Energy Conservation Standards 

Rulemaking Framework Document for 

Commercial and Industrial Pumps 

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

January 25, 2013
i 

TABLE OF CONTENTS 

1. INTRODUCTION .................................................................................................................. 1

1.1 Authority and Background ............................................................................................... 1

1.2 Pumps for which DOE is Considering Standards ............................................................ 2

1.2.1 Pump Types .............................................................................................................. 2

1.2.2 Parameters for Potential Energy Conservation Standards ........................................ 6

1.2.3 Pumping System ..................................................................................................... 10

1.3 Equipment Definitions ................................................................................................... 12

1.4 Efficiency Metrics and Implementation Methods .......................................................... 14

1.4.1 Pump Efficiency...................................................................................................... 14

1.4.2 Overall (Wire-to-Water) Efficiency ........................................................................ 17

1.4.3 Other ....................................................................................................................... 17

1.4.4 DOE Efficiency Metric Considerations .................................................................. 17

1.4.5 Discussion of Potential Implementation Method .................................................... 25

1.5 Test Procedures .............................................................................................................. 31

1.5.1 Preliminary Discussion of Approaches ................................................................... 33

1.6 Overview of the Rulemaking Process and Stakeholder Participation ............................ 35

1.6.1 Preliminary Analysis ............................................................................................... 36

1.6.2 Notice of Proposed Rulemaking ............................................................................. 38

1.6.3 Final Rule ................................................................................................................ 38

1.6.4 Labeling .................................................................................................................. 39

2. OVERVIEW OF ANALYSES FOR RULEMAKING......................................................... 40

3. MARKET AND TECHNOLOGY ASSESSMENT ............................................................. 42

3.1 Market Assessment ........................................................................................................ 42

3.1.2 Shipments and Value .............................................................................................. 45

3.2 Equipment Classes ......................................................................................................... 52

3.2.2 Pump Category (Mechanical Configuration) .......................................................... 52

3.2.3 Pump Design Speed ................................................................................................ 54

3.2.4 Motor (and Control) Package.................................................................................. 61

3.2.5 Tentative Equipment Classes .................................................................................. 61

3.3 Technology Assessment ................................................................................................. 62

3.3.1 Improving Hydraulic Design .................................................................................. 63

3.3.2 Smoothing Surface Finish ....................................................................................... 63

3.3.3 Reducing Running Clearances ................................................................................ 63

3.3.4 Reducing Mechanical Friction in Seals .................................................................. 64

3.3.5 Reducing Other Volumetric Losses ........................................................................ 64

3.3.6 Using a Variable Speed Drive................................................................................. 64

3.3.7 Improving VSD Efficiency ..................................................................................... 64

3.3.8 Reducing VSD Standby and Off Mode Power Usage ............................................ 64

4. SCREENING ANALYSIS ................................................................................................... 65

5. ENGINEERING ANALYSIS ............................................................................................... 66

5.1 Overview ........................................................................................................................ 66

5.2 Representative Class Selection....................................................................................... 67

5.3 Representative Unit Selection ........................................................................................ 68
ii

5.4 Baseline Models ............................................................................................................. 68

5.5 Efficiency Levels............................................................................................................ 69

5.6 Developing Cost-Efficiency Relationships .................................................................... 71

5.7 Proprietary Designs ........................................................................................................ 73

5.8 Outside Regulatory Changes Affecting the Engineering Analysis ................................ 74

6. MARKUPS ANALYSIS ...................................................................................................... 74

6.1 Market Participants and Distribution Channels ............................................................. 74

6.2 Estimating Markups ....................................................................................................... 75

7. ENERGY USE AND END-USE DUTY PROFILE ANALYSIS ........................................ 76

7.1 Overview ........................................................................................................................ 76

7.2 Analytical Approach ...................................................................................................... 78

8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS .......................................... 79

8.1 Analytical Approach ...................................................................................................... 79

8.2 Installation Costs ............................................................................................................ 81

8.3 Energy Prices.................................................................................................................. 81

8.4 Maintenance and Repair Costs ....................................................................................... 82

8.5 Equipment Lifetime........................................................................................................ 82

8.6 Discount Rates................................................................................................................ 84

9. SHIPMENTS ANALYSIS ................................................................................................... 84

9.2 Standards Impacts on Shipments.................................................................................... 85

10. NATIONAL IMPACT ANALYSIS ..................................................................................... 85

10.1 National Energy Savings ............................................................................................ 86

10.2 Net Present Value of User Benefits ............................................................................ 86

11. CUSTOMER SUBGROUP ANALYSIS .............................................................................. 87

12. MANUFACTURER IMPACT ANALYSIS......................................................................... 87

12.1 Sources of Information for the Analysis..................................................................... 87

12.2 Industry Cash Flow Analysis ...................................................................................... 88

12.3 Manufacturer Subgroup Analysis ............................................................................... 89

12.4 Competitive Impacts Assessment ............................................................................... 89

12.5 Cumulative Regulatory Burden .................................................................................. 89

13. EMISSIONS ANALYSIS ..................................................................................................... 90

14. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS .......... 91

15. UTILITY IMPACT ANALYSIS .......................................................................................... 92

16. EMPLOYMENT IMPACT ANALYSIS .............................................................................. 93

17. REGULATORY IMPACT ANALYSIS .............................................................................. 94

APPENDIX A - LIST OF ITEMS FOR COMMENT ............................................................... 95

APPENDIX B - COMPARISON OF THE U.S. PUMP MARKET TO THE EU PUMP 

MARKET 103

B1. End-Suction Closed Coupled (ESCC) pumps .............................................................. 103

B2. End-Suction Frame Mounted (ESFM) pumps ............................................................. 105

B3. Vertical Inline (IL) pumps............................................................................................ 107

APPENDIX C - DOE EFFICIENCY SURFACE METHODOLOGY .................................... 110

C1. Example Surface Development for All ESCC Pumps ................................................. 110

C2. Water-Only Pumps ....................................................................................................... 113

C3. Baseline and Market Maximum Levels ....................................................................... 114

APPENDIX D - PUMP DESIGN SPEED............................................................................... 116
iii

D1. Varying Intercept Approach (Vertical Change in Surface) .......................................... 116

D2. Constant Intercept Approach (Surface Shape Change) ................................................ 121

D3. Effects of Pump Scope ................................................................................................. 122

D4. Results .......................................................................................................................... 124

References ................................................................................................................................... 125
iv

LIST OF TABLES 

Table 1.1 Rotodynamic Clean Water Pump Equipment Overview and Proposed Coverage ... 5

Table 1.2 Scope of EU Water Pump Regulation ...................................................................... 7

Table 1.3 EU Scope Translated for the United States ............................................................... 7

Table 1.4 Stakeholder Proposed Scope Exclusions .................................................................. 8

Table 1.5 Sample C Values for EU Minimum Pump Efficiency Equation ............................ 15

Table 1.6 Tentative Proposed Metrics for Pump Regulation Options .................................... 18

Table 1.7 Example Pump Parameter Comparison With and Without VSD ........................... 22

Table 1.8 Metric Alignment Options ...................................................................................... 24

Table 1.9 Overview of Currently Available Pump Test Procedures ....................................... 32

Table 3.1 Top 10 U.S. Pump Suppliers with Major Brands/Operating Units ........................ 43

Table 3.2 Major Suppliers for Proposed Covered Pump Equipment Categories.................... 44

Table 3.3 U.S. Pump Manufacturer Shipments of Covered Pumps ........................................ 46

Table 3.4 U.S. Pump Manufacturer Shipments of Non-Covered Pumps ............................... 47

Table 3.5 U.S. Market Size Estimate for Pumps Proposed for the Standard .......................... 49

Table 3.6 U.S. Market Size Estimate for Pumps Proposed for the Standard – Clean Water .. 50

Table 3.7 Estimate of U.S. Clean Water Pumps Sold with Motors (by Manufacturer) .......... 51

Table 3.8 Rotodynamic Clean Water Pump Categories Proposed for Coverage.................... 53

Table 3.9 Comparison of Minimum Efficiencies for Identical Pumps Running at Two 

Different Speeds................................................................................................................... 60

Table 3.10 Tentative Equipment Classes for Rotodynamic Clean Water Pumps ..................... 62

Table 8.1 Lifetime Distribution for Pump Categories ............................................................ 83

Table 8.2 Repair Cycle Distribution for Pump Categories ..................................................... 83

Table B.1 EU Values of C for ESCC Pumps......................................................................... 103

Table B.2 EU Values of C for ESFM Pumps ........................................................................ 105

Table B.3 EU Values of C for IL Pumps ............................................................................... 107

Table C.1 DOE Coefficients of Efficiency Surfaces for ESCC Pumps ................................ 110

Table D.1 Distribution of Number of Poles for ESCC Pumps .............................................. 116

Table D.2 Models with Vertical Change in Surface for ESCC Pumps ................................. 117

Table D.3 Coefficients from Model 2 with Vertical Change in Surface for ESCC Pumps ... 117

Table D.4 Distribution of Number of Poles for ESFM Pumps .............................................. 118

Table D.5 Coefficients for ESFM Pump Model .................................................................... 118

Table D.6 Distribution of Number of Poles for IL Pumps .................................................... 120

Table D.7 Coefficients for IL Pump Model ........................................................................... 120

Table D.8 Models with Surface Shape Change for All ESCC Pumps ................................... 121

Table D.9 Coefficients from Model 4 with Surface Shape Change for ESCC Pumps .......... 122

Table D.10 Distribution of Number of Poles for ESCC Water-Only Pumps .......................... 122

Table D.11 Coefficients for Water-Only Pumps ..................................................................... 123

LIST OF FIGURES 

Figure 1.1 Flow Reduction from Throttling and Use of VSD.................................................. 21

Figure 1.2 Comparison of EU MEIs to US Market for ESCC Pumps (Based on BEP Only) . 26

Figure 1.3 Comparison of DOE ESCC Average Surface with EU MEI 50% 4-Pole Surface . 27
v

Figure 1.4 Example Average, Top-of-Market, and Bottom-of-Market Efficiency Levels for 

ESCC Pumps ........................................................................................................................ 28

Figure 1.5 Example 2D Specific Speed “Slice” (Ns=1500-2500) Showing Average, Top-ofMarket, and Bottom-of-Market Efficiency Levels for ESCC Pumps .................................. 28

Figure 1.6 Comparison of EU MEIs to US Market for ESCC Pumps (75% BEP) .................. 30

Figure 1.7 Comparison of EU MEIs to U.S. Market for ESCC Pumps (110% BEP) .............. 30

Figure 2.1 Flow Diagram of Analyses for the Pumps Standards Rulemaking Process ........... 41

Figure 3.1 Example of Pumps Showing the Size Effect (2 Different Pumps: A and B) and the 

Speed Effect (Same Pump at Multiple Speeds: A and A2) ................................................. 55

Figure 3.2 Example Graph Showing Pump Efficiency as a Function of Specific Speed and 

Flow 56

Figure 3.3 Predicted Efficiency Differences Between Single ESCC Pumps Running with 2-

Pole versus 4-Pole Motors at Selected Specific Speeds (Using Equation Set 1) ................. 59

Figure 3.4 Predicted Efficiency Differences Between Single ESCC Pumps Running with 2-

Pole versus 4-Pole Motors at Selected Specific Speeds (Using Equation Set 2) ................. 59

Figure 5.1 Example Baseline Efficiency Levels for ESCC Pumps (Ns=1500-2500) .............. 69

Figure 5.2 Example Max-Tech Efficiency Levels for ESCC Pumps (Ns=1500-2500) ........... 70

Figure 6.1 Commercial and Industrial Pump Distribution Channels ....................................... 75

Figure 8.1 Flow Diagram of LCC Analyses for Pumps ........................................................... 80

Figure B.1 Comparison of EU MEIs to US Market for ESCC Pumps ................................... 105

Figure B.2 Comparison of EU MEIs to US Market for ESFM Pumps ................................... 107

Figure B.3 Comparison of EU MEIs to U.S. Market for IL Pumps ....................................... 109

Figure C.1 Average, Top-of-Market, and Bottom-of-Market Efficiency Surfaces for ESCC 

Pumps 111

Figure C.2 Specific Speed “Slices” Showing Average, Top-of-Market, and Bottom-of-Market 

Efficiency Surfaces for ESCC Pumps ................................................................................ 112

Figure C.3 Specific Speed “Slices” Showing Average, Top-of-Market, and Bottom-of-Market 

Efficiency Surfaces for Water-Only ESCC Pumps ........................................................... 114

Figure C.4 Specific Speed “Slices” Showing Potential Average, Baseline, and Market 

Maximum Efficiency Surfaces for ESCC Pumps .............................................................. 115

Figure D.1 Efficiency Surfaces Using Model 2 with Vertical Change in Surface for All Pumps

 118

Figure D.2 Efficiency Surfaces of ESFM pumps with 2 and 4 poles ..................................... 119

Figure D.3 Efficiency Surfaces of IL Pumps with 2 and 4 poles ............................................ 120

Figure D.4 Efficiency Surfaces Using Model 4 with Surface Shape Change for ESCC Pumps

 122

Figure D.5 Efficiency Surfaces for Water-only Pumps .......................................................... 123
vi 

LIST OF ACRONYMS 

AEC annual energy consumption 

AEO Annual Energy Outlook

ANSI American National Standard Institute 

API American Petroleum Institute 

BEP best efficiency point 

BLS Bureau of Labor Statistics 

BT Building Technologies Program 

CAIR Clean Air Interstate Rule 

CAMR Clean Air Mercury Rule 

CFD computational fluid dynamic 

CFR Code of Federal Regulations 

CO2 carbon dioxide 

CSL candidate standard level 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice 

EERE Office of Energy Efficiency and Renewable Energy 

EGU electricity generating unit 

EIA Energy Information Administration 

EISA Energy Independence and Security Act of 2007 

EPA U.S. Environmental Protection Agency 

EPCA Energy Policy and Conservation Act 

EU European Union 

FFC full-fuel cycle 

FR Federal Register 

GHG greenhouse gas 

gpm gallons per minute 

GREET Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation

GRIM Government Regulatory Impact Model 

HAP hazardous air pollutant 

Hg mercury 

HI Hydraulic Institute 

HP horsepower 

HVAC heating, ventilating, and air conditioning 

ImSET Impact of Sector Energy Technologies 

ISO International Organization for Standardization 

kg kilograms 

kW kilowatt 

LCC life-cycle cost 

MEI minimum efficiency index 

MPC manufacturer production cost 

MSP manufacturer selling price 

MIA manufacturer impact analysis 

NIA national impact analysis 

NEMS National Energy Modeling System 
vii 

NES national energy savings 

NESHAPs national emissions standards for hazardous air pollutants 

NOPR notice of proposed rulemaking 

NOX oxides of nitrogen 

NPSH net positive suction head 

NPV net present value 

OEM original equipment manufacturer 

OMB Office of Management and Budget 

PBP payback period 

PM particulate matter 

R&D research and development 

RFI request for information 

rpm revolutions per minute 

SCC social cost of carbon 

SG&A selling, general, and administrative costs 

SO2 sulfur dioxide 

TSD technical support document 

TSL trial standard level 

U.S. United States 

U.S.C. United States Code 

VSD variable speed drive 
1

1. INTRODUCTION 

The U.S. Department of Energy (DOE) Appliances and Equipment Standards Program, 

within the Office of Energy Efficiency and Renewable Energy’s Building Technologies Program 

(BT), develops and promulgates test procedures and energy conservation standards for certain 

consumer appliances and commercial and industrial equipment. The process for developing 

standards involves analysis, public notice and comment, and consultation with interested parties. 

Interested parties include manufacturers, consumers, energy conservation and environmental 

advocates, State and Federal agencies, and any other groups or individuals having an interest in 

these standards and test procedures. 

The purpose of this framework document is to describe the procedural and analytical 

approaches DOE anticipates using to evaluate potential new energy conservation standards for

pumps. This framework document is intended to inform interested parties of the process DOE 

will follow for the standards rulemaking for pumps and to encourage and facilitate the input of 

interested parties during the rulemaking. This document is merely the starting point for 

evaluating energy conservation standards or energy use standards and is not a definitive 

statement on any issue to be determined in the rulemaking.

This framework document is organized in the following manner. Section 1.1 describes 

the statutory authority for this rulemaking. Section 1.2 provides an overview of the scope of 

coverage DOE is considering, section 1.3 discusses equipment definitions, section 1.4 discusses 

metrics used to describe pump efficiency, and section 1.5 discusses test procedure methods that 

could be used to measure pump efficiency. Section 1.6 provides an overview of DOE’s 

rulemaking process, and section 2 describes the analyses that DOE conducts, which are 

described further in sections 3 through 17. 

DOE will analyze pumps to determine whether new energy conservation standards are 

technologically feasible and economically justified and would result in significant energy 

savings. DOE will maintain information about this rulemaking on its Office of Energy Efficiency 

and Renewable Energy (EERE) website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/commercial_industrial_

pumps.html. 

While DOE invites comment on all aspects of the material presented in this 

document, several specific issues on which DOE seeks comment are set out in comment 

boxes like this one. DOE uses these comment boxes to highlight issues and ask specific 

questions on the approaches DOE plans to follow to conduct the analyses required for the 

energy conservation standards rulemaking. Such requests for feedback are numbered 

sequentially throughout the document and are listed in appendix A. 

1.1 Authority and Background 

 Title III of the Energy Policy and Conservation Act of 1975 (EPCA), as amended (42 

U.S.C. 6291 et seq.), sets forth various provisions designed to improve energy efficiency. Part C 
2

of Title III of EPCA (42 U.S.C. 6311-6317) (re-designated as part A-1 upon codification in the 

U.S. Code), establishes the "Energy Conservation Program for Certain Industrial Equipment," 

which covers certain commercial and industrial equipment (hereafter referred to as "covered 

equipment"). 

 EPCA specifies a list of equipment that constitutes covered commercial and industrial 

equipment, including pumps. (42 U.S.C. 6311(1)(A)). In considering whether to establish 

standards for pumps, DOE issued a Request for Information (RFI) on June 13, 2011. (76 FR 

34192). DOE received comments from stakeholders, which are available in the rulemaking 

docket (EERE-2011-BT-STD-0031)1and have been considered in developing this framework. In 

December 2011, DOE received a letter from the Appliance Standards Awareness Project (ASAP) 

and the Hydraulic Institute indicating that efficiency advocates (including ASAP, American 

Council for an Energy-Efficient Economy, Natural Resources Defense Council, and Northwest 

Energy Efficiency Alliance) and pump manufacturers (as represented by the Hydraulic Institute), 

had initiated discussions regarding potential energy conservation standards for commercial and 

industrial pumps. In subsequent letters in March and April 2012, and in a meeting with DOE in 

May 20122

, the stakeholders reported on a tentative path forward on three items: energy 

conservation standards for water pumps, certification and labeling, and an “extended product” 

approach. These items are expanded upon in relevant sections of this document. 

1.2 Pumps for which DOE is Considering Standards 

Commercial and industrial pumps cover a wide range of equipment and applications. In 

this rulemaking, DOE is considering energy conservation standards for a subset of available 

pumps that accounts for a significant share of energy use, as described in 1.2.1. Standards could 

be established for additional types of pumps in this or a future rulemaking. 

1.2.1 Pump Types 

1.2.1.1 Clean Water Pumps 

While numerous pump types exist for commercial and industrial applications, DOE is 

considering standards for pumps designed for clean water. This approach is consistent with the 

European Union (EU) regulation for water pumps [1]. The stakeholders also expressed agreement on 

pursuing standards for clean water pumps based on the EU regulation. 

DOE is considering standards for clean water pumps because industry standard pump tests use 

clean water only, and most published pump performance curves are based on clean water. DOE notes 

that testing with some fluids other than water may cause additional manufacturer burden. The 

American National Standard Institute (ANSI) and the Hydraulic Institute (HI) standard, ANSI/HI 

12.6-2011 (Rotodynamic [Centrifugal] Slurry Pumps), notes that “Slurry tests are expensive and, 

therefore, should only be considered for extremely critical services where there is no other alternative 

 

1

http://www.regulations.gov/#!docketDetail;D=EERE-2011-BT-STD0031;dct=FR%252BPR%252BN%252BO%252BSR

2

 The December 2011, March 2012, and April 2012 letters are available for review in the rulemaking docket. A 

memorandum memorializing the May 2012 meeting is available in the docket and at: 

http://energy.gov/sites/prod/files/Ex_Parte_Memo_ASAP_%26_HI_5_10_2012.pdf. 
3

[2].” In addition, even where test procedures are possible for other fluids, setting standards for pumps 

using many fluids could be difficult. 

As part of this rulemaking, DOE will consider developing a definition for ‘clean water’ that 

may include suspended and dissolved solids limits high enough to cover most pumps designed for 

water that may not typically be considered clean, such as river water, sea water, or brackish water (see 

section 1.3). Alternatively, DOE may define “pumps designed for clean water” based on physical 

characteristics of the pumps, such as the following: 

metallurgy, 

Sealing (or sealless) technology (depending on pressure and temperature limits), 

impeller type3 (i.e., slurry, vortex, recessed impeller), 

replaceable wear plates, 

barrel casing, and 

center-line support.4

DOE understands that sump and slurry pumps and solids-handling type pumps are rarely 

used for clean water. The EU Lot 285

process proposes covering a large number of pump types 

for these applications and will likely define classes of wastewater for which manufacturers 

would have to guarantee efficiency [3]. However, testing may be based on clean water, with 

efficiency for the classes of wastewater based on relationships between clean water and the given 

wastewater. DOE is considering not covering these pumps in the current rulemaking. 

However, DOE also understands that other types of pumps not primarily designed for clean 

water, such as ANSI chemical process pumps, may also be used to pump clean water. These pumps 

are generally designed for other liquids that contain no solids, are aqueous, and would behave 

similarly to water in terms of their effect on pump efficiency. They are also tested with clean 

water. Not regulating them may simply represent a lost energy savings opportunity, particularly 

if standards for other pumps result in increased sales of these unregulated pumps. DOE requests 

comment on whether such pumps should be covered or if they should be excluded based on their 

certifications or certain design characteristics, such as those listed above. DOE recognizes that 

pumps designed to meet the American Petroleum Institute (API) 610 standard (for hydrocarbon 

products) may have safety requirements (larger clearances) that result in reduced efficiency [3]. 

In addition, DOE understands API 610 pumps to be extremely cost-prohibitive for water 

applications. As such, DOE is not considering standards for API 610 pumps in this framework 

document, but welcomes comment on this issue. 

Item 1-1 DOE seeks comment on its proposal to cover only clean water pumps in this 

rulemaking. 

 

3

 DOE may exclude pumps with slurry, vortex, and recessed impellers. However, DOE is considering standards for 

pumps with open impellers in this framework document. 

4

 DOE also considered shaft sleeves, bearing weight, and pump-out vanes on the back side of an impeller, but 

determined that these characteristics have some functions not related to the liquid being pumped. 

5

 The European Union (EU) Lot 28 Ecodesign Directive proposes coverage of pumps for private and public waste 

water and for fluids with high solid content. 
4

Item 1-2 DOE requests comment on whether it should rely on a definition of ‘clean 

water’ to determine coverage of pumps, as in the EU, or if, instead, the definition of ‘clean 

water pumps’ should include physical characteristics that distinguish pumps designed for 

clean water or exclude pumps designed for other purposes. 

Item 1-3 DOE seeks comment on the list of physical differences that may exist between 

pumps designed for clean water and pumps designed for other substances. Specifically, (1) is 

the list accurate and exhaustive, (2) do the differences impact efficiency, and (3) do the 

differences have increased cost? 

Item 1-4 DOE seeks comment on whether it should consider standards for pumps 

designed for non-water liquids that contain limited solids in this rulemaking. DOE is 

specifically interested in ANSI chemical process pumps, API 610 pumps, sealless (magnetic 

drive, canned, or cantilever) pumps, sanitary pumps, refrigerant pumps, and general 

industrial pumps. When suggesting pump types for which standards should not be 

considered, please be specific as to the reason why. 

Item 1-5 DOE requests comment on whether any design changes made to standard 

clean water pumps would carry through to pumps designed for other applications. 

1.2.1.2 Rotodynamic Pumps 

There are two broad categories of pumps: rotodynamic and positive displacement. In this 

framework document, DOE is considering energy conservation standards for rotodynamic pumps. 

This is the approach used in the EU regulations6

, and the stakeholders also expressed support for this 

approach. Rotodynamic pumps represent approximately 70 percent of industrial pump sales by value 

[4] and 90 percent of pump energy use [5]. Positive displacement pumps represent a small percentage 

of the market and are generally used for niche applications such as viscous or shear-sensitive liquids. 

Because positive displacement pumps and rotodynamic pumps provide different utility, technical and 

economic issues generally prevent their overlap [6].7

For clean water pumps, some positive 

displacement pumps, such as piston pumps, can be used instead of rotodynamic pumps, but they are 

more expensive and typically have higher maintenance costs, making users more likely to choose 

rotodynamic pumps. On the other hand, for high head (pressure) applications, rotodynamic pumps 

have increased cost and less reliability, making users more likely to choose positive displacement 

pumps. 

Item 1-6 DOE seeks comment on its proposal to consider standards for rotodynamic 

pumps and not positive displacement pumps. In particular, DOE requests comment on the 

extent of the overlap between rotodynamic and positive displacement pumps and whether 

there are certain categories of rotodynamic pumps (pump types and ranges of flow and 

specific speed) for which positive displacement pumps could be a direct replacement. 

 

6

 DOE notes that Executive Order 13609 of May 1, 2012 promotes international regulatory cooperation. 77 FR 

26413. http://www.gpo.gov/fdsys/pkg/FR-2012-05-04/pdf/2012-10968.pdf. 

7

 The analysis will consider switching between rotodynamic and positive displacement pumps. 
5

1.2.1.3 Pump Equipment Categories 

An overview of pump equipment categories is presented in Table 1.1, with a preliminary 

indication of the categories for which DOE is considering energy conservation standards, as well as 

the categories considered by the stakeholders based on EU coverage, for comparison. DOE’s 

proposed pump categories constitute up to 70 percent of commercial and industrial pump (including 

rotodynamic and positive displacement) energy use [6], as well as approximately 40 percent of 

industrial pump sales by unit and 30 percent by value [4]. DOE believes that the pump categories for 

which DOE is not considering standards in this framework document represent a small market share 

or are not for clean water use. Section 3.2 on equipment classes provides further discussion of whether 

each pump category listed warrants a separate equipment class or if a listed pump category requires 

disaggregation into multiple equipment classes. Table 1.1 identifies the pumps for which DOE is 

considering energy conservation standards. 

Table 1.1 Rotodynamic Clean Water Pump Equipment Overview and Proposed 

Coverage 

Pump Type Sub-Type Stages

EU 

Coverage/Sta

keholder 

Proposal

DOE Coverage Proposal and 

Terminology

End Suction

Close Coupled Single X

End Suction Close Coupled 

(ESCC)

Two

Own Bearings/ 

Frame Mounted

Single X

End Suction Frame Mounted 

(ESFM)

Two

Vertical In-Line Single X

*

In-Line (IL)

Two

Axial Split Single Double Suction (DS)

Multi Axially Split Multi-Stage (AS)

Radial Split

Single

Multi Partial (vertical 

in-line)** Radially Split Multi-Stage (RS)

Vertical 

Turbine

Non-Submersible Any Vertical Turbine (VT)

Submersible Any Partial (> 1 

stage)*** Submersible (VT-S)

Axial/Propeller and Mixed Flow Any Axial/Propeller and Mixed (A-M)

Regenerative Turbine Any

Pitot Any

*

In EU standard, this category is called end suction close coupled inline and therefore presumably only covers close coupled pumps; the 

stakeholders propose to add flexibly coupled and rigidly coupled pumps to this category. 

**In EU standard, this is called vertical multistage. Although not clear from the EU standard, the stakeholders have interpreted this to cover 

only multi-stage in-line casing diffuser pumps. 

***In EU standard, this is called submersible multistage. 

Item 1-7 DOE seeks comment on its proposal to consider standards for pumps not 

covered in the EU. 
6

Item 1-8 DOE seeks comment on its development of pump equipment categories and 

whether these categories provide an appropriate basis for developing equipment classes. (See 

section 3.2.) 

Item 1-9 DOE seeks comment on whether standards for any additional pump categories 

should be considered. In particular, DOE is interested in pump categories that may have 

significant potential for energy savings. 

Item 1-10 DOE seeks comment on the pump types as described by ANSI/HI 

nomenclature that fall into the equipment categories set forth in Table 1.1. For example, 

pump type OH1 would be classified as an end suction frame mounted pump. For ANSI/HI 

pump types that would not fall into the categories in Table 1.1, please provide a specific 

reason, such as “solids-handling only.” 

DOE notes that, in the EU, a type of pump known as glandless or wet-running circulators 

are covered under a separate regulation. While these pumps are manufactured and sold almost 

exclusively in the EU [7], there is currently a small market for these circulatorsin the United States. 

DOE tentatively proposes to cover these wet-running circulators under their relevant equipment 

categories (most typically end suction close coupled or in-line). DOE notes, however, that standards 

for circulators (or any pumps) used primarily in residential applications would not be considered in 

this rulemaking. 

Item 1-11 DOE seeks comment on whether wet-running circulator-type pumps should be 

covered in this rulemaking. 

Item 1-12 DOE seeks comment on the market size for wet-running circulators in the 

United States, including the split between commercial and residential applications in terms of 

physical size or other features, as well as the potential for growth of the market for 

circulators in commercial applications. 

1.2.2 Parameters for Potential Energy Conservation Standards 

The EU standard generally covers pumps up to the practical limits of the equipment, although 

a few pumps may fall outside of the parameters specified [1]. The parameters are shown in Table 1.2. 

(Note that the equipment categories listed are not comprehensive of those DOE is proposing for 

coverage.) DOE has translated the EU limits into the speeds and units used in the United States,

as shown in Table 1.3.

8

 

8

 DOE translated these limits for the United States by assuming equivalent pump geometry and increased speed 

based on frequency (60 hz in the United States versus 50 hz in the EU), and then applying pump affinity laws that 

show the relationship between changes in speed and changes in head, flow, and power. DOE then converted units 

from metric to U.S.-based. 
7

Table 1.2 Scope of EU Water Pump Regulation 

Pump 

Category

Defined Scope

Speed

Flow at 

BEP*

Head at 

BEP

Specific 

Speed**

Shaft 

Power Temp. Other

End Suction 

Single-Stage

1,450 

rpm†

≥ 6 m3/h‡≤ 90 m 6 ≤ns≤ 80 ≤ 150 

kW§

-10 

through 

+120°C

Pressures up 

to 16 bar

End Suction 

Single-Stage

2,900 

rpm

≥ 6 m3/h ≤ 140 m 6 ≤ns≤ 80 ≤ 150 

kW

-10 

through 

+120°C

Pressures up 

to 16 bar

Vertical 

Multi-Stage

2,900 

rpm

≤ 100 

m

3

/h

-10 

through 

+120°C

Pressures up 

to 25 bar

Submersible 

Multi-Stage

2,900 

rpm

0 through 

90°C

Nominal 

sizes 4" and 

6"

* BEP = best efficiency point (the duty point that leads to the maximum efficiency value). 

** . In the EU regulation, specific 

speed is calculated from the numerical values for speed in rpm, flow in meters cubed per second, and head in m. 

Although the EU regulation gives the units rpm or min-1 for specific speed, it is not clear how these units were 

obtained. Specific speed is generally treated as dimensionless

† rpm = revolutions per minute. 

‡ m3/h = cubic meters per hour. 

§ kW = kilowatts. 

Table 1.3 EU Scope Translated for the United States 

Pump 

Category

Defined Scope (Based on Affinity Laws)

Speed

Flow at 

BEP

Head at 

BEP

Specific 

Speed**

Shaft 

Power Temp. Other

End Suction 

Single-Stage

1,750 

rpm

≥ 32 

gpm*

≤ 430 

feet

312 ≤Ns≤ 

4,160 

≤ 353 

HP†

14 through 

+248°F

Pressures up 

to 232 psi 

absolute

End Suction 

Single-Stage

3,500 

rpm

≥ 32 

gpm

≤ 669 

feet

312 ≤Ns≤ 

4,160 

≤ 353 

HP

14 through 

+248°F

Pressures up 

to 232 psi 

absolute

Vertical 

Multi-Stage

3,500 

rpm

≤ 531 

gpm

14 through 

+248°F

Pressures up 

to 363 psi 

absolute

Submersible 

Multi-Stage

3,500 

rpm

32 through 

194°F

Nominal 

sizes 4" and 

6"

* gpm = gallons per minute. 

