Energy Conservation Program: Energy Conservation Standards for Commercial and Industrial Electric Motors, 73589-73681 [2013-28776]
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Vol. 78
Friday,
No. 235
December 6, 2013
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for
Commercial and Industrial Electric Motors; Proposed Rule
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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE–2010–BT–STD–
0027]
RIN 1904–AC28
Energy Conservation Program: Energy
Conservation Standards for
Commercial and Industrial Electric
Motors
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking
(NOPR) and public meeting.
AGENCY:
The Energy Policy and
Conservation Act of 1975 (EPCA), as
amended, prescribes energy
conservation standards for various
consumer products and certain
commercial and industrial equipment,
including commercial and industrial
electric motors. EPCA also requires the
U.S. Department of Energy (DOE) to
determine whether more-stringent,
amended standards would be
technologically feasible and
economically justified, and would save
a significant amount of energy. In this
notice, DOE proposes energy
conservation standards for a number of
different groups of electric motors that
DOE has not previously regulated. For
those groups of electric motors currently
regulated, the proposed standards
would maintain the current energy
conservation standards for some electric
motor types and amend the energy
conservation standards for other electric
motor types. The document also
announces a public meeting to receive
comment on these proposed standards
and associated analyses and results.
DATES: DOE will hold a public meeting
on Wednesday, December 11, 2013,
from 9 a.m. to 4 p.m., in Washington,
DC. The meeting will also be broadcast
as a webinar. See section VII Public
Participation for webinar registration
information, participant instructions,
and information about the capabilities
available to webinar participants.
DOE will accept comments, data, and
information regarding this NOPR before
and after the public meeting, but no
later than February 4, 2014. See section
VII Public Participation for details.
ADDRESSES: The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 8E–089, 1000
Independence Avenue SW.,
Washington, DC 20585. To attend,
please notify Ms. Brenda Edwards at
(202) 586–2945. Please note that foreign
nationals visiting DOE Headquarters are
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subject to advance security screening
procedures. Any foreign national
wishing to participate in the meeting
should advise DOE as soon as possible
by contacting Ms. Edwards to initiate
the necessary procedures. Please also
note that those wishing to bring laptops
into the Forrestal Building will be
required to obtain a property pass.
Visitors should avoid bringing laptops,
or allow an extra 45 minutes. Persons
can attend the public meeting via
webinar. For more information, refer to
the Public Participation section near the
end of this notice.
Any comments submitted must
identify the NOPR for Energy
Conservation Standards for electric
motors, and provide docket number
EE–2010–BT–STD–2027 and/or
regulatory information number (RIN)
number 1904–AC28. Comments may be
submitted using any of the following
methods:
1. Federal eRulemaking Portal:
www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: ElecMotors-2010-STD-0027@
ee.doe.gov. Include the docket number
and/or RIN in the subject line of the
message.
3. Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Program, Mailstop EE–2J,
1000 Independence Avenue SW.,
Washington, DC 20585–0121. If
possible, please submit all items on a
CD. It is not necessary to include
printed copies.
4. Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza SW., Suite 600,
Washington, DC 20024. Telephone:
(202) 586–2945. If possible, please
submit all items on a CD, in which case
it is not necessary to include printed
copies.
Written comments regarding the
burden-hour estimates or other aspects
of the collection-of-information
requirements contained in this proposed
rule may be submitted to Office of
Energy Efficiency and Renewable
Energy through the methods listed
above and by email to Chad_S_
Whiteman@omb.eop.gov.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section VII of this document (Public
Participation).
Docket: The docket, which includes
Federal Register notices, public meeting
attendee lists and transcripts,
comments, and other supporting
documents/materials, is available for
review at regulations.gov. All
documents in the docket are listed in
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the regulations.gov index. However,
some documents listed in the index,
such as those containing information
that is exempt from public disclosure,
may not be publicly available.
A link to the docket Web page can be
found at https://www.regulations.gov/
#!docketDetail;D=EERE-2010-BT-STD0027. This Web page will contain a link
to the docket for this notice on the
regulations.gov site. The regulations.gov
Web page will contain simple
instructions on how to access all
documents, including public comments,
in the docket. See section VII for further
information on how to submit
comments through
www.regulations.gov.
For further information on how to
submit a comment, review other public
comments and the docket, or participate
in the public meeting, contact Ms.
Brenda Edwards at (202) 586–2945 or by
email: Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
James Raba, U.S. Department of Energy,
Office of Energy Efficiency and
Renewable Energy, Building
Technologies Program, EE–2J, 1000
Independence Avenue SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–8654. Email:
Jim.Raba@ee.doe.gov.
Ms. Ami Grace-Tardy, U.S.
Department of Energy, Office of the
General Counsel, GC–71, 1000
Independence Avenue SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–5709. Email:
Ami.Grace-Tardy@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for
Electric Motors
3. Process for Setting Energy Conservation
Standards
III. General Discussion
A. Test Procedure
B. Equipment Classes and Current Scope of
Coverage
C. Expanded Scope of Coverage
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible
Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and
Consumers
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b. Life-Cycle Costs
c. Energy Savings
d. Lessening of Utility or Performance
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related
Comments
A. Market and Technology Assessment
1. Current Scope of Electric Motors Energy
Conservation Standards
2. Expanded Scope of Electric Motor
Energy Conservation Standards
3. Advanced Electric Motors
4. Equipment Class Groups and Equipment
Classes
a. Electric Motor Design Letter
b. Fire Pump Electric Motors
c. Brake Motors
d. Horsepower Rating
e. Pole Configuration
f. Enclosure Type
g. Other Motor Characteristics
5. Technology Assessment
a. Decrease the Length of Coil Extensions
b. Increase Cross-Sectional Area of Rotor
Conductor Bars
c. Increase Cross-Sectional Area of End
Rings
d. Increase the Number of Stator Slots
e. Electrical Steel With Lower Losses
f. Thinner Steel Laminations
g. Increase Stack Length
h. More Efficient Cooling System
i. Reduce Skew on Conductor Cage
B. Screening Analysis
1. Technology Options Not Screened Out
of the Analysis
a. Copper Die-Cast Rotors
b. Increase the Cross-Sectional Area of
Copper in the Stator Slots
2. Technology Options Screened Out of the
Analysis
C. Engineering Analysis
1. Engineering Analysis Methodology
2. Representative Units
a. Electric Motor Design Type
b. Horsepower Rating
c. Pole-Configuration
d. Enclosure Type
3. Efficiency Levels Analyzed
4. Test and Teardowns
5. Software Modeling
6. Cost Model
a. Copper Pricing
b. Labor Rate and Non-Production Markup
c. Catalog Prices
d. Product Development Cost
7. Engineering Analysis Results
8. Scaling Methodology
D. Markups Analysis
E. Energy Use Analysis
1. Comments on Operating Hours
2. Comments on Other Issues
F. Life-Cycle Cost and Payback Period
Analysis
1. Equipment Costs
2. Installation Costs
3. Maintenance Costs
4. Repair Costs
5. Unit Energy Consumption
6. Electricity Prices and Electricity Price
Trends
7. Lifetime
8. Discount Rate
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9. Base Case Market Efficiency
Distributions
10. Compliance Date
11. Payback Period Inputs
12. Rebuttable-Presumption Payback
Period
G. Shipments Analysis
H. National Impact Analysis
1. Efficiency Trends
2. National Energy Savings
3. Equipment Price Forecast
4. Net Present Value of Customer Benefit
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
a. Product and Capital Conversion Costs
b. Manufacturer Production Costs
c. Shipment Forecast
d. Markup Scenarios
3. Discussion of Comments
a. Scope of Coverage
b. Conversion Costs
c. Enforcement of Standards
d. Motor Refurbishment
4. Manufacturer Interviews
a. Efficiency Levels above NEMA Premium
b. Increase in Equipment Repairs
c. Enforcement
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other
Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in
Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions
Reductions
M. Utility Impact Analysis
N. Employment Impact Analysis
O. Other Comments Received
V. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy
Savings
1. Economic Impacts on Individual
Customers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Sub-Group of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Customer Costs and
Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Summary of National Economic Impacts
8. Other Factors
C. Proposed Standards
1. Benefits and Burdens of Trial Standard
Levels Considered for Electric Motors
2. Summary of Benefits and Costs
(Annualized) of the Proposed Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866
and 13563
B. Review Under the Regulatory Flexibility
Act
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1. Description and Estimated Number of
Small Entities Regulated
a. Methodology for Estimating the Number
of Small Entities
b. Manufacturer Participation
c. Electric Motor Industry Structure and
Nature of Competition
d. Comparison Between Large and Small
Entities
2. Description and Estimate of Compliance
Requirements
3. Duplication, Overlap, and Conflict with
Other Rules and Regulations
4. Significant Alternatives to the Proposed
Rule
5. Significant Issues Raised by Public
Comments
C. Review Under the Paperwork Reduction
Act
D. Review Under the National
Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates
Reform Act of 1995
H. Review Under the Treasury and General
Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General
Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality
Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared
General Statements For Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
1. The authority citation for part 431
continues to read as follows:
2. Revise § 431.25 to read as follows:
I. Summary of the Proposed Rule
Title III, Part B of the Energy Policy
and Conservation Act of 1975 (EPCA or
the Act), Public Law 94–163 (42 U.S.C.
6291–6309, as codified), established the
Energy Conservation Program for
Consumer Products Other Than
Automobiles. Part C of Title III of EPCA
(42 U.S.C. 6311–6317) established a
similar program for ‘‘Certain Industrial
Equipment,’’ including certain electric
motors.1 (Within this preamble, DOE
will use the terms ‘‘electric motors’’ and
‘‘motors’’ interchangeably.) Pursuant to
EPCA, any new or amended energy
conservation standard that DOE may
prescribe for certain equipment, such as
electric motors, shall be designed to
achieve the maximum improvement in
energy efficiency that DOE determines
is technologically feasible and
economically justified. (42 U.S.C.
6295(o)(2)(A) and 6316(a)).
Furthermore, any new or amended
standard must result in a significant
1 For editorial reasons, upon codification in the
U.S. Code, Parts B and C were redesignated as Parts
A and A–1, respectively.
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conservation of energy. (42 U.S.C.
6295(o)(3)(B) and 6316(a)).
In accordance with these and other
statutory provisions discussed in this
notice, the U.S. Department of Energy
(DOE) proposes amending the energy
conservation standards for electric
motors by applying the standards
currently in place to a wider scope of
electric motors for which DOE does not
currently regulate. In setting these
standards, DOE is proposing to address
a number of different groups of electric
motors that have, to date, not been
required to satisfy the energy
conservation standards currently set out
in 10 CFR part 431. In addition, with the
exception of fire pump electric motors,
the proposal would require all currently
regulated motors to satisfy the efficiency
levels prescribed in Table 12–12 and
Table 20–B 2 of MG1–2011, published
by the National Electrical Manufacturers
Association; fire pump motors would
continue to meet the current standards
that apply. All other electric motors that
DOE is proposing to regulate would also
need to meet these efficiency levels (i.e.
Tables 12–12 and 20–B). As a practical
matter, the many currently regulated
motors would continue to be required to
meet the standards that they already
meet, but certain motors, such as those
that satisfy the general purpose electric
motors (subtype II) (‘‘subtype II’’) or that
are NEMA Design B motors from 201
through 500 horsepower, would need to
meet the more stringent levels
prescribed by MG1–2011 Tables 12–12
and 20–B. These proposed efficiency
levels are shown in Table I.1. If adopted,
the proposed standards would apply to
all covered motor types listed in Table
I.1 that are manufactured in, or
imported into, the United States starting
on December 19, 2015. DOE may,
however, depending on the nature of the
comments it receives, revisit this
proposed compliance date.
TABLE I.1—PROPOSED ENERGY CONSERVATION STANDARDS FOR ELECTRIC MOTORS
[Compliance starting December 19, 2015]
Equipment class
group
Electric motor design type
Horsepower
rating
Pole
configuration
1 ........................
NEMA Design A & B * ...............
1–500
2, 4, 6, 8
2 ........................
NEMA Design C * ......................
1–200
4, 6, 8
3 ........................
Fire Pump * ...............................
1–500
2, 4, 6, 8
4 ........................
Brake Motors * ...........................
1–30
4, 6, 8
Enclosure
Proposed TSL
Open .........................................
Enclosed ...................................
Open .........................................
Enclosed ...................................
Open .........................................
Enclosed ...................................
Open .........................................
Enclosed ...................................
2
2
2
2
2
2
2
2
* Indicates IEC equivalent electric motors are included.
The following tables (Tables I.2 to I.5)
detail the various proposed standard
levels that comprise TSL 2 and that DOE
would apply to each group of motors. In
determining where a particular motor
with a certain horsepower (hp) or
kilowatt rating would fall within the
requirements, as in DOE’s current
regulations, DOE would apply the
following approach in determining
(3) A kilowatt rating shall be directly
converted from kilowatts to horsepower
using the formula 1 kilowatt = (1/0.746)
horsepower. The conversion should be
calculated to three significant decimal
places, and the resulting horsepower
shall be rounded in accordance with the
rules listed in (1) and (2).
which rating would apply for
compliance purposes:
(1) A horsepower at or above the
midpoint between the two consecutive
horsepowers shall be rounded up to the
higher of the two horsepowers;
(2) A horsepower below the midpoint
between the two consecutive
horsepowers shall be rounded down to
the lower of the two horsepowers; or
TABLE I.2—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS (EXCLUDING FIRE PUMP ELECTRIC MOTORS, INTEGRAL BRAKE ELECTRIC MOTORS, AND NON-INTEGRAL BRAKE
ELECTRIC MOTORS)
[Compliance starting December 19, 2015]
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Motor horsepower/standard
kilowatt
equivalent
1/.75 .................
