
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1 because the air conditioning unit was asking

2 why they had to be putting motors that had to

3 meet these standards into their equipment when

4 their equipment was covered under its own

5 requirement. And so while they could obtain

6 their requirement by total design of the

7 system, they were now handicapped by having to

8 use a motor that met these efficiency levels

9 and I believe you'll find that the DOE ruled

10 that because it was written in the law that

11 those motors had to meet those requirements. 

12 So these motors regardless of where they're

13 used are covered and there's no end use

14 product exemption for those motors.

15 MR. SCHOLAND: I just want to make

16 a point of clarification. Small electric

17 motors are different from what we're talking

18 about here.

19 MR. DAUGHERTY: That's a different

20 statute.

21 MR. SCHOLAND: Right. Small

22 electric motors that are in covered equipment

EERE-2008-BT-TP-0008 COMMENT 08
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1 as Ron has mentioned are not covered under the

2 small electric motor standard, should there be

3 one. But electric motors we're talking about

4 here in this test procedure, they are, no

5 matter where they go. That's correct. 

6 Okay. Last two slides. This is

7 the definition for NEMA Design B, general

8 purpose electric motor. In essence DOE based

9 its proposal on the definition that's in MG1-

10 2006 with three minor changes. Excuse my

11 slide there. The reference to 50Hz, a

12 frequency that made no sense because DOE is

13 only covering 60Hz. So that was taken out. 

14 The maximum slip in MG1 as I recall extends to

15 10 poles and higher, but DOE is only

16 regulating 2 through 8. So the language was

17 modified to simply say "fewer than 10 poles." 

18 And then finally I think there was a cross19 reference error in MG1-2006 that the locked20 rotor current was referencing 12-35.3 and it

21 should have been 12-35.1. So with those

22 modifications the definition appears at the

EERE-2008-BT-TP-0008 COMMENT 08
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1 bottom of Slide 36 and 37 is a key issue for

2 comment from stakeholders on that proposed

3 definition. Roger?

4 MR. DAUGHERTY: Roger Daugherty,

5 Baldor Electric. I would like to encourage

6 the DOE not change the NEMA definition by not

7 striking the 50Hz. Just one, for the purpose

8 of maintaining the definition. Second, if you

9 do a literal interpretation of EISA as it was

10 passed, there's nothing in there about 60Hz. 

11 If you have proposed removing the present

12 EPAct definition of electric motor, then 10

13 CFR Part 431 as you proposed it makes no

14 reference to 60Hz as being the only covered

15 products. So, but the main interest is let's

16 not change an industry definition that's been

17 around for many, many years just because maybe

18 a 50Hz doesn't apply. If it doesn't apply it

19 just ends up not applying, but let's not

20 change the definition. 

21 MR. SCHOLAND: Excuse me, just

22 point of clarification. Can you comment on

EERE-2008-BT-TP-0008 COMMENT 08
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1 the cross reference to the table?

2 MR. DAUGHERTY: Cross references,

3 I'd say those are typographical errors and we

4 will correct them in the standard as they're

5 pointed out to us.

6 MR. SCHOLAND: Could DOE use the

7 correct one?

8 MR. DAUGHERTY: Yes. Roger

9 Daugherty, Baldor Electric. Yes. 

10 MR. SCHOLAND: Small victories.

11 FACILITATOR RABA: It's all good.

12 MR. SCHOLAND: Okay, I think it's

13 - if there's no other issues or comments on

14 definitions we'll take a break for an hour for

15 lunch and continue on Slide 38 when we come

16 back. Jim, do you want to tell people where

17 to go?

18 FACILITATOR RABA: You mean where

19 to have lunch.

20 MR. SCHOLAND: And the fact that

21 this room will be secure. The door will be

22 locked while we're out so if you need to leave

EERE-2008-BT-TP-0008 COMMENT 08
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1 your computer or other things behind it's -

2 they will be safe.

3 FACILITATOR RABA: Thank you very

4 much. Good discussion. A lot of good input

5 all around. Sounds like we're all kind of on

6 the same page, same table with all this. So

7 keep it up and we'll hear more this afternoon. 

8 Back at 1:15 sharp.

9 (Whereupon, the foregoing matter

10 went off the record at 12:15 p.m. and resumed

11 at 1:24 p.m.)

12 FACILITATOR RABA: So we shall

13 proceed where we left off. And I think we

14 should jump out of the slides now. About

15 affectionately known as IBRs, incorporations

16 by reference, and Michael Scholand. Go ahead,

17 sir.

18 MR. SCHOLAND: Okay. Thank you,

19 Jim. We're picking up again on Slide 38

20 titled Materials Incorporated by Reference. 

21 In essence this and the next few slides we

22 kind of talk about changes to the existing

EERE-2008-BT-TP-0008 COMMENT 08
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1 section of Code of Federal Regulations for

2 this product where some material that's no

3 longer needed is proposed to be deleted. 