** Specific Speed (Ns) is calculated using the same equation shown in the previous table using the numerical values 

for speed in rpm, flow in gpm, and head in feet. Ns is treated as dimensionless. 

† HP = horsepower. 
8

Stakeholders have proposed that DOE consider standards for the following pumps in this 

rulemaking: 

25 gpm and greater; 

295 feet of head maximum; 

1-200 horsepower (HP); and 

temperature range from -10 °C through +120 °C. 

According to stakeholders, this approach is meant to generally align with the EU scope 

and is designed to focus on off-the-shelf pumps and to exempt pumps with low flow and 

fractional horsepower that have little opportunity for efficiency improvement and energy 

savings. DOE estimates that these parameters would exclude the percentages of pumps, by 

model availability and shipment, shown in Table 1.4. 

Table 1.4 Stakeholder Proposed Scope Exclusions 

Pump Category Percent Excluded

Model Availability* Shipments (Units)**

End Suction Close Coupled (ESCC) 43% 71%

End Suction Frame Mounted (ESFM) 41% 34%

In-Line (IL) 43% 47%

Double Suction (DS) 58% 32%

Axially Split Multi-Stage (AS) 80% 86%

Radially Split Multi-Stage (RS) 87% 49%

Vertical Turbine (VT) 49% 43%

Submersible (VT-S) 54% 42%

Axial/Propeller and Mixed (A-M) 36% 40%

Total 48% 68%

*Based on more than 27,000 clean water pump models extracted from PUMP-FLOTM Desktop, a 

pump selection tool from Engineered Software. 

**DOE estimates. 

Many multi-stage pump models would be included in the pump percentages listed in 

Table 1.4 as a result of the maximum proposed head (295 feet), because the purpose of multistage pumps is to provide increased head. Vertical turbine pumps and radially split multi-stage 

pumps, however, are generally cellular in nature; in other words, all stage versions of a given 

pump are based on the same bowl, and identical bowls are stacked together to create multi-stage 

versions. Therefore, if DOE were to set standards for this type of pump, improving efficiency for 

models with less than 295 feet of head would also result in efficiency improvements for models 

with higher than 295 feet of head. Furthermore, for these pumps, DOE may consider testing on 

basic models with a certain number of stages (see section 1.4.5), which would make a maximum 

head limit unnecessary. 

Under the stakeholders’ approach, standards would also not be considered for many 

pumps in certain categories as a result of the maximum temperature (+120 °C). These categories 

include end suction close coupled (ESCC), double suction (DS), and axially split multi-stage (AS). 
9

If DOE does not consider standards for ANSI pumps, however, many of which have high 

temperature ranges, the percent of clean water pumps excluded by a maximum temperature limit 

would be much lower. (See comment Item 1-4). 

In this framework document, DOE is not considering adopting coverage parameters 

except possibly to exempt certain pumps from standards for specific reasons. For example, 

because this rulemaking focuses on commercial and industrial pumps, DOE may not consider 

standards for pumps used primarily in residential applications. 

Item 1-13 DOE requests comment on which parameters, if any, should be added to this 

rulemaking. For each parameter proposed, please include the rationale and the type of pump 

that the parameter is designed to exclude from standards. Comments may address those 

translated from the EU or those proposed by stakeholders, but do not have to be limited to 

those proposals. DOE especially seeks comments on parameters that should be added to 

exclude pumps used primarily in residential applications. DOE also seeks comment on 

whether, if using power as a coverage parameter, hydraulic power would be more appropriate 

than shaft power. 

Item 1-14 DOE requests comments on the estimates of pumps that would be excluded 

based on the stakeholders’ proposed parameters. 

The EU regulation and the stakeholder proposal also exclude self-priming pumps and pumps 

designed only for fire-fighting applications. Self-priming pumps are used primarily for the wastewater 

industry and are thought to be cost prohibitive in applications where they are not necessary. Firefighting pumps are excluded because of their low hours of use, but they are often identical to clean 

water pumps and so would likely meet the applicable standards. If these pumps are likely to be 

purchased and used for applications other than their intended ones, however, they may warrant 

coverage. 

The term self-priming generally refers to pumps mounted above liquid level that can, 

after initial priming, evacuate gases from the suction line and lift fluid to the pump inlet without 

intervention and without requiring a foot check valve. However, some HI standards refer to 

pumps with the wet end immersed in water, such as vertical turbine pumps, as self-priming, and 

the EU definition9 may also consider this type of pump as self-priming. For the purposes of this 

framework document, DOE intends to adopt a narrower definition of self-priming that would not 

include vertical turbine pumps, on the basis that vertical turbine pumps are not mounted above 

liquid level, and thus do not feature the design characteristics typical of true self-priming pumps. 

Item 1-15 DOE requests comment on the technical features and applications for firefighting pumps and self-priming pumps that would allow it to determine whether these 

pumps should be covered. 

 

9

 “A water pump that moves clean water and which can start and/or operate also when only partly filled with water.” 
10

1.2.3 Pumping System 

There may be greater potential for energy savings if the energy conservation standards 

addressed pumps as a system of components. Pump systems are subject to a variety of inefficiencies, 

and those inherent in the pump are often among the smallest. As a result, addressing other system 

inefficiencies10 in any DOE regulations could significantly increase energy savings. The EU has been 

exploring an approach for equipment sold in a package with a motor and control, and the stakeholders 

have also agreed to explore the issues associated with setting standards for pump systems. The main 

goal of such an approach is to capture the benefits of variable speed drives (VSDs). VSDs are control 

devices that can be used to improve equipment performance under variable loads. The savings 

potential is highly dependent on (a) how much time the system requires operation at a reduced load 

(i.e., flow less than full flow); and (b) the means, if any, used to adjust pumping system operation 

during these times. For example, systems that use throttling valves to reduce flow while maintaining 

pump speed for many hours per year have the potential to significantly reduce annual energy use by 

using VSDs to instead reduce flow by reducing the pump speed. 

It is important to note, however, that VSDs used under constant load operation conditions may 

degrade efficiency because of the electric losses in the VSD during full load operation. In addition, the 

savings also depend on the pressure and flow characteristics of the system. If the system head 

requirement includes a large percentage of constant head (i.e. static head)—for instance, to lift water 

from a low location to a high location—the potential for energy savings through use of VSDs is 

significantly less. For these reasons, VSDs are best applied to pumps used primarily in applications 

with variable load and relatively low static head. However, the same pump equipment is often 

installed with a VSD in some cases and without it in others. In fact, DOE is not aware of any specific 

pump type that is always used in an application that would benefit from a VSD. As a result, DOE 

would consider the impacts of VSDs in various applications in determining whether to establish 

energy conservation standards that could increase the use of VSDs in any pump equipment categories. 

Item 1-16 DOE requests data on how pumps are sold by pump manufacturers. 

Specifically DOE requests data on market share of pumps 1) sold by themselves, 2) sold 

attached to or integrated with motors only, 3) sold attached to or integrated with both motors 

and VSDs, 4) sold physically separate from but priced together with a motor only, or 5) sold 

physically separate from but priced together with both a motor and VSD. DOE seeks these 

data by size, equipment category (see section 3.2), and application. 

Item 1-17 DOE requests data and information on whether pumps are more often 

combined with motors, VSDs, or both by the pump manufacturer or by distributors. 

Item 1-18 DOE requests information on how often and in what circumstances the 

intended application of the pump is known when the pump is sold. 

 

10 These other inefficiencies include mismatch of pump to system requirements, use of throttling valves and dampers 

to control flow, running at constant load all the time when load is or could be variable, and use of inefficient motors 

and inefficient motor drives. 
11

Item 1-19 DOE understands that VSDs are not very effective without system feedback. 

DOE seeks comment on the need for considering feedback in any extended product-type 

definition for pumps. 

DOE is considering the following options for regulation depending on how pumps are 

defined and sold: 

1. Defining and establishing standards for the pump exclusive of the motor, except possibly for 

submersible pumps. This option follows the current EU approach for clean water pumps. 

2. Defining and establishing standards for the pump inclusive of the motor and controls, if the 

pump is sold with them. Using this approach, each pump equipment class would be subdivided into two categories: (1) without VSD (pump is sold with or without motor) and (2) 

with VSD (VSD included only if the pump is sold with a motor).11

3. Defining and establishing standards for the pump inclusive of the motor, if the pump is sold 

with a motor12, and considering the VSD as a design option to improve the efficiency of 

pumps sold with motors. Each pump equipment class could be divided into two further 

categories: (1) without motor (or VSD) and (2) with motor (with or without VSD). 

Based on DOE’s preliminary research, option 1 would be the simplest approach. Option 2 has 

potential to capture additional energy savings because it directly addresses the use of more efficient 

VSD and motor pairs than might be sold in the absence of a standard. Option 3 may increase the 

potential to capture savings associated with system inefficiencies, as a metric could be developed to 

demonstrate energy savings associated with reducing flow using a VSD to address operation when full 

load is not required, rather than by less efficient means, such as using throttling valves to reduce flow. 

DOE notes that in options 2 and 3, the same pump could be placed into two different equipment 

classes, one for the pump alone and the other for the pump sold with the motor or motor and controls. 

Each equipment class would be subject to a separate energy conservation standard. 

DOE realizes that pump manufacturers cannot control if or how a VSD is used in the 

field. In addition, a standard that requires or encourages the use of VSDs could result in the 

presence of VSDs in applications for which they are not suited, such as constant loads with 

correctly sized pumps or variable loads with high static head. To determine whether selling more 

pumps with VSDs (the possible result of option 3) or selling more efficient VSD/motor pairs 

(option 2) would actually save energy in the field, DOE will conduct analyses of pump and VSD 

usage across the full spectrum of pump applications and baseline conditions (including throttling 

valves, bypass valves, on/off cycling, and constant full speed operation). 

 

11 As noted previously, most pump motors (85 percent to 90 percent) are already subject to energy conservation 

standards. One of the key exceptions is submersible motors, which are used with submersible pumps. 

12 The presence of a motor can be used as a feature to differentiate equipment classes because the pump 

manufacturer is likely to make an informed decision about the appropriate motor to pair with a given pump, which 

offers utility to the consumer. 
12

Item 1-20 DOE requests comment on the benefits and drawbacks of the options 

presented above. For options 2 and 3, DOE seeks comment on whether these options could 

increase the beneficial use of VSDs in the field, and whether these options could result in the 

use of a VSD in an application for which it is not suited. 

Item 1-21 DOE seeks comment on the market share of pumps by category that would be 

used in applications that would benefit from VSDs, as well as those where use of a VSD 

could result in increased energy use. 

DOE notes that not all pumps are driven by electric motors; some pumps may be driven by 

natural gas or diesel engines or steam turbines. These pumps may represent 10% or less of the pumps 

that DOE is currently considering regulating through efficiency standards. Because some pumps can 

be used with both motors and engines, DOE is considering in this framework document setting 

standards for pumps without regard to how they are driven. Any pump sold with an engine or for use 

with an engine (as opposed to an electric motor) would likely be regulated as a pump sold without a 

motor if DOE defines pumps to include the motor or motor and controls. 

Item 1-22 DOE seeks comment on the market share and applications of pumps by 

category driven by equipment other than an electric motor. 

1.3 Equipment Definitions 

In this rulemaking, DOE is considering a definition for pumps (commercial and 

industrial), definitions for specific types of pumps, and a definition of ‘clean water’. In the June 

2011 RFI, DOE requested comment on definitions for ‘rotodynamic pumps’, ‘centrifugal (radial) 

pumps’, ‘mixed flow pumps’, ‘axial flow pumps’, and ‘positive displacement pumps’. DOE also 

reviewed the definitions in the EU regulation for water pumps [1]. DOE has based the following 

definitions on those in the EU regulation but has not specified the parameters discussed in 

section Item 1-11 and has made other changes for clarification. In addition, DOE has proposed 

definitions for additional equipment coverage beyond that in the EU regulation. DOE may add 

any parameters determined appropriate for this rulemaking to the pump definitions. The 

proposed definitions follow. 

‘Pump’ is a device that moves clean water by physical or mechanical action. 

‘Rotodynamic water pump’ means a pump that moves clean water by means of 

hydrodynamic forces, excluding regenerative turbine pumps. 

‘End suction water pump’ means a single-stage rotodynamic water pump in which the liquid 

enters the pump from the end, opposite the pump’s shaft-end and parallel with the shaft, and 

the discharge is at a right angle from the shaft. 

‘End suction frame mounted water pump’ is an end suction rotodynamic water pump with 

its own bearings; such a pump does not rely on the motor bearings to support the impeller. 
13

‘End suction close coupled water pump’ is an end suction rotodynamic water pump in which 

the motor shaft is extended to become also the pump shaft. 

‘In-line water pump’ means a single-stage rotodynamic water pump in which the water inlet 

of the pump is on the same axis as the water outlet of the pump; such pumps are generally 

installed with the shaft oriented vertically and the motor on top. 

‘Radially split multi-stage water pump’ means a rotodynamic water pump with two or more 

stages in a radially split case. Flow proceeds from the inlet through the stages in series, with 

each stage increasing the total head. The flow rate is the same through each stage. 

‘Submersible water pump’ means a rotodynamic water pump with one or more stages 

designed to be operated in a borehole with the motor fully submerged in the pumped water; 

such pumps are generally vertical turbine pumps with submersible motors mounted to the 

bottom. 

‘Double suction water pump’ means an axially split single-stage rotodynamic water pump 

with two inlets. 

‘Axially split multi-stage water pump’ means a rotodynamic water pump with two or more 

stages in an axially split case that is generally oriented horizontally. 

‘Vertical turbine water pump (non-submersible)’ means a rotodynamic water pump in 

which liquid enters the lower end through the suction bell and then passes through one or 

more stages with impellers and diffuser cases called bowls; these pumps are narrow in 

diameter as a result of their origin as deep-well pumps, and the diffuser bowls are in-line 

with the impellers rather than outside them; above the column section, the pump supports a 

vertical motor located above the pumped water. 

‘Axial/propeller and mixed flow water pump’ means a rotodynamic water pump with an 

impeller(s) that develops head (pressure) through axial or close to axial forces or a mix of 

axial and radial forces, with the characteristic of relatively high rotational speed and flow 

relative to head or intermediate flow and head.13

Item 1-23 DOE requests comment on the suggested definitions for pumps. 

Item 1-24 DOE requests input on whether the definitions proposed by DOE are 

sufficient to allow manufacturers to determine whether their pumps are covered, and in 

which pump category their equipment falls.

Item 1-25 DOE requests comment on what minimum specific speed should define the 

axial/propeller and mixed flow water pump. 

 

13 There is no definite demarcation that separates mixed or axial flow pumps from the more common radial flow 

pumps. However, ranges of specific speed can be used. 
14

DOE is also considering the EU definition for ‘clean water’: 

‘Clean water’ means water with a maximum non-absorbent free solid content of 0.25 kg/m3, 

and with a maximum dissolved solid content of 50 kg/m3, provided that the total gas content 

of the water does not exceed the saturation volume. Any additives that are needed to avoid 

water freezing down to -10°C shall not be taken into account.14

Item 1-26 DOE requests comment on the definition of ‘clean water’. DOE specifically 

requests input on the translation of wording and units to those typically used in the United 

States, such as parts per million limits for suspended and dissolved solids. DOE also seeks 

comment on the appropriateness of the proposed limits. DOE requests clarification on 

whether mixtures including water with freezing points above -10°C should be considered 

clean water for the purposes of this definition and rulemaking. 

Item 1-27 DOE requests comment on whether maximum solids diameter, which is a 

parameter provided with many pump curves, could be used in the definition of ‘clean water’. 

1.4 Efficiency Metrics and Implementation Methods 

To establish a metric15 to determine efficiency for this rulemaking, DOE reviewed the 

metrics and implementation methods used in other regulatory or voluntary programs. 

1.4.1 Pump Efficiency 

Pump efficiency is the ratio of hydraulic power (the product of flow, density, gravity, and 

head) to shaft input power. Pump efficiency does not take motor efficiency into account. 

1.4.1.1 European Union – Clean Water Pumps 

The metric used in the EU regulation for water pumps used in commercial buildings, 

drinking water pumping, the food industry, and agriculture is the pump efficiency [1]. The EU 

has requirements at three different points along the pump pressure/flow curve when operating at 

the pump’s rated speed: full load (i.e., at Best Efficiency Point (BEP)), part load (i.e., at 75 

percent of flow at BEP), and overload (i.e., at 110 percent of flow at BEP). The EU standard 

would set a required efficiency for BEP, and the minimum pump efficiency at part load, and 

overload would be set at the required BEP efficiency multiplied by a factor equal to 0.947 and 

0.985, respectively. A failure at one or more points would mean the pump did not meet the 

standard. This approach accounts for the fact that pumps do not always operate at BEP and has the 

potential to increase pump efficiency over a wider range of operating conditions. 

For minimum pump efficiency levels, the EU is using an equation based on pump type, 

rotating speed, flow, and specific speed (all of which are parameters that affect efficiency): 

 

14 The EU definition of ‘clean cold water’ for testing purposes differs from this definition of “clean water” and 

includes viscosity, density, and temperature limits. 

15 A metric is a standard of measurement, or the parameter DOE will use to determine if a pump meets an energy 

conservation standard. 
15

Where, 

x= ln(ns); y= ln(Q); ln= natural logarithm; Q = flow in [m3/h]; ns= specific speed; C= value 

found in Table 1.5. [1] 

The EU equation, which describes a three-dimensional surface, was defined using data from a 

1998 investigation [7]. The equation is intended to represent pumps that have the same stringency 

of achievable efficiency across all different parts of the surface. The EU sets efficiency standards 

based on desired percentages of the market to cut-off, and they refer to these as minimum 

efficiency indexes (MEIs). By changing the constant, C, the surface can be raised and lowered 

until the desired percentage of market to cut-off is achieved for a particular pump equipment class 

(i.e.,. the percentage of pumps desired to be impacted by the standard is lying below the surface). 

Table 1.5 shows sample values of C. The EU analyzed potential standards from 5% cut-off to 80% 

[9], and the final standard has phased implementation of 10% and 40% levels [1].

Table 1.5 Sample C Values for EU Minimum Pump Efficiency Equation 

C value

Equipment Class MEI= 10% MEI=40%

End Suction Own Bearings, 1450 rpm 132.58 128.07

End Suction Own Bearings, 2900 rpm 135.60 130.27

End Suction Close Coupled, 1450 rpm 132.74 128.46

End Suction Close Coupled, 2900 rpm 135.93 130.77

The EU standard and testing is based on pumps with a full impeller.16 For vertical multistage water pumps, compliance with the standard is based on testing a product with three stages, 

rather than all stage versions of the same basic pump. For submersible multi-stage water pumps, 

compliance is based on testing a product with nine stages. 

The stakeholders have proposed that DOE use the EU metric and approach in considering 

standards for clean water pumps. 

1.4.1.2 Hydraulic Institute (United States) 

 HI 20.3-2010 (Rotodynamic [Centrifugal and Vertical] Pump Efficiency Prediction) 

provides information and figures to predict pump efficiency at a given flow and specific speed 

for industrial-class rotodynamic pumps [11]. Descriptions of these figures (provided in both 

metric and English units) follow: 

 

16 ‘Impeller’ means the rotating component of a rotodynamic pump that transfers energy to the water. ‘Full impeller’ 

means the impeller with the maximum diameter for which performance characteristics are given for a pump size in 

the catalogues of a water pump manufacturer. ” 
16

Figures 20.3a and b provide efficiency versus flow rate curves (at optimum specific 

speed) for 10 different pump categories (eight curves, as some pump categories 

share a curve). 

Figures 20.3c and d provide efficiency corrections (in efficiency points) based on 

specific speed (two curves; one represents nine pump categories). 

Using Figures 20.3a and b and c and d in combination results in a generally 

attainable efficiency for a given pump category at a given flow and specific speed. 

Figures 20.3e and f also provide potential deviation (minimum and maximum 

curves) from normally attainable efficiency by flow, allowing the user to determine 

the range of available pump efficiencies for a given pump type, flow, and specific 

speed (when used in sequence with Figures a and b and Figures c and d). 

Figures 20.3g and h and Figures 20.3i and j provide additional information on efficiency 

increases from improved surface finishes and efficiency decreases due to increased wear ring 

clearances, respectively, but these are designed to help users determine the benefit of making 

improvements to existing, in-use pumps. 

1.4.1.3 Mexico – Vertical Turbine Pumps 

Mexico regulates vertical turbine pumps with external vertical electric motors for 

pumping clean water for irrigation, municipal supply, or industrial supply [8]. For these 

products, there are minimum pump efficiency levels at BEP for 16 equipment classes based on 

nominal bowl diameter and flow ranges. Further adjustments for efficiency are also specified for 

pumps with fewer stages than specified based on catalog curves. 

1.4.1.4 South Korea 

South Korea’s voluntary certification program is based on pump efficiency, according to 

an EU report [9]. Flow at BEP must be within a specified range for each specified discharge bore 

size. Efficiency at BEP must exceed a specified point defined by a plot of efficiency versus flow. 

The efficiency at all flows within the specified range of flow must exceed a point on a separate 

plot of efficiency versus flow, which is approximately 12 efficiency points below efficiency at 

BEP. This is designed to encourage broad efficiency curves. This method does not take into 

account specific speed or head, and target efficiencies do not take into account number of stages. 

1.4.1.5 China 

 China’s efficiency standards are based on pump efficiency at BEP [10]. China uses 

several divisions of products when setting minimum efficiency values. There are three main 

pump categories, and, within each of these categories, additional groupings are based on flow 

ranges and specific speed ranges. The same specific speed correction is used for all pump 

categories. 

1.4.1.6 European Union – Clean Water Pump Selection Guide 

 The EU has a non-regulatory selection guide for single-stage centrifugal clean water 

pumps [12]. As in the EU regulation for water pumps, this guide is based on the relationship 

between pump efficiency, flow, and specific speed. Developers wanted to avoid explaining 

specific speed to pump buyers [9], however, so for each pump type and speed, they produced a 

single figure showing efficiency versus flow rate at optimum specific speed with efficiency 
17

correction curves for various head levels superimposed. The user can look at a single figure, find 

optimum pump efficiency at a certain flow, and then subtract efficiency points for a given head 

from the head correction curves to find out what level of efficiency to expect from a given type 

and size of pump. 

1.4.2 Overall (Wire-to-Water) Efficiency 

Another metric used for pump regulatory programs is overall, or wire-to-water, 

efficiency. Overall efficiency is the ratio of hydraulic power to the electric power input at the 

motor and/or the VSD driving the motor. 

1.4.2.1 Mexico – Submersible Pumps 

The Mexico standard for submersible deep well clean water three-phase motor pumps is 

based on an overall efficiency metric [13]. The minimum overall efficiency a pump-motor unit 

must meet is based on the multiplication of a minimum pump efficiency level (based on nine 

ranges of pump capacity) and a minimum motor efficiency level (based on ten ranges of motor 

size). This effectively results in different minimum overall efficiency levels for 90 equipment 

classes. 

1.4.3 Other 

1.4.3.1 European Union – Circulators 

The EU regulation for circulators uses an energy efficiency index (EEI), which is the 

ratio of the average hydraulic power for a pump (at four different flows) to a reference power 

derived from the relationship between maximum hydraulic power and maximum power 

consumption for the majority of circulators on the market [14]. 

1.4.3.2 Hydraulic Institute – Vertically Suspended Pumps 

ANSI/HI 14.6-2011 (Rotodynamic Pumps for Hydraulic Performance Tests) specifies that 

the performance for vertically suspended pumps (which includes vertical turbines) should be 

based on bowl performance [15]. This is because vertically suspended pumps may be sold with 

any number of stages, all based on a given bowl. Manufacturers would test the bowl for 

performance, as losses for a specific pump configuration would not be known until finalized. 

Bowl efficiency is the ratio of bowl hydraulic power output to bowl shaft or electric power 

input. 

1.4.4 DOE Efficiency Metric Considerations 

1.4.4.1 Overview 

As discussed in section 1.2.3, DOE is considering whether to define and establish 

standards for pumps, pumps inclusive of the motor, or pumps inclusive of the motor and VSD. 

Table 1.6 summarizes the metric DOE is considering for each regulatory option. The subsequent 

section discusses the metrics and reasons for their selection. 
18

Table 1.6 Tentative Proposed Metrics for Pump Regulation Options 

Regulatory Option Equipment Class Set Metric

1 Pumps N/A Pump efficiency at three points

2 Pumps inclusive 

of motor and 

VSD

Pumps Without VSD (with 

or without motor) 

Pump efficiency at three points 

Pumps With VSD Overall efficiency at three points 

3

Pumps inclusive 

of motor, with 

VSD as a design 

option for all 

pumps sold with 

motors

Pumps Without Motor Pump efficiency at three points

Pumps With Motor (with or 

without VSD)

Potentially based on motor/VSD input 

power at multiple load points*

*DOE may also consider the use of pump efficiency as an additional metric or labeling requirement. 

1.4.4.2 Option 1 

If DOE defines and regulates the pump exclusive of the motor and VSD (option 1 in 

section 1.2.3), DOE is considering following the EU’s clean water pump approach based on 

pump efficiency at BEP (at rated speed), part-load (75% of BEP flow), and overload (110% of 

BEP flow), where the pump must meet all three points to meet the standard. As mentioned 

previously, this approach has the potential to increase pump efficiency over a wide range of operating 

conditions. However, for submersible pumps, for which the submersible motor is an integral part 

of the pump, accurate determination of pump efficiency may be difficult as losses must be 

accounted for and distributed between the motor (seal losses) and the pump (losses internal to the 

pump wet end, losses caused by using pumped liquid to cool the driver, etc.). As a result, DOE 

may consider a metric of overall (wire-to-water) efficiency (within the framework of the EU 

standard) for submersible pumps. Alternatively, DOE may consider a metric of bowl efficiency 

for vertically suspended pumps including vertical turbines and submersibles, as DOE 

understands that this is common testing practice for manufacturers. 

Item 1-28 DOE requests comment on its proposal to follow the EU approach using pump 

efficiency if pumps are defined without the motor or controls. DOE is especially interested in 

whether a pump should have to meet a standard at multiple load points, or if a weighted 

average metric should be developed. 

Item 1-29 DOE requests comment on the selection of 75% BEP flow as the part-load 

point and 110% as the overload point and whether these are the most appropriate points to 

encourage broad pump efficiency curves. 

Item 1-30 DOE requests comment on whether the use of an overall efficiency metric for 

submersible pumps would cause problems for manufacturers, as the EU metric is pump 

efficiency. 
19

Item 1-31 DOE requests comment on whether the metric for vertically suspended pumps 

should be bowl efficiency rather than pump efficiency. 

1.4.4.3 Option 2 

If DOE defines and regulates pumps inclusive of the motor and VSD if sold together 

(option 2 in section 1.2.3), DOE would follow the same metric approach discussed for regulation 

option 1 for equipment classes for pumps sold without VSDs. For equipment classes for pumps 

sold with VSDs, DOE would identify a metric that can be used to consider efficiency levels that 

require the use of more efficient VSDs; such a metric does not need to compare pumps with 

VSDs to pumps without VSDs, because pumps without VSDs (with or without motors) would be 

in a separate set of equipment classes. For extended products including both motors and VSDs if 

sold together, DOE is considering a metric of overall efficiency, measured as the ratio of 

hydraulic power to the electric power input at the VSD. (This metric can also be thought of as 

the product of pump efficiency, motor efficiency, and VSD efficiency.) DOE is considering 

capturing overall efficiency at BEP, part-load (75% of BEP flow), and overload (110% of BEP 

flow) for this metric as well. The pump, motor, and VSD must be tested together because VSDs 

are not regulated separately (and thus there is no verified source of VSD efficiencies), motors are 

regulated only at full-load, and VSDs and motors in combination do not necessarily operate with 

the efficiency that would be calculated by multiplying their individual tested efficiencies 

together. 

Item 1-32 DOE requests comment on its proposal to adapt the EU standard metric to 

overall efficiency for pumps sold with both motors and VSDs. DOE is also interested in 

whether additional test points should be added below 75% of BEP flow to address more of 

the operating range of pumps with VSDs. 

1.4.4.4 Option 3 

If DOE decides to define and regulate pumps inclusive of the motor if sold together and 

include VSD as a design option (option 3 in section 1.2.3), DOE would follow the same metric 

approach discussed for regulation option 1 for equipment classes for pumps sold without motors. 

For equipment classes sold with motors, DOE would identify a metric that can capture the 

impacts on energy efficiency associated with the use of a VSD in comparison to a pump with a 

motor but without a VSD. DOE could then consider efficiency levels that require VSDs and 

high-efficiency VSDs. 

VSDs create two main energy-related benefits compared to throttling (either to better 

match the pump to a constant load or to match different loads at different times). First is the 

ability to reduce power when operating at flows lower than full flow17; pumps roughly follow 

affinity laws, and in the “cube law”, pumps running at 75% speed require approximately 42% 

power, for example, depending on a variety of parameters, including the system in which the 

pump operates. Figure 1.1 demonstrates this effect, as the power required at 75% flow using 

 

17 This benefit may be realized in variable load systems when flows less than the maximum flow are required. It may 

also be realized in constant load systems with oversized pumps, when a VSD is used to reduce speed and flow to the 

system requirements; however, it would use more power in constant load systems with correctly sized pumps. 
20

speed reduction is much less than the power required at 75% flow using throttling. Note that 

75% is just an example; the “cube law” can be used with different speed reductions as well. 

Second, when reducing flow by shifting the pump performance curve using speed control, pump 

efficiency is roughly maintained relative to BEP. When reducing flow by throttling (and shifting 

the system curve), pump efficiency degrades. Figure 1.1 also demonstrates this effect, as pump 

efficiency at Point B (throttling) is lower than pump efficiency at Point C (speed reduction). 

Figure 1.1 shows both of these benefits for a friction-only system (i.e., a system with no static 

head), in which VSD benefits are greatest. Systems with high static head will have lower power 

savings and will also have lower efficiency at reduced flows. If relatively high heads must be 

maintained at low flows, very little speed reduction may be possible. 

Use of a VSD introduces losses into the system, which can be seen in overall or wire-towater efficiency. At all flows, a pump with VSD will have lower overall efficiency than a pump 

without VSD. Furthermore, while motor efficiency does not degrade significantly with speed 

reductions up to 50% or more, the efficiency of a VSD degrades more significantly. As a result, 

overall efficiency at 75% flow using a VSD is less than overall efficiency at 100% BEP flow and 

may be less than overall efficiency at 75% flow achieved through throttling, depending on a 

variety of parameters including the pump efficiency curve. However, at reduced flows, this 

efficiency loss, combined with the significantly reduced power requirements of a VSD, means 

that the power drawn by the motor and VSD will still be less than the power drawn for a throttled 

situation. Table 1.7 shows an example of the effect of drive efficiency on overall efficiency, as 

well as the resulting motor/drive input power requirements. 
21

Figure 1.1 Flow Reduction from Throttling and Use of VSD 
22

Table 1.7 Example Pump Parameter Comparison With and Without VSD 

Without VSD With VSD

Rated 

Speed, 

100% BEP 

Flow

Rated 

Speed, 75% 

BEP Flow 

(Throttled)

Rated 

Speed, 

100% BEP 

Flow

Reduced 

Speed, 

75% BEP 

Flow

Operation 

Conditions

Flow (gpm) 120 90 120 90

Head (feet) 300 330 300 169

Speed (rpm) 3550 3550 3550 2663

Efficiencies

Pump Efficiency 86% 82% 86% 86%

Motor Efficiency 89% 89% 89% 89%

VSD Efficiency N/A N/A 97% 94%

Combined Motor/VSD Efficiency N/A N/A 86% 84%

Overall Efficiency 77% 73% 74% 72%

Power

Water (Hydraulic) HP 9.1 7.5 9.1 3.8

Pump Shaft Input Power (HP) 10.6 9.1 10.6 4.5

Motor/ VSD Input Power (HP) 11.9 10.3 12.2 5.3

Potential Metrics

Motor/VSD Input Power Per Unit 

Operating Flow (HP/ gpm) 0.099 0.114 0.102 0.059

Ratio motor/VSD input power at 

given condition to motor/VSD 

input power at full speed, 100% 

flow, no VSD condition

1.00 0.87 1.03 0.45

DOE would consider metrics other than pump and overall efficiency to capture the 

energy efficiency impacts of VSDs for pumps sold with motors. These metrics may need to be 

based on motor/control input power, such as the input power requirement per unit flow18 or the 

ratio of input power at part-load to input power at full-load measured or calculated without VSD, 

rather than efficiency metrics for the pump, pump/motor, or pump/motor/VSD combination only. 