1.5/1.1 ..............
2/1.5 .................
3/2.2 .................
5/3.7 .................
7.5/5.5 ..............
10/7.5 ...............
15/11 ................
20/15 ................
25/18.5 .............
30/22 ................
Nominal full load efficiency (%)
2 Pole
Enclosed
4 Pole
Open
77.0
84.0
85.5
86.5
88.5
89.5
90.2
91.0
91.0
91.7
91.7
77.0
84.0
85.5
85.5
86.5
88.5
89.5
90.2
91.0
91.7
91.7
Enclosed
6 Pole
Open
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
Enclosed
8 Pole
Open
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
2 Table 20–B of MG1–2011 provides nominal fullload efficiencies for ratings without nominal fullload efficiencies in Table 12–12 of MG1–2011.
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Enclosed
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
Open
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE I.2—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS (EXCLUDING FIRE PUMP ELECTRIC MOTORS, INTEGRAL BRAKE ELECTRIC MOTORS, AND NON-INTEGRAL BRAKE
ELECTRIC MOTORS)—Continued
[Compliance starting December 19, 2015]
Motor horsepower/standard
kilowatt
equivalent
40/30 ................
50/37 ................
60/45 ................
75/55 ................
100/75 ..............
125/90 ..............
150/110 ............
200/150 ............
250/186 ............
300/224 ............
350/261 ............
400/298 ............
450/336 ............
500/373 ............
Nominal full load efficiency (%)
2 Pole
Enclosed
4 Pole
Open
92.4
93.0
93.6
93.6
94.1
95.0
95.0
95.4
95.8
95.8
95.8
95.8
95.8
95.8
Enclosed
92.4
93.0
93.6
93.6
93.6
94.1
94.1
95.0
95.0
95.4
95.4
95.8
96.2
96.2
6 Pole
Open
94.1
94.5
95.0
95.4
95.4
95.4
95.8
96.2
96.2
96.2
96.2
96.2
96.2
96.2
Enclosed
94.1
94.5
95.0
95.0
95.4
95.4
95.8
95.8
95.8
95.8
95.8
95.8
96.2
96.2
8 Pole
Open
94.1
94.1
94.5
94.5
95.0
95.0
95.8
95.8
95.8
95.8
95.8
95.8
95.8
95.8
94.1
94.1
94.5
94.5
95.0
95.0
95.4
95.4
95.8
95.8
95.8
95.8
96.2
96.2
Enclosed
91.7
92.4
92.4
93.6
93.6
94.1
94.1
94.5
95.0
95.0
95.0
95.0
95.0
95.0
Open
91.7
92.4
93.0
94.1
94.1
94.1
94.1
94.1
95.0
95.0
95.0
95.0
95.0
95.0
TABLE I.3—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN C ELECTRIC MOTORS (EXCLUDING
NON-INTEGRAL BRAKE ELECTRIC MOTORS AND INTEGRAL BRAKE ELECTRIC MOTORS)
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor horsepower/standard kilowatt equivalent
4 Pole
Enclosed
1/.75 .....................................................................
1.5/1.1 ..................................................................
2/1.5 .....................................................................
3/2.2 .....................................................................
5/3.7 .....................................................................
7.5/5.5 ..................................................................
10/7.5 ...................................................................
15/11 ....................................................................
20/15 ....................................................................
25/18.5 .................................................................
30/22 ....................................................................
40/30 ....................................................................
50/37 ....................................................................
60/45 ....................................................................
75/55 ....................................................................
100/75 ..................................................................
125/90 ..................................................................
150/110 ................................................................
200/150 ................................................................
6 Pole
Open
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
94.1
94.5
95.0
95.4
95.4
95.4
95.8
96.2
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.8
95.8
Enclosed
8 Pole
Open
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
94.1
94.1
94.5
94.5
95.0
95.0
95.8
95.8
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
94.1
94.1
94.5
94.5
95.0
95.0
95.4
95.4
Enclosed
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
91.7
92.4
92.4
93.6
93.6
94.1
94.1
94.5
Open
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
91.7
92.4
93.0
94.1
94.1
94.1
94.1
94.1
TABLE I.4—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS
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[Compliance starting December 19, 2015]
Motor horsepower/standard
kilowatt
equivalent
1/.75 .................
1.5/1.1 ..............
2/1.5 .................
3/2.2 .................
5/3.7 .................
7.5/5.5 ..............
10/7.5 ...............
15/11 ................
20/15 ................
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Nominal full load efficiency (%)
2 Pole
Enclosed
4 Pole
Open
75.5
82.5
84.0
85.5
87.5
88.5
89.5
90.2
90.2
18:00 Dec 05, 2013
75.5
82.5
84.0
84.0
85.5
87.5
88.5
89.5
90.2
Jkt 232001
PO 00000
Enclosed
6 Pole
Open
82.5
84.0
84.0
87.5
87.5
89.5
89.5
91.0
91.0
Frm 00005
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82.5
84.0
84.0
86.5
87.5
88.5
89.5
91.0
91.0
Sfmt 4702
Enclosed
8 Pole
Open
80.0
85.5
86.5
87.5
87.5
89.5
89.5
90.2
90.2
E:\FR\FM\06DEP2.SGM
80.0
84.0
85.5
86.5
87.5
88.5
90.2
90.2
91.0
06DEP2
Enclosed
74.0
77.0
82.5
84.0
85.5
85.5
88.5
88.5
89.5
Open
74.0
75.5
85.5
86.5
87.5
88.5
89.5
89.5
90.2
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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE I.4—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS—Continued
[Compliance starting December 19, 2015]
Motor horsepower/standard
kilowatt
equivalent
25/18.5 .............
30/22 ................
40/30 ................
50/37 ................
60/45 ................
75/55 ................
100/75 ..............
125/90 ..............
150/110 ............
200/150 ............
250/186 ............
300/224 ............
350/261 ............
400/298 ............
450/336 ............
500/373 ............
Nominal full load efficiency (%)
2 Pole
Enclosed
4 Pole
Open
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.5
94.5
95.0
95.4
95.4
95.4
95.4
95.4
95.4
Enclosed
91.0
91.0
91.7
92.4
93.0
93.0
93.0
93.6
93.6
94.5
94.5
95.0
95.0
95.4
95.8
95.8
6 Pole
Open
92.4
92.4
93.0
93.0
93.6
94.1
94.5
94.5
95.0
95.0
95.0
95.4
95.4
95.4
95.4
95.8
Enclosed
91.7
92.4
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.4
95.4
95.8
95.8
8 Pole
Open
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.1
95.0
95.0
95.0
95.0
95.0
95.0
95.0
95.0
91.7
92.4
93.0
93.0
93.6
93.6
94.1
94.1
94.5
94.5
95.4
95.4
95.4
95.4
95.4
95.4
Enclosed
Open
89.5
91.0
91.0
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.5
94.5
94.5
94.5
94.5
94.5
90.2
91.0
91.0
91.7
92.4
93.6
93.6
93.6
93.6
93.6
94.5
94.5
94.5
94.5
94.5
94.5
TABLE I.5—PROPOSED ENERGY CONSERVATION STANDARDS FOR INTEGRAL BRAKE ELECTRIC MOTORS AND NONINTEGRAL BRAKE ELECTRIC MOTORS
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor horsepower/standard kilowatt
equivalent
4 Pole
6 Pole
Enclosed
Open
1/.75 .........................................................
1.5/1.1 ......................................................
2/1.5 .........................................................
3/2.2 .........................................................
5/3.7 .........................................................
7.5/5.5 ......................................................
10/7.5 .......................................................
15/11 ........................................................
20/15 ........................................................
25/18.5 .....................................................
30/22 ........................................................
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
A. Benefits and Costs to Consumers
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Table I.6 presents DOE’s evaluation of
the economic impacts of the proposed
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8 Pole
Enclosed
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
standards on consumers of electric
motors, as measured by the weighted
average life-cycle cost (LCC) savings and
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Enclosed
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
Open
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
the weighted average median payback
period.
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rate of 9.1 percent, DOE estimates that
TABLE I.6—IMPACTS OF PROPOSED
STANDARDS ON CONSUMERS OF the industry net present value (INPV)
for manufacturers of electric motors is
ELECTRIC MOTORS
Weighted
average
LCC
savings *
(2012$)
Equipment Class
Group 1.
Equipment Class
Group 2.
Equipment Class
Group 3.
Equipment Class
Group 4.
Weighted
average
median
payback
period *
(years)
132 .........
3.3
38 ...........
5.0
N/A ** ......
N/A **
259 .........
1.9
$3,371.2 million in 2012$. Under the
proposed standards, DOE expects that
manufacturers may lose up to 8.4
percent of their INPV, which
corresponds to approximately $283.5
million. Additionally, based on DOE’s
interviews with the manufacturers of
electric motors, DOE does not expect
any plant closings or significant loss of
employment based on the energy
conservation standards chosen in
today’s Notice of Proposed Rulemaking
(NOPR).
C. National Benefits and Costs 3
DOE’s analyses indicate that the
* The results for each equipment class
group (ECG) are a shipment weighted aver- proposed standards would save a
age of results for the representative units in significant amount of energy. Estimated
the group. ECG 1: Representative units 1, 2,
and 3; ECG 2: Representative units 4 and 5; lifetime savings for electric motors
ECG 3: Representative units 6, 7, and 8; ECG purchased over the 30-year period that
4: Representative units 9 and 10. The weight- begins in the year of compliance with
ed average lifetime in each equipment classes new and amended standards (2015–
is 15 years and ranges from 8 to 29 years depending on the motor horsepower and applica- 2044) would amount to 7.0 quads (fullfuel-cycle energy).4 The annualized
tion.
** For equipment class group 3, the pro- energy savings (0.23 quads) are
posed standard level is the same as the base- equivalent to one percent of total U.S.
line; thus, no customers are affected.
industrial primary energy consumption
in 2011.5
B. Impact on Manufacturers
The estimated cumulative net present
The industry net present value (INPV) value (NPV) of total consumer costs and
is the sum of the discounted cash flows
savings attributed to the proposed
to the industry from the base year
standards for electric motors ranges
through the end of the analysis period
from $8.7 billion (at a 7-percent
(2013 to 2044). Using a real discount
discount rate) to $23.3 billion (at a 3-
73595
percent discount rate). This NPV
expresses the estimated total value of
future operating-cost savings minus the
estimated increased equipment costs for
equipment purchased in 2015–2044.
In addition, the proposed standards
would have significant environmental
benefits. Estimated energy savings
would result in cumulative emission
reductions of 396 million metric tons
(Mt) 6 of carbon dioxide (CO2), 674
thousand tons of sulfur dioxide (SO2),
499 thousand tons of nitrogen oxides
(NOX) and 0.8 tons of mercury (Hg).7
Through 2030, the estimated energy
savings would result in cumulative
emissions reductions of 96 Mt of CO2.
The value of the CO2 reductions is
calculated using a range of values per
metric ton of CO2 (otherwise known as
the Social Cost of Carbon (SCC)
developed by an interagency process).8
The derivation of the SCC values is
discussed in section IV.M. DOE
estimates the present monetary value of
the CO2 emissions reduction is between
$2.5 and $36.6 billion. DOE also
estimates the present monetary value of
the NOX emissions reduction is $0.3
billion at a 7-percent discount rate and
$0.6 billion at a 3-percent discount
rate.9
Table I.7 summarizes the national
economic costs and benefits expected to
result from the proposed standards for
electric motors.
TABLE I.7—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF ELECTRIC MOTORS ENERGY CONSERVATION
STANDARDS, PRESENT VALUE FOR MOTORS SHIPPED IN 2015–2044 IN BILLION 2012$
Present value
billion 2012$
Category
Benefits:
Consumer Operating Cost Savings ......................................................................................................
14.8
34.9
2.5
11.8
18.9
36.6
0.3
0.6
Costs:
Consumer Incremental Installed Costs ................................................................................................
7
3
6.1
11.7
Total Benefits † .................................................................................................................................
7
3
5
3
2.5
3
7
3
26.9
47.4
CO2 Reduction Monetized Value ($11.8/t case) * ................................................................................
CO2 Reduction Monetized Value ($39.7/t case) * ................................................................................
CO2 Reduction Monetized Value ($61.2/t case) * ................................................................................
CO2 Reduction Monetized Value ($117.0/t case) * ..............................................................................
NOX Reduction Monetized Value (at $2,639/ton) ** .............................................................................
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Discount rate
(%)
7
3
Net Benefits:
3 All monetary values in this section are
expressed in 2012 dollars and are discounted to
2013.
4 One quad (quadrillion Btu) is the equivalent of
293.1 billion kilowatt hours (kWh) or 172.3 million
barrels of oil.
5 Based on U.S. Department of Energy, Energy
Information Administration, Annual Energy
Outlook (AEO) 2013 data.
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6 A metric ton is equivalent to 1.1 short tons.
Results for NOX and Hg are presented in short tons.
7 DOE calculates emissions reductions relative to
the AEO2013 reference case, which generally
represents current legislation and environmental
regulations for which implementing regulations
were available as of December 31, 2012.
8 Technical Update of the Social Cost of Carbon
for Regulatory Impact Analysis Under Executive
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Order 12866. Interagency Working Group on Social
Cost of Carbon, United States Government. May
2013; revised November 2013. https://
www.whitehouse.gov/sites/default/files/omb/assets/
inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf.
