### Page 1 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

### Page 2

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

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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

### Page 4 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,

### Page 5 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

### Page 6 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

### Page 7 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.

### Page 8 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

### Page 9 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.)

### Page 10 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

### Page 11 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

### Page 12 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

### Page 13 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

### Page 14 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

### Page 15 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

### Page 16 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

### Page 17 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

### Page 18 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

### Page 19 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

### Page 20 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

### Page 21 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.

### Page 22 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

### Page 23 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.

### Page 24 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

### Page 25 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

### Page 26 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

### Page 27 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

### Page 28 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

### Page 29 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

### Page 30 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-start15 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.

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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 across9 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

### 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

### 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.

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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.

### 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

### 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

### 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

### 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.

### 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

### 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

### 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.

### Page 63 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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

### 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 models19 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 -

### 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

### 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

### 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

### 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

### 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.

### 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

### 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

### 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

### 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, and11 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 the17 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.

### 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

### 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.

### 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.)

### 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

### 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.

### 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

### 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

### 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

### Page 89 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?

### Page 90 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

### Page 91 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.

### Page 92 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

### 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

### Page 94 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

### 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

### Page 96 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

### Page 97 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

### Page 98 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

### 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

### Page 100 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

### 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

### Page 102 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 only11 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

### Page 103 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

### Page 104 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

### 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.

### 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

### Page 107 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,

### Page 108 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

### 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

### 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

### Page 111 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

### 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.

### 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.

### Page 114 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

### Page 115 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,

### 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

### Page 117 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

### Page 118 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 be13 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

### Page 119 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

### Page 120 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

### Page 121 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

### Page 122 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.

### Page 123 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

### Page 124 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

### Page 125 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

### Page 126 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 attainable20 levels of efficiency assuming that the multi21 speed motors cannot attain those efficiencies 22 for a variety of reasons, that including those

### Page 127 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 for6 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

### Page 128 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

### Page 129 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

### Page 130 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

### Page 131 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

### Page 132 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?

### Page 133 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 the7 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

### Page 134 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

### Page 1351 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

### Page 136 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

### Page 137 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

### Page 138 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

### Page 139 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

### Page 140 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

### Page 141 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

### Page 142 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

### Page 143 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

### Page 144 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

### Page 145 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

### Page 146 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

### Page 147 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

### Page 148 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

### Page 149 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

### Page 150 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.

### Page 151 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 that10 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

### Page 152 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

### Page 153 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.

### Page 154 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

### Page 155 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

### Page 156 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

### Page 157 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

### Page 158 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

### Page 159 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

### Page 160 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

### Page 161 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

### Page 162 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

### 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

### Page 164 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

### Page 165 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

### Page 166 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

### Page 167 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

### Page 168 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

### Page 169 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

### Page 170 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

### Page 171 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

### Page 172 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

### Page 173 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

### Page 174 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,

### Page 175 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 the21 Department updating some of the cross22 references that had moved around in Appendix

### Page 176 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

### Page 177 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

### Page 178 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 have7 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

### Page 179 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

### Page 180 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,

### Page 181 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.

### Page 182 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

### Page 183 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.)

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75:21 83:8 92:4 99:1,2,11 102:4 113:5 126:9 134:8 134:12 156:16 159:13 431.1242:3 431.15 165:8 431.15(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 49 176:20 5 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

33:14,19 8 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