Table 1.7 shows examples of these metrics. Such metrics show both the power-saving benefits of 

VSDs and the losses associated with the presence of a VSD. DOE is interested in suggestions for 

metrics that would achieve the stated goals for this approach. 

Item 1-33 DOE requests comment on the appropriate metric to capture the energy 

efficiency impacts of VSDs. DOE is interested in whether test points at BEP, 75% BEP flow, 

and 110% BEP flow are appropriate for this metric and whether additional test points should 

be added below 75% BEP flow to address more of the operating range of pumps with VSDs. 

DOE is also interested in whether pumps should be required to meet minimum levels at 

multiple points or if a weighted average metric should be developed. 

 

18 Although a power per flow requirement could potentially be seen to penalize high-pressure pumps, a standard 

could be based on specific speed, which would take into account head needs. 
23

1.4.4.5 Additional Considerations 

For the overload condition (110% of BEP flow), DOE is considering whether for both 

regulation options 2 and 3, overspeeding should be used to achieve the overload test point for the 

metrics designed to capture the benefits of VSDs. This may not be a realistic way to provide an 

indication of how the pump performs in the field, as most pumps are likely oversized and could 

be operated at 110% of BEP flow without overspeeding. However, some systems could be set up 

to use overspeeding on occasion to meet especially large loads instead of oversizing the pump 

for its general duty. 

Item 1-34 DOE requests comment on whether the metric for regulatory option 2 and 3 

should include an overload test point based on overspeeding. 

As mentioned previously, if DOE defines pumps inclusive of the motor or motor and 

VSD, DOE would likely have two sets of equipment classes for regulatory options 2 and 3. 

(Regulatory option 1, where pumps are defined exclusive of the motor and controls, would have 

only one set of equipment classes.) For regulatory option 2, there would be one set for pumps 

sold without a VSD and one set for pumps sold with a VSD. For regulatory option 3, there would 

be one set for pumps sold without a motor and one set for pumps sold with a motor. DOE is 

exploring the options for metric alignment for these different cases, and the metrics for use 

within each option are summarized in Table 1.8.

Separate metrics: DOE would use metrics that differ by equipment class set within each 

regulatory option. For example, a pump sold without a motor or drive would use a pump 

efficiency metric that considers only pump losses, while a pump sold with a motor and 

drive would use an overall efficiency metric that also considers losses associated with 

motor and control inefficiencies. Although efficiencies would not be comparable across 

equipment class sets (i.e. pump efficiency would generally be higher than overall 

efficiency because it includes only pump losses), this would allow for an appropriate 

metric to be used to evaluate energy saving potential for the different equipment. 

Same metrics: DOE would use the same metric for both sets of equipment classes in a 

given regulatory option. The test procedure would specify nominal motor and/or VSD 

efficiency to be incorporated into the performance metric for pumps sold without one or 

both items. This option could enable the test results for all pumps to be directly 

comparable regardless of the equipment with which they are sold. DOE notes, however, 

the motor or VSD used in the field may have different efficiency characteristics than those 

selected for testing.

Multiple metrics for equipment sold with a VSD (or with the motor where a VSD is a 

technology option to improve efficiency). DOE is analyzing whether the equipment class 

set that addresses VSDs could have two metrics. In the alternative, DOE is analyzing 

whether one of the metrics could be used as a labeling requirement. This approach would 

allow comparison across all pumps using the common metric of pump efficiency, no 

matter how the pumps are sold, and also would account for the motor or VSD actually 

used with the pump. 
24

Table 1.8 Metric Alignment Options 

Regulatory

Option Equipment Class Set

Metric Alignment Options

Separate Same Multiple

2 Pumps 

inclusive of 

motor and 

VSD

Pumps Without VSD 

(with or without 

motor) 

Pump 

Efficiency

Overall 

Efficiency 

(standardized 

motor and 

VSD)

Pump 

Efficiency

Pumps With VSD Overall 

Efficiency

Overall 

Efficiency

Pump 

Efficiency and 

Overall 

Efficiency

3 Pumps 

inclusive of 

motor, with 

VSD as a 

design option 

for all pumps 

sold with 

motors

Pumps Without Motor Pump 

Efficiency

Motor/VSD 

Input Power 

Based 

(standardized 

motor)

Pump 

Efficiency

Pumps With Motor 

(with or without VSD)

Motor/VSD 

Input Power 

Based

Motor/VSD 

Input Power 

Based

Pump 

Efficiency and 

Motor/VSD 

Input Power 

Based Metric

 DOE notes that the options for metric alignment may impact manufacturer burden. For 

pumps sold both with and without motors or with and without VSDs, the same pump may be included 

in two different equipment classes, one for the pump alone and one for the pump with the motor or 

motor and VSD. Each of these equipment classes would be subject to a different standard. The same 

test stand, however, could be used in both cases, and some metrics or metric alignment options may 

simply require additional measurements or calculations. For example, in regulatory option 2, the 

separate alignment option would require reporting pump efficiency for a pump sold without a VSD 

and overall efficiency for a pump sold with a VSD. The manufacturer would measure hydraulic power 

in each case, but for pumps without VSD they would also measure shaft input power, while for pumps 

with VSDs, they would measure electric input power to the VSD. For the same metric alignment 

option, the same testing would be required, but for pumps without VSD, the pump efficiency would 

be multiplied by a standard motor and VSD efficiency to arrive at the overall efficiency (in other 

words, standardized efficiencies could be employed rather than requiring testing with standardized 

motors and VSDs). 

Item 1-35 DOE recognizes that the same pump may in some cases be sold alone or may 

be sold in conjunction with a motor or motor/control package. DOE seeks comment on any 

issues that may result from having different metrics for pumps sold alone and pumps sold 

with motors or VSDs. 
25

1.4.5 Discussion of Potential Implementation Method 

1.4.5.1 Efficiency Surfaces 

DOE is considering whether any standard developed would be a function of specific speed 

and flow, as in the EU water pumps regulation, which would eliminate the need to develop hundreds 

of equipment classes based on ranges of these parameters. Flow and specific speed may be 

appropriate parameters on which to base efficiency. The efficiency of a pump is primarily 

determined by (1) size, (2) speed, and (3) ratio of the casing throat diameter to the impeller 

diameter [19]. The last parameter can be represented by specific speed. Research has shown that 

flow can be used as a proxy for the influence of the first two parameters, size and speed [19].

DOE could use the EU equation in its rulemaking as the basis for defining pump efficiency 

levels. DOE’s preliminary investigations, however, indicate that the distribution of efficiency of the 

U.S. pump market is sufficiently different than that of the EU pump market that the EU’s minimum 

pump efficiency surface does not provide a good representation of efficiency levels. For example, 

Figure 1.2 shows that, in the United States, the EU surfaces would eliminate from the market more 

ESCC pumps at low MEIs and fewer ESCC pumps at high MEIs.19 For example, the 5% EU MEI 

would eliminate 13% or more of U.S. pumps, while the 80% MEI would eliminate approximately 

72% of U.S. pumps. In effect, there is a significantly wider distribution of efficiencies in the United 

States than in the EU. Appendix B contains examples for other equipment classes. DOE recognizes 

that its current database may not be fully representative of the entire U.S. pump market and a revised 

database could show a better match with the EU market. 

 

19 U.S. data are based on a database of pump models and performance data compiled using PUMP-FLOTM Desktop, 

a pump selection tool from Engineered Software. This tool provides performance data at five to six flow and head 

points for each pump from the catalogs of 115 manufacturers or brands, representing approximately 50% of the 

market. DOE removed from the database the 50 hz catalogs and various forms of wastewater and sealless pumps, as 

well as some other pumps not proposed for coverage. DOE then attempted to classify these pumps into coverage 

categories based on information gathered from websites. 
26

Note: The chart labels show U.S. percentages for 2-pole pumps. 

Figure 1.2 Comparison of EU MEIs to US Market for ESCC Pumps (Based on BEP 

Only) 

DOE could potentially address the problem of the U.S. market not matching the EU market 

simply by changing the C values as desired to represent a given efficiency level. (As mentioned in 

section 1.4.1.1, the EU uses the same surface shape for all equipment classes and MEIs.) 

Alternatively, DOE could develop separate equations (surfaces) unique to individual equipment 

classes by performing regressions on the data in its database,20,21 and change the surface shape from 

bottom- to top-of-market to more accurately represent the market and potential efficiency levels. For 

example, pumps with higher flows typically can reach higher efficiencies at BEP compared to smaller 

flow pumps. As the surface moves from bottom-to-top, DOE can account for the fact that the 

difference in efficiency from bottom- to top-of-market for higher flow pumps is much smaller than the 

difference for smaller flow pumps; the surface will become flatter and flatter from bottom to top of 

market. DOE could develop all these surfaces using the same equation form as the EU, but with 

different coefficients for each parameter in the equation (not just the C value).22 Details regarding the 

coefficients and equations can be found in Appendix C. 

Figure 1.3 shows an example of a surface that DOE developed to represent the average 

ESCC market (based on model availability), compared to the EU MEI 50% level. Figure 1.4

shows the U.S. average ESCC surface again, along with a bottom-of-market and top-of-market 

surface. Figure 1.5 shows a 2D “slice” of the 3D surfaces for the specific speed range of 1,500 to 

 

20 DOE seeks additional data to create unique surfaces for the radially split and axially split multi-stage equipment 

categories. DOE currently has on the order of 1,000 or more pumps for the remaining equipment classes, although 

these numbers could decrease based on the definition of clean water and the employment of flow, head, or power 

limits for coverage. 

21 Researchers in the EU note that they did not change the surface by pump type because the main hydraulic 

components (impeller and volute) for the pumps in scope are not very different. 

22 Note that the coefficients and surfaces shown in this section are for ESCC pumps of all poles or design speeds. 

Separate surfaces based on design speed are discussed further in section 3.2.3 as part of a larger equipment class 

discussion. 

13%

16%

20% 24%

31%

40%

46%

54%

64%

72%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP flow

US 2 poles

US 4 poles

EU
27

2,500. This slice demonstrates the flattening of the surface from bottom- to top-of-market. These 

surfaces are meant to be examples of surface development methodology only, and further discussions 

on choosing the baseline and market maximum surfaces can be found in sections 5.4 and 5.5, 

respectively. As mentioned previously, DOE recognizes that its current database may not be fully 

representative of the entire pumps market. As such, any efficiency surfaces developed are subject to 

change and are shown here only to demonstrate a potential methodology. Appendix C also contains a 

discussion on the influence of the exact definition of clean water pumps on the surface development. 

Figure 1.3 Comparison of DOE ESCC Average Surface with EU MEI 50% 4-Pole 

Surface 

EU (Blue)

DOE (Green) (Green)
28

Figure 1.4 Example Average, Top-of-Market, and Bottom-of-Market Efficiency Levels 

for ESCC Pumps 

Figure 1.5 Example 2D Specific Speed “Slice” (Ns=1500-2500) Showing Average, Topof-Market, and Bottom-of-Market Efficiency Levels for ESCC Pumps 

Average (Green) Thick-1500; Thin-2500

Bottom-of-Market (Red)

Top-of-Market (Blue)

Average (Green)

Bottom-of-Market (Red)

Top-of-Market (Blue)

Average (Green)

Bottom-of-Market (Red)

Top-of-Market (Blue)
29

Item 1-36 DOE seeks comment regarding the implementation methodology described in 

this section, including whether basing efficiency on flow and specific speed is appropriate 

and, if so, whether the EU surface should be used as is, with adjusted Cs, or with modified 

shapes (adjustment of all coefficients). The last option would allow type- and efficiency 

level-specific surfaces. DOE also seeks comment on whether other parameters or 

combinations of parameters would be more appropriate or easier to implement, such as flow 

and head (instead of specific speed). 

Item 1-37 DOE requests data that would help it improve its database, specifically 

performance data (i.e., head, flow, power, and efficiency at BEP and multiple additional 

points) for clean water pumps from catalogs not available on PUMP-FLO. 

Item 1-38 DOE seeks comment on how to calculate specific speed (with regard to flow) 

for double suction axial split pumps and axially split multi-stage pumps with a doublesuction first stage (i.e., whether to use total flow ore one-half the flow). 

1.4.5.2 Standards for Off-Design Performance 

DOE may also consider having a three-point efficiency metric. As mentioned in section 

1.4.1.1, the EU requirement for part-load (75% of BEP flow) is 0.947 times the requirement at BEP, 

and the requirement for over-load (110% of BEP flow) is 0.985 times the requirement at BEP. For 

ESCC pumps in DOE’s database, efficiency at 75% BEP flow is on average 0.951 times efficiency at 

BEP, and efficiency at 110% BEP flow is 0.985 times efficiency at BEP; the values are similar for 

ESFM. While these values are very similar to those used in the EU, an analysis of individual pumps 

compared to their EU minimum required efficiency at part-load and over-load indicates that 

application of the EU part-load and over-load standards would have a different result when applied to 

pumps in the U.S. market. This is demonstrated in Figure 1.6 and Figure 1.7, and additional figures 

can be found in Appendix B. However, it is important to note that these results are impacted by the 

appropriateness of the EU’s surface, which may also not necessarily represent the U.S. market at BEP. 
30

Note: U.S. percentages shown for 2-pole pumps only. 

Figure 1.6 Comparison of EU MEIs to US Market for ESCC Pumps (75% BEP) 

Note: U.S. percentages shown for 2-pole pumps only. 

Figure 1.7 Comparison of EU MEIs to U.S. Market for ESCC Pumps (110% BEP) 

Item 1-39 DOE seeks test data for pumps at 75% and 110% BEP flow points that would 

allow it to better analyze potential efficiency levels for these points. 

8% 10% 13% 16%

24%

32%

37%

44%

52%

57%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 75% BEP flow

US 2 poles

US 4 poles

EU

21%

26%

30%

37%

49%

61%

68%

75%

82%

88%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 110% BEP flow

US 2 poles

US 4 poles

EU
31

1.4.5.3 Other Considerations 

In addition, DOE is considering requiring testing based on three stages for radially split multistage pumps and nine stages for submersible pumps, as in the EU approach.23 However, DOE 

believes that because axially split multi-stage pumps are not cellular in nature, those pumps would 

have to be tested in the stage configuration in which they are sold. 

DOE is also considering whether to follow the EU approach in which the standard is 

based on the energy efficiency of pumps with a full impeller. Pump manufacturers typically 

design fewer pump housings than impeller sizes for cost reasons. A given pump housing can be 

sold with a full impeller or with reduced diameter impellers, down to approximately 80% of full 

diameter. Efficiency at reduced diameters is generally less than with a full diameter. However, 

many in the industry advocate purchasing a pump with a reduced impeller diameter, so that when 

load increases in the future, only the impeller has to be replaced rather than the entire pump. On 

the other hand, trimming impellers is a common practice in the field to bring the pump operation 

closer to the desired duty point. 

Improving the efficiency of pumps can be achieved through use of a full impeller, which 

would result in the design and manufacture of additional sizes of pump casings. Increasing the 

variety of available pump casings would likely be extremely cost prohibitive for manufacturers, 

however, and would have no benefits if pumps were not correctly sized. 

Item 1-40 DOE requests comment on the appropriateness of setting a standard based on 

a full impeller. 

Item 1-41 DOE requests comment on standards based on certain numbers of stages for 

radially split multi-stage and submersible pumps. DOE also seeks comment on whether the 

same approach could be taken for axially split multi-stage pumps. 

Item 1-42 DOE requests data on the percent of pumps sold with a full impeller, as well 

as the distribution of pump sales with reduced impellers (as a percentage of full impeller). 

1.5 Test Procedures 

Manufacturers must use a DOE prescribed test procedure to establish compliance with 

any standards adopted and make representations of energy efficiency for commercial and 

industrial pumps. DOE also uses the established test procedure to subsequently verify the 

performance of covered equipment once standards have been established. Thus, in conjunction 

with considering setting standards for commercial and industrial pumps, DOE is also considering 

a test procedure rulemaking that would define the requisite DOE test procedure for all covered 

commercial and industrial pumps. DOE intends for the test procedure to include an efficiency 

descriptor and the methods necessary to adequately measure the performance of the pump for the 

purposes of determining compliance with energy conservation standards. 

 

23 If this number of stages is not offered within the specific product range, the next higher number of stages within 

the product range is to be chosen for testing. 
32

 When establishing or amending test procedures, DOE reviews existing industry test 

procedures currently used to measure the energy use or energy efficiency of the covered 

equipment. DOE then considers whether to: (1) adopt a test procedure(s) in its entirety, (2) adopt 

portions of a test procedure(s) with modification or additions, or (3) develop a new test 

procedure if existing test procedures do not provide necessary energy use or efficiency methods 

necessary to calculate DOE’s energy use or efficiency metrics. In addition, DOE’s test 

procedures consider ambient test conditions, repeatability and tolerances on test conditions and 

results, and calibration and accuracy of test equipment, among other things. Table 1.9 shows a 

number of test procedures that relate to the pumps for which DOE is considering establishing 

standards. 

Table 1.9 Overview of Currently Available Pump Test Procedures 

Test Procedure Origin Notes

ANSI/HI 14.6-2011 Rotodynamic Pumps for 

Hydraulic Performance Acceptance Tests

U.S. Harmonized with ANSI/HI 11.6 

and ISO 9906-2012

ANSI/HI 11.6-2012 Submersible Pump Tests U.S. Harmonized with ANSI/HI 14.6

ISO 9906-2012 Rotodynamic pumps –

Hydraulic performance acceptance tests –

Grades 1, 2 and 3 

International Harmonized with ANSI/HI 14.6 

ISO 5198-1999 Centrifugal, mixed flow, and 

axial pumps. Code for hydraulic performance 

tests. Precision class

International Provides guidance for 

measurement of very high 

accuracy. Includes specification 

of an optional thermodynamic

method for direct measurement 

of efficiencies.

AS 2417-2001 Rotodynamic pumps -

Hydraulic performance acceptance tests -

Grades 1 and 2

Australia Based on ISO 9906

GB/T 3216-2005 China Based on ISO 9906

NOM-010-ENER-2004 Submersible deep 

well clean water motor pumps

Mexico Based on ISO 9906

NOM-001-ENER-2000 Vertical turbine 

pumps with external vertical electric motor 

for pumping clean water for irrigation, 

municipal supply, or industrial supply

Mexico Based on ISO 3555 (predecessor 

to 9906)

 DOE will review these test procedures, along with additional test procedures that may not 

be listed in Table 1.9, in the test procedure rulemaking. In discussions with stakeholders, DOE 

determined that ANSI/HI 14.6-2011 - Rotodynamic Pumps Hydraulic Performance Tests, 

ANSI/HI 11.6-2001 - Submersible Pump Tests, and ISO 9906-2012 - Rotodynamic Pumps - 

Hydraulic Performance Acceptance Tests- Grades 1, 2 and 3 are the most widely used in the 

industry. DOE, in its test procedure development, aims to align its test procedure with existing 

and widely used industry test procedures to the extent possible, to limit unnecessary burden on 

manufacturers. DOE discusses its preliminary review of these test procedures and approaches in 

section 1.5.1.
33

1.5.1 Preliminary Discussion of Approaches 

In the test procedure rulemaking, DOE will consider methods that are not unduly 

burdensome to conduct for measuring the energy efficiency, energy use, or average annual 

operating cost of covered pumps during a representative average use cycle or period of use. (42 

U.S.C. 6314(a)(2)) In prescribing new test procedures, DOE takes into account relevant 

information including technological developments relating to energy use or energy efficiency of 

pumps. The test procedure will be specifically designed to produce results consistent with the 

metrics discussed in section 1.4.

The ANSI and HI test procedures ANSI/HI 14.6-2011 and 11.6-2012, and the 

International Organization for Standardization (ISO) 9906-2012 procedure for rotodynamic 

pumps, define uniform methods for conducting laboratory tests to determine flow rate, head, 

power, and efficiency at a given speed of rotation. These test methods employ similar metrics, 

test conditions, and protocols. 

ANSI/HI 14.6-2011 and 11.6-2012 and ISO 9906-2012 are conventional test methods 

requiring measurements of actual flow of the pumped liquid. Test methods specified in ANSI/HI 

14.6-2011 and ISO 9906-2012 apply to any size centrifugal, mixed, and axial flow rotodynamic 

pump (without fittings) using any pumped liquid behaving as clear water. ANSI/HI 14.6-2011 

and ISO 9906-2012 also allow for the use of alternative homogenous liquids24 when water is not 

appropriate for the application. ANSI/HI 14.6-2011 and ISO 9906-2012 mirror each other 

sufficiently and include methods to measure performance of the covered products such that DOE 

believes ANSI/HI 14.6-2011 is applicable for testing all commercial and industrial pumps 

proposed for coverage in Table 1.1. 

In contrast, test methods described in ANSI/HI 11.6-2012 apply only to centrifugal 

submersible pumps (close coupled impeller pump/motor unit) driven by induction motors and 

designed to operate submerged in liquid with the exception of submersible vertical turbine 

pumps. ANSI/HI 11.6-2012 also requires the test be performed with clean water. DOE 

understands that this test method is specific to submersible pumps and has similar metrics and 

test methods to ANSI/HI 14.6-2011. As such, ANSI/HI 11.6-2012 may be more appropriate for 

submersible pumps and better account for test conditions and specific test requirements when the 

pump and motor are fully submerged in the pumping fluid. 

As another approach, DOE could consider a test procedure based on fundamental 

thermodynamic principles, such as ISO 5198-1999. This test standard does not require actual 

measurement of flow, but rather relies on temperature and pressure measurements at both the 

suction and delivery sides of the pump. The differential pressure and temperature across the 

pump are then used to determine the energy lost due to inefficiency. 

As discussed in section 1.3.2, DOE may define commercial and industrial pumps 

inclusive of motors and VSDs. ANSI/HI 14.6-2011 provides a potential basis for testing overall 

system efficiency (wire-to-water) with motors and VSDs, using a wattmeter to measure the input 

power to the motor or VSD, as opposed to the input power to the pump. ANSI/HI 14.6-2011 also 

 

24 Maximum viscosity limits apply when liquids other than water are appropriate for the application. 
34

describes a “string” test that relies on rated efficiencies of the motor or VSD, or both, to 

determine the pump efficiency (as a component of overall system efficiency); however, the 

rating attained through the string tests in ANSI/HI 14.6-2011 is less accurate than when the 

pump is tested by itself. ANSI/HI 11.6-2012 also provides for the calculation of either pump 

efficiency or overall efficiency for submersible pumps. 

ANSI/HI 14.6-2011 provides specifications for a test and suggestions regarding 

measurement equipment in Appendix I, as well as calibration requirements in Appendix J. 

Because test accuracy and repeatability can vary based on the sensitivity and calibration of the 

selected measurement equipment, it is important for DOE to consider the impact of different 

measurement instruments on test results. 

For certain commercial equipment, DOE also allows the use of specific approved 

calculation methods to determine the rated efficiency of a certain piece of equipment based on a 

similar piece of equipment that has been physically tested. This can reduce the burden of test on 

manufacturers. ANSI/HI 14.6-2011 Appendix K includes scaling methods that can be used to 

translate the behavior of a model to that of a geometrically, kinematically, and dynamically 

similar prototype pump which has not been tested. DOE is considering the impacts of scaling on 

the accuracy of the calculated rated efficiency of some pump models 

As part of DOE’s test procedure rulemaking, DOE will also consider establishing 

tolerances on test conditions and test results and defining the number of units that should be 

tested. DOE’s certification, compliance, and enforcement (CCE) requirements, located at 10 

CFR 429, typically require a minimum of two unique units be tested to calculate the average 

certified rating for basic models that require testing. 

If DOE references ANSI/HI 14.6-2011, DOE is considering requiring that tests conform 

to “Grade 1” tolerances for the purposes of certification with DOE energy conservation 

standards. As is allowed in ANSI/HI 14.6-2011, DOE is considering allowing for larger 

tolerances for pumps with input power of less than 10 kW (13 hp). In this case, DOE may also 

consider increasing the number of units tested for small shaft power pumps to increase the 

repeatability and accuracy of the certified rating. 

Item 1-43 DOE requests comment on the use of the ANSI/HI 14.6-2011, ANSI/HI 11.6-

2012, , ISO 9906-2012, and ISO 5198-1999 test procedures, as well as any other test 

procedures, as a basis for the development of a DOE test procedure, including any 

modifications or additions that may be necessary. 

Item 1-44 DOE requests comment on the scope of each test procedure with respect to the 

equipment for which DOE is considering standards, as well as any limitations of these test 

procedures. 

Item 1-45 DOE is also interested in the pros and cons of using a thermodynamic 

approach to determining pump or pumping system efficiency, as in ISO 5198-1999. 
35

Item 1-46 DOE requests comment on use of “Grade 1” from ANSI/HI 14.6-2011 

tolerances for all pump categories and whether it places any additional burden associated 

with performing testing requirements for all covered equipment classes. 

Item 1-47 DOE requests comment on the applicable test procedures for complete pump, 

motor, and VSD system packages. 

Item 1-48 DOE requests comment on the accuracy of different measurement equipment 

used to measure pump power, input power to a motor or VSD, pump flow, head, or other 

parameters and their impact on the accuracy of the measured pump efficiency. DOE also 

requests comment on the calibration frequency required to maintain sufficient equipment 

accuracy. 

Item 1-49 DOE requests comment on the applicability of calculation methods to 

determine rated pump efficiencies from similar, tested pump efficiencies. 

Item 1-50 DOE requests comment on the number of unique pump models manufacturers 

would have to test, as well as the ability for a calculation method to reduce testing burden. 

DOE also requests comment on the reduction in test accuracy when using a calculation 

method to determine rated efficiency of a unit. 

1.6 Overview of the Rulemaking Process and Stakeholder Participation 

Under EPCA, any new or amended standards must achieve the maximum improvement 

in energy efficiency that is technologically feasible and economically justified. In setting any 

new or amended standards, DOE must consider: (1) the economic impact of the standard on the 

manufacturers and consumers of the affected products; (2) the savings in operating costs 

throughout the estimated average life of the product compared to any increases in the initial cost 

or maintenance expense; (3) the total projected amount of energy savings likely to result directly 

from the imposition of the standard; (4) any lessening of the utility or the performance of the 

products likely to result from the imposition of the standard; (5) the impact of any lessening of 

competition, as determined in writing by the Attorney General, that is likely to result from the 

imposition of the standard; (6) the need for national energy conservation; and (7) other factors 

the Secretary considers relevant. (42 U.S.C. § 6295(o)(2)(B)(i) and 42 U.S.C. § 6316(a)) 

As discussed in further detail below, the standards rulemaking process typically includes 

four steps for a given consumer product or commercial/industrial equipment type: (1) the 

publication of a framework document in which DOE describes the overall approach it is 

considering in developing potential energy conservation standards for a particular product or 

equipment; (2) the publication of a preliminary analysis that focuses on the analytical 

methodology DOE is considering in setting potential standards; (3) the issuance of a notice of 

proposed rulemaking (NOPR); and (4) the issuance of a final rule. At each of the first three steps, 

DOE holds a public meeting and solicits comments from the public on a variety of relevant 

issues under consideration in developing potential standards. 
36

A brief description of the next steps in DOE’s process follows:

Preliminary Analysis (section 1.6.1). The preliminary analysis presents a discussion of 

comments received on the framework document and is designed to publicly vet the 

models and tools that DOE intends to use in the rulemaking. Using these models and 

tools, DOE performs preliminary analyses to assess candidate standard levels (CSLs), 

which span the range of efficiencies from baseline equipment to the most efficient 

technology. 

Notice of Proposed Rulemaking (NOPR; section 1.6.2). The NOPR presents a discussion 

of comments received in response to the preliminary analysis; DOE’s analysis of the 

impacts of potential standards on consumers, manufacturers, and the nation; DOE’s 

weighting of these impacts; and any proposed standard levels for public comment. 

Final Rule (section 1.6.3). The final rule presents a discussion of comments received in 

response to the NOPR, revised analyses, as appropriate, of the impacts of any standards, 

DOE’s weighting of those impacts, and the standard levels, if any, that DOE is adopting. 

The final rule also establishes the date by which manufacturers must comply with any 

standards. 

DOE encourages interested parties to develop and submit joint recommendations and will 

carefully consider such recommendations in its decision making. DOE will also post to the 

website analytical tools, analysis, and data as soon as it becomes available. 

1.6.1 Preliminary Analysis 

 As part of its energy conservation standards rulemaking activity, DOE typically identifies 

equipment technology options and makes a preliminary determination as to whether to retain 

each option for detailed analysis or to eliminate it from further consideration. This process 

includes a market and technology assessment (section 0) and a screening analysis (section 4). 

DOE applies four screening criteria in the screening analysis to determine which technology 

options to eliminate from further consideration: (1) technological feasibility; (2) practicability to 

manufacture, install, and service; (3) adverse impacts on equipment utility or availability; and 

(4) adverse impacts on health or safety. Technologies that pass through the screening analysis are 

evaluated, and referred to as design options, in the engineering analysis. 

 DOE consults with interested parties and researches industry literature to identify the 

design options or efficiency levels that DOE will consider in the rulemaking. 

DOE considers design options or efficiency levels for each equipment class. DOE uses 

these design options or efficiency levels to collect manufacturer cost data, historical shipment 

data, shipment-weighted average efficiency data, and preliminary manufacturer impact data (e.g., 

capital conversion expenditures, marketing costs, and research and development (R&D) costs). 

Using these data, DOE conducts other analyses as part of the preliminary analysis, 

including: 

1. engineering analysis (section 5);

2. markups analysis (section 6);
37

3. energy use analysis (section 7);

4. consumer life-cycle cost (LCC) and payback period (PBP) analyses (section 8); 

5. shipments analysis (section 9);

6. national impact analysis (NIA), which considers national energy savings (NES) and 

consumer net present value (NPV) (section 10); and 

7. preliminary manufacturer impact analysis (MIA) (section 12). 

 DOE will present the results of these analyses in the preliminary analysis technical 

support document (TSD). 

Based on the preliminary results of these analyses, DOE selects CSLs from the energy 

efficiency levels considered in the preliminary analysis. In addition to the efficiency level 

corresponding to the maximum technologically feasible (“max-tech”) efficiency level, DOE 

generally considers efficiency levels or design options that span the full range of technologically 

achievable efficiencies. The range of efficiency levels DOE typically analyzes includes the 

following: 

The baseline efficiency level, which typically represents equipment with the lowest 

energy efficiency on the market. For equipment where minimum energy conservation 

standards already exist, the baseline efficiency level is typically defined by the 

existing energy conservation standard. 

The highest energy efficiency level or lowest energy consumption level that is 

technologically feasible (i.e., max-tech). 

Levels that incorporate noteworthy technologies or fill large gaps between other 

efficiency levels being considered. 

DOE uses analytical models and tools to assess the different equipment classes at each 

efficiency level analyzed. Many of these analytical models and tools are in the form of 

spreadsheets used to conduct the LCC and PBP analyses and to determine the NES and NPV of 

prospective standards. Discussion of various CSLs in the preliminary analysis helps interested 

parties review the spreadsheet models that underpin the analyses. DOE uses comments from 

interested parties to refine the models for the next stage of the rulemaking analyses. 

DOE makes the spreadsheet tools and results of the preliminary analysis available on its 

website for review.25 When it publishes the preliminary analysis, DOE also makes a preliminary 

TSD available, which contains the details of all the analyses performed to date. After publication 

of the preliminary analysis, DOE provides a public comment period and holds a public meeting 

to discuss these analyses. 