9 DOE is currently investigating valuation of
avoided Hg and SO2 emissions.
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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE I.7—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF ELECTRIC MOTORS ENERGY CONSERVATION
STANDARDS, PRESENT VALUE FOR MOTORS SHIPPED IN 2015–2044 IN BILLION 2012$—Continued
Present value
billion 2012$
Category
Including CO2 and NOX Reduction Monetized Value ..........................................................................
Discount rate
(%)
20.8
35.7
7
3
* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC
from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile
SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature
change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate
an escalation factor.
** The value represents the average of the low and high NOX values used in DOE’s analysis.
† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to SCC value of $39.7/t in 2015.
The benefits and costs of today’s
proposed standards for electric motors,
sold in years 2015–2044, can also be
expressed in terms of annualized values.
The annualized monetary values are the
sum of (1) the annualized national
economic value of the benefits from
operation of the commercial and
industrial equipment that meet the
proposed standards (consisting
primarily of operating cost savings from
using less energy, minus increases in
equipment purchase and installation
costs, which is another way of
representing consumer NPV), and (2)
the annualized monetary value of the
benefits of emission reductions,
including CO2 emission reductions.10
Although combining the values of
operating savings and CO2 emission
reductions provides a useful
perspective, two issues should be
considered. First, the national operating
savings are domestic U.S. consumer
monetary savings that occur as a result
of market transactions while the value
of CO2 reductions is based on a global
value. Second, the assessments of
operating cost savings and CO2 savings
are performed with different methods
that use different time frames for
analysis. The national operating cost
savings is measured over the lifetime of
electric motors shipped in years 2015–
2044. The SCC values, on the other
hand, reflect the present value of some
future climate-related impacts resulting
from the emission of one ton of carbon
dioxide in each year. These impacts
continue well beyond 2100.
Estimates of annualized benefits and
costs of the proposed standards for
electric motors are shown in Table I.8.
The results under the primary estimate
are as follows. Using a 7-percent
discount rate for benefits and costs other
than CO2 reduction, for which DOE
used a 3-percent discount rate along
with the average SCC series that uses a
3-percent discount rate, the cost of the
standards proposed in today’s rule is
$462 million per year in increased
equipment costs; while the estimated
benefits are $1,114 million per year in
reduced equipment operating costs,
$586 million in CO2 reductions, and
$21.5 million in reduced NOX
emissions. In this case, the net benefit
would amount to $957 million per year.
Using a 3-percent discount rate for all
benefits and costs and the average SCC
series, the estimated cost of the
standards proposed in today’s rule is
$577 million per year in increased
equipment costs; while the estimated
benefits are $1,730 million per year in
reduced operating costs, $586 million in
CO2 reductions, and $31.5 million in
reduced NOX emissions. In this case, the
net benefit would amount to
approximately $1,354 million per year.
TABLE I.8—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR ELECTRIC
MOTORS, IN MILLION 2012$
Discount rate
Primary estimate *
Low net benefits
estimate *
High net benefits
estimate *
million 2012$/year
Benefits:
Consumer Operating Cost Savings ...........................
CO2 Reduction Monetized Value ($11.8/t case) * .....
CO2 Reduction Monetized Value ($39.7/t case) * .....
CO2 Reduction Monetized Value ($61.2/t case) * .....
CO2 Reduction Monetized Value ($117.0/t case) * ...
NOX Reduction Monetized Value (at $2,639/ton) ** ..
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Total Benefits † .......................................................
7% ..............................
3% ..............................
5% ..............................
3% ..............................
2.5% ...........................
3% ..............................
7% ..............................
3% ..............................
7%
7%
3%
3%
plus CO2 range ....
..............................
plus CO2 range ....
..............................
1,114
1,730
155
586
882
1,811
21.46
31.48
924
1,421
134
506
762
1,565
18.55
27.20
1,358
2,134
179
679
1022
2,098
24.68
36.39
1,290 to 2,947
1,721
1,916 to 3,572
2,347
1,077 to 2,507
1,449
1,583 to 3,014
1,955
1,562 to 3,481
2,061
2,350 to 4,268
2,849
Costs:
10 DOE used a two-step calculation process to
convert the time-series of costs and benefits into
annualized values. First, DOE calculated a present
value in 2013, the year used for discounting the
NPV of total consumer costs and savings, for the
time-series of costs and benefits using discount
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rates of three and seven percent for all costs and
benefits except for the value of CO2 reductions. For
the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE
then calculated the fixed annual payment over a 30year period (2015 through 2044) that yields the
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same present value. The fixed annual payment is
the annualized value. Although DOE calculated
annualized values, this does not imply that the
time-series of cost and benefits from which the
annualized values were determined is a steady
stream of payments.
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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
73597
TABLE I.8—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR ELECTRIC
MOTORS, IN MILLION 2012$—Continued
Discount rate
Incremental Installed Costs .......................................
Net Benefits:
Total † .........................................................................
Primary estimate *
7% ..............................
3% ..............................
7%
7%
3%
3%
plus CO2 range ....
..............................
plus CO2 range ....
..............................
Low net benefits
estimate *
High net benefits
estimate *
462
577
492
601
447
569
585 to 2,016
957
982 to 2,413
1,354
1,115 to 3,033
1,614
1,781 to 3,700
2,280
1,353 to 3,438
1,887
1,957 to 4,043
2,492
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
* This table presents the annualized costs and benefits associated with electric motors shipped in 2015–2044. These results include benefits to
consumers which accrue after 2044 from the equipment purchased in years 2015–2044. Costs incurred by manufacturers, some of which may
be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The Primary,
Low Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy Outlook (AEO) 2013 Reference
case, Low Estimate, and High Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected equipment
price in the Primary Estimate, a declining rate for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC
from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile
SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature
change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate
an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount
rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled
discount rate, and those values are added to the full range of CO2 values.
DOE has tentatively concluded that
the proposed standards represent the
maximum improvement in energy
efficiency that is technologically
feasible and economically justified, and
would result in the significant
conservation of energy. DOE further
notes that equipment achieving these
standard levels are already
commercially available for most
equipment classes covered by today’s
proposal. Based on the analyses
described above, DOE has tentatively
concluded that the benefits of the
proposed standards to the Nation
(energy savings, positive NPV of
consumer benefits, consumer LCC
savings, and emission reductions)
would outweigh the burdens (loss of
INPV for manufacturers and LCC
increases for some consumers).
DOE also considered more-stringent
energy efficiency levels as trial standard
levels, and is still considering them in
this rulemaking. However, DOE has
tentatively concluded that the potential
burdens of the more-stringent energy
efficiency levels would outweigh the
projected benefits. Depending on the
comments that DOE receives in
response to this notice and related
information collected and analyzed
during the course of this rulemaking,
DOE may adopt energy efficiency levels
presented in this notice that are either
higher or lower than the proposed
standards, or some combination of
level(s) that incorporate the proposed
standards in part.
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II. Introduction
The following section briefly
discusses the statutory authority
underlying today’s proposed rule, as
well as some relevant historical
background related to the establishment
of standards for electric motors.
A. Authority
Title III, Part B of the Energy Policy
and Conservation Act of 1975 (EPCA or
the Act), Public Law 94–163, as
amended (42 U.S.C. 6291–6309)
established the ‘‘Energy Conservation
Program for Consumer Products Other
Than Automobiles.’’ Part C of Title III of
EPCA (42 U.S.C. 6311–6317) established
a similar program for ‘‘Certain Industrial
Equipment,’’ including electric
motors.11 The Energy Policy Act of 1992
(EPACT 1992) (Pub. L. 102–486)
amended EPCA by establishing energy
conservation standards and test
procedures for certain commercial and
industrial electric motors (in context,
‘‘motors’’) manufactured (alone or as a
component of another piece of
equipment) after October 24, 1997. In
December 2007, Congress passed into
law the Energy Independence and
Security Act of 2007 (EISA 2007) (Pub.
L. 110–140). Section 313(b)(1) of EISA
2007 updated the energy conservation
standards for those electric motors
already covered by EPCA and
established energy conservation
standards for a larger scope of motors
11 For editorial reasons, upon codification in the
U.S. Code, Parts B and C were redesignated as Parts
A and A–1, respectively.
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not previously covered by standards. (42
U.S.C. 6313(b)(2)) EPCA directs the
Secretary of Energy to publish a final
rule no later than 24 months after the
effective date of the previous final rule
to determine whether to amend the
standards already in effect. Any such
amendment shall apply to electric
motors manufactured after a date which
is five years after either: (1) The
effective date of the previous
amendment or (2) if the previous final
rule did not amend the standards, the
earliest date by which a previous
amendment could have been effective.
(42 U.S.C. 6313(b)(4)(B))
DOE is issuing today’s proposal
pursuant to Part C of Title III, which
establishes an energy conservation
program for covered equipment that
consists essentially of four parts: (1)
Testing; (2) labeling; (3) the
establishment of Federal energy
conservation standards; and (4)
certification and enforcement
procedures. For those electric motors for
which Congress established standards,
or for which DOE amends or establishes
standards, the DOE test procedure must
be the prescribed procedures that
currently appear at 10 CFR part 431 that
apply to electric motors. The test
procedure is subject to review and
revision by the Secretary in accordance
with certain criteria and conditions.
(See 42 U.S.C. 6314(a))
Section 343(a)(5)(B)–(C) of EPCA, 42
U.S.C. 6314(a)(5)(B)–(C), provides in
part that if the NEMA- and IEEEdeveloped test procedures are amended,
DOE shall so amend the test procedures
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Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
under 10 CFR part 431, unless the
Secretary determines, by rule, that the
amended industry procedures would
not meet the requirements for test
procedures to produce results that
reflect energy efficiency, energy use,
and estimated operating costs of the
tested motor, or, would be unduly
burdensome to conduct. (42 U.S.C.
6314(a)(2)–(3), (a)(5)(B)) As newer
versions of the NEMA and IEEE test
procedures for electric motors were
developed, DOE updated 10 CFR part
431 to reflect these changes.
Manufacturers of covered equipment
must use the prescribed DOE test
procedure as the basis for certifying to
DOE that their equipment complies with
the applicable energy conservation
standards adopted under EPCA and
when making representations to the
public regarding the energy use or
efficiency of such equipment. (42 U.S.C.
6314(d)) Similarly, DOE must use these
test procedures to determine whether
the equipment comply with standards
adopted pursuant to EPCA. Id.
DOE must follow specific statutory
criteria for prescribing new and
amended standards for covered
equipment. In the case of electric
motors, the criteria set out in relevant
subsections of 42 U.S.C. 6295, which
normally applies to standards related to
consumer products, also apply to the
setting of energy conservation standards
for motors via 42 U.S.C. 6316(a). As
indicated above, new and amended
standards must be designed to achieve
the maximum improvement in energy
efficiency that is technologically
feasible and economically justified. (42
U.S.C. 6295(o)(2)(A) and 6316(a))
Furthermore, DOE may not adopt any
standard that would not result in the
significant conservation of energy. (42
U.S.C. 6295(o)(3) and 6316(a))
Moreover, DOE may not prescribe a
standard: (1) For certain equipment,
including electric motors, if no test
procedure has been established for the
product, or (2) if DOE determines by
rule that the proposed standard is not
technologically feasible or economically
justified. (42 U.S.C. 6295(o)(3)(A)–
6316(a)) In deciding whether a proposed
standard is economically justified, DOE
must determine whether the benefits of
the standard exceed its burdens. (42
U.S.C. 6295(o)(2)(B)(i) and 6316(a)) DOE
must make this determination after
receiving comments on the proposed
standard, and by considering, to the
greatest extent practicable, the following
seven factors:
1. The economic impact of the
standard on manufacturers and
consumers of the products subject to the
standard;
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2. The savings in operating costs
throughout the estimated average life of
the covered products in the type (or
class) compared to any increase in the
price, initial charges, or maintenance
expenses for the covered products that
are likely to result from the imposition
of the standard;
3. The total projected amount of
energy, or as applicable, water, savings
likely to result directly from the
imposition of the standard;
4. Any lessening of the utility or the
performance of the covered 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 and
water conservation; and
7. Other factors the Secretary of
Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII) and
6316(a))
EPCA, as codified, also contains what
is known as an ‘‘anti-backsliding’’
provision, which prevents the Secretary
from prescribing any new or amended
standards that either increase the
maximum allowable energy use or
decrease the minimum required energy
efficiency of a covered product. (42
U.S.C. 6295(o)(1) and 6316(a)) Also, the
Secretary may not prescribe an amended
or new standard if interested persons
have established by a preponderance of
the evidence that the standard is likely
to result in the unavailability in the
United States of any covered product
type (or class) of performance
characteristics (including reliability),
features, sizes, capacities, and volumes
that are substantially the same as those
generally available in the United States.
(42 U.S.C. 6295(o)(4) and 6316(a))
Further, EPCA, as codified,
establishes a rebuttable presumption
that a standard is economically justified
if the Secretary finds that the additional
cost to the consumer of purchasing a
product complying with an energy
conservation standard level will be less
than three times the value of the energy
savings during the first year that the
consumer will receive as a result of the
standard, as calculated under the
applicable test procedure. (42 U.S.C.
6295(o)(2)(B)(iii) and 6316(a))
Additionally, 42 U.S.C. 6295(q)(1), as
applied to covered equipment via 42
U.S.C. 6316(a), specifies requirements
when promulgating a standard for a type
or class of covered product that has two
or more subcategories. DOE must
specify a different standard level than
that which applies generally to such
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type or class of equipment for any group
of covered equipment that have the
same function or intended use if DOE
determines that equipment within such
group: (A) Consume a different kind of
energy from that consumed by other
covered equipment within such type (or
class); or (B) have a capacity or other
performance-related feature which other
equipment within such type (or class)
do not have and such feature justifies a
higher or lower standard. (42 U.S.C.
