# 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 paperMr. 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