 

25 All materials associated with the rulemaking for pumps, product test procedures, and energy conservation 

standards are available on DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/commercial_industrial_pumps.html 
38

1.6.2 Notice of Proposed Rulemaking 

In developing the NOPR, DOE considers the comments received during the comment 

period on the preliminary analysis. This process can result in revisions to the analyses conducted 

during the preliminary analysis stage. DOE conducts additional economic and environmental 

impact analyses for the NOPR. These analyses generally include: 

1. LCC analysis for user subgroups (section 11); 

2. complete MIA (section 12);

3. utility impact analysis (section 15); 

4. employment impact analysis (section 16); 

5. emissions analysis (section 13); 

6. monetization of emissions (section 14); and 

7. regulatory impact analysis (section 17).

DOE describes the methodology used and makes the results of all the analyses available 

on its website for review. This analytical process results in the selection of proposed standard 

levels, if any, that DOE presents in the NOPR. DOE selects the proposed standard levels from 

the trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking.26 The NOPR 

is published in the Federal Register and describes the evaluation and selection of any proposed 

standards levels, along with a discussion of other TSLs considered but not selected and the 

reasons DOE did not select them. 

For each equipment class, DOE identifies the max-tech efficiency level. If DOE proposes 

a lower level, DOE explains the reasons for eliminating higher levels, beginning with the highest 

level considered. DOE presents the analytical results in the NOPR and provides the details of the 

analysis in an accompanying TSD. 

DOE considers many factors in selecting proposed standards. These factors are 

prescribed by EPCA and take into consideration the benefits and costs of energy conservation 

standards. 

When DOE publishes the NOPR, it provides the U.S. Department of Justice (DOJ) with 

copies of the NOPR and TSD to solicit feedback on the impact of any proposed standard levels 

on competition in the market of the products that are the subject of the rulemaking. DOJ reviews 

standard levels to assess the impacts from any lessening of competition likely to result from the 

imposition of such standards. (42 U.S.C. § 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the 

NOPR is followed by a public comment period that includes a public meeting. 

1.6.3 Final Rule

 After publication of the NOPR, DOE considers public comments received on the 

proposal and accompanying analyses. DOE reviews the engineering and economic impact 

analyses and any proposed standards, based on these comments, and considers modifications 

 

26 TSLs are assembled from the candidate standard levels (CSL) analyzed for the individual equipment classes, 

based on a set of criteria from the analysis results. 
39

where necessary. DOE also considers DOJ’s comments on the NOPR relating to the impacts of 

any proposed standard levels on competition to determine whether changes to these standard 

levels are needed. DOE publishes the DOJ comments and DOE’s response as part of the final 

rule.

In any final rule, DOE sets any final standard levels and the compliance date and also 

explains the basis for the selection of such standard levels. The final rule is accompanied by a 

final TSD. 

1.6.4 Labeling 

Title III of the Energy Policy and Conservation Act of 1975 (EPCA), as amended (42 

U.S.C. 6291 et seq.), includes provisions for labeling (42 U.S.C. 6315). If DOE prescribes test 

procedures for pumps, DOE must determine if the following criteria are met before prescribing a 

labeling rule: (1) labeling in accordance with this section is technologically and economically 

feasible with respect to such class; (2) significant energy savings will likely result from such 

labeling; and (3) labeling in accordance with this section is likely to assist consumers in making 

purchasing decisions (42 U.S.C. 6315(h)). 

Section 6315 of EPCA specifies certain aspects of equipment labeling that DOE must 

consider in any rulemaking establishing labeling requirements for covered equipment. At a 

minimum, such labels must include the energy efficiency of the equipment to which the 

rulemaking applies, as tested under the prescribed DOE test procedure. In addition, the labeling 

rulemaking may consider the addition of other specifications for equipment labels, including: 

directions for the display of the label; a requirement to display on the label additional 

information related to energy efficiency or energy consumption, which may include instructions 

for maintenance and repair of the covered equipment, as necessary to provide adequate 

information to purchasers; and requirements that printed matter displayed or distributed with the 

equipment at the point of sale also include the information required by the labeling rule to be 

displayed on the label. (42 U.S.C. 6315(b) and 42 U.S.C. 6315(c)). For more information, see 

DOE’s Request for Information on labeling for commercial and industrial equipment 77 FR 

75400 (December 20, 2012). 

DOE could analyze the appropriateness of a labeling rule in conjunction with the 

analyses for standards described in the remainder of this document. The stakeholders have 

expressed interest in DOE establishing a label to reflect pump efficiency and other critical 

application parameters. 

Item 1-51 DOE seeks comment on whether a labeling rule would be technologically or 

economically feasible, result in a significant conservation of energy, or assist customers in 

making purchasing decisions. 

Item 1-52 DOE seeks comment on information that it should consider requiring for 

display on any prospective label, as well as factors DOE should consider regarding the size, 

format, and placement of any such label. 
40

2. OVERVIEW OF ANALYSES FOR RULEMAKING 

The purpose of the analyses is to support DOE’s determination on whether to establish 

energy conservation standards for pumps. The analyses ensure that, if standards are established, 

DOE selects standards that achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified and will result in significant energy savings, 

as required by EPCA. Economic justification includes the consideration of the factors set forth in 

EPCA (see Section 1.1 of this framework document), which encompass the economic impacts on 

domestic manufacturers and consumers, national benefits including environmental impacts, 

issues of consumer utility, and impacts from any lessening of competition. 

Figure 2.1 summarizes the analytical components of the DOE standards-setting process. 

The analyses are presented in the center column. Each analysis has a set of key inputs, which are 

data and information required for the analysis. “Approaches” are the methods that DOE will use 

to obtain key inputs. The results of each analysis are key outputs, which feed directly into the 

rulemaking. Arrows indicate the flow of information between the various analyses. DOE ensures 

a consistent approach to its analyses throughout the rulemaking by considering each analysis as a 

part of the overall standard-setting framework. 
41

Figure 2.1 Flow Diagram of Analyses for the Pumps Standards Rulemaking Process 
42

3. MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment provides information about the commercial and 

industrial pump industries and the performance attributes of this equipment. DOE uses this 

assessment to determine equipment classes and identify potential design options or efficiency 

levels for each equipment class. 

3.1 Market Assessment 

DOE’s market assessment identifies and characterizes the manufacturers of pumps, 

estimates market shares and trends, and addresses regulatory and non-regulatory initiatives 

intended to improve the energy efficiency or reduce the energy consumption of the pumps 

covered by this rulemaking. 

The market assessment allows DOE to gather data that can help identify important issues 

(e.g., potential small business impacts, competitive disruptions, and other factors that may arise 

from enacting standards). For example, market structure data can be used to assess competitive 

impacts as part of the manufacturer impact analysis. 

DOE considers manufacturers, industry organizations, and other interested parties as 

potential sources of such information. In addition, DOE is considering examining national 

market reports or data collected in national energy use surveys, or extrapolating historical pump 

sales data from the U.S. Census Bureau. The Census Bureau publishes limited information on the 

quantity and dollar-value of equipment shipments. The Census Bureau data do not, however, 

disaggregate the pumps according to the equipment classes DOE is considering for this 

rulemaking. 

Item 3-1 DOE requests information that would contribute to the market assessment for 

the pumps that would be covered in this rulemaking, especially for those equipment classes 

designated in section 3.2. Examples of information sought include current equipment 

features and efficiencies, equipment feature and efficiency trends, and historical equipment 

shipments and prices. 

According to HI’s comments on the RFI, there are approximately 450 pump 

manufacturers that serve the U.S. market, with nine having sales of at least one billion dollars, 

and 72 having sales of more than 100 million dollars. (HI, No. 6 at p. 4) HI represents 97 pump 

manufacturers and suppliers. (HI, No. 6 at p. 1) 

In the United States, ten companies represent 60-70% of the total U.S. pumps market: 

Grundfos, Sulzer, Weir Group, KSB, Xylem, Flowserve, Ebara, Pentair, Roper Industries, and 

ITT Goulds [16]. With the exception of Roper Industries, all of these manufacturers make pumps 

that fall into the scope discussed in section 1.3. There has been significant consolidation in the 

global pump market in the past 25 years, and these ten companies comprise approximately 70 

brands or divisions, shown in Table 3.1, nearly all of which used to be independent companies. 

In some cases the manufacturing for these brands has been consolidated, but in most cases the 
43

legacy brand names continue to be used. Table 3.2 shows major suppliers for various pump 

equipment categories, some but not all of which are brands of the top 10 companies. 

Table 3.1 Top 10 U.S. Pump Suppliers with Major Brands/Operating Units 

Parent 

Company Major Brands/Operating Units

Grundfos Chicago, Grundfos, Morris, Paco, Peerless, Yeomans

Sulzer ABS, Johnston, Sulzer

Weir Group Begeman, Envirotech, Floway, Geho, Hazleton, Lewis, Multiflo, Warman, 

Weir

KSB GIW, KSB

Xylem A.C., Bell & Gossett, Flygt, Goulds Water Technology, Godwin, Jabsco, 

Laing, Lowara, Marlow, Red Jacket

Flowserve ACEC, Aldrich, Byron Jackson, Cameron, Durco, Flowserve, IDP, Lawrence, 

Pacific, Pleuger, Scienco, Sier Bath, TKL, United, Western Land Roller, 

Wilson Snyder, Worthington

Ebara Ebara

Pentair Aermotor, Aurora, Berkeley, Edwards, Fairbanks Morse, Flotec, Hydromatic, 

Hypro, Jung Pumpen, Layne/Vertiline, Myers, Nocchi, Shurflo, Simer, StaRite

Roper 

Industries

Abel, Cornell, Neptune, Roper

ITT Goulds AC, Goulds

Note: Brands/Operating units in italics do not have manufacturing locations in the U.S.
44

Table 3.2 Major Suppliers for Proposed Covered Pump Equipment Categories 

Parent company Brand/Operating Unit ESCC ESFM DS AS/RS VT-S VT A-M

Top 10 Parent Companies

Ebara Ebara X

Flowserve Byron Jackson X X

Flowserve Flowserve X X X X

Flowserve IDP X X X X

Grundfos Grundfos X X X X

Grundfos Paco X X X

Grundfos Peerless X X X X X

ITT Goulds AC X

ITT Goulds Goulds X X X X X X X

KSB KSB X X X

Pentair Aurora X X X

Pentair Fairbanks Morse X X

Pentair Layne/Vertiline X X

Sulzer Johnston X X X

Sulzer Sulzer X X

Weir Group Floway X X X

Xylem Bell & Gossett X X X X

Xylem Goulds Water Technology X

Non-Top 10 Parent Companies

American Turbine Pump American Turbine Pump X

Crane Pumps & Systems Burks X

Crane Pumps & Systems Weinman X

Cascade Pump Company Cascade Pump Company X

Gusher Pump Gusher Pump X

National Pump Company National Pump Company X X

GE Water Technology Osmonics X

Price Pump Company Price Pump Company X

Ardox Scot Pump X

Simflo Pumps Simflo Pumps X

Taco Taco X
45

3.1.2 Shipments and Value 

The U.S. Census Bureau has collected data on pumps (except hydraulic) and compressors 

under MA333P [4]. Table 3.3 shows 2010 data for product codes that include pump types for 

which DOE is currently considering energy conservation standards in this rulemaking. Some of 

these pumps, however, may not be for clean water applications. Table 3.4 shows 2010 data27 for 

product codes that include pump types that fall outside the current scope of this rulemaking. The 

Census Bureau also provides information on export shipments and import shipments, but these 

data are not disaggregated to the same extent as the manufacturer shipment data. Table 3.5 shows 

DOE estimates of the imports and exports disaggregated to the equipment classes. Table 3.6

shows DOE estimates of the percent of pumps by category used in clean water applications. 

Table 3.7 shows DOE estimates of the percent of pumps by category sold with motors by the 

pump manufacturer. 

Item 3-2 DOE requests input on its identification of product codes in the U.S. Census 

data that match the equipment classes proposed for coverage in this rulemaking. 

Item 3-3 DOE requests feedback on its estimates of the disaggregation of pump exports 

and imports to product codes, its estimates of the percentage of shipments of clean water 

pumps, and its estimates of the percent of shipments sold with motors by the pump 

manufacturer. 

 

27 These data are not expected to be available for 2011 or future years because the Current Industrial Report program 

has been terminated. DOE seeks information on additional sources of this or similar data. 
46

Table 3.3 U.S. Pump Manufacturer Shipments of Covered Pumps 

Census 

Product Code Pump Type

2010 

Quantity 

(000s)

2010 Value 

(Million $) Equipment Category Notes

3339111448 Centrifugal single and two stage, single and 

end suction, close coupled with driver 1,301 191 End Suction Close Coupled Two stage would not be covered under the current scope

3339111452

Centrifugal single-stage, single suction, frame 

or foot mounted, non-ANSI, non-ISO, with or 

without recessed impeller, all size discharge

 235 133 End Suction Frame Mounted

Pumps with recessed impellers would 

not be covered under the current scope 

(solids-handling)

3339111450 Centrifugal single and two stage, single 

suction, in-line, close coupled with driver 95* 14* In-Line Two stage would not be covered under the current scope

333911144E Centrifugal single-stage, single suction, 

vertical, in-line frame 29 29 In-Line

333911144H

Centrifugal, single-stage, single suction, frame 

or foot mounted, metallic pumps, built to 

ANSI B73.1 or ISO2858

41 166 End Suction Frame Mounted

Primarily for chemicals, but some may 

be for clean water and would be 

covered under the current scope

333911145L Centrifugal single-stage, axially split, double 

suction, all size discharge 13 213 Double Suction

333911146F

Centrifugal multi-stage, single or double 

suction, volute or diffuser design, axially split 

case

 1 97* Multi-Stage Axial Split 

3339111468 Centrifugal multi-stage, single or double 

suction, diffuser design, radially split case 14 155* Multi-Stage Radial Split

3339111496

Vertical turbine pumps, including pumps with 

submersible motor, bowl assemblies, and can 

and pot type

 29 175 Vertical Turbine and 

Submersible

3339111486 Centrifugal propeller and mixed flow, 

horizontal and vertical, all sizes 1 135 Axial/Propeller and Mixed

*Estimated values 
47

Table 3.4 U.S. Pump Manufacturer Shipments of Non-Covered Pumps 

Census 

Product 

Code Pump Type

2010 Quantity 

(000s)

2010 Value 

(Million $)

Reason Product Code Does Not Seem 

to Fall in Current Scope of Coverage

3339111413 Centrifugal sewage type (nonsubmersible), vertical or horizontal 

with non-clog impeller, all sizes 20 243 Not clean water (solids-handling)

3339111432 Centrifugal submersible solids handling pumps, solids 1" to 2" 

inclusive, all hp 479 101 Not clean water (solids-handling)

3339111434 Centrifugal submersible non-clog pumps, greater than 2" solids 

handling capacity, all size discharge 14 58 Not clean water (solids-handling)

3339111436 Centrifugal submersible grinder pumps, all hp 94 103 Not clean water (grinder)

333911144L

Centrifugal single-stage, single suction, frame or foot mounted, 

nonmetallic pumps, built to National or International Standards 

ANSI B73.1 or ISO 2858 

1 10 Not clean water (chemical process)

3339111455 Centrifugal single-stage, single suction, replaceable elastomer lined 

or hard metal, frame or foot mounted 2* 20* Not clean water (slurry)

3339111458 Centrifugal single-stage, single suction, centerline mounted 74 62 Not clean water (oil)

3339111426 Centrifugal submersible effluent pumps, less than 1” solids 

handling capacity, all hp 287 47 Not clean water (solids-handling)

3339111488 All other centrifugal pumps (including single stage radially split 

double suction; and sealless) 1,308 467 Not clean water (refinery use, sealless)

33391114C7

Reciprocating pumps, driven by electric motor, engine, or steam 

turbine, including reciprocating piston, plunger, power-pumps for 

water flooding, or diaphragm (not air operated) pumps 

604 311 Positive Displacement

33391114D5 Diaphragm pumps, air operated 300 234 Positive Displacement

33391114R9 Rotary pumps, 100 PSI and under, designed pressure, all GPM, 

designed capacity 470 148 Positive Displacement

33391114RG Rotary pumps, 101 to 249 PSI, designed pressure, all GPM, 

designed capacity 193 119 Positive Displacement

33391114RN Rotary pumps, 250 PSI and over, designed pressure 166 117 Positive Displacement

33391114T5 Other industrial pumps 208* 122* Positive Displacement

3339111101 Domestic water systems, nonsubmersible pump systems (jet and 

nonjet, including drivers) 955 149 Residential

3339111108 Domestic water systems, submersible pump systems including 

drivers, all hp 509 111 Residential
48

Census 

Product 

Code Pump Type

2010 Quantity 

(000s)

2010 Value 

(Million $)

Reason Product Code Does Not Seem 

to Fall in Current Scope of Coverage

3339111107 Domestic water systems, domestic hand and windmill pumps, 

pump jacks, and cylinders, sold separately, including drivers 20 2 Residential

3339111235 Domestic sump pumps, 1 hp and under, pedestal, including drivers 265 13 Residential

3339111242 Domestic sump pumps, submersible, including drivers, all hp 3,101 222 Residential

3339111341 Oil-well and oil-field pumps, subsurface pumps for oil-well 

pumping 42 223 Not clean water (oil)

3339111364 Oil-well and oil-field pumps, other oil-well and oil-field pumps, 

including mud pumps (slush pumps) 20 187 Not clean water (oil, slush)

3339111590 Other pumps, including drivers 2,651 381 Unknown types

*Estimated values
49

Table 3.5 U.S. Market Size Estimate for Pumps Proposed for the Standard 

Product Code Product

Description

Shipped

Qty.

(000 

Units)

Import

Units

(000)

Export

Units

(000)

Market Size in

1000 Units

(Shipped + Imp.

- Exp.)

Shipped

Value

(Mill $)

Import

Value

(Mill $)

Export

Value

(Mill $)

Market Size 

Mill $ 

(Shipped + 

Imp. - Exp.)

3339111448 Centrifugal single and two stage, 

single and end suction, close coupled 

with driver

1,301 4,323 73 5,551 191 169 58 302

3339111452 Centrifugal single stage, single 

suction, frame or foot mounted, nonANSI, non-ISO, with or without 

recessed impeller, all size discharge

235 0 13 222 133 0 41 92

3339111450 Centrifugal single and two stage, 

single suction, in-line, close coupled 

with driver

95 315 5 405 14 12 4 22

333911144E Centrifugal single stage, single 

suction, vertical, in-line frame

29 0 2 27 29 0 9 20

333911144H Centrifugal single stage, single 

suction, frame or foot mounted, 

metallic pumps, built to National or 

International Standards ANSI B73.1 

or ISO2858

41 0 2 39 166 0 51 115

333911145L Centrifugal single stage, axially spit, 

double suction, all size discharge

13 0 1 12 213 0 65 148

333911146F Centrifugal multi-stage, single or 

double suction, diffuser design, 

volute or diffuser design, axially split 

case

1

(2) 0 0 1 97 0 30 67

3339111468 Centrifugal multi-stage, single or 

double suction, diffuser design, 

radially split case

14 0 1 13 155 0 47 108

3339111486 Centrifugal propeller and mixed 

flow, horizontal and vertical, all 

sizes.

1 0 0 1 135 0 42 93

3339111496 Vertical turbine pumps, including 

pumps with submersible motor, bowl 

assemblies, and can and pot type

29 10 10 29 175 15 77 113

TOTAL 1,759 4,648 107 6,300 1,308 196 424 1,080
50

Table 3.6 U.S. Market Size Estimate for Pumps Proposed for the Standard – Clean Water 

Product Code Product

Description

Market Size in

1000 Units 

(Shipped + 

Imp.

- Exp.)

Estimated

% Which

Handles 

Clean Water

Size of 

Market for 

Clean Water 

Pumps

(000 Units)

Market Size 

Mill $

(Shipped

+ Imp. -

Exp.)

Estimated

% Which

Handles 

Clean 

Water

Size of 

Market for 

Clean Water 

Pumps

(Mill. $)

3339111448 Centrifugal single and two stage, single 

and end suction, close coupled with 

driver

5,551 90% 4,996 302 85% 257

3339111452 Centrifugal single stage, single suction, 

frame or foot mounted, non-ANSI, nonISO, with or without recessed impeller, 

all size discharge

222 80% 178 92 75% 69

3339111450 Centrifugal single and two stage, single 

suction, in-line, close coupled with 

driver

405 90% 365 22 85% 19

333911144E Centrifugal single stage, single suction, 

vertical, in-line frame

27 50% 14 20 40% 8

333911144H Centrifugal single stage, single suction, 

frame or foot mounted, metallic pumps, 

built to National or International 

Standards ANSI B73.1 or ISO2858

39 20% 8 115 10% 12

333911145L Centrifugal single stage, axially spit, 

double suction, all size discharge

12 90% 11 148 70% 104

333911146F Centrifugal multi-stage, single or double 

suction, diffuser design, volute or 

diffuser design, axially split case

1 40% 0.4 67 30% 20

3339111468 Centrifugal multi-stage, single or double 

suction, diffuser design, radially split 

case

13 80% 10 108 70% 76

3339111486 Centrifugal propeller and mixed flow, 

horizontal and vertical, all sizes.

1 90% 1 93 75% 70

3339111496A Vertical turbine pumps, bowl 

assemblies, and can and pot type. 

Excludes those with submersible motor

22 90% 21 96 70% 67

3339111496B Vertical turbine pumps with submersible 

motors, bowl assemblies

7 99% 6 17 99% 17

TOTAL 6,300 89% 5,610.4 1,080 67% 719
51

Table 3.7 Estimate of U.S. Clean Water Pumps Sold with Motors (by Manufacturer) 

Product Code Product

Description

Size of Market 

-Clean 

Water Pumps 

(000 Units)

Size of Market 

- Clean Water 

Pumps

(Mill. $)

Percent

Where Pump 

Mfr.

Supplies Motor

Number of 

Pumps Sold 

with Motors

(000 Units)

Dollar Amount 

of Pumps Sold 

with Motors 

(Mill $)

3339111448 Centrifugal single and two stage, single 

and end suction, close coupled with driver

4,996 257 75% 3,747 193

3339111452 Centrifugal single stage, single suction, 

frame or foot mounted, non-ANSI, nonISO, with or without recessed impeller, all 

size discharge

178 69 15% 27 10

3339111450 Centrifugal single and two stage, single 

suction, in-line, close coupled with driver

365 19 80% 292 15

333911144E Centrifugal single stage, single suction, 

vertical, in-line frame

14 8 15% 2 1

333911144H Centrifugal single stage, single suction, 

frame or foot mounted, metallic pumps, 

built to National or International Standards 

ANSI B73.1 or ISO2858

8 12 15% 1 2

333911145L Centrifugal single stage, axially spit, 

double suction, all size discharge

11 104 10% 1 10

333911146F Centrifugal multi-stage, single or double 

suction, diffuser design, volute or diffuser 

design, axially split case

0.4 20 10% 0 2

3339111468 Centrifugal multi-stage, single or double 

suction, diffuser design, radially split case

10 76 15% 2 11

3339111486 Centrifugal propeller and mixed flow, 

horizontal and vertical, all sizes.

1 70 10% 0 7

3339111496A Vertical turbine pumps, bowl assemblies, 

and can and pot type. Excludes those with 

submersible motor

21 67 10% 2 7

3339111496B Vertical turbine pumps with submersible 

motors, bowl assemblies

6 17 85% 5 14

TOTAL 5610.4 719 4,079 272
52

3.2 Equipment Classes 

 DOE may divide covered equipment into equipment classes by: (a) the type of energy 

used; (b) the capacity of the equipment; and/or (c) any other performance-related feature that 

justifies different standard levels. In determining whether any such feature justifies a different 

standard level, DOE considers the utility of the feature to the consumer and other factors DOE 

considers appropriate. (42 U.S.C. 6295(q)) DOE uses the market assessment to determine the 

appropriate equipment classes and their respective operating ranges. DOE will conduct its 

analysis to establish separate standard levels for each equipment class. 

 In this framework document, DOE is not differentiating equipment classes for pumps 

based on the type of energy used, because the majority of pumps are driven by electric motors. 

In addition, for those pumps driven by engines, DOE is considering a metric based only on pump 

efficiency. 

 Because DOE tentatively plans to set standards as a function of flow and specific speed, 

DOE is not defining equipment classes in this framework document based on capacity (i.e., flow 

or other related parameters such as horsepower). 

 DOE is considering differentiating equipment classes based on the following 

performance-related or utility features: 

pump category (mechanical configuration), 

pump design speed, and 

motor (and control) package. 

Item 3-4 DOE welcomes comments on which performance-related features or design 

characteristics DOE should consider to define pump equipment classes. 

3.2.2 Pump Category (Mechanical Configuration) 

DOE is considering establishing equipment classes for the specific pump categories set 

forth in Table 3.8. 
53

Table 3.8 Rotodynamic Clean Water Pump Categories Proposed for Coverage 

Pump Type Sub-Type Stages DOE Terminology

End Suction

Close Coupled Single End Suction Close Coupled (ESCC)

Own Bearings/ 

Frame Mounted Single End Suction Frame Mounted (ESFM)

In-Line Single In-Line (IL)

Axial Split Single Double Suction (DS)

Multi Axially Split Multi-Stage (AS)

Radial Split Multi Radially Split Multi-Stage (RS)

Vertical 

Turbine

Non-Submersible Any Vertical Turbine (VT)

Submersible Any Submersible (VT-S)

Axial/Propeller and Mixed Flow Any Axial/Propeller and Mixed (A-M)

DOE is considering these equipment classes for the different categories of pumps 

designed for different applications. DOE notes that, in some areas of head and flow requirements, 

multiple categories of pumps can be used, and some are inherently more efficient than others. For 

example, at low specific speeds, adding stages may be a design option that improves efficiency. DOE 

recognizes, however, that there may be issues related to utility if a pump standard effectively 

eliminated a given pump category. For example, in retrofit situations, it may be cost-prohibitive to redesign piping to accommodate a new category of pump. 

Item 3-5 DOE requests information regarding the utility of different pump categories 

proposed for coverage that would warrant separate equipment classes. For example, could 

end suction pumps be a single equipment class, or are the breakdowns shown necessary to 

preserve equipment utility that would affect performance? Could axially and radially split 

multi-stage pumps be a single equipment class? Could all vertical turbine pumps (both 

submersible and non-submersible) be a single equipment class? 

DOE also realizes that it may need to further disaggregate the equipment categories 

considered for coverage to accommodate the utility of certain pumps. If DOE defines pumps inclusive 

of the motor or motor and controls, for example, it would also be advantageous to disaggregate 

equipment classes for pumps that would always be used in variable load applications. 

Item 3-6 DOE requests information on whether any of the equipment proposed for 

coverage provides utility that requires further breakdown from the categories shown in Table 

3.8. For example, do multi-stage pumps with a double suction first stage require a separate 

equipment class? Do vertical turbine can pumps require a separate equipment class from 

vertical turbine lineshaft pumps? 

Item 3-7 DOE requests comment on whether equipment classes can be developed for 

pump categories that would always be used in variable load applications. 
54

3.2.3 Pump Design Speed 

Pump speed selection affects noise, maintenance cost, net positive suction head required 

(NPSHr), and controllability requirements, as well as attainable efficiency, which is why DOE 

may consider using it as a feature to differentiate equipment classes. The EU regulation contains 

separate efficiency standards for pumps operating at 1,450 rpm and pumps operating at 2,900 

rpm (i.e., 4-pole and 2-pole motors, equating to 1,750 rpm and 3,500 rpm in the United States) 

[1]. As a result of DOE’s review of this approach, this section discusses: (1) the size effect 

captured by the EU standards that differ by design speed, (2) the implications for single pumps 

running at multiple speeds, and (3) DOE’s options in addressing the design speed issue. To help 

clarify this discussion, Figure 3.1 demonstrates the difference between (1) and (2): Pumps A and 

B demonstrate the size effect (1), whereas Pump A and A2 demonstrate a single pump running at 

multiple speeds (2).28

 

28 Note that none of the pumps shown represents a selection option by an end user; end users choosing between 

pumps with different speeds would be choosing between pumps that produce the same flow and head but with 

different specific speeds. This scenario is not addressed in this section, which is focused on pump manufacturing 

rather than pump selection. 
55

Figure 3.1 Example of Pumps Showing the Size Effect (2 Different Pumps: A and B) 

and the Speed Effect (Same Pump at Multiple Speeds: A and A2) 

3.2.3.1 Size Effect 

Using ESCC pumps as an example, the EU minimum efficiency surface for pumps with 

4-pole motors is two to three points higher than the efficiency surface for pumps with 2-pole 

motors, depending on the standard level.29 In other words, for a given flow and specific speed, 

pumps operating with 4-pole motors have better pump efficiency (and therefore higher EU 

efficiency standards) than pumps operating with 2-pole motors. It is important to note that this 

difference is not specifically related to speed, but rather to pump size. Comparing pumps with 

the same specific speed and flow, but at two different speeds, means comparing two 

geometrically similar pumps—a smaller pump running at higher speed and a larger pump 

running at lower speed (such as Pumps A and B in Figure 3.1). The EU’s standard indicates that 

the latter is more efficient. 

DOE notes that other pump resources show efficiency as a function of flow and specific 

speed without regard to speed or physical size [11,18, 19]. See Figure 3.2 for an example. These 

resources may be relying on Anderson, who concluded after the analysis of true Reynolds 

number and direct flow quantity that the latter is a sufficiently accurate arbiter for the efficiency 

 

29 Compare the values for C for 1,450 rpm and 2,900 rpm pumps in Table 1.5, for example. Note that, the higher the 

C value, the lower the minimum efficiency (because C is subtracted in the equation). 
56

of a group of pumps [19]. Anderson goes on to state that “the efficiency of a small pump at high 

speed can be the same as a large pump at low speed, providing the shape number [specific speed] 

and flow are kept the same. That is the reason why [figures] can, in general, show efficiency 

against quantity [flow] and shape number [specific speed] without reference to physical size or 

operating speed.” However, a Europump Guide notes that, when using flow instead of Reynolds 

number along with specific speed to predict efficiency, the efficiency at speeds other than 2,900 

rpm may be different than that predicted [20]. Because predicted efficiency varies with design 

speed, this indicates that flow is not actually a sufficient determiner of pump efficiency. 

Figure 3.2 Example Graph Showing Pump Efficiency as a Function of Specific Speed 

and Flow 

Item 3-8 DOE requests comment on whether it should consider using Reynolds number 

instead of flow in setting minimum efficiency standards for pumps and whether this choice 

would prevent adding design speed as an additional parameter. DOE notes that there are 

multiple methods of calculating Reynolds number for pumps and that all calculations do not 

produce the same relative results. As a result, DOE seeks comment on the most appropriate 

form of Reynolds number for pumps. 

The EU’s methodology relies on raising or lowering the efficiency surface based on 

pump speed by changing the constant in the equation. (See Equation Set 1.) DOE’s preliminary 

analysis following the EU methodology produces a similar result to the EU, with 4-pole ESCC 
57

pumps being on average 2.2 points more efficient than 2-pole ESCC pumps for a given flow and 

specific speed.30 However, DOE notes that when fitting the surfaces by allowing other 

parameters besides the constant to change (i.e., changing the shape instead of just the vertical 

position as in Equation Set 2), in some areas of flow and specific speed, 2-pole is more efficient 

than 4-pole; in other words, the data show that the relationship is not necessarily fixed. See 

Appendix D for figures demonstrating these results and the related coefficients. 

Equation Set 1: Vertical Change in Surface 

Equation Set 2: Surface Shape Change 

3.2.3.2 Impact of Setting Standards by Speed on Single Pumps Running at Multiple 

Speeds 

The impact of pump size on efficiency has implications for any efficiency standards for 

single pumps offered at two or more speeds (such as Pump A and A2 in Figure 3.1). DOE 

understands that many manufacturers offer a given pump model at two or more design speeds, 

but that wet end of the pump is identical for both offerings. 

Pump affinity laws indicate that a pump should have the same efficiency at any speed, 

and many pump manufacturers publish the same efficiency at multiple speeds. HI 14.6 notes, 

however, that efficiency changes are not negligible for speed changes of more than 20% [15]. 

The pump resources that show efficiency as a function of flow and specific speed, as indicated 

earlier, predict a higher efficiency for higher flow pumps at the same specific speed. Using 

ESCC as an example, the EU’s standards show that higher flow (higher speed, or 2 pole pumps) 

are more efficient than lower flow pumps only for pumps less than around 800 gpm (2-pole)/400 

gpm (4-pole). (See Figure 3.3.) For pumps at higher flow ranges, the EU standards require a 

higher efficiency for 4-pole pumps (i.e., the same pump running at lower speed). 