6294(q)(1) and 6316(a)). In determining
whether a performance-related feature
justifies a different standard for a group
of products, DOE must consider such
factors as the utility to the consumer of
the feature and other factors DOE deems
appropriate. Id. Any rule prescribing
such a standard must include an
explanation of the basis on which such
higher or lower level was established.
(42 U.S.C. 6295(q)(2) and 6316(a))
Federal energy conservation
requirements generally supersede State
laws or regulations concerning energy
conservation testing, labeling, and
standards. (42 U.S.C. 6297(a)–(c) and
6316(a)) DOE may, however, grant
waivers of Federal preemption for
particular State laws or regulations, in
accordance with the procedures and
other provisions set forth under 42
U.S.C. 6297(d)).
B. Background
1. Current Standards
An electric motor is a device that
converts electrical power into rotational
mechanical power. The outside
structure of the motor is called the
frame, which houses a rotor (the
spinning part of the motor) and the
stator (the stationary part that creates a
magnetic field to drive the rotor).
Although many different technologies
exist, DOE’s rulemaking is concerned
with squirrel-cage induction motors,
which represent the majority of electric
motor energy use. In squirrel-cage
induction motors, the stator drives the
rotor by inducing an electric current in
the squirrel-cage, which then reacts
with the rotating magnetic field to
propel the rotor in the same way a
person can repel one handheld magnet
with another. The squirrel-cage used in
the rotor of induction motors consists of
longitudinal conductive bars (rotor bars)
connected at both ends by rings (end
rings) forming a cage-like shape. Among
other design parameters, motors can
vary in horsepower, number of ‘‘poles’’
(which determines how quickly the
motor rotates), and torque
characteristics. Most motors have
‘‘open’’ frames that allow cooling
airflow through the motor body, though
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some have enclosed frames that offer
added protection from foreign
substances and bodies. DOE regulates
various motor types from between 1 and
500 horsepower, with 2, 4, 6, and 8
poles, and with both open and enclosed
frames.
EPACT 1992 amended EPCA by
establishing energy conservation
standards and test procedures for
certain commercial and industrial
electric motors manufactured either
alone or as a component of another
piece of equipment after October 24,
1997. Section 313 of EISA 2007
amended EPCA by: (1) Striking the
definition of ‘‘electric motor’’ provided
under EPACT 1992, (2) setting forth
definitions for ‘‘general purpose electric
motor (subtype I)’’ and ‘‘general purpose
electric motor (subtype II),’’ and (3)
prescribing energy conservation
standards for ‘‘general purpose electric
motors (subtype I),’’ ‘‘general purpose
electric motors (subtype II), ‘‘fire pump
electric motors,’’ and ‘‘NEMA Design B
general purpose electric motors’’ with a
power rating of more than 200
horsepower but not greater than 500
horsepower. (42 U.S.C. 6311(13),
6313(b)). The current standards for these
motors, which are reproduced in the
proposed regulatory text at the end of
this notice, are divided into four tables
that prescribe specific efficiency levels
for each of those groups of motors.
2. History of Standards Rulemaking for
Electric Motors
On October 5, 1999, DOE published in
the Federal Register, a final rule to
implement the EPACT 1992 electric
motor requirements. 64 FR 54114. In
response to EISA 2007, on March 23,
2009, DOE updated, among other things,
the corresponding electric motor
regulations at 10 CFR part 431 with the
new definitions and energy
conservation standards. 74 FR 12058.
On December 22, 2008, DOE proposed
to update the test procedures under 10
CFR part 431 both for electric motors
and small electric motors. 73 FR 78220.
DOE finalized key provisions related to
small electric motor testing in a 2009
final rule at 74 FR 32059 (July 7, 2009),
and further updated the test procedures
for electric motors and small electric
motors at 77 FR 26608 (May 4, 2012).
The May 2012 final rule primarily
focused on updating various definitions
and incorporations by reference related
to the current test procedure. In that
rule, DOE promulgated a regulatory
definition of ‘‘electric motor’’ to account
for EISA 2007’s removal of the previous
statutory definition of ‘‘electric motor.’’
DOE also clarified definitions related to
those motors that EISA 2007 laid out as
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part of EPCA’s statutory framework,
including motor types that DOE had not
previously regulated. See generally, id.
at 26613–26619. DOE published a new
proposed test procedure rulemaking on
June 26, 2013, that proposes to further
refine some existing electric motor
definitions and add certain definitions
and test procedure preparatory steps to
address a wider variety of electric motor
types than are currently regulated. 78
FR 38456.
Regarding the compliance date that
would apply to the requirements of
today’s proposed rule, EPCA directs the
Secretary of Energy to publish a final
rule no later than 24 months after the
effective date of the previous final rule
to determine whether to amend the
standards in effect for such equipment.
Any such amendment shall apply to
electric motors manufactured after a
date which is five years after: (i) The
effective date of the previous
amendment; or (ii) if the previous final
rule did not amend the standards, the
earliest date by which a previous
amendment could have been effective.
(42 U.S.C. 6313(b)(4))
As described previously, EISA 2007
constitutes the most recent amendment
to EPCA and energy conservation
standards for electric motors. Because
these amendments required compliance
on December 19, 2010, DOE had
indicated during the course of public
meetings held in advance of today’s
proposal that motors manufactured after
December 19, 2015, would need to
comply with any applicable new
standards that DOE may set as part of
this rulemaking. Today’s proposed
standards would apply to motors
manufactured starting on December 19,
2015. As noted in detail later in this
notice, however, DOE is interested in
receiving comments on the ability of
manufacturers to meet this deadline.
DOE received numerous comments
from interested parties who provided
significant input to DOE in response to
the framework document and
preliminary analysis that the agency had
issued. See 75 FR 59657 (Sept. 28, 2010)
(framework document notice of
availability) and 77 FR 43015 (July 23,
2012) (preliminary analysis notice of
availability). During the framework
document comment period for this
rulemaking, several interested parties
urged DOE to consider including
additional motor types currently
without energy conservation standards
in DOE’s analyses and establishing
standards for such motor types. In the
commenters’ view, this approach would
more effectively increase energy savings
than setting more stringent standards for
currently regulated electric motors. In
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73599
response, DOE published a Request for
Information (RFI) seeking public
comments from interested parties
regarding establishment of energy
conservation standards for several types
of definite and special purpose motors
for which EISA 2007 did not provide
energy conservation standards. 76 FR
17577 (March 30, 2011). DOE received
comments responding to the RFI
advocating that DOE regulate many of
the electric motors discussed in the RFI,
as well as many additional motor types.
Then, on August 15, 2012, a group of
interested parties (the ‘‘Motor
Coalition’’ 12) submitted a Petition to
DOE asking the agency to adopt a
consensus stakeholder proposal that
would amend the energy conservation
standards for electric motors. The Motor
Coalition’s proposal advocated
expanding the scope of coverage to a
broader range of motors than what DOE
currently regulates and it recommended
that energy conservation standards for
all covered electric motors be set at
levels that are largely equivalent to what
DOE proposes in today’s NOPR (i.e.,
efficiency levels in NEMA MG1–2011
Tables 12–12 and 20–B).13
DOE received several comments from
NEMA regarding the December 19,
2015, compliance date. First, NEMA
pointed out that all publications and
presentations prior to that preliminary
analysis public meeting on August 21,
2012, indicated that DOE’s statutory
deadline for any final rule was
December 19, 2012, but at the public
meeting DOE showed a final rule
completion date as the end of 2013.
(NEMA, No. 54 at pp. 2, 6–7) NEMA
questioned the authority by which DOE
has decided to delay the Final Rule
beyond the date of December 19, 2012,
as stipulated in EPCA. (NEMA, No. 54
at p. 2)
Second, NEMA commented that
shortening the time to comply with any
new standards from three years to two
years would place additional burdens
on manufacturers considering all of the
electric motors types that DOE is
considering in the preliminary TSD, the
burdensome candidate standard levels
that DOE is considering, and the
12 The members of the Motor Coalition include:
National Electrical Manufacturers Association,
American Council for an Energy-Efficient Economy,
Appliance Standards Awareness Project, Alliance to
Save Energy, Earthjustice, Natural Resources
Defense Council, Northwest Energy Efficiency
Alliance, Northeast Energy Efficiency Partnerships,
and Northwest Power and Conservation Council.
13 DOE’s proposal differs from that of the Motor
Coalition in that DOE’s proposal covers brake
motors and does not set separate standards for Uframe motors. It also seeks supplemental
information regarding certain 56-frame motors. See
section IV.A.2 for details.
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possibility of expanding the scope of
energy conservation standards. (NEMA,
No. 54 at pp. 2, 7; NEMA, Public
Meeting Transcript, No. 60 at p. 30)
Third, NEMA also noted that when
EPACT 1992 first added electric motors
as covered equipment, motor
manufacturers were allowed five years
to modify motor designs and certify
compliance to the new standards.
(NEMA, No. 54 at p. 7) It further noted
that NEMA MG 1–1998 subsequently
introduced NEMA Premium efficiency
standards, and between 1998 and 2007
manufacturers voluntarily increased the
number of NEMA Premium efficiency
motor models available. (NEMA, No. 54
at p. 7) NEMA commented that this
transition period eased the burden of
satisfying the added stringency of the
standards set by EISA 2007, which
allowed three years to update energy
conservation standards to mandatory
NEMA Premium levels for certain motor
ratings. (NEMA, No. 54 at p. 7) NEMA
added that adhering to the statutory
deadline for setting any new and
amended standards would minimize
any disruption in the electric motor
market. (NEMA, No. 54 at p. 8) NEMA
also commented that since the EISA
2007 standards were enacted, only a
limited number of motor ratings above
NEMA Premium have been offered
because there is not sufficient space
available in most frame ratings to
increase the efficiency. (NEMA, No. 54
at p. 7) NEMA added that any standards
above NEMA Premium would force
manufacturers to redesign entire
product lines and go through the
process of certification and compliance,
all of which would be expected to take
longer than three years. (NEMA, No. 54
at pp. 7, 8)
Finally, NEMA also attempted to
illustrate the difficulty of reaching
NEMA Premium levels in IEC frame
motors, noting that a comparison of
certificates of compliance before and
after EISA 2007 standards went into
effect would demonstrate that some
manufacturers were forced to abandon
the U.S. electric motor market for some
period of time before they could update
their IEC frame motor product line.
(NEMA, No. 54 at p. 8) NEMA added
that increasing the efficiency of subtype
II motors to NEMA Premium efficiency
and expanding the scope of motors
subject to energy conservation standards
(many of which currently have
efficiency levels below EPACT 1992
energy conservation levels) will also
require extensive redesign, and
manufacturers would be forced to
comply in only three years. (NEMA, No.
54 at p. 8)
During the course of preparing for the
electric motors energy conservation
standards rulemaking, information was
submitted to DOE by NEMA, ASAP, and
CDA in response to DOE’s RFI and then
later in the Petition from the Motors
Coalition 14 that caused DOE to
reevaluate the scope of electric motors
it was considering in this rulemaking.
That Petition, and related supporting
information, suggested that DOE apply
the NEMA Premium efficiency levels
(‘‘NEMA Premium’’) to a much broader
swath of electric motors than are
currently regulated by DOE, rather than
increase the stringency of the standards
that had only recently come into effect
(i.e., EISA 2007 standards). As part of its
routine practice, DOE reviewed the
information and the merits of the
Petition. With the potential prospect of
expanding the types of motors that
would be regulated by standards, DOE
recognized the need to amend its test
procedures to add the necessary testing
preparatory steps (i.e. test set-up
procedures) to DOE’s regulations. The
inclusion of these steps would help
ensure that manufacturers of these new
motor types would be performing the
same steps as are performed when
testing currently regulated motors.
The compliance date prescribed by
statute would require manufacturers to
begin manufacturing compliant motors
by December 19, 2015. Accordingly,
DOE is proposing a December 19, 2015,
compliance date. DOE, however,
recognizes that the statute also
contemplated a three-year lead time for
manufacturers in order to account for
the potential logistical and production
hurdles that manufacturers may face
when transitioning to the new
standards. Accordingly, while DOE is
proposing a December 19, 2015
compliance deadline, it is also
interested in comments that detail any
hurdles with meeting this compliance
deadline along with the merits of
receiving the three-year lead-time also
set out in the statute.
3. Process for Setting Energy
Conservation Standards
Section 325(o) provides criteria for
prescribing new or amended standards
which are designed to achieve the
maximum improvement in energy
efficiency and for which the Secretary of
Energy determines are technologically
feasible and economically justified.
Consequently, DOE must consider, to
the greatest extent practicable, the
following seven factors: (1) The
economic impact of the standard on the
manufacturers and consumers of the
products subject to the standard; (2) the
savings in operating costs throughout
the estimated average life of the
products compared to any increase in
the prices, initial costs, or maintenance
expenses for the products that are likely
to result from the imposition of the
standard; (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 covered 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 6316(a))
Other statutory requirements are set
forth in 42 U.S.C. 6295(o)(1)–(2)(A),
(2)(B)(ii)–(iii), and (3)–(4). These criteria
apply to the setting of standards for
electric motors through 42 U.S.C.
6316(a).