4 Other places we are updating citations and

5 rationalizing that. The detail, and this is

6 I think an important point. The slides give

7 you kind of a 30,000-foot view on it. The

8 real detail comparison where DOE sat down with

9 the old version, referencing the CFR, and the

10 new versions and did side-by-side comparisons

11 and then wrote about it, you know, that's in

12 Section III(c) of the NOPR. So we suggest

13 here that's best reviewed with copies of the

14 old and new industry standards and the CFR if

15 you want to do that same side-by-side

16 comparison for yourselves.

17 These are versions where primarily

18 non-substantive changes. Mainly in this

19 section incorporated by reference we're taking

20 NEMA MG1-1993 and adjusting it to MG1-2006,

21 but there's also adjustments for obviously CSA

22 and IEEE as well. And certain IEC standard

EERE-2008-BT-TP-0008 COMMENT 08
Page 163

1 references were deleted because they're no

2 longer needed since certain provisions were

3 changed, you know, deleted by EISA 2007. And

4 again, I mentioned here that all the changes

5 were compared side-by-side for the Department

6 and the detailed comparisons were in Section

7 III(c).

8 So let's just go to a couple of

9 specifics on Slide 39, MG1-2006 with Revision

10 1, Paragraph 12.58 extends the upper limit of

11 recovered horsepower. I believe the previous

12 version only went to 400 horsepower. Now it's

13 500. So that was sort of a little change. 

14 Paragraph 12.58.2 addresses labeling

15 requirements. Table 12-10 was the one where

16 the efficiency values stayed the same, but the

17 table was renumbered. And Paragraphs 14.2 and

18 14.3 were renumbered paragraphs, but the

19 content of those paragraphs stayed the same. 

20 So those are some examples. The IEEE

21 standard, it stayed with I think it's Test

22 Method B, IEEE 112-96 stayed with Test Method

EERE-2008-BT-TP-0008 COMMENT 08
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1 B in 112-2004. And then the Canadian standard

2 went from the 1993 edition to 1998, revised

3 2005. And then we mentioned here some of the

4 IEC standards that were deleted, and that was

5 a result of the EISA 2007, removing the term

6 "electric motor" inadvertently. Comments? Go

7 ahead.

8 FACILITATOR RABA: Roger

9 Daugherty, Baldor Electric. 

10 MR. DAUGHERTY: Roger Daugherty,

11 Baldor Electric. With respect to the IEC, I

12 just note that if you look in the NOPR at

13 431.15(b)(4) the IEC reference is still there

14 to 60034-1.

15 MR. SCHOLAND: What's that page

16 again?

17 MR. DAUGHERTY: 431.15(b)(4)

18 MR. SCHOLAND: And which IEC

19 standard is still there?

20 MR. DAUGHERTY: 60034-1.

21 MR. SCHOLAND: Okay.

22 MR. DAUGHERTY: Then based on our

EERE-2008-BT-TP-0008 COMMENT 08
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1 discussion this morning about the desire that

2 IEC motors continue to be considered covered

3 products, then you'll probably need to revisit

4 this and restore these deletions.

5 MR. SCHOLAND: Okay. 

6 FACILITATOR RABA: May I chime in

7 also too. I think you raised a good point,

8 Roger, about 431.15. Note also that those are

9 also provisions I think that are used for

10 laboratory accreditation and other criteria

11 too. So there may be a double use there. So

12 I would appreciate - I think the Department

13 would appreciate comments back on the actual

14 coverage. And also refer to NIST Handbook 150

15 and 150-10 for electric motors because I think

16 there's some reference in the later section of

17 the CFR that discusses the criteria for

18 national recognition of accredited

19 laboratories and certification programs on the

20 regs that call out some of them, those the IEC

21 - in a separate venue, not necessarily

22 definitional, but rather for criteria for

EERE-2008-BT-TP-0008 COMMENT 08
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1 examining motors. So there may be a double

2 thing there to take a look at as well and

3 would appreciate comments back on that study

4 also. NIST Handbook 150 is the general and

5 NIST 150-10 is the electric motors. Both are

6 online on the web. Thank you. 

7 MR. SCHOLAND: In fact, 150 is

8 called Procedures and General Requirements,

9 February 2006, and 150-10 is Efficiency of

10 Electric Motors, February 2007. Yes, go

11 ahead.

12 MR. DAUGHERTY: Roger Daugherty,

13 Baldor Electric. Just while you mention it,

14 Jim, while the 150-10 handbook is available

15 online, I'm having trouble trying to find the

16 checklist that - in the original version of

17 the handbook it did tell all the laboratory

18 test requirements and the test procedures. 