In the United States, for ESCC pumps, following the same method of fitting surfaces as is 

used in the EU (Equation Set 1) results in higher efficiency for 2-pole as compared to 4-pole 

pumps, except for at low specific speeds and high flow. (See Figure 3.3. This figure is produced 

by calculating and using in each equation the same specific speed, but half 

the flow, for the 4-pole pump as compared to the 2-pole pump.) Following the second fitting 

method discussed previously (Equation Set 2), the same trends apply, but the predicted 

differences are higher. (See Figure 3.4.) Finally, if DOE produced one surface without regard to 

design speed (i.e., ignoring the size effect), the efficiency for a pump running at 3,550 rpm (2-

pole) would always be higher than for that same pump running at 1,750 rpm (4-pole), and the 

 

30 See Appendix D for a discussion of how this changes with the pump scope, i.e. the pumps counted as clean water. 
58

differences would be higher than in the other possible scenarios. Table 3.9 summarizes the 

efficiency differences between pumps running with 2-pole and 4-pole motors for each of the 

scenarios discussed. 

Analysis of DOE’s pump performance data indicates that out of approximately 500 pairs 

in the ESCC database31, 57% showed 2-pole as more efficient, 29% showed 2-pole and 4-pole 

equal32, and 14% showed 4-pole more efficient than 2-pole. There do not appear to be strong 

trends regarding which speed is more efficient related to flow or specific speed. These data 

indicate much larger differences in efficiency between identical pumps running at different 

speeds than do the EU’s standards. DOE notes that it is unknown if the published data in its 

database are based on testing or rather assumptions of theoretical relationships such as the 

affinity laws. In addition, DOE notes that a similar analysis performed on non-submersible 

vertical turbine pumps shows a different trend, with 77% of pairs showing 2-pole and 4-pole 

equal, 10% showing 2-pole more efficient, and 13% showing 4-pole more efficient (out of about 

2,000 pairs); therefore, any trends identified may not hold true for all equipment classes and may 

simply be a function of which speeds pumps are generally optimized for in each equipment class 

and how much of the data is created using affinity law assumptions. 

 

31 Pumps with the same manufacturer, catalog, type, model, and impeller diameter, but with different speeds, were 

assumed to be pairs. These pumps did not have identical specific speeds (which theoretically should be true for 

identical pumps), presumably because the affinity laws are not completely accurate, which would produce different 

calculations based on head and flow. 

32 It is unknown if, for these pumps, the manufacturers simply assumed the affinity laws, or if these are actual test 

results. 
59

Figure 3.3 Predicted Efficiency Differences Between Single ESCC Pumps Running with 

2-Pole versus 4-Pole Motors at Selected Specific Speeds (Using Equation Set 1) 

Figure 3.4 Predicted Efficiency Differences Between Single ESCC Pumps Running with 

2-Pole versus 4-Pole Motors at Selected Specific Speeds (Using Equation Set 2) 

-2.00

-1.00

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

Efficiency Difference (Percentage Points)

50 150 250 350 450 550 650 750 850 950

2-Pole - 4-Pole

Flow (gpm) - 2 pole

diff (Ns = 1000)

diff EU (Ns = 1000)

diff (Ns = 2000)

diff EU (Ns = 2000)

diff (Ns = 3000)

diff EU (Ns = 3000)

-10.00

-8.00

-6.00

-4.00

-2.00

0.00

2.00

4.00

6.00

100200300400500600700800900

10001100120013001400150016001700180019002000

Efficiency Difference (Percentage Points)

2-Pole - 4-Pole

Flow (gpm) - 2 Pole

diff (Ns = 1000)

diff (Ns = 2000)

diff (Ns = 3000)
60

Table 3.9 Comparison of Minimum Efficiencies for Identical Pumps Running at Two 

Different Speeds 

Pump

Ns 

(US)

Flow 

(gpm) 

at 

3,550 

rpm

Flow 

(gpm) 

at 

1,750 

rpm

Efficiency Differences (2-pole – 4-pole)

Percentage Points

EU 

(equation 

set 1)

DOE 

(equation 

set 1)

DOE 

(equation 

set 2)

DOE 

(single 

equation*)

A 1000 200 100 2.0% 2.9% 2.9% 5.0%

B 1000 1200 600 -0.1% -0.7% -5.3% 1.8%

C 2000 400 200 1.0% 3.4% 4.0% 5.6%

D 2000 1200 600 -0.4% 1.3% 2.1% 3.6%

E 3000 400 200 0.9% 4.6% 4.8% 6.7%

F 3000 2000 1000 -1.0% 1.4% 4.6% 3.8%

*In the single equation approach, DOE would not take design speed into account in developing 

efficiency surfaces, so a single equation would be used no matter the speed. 

Item 3-9 DOE requests comment on which method of surface fitting produces the most 

appropriate results for both cases: (1) a smaller pump at higher speed compared to a larger 

pump at lower speed; and (2) identical pumps running at two different speeds. DOE requests 

comment on whether these relationships are expected to differ by equipment class. 

3.2.3.3 DOE Options for Addressing Design Speed 

If DOE does not use design speed as a feature differentiating equipment classes, it is 

unlikely that any pump speeds would be eliminated from the market, because only pump models 

with efficiencies close to the standard level would be impacted. In addition, pumps can run at 

multiple speeds, so a given model that might be eliminated at one speed may be able to meet the 

standard at a different speed. However, DOE is concerned about the implications for identical 

pumps offered at multiple speeds, as shown in Table 3.9. Specifically, DOE wants to make sure 

that it selects a method of surface fitting that produces appropriate results at all speeds. 

Regardless of whether DOE sets equipment classes based on design speed, DOE must 

determine at what speed testing and compliance should occur. DOE may consider requiring 

testing and compliance with the standard based on a certain pump speed. Not all pumps are 

designed to operate at all speeds, particularly high speeds, however, and within a given 

equipment class, there will be a variation of pump speeds offered. Therefore it may be difficult 

for DOE to select a single speed for testing in each equipment class. In addition, some 

manufacturer test loops might be set up for a certain speed, so requiring testing at a different 

speed could increase manufacturer burden by requiring a change in test loop. Alternatively, 

DOE could potentially require pumps that operate at multiple speeds to meet the most stringent 

standard (in other words, test the same pump model at specified speeds, calculate the minimum 

efficiency for the pump at specified speeds, and require compliance with the greatest efficiency, 

if there is a difference). DOE notes that because not all pumps are designed to operate at all 

speeds, DOE may use manufacturer input to determine the range of speeds at which a particular 

pump model can be safely tested. 
61

DOE understands that some pumps are optimized for a certain design speed (which may 

not be the speed at which efficiency is the highest or the speed at which DOE requires testing, 

and that therefore either of these approaches may penalize some pump models. 

Item 3-10 DOE requests comment on the use of pump design speed as a feature that 

distinguishes equipment classes. In particular, DOE seeks comment on whether pumps 

designed for different rotating speeds perform differently enough to warrant separate 

equipment classes. DOE also requests comment on any physical differences between pump 

models offered at different speeds and the nature of those differences, including whether 

DOE could determine by physical inspection at what speeds a pump can safely operate. 

Item 3-11 DOE requests comment on the testing and compliance burden on 

manufacturers under the approaches set forth above. 

Item 3-12 DOE requests comment on whether it could require all pumps in a given 

equipment class to be tested at (a) certain speed(s) and, if so, which speed(s) is (are) most 

appropriate. 

Item 3-13 DOE requests comment on how manufacturers in the EU are determining the 

minimum efficiency required for a pump offered at multiple speeds. 

3.2.4 Motor (and Control) Package 

As mentioned in section 1.2.3, DOE may define pumps inclusive of the motor or motor 

and controls. Under these scenarios, DOE would establish separate sets of equipment classes for 

pumps sold without motors and pumps sold with motors (or pumps sold without VSDs and 

pumps sold with VSDs). DOE believes that these motor (and control) packages represent a utility 

feature in which the pump manufacturer matches equipment to best meet customer needs. 

3.2.5 Tentative Equipment Classes 

Table 3.10 shows DOE’s preliminary designations for pump equipment classes. These 

equipment classes are subject to change based on changes to the pumps for which DOE 

considers standards in this rulemaking, equipment definitions, additional information on the 

market, and information and data provided by stakeholders. For example, if DOE considers 

standards for pumps designed for lower nominal speeds, such as 1,200 rpm, and DOE establishes 

equipment classes based on pump design speed, equipment classes would also need to include 

pumps designed for 6-pole, 8-pole, and possibly higher motor configurations. If DOE develops a 

separate set of equipment classes for pumps sold with and without VSDs or with and without 

motors, the equipment classes would likely be identical to those shown in Table 3.10. 
62

Table 3.10 Tentative Equipment Classes for Rotodynamic Clean Water Pumps 

Pump Type Sub-Type Stages DOE Terminology

Design 

Speed

End Suction

Close Coupled Single End Suction Close Coupled (ESCC) 3,500

1,750

Own Bearings/ 

Frame Mounted Single End Suction Frame Mounted (ESFM)

3,500

1,750

In-Line Single In-Line (IL) 3,500

1,750

Axial Split

Single Double Suction (DS) 3,500

1,750

Multi Axially Split Multi-Stage (AS) 3,500

1,750

Radial Split Multi Radially Split Multi-Stage (RS) 3,500

1,750

Vertical 

Turbine

Non-Submersible Any Vertical Turbine (VT) 3,500

1,750

Submersible Any Submersible (VT-S) 3,500

1,750

Axial/Propeller and Mixed Flow Any Axial/Propeller and Mixed (A-M) 3,500

1,750

3.3 Technology Assessment 

The technology assessment focuses on understanding how energy is used by commercial 

and industrial pumps and what potential technology changes to the design and construction of 

these pumps would improve their energy efficiency. Measures that improve the energy efficiency 

of the equipment are called “technology options.” These measures are based on existing 

technologies, as well as working prototypes. In consultation with interested parties, DOE will 

develop a list of technology options to consider in this rulemaking. Initially, this list will include 

all those options that may improve energy efficiency, including a max-tech design. Then DOE 

will consider each of these technology options against four screening criteria, as discussed in 

section 4. Technology options that pass all the screening criteria are called “design options” and 

are analyzed in the engineering analysis (section 5). 

To develop the list of technology options that could improve the efficiency of the pumps 

for which DOE is considering energy conservation standards in this rulemaking, DOE is 

reviewing manufacturer catalogs, recent trade publications, and technical journals. DOE also 

intends to consult with interested parties to gather information on pump designs and applications. 

Pump efficiency can be increased by improving the technology used in the design and 

manufacturing process. Based on its preliminary review, DOE identified the following 

technology options as having potential to improve the efficiency of pumps: 

1. improving the hydraulic design, 
63

2. smoothing surface finish, 

3. reducing running clearances, 

4. reducing mechanical friction in seals, 

5. reducing other volumetric losses, 

6. using a variable speed drive, 

7. improving VSD efficiency, and 

8. reducing VSD standby and off mode power usage. 

Each technology option affects one or more sources of efficiency losses in pumps 

(leakage losses, disk friction, and hydraulic losses). Some of these losses are dependent on 

specific speed; therefore, the effect on efficiency of these design options will be dependent on 

specific speed. 

Note that technology options 6, 7, and 8 would not be considered in regulatory option 1; 

they would only be considered if DOE defines pumps inclusive of the motor or motor and 

controls. 

3.3.1 Improving Hydraulic Design 

This option involves modification of the impeller and volute or diffuser designs to 

improve the efficiency of the pump at the BEP by controlling the diffusion process and reducing 

recirculation in the pump and by widening the efficiency curve, so that efficiency does not drop 

off as quickly as the pump moves away from its BEP. This option has the potential to improve 

efficiency of pumps being sold today by as much as 10-12%, depending on the size and specific 

speed of the pump and on how poor the pump performance was before design modifications. 

DOE recognizes that some designs, while less efficient, may be necessary for certain 

applications. For example, enclosed impellers (with side walls) are normally expected to be more 

efficient than open impellers (without side walls). However, open impellers may be necessary, 

even in clean water applications. For example, many vertical turbines employ open impellers, 

because of the possibility that sand may enter the pump through the well. DOE will take into 

account these issues, including the possibility of market shift as a result of efficiency levels that 

may require certain impeller types, when developing technology options. DOE requests any 

information that would help characterize these issues. 

3.3.2 Smoothing Surface Finish 

Impellers can be polished by spinning them in a slurry, and volutes and diffusers can be 

polished by similar methods, or may be coated with enamel or other coatings to improve surface 

finish. Research shows that smoothing the entire pump can create theoretical efficiency gains on 

the order of 18 percent, but this can be prohibitively expensive [21]. Smoothing certain sections 

of the pump has the potential to increase pump efficiency by an estimated 1-3% overall. 

3.3.3 Reducing Running Clearances 

There are a number of running clearances that might be tightened, which would reduce 

the amount of volumetric losses that occurs as pressurized liquid leaks across the running 
64

clearance to a zone of lower pressure. The running clearances to be considered for tightening 

include: 

front wear rings, 

back wear rings (thrust balance rings), 

center bushing or wear ring on multi-stage axial split pumps with crossover, and 

balance drums or sleeves. 

To further tighten these clearances beyond what manufacturers have already done might 

require alternate materials for wear rings and other running surfaces, tighter machining 

tolerances, modifications to assembly procedures, or some combination of these adaptations. 

These changes could improve pump efficiency by up to 3% depending on specific speed. 

3.3.4 Reducing Mechanical Friction in Seals 

There may be different seal materials or seal designs (e.g., non-contacting gas seals) that 

produce less mechanical friction loss, which will result in improved efficiency. These 

improvements will be possible mainly in higher pressure pumps. These improvements are not 

expected to improve efficiency by more than one percent. 

3.3.5 Reducing Other Volumetric Losses 

This might involve design changes to eliminate or reduce the volumetric losses in open 

impeller settings, thrust balance holes, and seal flush systems. Design changes in these 

components have the potential to increase pump efficiency by an estimated 1-3%. 

3.3.6 Using a Variable Speed Drive 

As discussed in section 1.2.3, for pumps in variable load applications, variable speed 

drives can be used to adjust pump output without throttling or bypass. This results in reduced 

power draw and maintenance of efficiency. (See section 1.2.3.) However, at full load, overall 

efficiency is lower, due to the losses within the VSD. VSDs will be considered a technology 

option in regulatory option 3. In addition, use of a VSD may introduce energy use in standby and 

off modes. DOE will consider this energy use in analyzing VSD use as a technology option. 

3.3.7 Improving VSD Efficiency 

VSDs have varying degrees of efficiency, and improvements to VSD efficiency will be 

considered a technology option for pumps sold with motors and VSDs. 

3.3.8 Reducing VSD Standby and Off Mode Power Usage 

Technology options may be considered that reduce the energy use of a VSD in standby 

and off modes. 
65

Item 3-14 DOE welcomes comment on the technology options identified in this section, 

including further details on methods (such as lists of specific methods for each listed broad 

option) and potential efficiency gains, as well as information on whether the method in 

question is applicable to all pumps in a given equipment class or only pumps with certain 

design characteristics). DOE also welcomes comment on whether there are other technology 

options that it should also consider. 

Item 3-15 DOE welcomes comment on the relevance of the technology options 

identified to pumps sold with smaller impellers than the full impeller on which DOE is 

tentatively proposing to base a standard. In particular, would these design options be carried 

through to pumps with all impeller sizes? 

Item 3-16 DOE requests information related to various impeller types used in clean 

water pump designs and the efficiency impacts of each type. 

4. SCREENING ANALYSIS 

The purpose of the screening analysis is to screen out technology options that DOE will 

not consider in its potential energy conservation standard rulemaking for commercial and 

industrial pumps. At the outset, DOE develops a list of technology options for consideration 

through its own research and in consultation with interested parties. Development of the list is 

based on the technologies described in section 3.3. The identified candidate technology options 

encompass all those technologies that may improve energy efficiency. 

DOE then reviews each technology option considering the following four criteria, as 

provided in sections 4(a)(4) and 5(b) of Procedures, Interpretations, and Policies for 

Consideration of New or Revised Energy Conservation Standards for Consumer Products (see 

10 CFR Part 430, Subpart C, Appendix A): 

1. Technological feasibility. DOE does not further consider technologies that are not 

incorporated in commercially available equipment or in working prototypes. 

2. Practicability to manufacture, install, and service. If DOE determines that mass 

production of a technology in commercial equipment and reliable installation and 

servicing of the technology could not be achieved on the scale necessary to serve the 

relevant market by the time of the effective date of the standard, then it does not 

consider that technology further. 

3. Adverse impacts on product or equipment utility or availability. If DOE determines 

that a technology will have a significant adverse impact on the utility of the 

equipment to significant subgroups of consumers, or result in the unavailability of 

any covered equipment type with performance characteristics (including reliability), 

features, size, capacities, and volumes that are substantially the same as equipment 

generally available in the United States at the time, it does not consider that 

technology further. 
66

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it does not consider that technology 

further. 

DOE will fully document the reasons for eliminating any technology options during the 

screening analysis and solicit stakeholder comment. The remaining options, called design 

options, are considered further in the engineering analysis (section 5). 

Item 4-1 Are there any technologies listed in section 3.3 (or others not proposed) that 

DOE should not consider because of any of the four screening criteria? If so, which screening 

criteria apply to the cited technology or technologies? 

5. ENGINEERING ANALYSIS 

After conducting the screening analysis described above, DOE performs an engineering 

analysis based on the remaining design options that would improve pump efficiency. This 

section provides an overview of the engineering analysis and discusses baseline units, DOE’s 

proposed approach for determining the cost-efficiency relationship, proprietary designs, 

efficiency levels, and cumulative regulatory burdens that might affect the engineering analysis. 

5.1 Overview 

The purpose of the engineering analysis is to determine the relationship between 

manufacturer selling price (MSP) and efficiency for pumps. In determining the cost-efficiency 

relationship, DOE estimates the increase in manufacturer selling price associated with design 

changes that increase the efficiency of pumps relative to the baseline models (which in most 

cases are the most typical low efficiency equipment currently sold on the market). 

As a preliminary step in this analysis, DOE may determine an appropriate subset of 

representative equipment classes to analyze. DOE would extrapolate the results of this analysis 

to the remaining equipment classes. Typically, each representative equipment class would 

represent the majority of the shipments in its category. The number of representative equipment 

classes will depend on the availability of data that would allow for developing appropriate 

relationships between the engineering analysis results of the representative equipment class and 

the other equipment classes not directly analyzed. 

For each representative equipment class, DOE may analyze a subset of representative 

units at selected flow and specific speed. Once DOE has identified cost-efficiency relationships 

for the representative units, it will scale the engineering analysis results to cover the full range of 

flow and specific speeds. DOE proposes to develop scaling relationships for pumps by creating a 

model that describes efficiency as a function of a pump’s flow and specific speed at BEP. As 

discussed in Section 1.4.5, DOE has developed a method to create the full range of surfaces from 

manufacturer catalog data. DOE may develop additional intermediate surfaces with these same 

data to use for scaling. Alternatively, DOE could use the EU surfaces for scaling. Finally, DOE 
67

could use the representative units to create incremental cost increases and efficiency increases, 

and apply these directly to other models. 

Once DOE establishes the representative equipment classes and representative units, it 

selects a baseline model as a reference point for each representative unit from which to measure 

changes resulting from the design options. DOE will then develop separate cost efficiency 

relationships for each baseline model analyzed. DOE intends to use pump teardowns and 

efficiency tests to develop these cost-efficiency relationships. DOE is considering the 

appropriate test procedures and will conduct a separate test procedure rulemaking (section 1.5). 

To develop the relationships between efficiency and technology options, DOE intends to 

utilize publicly available data from manufacturer catalogs and websites, where the technology 

options used can be identified. DOE encourages interested parties to submit test data that will 

improve DOE’s understanding of pump performance. Using these data, which will allow DOE to 

determine the incremental costs of changes in material, labor, shipping, and overhead from the 

baseline, DOE will develop cost estimates for design options (which it will also use in the 

manufacturer impact analysis, section 12). 

Item 5-1 DOE seeks input on the methods and approaches used by manufacturers to 

improve the efficiency of pumps and, in particular, how frequently hydraulic re-design would 

be the only method employed. 

Item 5-2 DOE welcomes comment from interested parties on the best methodology for 

scaling cost-efficiency curve results from the representative units to the representative 

equipment classes and extrapolating from the representative equipment classes to the 

remaining equipment classes not directly analyzed. 

5.2 Representative Class Selection 

Not all equipment classes may require unique representative units. For example, many 

manufacturers publish identical performance data for End Suction Close Coupled (ESCC) and 

End Suction Frame Mounted (ESFM) pumps. These are essentially identical pumps, but are 

supplied with different motors, which should affect wire-to-water efficiency but not pump 

efficiency. Ideally, ESFM pumps would be the preferred pump type to test in terms of accuracy 

of pump efficiency measurement, although ESCC pumps represent significantly more shipments. 

If DOE defines pumps inclusive of the motor and/or motor and controls, it will be necessary to 

test ESCC pumps in addition to ESFM pumps. 

Other equipment classes that could potentially be served by only one representative unit 

are vertical turbine and submersible vertical turbine pumps, as the bowls used in these pumps are 

often identical. However, the metric for submersible turbines may be overall efficiency, which 

would be different from the metric for vertical turbines. 

Item 5-3 DOE seeks comment on its selection of representative classes: which classes 

could be grouped together for this analysis, and which class should be tested. 
68

5.3 Representative Unit Selection 

Ideally, selection of representative units within an equipment class is based on 

identification of units that are functionally equivalent in all respects except efficiency. For many 

products, this would be done by choosing equipment of the same size at both baseline and higher 

efficiency levels (i.e., standard and premium efficiency motors) from a single manufacturer. An 

additional representative unit at a different size may also be chosen depending on the size range 

of the equipment class. For pumps, however, a given pump manufacturer generally does not 

offer multiple pumps with the same BEP at full impeller diameter. This is because manufacturers 

strategically offer pumps with overlapping and distributed performance ranges (at full and 

reduced impellers) to cover a large range of potential operating conditions. In addition, pump 

equipment classes currently under consideration cover a wide and continuous range of variations 

including designs (specific speed) and sizes (flow). If DOE defines minimum efficiency as a 

function of specific speed and flow, representative unit selection would need to account for 

specific speed in addition to size. 

DOE must select representative units for which there are pump models on the market at 

approximately constant BEP flow and specific speed but with different efficiency levels, and 

DOE would have to examine representative units at many flow and specific speed combinations. 

To identify these units, DOE developed a computer program to look at its database and iterate 

ranges of flow and specific speed to achieve bins of three pumps with as wide an efficiency 

range as possible. The parameters of the program can be altered to attempt to find pumps at 

desired baseline and higher efficiency levels, as discussed below. 

DOE realizes that it may be difficult to identify pump models with similar flow and 

specific speed at BEP that are available at both baseline efficiency and increased efficiency 

levels. In this case, DOE will consider scaling relationships to adjust testing results and develop 

cost-efficiency relationships using equipment with different BEPs. 

Item 5-4 DOE welcomes comment on the selection of representative units in terms of 

appropriate flow and specific speed ratings within each equipment class. 

5.4 Baseline Models 

DOE selects baseline models that represent the characteristics of pumps in a given 

equipment class used in common commercial or industrial applications. Typically, the baseline 

model would be a model that just meets current energy conservation standards. Because energy 

conservation standards for pumps do not exist, however, DOE will select baseline models 

representative of the least efficient, most typical pump offered for sale in the market. Selection of 

the baseline model for each representative unit will encompass consideration of pump features 

and performance characteristics. 

DOE is considering the appropriate method to develop baseline efficiency levels 

representative of the least efficient, most typical pumps offered for sale in each equipment class, 

recognizing that each equipment class contains pumps with a broad range of flows and specific 

speeds. As an example, the bottom-of-market surface presented in Figure 1.4 (in section 1.4.5) 
69

was developed to capture the least efficient pumps at any flow and specific speed. However, this 

approach results in areas of flow and specific speed without any pumps near this level (as can be 

seen in Figure 5.1). DOE could address this issue through disaggregation into additional 

equipment classes and development of a discontinuous function for the baseline level. 

Alternatively, DOE is considering a baseline level that covers many pumps over a wide range of 

flow and specific speed, such as that shown in Figure 5.1, in comparison to the bottom-of-market 

example. More figures can be found in Appendix C. 

Figure 5.1 Example Baseline Efficiency Levels for ESCC Pumps (Ns=1500-2500) 

DOE’s determination of the appropriate baseline efficiency levels will be determined by 

pump model data, pricing data, and shipment data by efficiency that are publically available or 

provided to DOE. Shipment data may indicate more appropriate baseline levels than model 

availability data, as the least efficient pumps may not have significant shipments and therefore 

would not be considered the least efficient, most typical pumps in the market.

Item 5-5 DOE seeks comment on the selection and performance characteristics of 

baseline models for each equipment class. DOE will consider such comments in defining the 

characteristics of the proposed baseline models. 

5.5 Efficiency Levels 

To establish the efficiency levels DOE intends to consider, DOE will identify the highest 

efficiency that is technologically feasible within each equipment class (i.e., the max-tech level) 

and analyze the design options and costs associated with improving pump efficiency from the 

baseline through the max-tech model. DOE intends to collect pump efficiency data from various 
70

manufacturer catalogs to establish the range of efficiencies currently available on the market. 

DOE will also use these data to categorize relationships between efficiency and technological 

options where the technological options used can be identified. 

 When defining a max-tech level based on market maximums, DOE found that a surface 

developed to go through the very highest efficiency pumps (as shown in Figure 1.4 in section 

1.4.5) will not represent the maximum efficiency available on the market for the majority of the 

flow-specific speeds. If a representative unit is selected at a market-max level that does not exist 

for many flow-specific speeds, it may not be appropriate to apply the results of the cost curve to 

pumps at these flow-specific speeds; in other words, the efficiency level may not represent the 

same level of cost-effectiveness at other flow-specific speed combinations. 

As in the baseline efficiency level discussion, DOE could address this issue through 

disaggregation into additional equipment classes and development of a discontinuous function 

for the market-max level. However, the cost of achieving the levels would not be discontinuous; 

the lack of models in certain areas likely just represents the lack of a market. Alternatively, DOE 

could draw a market-max level that goes through many pumps at a wide range of flow-specific 

speeds. Figure 5.2 shows an example of this latter option, in comparison to the top-of-market 

surface shown in Figure 1.4 Additional figures can be found in Appendix C.

Figure 5.2 Example Max-Tech Efficiency Levels for ESCC Pumps (Ns=1500-2500) 

DOE notes that the maximum efficiency levels available in current pump equipment may 

not necessarily correspond to the max-tech levels. It is possible that some of the design options 

that have met the screening criteria (i.e., passed the screening analysis) may be working 

prototypes that are not yet commercially available and, therefore, would not be found in today’s 
71

available maximum efficiency pumps. DOE seeks stakeholder input to determine appropriate 

max-tech efficiency levels. (42 U.S.C. § 6295(p)(2)) 

Item 5-6 DOE seeks input from stakeholders regarding the range of efficiency levels 

that should be examined as part of its analysis. 

Item 5-7 DOE seeks input from interested parties on a methodology that would be 

appropriate for determining the max-tech models for each pump analyzed. 

5.6 Developing Cost-Efficiency Relationships 

DOE uses a manufacturing costs structure that follows the traditional manufacturing 

process and includes: 

1) Equipment Costs (MSP): Recurring costs associated with manufacturing. 

a. Full production cost (manufacturer production cost (MPC)), i.e., direct labor, 

direct material, overhead (indirect labor, indirect material, maintenance, 

depreciation, taxes, insurance related to assets). 

b. Non-production cost, i.e., selling (market research, advertizing, point-of-sale 

(POS) promotion, sales person compensation and travel, logistics such as 

warehousing, delivery, record keeping), general and administration (costs for 

service and staff units, general corporate costs such as compensation, etc.), 

research and development (R&D) (costs associated with efforts to find new or 

improved products or production processes) and interest (costs of borrowing 

funds). DOE typically uses manufacturer markups calculated from publicly 

available financial information (e.g., Securities and Exchange Commission 10-K 

reports) to account for non-production costs. 

2) Conversion Costs: Investments to bring production facilities and equipment designs 

in compliance with the new regulation. 

a. Equipment conversion costs, i.e., investments in research, development, testing, 

and marketing focused on making equipment designs comply with the new 

standard. 

b. Capital conversion costs, i.e., investments in property, plant, and equipment to 

adapt or change existing production facilities so that the new equipment designs 

can be fabricated and assembled. 

c. Stranded assets, i.e., equipment or tooling that become obsolete as a result of new 

regulation. 
72

To derive the material and labor cost portions of the full production cost, DOE plans to 

purchase, test, and tear down selected pumps within each representative equipment class. DOE 

will disassemble and inventory the pump components, creating a bill of materials and identifying 

manufacturing processes required to fabricate the pumps. 

DOE may supplement the findings from its tests and teardowns through: (1) a review of 

data collected from manufacturers about prices, efficiencies, and other features of various models 

of pumps, and (2) interviews with manufacturers about the techniques and associated costs used 

to improve efficiency. If possible, DOE will then aggregate the cost numbers by weighing 

individual data points by company-level sales volumes for each equipment class.

DOE recognizes that there may be limited public information on national shipments, 

manufacturing costs, channels of distribution, and manufacturers’ market shares of pumps. DOE 

encourages interested parties to submit any available data that pertain to these areas of interest 

and that would improve DOE’s understanding of the pump market. 

DOE is sensitive to manufacturer concerns regarding proprietary designs and will make 

provisions to maintain the confidentiality of proprietary data submitted by manufacturers or 

discussed during manufacturer interviews. Materials provided to Lawrence Berkeley National 

Laboratory (LBNL) and Navigant Consulting, Inc. (NCI), DOE contractors for this rulemaking, 

are generally subject to the terms of the applicable agreement under which those materials are 

submitted. In the case of materials provided to LBNL or NCI in the context of a DOE 

rulemaking and subject to a non-disclosure agreement, those materials are generally not shared 

with DOE, apart from aggregated data that do not identify particular submitters. These materials 

may also be subject to a variety of laws and regulations governing the disclosure of Federal 

agency information. Information submitted to DOE will be protected in accordance with all 

applicable federal laws, rules, or regulations, including but not limited to the Trade Secrets Act, 

18 U.S.C. §1905, and the Freedom of Information Act (FOIA), 5 U.S.C. §552, and DOE's 

implementing regulations at 10 CFR 1004. 

Manufacturer cost information should reflect the variability in baseline models, design 

strategies, and cost structures that exist among manufacturers. If necessary, DOE will qualify any 

aggregated cost-efficiency data using information obtained through follow-up discussions with 

manufacturers. These interviews will provide a deeper understanding of the various 

combinations of technologies used to increase pump efficiency, as well as their associated 

manufacturing costs. 

During the interviews with manufacturers, DOE will gather information about the capital 

expenditures needed to increase the efficiency of baseline models to various efficiency levels 

(i.e., conversion expenditures by efficiency). DOE will also gather information about the 

depreciation method(s) used to expense the conversion expenditures. DOE will then estimate the 

contribution of the depreciation of conversion capital expenditures to the incremental overhead 

portion of the full production cost. 

This proposed approach will enable DOE to characterize the cost-efficiency relationship 

for pumps across the entire efficiency range for all equipment classes and allow the public to 
73

examine the aggregated cost and design assumptions that underlie the cost-efficiency estimates, 

while maintaining the confidentiality of proprietary data as described above. 

DOE typically uses markups to represent non-production costs and convert the MPC to 

the MSP. DOE intends to estimate manufacturer markups from publicly available financial 

information (e.g., Securities and Exchange Commission 10-K reports) and from information 

obtained in manufacturer interviews. 

DOE typically does not include conversion costs in the engineering analysis. Although 

these costs may be passed along to the customer, they are traditionally considered during the 

manufacturer impact analysis. DOE understands, however, that one of the primary methods used 

to increase the efficiency of pumps is hydraulic re-design, which may not represent any 

difference in manufacturing cost, but which incurs primarily up-front R&D and conversion costs 

(including the complete remaking of pattern tooling, new machine drawings, a full range of 

hydraulic testing to document the new hydraulic performance, and manufacturing plant 

conversion). If DOE decides to account for some or all of these conversion costs, these costs 

would be included as part of the manufacturer markups (see section 6). 