III. General Discussion
DOE developed today’s proposed rule
after considering input, including verbal
and written comments, data, and
information from interested parties that
represent a variety of interests. All
commenters, along with their
corresponding abbreviations and
affiliations, are listed in Table III.1
below. The issues raised by these
commenters are addressed in the
discussions that follow.
TABLE III.1—SUMMARY OF COMMENTERS
Company or organization
Abbreviation
Air Movement and Control Association International, Inc.
AMCAI ........................
Affiliation
Trade Association.
14 The Petition is available at: https://
www.regulations.gov/#!documentDetail;D=EERE2010-BT-STD-0027-0035.
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TABLE III.1—SUMMARY OF COMMENTERS—Continued
Company or organization
Abbreviation
Affiliation
Alliance to Save Energy .................................
American Council for an
Energy-Efficient Economy.
Appliance Standards Awareness Project .......
Baldor Electric Co. ..........................................
BBF & Associates ...........................................
California Investor Owned Utilities .................
Copper Development Association ..................
Earthjustice .....................................................
Electric Apparatus Service Association ..........
Flolo Corporation ............................................
Industrial Energy Consumers of America .......
Motor Coalition * ..............................................
ASE ............................
ACEEE .......................
Energy Efficiency Advocates.
Energy Efficiency Advocates.
ASAP .........................
Baldor .........................
BBF ............................
CA IOUs .....................
CDA ...........................
Earthjustice ................
EASA .........................
Flolo ...........................
IECA ...........................
MC .............................
National Electrical Manufacturers Association
Northwest Energy Efficiency Alliance .............
Northwest Power & Conservation Council .....
SEW-Eurodrive, Inc. .......................................
UL LLC ............................................................
NEMA .........................
NEEA .........................
NPCC .........................
SEWE ........................
UL ..............................
Energy Efficiency Advocates.
Manufacturers.
Representative for Trade Association.
Utilities.
Trade Association.
Energy Efficiency Advocates.
Trade Association.
Other.
Trade Association.
Energy Efficiency Advocates, Trade Associations, Manufacturers, Utilities.
Trade Association.
Energy Efficiency Advocates.
Utilities.
Manufacturer.
Testing Laboratory.
* The members of the Motor Coalition include: National Electrical Manufacturers Association (NEMA), American Council for an Energy-Efficient
Economy (ACEEE), Appliance Standards Awareness Project (ASAP), Alliance to Save Energy (ASE), Earthjustice, Natural Resources Defense
Council (NRDC), Northwest Energy Efficiency Alliance (NEEA), Northeast Energy Efficiency Partnerships (NEEP), and Northwest Power and
Conservation Council (NPCC).
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Subsequent to DOE’s preliminary
analysis public meeting, several other
interested parties submitted comments
supporting the Petition. Those
supporters included: BBF and
Associates, the Air Movement and
Control Association International, Inc.,
U.S. Senators Lisa Murkowski and Jeff
Bingaman, the Hydraulic Institute, the
Arkansas Economic Development and
Commission-Energy Office, and the
Power Transmission Distributors
Association.
A. Test Procedure
On June 26, 2013, DOE published a
notice that proposed to incorporate
definitions for certain motor types not
currently subject to energy conservation
standards (78 FR 38456). The notice also
proposed to clarify several definitions
for motor types currently regulated by
energy conservation standards and
adding some necessary steps to facilitate
the testing of certain motor types that
DOE does not currently require to meet
standards. During its preliminary
analysis stage, DOE received comments
concerning definitions and test
procedure set-up steps suggested for
testing motors under an expanded scope
approach. DOE addressed the comments
as part of the test procedure NOPR. For
additional details, see 78 FR 38456
(June 26, 2013).
B. Equipment Classes and Current
Scope of Coverage
When evaluating and establishing
energy conservation standards, DOE
divides covered equipment into
equipment classes by the type of energy
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used or by capacity or other
performance-related features that would
justify a different standard. In making a
determination whether a performancerelated feature would justify a different
standard, DOE must consider factors
such as the utility to the consumer of
the feature and other factors that DOE
determines are appropriate. (42 U.S.C.
6295(q) and 6316(a))
Existing energy conservation
standards cover electric motors that fall
into four categories based on physical
design features of the motor. These four
categories are: General purpose electric
motors (subtype I), general purpose
electric motors (subtype II), fire pump
electric motors, and NEMA Design B
motors (with a horsepower rating from
201 through 500). Definitions for each of
these terms can be found at 10 CFR
431.12.
C. Expanded Scope of Coverage
DOE has the authority to set energy
conservation standards for a wider range
of electric motors than those classified
as general purpose electric motors (e.g.,
definite or special purpose motors).
EPACT 1992 amended EPCA to include,
among other things, a definition for the
term ‘‘electric motor’’—which the
statute defined as including certain
‘‘general purpose’’ motors. (42 U.S.C.
6311(13)(A) (1992)) The amendments
also defined the terms ‘‘definite purpose
motors’’ and ‘‘special purpose motor.’’
(42 U.S.C. 6311(13)(C) and (D)) (1992))
EPACT 1992 initially prescribed energy
conservation standards for ‘‘electric
motors’’ (i.e., subtype I general purpose
electric motors) and explicitly stated
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that these standards did not apply to
definite purpose or special purpose
motors. (42 U.S.C. 6313(b)(1) (1992))
However, EISA 2007 struck the narrow
EPACT 1992 definition of ‘‘electric
motor.’’ With the removal of this
definition, the term ‘‘electric motor’’
became broader in scope. As a result of
these changes, both definite and special
purpose motors fell under the broad
heading of ‘‘electric motors’’ that
previously only applied to ‘‘general
purpose’’ motors. While EISA 2007
prescribed standards for general
purpose motors, the Act did not apply
those standards to definite or special
purpose motors. (42 U.S.C. 6313(b)
(2012))
Although DOE believes that EPCA, as
amended through EISA 2007, provides
sufficient statutory authority for the
regulation of special purpose and
definite purpose motors as ‘‘electric
motors,’’ DOE notes it has additional
authority under section 10 of the
American Energy Manufacturing
Technical Corrections Act, Public Law
112–210, which amended DOE’s
authority to regulate commercial and
industrial equipment under section
340(2)(B) of EPCA to include ‘‘other
motors,’’ in addition to ‘‘electric
motors’’. (42 U.S.C. 6311(2)(B)(xiii)).
Therefore, even if special and definite
purpose motors were not ‘‘electric
motors,’’ special and definite purpose
motors would be considered as ‘‘other
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motors’’ that EPCA already treats as
covered industrial equipment.15
Consistent with EISA 2007’s
reworking of the definition, the 2012
test procedure final rule broadly defined
the term ‘‘electric motor.’’ at 10 CFR
431.12. (77 FR 26608 (May 4, 2012)).
That definition covers ‘‘general
purpose,’’ ‘‘special purpose’’ and
‘‘definite purpose’’ electric motors (as
defined by EPCA). As noted above,
EPCA did not require either ‘‘special
purpose’’ or ‘‘definite purpose’’ motor
types to meet energy conservation
standards because they were not
considered ‘‘general purpose’’ under the
EPCA definition of ‘‘general purpose
motor’’—a necessary element to meet
the pre-EISA 2007 ‘‘electric motor’’
definition. See 77 FR 26612. Because of
the restrictive nature of the prior electric
motor definition, along with the
restrictive definition of the term
‘‘industrial equipment,’’ DOE would
have been unable to set standards for
such motors without this change. (See
42 U.S.C. 6311(2)(B) (2006) (limiting the
scope of equipment covered under
15 EPCA specifies the types of industrial
equipment that can be classified as covered in
addition to the equipment enumerated in 42 U.S.C.
6311(1). This equipment includes ‘‘other motors’’
(to be codified at 42 U.S.C. 6311(2)(B)). Industrial
equipment must also, without regard to whether
such equipment is in fact distributed in commerce
for industrial or commercial use, be of a type that:
(1) In operation consumes, or is designed to
consume, energy in operation; (2) to any significant
extent, is distributed in commerce for industrial or
commercial use; and (3) is not a covered product
as defined in 42 U.S.C. 6291(a)(2) of EPCA, other
than a component of a covered product with respect
to which there is in effect a determination under 42
U.S.C. 6312(c). (42 U.S.C. 6311 (2)(A)). Data from
the 2002 United States Industrial Electric Motor
Systems Market Opportunities Assessment
estimated total energy use from industrial motor
systems to be 747 billion kWh. Based on the
expansion of industrial activity, it is likely that
current annual electric motor energy use is higher
than this figure. Electric motors are distributed in
commerce for both the industrial and commercial
sectors. According to data provided by the Motor
Coalition, the number of electric motors
manufactured in, or imported into, the United
States is over five million electric motors annually,
including special and definite purpose motors.
Finally, special and definite purpose motors are not
currently regulated under Title 10 of the Code of
Federal Regulations, part 430 (10 CFR part 430).
To classify equipment as covered commercial or
industrial equipment, the Secretary must also
determine that classifying the equipment as covered
equipment is necessary for the purposes of Part A–
1 of EPCA. The purpose of Part A–1 is to improve
the efficiency of electric motors, pumps and certain
other industrial equipment to conserve the energy
resources of the nation. (42 U.S.C. 6312(a)–(b)) In
today’s proposal, DOE has tentatively determined
that the regulation of special and definite purpose
motors is necessary to carry out the purposes of part
A–1 of EPCA because regulating these motors will
promote the conservation of energy supplies.
Efficiency standards that may result from coverage
would help to capture some portion of the potential
for improving the efficiency of special and definite
purpose motors.
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EPCA)) In view of the changes
introduced by EISA 2007 and the
absence of energy conservation
standards for special purpose and
definite purpose motors, as noted in
chapter 2 of DOE’s July 2012 electric
motors preliminary analysis technical
support document (TSD),16 it is DOE’s
view that both of these motors are
categories of ‘‘electric motors’’ covered
under EPCA, as currently amended.
Accordingly, DOE is proposing
standards for certain definite purpose
and special purpose motors. To this
end, DOE is considering setting energy
conservation standards for those motors
that exhibit all of the following nine
characteristics:
• Is a single-speed, induction motor,
• Is rated for continuous duty (MG 1)
operation or for duty type S1 (IEC),
• Contains a squirrel-cage (MG 1) or
cage (IEC) rotor,
• Operates on polyphase alternating
current 60-hertz sinusoidal line power,
• Is rated 600 volts or less,
• Has a 2-, 4-, 6-, or 8-pole
configuration,
• Has a three-digit NEMA frame size
(or IEC metric equivalent) or an
enclosed 56 NEMA frame size (or IEC
metric equivalent),
• Has no more than 500 horsepower,
but greater than or equal to 1
horsepower (or kilowatt equivalent),
and
• Meets all of the performance
requirements of a NEMA Design A, B, or
C electric motor or an IEC design N or
H electric motor.
However, motor types that exhibit all
of the characteristics listed above, but
that DOE does not believe should be
subject to energy conservation standards
at this time because of the current
absence of a reliable and repeatable
method to test them for efficiency,
would be listed as motors that would
not at this time be subject to energy
conservation standards. Once a test
procedure becomes available, DOE may
consider setting standards for these
motors at that time. See generally, 78 FR
38456 (June 26, 2013). DOE requests
comment on these nine characteristics
and their appropriateness for outlining
scope of coverage.
To facilitate the potential application
of energy conservation standards to
special and definite purpose motors,
DOE proposed to define such motors
and provide certain preparatory test
procedure steps. 78 FR 38456 (June 26,
2013). The definitions under
16 The preliminary TSD published in July 2012 is
available at: https://www.regulations.gov/
#!documentDetail;D=EERE-2010-BT-STD-00270023.
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consideration would address motors
currently subject to standards, specific
motors DOE is considering requiring to
meet standards, and some motors that
will continue to not be required to meet
particular energy conservation
standards. Some of the clarifying
definitions, such as the definitions for
NEMA Design A and C electric motors,
come from NEMA Standards
Publication MG 1–2009, ‘‘Motors and
Generators.’’ DOE understands that
some of the motors addressed, such as
partial motors and integral brake
motors, do not have standard industryaccepted definitions. For such motor
types, DOE worked with subject-matter
experts (SMEs), manufacturers, and the
Motor Coalition to create the working
definitions that are proposed in the test
procedure NOPR. (8 FR 38456 (June 26,
2013).
D. Technological Feasibility
1. General
EPCA requires that any new or
amended energy conservation standard
that DOE prescribes shall be designed to
achieve the maximum improvement in
energy efficiency that DOE determines
is technologically feasible. (42 U.S.C.
6295(o)(2)(A) and 6316(a)). In each
standards rulemaking, DOE conducts a
screening analysis based on information
gathered on all current technology
options and prototype designs that
could improve the efficiency of the
products or equipment that are the
subject of the rulemaking. As the first
step in such an analysis, DOE develops
a list of technology options for
consideration in consultation with
manufacturers, design engineers, and
other interested parties. DOE then
determines which of those means for
improving efficiency are technologically
feasible.
Where DOE determines that particular
technology options are technologically
feasible, it further evaluates each
technology option in view of the
following additional screening criteria:
(1) Practicability to manufacture, install,
or service; (2) adverse impacts on
product utility or availability; and (3)
adverse impacts on health or safety.
Section IV.B of this notice addresses the
results of the screening analysis for
electric motors, particularly the designs
DOE considered—those it screened out,
and those that are the basis for the trial
standard levels (TSLs) in this
rulemaking. For further details on the
screening analysis for this rulemaking,
see chapter 4 of the NOPR TSD.
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2. Maximum Technologically Feasible
Levels
When DOE proposes to adopt a new
or amended standard for a type or class
of covered product, it must determine
the maximum improvement in energy
efficiency or maximum reduction in
energy use that is technologically
feasible for such product. (42 U.S.C.