19 The new version doesn't contain anything about

20 test procedure that is to be used for

21 accreditation and it's all obviously appears

22 to be embedded off in some checklist which you

EERE-2008-BT-TP-0008 COMMENT 08
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1 can't get a copy of that I found on the

2 website. So if you have a link to that or

3 something and you could provide it, it would

4 certainly help out.

5 FACILITATOR RABA: Yes, I will

6 look at - the team will look for that. But

7 indeed we value your comments as well. 

8 Please, I went online the other day myself and

9 looked around. I saw it listed there. I did

10 not click on the link to see if it actually

11 connected, so you raise a valid issue and the

12 team will examine that. The DOE team.

13 MR. SCHOLAND: Here's another

14 option perhaps, Jim. Roger, you could tell

15 the Department what should that checklist look

16 like and instead of cross-referencing a

17 document that varies from year to year, DOE

18 would then have in the CFR the checklist for

19 what is an accredited laboratory. Make sure

20 you - no?

21 MR. DAUGHERTY: Roger Daugherty,

22 Baldor Electric. As I understand it the

EERE-2008-BT-TP-0008 COMMENT 08
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1 checklist is created by NVLAP/NIST as a part

2 of the accreditation program in a way that

3 they examine a test facility to accredit that

4 test facility. So all I'm asking is that when

5 they rewrote the new version of the handbook,

6 they made a statement in it that they no

7 longer include any of the items of the

8 checklist which includes the national test

9 procedure to - because that way they didn't

10 have to update the handbook when they wanted

11 to change an item in the checklist. So the

12 problem now to a manufacturer who wants to

13 check up on any revisions of the NVLAP

14 accreditation program, if you pull up the

15 handbook you no longer get all the

16 requirements for accreditation which include

17 the accuracy of all your meters, the exact

18 test procedure you have to follow and

19 everything else. That's off in something that

20 you now can't obtain. So I was just asking if

21 since you're aware of that checklist if you

22 know how to get to it. It would be a good

EERE-2008-BT-TP-0008 COMMENT 08
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1 benefit.

2 FACILITATOR RABA: Okay, thank you

3 for making us aware of that, the Department

4 aware of that. Good, good.

5 MR. SCHOLAND: All right. I guess

6 the next slide here. DOE updated - this is

7 just an FYI, really - updated contact

8 information for organizations that provide

9 copies of the reference material that's

10 incorporated by reference. So just mentioned

11 here that NEMA contact information is now

12 proposed to be inserted into the CFR for MG1.

13 I think there were some minor changes, a phone

14 number and a website or something like that,

15 but in essence just to make it easier to

16 access the data. 

17 This next slide talks a little bit

18 about the issue we were just on, laboratory

19 accreditation and labeling. Here DOE is

20 proposing to update references to standards

21 documents that were provided for information

22 and guidance and these form the basis of the

EERE-2008-BT-TP-0008 COMMENT 08
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1 nationally recognized laboratory accreditation

2 program. These references are, you know, the

3 NVLAP program handbooks we just mentioned, 150

4 and 150-10 and the ISO, IEC guides. So you

5 can find those listed in the Notice, the

6 current versions that are being proposed

7 there. The next bullet talks about - sorry,

8 is about the 150 and the 150-10. And this is

9 discussed in Section III(e) of the NOPR and we

10 have page numbers there for you on that

11 bullet. And then finally DOE proposes to

12 update some of the citations in this section

13 to the current version of MG1. And obviously

14 that's to maintain consistency between DOE and

15 current industry practice.

16 The next slide touches on an issue

17 which we sort of have discussed earlier. 

18 Appendix A to Subpart B is a, quote, "Policy

19 statement for electric motors covered under

20 the Energy Policy and Conservation Act." And

21 I understand that it was a policy position or

22 an interpretation of covered motors, the 1 to

EERE-2008-BT-TP-0008 COMMENT 08
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1 200 horsepower range, that was developed

2 through a rulemaking process that DOE managed

3 with input from stakeholders. Essentially

4 when DOE was looking at this appendix after

5 EISA had passed what do you do with it? 

6 Because the question came up, you know, the

7 horsepower reading ranged - changed. Now

8 there were new motors that were covered in the

9 Subtype II. There were issues where the

10 definition of electric motor was stricken,

11 perhaps unintentionally so. And this was

12 providing interpretation of that work, of that

13 definition that was now gone. So DOE is

14 proposing in the NOPR to delete the policy

15 statement in essence because EISA has

16 broadened the scope of coverage and EISA

17 deleted the term "electric motor" from the

18 statute. So DOE felt that this was the most

19 appropriate action.

20 DOE put a statement reserved in

21 there in place of what policy statement was

22 there. So Appendix A would still exist in the

EERE-2008-BT-TP-0008 COMMENT 08
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1 CFR. It would simply say "reserved." And the

2 thought there is that DOE may need to develop

3 a new policy statement with stakeholders which

4 would help to clarify issues of coverage and

5 scope based on the new EISA definitions. So

6 the idea there is not to totally kill Appendix

7 A, but to preserve it in the event that it

8 needs to be revisited. So that was that.