Item 5-8 For each equipment class, DOE welcomes comments on methods and 

approaches that DOE intends to employ to determine potential efficiency improvements for 

pumps. Detailed information on the pump performance and the incremental manufacturing 

costs (e.g., material costs, labor costs, overhead costs, building conversion capital 

expenditures, capital expenditures for tooling or equipment conversion associated with more 

efficient designs, R&D expenses, and marketing expenses) would be useful. 

Item 5-9 DOE welcomes comment on the markup approach proposed for developing 

estimates of manufacturer selling prices. 

Item 5-10 DOE welcomes comment on the approach to determining the relationship 

between manufacturer selling price and pump efficiency. 

Item 5-11 DOE welcomes comment on the conversion costs required to improve the 

efficiency of the pumps to various levels, as well as what portion of these costs would be 

passed on to the consumer. 

5.7 Proprietary Designs 

DOE will consider in its engineering and economic analyses all design options that are 

commercially available or present in a working prototype, including proprietary designs and 

technologies. However, DOE will consider a proprietary design in the subsequent analyses only 

if the achieved efficiency level can also be reached using other non-proprietary design options. 

 If the proprietary design is the only approach available to achieve a given efficiency level, then 

DOE will reject that efficiency level, as the analytical results would appear to favor one 

manufacturer over others. DOE welcomes comment on whether there are proprietary designs it 
74

should be aware of that may give some manufacturers a disproportionate advantage for any of 

the pump designs under consideration in this rulemaking. 

5.8 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE takes into consideration the effects of other 

DOE energy conservation standards and regulatory changes outside DOE’s statutory energy 

conservation standards rulemaking process that can impact the manufacturers of the covered 

equipment. Some regulatory changes can also affect the efficiency or energy consumption of the 

pumps covered under this rulemaking. DOE will attempt to identify all such outside engineering 

issues that could impact the engineering analysis. The consideration of these issues is closely 

related to the cumulative regulatory burden assessment that DOE will carry out as part of the 

manufacturer impact analysis (see section 12.5).

Item 5-12 DOE welcomes comment on whether there are outside regulatory changes that 

DOE should consider in its engineering analysis of pumps. 

6. MARKUPS ANALYSIS 

DOE uses manufacturer-to-consumer markups to convert the MSP estimates from the 

engineering analysis to consumer prices, which are then used in the LCC and PBP analyses. Enduser prices are needed for the baseline efficiency level and all other efficiency levels under 

consideration to estimate consumer costs and benefits as a result of energy conservation 

standards. DOE will obtain these end-user prices by applying manufacturer-to-consumer 

markups (consisting of distribution channel markups and sales tax) to the MSP estimates. 

To develop estimates for markups, DOE must identify distribution channels (i.e., how the 

equipment is distributed from the manufacturer to the consumer). Once it determines the 

distribution channels used for each of the equipment classes, DOE will rely primarily on 

economic census data from the U.S. Census Bureau and input from the industry to estimate how 

equipment is marked up in the distribution chain from the manufacturer to the consumer. DOE 

may also consider whether end-user price data can be used to characterize overall manufacturerto-consumer markups. 

 

The following subsections summarize DOE’s approach for developing markups for the 

Preliminary Analysis of commercial and industrial pumps. 

6.1 Market Participants and Distribution Channels 

DOE’s review of information indicates that pump manufacturers provide pumps to the 

marketplace through a variety of channels. 

Figure 6.1 shows the likely distribution channels for commercial and industrial pumps. In 

the original equipment manufacturer (OEM) and direct-to-customer channels, DOE expects that 

the manufacturer sells the equipment directly to the OEM, or customer, through a national 

account. For the OEM channel, after the OEM integrates the pump(s) into a final packaged 
75

product, it is expected that the OEM distributor sells the packaged unit to the customer. In the 

wholesaler channels, DOE believes that the manufacturer sells the equipment to a wholesaler, 

who in turn may sell it directly to the customer or through a contractor. 

Figure 6.1 Commercial and Industrial Pump Distribution Channels 

DOE has preliminarily identified the following high-volume application segments [22] 

for commercial and industrial water pumps: agriculture; water and sewage handling; 

construction; heating, ventilating, and air conditioning (HVAC); food processing, 

pharmaceutical; refineries; and hydropower. DOE believes these application segments map to 

market segments for which the applicable distribution channels are those discussed previously. 

For the OEM channel, where pumps are integrated in the systems manufactured by the OEMs, 

DOE’s preliminary review suggests the products are sold only into the commercial and industrial 

market segments. 

Item 6-1 DOE requests information on the distribution channels under consideration. 

Item 6-2 DOE requests comments and additional information on the appropriate way to 

establish distribution channel percentages across equipment classes and application (market) 

segments for the current rulemaking. In particular, DOE seeks information on the percentage 

by market segment (i.e., agriculture, municipal, commercial, industrial, and other markets) of 

direct sales, OEM sales, wholesaler to customer sales, wholesaler to contractor sales, and 

other sales. DOE seeks this information over the total market. 

6.2 Estimating Markups 

DOE intends to develop baseline and incremental markups for commercial and industrial 

pumps. Baseline markups are cost multipliers applied to the MSP of baseline equipment, while 

the incremental markups are cost multipliers applied to the incremental cost change in the MSP 

of the higher efficiency equipment. The markup analysis will generate end-user prices for each 

equipment efficiency level that DOE considers. 

DOE plans on using data sources such as the U.S. Census Bureau Economic reports, 

trade association member aggregate profit analysis reports, as available, and RS Means 

mechanical cost data to estimate baseline and incremental markups. For the sales through the 

direct end-user channel, DOE will estimate the markup percentage based on information 

provided by the manufacturers on differences in the final end-user price through the distribution 

Manufacturer  Customer (Direct End-User Channel)

Manufacturer  OEM  OEM Distributor  Customer (OEM Channel)

Manufacturer  Wholesaler  Customer (Distributor Channel) 

Manufacturer  Wholesaler  Contractor  Customer (Contractor Channel)
76

channels and the manufacturer-to-wholesaler prices. For the OEM channel, DOE will first 

estimate the manufacturers’ markup percentage using either public domain data from a 

representative sample of manufacturers or economic census data from the U.S. Census Bureau 

for the specific industry group. Then, the distributors’ mark-up multiplier for the OEM 

equipment incorporating the pumps will be estimated using the wholesaler markup. For 

estimating wholesaler markups, DOE will use the U.S. Census Bureau Economic Census reports 

and the aggregate profit analysis reports. For estimating general contractor markups, DOE 

proposes to use the U.S. Census Bureau data for Pumps and Pumping Equipment Manufacturing 

(North American Industry Classification System 333911) and RS Means mechanical cost data. 

For the appropriate sales tax markup, population-weighted average tax data will be based on the 

Sales Tax Clearinghouse and U.S. Census Bureau. DOE may consider adding shipping costs to 

the markups or include them in the manufacturer’s sales price, as appropriate. 

Item 6-3 DOE seeks comment on other sources of relevant data that could be used to 

characterize markups for commercial and industrial pumps. 

Item 6-4 DOE requests feedback on its proposal to use incremental distribution channel 

markups. 

Item 6-5 DOE seeks comment on appropriate transportation and shipping costs to 

include in the analysis and whether those costs are likely to vary for higher efficiency 

commercial and industrial pumps. 

7. ENERGY USE AND END-USE DUTY PROFILE ANALYSIS 

The purpose of the energy-use and end-use duty profile analysis is to identify how 

equipment is used by end users, and to determine the energy savings potential of equipment with 

a more efficient design in the same operating conditions. The results of this analysis are used as 

input to the LCC, PBP, NIA, and other downstream analyses. 

7.1 Overview 

The annual energy consumption (AEC) associated with a pump in actual use conditions 

depends primarily on the power drawn by the pump and its duty profile. DOE uses the term 

“duty profile” to represent the variation of the pump flow rate and head at the point of pump 

outlet over the usage cycle in a specific time frame (annual, monthly, and daily), relative to a 

predetermined fixed duty or operating point on the pump performance curve. The duty or 

operating point may correspond to the “design” or “peak flow rate”, or other well defined 

operating point on the pump performance curve. Flow rate and head are related through the 

pump performance curve. As flow rate is the more commonly used descriptor of the pump 

output, DOE will use duty profile to represent the variability of the ratio of the actual flow rate to 

a predetermined fixed flow rate over the typical usage period for pumps with fixed speed drives. 

Pumps coupled to VSDs follow the system curve of the network connected to the pump. In this 

case, the duty profile will represent the distribution of the operating hours within a range near a 
77

selected point on the system curve from the minimum turndown flow rate to the maximum 

allowable flow rate of the system. 

For most pumps, the end-use duty profiles are expected to vary across the equipment 

classes and application segments. If there is little variation in the pump flow rate over the period 

of use, only the number of annual operating hours needs to be determined to estimate the AEC. 

For an application driven by a VSD, the flow rate will change continuously based on the 

pumping load. In this case, the AEC is determined by a summation of the number of hours run 

for each specific flow rate and pump head bin on the system curve and the corresponding hourly 

energy consumption in each bin. 

A pump’s specified operating point efficiency in relation to the pump’s efficiency at 

BEP is used in determining the AEC of a pump under actual usage condition. Ideally the user 

will size the pump such that the BEP of the pump closely matches the most frequent duty 

requirement of the pumping load. However, pump manufacturers produce only a limited range of 

pumps in a given series to meet a wide range of duties encountered in typical operating 

conditions. This creates the situation of catalog inefficiency, where the user purchases the pump 

closest to, but not necessarily at, the specified duty point. This catalog inefficiency results in 

deviation of the operating point of the selected pump from its recommended BEP. DOE 

recognizes that the manufacture and use of discrete sizes of pumps, limitation of the range of 

available sizes, and practical application constraints result in pumps not operating at the 

manufacturer recommended BEPs. DOE also recognizes that pumps are often designed to exceed 

the flow rate capacity and head requirements as an engineering precaution. In addition, pumps 

are often selected based on the peak load or maximum system capacity, resulting in further 

inefficiency. These considerations apply to both the baseline pump energy use and to the energy 

use of more efficient pumps. 

DOE will develop statistical models describing the expected range of duty profiles for 

pumps in different applications. DOE will determine whether the model parameters should also 

vary with the pump equipment class or capacity. DOE will use manufacturer pump curves and 

pump similarity laws to determine the energy use of a pump under the expected deviation from 

the BEP. This approach will provide a statistical distribution of AEC values for each pump type 

and application, for use in the LCC and PBP analysis (section 10). 

Item 7-1 DOE requests input and recommendations for identifying high sales volume 

and large installed base application segments corresponding to specific applications for 

which the pumps used may have similar duty profiles. 

Item 7-2 DOE welcomes recommendations on sources of data or analysis methods that 

would provide end-use duty profiles for each of the equipment classes of pumps covered 

under this rulemaking in the major application segments. 

Item 7-3 DOE requests input on ways to characterize pump sizing and selection 

practices for different equipment classes and applications. 
78

Item 7-4 DOE requests comment on the degree of oversizing prevalent in different 

application segments. 

Item 7-5 DOE welcomes comment on methods for determining nominal (non-market 

segment specific) duty profiles for pump equipment classes considered in this rulemaking. 

Item 7-6 DOE welcomes comment on the current penetration level of VSDs in the 

installed base of equipment in each application segment for each of the equipment classes 

considered in this rulemaking. DOE also welcomes comment on the baseline condition for 

applications without VSDs, such as running at full load, use of a throttling valve, etc. 

7.2 Analytical Approach 

DOE will estimate the energy savings for an equipment class based on the calculated 

energy saving potential for improved efficiency designs for each representative unit. For each 

analyzed representative unit, the starting point for the AEC calculation will be the power curves 

developed in the engineering analysis for a range of operating points on the pump performance 

curve. DOE will estimate the average AEC for each representative unit in a given application by 

using the following formula: 

,5/).()/( 308

_ _

1

AEC HQ N Sp Gr

All operating ponts

i

ii

overallii

Where: 

AEC = annual energy consumption (kWh), 

 = flow rate at the operating point i, gallons per minute (gpm), 

= pump head at the operating point i, ft, 

Ni = operating hours at the operating point i, 

ηOverall = ηF × ηT × ηM × ηC at the operating point i, 

ηF = pump efficiency, 

ηT = transmission efficiency, 

ηM = motor efficiency, 

ηC = control system efficiency, 

Sp.Gr = specific gravity of the fluid, and 

5,308 is a unit conversion constant. 

Qi and Hi are based on the actual operating points of the pump on the pump performance 

curve for fixed-speed pumps and on the system curve for VSD-driven pumps. For a given 

application in an equipment class, and for each equipment class overall, DOE requests 

information and data sources useful for determining each of the factors described above. 
79

Item 7-7 DOE requests comment and recommendation on the range and number of 

sizes over which the analysis should be carried out for each specific speed in different classes 

of equipment. 

Item 7-8 DOE requests information on current industry practices and recommendations 

on the selection of representative operating points for a given specific speed. DOE welcomes 

comment on whether the analysis should be extended to a range of operating points away 

from BEP. 

Item 7-9 DOE requests comment and estimates to establish the mean value and the 

ranges of likely values for transmission, motor, and motor control efficiencies, as well as the 

impact of a control on motor performance and efficiency. 

8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

The effects of energy conservation standards on customers include a change in operating 

expense (usually decreased) and a change in purchase price (usually increased). DOE analyzes 

the net effect on customers by calculating the LCC and PBP using the engineering performance 

data, the equipment prices, and the energy-use and end-use load characterization data. Inputs to 

the LCC calculation include the cost to the customer of the installed equipment (purchase price 

plus installation cost), operating expenses (energy expenses and, if applicable, repair costs and 

maintenance costs), the lifetime of the equipment, and a discount rate. 

8.1 Analytical Approach 

DOE plans to conduct an LCC and PBP analysis for each of the representative units for 

each representative pump equipment class. As illustrated in Figure 8.1, DOE considers the pump 

selection process in the center of the LCC Analyses flow diagram to reflect product choices by 

customers. The market size of covered pumps (such as shipments and values) depends on 

equipment classes and application segments, while energy price varies by end-user sectors. 

Similarly, a pump’s duty profile (including hours of operation and specific duty points) changes 

in different application segments. In the pump selection process, customers are expected to select 

pump models (and motors, if applicable) that meet the duty point requirements. Based on pump 

efficiencies at a specific duty point, annual energy consumption is calculated depending on 

whether it operates under variable load or constant load. DOE then aggregates the annual energy 

consumption over a pump’s lifetime for the life-cycle cost analysis, taking into account an 

efficiency degradation factor and a discount rate. 
80

Figure 8.1 Flow Diagram of LCC Analyses for Pumps 

DOE conducts the LCC and PBP analysis by modeling both the uncertainty and 

variability in the inputs using Monte Carlo simulation and probability distributions. The Monte 

Carlo approach identifies the percentage of consumers benefiting from and being burdened by a 

prospective standard. The LCC model uses Monte Carlo simulation to sample probability 

distributions for several of the parameters that affect the LCC. The Monte Carlo simulation is 

implemented using Microsoft Excel spreadsheets and the Crystal Ball add-in program. Each 

Monte Carlo simulation would typically consist of 10,000 LCC and PBP calculations. Each 

calculation uses input values sampled from a probability distribution or defined as single point 

values. The analysis results are presented as a distribution of LCC values and summary statistics, 

such as average LCC and standard deviation. 

DOE expects to use probability distributions to characterize equipment lifetimes, 

discount rates, and annual energy use and to represent the degree to which equipment is 

optimally sized for a given pumping load. DOE may also use probability distributions for 

distributor markups. DOE expects to use point values to characterize the other LCC inputs, 

including the manufacturer markup, as these data are available only as single values. 

To accurately estimate the percentage of customers that would be affected by a particular 

standard level, DOE takes into account the distribution of equipment efficiencies expected for 

the compliance year. In other words, rather than analyzing the impacts of a particular standard 

level assuming that all consumers are currently purchasing equipment at the baseline level, DOE 
81

conducts the analysis by taking into account the full range of equipment efficiencies that 

customers purchase under the base case (i.e., the case without new energy efficiency standards). 

By accounting for customers who already purchase more-efficient equipment, DOE avoids 

overstating the potential benefits from standards. DOE determines the LCC and PBP for a 

particular standard level relative to the base case distribution of equipment efficiencies. Hence, if 

the equipment chosen in the base case has an efficiency that meets a given CSL, the LCC and 

PBP calculations for that customer are not impacted by the standard. For customers not affected 

by a given CSL, the LCC savings are zero, and the payback period is not defined. 

DOE is also required to perform an analysis to determine whether the three-year 

rebuttable presumption of economic justification applies, that is, whether the additional cost of 

purchasing a product that meets the standard level would be less than three times the value of the 

energy savings in the first year. (42 U.S.C. § 6295(o)(2)(B)(iii)) For this analysis, DOE 

determines the value of the first year’s energy savings using the DOE test procedure. The 

economic justification of CSLs, however, is based on the analysis conducted pursuant to section 

325(o)(2)(B)(i) of EPCA. (42 U.S.C. § 6295(o)(2)(B)(i)) 

The following sections discuss how DOE plans to develop key inputs to the LCC and 

PBP analysis, including (1) installation costs, (2) energy prices, (3) maintenance and repair costs, 

(3) equipment lifetime, and (4) discount rates. The other inputs to the LCC and PBP analysis—

namely, manufacturer costs, annual energy consumption, and markups for the determination of 

retail prices—have been discussed previously. 

8.2 Installation Costs 

The installation cost includes labor, overhead, and any other miscellaneous materials and 

parts. DOE is aware that there is variability in the costs for commercial and industrial sector 

pump installations. However, DOE does not have information to suggest that existing installation 

practices would necessarily change under an energy conservation standard. 

Item 8-1 DOE welcomes comment on whether installation costs for pumps increase 

with higher efficiency equipment. 

8.3 Energy Prices 

DOE will use tariff-based marginal electricity prices to value electricity savings for 

commercial and industrial customers. Marginal prices will be developed for the different 

customer sectors at the census division level. DOE will then use projections of energy prices for 

commercial and industrial customers by census division from the most recent version of the 

Energy Information Administration’s (EIA’s) Annual Energy Outlook (AEO) to estimate future 

energy prices. To account for the expenses due to reactive power demand, DOE also intends to 

survey reactive power prices, principally using data from the EIA. 

Item 8-2 DOE welcomes input on the proposed methodology for estimating current and 

future electricity prices. 
82

8.4 Maintenance and Repair Costs 

DOE will take into consideration any expected changes to maintenance and repair costs 

for the equipment covered in a rulemaking. Small incremental changes in equipment efficiency 

are expected to incur little or no change in repair and maintenance costs over baseline equipment. 

For equipment with significant energy efficiency improvements over the baseline, there may be 

increased repair and maintenance costs, because such equipment may incorporate technologies 

that are not widely available. 

Item 8-3 DOE invites comment on how repair costs may change for more efficient 

pumps. 

8.5 Equipment Lifetime 

DOE will use information from catalogs and various literature sources, and input from 

manufacturers and other stakeholders, to establish pump lifetimes for use in the LCC and 

subsequent analyses. DOE may consider correlation between pump lifetime, annual operating 

hours, and loading (i.e., operation away from BEP) if quantitative evidence is found that these 

factors in the field affect pump lifetimes. DOE believes that the average pump lifetime is 10-15 

years, with a maximum of around 25 years. 

The service lifetime of centrifugal pumps varies quite widely. The average lifetime of 

clean water pumps is significantly higher than that of non-clean water pumps, as pumps handling 

liquids other than clean water are subject to corrosion or abrasion of the wetted parts, or both. 

Even within the category of clean water pumps, though, the lifetime of centrifugal pumps varies 

widely based on a variety of application characteristics, such as: 

Whether the pump is immersed in liquid such as in a vertical turbine or submersible style, 

as immersed or submersible pumps with wetted bearings may be expected to have a 

shorter mechanical life than pumps such as end suction pumps, which have bearings that 

are lubricated with clean oil or grease. 

The pump head, horsepower, and speed, as higher values of any of these parameters tend 

to increase bearing loads and the amount of wear and tear on mechanical seals. 

The temperature of the fluid being pumped, as higher temperature fluids tend to shorten 

mechanical seal life. 

The discussion of service lifetime of pumps is somewhat complicated by the fact that 

smaller, less expensive pumps are treated as “throwaway” pumps, that is, they are not repaired, 

but simply run to the point where they no longer deliver the minimum flow desired, or to where 

they leak excessively and uncontrollably, and then replaced. Typically, this would be the 

strategy for smaller pumps, 2 or 3 HP and less, and even larger pumps, up to 10 - 25 Hp for some 

users of pumps. For pumps that are bigger than this threshold of size, the pumps are repaired, 

with the repair activity including replacing or refurbishing such parts as bearings, mechanical 

seals, sleeves, wear rings, impellers, etc. This repair cycle is likely to be repeated multiple times 

throughout the complete life of the pump, which in many cases is as long as the plant or building 
83

is in service (30 – 50+ years). In other cases the pump may be prematurely replaced if the 

system in which the pump operates is being significantly modified, if the conditions of service 

for the pump dramatically change, or if the major parts of the pump are worn such that a repair is 

significantly more costly than the purchase of a new pump. Table 8.1 shows DOE’s estimates of 

the lifetime distribution for pump categories that are treated as throwaway pumps. Table 8.2

shows DOE’s estimates of the repair cycle distribution for pump categories that are repaired 

rather than thrown away. 

Table 8.1 Lifetime Distribution for Pump Categories 

Product 

Code

Product

Description

1

st

5

th

(Yrs.)

2

nd

5

th

(Yrs.)

3

rd

5

th

(Yrs.)

4

th

5

th

 

(Yrs.)

5

th

5

th

 

(Yrs.)

3339111448 Centrifugal single and two stage, single 

and end suction, close coupled with 

driver

3 7 10 13 17

3339111450 Centrifugal single and two stage, single 

suction, in-line, close coupled with 

driver

3 7 10 13 17

3339111496B Vertical turbine pumps with 

submersible motors, bowl assemblies

3 6 9 12 15

Table 8.2 Repair Cycle Distribution for Pump Categories 

Product 

Code

Product

Description

1

st

5

th

(Yrs.)

2

nd

5

th

(Yrs.)

3

rd

5

th

(Yrs.)

4

th

5

th

 

(Yrs.)

5

th

5

th

 

(Yrs.)

3339111452 Centrifugal single stage, single suction, 

frame or foot mounted, non-ANSI, 

non-ISO, with or without recessed 

impeller, all size discharge

2 4 6 8 10

333911144E Centrifugal single stage, single suction, 

vertical, in-line frame

1 3 5 7 9

333911144H Centrifugal single stage, single suction, 

frame or foot mounted, metallic 

pumps, built to National or 

International Standards ANSI B73.1 or 

ISO2858

1 3 5 7 9

333911145L Centrifugal single stage, axially spit, 

double suction, all size discharge

2 4 6 8 10

333911146F Centrifugal multi-stage, single or 

double suction, diffuser design, volute 

or diffuser design, axially split case

2 4 6 8 10

3339111468 Centrifugal multi-stage, single or 

double suction, diffuser design, radially 

split case

1 3 5 7 9
84

Product 

Code

Product

Description

1

st

5

th

(Yrs.)

2

nd

5

th

(Yrs.)

3

rd

5

th

(Yrs.)

4

th

5

th

 

(Yrs.)

5

th

5

th

 

(Yrs.)

3339111486 Centrifugal propeller and mixed flow, 

horizontal and vertical, all sizes.

2 4 6 8 10

3339111496A Vertical turbine pumps, bowl 

assemblies, and can and pot type. 

Excludes those with sub. motor

1 3 5 7 9

Item 8-4 DOE welcomes comment on appropriate pump lifetimes for the equipment 

classes covered in this rulemaking, as well as data regarding correlation between pump enduse patterns and pump lifetime. 

Item 8-5 DOE requests data on the degradation of pump efficiency over a pump’s 

lifetime. 

8.6 Discount Rates 

The calculation of LCC requires the use of an appropriate discount rate for those 

commercial or industrial companies that purchase pumps. DOE will derive the discount rates for 

these commercial and industrial customers by estimating the capital costs for companies that 

purchase pumps. The cost of capital is commonly used to estimate the present value of cash 

flows to be derived from a typical company project or investment. Most companies use both debt 

and equity capital to fund investments, so the cost of capital is the weighted-average cost of 

equity and debt financing, which is referred to as the weighted-average cost of capital. 

Item 8-6 DOE welcomes input on the proposed approaches for estimating discount 

rates for pump customers. 

9. SHIPMENTS ANALYSIS 

DOE uses shipment projections by equipment class to calculate the national impacts of 

standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to 

develop shipments projections based on an analysis of key market drivers (i.e., commercial 

building construction trends, growth in industries that use pumps) for the equipment in this 

rulemaking. 

DOE’s approach considers that shipments of pumps are driven by machinery production 

growth for equipment incorporating pumps and by the economic growth of commercial and 

industrial sectors that use this equipment. Historical data will be used to establish the relationship 

between shipments of pumps and the appropriate growth index for sector growth. DOE intends 

to use private fixed investment data for equipment incorporating pumps from the U.S. 
85

Department of Commerce’s Bureau of Economic Analysis to characterize the production of this 

equipment. 

DOE typically projects shipments for a 30-year period beginning with the expected 

compliance date of any standards. 

Item 9-1 DOE welcomes comment on the shipments projection methodology. DOE 

invites comments regarding the selection of appropriate economic drivers and sources of data 

for historical shipments and shipment breakdowns by equipment class. 

Item 9-2 DOE requests historical shipments or bookings data for each of the considered 

equipment classes, with further breakdowns where available including, but not limited to, 

flow, head, specific speed, horsepower, or efficiency. 

9.2 Standards Impacts on Shipments 

DOE plans to derive standards-case projections using the same data used in the 

development of the base-case projections. However, because the standards-case forecasts take 

into account the usual increase in purchase price and the usual decrease in operating costs caused 

by standards, projected shipments typically deviate from the base case. The magnitude of the 

difference between the standards-case and base-case shipment projections depends on the 

estimated purchase price increase, as well as the operating-cost savings from the standard. DOE 

plans to assess whether the purchase price or the operating cost will have a greater impact on 

equipment purchase decisions; therefore, standards-case projections may show a change in 

shipments relative to the base case. 

Item 9-3 DOE welcomes comment on how any standard for pumps might impact 

shipments of the equipment in this rulemaking. 

10. NATIONAL IMPACT ANALYSIS 

The NIA assesses the aggregate impacts of potential efficiency standards at the national 

level. Impacts that DOE will report include the NES from potential pump standards (i.e., the 

cumulative incremental energy savings from pump efficiency standards) and the NPV of the total 

customer benefits. 

A key component of DOE’s estimates of NES and NPV are the equipment energy 

efficiencies projected over time, for the base case (without new standards) and for each of the 

standards cases. To develop the various standards cases, DOE plans to develop market-share 

efficiency data (i.e., data on the distribution of equipment shipments by efficiency) for the pump 

equipment classes DOE is considering. 

To estimate the impact that standards may have in the year compliance becomes required, 

DOE has used "roll-up" and/or "shift" scenarios in its standards rulemakings. Under the "roll-up" 
86

scenario, DOE assumes (1) equipment efficiencies in the base case that do not meet the standard 

level under consideration would "roll up" to meet the new standard level; and (2) equipment 

shipments at efficiencies above the standard level under consideration would not be affected. 

Under the "shift" scenario, DOE retains the pattern of the base-case efficiency distribution but reorients the distribution at and above the new minimum energy conservation standard. For this 

rulemaking DOE proposes to use their traditional "roll-up" scenario to perform this estimation as 

it has done in many past standards rulemakings. DOE believes that pump manufacturers are 

likely to make the minimum investment necessary to roll-up pumps to the standard level and that 

the efficiency distribution would not be re-oriented at and above the new standard. After DOE 

establishes the average efficiency for the assumed effective date of a standard, it can estimate 

future efficiency by using the same rate of projected efficiency growth as for the base-case 

efficiency trend. 

10.1 National Energy Savings 

DOE intends to calculate national pump energy consumption for each year beginning 

with the expected compliance date of any standards. It will calculate national pump energy 

consumption for the base cases and each standard level analyzed, and the energy savings will be 

calculated as the difference in energy consumption between the base case and the standards 

cases. DOE plans to perform this calculation through the use of a spreadsheet model that 

accounts for the stock of equipment affected by standards.33 The energy savings are measured 

over the entire lifetime of products purchased in the 30-year projection period.34

DOE has historically presented NES in terms of primary energy savings. On August 18, 

2011, DOE announced its intention to use full-fuel-cycle (FFC) measures of energy use and 

greenhouse gases and other emissions in the national impact analyses and emissions analyses 

included in future energy conservation standards rulemakings. (76 FR 51282) While DOE stated 

in that notice that it intended to use the Greenhouse Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) model to conduct the analysis, it also said it would review 

alternative methods, including the use of the National Energy Modeling System (NEMS). After 

evaluating both models and the approaches discussed in the August 18, 2011 notice, DOE 

determined that NEMS is a more appropriate tool for this analysis. 77 FR 49701 (August 17, 

2012). Therefore, DOE intends to use NEMS to conduct FFC analyses. 

10.2 Net Present Value of User Benefits 

To develop the national NPV of user benefits from potential standards, DOE must 

calculate annual energy expenditures and annual equipment expenditures for the base case and 

the standards cases. DOE calculates annual energy expenditures from annual energy 

consumption by incorporating forecasted energy prices, using the shipment and average energy 

efficiency projections described in section 9. DOE calculates annual equipment expenditures by 

multiplying the price per unit times the projected shipments. The difference each year between 

 

33 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at: 

http://www.eere.energy.gov/buildings/appliance_standards/. 

34 In the past DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured 

over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of 

national energy savings to be consistent with the approach used for its national economic analysis. 
87

energy bill savings and increased equipment expenditures is the net savings (if positive) or net 

costs (if negative). DOE discounts these annual values to the present time and sums them to 

provide a NPV. According to U.S. Office of Management and Budget (OMB) guidelines, DOE 

will calculate NPV using real discount rates of three percent and seven percent (OMB, Circular 

A-4: Regulatory Analysis (2003). 

11. CUSTOMER SUBGROUP ANALYSIS 

The LCC analysis described in section 8 analyzes the impacts of energy conservation 

standards on all users of commercial and industrial pumps. For the subgroup analysis, DOE 

divides users into subgroups, which comprise a subset of the population that is likely, for one 

reason or another, to be affected disproportionately by new or revised energy conservation 

standards (e.g., small businesses or firms that use pumps in particular applications where energy 

savings are likely to be small35). The purpose of a subgroup analysis is to determine the extent of 

this disproportional impact. DOE will work with stakeholders to identify any subgroups for this 

consideration and will conduct a subgroup analysis during the NOPR stage of this rulemaking. 

Item 11-1 DOE welcomes comment on what, if any, user subgroups are appropriate in 

considering standards for pumps. 

12. MANUFACTURER IMPACT ANALYSIS 

DOE intends the MIA to provide an assessment of the potential impacts of energy 

conservation standards on manufacturers of commercial and industrial pumps. A wide range of 

quantitative and qualitative effects may occur following the adoption of a standard that may 

require changes to manufacturing practices. DOE will identify these potential effects through 

interviews with manufacturers and other interested parties.

For the NOPR, DOE will conduct an industry-wide cash-flow analysis using the 

Government Regulatory Impact Model (GRIM), identify and analyze subgroups of 

manufacturers whose businesses vary significantly from the industry as a whole, perform a 

competitive impacts assessment, and review the cumulative regulatory burden for the industry. 

12.1 Sources of Information for the Analysis 

Many of the analyses described earlier provide information that DOE will use as inputs 

for the MIA. Such information includes financial parameters developed in the market assessment 

(section 3.1), cost data developed in the engineering analysis (section 5), and shipments 

projections (section 9). DOE will supplement this information with information gathered during 

manufacturer interviews. 