6295(p)(1)) This requirement also
applies to DOE proposals to amend the
standards for electric motors. See 42
U.S.C. 6316(a). Accordingly, in its
engineering analysis, DOE determined
the maximum technologically feasible
(‘‘max-tech’’) improvements in energy
efficiency for electric motors, using the
design parameters for the most efficient
motors available on the market or in
working prototypes. (See chapter 5 of
the NOPR TSD.) The max-tech levels
that DOE determined for this
rulemaking are described in section
IV.C.3 of this proposed rule.
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E. Energy Savings
1. Determination of Savings
Section 325(o) of EPCA also provides
that any new or amended energy
conservation standard that DOE
prescribes shall be designed to achieve
the maximum improvement in energy
efficiency that DOE determines is
economically justified. (42 U.S.C.
6295(o)(2)(A)–(B) and 6316(a)). In
addition, in determining whether such
standard is technologically feasible and
economically justified, DOE may not
prescribe standards for certain types or
classes of electric motors if such
standards would not result in significant
energy savings. (42 U.S.C. 6295(o)(3)(B)
and 6316(a)). For each TSL, DOE
projected energy savings from the
motors that would be covered under this
rulemaking and that would be
purchased in the 30-year period that
begins in the year of compliance with
the new and amended standards (2015–
2044). The savings are measured over
the entire lifetime of equipment
purchased in the 30-year period.17 DOE
quantified the energy savings
attributable to each TSL as the
difference in energy consumption
between each standards case and the
base case. The base case represents a
projection of energy consumption in the
absence of new or amended mandatory
efficiency standards, and considers
17 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
equipment 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.
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market forces and policies that affect
demand for more efficient equipment.
DOE used its national impact analysis
(NIA) spreadsheet model to estimate the
energy savings from new and amended
standards for the equipment that would
be subject to this rulemaking. The NIA
spreadsheet model (described in section
IV.H of this notice) calculates energy
savings in site energy, which is the
energy directly consumed by motors at
the locations where they are used. For
electricity, DOE reports national energy
savings in terms of the savings in the
energy that is used to generate and
transmit the site electricity. To calculate
source energy, DOE derives annual
conversion factors from the model used
to prepare the Energy Information
Administration’s (EIA) Annual Energy
Outlook (AEO).
DOE has begun to also estimate fullfuel-cycle energy savings. 76 FR 51282
(August 18, 2011), as amended at 77 FR
49701 (August 17, 2012). The full-fuelcycle (FFC) metric includes the energy
consumed in extracting, processing, and
transporting primary fuels, and thus
presents a more complete picture of the
impacts of energy efficiency standards.
DOE’s evaluation of FFC savings is
driven in part by the National Academy
of Science’s (NAS) report on FFC
measurement approaches for DOE’s
Appliance Standards Program.18 The
NAS report discusses that FFC was
primarily intended for energy efficiency
standards rulemakings where multiple
fuels may be used by a particular
product. In the case of this rulemaking
pertaining to electric motors, only a
single fuel—electricity—is consumed by
the equipment. DOE’s approach is based
on the calculation of an FFC multiplier
for each of the energy types used by
covered equipment. The methodology
for estimating FFC does not project how
fuel markets would respond to this
particular standard rulemaking. The
FFC methodology simply estimates how
much additional energy, and in turn
how many tons of emissions, may be
displaced if the estimated fuel were not
consumed by the equipment covered in
this rulemaking. It is also important to
note that inclusion of FFC savings does
not affect DOE’s choice of proposed
standards.
2. Significance of Savings
As noted above, 42 U.S.C.
6295(o)(3)(B) prevents DOE from
18 ‘‘Review of Site (Point-of-Use) and Full-FuelCycle Measurement Approaches to DOE/EERE
Building Appliance Energy-Efficiency Standards,’’
(Academy report) was completed in May 2009 and
included five recommendations. A copy of the
study can be downloaded at: https://www.nap.edu/
catalog.php?record_id=12670.
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adopting a standard for a covered
product unless such standard would
result in ‘‘significant’’ energy savings.
Although the term ‘‘significant’’ is not
explicitly defined in EPCA, the U.S.
Court of Appeals, in Natural Resources
Defense Council v. Herrington, 768 F.2d
1355, 1373 (D.C. Cir. 1985), indicated
that Congress intended ‘‘significant’’
energy savings in this context to be
savings that were not ‘‘genuinely
trivial.’’ DOE believes that the energy
savings for all of the TSLs considered in
this rulemaking (presented in section
V.A) are nontrivial, and, therefore, DOE
considers them ‘‘significant’’ within the
meaning of section 325 of EPCA.
F. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be
evaluated in determining whether a
potential energy conservation standard
is economically justified. (42 U.S.C.
6295(o)(2)(B)(i)) The following sections
detail how DOE addresses each of those
factors in this rulemaking.
a. Economic Impact on Manufacturers
and Consumers
In determining the impacts of a new
or amended standard on manufacturers,
DOE first uses an annual cash-flow
approach to determine the quantitative
impacts. This step includes both a shortterm assessment—based on the cost and
capital requirements during the period
between when a regulation is issued and
when entities must comply with the
regulation—and a long-term assessment
over a 30-year period.19 The industrywide impacts analyzed include industry
net present value (INPV), which values
the industry on the basis of expected
future cash flows; cash flows by year;
changes in revenue and income; and
other measures of impact, as
appropriate. Second, DOE analyzes and
reports the impacts on different types of
manufacturers, including impacts on
small manufacturers. Third, DOE
considers the impact of standards on
domestic manufacturer employment and
manufacturing capacity, as well as the
potential for standards to result in plant
closures and loss of capital investment.
Finally, DOE takes into account
cumulative impacts of various DOE
regulations and other regulatory
requirements on manufacturers.
For individual consumers, measures
of economic impact include the changes
in life-cycle cost (LCC) and payback
period (PBP) associated with new or
amended standards. The LCC, addressed
19 DOE also presents a sensitivity analysis that
considers impacts for products shipped in a 9-year
period.
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as ‘‘savings in operating costs’’ at 42
U.S.C. 6295(o)(2)(B)(i)(II), is one of
seven factors considered in determining
the economic justification for a new or
amended standard and is discussed in
the following section. For consumers in
the aggregate, DOE also calculates the
national net present value of the
economic impacts applicable to a
particular rulemaking.
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b. Life-Cycle Costs
The LCC is the sum of the purchase
price of a piece of equipment (including
its installation) and the operating
expense (including energy,
maintenance, and repair expenditures)
discounted over the lifetime of that
equipment. The LCC savings for the
considered efficiency levels are
calculated relative to a base case that
reflects projected market trends in the
absence of new or amended standards.
The LCC analysis requires a variety of
inputs, such as equipment prices,
equipment energy consumption, energy
prices, maintenance and repair costs,
equipment lifetime, and consumer
discount rates. For its analysis, DOE
assumes that consumers, as users of
electric motors, will purchase the
considered equipment in the first year
of compliance with new or amended
standards.
To account for uncertainty and
variability in specific inputs, such as
equipment lifetime and discount rate,
DOE uses a distribution of values with
probabilities attached to each value.
DOE identifies the percentage of
consumers estimated to receive LCC
savings or experience an LCC increase,
in addition to the average LCC savings
associated with a particular standard
level. DOE also evaluates the LCC
impacts of potential standards on
identifiable subgroups of consumers
that may be affected disproportionately
by a national standard.
c. Energy Savings
Although significant conservation of
energy is a separate statutory
requirement for imposing an energy
conservation standard, EPCA requires
DOE, in determining the economic
justification of a standard, to consider
the total projected energy savings that
are expected to result directly from the
standard. (42 U.S.C. 6295(o)(2)(B)(i)(III))
As discussed in section IV.H, DOE uses
the NIA spreadsheet to project national
energy savings.
d. Lessening of Utility or Performance
In establishing classes of products,
and in evaluating design options and
the impact of potential standard levels,
DOE evaluates standards that would not
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lessen the utility or performance of the
considered products. (42 U.S.C.
6295(o)(2)(B)(i)(IV)) As noted earlier, the
substance of this provision applies to
the equipment at issue in today’s
proposal as well. DOE has determined
that the standards proposed in today’s
notice will not reduce the utility or
performance of the equipment under
consideration in this rulemaking. One
piece of evidence for this claim includes
the fact that many motors are already
commonly being sold at the proposed
levels (NEMA’s ‘‘Premium’’
designation). A second piece of
evidence is that the proposed standards
closely track the recommendations of
NEMA, which represents manufacturers
who understand deeply the design
compromises entailed in reaching
higher efficiencies and who would be
acting against the interest of their
customers in recommending standards
that would harm performance or utility.
e. Impact of Any Lessening of
Competition
EPCA directs DOE to consider the
impact of any lessening of competition,
as determined in writing by the
Attorney General, that is likely to result
from the imposition of a standard. (42
U.S.C. 6295(o)(2)(B)(i)(V). It also directs
the Attorney General to determine the
impact, if any, of any lessening of
competition likely to result from a
proposed standard and to transmit such
determination to the Secretary of Energy
within 60 days of the publication of a
proposed rule, together with an analysis
of the nature and extent of the impact.
(42 U.S.C. 6295(o)(2)(B)(ii)) DOE will
transmit a copy of today’s proposed rule
to the Attorney General with a request
that the Department of Justice (DOJ)
provide its determination on this issue.
DOE will address the Attorney General’s
determination in the final rule.
f. Need for National Energy
Conservation
The energy savings from the proposed
standards are likely to provide
improvements to the security and
reliability of the Nation’s energy system.
Reductions in the demand for electricity
also may result in reduced costs for
maintaining the reliability of the
Nation’s electricity system. DOE
conducts a utility impact analysis to
estimate how standards may affect the
Nation’s needed power generation
capacity.
The proposed standards also are
likely to result in environmental
benefits in the form of reduced
emissions of air pollutants and
greenhouse gases associated with energy
production. DOE reports the emissions
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impacts from today’s standards, and
from each TSL it considered, in section
V.B.4 of this notice. DOE also reports
estimates of the economic value of
emissions reductions resulting from the
considered TSLs.
g. Other Factors
EPCA allows the Secretary of Energy,
in determining whether a standard is
economically justified, to consider any
other factors that the Secretary deems to
be relevant. (42 U.S.C.
6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
As set forth in 42 U.S.C.
6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy
conservation standard is economically
justified if the additional cost to the
consumer of a product that meets the
standard is less than three times the
value of the first year’s energy savings
resulting from the standard, as
calculated under the applicable DOE
test procedure. DOE’s LCC and PBP
analyses generate values used to
calculate the effects that proposed
energy conservation standards would
have on the payback period for
consumers. These analyses include, but
are not limited to, the three-year
payback period contemplated under the
rebuttable-presumption test. In addition,
DOE routinely conducts an economic
analysis that considers the full range of
impacts to consumers, manufacturers,
the Nation, and the environment, as
required under 42 U.S.C.
6295(o)(2)(B)(i). The results of this
analysis serve as the basis for DOE’s
evaluation of the economic justification
for a potential standard level (thereby
supporting or rebutting the results of
any preliminary determination of
economic justification). The rebuttable
presumption payback calculation is
discussed in section IV.F.12 of this
proposed rule.
IV. Methodology and Discussion of
Related Comments
DOE used four spreadsheet tools to
estimate the impact of today’s proposed
standards. The first spreadsheet
calculates LCCs and PBPs of potential
new energy conservation standards. The
second provides shipments forecasts
and the third calculates national energy
savings and net present value impacts of
potential new energy conservation
standards. The fourth tool helps assess
manufacturer impacts, largely through
use of the Government Regulatory
Impact Model (GRIM).
Additionally, DOE estimated the
impacts of energy conservation
standards for electric motors on utilities
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and the environment. DOE used a
version of EIA’s National Energy
Modeling System (NEMS) for the utility
and environmental analyses. The NEMS
model simulates the energy sector of the
U.S. economy. EIA uses NEMS to
prepare its Annual Energy Outlook
(AEO), a widely known energy forecast
for the United States. The version of
NEMS used for appliance standards
analysis is called NEMS–BT 20 and is
based on the AEO version with minor
modifications.21 The NEMS–BT model
offers a sophisticated picture of the
effect of standards because it accounts
for the interactions between the various
energy supply and demand sectors and
the economy as a whole.
A. Market and Technology Assessment
For the market and technology
assessment, DOE develops information
that provides an overall picture of the
market for the equipment concerned,
including the purpose of the equipment,
the industry structure, and market
characteristics. This activity includes
both quantitative and qualitative
assessments, based primarily on
publicly available information. The
subjects addressed in the market and
technology assessment for this
rulemaking include scope of coverage,
equipment classes, types of equipment
sold and offered for sale, and technology
options that could improve the energy
efficiency of the equipment under
examination. Chapter 3 of the TSD
contains additional discussion of the
market and technology assessment.
1. Current Scope of Electric Motors
Energy Conservation Standards
EISA 2007 amended EPCA to
prescribe energy conservation standards
for four categories of electric motors:
General purpose electric motors
(subtype I) (hereinafter, ‘‘subtype I’’),
general purpose electric motors (subtype
II) (hereinafter, ‘‘subtype II’’), fire pump
electric motors, and NEMA Design B,
general purpose electric motors that also
meet the subtype I or subtype II
definitions and are rated above 200
horsepower through 500 horsepower.
DOE’s most recent test procedure final
rule added clarity to the definitions for
each of these motor categories, which
are now codified at 10 CFR 431.12. 77
FR 26608.