9 And now I'll shift and talk about

10 the test procedure for electric motors, Slide

11 43. DOE proposed making the following updates

12 to documents referenced. MG1-1993 is shifting

13 to become MG1-2006 with Revision 1, the IEEE

14 standard 112-1996 Test Method B becomes 112-

15 2004 Test Method B, and finally CSA Standard

16 C390-93 Test Method 1 becomes 390-98 Revision

17 2005 Test Method 1. And then I say again, DOE

18 conducted a careful paragraph by paragraph

19 review of the sections referenced and

20 concluded that these updates will not have a

21 substantive impact on the measured efficiency

22 value. Again, details of these comparison can

EERE-2008-BT-TP-0008 COMMENT 08
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1 be found in Section 3(g) of the NOPR. And any

2 comments? Have people had a chance to look at

3 3(g)? And if not, please do. Comments of

4 whether you agree or disagree with the

5 Department's position. Roger?

6 MR. DAUGHERTY: Roger Daugherty,

7 Baldor Electric. Just a question that occurs

8 to me here. You're making reference to MG1-

9 2006. Other places you are including Rev 1. 

10 Is the intent to make everything be Rev 1, or

11 are you planning to use a mixture of

12 reference?

13 MR. SCHOLAND: No. I think - 

14 FACILITATOR RABA: That was put in

15 probably for consistency. What makes sense. 

16 Your comments on that, please. Would it be

17 2006?

18 MR. DAUGHERTY: Well - Roger

19 Daugherty, Baldor Electric. I mean, I

20 recommend Rev 1. There's probably not

21 significant changes that I can remember

22 between Rev 1 and the 2006 version with

EERE-2008-BT-TP-0008 COMMENT 08
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1 regards to those paragraphs that are cited

2 here.

3 MR. SCHOLAND: Right.

4 FACILITATOR RABA: So Rev 1 is the

5 current edition and probably should be cited. 

6 That's your comment. Thank you. 

7 MR. SCHOLAND: Okay. Now let's

8 talk in a little more detail on each of the

9 industry standards. Slide 44 flags first NEMA

10 Standard MG1, the update there. We identified

11 a change at the upper horsepower limit for

12 Paragraph 12.58.1 is extended for 400 to 500

13 horsepower. And that actually was a

14 convenient change because it's consistent with

15 the EISA 2007 coverage of the Subtype II

16 motors. It's also consistent with the IEEE

17 and - sorry, the updated version of MG1 is

18 consistent with IEEE and the CSA test

19 procedures.

20 In the CSA update, we did a side21 by-side paragraph comparison. Just found

22 minor editorial rephrasing of sentences,

EERE-2008-BT-TP-0008 COMMENT 08
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1 slight wording changes, but nothing of any

2 substantive impacts. Slide 45. IEEE 112

3 moved some of the discussion on specified

4 temperatures and methods of determining

5 temperature were moved to different sections. 

6 There is some discussion of no-load tests,

7 some discussion of termination tests,

8 discussion concerning temperature for distance

9 correction and the correction of the

10 definition of (k2) and a discussion of the

11 value of the corrected slip. Those

12 discussions were all added and I think those

13 were - trying to recall now. I think those

14 were corrections that DOE had written in

15 originally that IEEE adopted. And so ergo,

16 the next bullet DOE proposes to delete several

17 of those corrections since the new version of

18 IEEE had adopted that language. Which was

19 great. And then - so there were just three

20 corrections that were retained by the

21 Department updating some of the cross22 references that had moved around in Appendix

EERE-2008-BT-TP-0008 COMMENT 08
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1 B to Subpart B and Paragraphs 2(i), (v) and

2 (vii) were the ones that were kept. 

3 So, that brings me smoothly to the

4 last of the seven key issues for comment,

5 which is updates to the electric motor test

6 procedure. Were those the right three to

7 keep? Was it okay to delete the other five? 

8 Have people had a chance to kind of address

9 the Department's proposal? Any comments or

10 discussion at this point on the provisions in

11 the test method? Okay.

12 All right, moving right along. 

13 There's only three slides in this section. 

14 Basically I just called this Other Updates to

15 the CFR. These were issues that as we were

16 going through it we found - oops, this number

17 isn't right, and so we're proposing

18 corrections to the definitions of the terms

19 "Act," "covered equipment," and "EPCA." Slide

20 49 shows previously the definition of the term

21 "Act" didn't include Section 6317 of the

22 United States Code which is actually the part

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1 of the code that includes small electric

2 motors. So the Department is proposing a

3 correction to extend to include 6317,

4 previously 6316. 