 

35 These firms differ from any pump manufacturers who may qualify as a small business under the size standards 

established by the Small Business Administration. DOE analyzes impacts to these small businesses, which would 

be directly impacted by any final standards DOE might establish, as required by the Regulatory Flexibility Act (see 

section 12.3). 
88

During the preliminary analysis phase, DOE will conduct interviews with manufacturers 

to gain insight into the range of possible impacts from potential energy conservation standards. 

These interviews will coincide with preliminary technical interviews for the engineering 

analysis. 

During the NOPR phase, DOE will conduct more detailed MIA interviews with 

manufacturers. The interview process plays a key role in the MIA, because it provides an 

opportunity for directly affected parties to express their views on important issues. During the 

interviews, DOE will solicit information on the possible impacts of potential standards on 

manufacturing costs, product prices, sales, direct employment (i.e., employment for the 

manufacturer only), capital assets, and industry competitiveness. Both qualitative and 

quantitative information are valuable in this analysis. DOE prefers an interactive interview 

process because it helps to clarify manufacturer input and provides the opportunity to identify 

additional issues. 

DOE will ask interview participants to identify confidential information, and will protect 

the confidentiality of the information provided as explained in section 5. DOE will also ask 

participants to identify any information they wish to have included in the public record, but do 

not want to have associated with their interviews (thereby identifying that particular 

manufacturer). DOE will incorporate this information into the public record without attribution. 

DOE will collate the interview results and prepare a summary of the major issues and 

outcomes. This summary will become part of the TSD for this rulemaking. 

12.2 Industry Cash Flow Analysis 

The industry cash flow analysis will rely primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of new or amended energy conservation standards on the industry 

that produces the products covered by the standard. 

The GRIM uses a number of factors—annual expected revenues; manufacturer costs such 

as costs of goods sold; selling, general, and administrative (SG&A) costs; research and 

development costs; product conversion costs; taxes; capital expenditures (both ordinary capital 

expenditures and those related to standards); and working capital requirements—to determine 

annual cash flows associated with a new standard, beginning from the announcement of the 

standard and continuing through the analysis period. DOE compares the results against base-case 

projections that involve no new standards. The financial impact of new standards is the 

difference between the two sets of discounted annual cash flows, or the differences between the 

base-case and standards-case industry net present values (INPV). Other performance metrics, 

such as return on invested capital, are also available from the GRIM. 

DOE will gather the inputs needed for the GRIM from two primary sources: (1) the 

analyses conducted to this point; and (2) interviews with manufacturers and other interested 

parties. As discussed, information gathered from previous analyses will include financial 

parameters, manufacturing costs, price forecasts, and shipment projections. Interviews with 

manufacturers and other interested parties will supplement this information. 
89

12.3 Manufacturer Subgroup Analysis 

Average industry cost values may not reveal differential impacts among pump 

manufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a 

cost structure that differs significantly from the industry average may be affected differently by 

standards. Ideally, DOE would consider the impact on every firm individually. In highlyconcentrated industries, this may be possible. In industries having numerous participants, 

however, DOE uses the results of the market and technology assessment to group manufacturers 

into subgroups, as appropriate. For commercial and industrial pumps, DOE is interested in 

feedback about potential subgroups, including small businesses. DOE will conduct a Regulatory 

Flexibility Act analysis to determine the impacts of any standards on small businesses consistent 

with the Regulatory Flexibility Act. The manufacturer subgroup impact analysis will calculate 

cash flows separately for each class of manufacturer. 

Item 12-1 DOE seeks comments on the subgroups of the pumps equipment 

manufacturers that it should consider in a manufacturer subgroup analysis. 

12.4 Competitive Impacts Assessment 

EPCA directs DOE to consider any lessening of competition likely to result from the 

imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General 

to determine in writing the impacts, if any, of any lessening of competition likely to result from 

standards. (42 U.S.C. 6295(o)(2)(B)(ii)) 

DOE will make a determined effort to gather firm-specific financial information and 

impacts and report the aggregated impact of the amended standard on manufacturers. The 

competitive impacts analysis will focus on assessing the impacts on smaller manufacturers. DOE 

will base the assessment on manufacturing cost data and information collected from interviews 

with manufacturers. The manufacturer interviews will focus on gathering information that would 

help in assessing asymmetrical cost increases to some manufacturers, increased proportion of 

fixed costs potentially increasing business risks, and potential barriers to market entry (e.g., 

proprietary technologies). DOE will provide the Attorney General with a copy of the NOPR for 

consideration in his evaluation of the impact of standards on the lessening of competition. DOE 

will publish the Attorney General’s letter and address any related comments in the final rule. 

12.5 Cumulative Regulatory Burden 

Other regulations (Federal, State, local, or international) may apply to manufacturers of 

pumps covered under this rulemaking and to other equipment made by these manufacturers. 

Multiple regulations may result in a significant, cumulative regulatory burden on these 

manufacturers. DOE will consider the impact on these manufacturers of multiple, productspecific regulatory actions. 

Item 12-2 DOE welcomes comments on what other existing regulations or pending 

regulations it should consider in its examination of cumulative regulatory burden. 
90

13. EMISSIONS ANALYSIS 

In the emissions analysis, conducted in the NOPR phase, DOE will estimate the reduction 

in power sector emissions of carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2), 

and mercury (Hg) from potential energy conservation standards for pumps. In addition, DOE 

will estimate emissions impacts in production activities (extracting, processing, and transporting 

fuels) that provide the energy inputs to power plants. These are referred to as “upstream” 

emissions. Together, these emissions account for the FFC. In accordance with DOE’s FFC 

Statement of Policy (76 FR 51281 (Aug. 18, 2011)), the FFC analysis includes impacts on 

emissions of methane (CH4) and nitrous oxide (N2O), both of which are recognized as 

greenhouse gases. 

DOE will conduct the emissions analysis using emissions factors derived from data in 

EIA’s most recent Annual Energy Outlook (AEO), supplemented by data from other sources. 

EIA prepares the AEO using NEMS. Each annual version of NEMS incorporates the projected 

impacts of existing air quality regulations on emissions. The text below refers to AEO 2012. 

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap-and-trade programs. Title IV of the Clean Air Act sets an annual 

emissions cap on SO2 for affected EGUs in the 48 contiguous States and the District of Columbia 

(D.C.). SO2 emissions from 28 eastern States and D.C. were also limited under the Clean Air 

Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), which created an allowance-based trading 

program that operates along with the Title IV program. CAIR was remanded to the U.S. 

Environmental Protection Agency (EPA) by the U.S. Court of Appeals for the District of 

Columbia Circuit, but it remained in effect. See North Carolina v. EPA, 550 F.3d 1176 (D.C. 

Cir. 2008); North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2011, EPA issued 

a replacement for CAIR, the Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 

2011). The AEO 2012 emissions factors assume the implementation of the CSAPR.36

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an efficiency standard could be used to permit offsetting increases in SO2 emissions 

by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about 

the effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, but it concluded that negligible reductions in power sector SO2 emissions would occur as 

a result of standards. 

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 

 

36

 On December 30, 2011, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and told EPA 

to continue administering CAIR. See EME Homer City Generation, LP v. EPA, Order, No. 11-1302, Slip Op. at *2 

(D.C. Cir. Dec. 30, 2011). On August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME 

Homer City Generation, LP v. EPA, No. 11-1302, 2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 2012). The court 

again ordered EPA to continue administering CAIR. AEO 2012 had been finalized prior to both these decisions, 

however. DOE understands that CAIR and CSAPR are similar with respect to their effect on emissions impacts of 

energy efficiency standards. 
91

2011. 77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA established a standard for 

hydrochloric acid (HCl) as a surrogate for acid gas hazardous air pollutants (HAP), and also 

established a standard for SO2 (a non-HAP acid gas) as an alternative equivalent surrogate 

standard for acid gas HAP. The same controls are used to reduce HAP and non-HAP acid gas; 

thus, SO2 emissions will be reduced as a result of the control technologies installed on coal-fired 

power plants to comply with the MATS requirements for acid gas. AEO 2012 assumes that, in 

order to continue operating, coal plants must have either flue gas desulfurization or dry sorbent 

injection systems installed by 2015. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, NEMS shows a reduction in SO2

emissions when electricity demand decreases (e.g., as a result of energy efficiency standards). 

Emissions will be far below the cap that would be established by CSAPR, so it is unlikely that 

excess SO2 emissions allowances resulting from the lower electricity demand would be needed 

or used to permit offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE 

believes that efficiency standards will reduce SO2 emissions in 2015 and beyond. 

CSAPR established a cap on NOX emissions in the 28 eastern States and the District of 

Columbia. Energy conservation standards are expected to have little or no effect on NOX

emissions in those States covered by CSAPR because excess NOx emissions allowances resulting 

from the lower electricity demand could be used to permit offsetting increases in NOx emissions. 

However, standards would be expected to reduce NOx emissions in the States not affected by 

CSAPR, so DOE estimates NOX emissions reductions from potential standards for these States. 

The MATS limit mercury emissions from power plants, but they do not include emissions 

caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. 

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOx. The monetary benefits that DOE estimates for 

reductions in SO2 and NOx emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM. 

Item 13-1 DOE seeks input on its approach to conducting the emissions analysis for 

commercial and industrial pumps. 

14. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS 

 DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered.
92

 In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2, DOE plans to use the most current social cost of carbon (SCC) values developed or agreed 

to by an interagency process. The SCC is intended to be a monetary measure of the incremental 

damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, net 

agricultural productivity loss, human health effects, property damage from sea level rise, and 

changes in ecosystem services. Any effort to quantify and to monetize the harms associated with 

climate change will raise serious questions of science, economics, and ethics. But with full 

regard for the limits of both quantification and monetization, the SCC can be used to provide 

estimates of the social benefits of reductions in GHG emissions. 

 At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2015, expressed in 2011$, were $6.1, $25.4, 

$41.0, and $77.7 per metric ton avoided. For emissions reductions that occur in later years, these 

values grow in real terms over time. Additionally, the interagency group determined that a range 

of values from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although DOE will give preference to consideration of the global benefits of 

reducing CO2 emissions. To calculate a present value of the stream of monetary values, DOE 

will discount the values in each of the four cases using the discount rates used to obtain the SCC 

values in each case. 

 DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

 DOE also intends to estimate the potential monetary benefit of reduced NOX emissions 

resulting from the standard levels it considers. For NOX emissions, available estimates suggest a 

very wide range of monetary values for NOX emissions, ranging from $460 to $4,722 per ton in 

2011$.37 In accordance with OMB guidance, DOE will conduct two calculations of the monetary 

benefits derived using each of the economic values used for NOX, using real discount rates of 3 

percent and 7 percent.38

DOE is investigating appropriate valuation of Hg emissions. Whether monetization of 

reduced Hg emissions will occur in this rulemaking is not yet certain. 

Item 14-1 DOE requests comments on the approach it plans to use for estimating 

monetary values associated with emissions reductions. 

15. UTILITY IMPACT ANALYSIS 

In the utility impact analysis, DOE analyzes the changes in electric installed capacity and 

generation that result for each trial standard level. The utility impact analysis uses a variant of 

 

37 For additional information, refer to the U.S. Office of Management and Budget, Office of Information and 

Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded 

Mandates on State, Local, and Tribal Entities, Washington, DC. 

38 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
93

EIA’s NEMS39, which is a public domain, multi-sectored, partial equilibrium model of the U.S. 

energy sector. Each year, DOE/EIA uses NEMS to produce an energy forecast for the United 

States, the Annual Energy Outlook. DOE uses a variant of this model, referred to as NEMSBT40

, to account for selected utility impacts of new or amended energy conservation standards. 

DOE’s analysis consists of a comparison between model results for the most recent AEO

Reference Case and for cases in which energy use is decremented to reflect the impact of 

potential standards. For the analysis of standards on commercial and industrial pumps, DOE will 

use the version of NEMS used for the most recent AEO.

Item 15-1 DOE welcomes input from interested parties on its proposed approach to 

conduct the utility impact analysis.

16. EMPLOYMENT IMPACT ANALYSIS 

The employment impact analysis examines indirect employment impacts from standards, 

which consist of the net jobs created or eliminated in the national economy, other than in the 

manufacturing sector being regulated, caused by: (1) reduced spending by end users on energy; 

(2) reduced spending on new energy supply by the utility industry; (3) increased spending on 

new equipment to which the new standards apply; and (4) the effects of those three factors 

throughout the economy. (Direct employment impacts are any changes in the number of 

employees of manufacturers of the equipment subject to standards; the MIA will address these 

impacts.) 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare sector employment statistics developed by the Labor 

Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of the 

number of jobs per million dollars of economic activity in different sectors of the economy, as 

well as the jobs created elsewhere in the economy by this same economic activity. Data from 

BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and 

indirectly) than expenditures in other sectors of the economy.41 There are many reasons for these 

differences, including wage differences and the fact that the utility sector is more capitalintensive and less labor-intensive than other sectors. Energy conservation standards have the 

effect of reducing consumer utility bills. Because reduced consumer expenditures for energy 

likely lead to increased expenditures in other sectors of the economy, the general effect of 

efficiency standards is to shift economic activity from a less labor-intensive sector (i.e., the 

utility sector) to more labor-intensive sectors (e.g., the retail and service sectors). 

 

 

39 For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration 

documentation. A useful summary is National Energy Modeling System: An Overview 2003, DOE/EIA-0581(2003), 

(March 2003). 

40 DOE/EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is run 

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it by the name NEMSBT. (BT is DOE’s Building Technologies Program, under whose aegis this work has been performed) 

41 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input-Output 

Modeling System (RIMS II). Washington, DC. U.S. Department of Commerce, 1992. 
94

In the NOPR stage of this rulemaking, DOE plans to estimate indirect national 

employment impacts using an input/output model of the U.S. economy called Impact of Sector 

Energy Technologies version 3.1.1 (ImSET).42 ImSET is a special-purpose version of the “U.S. 

Benchmark National Input-Output” (I–O) model, which was designed to estimate the national 

employment and income effects of energy-saving technologies. The ImSET software includes a 

computer-based I–O model having structural coefficients that characterize economic flows 

among 187 sectors most relevant to industrial, commercial, and residential building energy use. 

DOE notes that ImSET is not a general equilibrium forecasting model and understands 

the uncertainties involved in projecting employment impacts, especially changes in the later 

years of the analysis. Because ImSET does not incorporate price changes, the employment 

effects predicted by ImSET may over-estimate actual job impacts over the long run. DOE may 

consider the use of other modeling approaches for examining long-run employment impacts. 

Item 16-1 DOE welcomes feedback on its proposed approach to assessing national 

employment impacts. 

17. REGULATORY IMPACT ANALYSIS 

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis that 

will address the potential for non-regulatory approaches to supplant or augment energy 

conservation standards to improve the efficiency of pumps on the market. DOE recognizes that 

voluntary or other non-regulatory efforts by manufacturers, utilities, and other interested parties 

can result in substantial efficiency improvements. DOE intends to analyze the likely effects of 

non-regulatory initiatives and compare those effects with those projected to result from 

standards. DOE will attempt to base its assessment on the actual impacts of any such initiatives 

to date, but will also consider information presented regarding the impacts that any existing 

initiative might have in the future. 

If DOE proposes energy conservation standards for pumps and the NOPR constitutes a 

significant regulatory action, DOE would prepare and submit to OMB for review the assessment 

of costs and benefits required under section 6(a)(3) of Executive Order 12866, “Regulatory 

Planning and Review,” 58 FR 51735 (October 4, 1993). 

 

42 J. M. Roop, M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies, PNNL-18412, 

Pacific Northwest National Laboratory, 2009. Available at: 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf 
95

APPENDIX A - LIST OF ITEMS FOR COMMENT 

Item 1-1 DOE seeks comment on its proposal to cover only clean water pumps in this 

rulemaking. ............................................................................................................................ 3

Item 1-2 DOE requests comment on whether it should rely on a definition of ‘clean water’ to 

determine coverage of pumps, as in the EU, or if, instead, the definition of ‘clean water 

pumps’ should include physical characteristics that distinguish pumps designed for clean 

water or exclude pumps designed for other purposes. ........................................................... 4

Item 1-3 DOE seeks comment on the list of physical differences that may exist between pumps 

designed for clean water and pumps designed for other substances. Specifically, (1) is the 

list accurate and exhaustive, (2) do the differences impact efficiency, and (3) do the 

differences have increased cost? ............................................................................................ 4

Item 1-4 DOE seeks comment on whether it should consider standards for pumps designed for 

non-water liquids that contain limited solids in this rulemaking. DOE is specifically 

interested in ANSI chemical process pumps, API 610 pumps, sealless (magnetic drive, 

canned, or cantilever) pumps, sanitary pumps, refrigerant pumps, and general industrial 

pumps. When suggesting pump types for which standards should not be considered, please 

be specific as to the reason why. ............................................................................................ 4

Item 1-5 DOE requests comment on whether any design changes made to standard clean water 

pumps would carry through to pumps designed for other applications. ................................ 4

Item 1-6 DOE seeks comment on its proposal to consider standards for rotodynamic pumps 

and not positive displacement pumps. In particular, DOE requests comment on the extent 

of the overlap between rotodynamic and positive displacement pumps and whether there 

are certain categories of rotodynamic pumps (pump types and ranges of flow and specific 

speed) for which positive displacement pumps could be a direct replacement. .................... 4

Item 1-7 DOE seeks comment on its proposal to consider standards for pumps not covered in 

the EU. ................................................................................................................................... 5

Item 1-8 DOE seeks comment on its development of pump equipment categories and whether 

these categories provide an appropriate basis for developing equipment classes. (See 

section 3.2.) ............................................................................................................................ 6

Item 1-9 DOE seeks comment on whether standards for any additional pump categories should 

be considered. In particular, DOE is interested in pump categories that may have significant 

potential for energy savings. .................................................................................................. 6

Item 1-10 DOE seeks comment on the pump types as described by ANSI/HI nomenclature 

that fall into the equipment categories set forth in Table 1.1. For example, pump type OH1 

would be classified as an end suction frame mounted pump. For ANSI/HI pump types that 

would not fall into the categories in Table 1.1, please provide a specific reason, such as 

“solids-handling only.” .......................................................................................................... 6

Item 1-11 DOE seeks comment on whether wet-running circulator-type pumps should be 

covered in this rulemaking. .................................................................................................... 6

Item 1-12 DOE seeks comment on the market size for wet-running circulators in the United 

States, including the split between commercial and residential applications in terms of 

physical size or other features, as well as the potential for growth of the market for 

circulators in commercial applications. ................................................................................. 6

Item 1-13 DOE requests comment on which parameters, if any, should be added to this 

rulemaking. For each parameter proposed, please include the rationale and the type of 
96

pump that the parameter is designed to exclude from standards. Comments may address 

those translated from the EU or those proposed by stakeholders, but do not have to be 

limited to those proposals. DOE especially seeks comments on parameters that should be 

added to exclude pumps used primarily in residential applications. DOE also seeks 

comment on whether, if using power as a coverage parameter, hydraulic power would be 

more appropriate than shaft power. ....................................................................................... 9

Item 1-14 DOE requests comments on the estimates of pumps that would be excluded based 

on the stakeholders’ proposed parameters. ............................................................................ 9

Item 1-15 DOE requests comment on the technical features and applications for fire-fighting 

pumps and self-priming pumps that would allow it to determine whether these pumps 

should be covered. ................................................................................................................. 9

Item 1-16 DOE requests data on how pumps are sold by pump manufacturers. Specifically 

DOE requests data on market share of pumps 1) sold by themselves, 2) sold attached to or 

integrated with motors only, 3) sold attached to or integrated with both motors and VSDs, 

4) sold physically separate from but priced together with a motor only, or 5) sold physically 

separate from but priced together with both a motor and VSD. DOE seeks these data by 

size, equipment category (see section 3.2), and application. ............................................... 10

Item 1-17 DOE requests data and information on whether pumps are more often combined 

with motors, VSDs, or both by the pump manufacturer or by distributors. ........................ 10

Item 1-18 DOE requests information on how often and in what circumstances the intended 

application of the pump is known when the pump is sold. .................................................. 10

Item 1-19 DOE understands that VSDs are not very effective without system feedback. DOE 

seeks comment on the need for considering feedback in any extended product-type 

definition for pumps. ............................................................................................................ 11

Item 1-20 DOE requests comment on the benefits and drawbacks of the options presented 

above. For options 2 and 3, DOE seeks comment on whether these options could increase 

the beneficial use of VSDs in the field, and whether these options could result in the use of 

a VSD in an application for which it is not suited. .............................................................. 12

Item 1-21 DOE seeks comment on the market share of pumps by category that would be used 

in applications that would benefit from VSDs, as well as those where use of a VSD could 

result in increased energy use. ............................................................................................. 12

Item 1-22 DOE seeks comment on the market share and applications of pumps by category 

driven by equipment other than an electric motor. .............................................................. 12

Item 1-23 DOE requests comment on the suggested definitions for pumps. .......................... 13

Item 1-24 DOE requests input on whether the definitions proposed by DOE are sufficient to 

allow manufacturers to determine whether their pumps are covered, and in which pump 

category their equipment falls. ............................................................................................. 13

Item 1-25 DOE requests comment on what minimum specific speed should define the 

axial/propeller and mixed flow water pump. ....................................................................... 13

Item 1-26 DOE requests comment on the definition of ‘clean water’. DOE specifically 

requests input on the translation of wording and units to those typically used in the United 

States, such as parts per million limits for suspended and dissolved solids. DOE also seeks 

comment on the appropriateness of the proposed limits. DOE requests clarification on 

whether mixtures including water with freezing points above -10°C should be considered 

clean water for the purposes of this definition and rulemaking. .......................................... 14
97

Item 1-27 DOE requests comment on whether maximum solids diameter, which is a 

parameter provided with many pump curves, could be used in the definition of ‘clean 

water’. 14

Item 1-28 DOE requests comment on its proposal to follow the EU approach using pump 

efficiency if pumps are defined without the motor or controls. DOE is especially interested 

in whether a pump should have to meet a standard at multiple load points, or if a weighted 

average metric should be developed. ................................................................................... 18

Item 1-29 DOE requests comment on the selection of 75% BEP flow as the part-load point 

and 110% as the overload point and whether these are the most appropriate points to 

encourage broad pump efficiency curves. ........................................................................... 18

Item 1-30 DOE requests comment on whether the use of an overall efficiency metric for 

submersible pumps would cause problems for manufacturers, as the EU metric is pump 

efficiency.............................................................................................................................. 18

Item 1-31 DOE requests comment on whether the metric for vertically suspended pumps 

should be bowl efficiency rather than pump efficiency. ...................................................... 19

Item 1-32 DOE requests comment on its proposal to adapt the EU standard metric to overall 

efficiency for pumps sold with both motors and VSDs. DOE is also interested in whether 

additional test points should be added below 75% of BEP flow to address more of the 

operating range of pumps with VSDs. ................................................................................. 19

Item 1-33 DOE requests comment on the appropriate metric to capture the energy efficiency 

impacts of VSDs. DOE is interested in whether test points at BEP, 75% BEP flow, and 

110% BEP flow are appropriate for this metric and whether additional test points should be 

added below 75% BEP flow to address more of the operating range of pumps with VSDs. 

DOE is also interested in whether pumps should be required to meet minimum levels at 

multiple points or if a weighted average metric should be developed. ................................ 22

Item 1-34 DOE requests comment on whether the metric for regulatory option 2 and 3 should 

include an overload test point based on overspeeding. ........................................................ 23

Item 1-35 DOE recognizes that the same pump may in some cases be sold alone or may be 

sold in conjunction with a motor or motor/control package. DOE seeks comment on any 

issues that may result from having different metrics for pumps sold alone and pumps sold 

with motors or VSDs. .......................................................................................................... 24

Item 1-36 DOE seeks comment regarding the implementation methodology described in this 

section, including whether basing efficiency on flow and specific speed is appropriate and, 

if so, whether the EU surface should be used as is, with adjusted Cs, or with modified 

shapes (adjustment of all coefficients). The last option would allow type- and efficiency 

level-specific surfaces. DOE also seeks comment on whether other parameters or 

combinations of parameters would be more appropriate or easier to implement, such as 

flow and head (instead of specific speed). ........................................................................... 29

Item 1-37 DOE requests data that would help it improve its database, specifically 

performance data (i.e., head, flow, power, and efficiency at BEP and multiple additional 

points) for clean water pumps from catalogs not available on PUMP-FLO. ....................... 29

Item 1-38 DOE seeks comment on how to calculate specific speed (with regard to flow) for 

double suction axial split pumps and axially split multi-stage pumps with a double-suction 

first stage (i.e., whether to use total flow ore one-half the flow). ........................................ 29

Item 1-39 DOE seeks test data for pumps at 75% and 110% BEP flow points that would 

allow it to better analyze potential efficiency levels for these points. ................................. 30
98

Item 1-40 DOE requests comment on the appropriateness of setting a standard based on a full 

impeller. ............................................................................................................................... 31

Item 1-41 DOE requests comment on standards based on certain numbers of stages for 

radially split multi-stage and submersible pumps. DOE also seeks comment on whether the 

same approach could be taken for axially split multi-stage pumps. .................................... 31

Item 1-42 DOE requests data on the percent of pumps sold with a full impeller, as well as the 

distribution of pump sales with reduced impellers (as a percentage of full impeller). ........ 31

Item 1-43 DOE requests comment on the use of the ANSI/HI 14.6-2011, ANSI/HI 11.6-2012, 

, ISO 9906-2012, and ISO 5198-1999 test procedures, as well as any other test procedures, 

as a basis for the development of a DOE test procedure, including any modifications or 

additions that may be necessary. .......................................................................................... 34

Item 1-44 DOE requests comment on the scope of each test procedure with respect to the 

equipment for which DOE is considering standards, as well as any limitations of these test 

procedures. ........................................................................................................................... 34

Item 1-45 DOE is also interested in the pros and cons of using a thermodynamic approach to 

determining pump or pumping system efficiency, as in ISO 5198-1999. ........................... 34

Item 1-46 DOE requests comment on use of “Grade 1” from ANSI/HI 14.6-2011 tolerances 

for all pump categories and whether it places any additional burden associated with 

performing testing requirements for all covered equipment classes. ................................... 35

Item 1-47 DOE requests comment on the applicable test procedures for complete pump, 

motor, and VSD system packages. ...................................................................................... 35

Item 1-48 DOE requests comment on the accuracy of different measurement equipment used 

to measure pump power, input power to a motor or VSD, pump flow, head, or other 

parameters and their impact on the accuracy of the measured pump efficiency. DOE also 

requests comment on the calibration frequency required to maintain sufficient equipment 

accuracy. .............................................................................................................................. 35

Item 1-49 DOE requests comment on the applicability of calculation methods to determine 

rated pump efficiencies from similar, tested pump efficiencies. ......................................... 35

DOE requests comment on the number of unique pump models manufacturers would have 

to test, as well as the ability for a calculation method to reduce testing burden. DOE also 

requests comment on the reduction in test accuracy when using a calculation method to 

determine rated efficiency of a unit. .................................................................................... 35

Item 1-50 .................................................................................. Error! Bookmark not defined.

Item 1-51 DOE seeks comment on whether a labeling rule would be technologically or 

economically feasible, result in a significant conservation of energy, or assist customers in 

making purchasing decisions. .............................................................................................. 39

Item 1-52 DOE seeks comment on information that it should consider requiring for display on 

any prospective label, as well as factors DOE should consider regarding the size, format, 

and placement of any such label. ......................................................................................... 39

Item 3-1 DOE requests information that would contribute to the market assessment for the 

pumps that would be covered in this rulemaking, especially for those equipment classes 

designated in section 3.2. Examples of information sought include current equipment 

features and efficiencies, equipment feature and efficiency trends, and historical equipment 

shipments and prices. ........................................................................................................... 42

Item 3-2 DOE requests input on its identification of product codes in the U.S. Census data that 

match the equipment classes proposed for coverage in this rulemaking. ............................ 45
99

Item 3-3 DOE requests feedback on its estimates of the disaggregation of pump exports and 

imports to product codes, its estimates of the percentage of shipments of clean water 

pumps, and its estimates of the percent of shipments sold with motors by the pump 

manufacturer. ....................................................................................................................... 45

Item 3-4 DOE welcomes comments on which performance-related features or design 

characteristics DOE should consider to define pump equipment classes. ........................... 52

Item 3-5 DOE requests information regarding the utility of different pump categories proposed 

for coverage that would warrant separate equipment classes. For example, could end 

suction pumps be a single equipment class, or are the breakdowns shown necessary to 

preserve equipment utility that would affect performance? Could axially and radially split 

multi-stage pumps be a single equipment class? Could all vertical turbine pumps (both 

submersible and non-submersible) be a single equipment class? ........................................ 53

Item 3-6 DOE requests information on whether any of the equipment proposed for coverage 

provides utility that requires further breakdown from the categories shown in Table 3.8. For 

example, do multi-stage pumps with a double suction first stage require a separate 

equipment class? Do vertical turbine can pumps require a separate equipment class from 

vertical turbine lineshaft pumps? ......................................................................................... 53

Item 3-7 DOE requests comment on whether equipment classes can be developed for pump 

categories that would always be used in variable load applications. ................................... 53

Item 3-8 DOE requests comment on whether it should consider using Reynolds number 

instead of flow in setting minimum efficiency standards for pumps and whether this choice 

would prevent adding design speed as an additional parameter. DOE notes that there are 

multiple methods of calculating Reynolds number for pumps and that all calculations do 

not produce the same relative results. As a result, DOE seeks comment on the most 

appropriate form of Reynolds number for pumps................................................................ 56

Item 3-9 DOE requests comment on which method of surface fitting produces the most 

appropriate results for both cases: (1) a smaller pump at higher speed compared to a larger 

pump at lower speed; and (2) identical pumps running at two different speeds. DOE 

requests comment on whether these relationships are expected to differ by equipment class.

 60

Item 3-10 DOE requests comment on the use of pump design speed as a feature that 

distinguishes equipment classes. In particular, DOE seeks comment on whether pumps 

designed for different rotating speeds perform differently enough to warrant separate 

equipment classes. DOE also requests comment on any physical differences between pump 

models offered at different speeds and the nature of those differences, including whether 

DOE could determine by physical inspection at what speeds a pump can safely operate... 61

Item 3-11 DOE requests comment on the testing and compliance burden on manufacturers 

under the approaches set forth above. .................................................................................. 61

Item 3-12 DOE requests comment on whether it could require all pumps in a given equipment 

class to be tested at (a) certain speed(s) and, if so, which speed(s) is (are) most appropriate.

 61

Item 3-13 DOE requests comment on how manufacturers in the EU are determining the 

minimum efficiency required for a pump offered at multiple speeds. ................................. 61

Item 3-14 DOE welcomes comment on the technology options identified in this section, 

including further details on methods (such as lists of specific methods for each listed broad 

option) and potential efficiency gains, as well as information on whether the method in 
100

question is applicable to all pumps in a given equipment class or only pumps with certain 

design characteristics). DOE also welcomes comment on whether there are other 

technology options that it should also consider. .................................................................. 65

Item 3-15 DOE welcomes comment on the relevance of the technology options identified to 

pumps sold with smaller impellers than the full impeller on which DOE is tentatively 

proposing to base a standard. In particular, would these design options be carried through 

to pumps with all impeller sizes? ......................................................................................... 65

Item 3-16 DOE requests information related to various impeller types used in clean water 

pump designs and the efficiency impacts of each type. ....................................................... 65

Item 4-1 Are there any technologies listed in section 3.3 (or others not proposed) that DOE 

should not consider because of any of the four screening criteria? If so, which screening 

criteria apply to the cited technology or technologies? ....................................................... 66

Item 5-1 DOE seeks input on the methods and approaches used by manufacturers to improve 

the efficiency of pumps and, in particular, how frequently hydraulic re-design would be the 

only method employed. ........................................................................................................ 67

Item 5-2 DOE welcomes comment from interested parties on the best methodology for scaling 

cost-efficiency curve results from the representative units to the representative equipment 

classes and extrapolating from the representative equipment classes to the remaining 

equipment classes not directly analyzed. ............................................................................. 67

Item 5-3 DOE seeks comment on its selection of representative classes: which classes could be 

grouped together for this analysis, and which class should be tested. ................................. 67

Item 5-4 DOE welcomes comment on the selection of representative units in terms of 

appropriate flow and specific speed ratings within each equipment class. .......................... 68

Item 5-5 DOE seeks comment on the selection and performance characteristics of baseline 

models for each equipment class. DOE will consider such comments in defining the 

characteristics of the proposed baseline models. ................................................................. 69

Item 5-6 DOE seeks input from stakeholders regarding the range of efficiency levels that 

should be examined as part of its analysis. .......................................................................... 71

Item 5-7 DOE seeks input from interested parties on a methodology that would be appropriate 

for determining the max-tech models for each pump analyzed. .......................................... 71

Item 5-8 For each equipment class, DOE welcomes comments on methods and approaches that 

DOE intends to employ to determine potential efficiency improvements for pumps. 