Although DOE is not proposing to
modify these definitions, commenters
sought additional clarifications. During
the preliminary analysis public meeting,
NEMA expressed confusion regarding
73605
whether IEC frame motors would fall
under the subtype I or subtype II
designation, as DOE defined them to be
related to both definitions. NEMA
added that because subtype I and
subtype II electric motors are subject to
different efficiency standards,
manufacturers producing IEC frame
motors are confused as to whether IEC
frame motors are subject to NEMA MG
1 Table 12–11 or Table 12–12 efficiency
standards.22 (NEMA, Public Meeting
Transcript, No. 60 at pp. 36, 37)
DOE understands that an IEC frame
motor could be treated as either a
subtype I or subtype II motor depending
on its other characteristics. Having an
IEC frame alone does not dictate
whether a motor is a general purpose
subtype I or subtype II motor; rather,
other physical characteristics, such as
equivalency to a NEMA Design A, B, or
C electric motor, and whether it has
mounting feet could determine the
subtype designation and associated
energy efficiency standard level. All of
these elements flow directly from the
statutory changes enacted by EISA 2007.
(See EISA 2007, sec. 313(a)(3), codified
at 42 U.S.C. 6311(13)) Currently, electric
motors are required to meet energy
conservation standards as follows:
TABLE IV.1—CURRENT ELECTRIC MOTOR ENERGY CONSERVATION STANDARDS 23
Energy conservation standard level
Horsepower range
General Purpose Electric Motors (Subtype I) ................................................
General Purpose Electric Motors (Subtype II) ...............................................
NEMA Design B and ......................................................................................
IEC Design N Motors .....................................................................................
Fire Pump Electric Motors ..............................................................................
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Electric motor category
1 to 200 (inclusive) ............................
1 to 200 (inclusive) ............................
201 to 500 (inclusive) ........................
MG 1–2011 Table 12–12.
MG 1–2011 Table 12–11.
MG 1–2011 Table 12–11.
1 to 500 (inclusive) ............................
MG 1–2011 Table 12–11.
Additionally, NEMA requested
clarification on the terminology DOE
intends to use for NEMA Design B
motors, namely whether the term is
‘‘NEMA Design B motor’’ or ‘‘NEMA
Design B electric motor’’ and what, if
any, differences there are between the
two terms. (NEMA, No. 54 at p. 14) DOE
understands that the terms ‘‘motor’’ and
‘‘electric motor’’ may refer to a variety
of machines outside of its regulatory
context. However, because there are no
NEMA Design B motors that are not
electrically-driven, in DOE’s view, the
20 BT stands for DOE’s Building Technologies
Program.
21 The EIA allows the use of the name ‘‘NEMS’’
to describe only an AEO version of the model
without any modification to code or data. Because
the present analysis entails some minor code
modifications and runs the model under various
policy scenarios that deviate from AEO
assumptions, the name ‘‘NEMS–BT’’ refers to the
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potential for ambiguity is minimal. DOE
clarifies that it is using the term ‘‘NEMA
Design B motor,’’ as is currently
codified in 10 CFR 431.12. Additionally,
DOE does not consider there to be any
meaningful difference between the two
terms and notes that all motors
currently regulated under 10 CFR part
431, subpart B, are electric motors.
DOE requests comment on whether
the proposed standards help resolve the
potential issue on which it had
previously issued clarification of
whether a [IEC] motor may be
model as used here. For more information on
NEMS, refer to The National Energy Modeling
System: An Overview, DOE/EIA–0581 (98) (Feb.
1998), available at: https://tonto.eia.doe.gov/
FTPROOT/forecasting/058198.pdf.
22 The efficiency levels found in Table 12–12 are
the more stringent of the two sets of efficiency
tables.
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considered to be subject to two
standards.
2. Expanded Scope of Electric Motor
Energy Conservation Standards
As referenced above, on August 15,
2012, the Motor Coalition petitioned
DOE to adopt the Coalition’s consensus
agreement, which, in part, formed the
basis for today’s proposal.24 The Motor
Coalition petitioned DOE to simplify
coverage to address a broad array of
electric motors with a few clearly
identified exceptions. The Motor
Coalition advocated this approach to
23 For the purposes of determining compliance,
DOE assesses a motors horsepower rating according
to the provisions of 10 CFR 431.25(e).
24 The Petition is available at: https://
www.regulations.gov/#!documentDetail;D=EERE2010-BT-STD-0027-0035.
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simplify manufacturer compliance and
to help facilitate DOE’s enforcement
efforts. The Petition highlighted
potential energy savings that would
result from expanding the scope of
covered electric motors. (Motor
Coalition, No 35 at pp. 1–30)
Subsequent to DOE’s preliminary
analysis public meeting, several other
interested parties submitted comments
supporting the Petition. Those
supporters included: BBF and
Associates, the Air Movement and
Control Association International, Inc.,
U.S. Senators Lisa Murkowski and Jeff
Bingaman, the Hydraulic Institute, the
Arkansas Economic Development and
Commission-Energy Office, and the
Power Transmission Distributors
Association.
The California Investor Owned
Utilities (CA IOUs), represented by the
Pacific Gas and Electric Company
(PG&E), Southern California Gas
Company (SCGC), San Diego Gas and
Electric (SDG&E), and Southern
California Edison (SCE) commented that
they supported the Petition’s intent to
expand the scope of coverage to the vast
majority of single speed, polyphase, and
integral horsepower induction motors
between 1 and 500 horsepower, as well
as increasing energy conservation
standards for some covered products.
(CA IOUs, No. 57 at p. 2)
The Air Movement and Control
Association International, Inc. (AMCA
International) endorsed the Petition.
AMCA International encouraged DOE to
adopt the Petition to save energy as soon
as possible. (AMCA International, No.
59 at p. 1)
The CDA and BBF supported DOE’s
preliminary analysis and the Petition,
indicating that the Petition sets
minimum efficiency levels that
represent a challenge to the industry
and can have a great impact on U.S.
energy use. (BBF & Associates, No. 51 at
pp. 1, 2; CDA, No. 55 at p. 1) BBF also
urged DOE to investigate energy
conservation standards for motors over
500 horsepower because preliminary
indications suggest that as much as 27
percent of total motor power consumed
in the U.S. is from motors over 500
horsepower, and higher efficiencies can
provide substantial savings. (BBF, No.
51 at p. 4)
EASA supported the Motor
Coalition’s Petition, asserting that it is
in the best interests of saving energy,
U.S. jobs, and the economy overall to
adopt that Petition’s approach. EASA
strongly encouraged the DOE to adopt
the recommendations of the Motor
Coalition, citing large and economically
justified energy savings. (EASA, No. 47
at p. 1)
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ACEEE commented on behalf of the
Motor Coalition, stating that expanding
the scope of energy conservation
standards and only excluding a small
group of motor types will enhance
enforcement efforts by the government,
by simplifying the standards to only
include explicit exclusions. (ACEEE,
Public Meeting Transcript, No. 60 at p.
19)
After reviewing the Petition, DOE is
proposing to require electric motor
types beyond those currently covered
(and discussed in section IV.A.1) to
meet energy conservation standards.
DOE’s proposed expansion is similar to
the approach recommended by the
Motor Coalition in its Petition (Motor
Coalition, No. 35 at pp. 1–3). DOE’s
proposal would establish energy
conservation standards for electric
motors that exhibit all of the
characteristics listed in Table IV.2, with
a limited number of exceptions.
TABLE IV.2—CHARACTERISTICS OF
MOTORS REGULATED UNDER EXPANDED SCOPE OF COVERAGE
Motor characteristic
Is a single-speed, induction motor,
Is rated for continuous duty (MG 1) operation
or for duty type S1 (IEC),
Contains a squirrel-cage (MG 1) or cage
(IEC) rotor,
Operates on polyphase alternating current
60-hertz sinusoidal power,
Is rated for 600 volts or less,
Is built with a 2-, 4-, 6-, or 8-pole configuration,
Is a NEMA Design A, B, or C motor (or IEC
Design N or H)
Is built in a three-digit NEMA frame size or
an enclosed 56-frame (or any IEC equivalent), and
Is rated from 1 to 500 horsepower (inclusive).
In response to its preliminary
analysis, DOE received several
comments about the characteristics that
DOE should use to define the broad
scope of electric motors potentially
subject to energy conservation
standards. First, NEMA suggested that
DOE define motor types exhibiting the
nine characteristics listed in Table IV.2.
(NEMA, No. 54 at p. 32) NEMA also
requested that DOE clarify the range of
horsepower ratings included and the
scope of 56- and IEC-frame motors
covered. The Energy Advocates (NPCC,
NEEA, ACEEE, ASAP, Earthjustice,
ASE) also suggested that DOE include
IEC-equivalents and NEMA 56-frame
sizes in the scope of coverage. (NPCC,
No. 56 at p. 2)
Additionally, DOE is proposing to
clarify the design, construction, and
performance characteristics of covered
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electric motors. Specifically, DOE is
proposing to clarify that only motors
rated from 1 to 500 horsepower
(inclusive), or their IEC equivalents,
would be covered by the standards
being proposed in today’s rulemaking.
Finally, with regard to IEC-frame
motors, DOE would not cover IEC
motors on the singular basis of frame
size, but would consider covering such
motors when they meet the criteria of
Table IV.2. In other words, an IEC-frame
motor would need to satisfy these nine
criteria for the proposed standards to
apply.
In its submitted Petition, the Coalition
requested that DOE cover all singlespeed, polyphase, 56-frame induction
motors rated at one horsepower or
greater that do not meet the regulatory
definition for ‘‘small electric motor’’ in
10 CFR part 431, subpart X. This
definition applies to both single-phase
and polyphase open-frame general
purpose AC induction motors built in a
two-digit frame size. The proposal put
forth by the Coalition would expand
energy conservation standards to
polyphase, enclosed 56-frame motors
rated at one or more horsepower along
with polyphase, special and definite
purpose open 56-frame motors of
horsepower greater than or equal to one
that are not covered by DOE’s small
electric motor regulations.
Regarding 56-frame motors at 1-hp or
greater, DOE is proposing standards for
polyphase, enclosed 56-frame motors
that are rated at 1-hp or greater. DOE is
also tentatively proposing TSL 2 for
polyphase, open 56-frame special and
definite purpose motors that are rated at
1-hp or greater as advocated by the
Motor Coalition. With respect to these
motors (i.e. 56-frame, open, special and
definite purpose), DOE seeks additional
data related to these motors, including,
but not limited to the following
categories: Motor efficiency
distributions; shipment breakdowns
between horsepower ratings, open and
enclosed motors, and between general
and special and definite purpose
electric motors; and information
regarding the typical applications that
use these motors. If this proposal is
adopted in the final rule, DOE will
account for a substantial majority of 56frame motors that are not already
regulated by efficiency standards and
ensure coverage for all general purpose
motors along with a substantial number
of special and definite purpose motors.
Based on currently available data,
DOE estimates that approximately
270,000 polyphase, open 56-frame
special and definite purpose motors (1hp or greater) were shipped in 2011 and
at least 70% of these motors have
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efficiency levels below NEMA
Premium.25 In addition, based on this
data, DOE believes that establishing TSL
2 for this subset of 56-frame motors
would result in national energy savings
of 0.58 quads (full-fuel-cycle) and net
present value savings of $1.11 billion
(2012$), with a 7 percent discount
rate.26 DOE has not merged its data and
analyses related to this subset of 56frame motors with the other analyses in
today’s NOPR. As described above, DOE
seeks additional information that can be
incorporated into its final analysis.
DOE notes that enclosed 56-frame
motors with horsepower ratings below 1
horsepower would not, however, be
covered as part of today’s proposal. DOE
is not proposing to cover 56-frame size
fractional motors because EPCA, as
amended, establishes energy
conservation standards for electric
motors at 1-hp or greater and DOE
requires the use of different test
procedures for motors above and below
1-hp. In particular, DOE’s regulations
prescribe, consistent with industry
practice, the use of the Institute of
Electrical and Electronics Engineers
(IEEE) Standard 112 (Test Method A) to
test motors rated below 1-hp, and IEEE
Standard 112 (Test Method B) to test
motor rated at or above 1-hp. To ensure
consistent testing results, DOE requires
application of the same test procedure
to all electric motors. Therefore, DOE is
not proposing to regulate enclosed 56frame size motors rated under 1-hp.27
73607
This tentative decision, however, does
not foreclose the possibility that DOE
may regulate the efficiency of these
motors and may change depending on
the nature of the feedback provided by
commenters with respect to this issue.
DOE requests comment on its tentative
decision to not address fractional
horsepower enclosed 56-frame motors
as part of today’s proposal, along with
any relevant information and data.
In view of Table IV.2, Table IV.3 lists
the various electric motor types that
would be covered by DOE’s proposed
approach. Further details and
definitions for the motor types can be
found in DOE’s electric motors test
procedure NOPR, which was published
on June 26, 2013 (78 FR 38456).
TABLE IV.3—CURRENTLY UNREGULATED MOTOR TYPES DOE PROPOSES TO COVER
Electric Motor Type
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NEMA Design A from 201 to 500 horsepower.
Electric motors with moisture resistant windings.
Electric motors with sealed windings.
Partial electric motors.
Totally enclosed non-ventilated (TENV) electric motors.
Immersible electric motors.
Integral brake electric motors.
Electric motors with non-standard endshields or flanges.
Electric motors with non-standard bases.
Electric motors with special shafts.
Vertical hollow-shaft electric motors.
Electric motors with sleeve bearings.