5 Covered equipment. You know, we

6 added a cross-reference to small electric

7 motors since they're now covered. So covered

8 equipment is a term defined in the Subpart A

9 general provisions. And we added the

10 statement, "Or small electric motor as defined

11 in 431.342," which is the proposed section in

12 Subpart T for small electric motors. And

13 finally "EPCA" had the same problem as "Act." 

14 It didn't include 6317. So pretty non15 controversial.

16 Slide 50, determination of

17 efficiency. Here we propose to update the

18 introductory paragraph to eliminate a risk of

19 confusion. I think it was the Energy

20 Independence and Security Act that did this,

21 but it used to be Part C and it got moved to

22 Part A(1). I can't remember if it was EPAct

EERE-2008-BT-TP-0008 COMMENT 08
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1 05 or if it was EISA. It was EPAct 05 that

2 did that? So, anyway, we changed the

3 reference EPCA to - in that introductory

4 paragraph to Part A(1). The U.S. Code

5 citation again had stopped at 6317. It should

6 have included - sorry, 6316. It should have

7 included 6317. And then there was a cross8 reference error that was pointing to 431.192

9 and it should have been 431.383. So these are

10 changes that are really just corrections to

11 editorial things if you will. The revised

12 paragraph appears there and you can compare

13 that to what's in the introductory paragraph

14 of 431.17 today to see exactly what the

15 changes were. And that's it. We go to

16 closing remarks and our discussion.

17 FACILITATOR RABA: I have a hand

18 over here.

19 MR. SCHOLAND: Excellent. Roger.

20 MR. DAUGHERTY: Roger Daugherty,

21 Baldor Electric. Yes, while you're covering

22 these references and things I'll just note

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1 that when I looked up in the NVLAP Handbook

2 150-10 it refers to IEEE 112-1996 version and

3 it refers to NEMA MG1's 1993 version as being

4 those which are used for accreditation. You

5 may wish to correspond with NVLAP on whether

6 they wish to update theirs to the present

7 versions as you're updating to present

8 version.

9 MR. SCHOLAND: Roger, do you have

10 a sense of how long that would be? Is NIST

11 pretty quick, the process?

12 FACILITATOR RABA: Note that we

13 have a vague gesture of uncertainty.

14 (Laughter.)

15 MR. SCHOLAND: Thanks for the

16 heads up on that.

17 FACILITATOR RABA: Good

18 observation, though. Thank you very much. 

19 MR. SCHOLAND: Slide 52, I just

20 want to make a comment on this. Originally

21 this test procedure was just about small

22 electric motors. And while we had initiated

EERE-2008-BT-TP-0008 COMMENT 08
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1 this rule before EISA was passed because we

2 started in July of 2006 and EISA was passed in

3 December of 2007, it became clear that it

4 needed to encompass electric motors as well. 

5 So when you see the email address here on

6 Slide 52 that says

7 Small_Electric_Motors_tp.rulemaking@hq.doe.gov

8 just understand that it's for both - it's for

9 the whole Notice, even though it says small. 

10 It's also for the medium, the integral

11 horsepower motors we talked about. Just want

12 to make sure that was clear. It's just kind

13 of a historical issue with our email address

14 in this rule. 

15 So all the information for

16 submitting comments, docket number is really

17 the best one to use rather than the regulatory

18 independent identification number. Email,

19 postal carrier and the comment period is open

20 till March 9. And early comments are always

21 welcome. Okay.

22 FACILITATOR RABA: Comment early,

EERE-2008-BT-TP-0008 COMMENT 08
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1 comment often. 

2 MR. SCHOLAND: That's it. Any

3 final issues for people to raise at this

4 point? Thank you all very much.

5 FACILITATOR RABA: Thank you very

6 much for turnout today. Very good turnout

7 from all sides and good discussion. I think

8 that there's been a lot achieved here today

9 about information the Department is seeking,

10 data to be gathered, things like that, and

11 comments that are very helpful as this is

12 supposed to be proposed, comments only taken

13 into account and examined carefully. Please,

14 we've made or heard oral comments. Please

15 also file the written comments. Whether you

16 spoke or not, written comments are always

17 welcome till, what, March 9 I believe.

18 MR. SCHOLAND: Yes.

19 FACILITATOR RABA: That is the

20 cutoff date for that. But other than that

21 with nothing further from everyone here, thank

22 you so much for turning out. Good meeting. 

EERE-2008-BT-TP-0008 COMMENT 08
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1 A lot of things that we covered. Well done. 

2 We're probably ahead of schedule actually

3 somewhat. Congratulations on that. And thank

4 Michael for doing a great job with - speaking

5 for the team, Robert, Matthew, Asa and others

6 who have been working on this so hard. 

7 They're all here. A lot of things that we've

8 covered today the Department appreciates I'm

9 sure. Thank you to Belinda and Brenda for

10 looking out for us too, keeping it together. 

11 Also, as far as logistics, you have on your

12 tables in front of you a comment sheet. 