Detailed information on the pump performance and the incremental manufacturing costs 

(e.g., material costs, labor costs, overhead costs, building conversion capital expenditures, 

capital expenditures for tooling or equipment conversion associated with more efficient 

designs, R&D expenses, and marketing expenses) would be useful. .................................. 73

Item 5-9 DOE welcomes comment on the markup approach proposed for developing estimates 

of manufacturer selling prices. ............................................................................................. 73

Item 5-10 DOE welcomes comment on the approach to determining the relationship between 

manufacturer selling price and pump efficiency. ................................................................. 73

Item 5-11 DOE welcomes comment on the conversion costs required to improve the 

efficiency of the pumps to various levels, as well as what portion of these costs would be 

passed on to the consumer. .................................................................................................. 73

Item 5-12 DOE welcomes comment on whether there are outside regulatory changes that 

DOE should consider in its engineering analysis of pumps. ............................................... 74

Item 6-1 DOE requests information on the distribution channels under consideration. ........... 75
101

Item 6-2 DOE requests comments and additional information on the appropriate way to 

establish distribution channel percentages across equipment classes and application 

(market) segments for the current rulemaking. In particular, DOE seeks information on the 

percentage by market segment (i.e., agriculture, municipal, commercial, industrial, and 

other markets) of direct sales, OEM sales, wholesaler to customer sales, wholesaler to 

contractor sales, and other sales. DOE seeks this information over the total market. ........ 75

Item 6-3 DOE seeks comment on other sources of relevant data that could be used to 

characterize markups for commercial and industrial pumps. .............................................. 76

Item 6-4 DOE requests feedback on its proposal to use incremental distribution channel 

markups. ............................................................................................................................... 76

Item 6-5 DOE seeks comment on appropriate transportation and shipping costs to include in 

the analysis and whether those costs are likely to vary for higher efficiency commercial and 

industrial pumps. .................................................................................................................. 76

Item 7-1 DOE requests input and recommendations for identifying high sales volume and large 

installed base application segments corresponding to specific applications for which the 

pumps used may have similar duty profiles. ........................................................................ 77

Item 7-2 DOE welcomes recommendations on sources of data or analysis methods that would 

provide end-use duty profiles for each of the equipment classes of pumps covered under 

this rulemaking in the major application segments.............................................................. 77

Item 7-3 DOE requests input on ways to characterize pump sizing and selection practices for 

different equipment classes and applications. ...................................................................... 77

Item 7-4 DOE requests comment on the degree of oversizing prevalent in different application 

segments. .............................................................................................................................. 78

Item 7-5 DOE welcomes comment on methods for determining nominal (non-market segment 

specific) duty profiles for pump equipment classes considered in this rulemaking. ........... 78

Item 7-6 DOE welcomes comment on the current penetration level of VSDs in the installed 

base of equipment in each application segment for each of the equipment classes 

considered in this rulemaking. DOE also welcomes comment on the baseline condition for 

applications without VSDs, such as running at full load, use of a throttling valve, etc. ..... 78

Item 7-7 DOE requests comment and recommendation on the range and number of sizes over 

which the analysis should be carried out for each specific speed in different classes of 

equipment. ............................................................................................................................ 79

Item 7-8 DOE requests information on current industry practices and recommendations on the 

selection of representative operating points for a given specific speed. DOE welcomes 

comment on whether the analysis should be extended to a range of operating points away 

from BEP. ............................................................................................................................ 79

Item 7-9 DOE requests comment and estimates to establish the mean value and the ranges of 

likely values for transmission, motor, and motor control efficiencies, as well as the impact 

of a control on motor performance and efficiency............................................................... 79

Item 8-1 DOE welcomes comment on whether installation costs for pumps increase with 

higher efficiency equipment. ............................................................................................... 81

Item 8-2 DOE welcomes input on the proposed methodology for estimating current and future 

electricity prices. .................................................................................................................. 81

Item 8-3 DOE invites comment on how repair costs may change for more efficient pumps. .. 82
102

Item 8-4 DOE welcomes comment on appropriate pump lifetimes for the equipment classes 

covered in this rulemaking, as well as data regarding correlation between pump end-use 

patterns and pump lifetime................................................................................................... 84

Item 8-5 DOE requests data on the degradation of pump efficiency over a pump’s lifetime. .. 84

Item 8-6 DOE welcomes input on the proposed approaches for estimating discount rates for 

pump customers. .................................................................................................................. 84

Item 9-1 DOE welcomes comment on the shipments projection methodology. DOE invites 

comments regarding the selection of appropriate economic drivers and sources of data for 

historical shipments and shipment breakdowns by equipment class. .................................. 85

Item 9-2 DOE requests historical shipments or bookings data for each of the considered 

equipment classes, with further breakdowns where available including, but not limited to, 

flow, head, specific speed, horsepower, or efficiency. ........................................................ 85

Item 9-3 DOE welcomes comment on how any standard for pumps might impact shipments of 

the equipment in this rulemaking. ........................................................................................ 85

Item 11-1 DOE welcomes comment on what, if any, user subgroups are appropriate in 

considering standards for pumps. ........................................................................................ 87

Item 12-1 DOE seeks comments on the subgroups of the pumps equipment manufacturers 

that it should consider in a manufacturer subgroup analysis. .............................................. 89

Item 12-2 DOE welcomes comments on what other existing regulations or pending 

regulations it should consider in its examination of cumulative regulatory burden. ........... 89

Item 13-1 DOE seeks input on its approach to conducting the emissions analysis for 

commercial and industrial pumps. ....................................................................................... 91

Item 14-1 DOE requests comments on the approach it plans to use for estimating monetary 

values associated with emissions reductions. ...................................................................... 92

Item 15-1 DOE welcomes input from interested parties on its proposed approach to conduct 

the utility impact analysis. ................................................................................................... 93

Item 16-1 DOE welcomes feedback on its proposed approach to assessing national 

employment impacts. ........................................................................................................... 94
103

APPENDIX B - COMPARISON OF THE U.S. PUMP MARKET TO THE EU PUMP 

MARKET 

In an effort to determine whether the specifics of the European Union (EU) water pumps 

regulation have a bearing on the U.S. market, DOE looked at the EU minimum efficiency 

indexes (MEIs) for End-Suction Closed Coupled (ESCC), End-Suction Frame Mounted (ESFM), 

and Vertical Inline (IL) pumps and determined what percent of pumps in its database would be 

cut off by those MEIs. 

The EU MEI is related to the C value in the following efficiency formula: 

ηBEP = -0.85 (lnQ)

2

-0.38 (lnQ · lnNs) -11.48 (lnNs)

2

+ 13.46 lnQ + 88.59 lnNs – C 

Where: 

Q is flow (m3h

-1), and 

Ns is specific speed (min-1). 

The C values vary for every equipment class and MEI (ranging from 5% to 80%). 

DOE used the five to six points of pump efficiency data provided by PUMP-FLO to 

interpolate efficiency at 75% of BEP (Best Efficiency Point) flow and 110% of BEP flow. 

Efficiency at BEP was provided for all pumps. DOE then compared these efficiency values to 

those calculated using the EU equation (accounting for different units) for all MEIs to determine 

whether a given pump would pass or fail each MEI. DOE then calculated the percent of all 

pumps for a given pump type that would be cut-off for each MEI. DOE performed these 

calculations for BEP only, 75% of BEP flow only, 110% of BEP flow only, and the combination 

of all three points (where a failure at any one point meant that pump would be cut-off by that 

MEI). These results are summarized in the sections B1 through B3 for three pump types. 

B1. End-Suction Closed Coupled (ESCC) pumps 

The C values for 2-pole and 4-pole ESCC pumps are listed in Table B.1. Figure B.1

compares the ESCC pumps in the U.S. market to various EU MEI standards. 

Table B.1 EU Values of C for ESCC Pumps 

Quantity cut-off

C 5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

ESCC 4 poles 134.39 132.74 132.07 131.2 129.77 128.46 127.38 126.57 125.46 124.07

ESCC 2 poles 137.32 135.93 134.86 133.82 132.23 130.77 129.86 128.8 127.75 126.54

 
104

(a)

(b)

(c)

13% 16% 20% 24%

31%

40%

46%

54%

64%

72%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP flow

US 2 poles

US 4 poles

EU

6% 6% 7% 8% 11% 15% 18%

22%

29%

36%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 75% BEP flow

US 2 poles

US 4 poles

EU

18%

23% 27% 30%

40%

52%

60%

69%

75%

82%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 110% BEP flow

US 2 poles

US 4 poles

EU
105

(d)

Note: U.S. percentages shown for 2 pole pumps only. 

Figure B.1 Comparison of EU MEIs to US Market for ESCC Pumps 

(a) based on best efficiency point (BEP) only, (b) based on the efficiency at 75% of the BEP 

flow only, (c) based on the efficiency at 110% of the BEP flow only, and (d) based on the 

efficiency of BEP, 75% of BEP flow, and 110% of BEP flow 

B2. End-Suction Frame Mounted (ESFM) pumps 

The C values for 2-pole and 4-pole ESFM pumps are listed in Table B.2. Figure B.2

compares the ESFM pumps in the U.S. market to various EU MEI standards. 

Table B.2 EU Values of C for ESFM Pumps 

Quantity cut-off

C 5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

ESFM 4 poles 134.38 132.58 131.70 130.68 129.35 128.07 126.97 126.10 124.85 122.94

ESFM 2 poles 137.28 135.60 134.54 133.43 131.61 130.27 129.18 128.12 127.06 125.34

18%

23% 27% 31%

40%

53%

61%

70%

76%

83%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP, 75% BEP flow, 110% BEP flow

US 2 poles

US 4 poles

EU
106

(a) 

(b) 

(c) 

8% 12% 15% 19%

29%

39%

49%

60%

69%

80%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP flow

US 2 poles

US 4 poles

EU

4% 4% 5% 7% 9% 12%

16%

22%

28%

38%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 75% BEP flow

US 2 poles

US 4 poles

EU

13%

19% 24%

31%

44%

55%

67%

74%

81%

90%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 110% BEP flow

US 2 poles

US 4 poles

EU
107

(d) 

Note: U.S. percentages shown for 2-pole pumps only. 

Figure B.2 Comparison of EU MEIs to US Market for ESFM Pumps 

(a) based on BEP only, (b) based on the efficiency at 75% of the BEP flow only, (c) based 

on the efficiency at 110% of the BEP flow only, and (d) based on the efficiency of BEP, 

75% of BEP flow, and 110% of BEP flow 

B3. Vertical Inline (IL) pumps 

The C values for 2-pole and 4-pole IL pumps are listed in Table B.3. Figure B.3

compares the IL pumps in the U.S. market to various EU MEI standards. 

Table B.3 EU Values of C for IL Pumps 

Quantity cut-off

C 5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

ESFM 4 poles 138.13 136.67 135.40 134.60 133.44 132.30 131.00 130.32 128.98 127.30

ESFM 2 poles 141.71 139.45 137.73 136.53 134.91 133.69 132.65 131.34 129.83 128.14

13%

19% 24%

31%

44%

55%

67%

75%

82%

90%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP, 75% BEP flow, 110% BEP flow

US 2 poles

US 4 poles

EU
108

(a) 

(b) 

(c) 

1% 4%

11% 15%

23%

32%

37%

44%

60%

72%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP flow

US 2 poles

US 4 poles

EU

1% 1% 1% 1% 3% 6% 9%

15%

24%

32%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 75% BEP flow

US 2 poles

US 4 poles

EU

3%

12%

19%

27%

34%

42%

48%

58%

71%

83%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ 110% BEP flow

US 2 poles

US 4 poles

EU
109

(d) 

Note: U.S. percentages shown for 2 pole pumps only. 

Figure B.3 Comparison of EU MEIs to U.S. Market for IL Pumps 

(a) based on BEP only, (b) based on the efficiency at 75% of the BEP flow only, (c) based 

on the efficiency at 110% of the BEP flow only, and (d) based on the efficiency of BEP, 

75% of BEP flow, and 110% of BEP flow 

4%

12%

19%

27%

34%

43%

49%

61%

71%

83%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

5% 10% 15% 20% 30% 40% 50% 60% 70% 80%

Pumps below the EU cutoff

EU cutoff percentile

Pumps @ BEP, 75% BEP flow, 110% BEP flow

US 2 poles

US 4 poles
110

APPENDIX C - DOE EFFICIENCY SURFACE METHODOLOGY 

As mentioned previously, the EU sets minimum efficiency levels using an equation of the 

following form: 

ηBEP = a (lnQ)

2

+ b (lnQ · lnNs) + c (lnNs)

2

+ d lnQ + e lnNs + f

Where: 

Q is flow (gpm), and 

Ns is specific speed (Speed (rpm)×[Flow (gpm)]1/2/[Head per stage (ft)]3/4).

In order to allow for a flattening of the surface from the bottom to the top of the market, 

DOE explored using the EU equation but adjusting more coefficients than simply the intercept 

(f). DOE used the 2,316 ESCC pumps with efficiency data for the exploration.

C1. Example Surface Development for All ESCC Pumps

DOE first developed the average surface using a standard regression. DOE then created 

the top-of-market surface by moving the average surface up by 6 percentiles (at the maximum 

flow) to 44 percentiles (at the minimum flow). Finally, DOE created the bottom-of-market 

surface by moving the average surface down by 13 percentiles at the maximum flow and specific 

speed and 42 percentiles more and 10 percentiles more at the minimum flow and specific speed, 

respectively. 

Coefficients used to create top-of-market, average, and bottom-of-market surfaces are 

shown in Table C.1. These coefficients and surfaces are simply meant to demonstrate the range 

of efficiencies available on the market and to show a potential methodology of efficiency surface 

development that can be adjusted according to the needs of the rulemaking. 

Table C.1 DOE Coefficients of Efficiency Surfaces for ESCC Pumps 

Coefficients a b c d e f

Top of Market (Blue) -1.303 3.915 -8.606 -11.324 109.402 -303.181

Average (Green) -1.303 3.915 -8.606 -6.945 109.402 -347.181

Bottom of Market (Red) -1.303 3.915 -8.606 -2.105 110.569 -412.181

*Note: There are 2 pumps below the bottom, and 2 pumps above the top.

Figure C.1 shows the fitted average efficiency surface of ESCC pumps at BEP 

(wireframe in Green), top-of-market efficiency surface (wireframe in Red), and bottom-ofmarket efficiency surface (wireframe in Blue). Figure C.2 shows the fitted average (Green), topof-market (Blue), and bottom-of-market (Red) efficiency versus flow lines of ESCC pumps at 

BEP between various specific speeds. The scatter points in Figure C.2 are ESCC pumps falling 

in the specific speed range at BEP, and points are colored by pumps’ applications in order to 
111

show that the development of surfaces would be affected by the exact definition of clean water 

pumps.43

Figure C.1 Average, Top-of-Market, and Bottom-of-Market Efficiency Surfaces for 

ESCC Pumps 

(a) (b)

 

43 DOE has already filtered all clear wastewater and sealless pumps from its database; the remaining pumps are 

questionable in terms of whether they will be covered. 

 Top-of-Market (Blue)

 Average (Green)

 Bottom-of-Market 

(Red)
112

(c) (d)

(e) (f)

(g)

Figure C.2 Specific Speed “Slices” Showing Average, Top-of-Market, and Bottom-ofMarket Efficiency Surfaces for ESCC Pumps 

(a) Ns = 500-700 (b) Ns = 700-900 (c) Ns = 900-1000 (d) Ns = 1000-1200 (e) Ns = 1200-1500 

(f) Ns = 1500-2500 (g) Ns = 2500-3500. Chemical Pumps in Blue, Pumps without Enough 

Info in Yellow, Refrigerant Pumps in Cyan, Sanitary Pumps in Green, Waste Water 

Pumps in Purple, Water Pumps in Black, and Water Only pumps in Red.
113

C2. Water-Only Pumps 

DOE also developed similar surfaces fitted with only pumps that DOE can confirm are 

for water-only applications. Figure C.3 shows the fitted average (Green), top-of-market (Blue), 

and bottom-of-market (Red) efficiency versus flow lines of confirmed water-only ESCC pumps 

at BEP between various specific speeds. 

(a) (b)

(c) (d)

(e) (f)
114

(g)

Figure C.3 Specific Speed “Slices” Showing Average, Top-of-Market, and Bottom-ofMarket Efficiency Surfaces for Water-Only ESCC Pumps 

(a) Ns = 500-700 (b) Ns = 700-900 (c) Ns = 900-1000 (d) Ns = 1000-1200 (e) Ns = 1200-1500 

(f) Ns = 1500-2500 (g) Ns = 2500-3500. 

C3. Baseline and Market Maximum Levels 

As discussed in the engineering analysis section, DOE must develop baseline and market 

maximum efficiency levels that may be different from the bottom-of-market and top-of-market 

efficiency levels, respectively. These levels must be fairly representative in all areas, covering 

many pumps over a wide range of flow and specific speed. Figure C.4 shows an example of this 

approach, in which the bottom of market has been moved up by 15 percentiles to better represent 

a possible baseline, and the top of market has been moved down by 8 percentiles, to better 

represent market maximum. Figure C.4 shows the average (Green), moved top-of-market (Blue), 

and moved bottom-of-market (Red) efficiency versus flow lines of ESCC pumps at BEP between 

various specific speeds. The scatter points in Figure C.4 are ESCC pumps falling in the specific 

speed range at BEP, and the points are colored by pump application. 

(a) (b)
115

(c) (d)

(e) (f)

(g)

Figure C.4 Specific Speed “Slices” Showing Potential Average, Baseline, and Market 

Maximum Efficiency Surfaces for ESCC Pumps 

(a) Ns = 500-700 (b) Ns = 700-900 (c) Ns = 900-1000 (d) Ns = 1000-1200 (e) Ns = 1200-1500 

(f) Ns = 1500-2500 (g) Ns = 2500-3500. Chemical Pumps in Blue, Pumps without Enough 

Info in Yellow, Refrigerant Pumps in Cyan, Sanitary Pumps in Green, Waste Water 

Pumps in Purple, Water Pumps in Black, and Water Only pumps in Red.
116

APPENDIX D - PUMP DESIGN SPEED 

 This appendix provides more details regarding the differences in pump efficiency curves 

due to design speed. Two different approaches are applied: one with varying intercept values in 

the efficiency curve formulation, while keeping all other coefficients the same; and the other 

with constant intercept values while changing other coefficients in the efficiency model. The 

former one corresponds to a vertical change in the efficiency surface, as in EU’s methodology, 

and the latter one corresponds to a surface shape change. 

 DOE also explores how the results of this modeling change when narrowing the pump 

scope to a more limited clean water-only set. 

D1. Varying Intercept Approach (Vertical Change in Surface) 

The efficiency is modeled as a function of specific speed (Ns) and flow (Q): 

 In the vertical change (varying intercept) approach, coefficient varies for different 

numbers of poles, while the other five coefficients stay the same. 

D1.1. ESCC Pumps 

 A total of 2,316 ESCC pumps with valid efficiency data are selected from DOE’s PUMP-FLO 

database. The distribution of number of poles is shown in Table D.1. 

Table D.1 Distribution of Number of Poles for ESCC Pumps 

Number of 

Poles ESCC Pumps

Freq. Percent

2 759 32.77%

4 1,168 50.43%

6 321 13.86%

8 30 1.30%

Total 2316 98.36%

 Different model formulations are considered with the results summarized in Table D.2. 

Model 1 is the base line with no consideration of design speed. Model 3 takes into account the 

intercept differences, Δf, for pumps with 2-pole, 4-pole, 6-pole, and 8-pole motors, respectively. 

However, the Δfs for 4-pole and 6-pole are not statistically significant at α = 0.05 (95% 

confidence). So in Model 2 DOE dropped Δf for 6-pole, which resulted in the highlighted model 

that has all statistically significant coefficients and a better model fit (higher adjusted R2

value). 

According to the model results, pumps with 4-pole motors translate into a 2.16 increase in 

efficiency, compared to pumps with 2-pole motors. Pumps with 6-pole motors have a 1.43 

increase compared to 4-pole motors, and pumps with 8-pole motors have a 4.81 increase 

compared to 6-pole motors. This makes the total efficiency spread between 2-pole and 8-pole 

motors 8.4. The coefficients from Model 2 are summarized in Table D.3, while the efficiency 

surfaces are plotted in Figure D.1. 
117

Table D.2 Models with Vertical Change in Surface for ESCC Pumps 

Model 1 Model 2 Model 3

η Coefficient Std. 

Err.

Coefficient Std. 

Err.

Coefficient Std. 

Err.

a -1.30* 0.12 -1.44* 0.12 -1.45* 0.12

b 3.92* 0.50 3.99* 0.49 4.01* 0.49

c -8.61* 0.71 -8.71* 0.69 -8.72* 0.70

d -6.95* 2.89 -6.00* 2.83 -6.07* 2.84

e 109.42* 8.29 110.15* 8.13 110.31* 8.15

f -347.23* 25.59 -349.38* 25.07 -349.43* 25.08

2-pole Δf -3.59* 0.45 -3.92* 1.19

4-pole Δf -1.43* 0.42 -1.75 1.17

6-pole Δf -0.35 1.21

8-pole Δf 4.81* 1.32 4.49* 1.72

R

2

0.6962 0.7094 0.7094

Adjusted R20.6956 0.7084 0.7082

*: statistically significant at 0.05 

Table D.3 Coefficients from Model 2 with Vertical Change in Surface for ESCC Pumps 

η Base 2-pole 4-pole 6-pole^ 8-pole Weighted 

Average

a -1.44 -1.44 -1.44 -1.44 -1.44 -1.44

b 3.99 3.99 3.99 3.99 3.99 3.99

c -8.71 -8.71 -8.71 -8.71 -8.71 -8.71

d -6.00 -6.00 -6.00 -6.00 -6.00 -6.00

e 110.15 110.15 110.15 110.15 110.15 110.15

f -349.38 -352.97 -350.82 -349.38 -344.57 -351.22

^: 6-pole coefficients are equivalent to the base coefficients because 6-pole pumps were removed from the model. 
118

Figure D.1 Efficiency Surfaces Using Model 2 with Vertical Change in Surface for All 

Pumps 

D1.2. End Suction Frame Mounted (ESFM) Pumps 

 A total of 4,222 ESFM pumps are selected from DOE’s PUMP-FLO database. The 

distribution of number of poles is shown in Table D.4. 

Table D.4 Distribution of Number of Poles for ESFM Pumps 

Number of Poles Freq. Percent

2 1,106 26%

4 1,877 44%

6 828 20%

8 220 5%

10 5 0%

12 1 0%

Total 4222 100%

 For ESFM, the model used included Δf for all poles, as all coefficients were statistically 

significant. The coefficients are summarized in Table D.5, while the efficiency surfaces are 

plotted in Figure D.2. The average difference between 4-pole and 2-pole pumps is 1.6 efficiency 

points. All coefficients are statistically significant at the 0.10 level (90% confidence). This is 

slightly less confident than the ones for ESCC, which are at a 0.05 level (95% confidence), but 

still acceptable. 

Table D.5 Coefficients for ESFM Pump Model 

η Base 2-pole 4-pole 6-pole 8-pole Weighted 

4-pole pumps (Blue)

All pumps (Green)

2-pole pumps (Red)
119

Average

a -1.02 -1.02 -1.02 -1.02 -1.02 -1.02

b 1.43 1.43 1.43 1.43 1.43 1.43

c -7.52 -7.52 -7.52 -7.52 -7.52 -7.52

d 6.53 6.53 6.53 6.53 6.53 6.53

e 109.68 109.68 109.68 109.68 109.68 109.68

f -390.03 -390.97 -389.32 -388.96 -389.01 -389.70

Figure D.2 Efficiency Surfaces of ESFM pumps with 2 and 4 poles 

4-pole pumps (Blue)

All pumps (Green)

2-pole pumps (Red)
120

D1.3. Inline (IL) Pumps 

 A total of 963 IL pumps are selected from DOE’s PUMP-FLO database. The distribution 

of number of poles is shown in Table D.6. 

Table D.6 Distribution of Number of Poles for IL Pumps 

Number of Poles Freq. Percent

2 286 30%

4 468 49%

6 200 21%

8 9 1%

Total 963 100%

 For IL, the best model fit dropped Δf for 6-pole and 8-pole pumps. The coefficients are 

summarized in Table D.7, while the efficiency surfaces are plotted in Figure D.3. The average 

difference between 4-pole and 2-pole pumps is 3.13 efficiency points. All coefficients except for 

d are statistically significant at a 0.05 level (95% confidence). 

Table D.7 Coefficients for IL Pump Model 

η Base 2-pole 4-pole 6-pole 8-pole Weighted 

Average

a -1.32 -1.32 -1.32 -1.32 -1.32 -1.32

b 3.13 3.13 3.13 3.13 3.13 3.13

c -9.52 -9.52 -9.52 -9.52 -9.52 -9.52

d -1.86 -1.86 -1.86 -1.86 -1.86 -1.86

e 128.77 128.77 128.77 128.77 128.77 128.77

f -433.48 -437.67 -434.54 -433.48 -433.48 -435.24

Figure D.3 Efficiency Surfaces of IL Pumps with 2 and 4 poles 

4-pole pumps (Blue)

All pumps (Green)

2-pole pumps (Red)
121

D2. Constant Intercept Approach (Surface Shape Change) 

 DOE also explored a constant intercept approach using ESCC pumps as an example. In 

the constant intercept approach, coefficients – vary for different design speeds, while the 

intercept stays constant. Different model formulations are considered with results summarized 

in Table D.8. Model 5 takes into account the differences Δa –Δe for pumps with 2-pole, 4-pole, 

6-pole, and 8-pole motors, respectively. However, most of the Δa –Δe for 6-pole and 8-pole are 

not statistically significant at α = 0.05 (95% confidence). So in Model 4 DOE dropped Δa –Δe

for 6-pole and 8-pole, which resulted in the highlighted model that has mostly statistically 

significant coefficients. Depending on the specific speed and flow at Best Efficiency Point 

(BEP), the differences between 2-pole and 4-pole could be positive or negative, which makes it 

difficult to interpret the relative efficiencies. The coefficients from Model 4 are summarized in 

Table D.9, while the efficiency surfaces are plotted in Figure D.4. 

Table D.8 Models with Surface Shape Change for All ESCC Pumps 

Model 1 Model 4 Model 5

η Coefficient Std. Err. Coefficient Std. Err. Coefficient Std. Err.

a -1.30* 0.12 1.03* 0.32 1.92 1.99

b 3.92* 0.50 -6.34* 1.27 -2.95 5.80

c -8.61* 0.71 -1.79 1.11 -5.92 4.26

d -6.95* 2.89 38.57* 7.08 -0.05* 25.06

e 109.42* 8.29 72.52* 9.87 109.20* 25.75

f -347.23* 25.59 -347.68* 24.94 -344.56* 25.20

2-pole Δa -3.26* 0.42 -4.15* 2.01

2-pole Δb 15.28* 1.59 11.85* 5.86

2-pole Δc -10.06* 1.12 -5.84 4.21

2-pole Δd -71.26* 8.96 -32.47 25.56

2-pole Δe 56.07* 7.24 18.38 24.22

4-pole Δa -2.57* 0.35 -3.46 2.00

4-pole Δb 10.47* 1.38 7.06 5.81

4-pole Δc -6.91* 0.99 -2.70 4.18

4-pole Δd -44.25* 7.74 -5.54 25.20

4-pole Δe 36.57* 6.38 -1.05 24.02

6-pole Δa -0.79 2.05

6-pole Δb -3.92 6.02

6-pole Δc 4.51 4.31

6-pole Δd 42.34 26.40

6-pole Δe -40.20 24.85

8-pole Δa 2.88 2.54

8-pole Δb -16.48 8.92

8-pole Δc 12.28 6.35

8-pole Δd 92.75* 47.18

8-pole Δe -

81.42* 39.51

R

2

0.6962 0.7221 0.7247
122

Model 1 Model 4 Model 5

η Coefficient Std. Err. Coefficient Std. Err. Coefficient Std. Err.

Adjusted R20.6956 0.7203 0.7217

*: statistically significant at 0.05 

Table D.9 Coefficients from Model 4 with Surface Shape Change for ESCC Pumps 

η Base 2-pole 4-pole Weighted 

Average

a 1.03 -2.23 -1.54 -1.34

b -6.34 8.93 4.13 3.94

c -1.79 -11.85 -8.70 -8.57

d 38.57 -32.69 -5.69 -7.10

e 72.52 128.60 109.09 109.34

f -347.68 -347.68 -347.68 -347.68

Figure D.4 Efficiency Surfaces Using Model 4 with Surface Shape Change for ESCC 

Pumps 

D3. Effects of Pump Scope 

 For ESCC pumps, DOE also explored the effect of using a more limited set of pumps 

from the database – namely, the 973 ESCC pumps for which DOE can confirm that the pumps 

are designed for water-only applications. Table D.10 shows the distribution of number of poles 

for these pumps. 

Table D.10 Distribution of Number of Poles for ESCC Water-Only Pumps 

Number of Poles Water-only Pumps

4-pole pumps (Blue)

All pumps (Green)

2-pole pumps (Red)
123

Freq. Percent

2 290 29.80%

4 512 52.62%

6 165 16.96%

8 5 0.51%

Total 973 99.90%

 DOE only used the vertical change approach for this analysis because of the difficulty in 

interpreting the results of the surface shape change approach. For ESCC water-only pumps, the 

best model fit excluded Δf for 4-pole, 6-pole, and 8-pole pumps. According to the model results, 

pumps with 4-pole motors translate into a 1.83 increase in efficiency, compared to pumps with 2-

pole motors. This difference is slightly lower than that of 2.16 obtained using the broader set of 

ESCC pumps in the database. The coefficients from the model are summarized in Table D.11, 

while the efficiency surfaces are plotted in Figure D.5.

Table D.11 Coefficients for Water-Only Pumps 

η Base 2-pole 4-pole^ 6-pole^ 8-pole^ Weighted 

Average

a -0.58 -0.58 -0.58 -0.58 -0.58 -0.58

b 1.79 1.79 1.79 1.79 1.79 1.79

c -3.76 -3.76 -3.76 -3.76 -3.76 -3.76

d -0.24 -0.24 -0.24 -0.24 -0.24 -0.24

e 51.56 51.56 51.56 51.56 51.56 51.56

f -155.94 -157.77 -155.94 -155.94 -155.94 -156.49

^: coefficients are equivalent to the base coefficients because these pumps were removed from the model. 

Figure D.5 Efficiency Surfaces for Water-only Pumps 

4-pole pumps (Blue)

All pumps (Green)

2-pole pumps (Red)
124

D4. Results 

 In general, the approach with surface shape change yields a better model fit than the 

vertical change in surface approach, though the model fit improvement is very small. In addition, 

depending on the specific speed and flow at BEP, the differences between 2-pole and 4-pole in 

the surface shape change model could be positive or negative, which makes it difficult to 

interpret the relative efficiencies. 

 In the vertical change approach on average, ESCC pumps with 4-pole motors show an 

increase of 2.16 in efficiency compared to ESCC pumps with 2-pole motors (at constant Ns and 

flow). This is slightly less than the EU difference between 4-pole and 2-pole pumps at MEI 50, 

which is 2.5. Similarly, ESFM pumps with 4-pole motors show an increase of 1.64 compared to 

ESFM pumps with 2-pole motors (at constant Ns and flow), and IL pumps show an increase of 

3.13 compared to IL pumps with 2-pole motors (at constant Ns and flow). 

 The analysis was also conducted on water-only ESCC pumps, which suggested 

statistically significant differences in efficiency between pumps with 2-pole motors and other 

pumps of 1.83. This difference is slightly lower than that of 2.16 using the broader set of ESCC 

pumps in the database 
125

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