iI

Department of Energy

Washington, DC 20585

Mr. Malcolm E. O'Hagan

President

National Electrical Manufacturers Association

1300 North 17th Street, Suite 1847

Rosslyn, VA 22209

Dear Mr. O'Hagan:

MAY 0' 9 1998

MAY 146

OFFICE OF

THE PRESIDENT

I am writing in response to an April 3 , 1996. letter to Deborah Miller, of my staff,

from Mr. Ted Atkins. Vice President, Baldor Electric , regarding manufacturers'

Compliance with the energy conservation standards for certain electric motors

found in the Energy Policy Act of 1992 (EPACT), Public Law 102-486.

EPACT specifies minimum nominal full-load energy efficiency standards for 1 to

200 horsepower electric motors, and, to measure compliance with those standards,

prescribes the test procedures of the National Electrical Manufacturers

Association (NEMA) Standard MG 1-1987 and Institute of Electrical and

Electronics Engineers (IEEE) Standard 112-1991. The Department of Energy

(DOE) is preparing a notice of proposed rulemaking regarding test procedures,

labeling, standards and compliance certification procedures for electric motors.

The Department is considering adopting NEMA MG1-1993 with Revision 1,.

which requires using IEEE 112-1991 or Canadian Standards Association (CSA)

Standard C390-93.

As Mr. Atkins indicates in his letter, motor manufacturers must comply with the

standards and test procedures prescribed by EPACT by October 1997. This

effective date is prescribed by statute. DOE's rulemaking proceeding, referred to

above, will concern modification of and elaboration on the test procedures set

forth in the statute, certain interpretative issues, and the promulgation of labeling

and certification requirements.

We infer from Mr. Atkins' letter that he believes EPACT requires motor

manufacturers to certify, by October 1997, that their motors comply with the

statute's requirements. That is not the case. Labeling and certification

requirements will become effective only after DOE has promulgated a final rule

prescribing such requirements. We are sympathetic to Mr. Atkins' concern that

electric motor manufacturers have sufficient lead time to comply with certification

requirements. DOE fully intends to set effective dates that allow manufacturers

sufficient time to comply with both the labeling and certification requirements.

Printed with soy nit on recycled paper

EE-RM-96-400 COMMENT 0M
Mr. Atkins indicates in his letter that, because DOE has not yet promulgated

certification procedures, manufacturers will be unable to establish compliance with

standards and test procedures by October 1997 as required. He suggests reliance

on the process already in place for certifying motor efficiency levels in accordance

with Canada s energy efficiency program. In DOE'S view, until DOE'S regulations

become effective , manufacturers can establish that their motors comply with

EPACT requirements if they use competent and reliable procedures or methods,

that give reasonable assurance of such compliance . So long as these criteria are

met, manufacturers could conduct required testing in their own laboratories or in

independent laboratories , and could employ alternative correlation methods (in lieu

of actual testing) for some motors . Based on information available to DOE, it

would also appear that manufacturers could establish their compliance with

EPACT requirements through use of third party certification or verification

programs such as those recognized by Natural Resources Canada.

1 hope that the foregoing satisfactorily addresses your concerns. If you have any

questions concerning this matter , please , contact Michael J. McCabe at

(202) 586-9127.

Best Regards,

r

Christine A. Ervin

Assistant Secretary

Energy Efficiency and Renewable Energy

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