13 Please fill that out so we know some feedback

14 to improve as we go along with these public

15 meetings. 

16 So if I could speak for the

17 Department, Michael Kido, thank you for being

18 our general counsel today. Good advice, good

19 input as always. And if there's nothing

20 further, we'll - once you finish your comment

21 sheets. Those will be here tomorrow. What

22 time do we start, 9:00 tomorrow morning? Same

EERE-2008-BT-TP-0008 COMMENT 08
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1 place. We'll take the next phase of the

2 motors rulemaking at that time. Thank you

3 very much.

4 (Whereupon, the foregoing matter

5 went off the record at 2:23 p.m.)

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

EERE-2008-BT-TP-0008 COMMENT 08
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A

ability 39:2 92:13

able 52:7 54:8,9

63:19 64:4 118:15

124:1,7 125:12

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abstract 122:8

acceleration 81:4

accept 39:6 93:2

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168:16 169:19

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accredited 84:19

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accurate 21:9,16

35:9,16 39:3 55:2

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Adjourn 3:22

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162:21

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Advanced 1:21,24

8:21,22 33:7

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advice 182:18

advisement 7:2

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28:7

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38:6,13,18 45:12

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121:13

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analogous 68:16

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20:18 21:18 25:14

60:3

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36:11 37:2 55:11

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118:2,6 170:18

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appreciate 5:7,10

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100:6 171:19

area 104:14 105:4

105:7 106:19,19

107:17

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arithmetic 40:13

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arrive 46:9 48:6

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EERE-2008-BT-TP-0008 COMMENT 08
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aspect 43:5 64:16

aspects 17:20 47:4

48:9 62:4,5

assessment 20:15

20:16

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assure 62:2

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A-G-E-N-D-A 3:2

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88:12

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B

B 31:9 32:6,9,16

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112:16,20 113:3,8

113:12 118:2

120:12 121:19

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160:16 161:8

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brief 66:11

briefly 48:15

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117:22 124:12

brings 176:3

broad 130:6

broadened 171:16

broadening 133:9

broadens 134:20

broader 122:22

123:10

broker 6:6

brought 75:16 95:5

102:17 124:12

125:21 126:3

bucks 154:3

build 63:21 117:16

117:18 122:2

building 1:9 3:9

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150:11

builds 126:10

built 28:8

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175:16

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bundled 18:13

110:13

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55:5,7,22 58:10

65:4 77:13 125:9

business 71:7

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129:13,14,19,22

Butler 1:24 8:22,22

buy 154:5,9

buying 61:15

by-side 174:21

C

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114:17 125:19

135:6,16 177:21

cafeteria 12:3,7

calculate 33:15

38:15

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calculation 52:8

53:4 63:18

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41:6 122:15

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126:17 153:10

call 23:1,8 104:19

107:13 124:15

134:6 165:20

called 94:19 109:20

142:22 149:16

153:15 154:6

166:8 176:14

calls 107:12

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44:14 66:18 143:2

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30:14,15 44:13,14

66:17,18 143:1,2

capture 14:3

139:14

careful 172:18

carefully 181:13

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carried 116:2

carrier 180:19

carrying 116:7

case 76:18 130:20

catches 150:11

category 127:4

caught 97:15

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163:2

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113:11 121:1

122:10 130:16

133:1 146:8 167:4

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70:1 71:12 72:15

73:4 84:11,18

85:1,9 86:15

154:2 165:19

certified 43:13

69:19,21 90:20

135:8

certify 77:19 78:9

84:10

certifying 55:3

62:9

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70:17 71:4 92:10

109:6 135:6,16

CFR 25:8 35:13

42:3 83:8 84:16

92:4,21,22 93:1,6

93:17 99:1,2,10

100:1,5 102:4

113:5 126:9 131:2

134:8,12 152:6

156:16 159:13

162:9,14 165:17

167:18 169:12

172:1 176:15

challenge 53:13

57:20 137:1

challenging 56:16

chance 14:19 24:3

59:9 173:2 176:8

change 42:12 43:4

43:15,17 45:2,4

46:5 48:3,18

49:21 50:8,13,15

51:13 53:10,15,15

53:16,18 54:20

56:10,14 59:1

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90:18,22 92:13

93:2,5 94:7 96:2

96:10 97:7 98:12

98:16 101:21

131:3,6 137:17

138:1,12 143:16

146:9 149:12

159:6,16,20

163:13 168:11

174:11,14

changed 67:18

70:16 71:1 98:10

145:3 146:11

163:3 171:7 178:2

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43:8,10,10 44:1

46:8 51:9,16 52:4

53:3 54:16 56:9

57:3 63:22 81:5

94:5 98:4 138:13

146:8 158:10

161:22 162:18

163:4 169:13

173:21 175:1

178:10,15

changing 54:5

106:16

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60:10,12 63:4

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58:1,3,13,16 59:1

59:3,11 60:5,11

60:14,21 61:3,4,7

62:4,20 63:6

139:15 140:10

143:21 144:2

Charlie 2:19 8:7

56:20 57:17,18

73:7,8 81:20,21

Charlie's 73:21

cheaper 154:6

check 91:16 98:14

148:15 168:13

checking 73:18

checklist 166:16,22

167:15,18 168:1,8

168:11,21

chief 7:13

chime 165:6

choice 29:22 30:6,9

choose 36:16

chosen 35:5

chronologically

11:7

circumspectly

151:5

circumstances 81:9

circumvention

21:10

citation 28:11

89:14 97:1 137:18

178:5

citations 89:13

90:15 162:4

170:12

cited 174:1,5

cites 119:21

claiming 50:18

clarification 73:10

74:10 86:13 87:21

106:1,10 116:6

121:11 152:6

157:16 159:22

clarifies 28:1

clarify 18:22 24:1

26:17 66:4,6 69:7

89:16 106:4 110:1

172:4

clarifying 74:1

clarity 81:11 111:7

111:8,10

class 49:7

classes 141:5

classification 67:3

107:16

classify 116:20

cleanest 131:5

clear 14:5 39:20

74:14 75:14 79:6

84:5 91:1 111:2

127:4 131:8

156:17 180:3,12

clearer 122:9

139:11

clearly 4:20 6:13

7:6 14:2

click 167:10

client 45:7

clock 137:8

close 115:20 128:12

closely 22:11

closer 133:2

closes 155:17

closing 3:20 178:16

code 18:19 25:7

28:11 30:3 40:9

71:12 110:3 162:1

176:22 177:1

178:4

codification 93:7

codified 84:15

91:14 152:1

codify 94:22 120:5

139:17

codifying 92:19

93:15

coffee 11:20 12:12

84:4

cognizant 137:14

colleague 52:22

150:6

colleagues 14:7

87:4

column 141:20

142:11

combination 42:20

72:14 138:11,20

139:10,13,15,20

139:22 140:1

combinations

42:13,18 44:12

138:9

come 10:20 13:9

18:7 23:11 57:21

58:6,17 59:9,20

74:6 77:4 80:7

122:19 137:12

143:19 153:15

160:15

comes 23:14 82:10

127:10 142:9

comfort 81:13

comfortable 4:6

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24:16 35:7,16

mechanisms 22:2

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42:22 47:16 65:5

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method 29:17 30:3

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31:3 32:19 35:4

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171:8 172:10

174:16 177:2,7,12

179:22 180:4,11

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motor's 40:18

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move 11:4 16:6

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multiple 72:13

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numbers 63:11

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82:20 87:7,8 88:4

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old 10:13 11:6

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once 24:17 25:12

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oral 95:14 181:14

order 14:18 24:13

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organization 4:21

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output 33:12,13

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overhear 5:2

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time 6:18 9:16,20

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today 4:5,9 5:11

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tomorrow's 19:18

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155:6 157:8,13

160:6 165:11

173:11 180:17

useful 40:18

users 125:12

uses 51:11,12,19

usual 96:6

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125:19 128:17

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U.S 1:1,10 28:10

75:16 178:4

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v 176:1

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vagueness 130:16

131:14

valid 167:11

value 47:2,8,10,22

125:22 138:17

167:7 172:22

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values 97:4,5 105:2

113:10,16 126:12

137:20 163:16

Van 1:17 9:9,9

59:19 60:1,1

129:13,13,19,22

varies 167:17

variety 126:22

vary 58:5

venue 165:21

verify 22:9

version 42:5 80:10

80:20 90:18 98:9

99:8 162:9 163:12

166:16,19 168:5

170:13 173:22

174:17 175:17

179:2,3,8

versions 35:6

162:10,17 170:6

179:7

versus 127:7

vertical 107:14

vibrate 14:10

victories 160:10

view 6:7 9:19 34:18

162:7

viewpoints 6:1

views 6:9 34:7 38:2

vii 176:2

virtue 153:14

visit 40:3

visitor's 13:11

voice 6:19 72:6

void 100:3 111:17

voltage 40:20

102:15,15 114:6

135:4

voltages 125:20

voltage-rated

102:18,19

volts 102:17 114:16

135:3,4

W

waiting 59:17

walk 38:11

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14:6,16,22 21:5

32:3 33:2 46:20

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EERE-2008-BT-TP-0008 COMMENT 08
Page 206

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49:10 56:21

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winding 58:21

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40:10 59:19 94:22

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words 127:5

work 7:9 15:12,20

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62:3 76:12 94:15

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131:20,22 132:2

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written 10:19 17:1

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37:19,21 66:7

69:6 74:6,13 83:2

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175:14 181:15,16

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Y

year 16:17 47:12

67:19 132:4

144:19 146:17,22

147:5 167:17,17

years 63:13 65:6

69:1 80:15 135:8

159:17

yeoman's 15:12

$

$2,000 77:17

0

05 178:1,1

07 42:17

1

1 18:21 32:10 33:21

35:12,20 40:10

42:7,9 78:5 84:7,9

89:19 98:1 104:9

105:18 108:8

111:15 113:13

145:14 149:19

163:10 170:22

172:13,16,17

173:9,10,20,22

174:4

1E-245 1:9

1-horsepower

44:20

1-200 30:8 39:12

1:15 161:8

1:24 161:11

10 19:10 26:19 42:3

75:21 78:2 83:7

84:15 92:3 99:1,2

99:10 102:3 113:5

126:9 134:8,12

156:16 158:15,17

159:12

10-12 77:16

10:31 88:11

10:50 88:12

1000 1:10

1004A 146:6

1004A-2001 144:16

1004-5 146:7 154:2

11 113:17

112 29:14,21 30:9

30:18 31:2,5,6

34:1 89:15 123:20

172:14 175:2

112-1996 90:16

172:14 179:2

112-2004 36:7

90:17 164:1

112-96 163:22

113 42:13,18 52:16

63:14,20,21 65:6

65:19 66:5,13,16

68:8,15,18 69:17

70:14,18 73:12

138:8,14 139:4

114 29:20 30:16

31:1 32:17 33:14

114-2001 29:14

36:6

12 113:16

12-10 97:3,4 163:15

12-11 104:17 105:2

135:20 148:7

12-12 104:20

105:10 113:17

12-35.1 158:21

12-35.3 158:20

12.58 163:10

12.58.1 174:12

12.58.2 163:14

12:15 161:10

13(A) 99:20,20

121:13,15 132:14

14 20:18

14.2 96:6,18 163:17

14.3 96:7,18 163:18

15 3:13 16:6 52:1

88:8 137:8

150 165:14 166:4,7

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150-10 165:15

EERE-2008-BT-TP-0008 COMMENT 08
Page 207

166:5,9,14 170:4

170:8 179:2

160 3:18

181 3:20

19 41:19

1987 80:9,20

1992 19:6 26:2

74:22 75:9 107:3

121:14 124:13

152:10

1993 97:2,6 164:2

179:3

1994 29:16

1997 135:8

1998 164:22 2 158:16

2(i) 176:1

2:23 183:5

20 52:1 144:21

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200 18:21 35:12,20

40:10 42:7,9 78:5

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104:5,9 105:18

108:8 111:15

113:9,13 145:15

147:13 148:10,22

149:2,19 150:4

171:1

2004 29:15 172:15

2005 29:16 164:3

172:17

2006 19:10 26:20

96:9,18 97:2,6

137:18 158:10

166:9 173:9,17,22

180:2

2007 10:9 19:3

91:20 99:18

124:17,21 145:2

152:18 163:3

164:5 166:10

174:15 180:3

2009 1:6 17:12

201 18:22 89:21

108:6

22 16:17

230 125:20 135:2

25 78:1 89:3

29 1:6

3

3(g) 173:1,3

30 17:12 137:16

30,000-foot 162:7

300-kilowatt 32:11

31's 141:20

313 132:13

313(a) 121:12

313(a)(2) 99:19

32 110:11 120:8

141:19 142:3

144:5

33 141:13

34 147:11

35 147:13

36 159:1

37 159:1

38 160:15 161:19

39 163:9

390-98 172:16 4 4 3:5 144:6

4-pole 44:20

40 80:15

400 32:10 163:12

174:12

42 79:3

43 172:11

431 30:3 71:11

75:21 83:8 92:4

99:1,2,11 102:4

113:5 126:9 134:8

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159:13

431.12 42:3

431.15 165:8

431.15(b)(4)

164:13,17

431.17 178:14

431.17(a)(5) 84:16

431.18 84:20

431.192 178:8

431.342 177:11

431.383 178:9

44 174:9

45 175:2

460 125:20 135:3

48 79:3

49 176:205 5 145:5

50 80:15 177:16

50Hz 158:11 159:7

159:18

500 18:22 32:13

89:22 104:6 108:6

113:10 145:9,16

147:12 148:8

149:3 163:13

174:12

52 179:19 180:6

56 79:3

6

6-7 16:20

60Hz 158:13

159:10,14

600 102:17 114:16

135:4

60034-1 164:14,20

6316 177:4 178:6

6317 176:21 177:3

177:14 178:5,7 7

747 29:21 30:17,18

33:14,198

8 158:16

88 3:16

9

9 16:19 180:20

181:17

9:00 1:9 182:22

9:03 4:2

9:30 16:3

92 68:22 70:15

98 90:17

EERE-2008-BT-TP-0008 COMMENT 08
EERE-2008-BT-TP-0008 COMMENT 08