Electric motors with thrust bearings.
Non-integral brake electric motors.
In view of DOE’s proposed approach
described in Table IV.3, DOE is
proposing to include certain motor
types that some interested parties have
suggested that DOE continue to exclude
from any energy efficiency
requirements. For example, the Motor
Coalition would exclude integral brake
motors from coverage, as DOE once did
through policy guidance, see 62 FR
59978 (November 5, 1997), but which
was subsequently removed. See 77 FR
26638 (May 4, 2012). (Motor Coalition,
No. 35 at p. 3) SEW-Eurodrive also
commented that there are two basic
types of integral gearmotor: (1) One that
meets the definition in DOE’s
preliminary analysis, and (2) another
having a special shaft or mounting
configuration. SEW-Eurodrive
contended that the second type of
integral gearmotor would require
replacement of the entire rotor shaft and
rotor cage to be tested. (SEWE, No. 53,
p. 3)
In view of the foregoing, DOE
continues to believe that consistent and
repeatable test procedures can be
prescribed for integral brake motors,
integral gearmotors, integral partial
motors, and partial d motors. See 78 FR
38456 (June 26, 2013). In particular,
DOE believes that an integral brake
motor that meets the nine criteria in
Table IV.2, could be readily tested and
satisfy the proposed standards. In
addition, DOE believes that the
definition for ‘‘partial electric motor’’
and ‘‘component set’’ proposed in its
June test procedure NOPR will clarify
what types of items would meet these
definitions, which should help
manufacturers determine whether the
equipment they manufacture fall under
these terms. See 78 FR 38456 (June 26,
2013). Furthermore, DOE believes that
the type of integral gearmotor addressed
by SEW-Eurodrive (i.e., with a special
shaft or mounting configuration) would
likely satisfy DOE’s proposed definition
of component set, because it would
require more than the addition of end
shields and a bearing to create an
operable motor. (Component sets would
not be required to meet standards under
today’s proposal)
ACEEE supported the Motor
Coalition’s Petition in its approach to
expand the scope of covered motors to
comply with the energy efficiency levels
found in Table 12–12 of NEMA
Standards Publication MG 1–2011.
According to ACEEE, such approach
could be easily accomplished by
manufacturers and, at the same time,
allow them to refocus resources on
designing and building the next
generation of electric motor. (ACEEE,
Public Meeting Transcript, No. 60 at pp.
18, 19) UL agreed with the ACEEE
approach and suggested that DOE clarify
the scope of coverage with a statement
whereby all electric motors are subject
to standards, except for those
specifically mentioned as excluded.
(UL, Public Meeting Transcript, No. 60
at pp. 60, 61) Finally, the California
Independently Owned Utilities (CA
IOUs) submitted similar comments,
suggesting that DOE expand the scope of
coverage and explicitly define those
motor types excluded from standards.
The CA IOUs stressed that this approach
would provide clarity both to
25 Shipments for these 56-open frame motors were
estimated from data provided by the Motor
Coalition. DOE assumed 56-frame open motors are
distributed across 2-, 4-, and 6-pole configurations
and 1 to 5 horsepower ratings. With this
assumption, DOE used the shipments distributions
from ECG 1 motors across these motor
configurations and ratings to establish shipments
data for open 56-frame motors by motor
configuration and horsepower rating. Efficiency
distributions were based on a limited survey of
electric motor models from six major manufacturer
catalogs.
26 DOE used the same NIA model and inputs
described in section IV.H to estimate these values
of NES and NPV, but adjusted the shipments and
efficiency distributions to match the data specific
to these 56-frame open motors.
27 DOE notes that general purpose, open 56-frame
motors are already addressed by the standards for
small electric motors.
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compliance and enforcement efforts by
government agencies and
manufacturers. (CA IOUs, No. 57 at
p. 1)
After considering these comments,
and further analyzing available relevant
information, DOE believes that a
simplified approach to determining
coverage would help ensure consistency
to the extent possible when applying the
proposed standards. Therefore, in
today’s notice, DOE is proposing that an
electric motor that meets the nine
characteristics in Table IV–3 would be
covered and required to meet the
applicable energy conservation
standards, either in NEMA MG 1 Table
12–11 or 12–12. Additionally, DOE is
proposing not to set standards at this
time for the following motors:
component sets, liquid-cooled motors,
submersible motors, and definitepurpose inverter-fed motors. DOE is not
proposing to set standards for these
motors in light of the substantial
difficulties and complexities that would
be involved in testing these motors at
this time. In addition, DOE is proposing
not to set standards at this time for airover motors, but intends to address
these types of motors in a separate
rulemaking. Definitions for the motor
types and additional details about these
issues are addressed at 78 FR 38456
(June 26, 2013).
3. Advanced Electric Motors
In its preliminary analysis, DOE
addressed various ‘‘advanced electric
motor,’’ which included those listed in
Table IV.4. While DOE recognized that
such motors could offer improved
efficiency, regulating them would
represent a significant shift for DOE,
which has primarily focused on the
efficiency of polyphase, single-speed
induction motors. Seeking more
information, DOE solicited public
comments about these types of motors
and how they would be tested for
energy efficiency.
TABLE IV.4—ADVANCED ELECTRIC
MOTORS
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Motor description
Inverter drives.
Permanent magnet motors.
Electrically commutated motors.
Switched-reluctance motors.
DOE received comments about
advanced motors from various
interested parties. NEMA asserted that,
in certain applications, inverter drives,
permanent-magnet motors,
electronically commutated motors, and
switched-reluctance motors, could offer
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improved efficiency. However, NEMA
also noted that these motors may
include technologies where standard
test procedures are still being
developed, making it unable to
comment. (NEMA, No. 54 at pp. 18–19)
DOE understands that a test procedure
would be necessary before it
contemplates setting energy
conservation standards for these types
of motors. Additionally, during the
preliminary analysis public meeting,
ACEEE commented that advanced motor
designs present the largest opportunity
for future energy savings within the
motor marketplace and NEMA member
manufacturers are already exploring the
standards-setting process for advanced
motor designs in the NEMA MG 1
standards publication. (ACEEE, Public
Meeting Transcript, No. 60 at p. 19)
Other interested parties submitted
comments regarding the efficiency of
‘‘advanced motor systems’’ and, in
general, motor-driven systems. Danfoss
commented that system efficiency
improvements would provide
significant energy savings, and cited
variable frequency drives (VFDs) as an
example of a way to improve system
efficiency. VFDs, or inverter drives, are
external components used in motordriven systems to control motor speed
and torque by varying motor input
frequency and voltage Danfoss
elaborated that VFDs could save 20 to
30 percent of the energy that typical,
non-VFD-motors consume and urged
that DOE consider this approach,
instead of seeking minimal energy
conservation improvements in acrossthe-line start polyphase electric
motors.28 (Danfoss, Public Meeting
Transcript, No. 60 at pp. 21–23, 174,
175) UL submitted similar comments
during the preliminary analysis public
meeting, indicating that DOE and the
industry should focus on improving
system-level efficiency. UL added that if
a motor is not properly matched to its
load then the system efficiency could be
20 or 30 percent less efficient than
possible. (UL, Public Meeting
Transcript, No. 60 at pp. 69, 70) BBF
and the CDA commented that the
overall evaluation of system efficiency
is very important, and the evaluation of
VFDs and the motor system represents
many major opportunities for improved
efficiency. (BBF, No. 51, p. 4; CDA, No.
55, p. 2)
DOE understands the concerns from
interested parties regarding advanced
motor efficiency and its connection with
28 For this rulemaking, ‘‘across-the-line start’’
indicates the electric motor is run directly on
polyphase, alternating current (AC) sinusoidal
power, without any devices or controllers
manipulating the power signal fed to the motor.
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the possible regulation of advanced
electric motors. At this time, however,
DOE has chosen not to regulate
advanced motors and knows of no
established definitions or test
procedures that could be applied to
them. Because DOE agrees that
significant energy savings may be
possible for some advanced motors,
DOE plans to keep abreast of changes to
these technologies and their use within
industry, and may consider regulating
them in the future. DOE invites
comment on the topic of advanced
motors, including any related
definitions or test procedures that it
should consider applying as part of
today’s rulemaking.
4. Equipment Class Groups and
Equipment Classes
When DOE prescribes or amends an
energy conservation standard for a type
(or class) of covered equipment, it
considers (1) the type of energy used; (2)
the capacity of the equipment; or (3) any
other performance-related feature that
justifies different standard levels, such
as features affecting consumer utility.
(42 U.S.C. 6295(q)) Due to the large
number of characteristics involved in
electric motor design, DOE has used two
constructs to help develop its energy
conservation standards proposals for
electric motors: ‘‘equipment class
groups’’ and ‘‘equipment classes.’’ An
equipment class represents a unique
combination of motor characteristics for
which DOE is proposing a specific
energy conservation standard. There are
580 potential equipment classes that
consist of all permutations of electric
motor design types (i.e., NEMA Design
A & B, NEMA Design C, fire pump
electric motor, or brake electric motor),
standard horsepower ratings (i.e.,
standard ratings from 1 to 500
horsepower), pole configurations (i.e.,
2-, 4-, 6-, or 8-pole), and enclosure types
(i.e., open or enclosed). An equipment
class group is a collection of equipment
classes that share a common design
type. For example, given a combination
of motor design type, horsepower rating,
pole-configuration, and enclosure type,
the motor’s design type dictates its
equipment class group, while the
combination of the remaining
characteristics dictates its specific
equipment class.29
29 At its core, the equipment class concept, which
is being applied only as a structural tool for
purposes of this rulemaking, is equivalent to a
‘‘basic model.’’ See 10 CFR 431.12. The
fundamental difference between these concepts is
that a ‘‘basic model’’ pertains to an individual
manufacturer’s equipment class. Each equipment
class for a given manufacturer would comprise a
basic model for that manufacturer.
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In the preliminary analysis, DOE
divided electric motors into three
groups based on two main
characteristics: NEMA (or IEC) design
letter and whether the motor met the
definition of a fire pump electric motor.
For the NOPR, DOE is keeping these
three groups and adding a fourth
equipment class group for electric
motors with brakes (integral and nonintegral). DOE’s four resulting
equipment class groups are: NEMA
Design A and B motors (ECG 1), NEMA
Design C motors (ECG 2), fire pump
electric motors (ECG 3), and electric
motors with brakes (ECG 4). Within
each of these groups, DOE would use
combinations of other pertinent motor
characteristics to enumerate individual
equipment classes. To illustrate the
differences between the two terms,
consider the following example. A
NEMA Design B, 50 horsepower, twopole enclosed electric motor and a
NEMA Design B, 100 horsepower, sixpole open electric motor would be in
the same equipment class group (ECG
1), but each would represent a unique
equipment class that will ultimately
have its own efficiency standard. Table
IV.5 outlines the relationships between
equipment class groups and the
characteristics used to define equipment
classes.
TABLE IV.5—ELECTRIC MOTOR EQUIPMENT CLASS GROUPS FOR THE NOPR ANALYSIS
Equipment class
group
Electric motor design
1 .................................
NEMA Design A & B * ..............................................................................
1–500
2, 4, 6, 8
2 .................................
NEMA Design C * .....................................................................................
1–200
4, 6, 8
3 .................................
Fire Pump * ...............................................................................................
1–500
2, 4, 6, 8
4 .................................
Brake Motors * ..........................................................................................
1–30
4, 6, 8
Horsepower
Poles
Enclosure
Open.
Enclosed.
Open.
Enclosed.
Open.
Enclosed.
Open.
Enclosed.
* Including IEC equivalents.
NEMA submitted multiple comments
about DOE’s equipment class groups
and equipment classes. First, NEMA
argued that such expansive groups
could make it difficult to properly
determine efficiency standards,
particularly given the large expansion of
scope being contemplated by DOE.
(NEMA, No. 54 at p. 40) NEMA
recommended that ‘‘for ‘electric motors’
the term ‘equipment class’ be identified
as those electric motors which are of the
polyphase squirrel-cage induction
type.’’ It added that:
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
‘‘An ‘equipment class group’ can be
defined as a particular ‘group’ of such
‘electric motor’ having a particular set of
common characteristics, such as NEMA
Design A and B electric motors or NEMA
Design C electric motors, or fire pump
electric motors. Each ‘equipment class group’
can be organized according to ‘rating’ where
‘rating’ is as it is presently defined in
§ 431.12 [of 10 CFR Part 431]. When
appropriate, an AEDM [alternative efficiency
determination method] can then be
substantiated for the complete ‘equipment
class’ of polyphase squirrel-cage induction
electric motors as is permitted and done
today.’’
Additionally, NEMA suggested that
DOE separate U-frame motors from
T-frame motors during the analysis
because any proposed increase in
efficiency standards for the low volume
production of U-frame motors would
likely result in a reduction in the
availability of U-frame motors, which
they assert, is not permitted under 42
U.S.C. 6295(o)(4). (NEMA, No. 54 at pp.
20, 26) Citing the high cost of
redesigning these motors relative to the
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potential savings, the Motor Coalition
predicted manufacturers would exit the
U-frame market leaving only one or two
manufacturers. (Motor Coalition, No. 35
at p. 13) NEMA also stated that the
demand for this type of motor has been
declining since the 1960’s and U-frame
motors have not been included in the
NEMA MG 1 standard since U-frame
motors were replaced by T-frame motors
as the NEMA standard in the 1960s.
(NEMA, No. 54 at pp. 19, 20) NEMA
added that the challenge created by
substituting a U-frame motor with a
T-frame motor must be accounted for in
the manufacturer and national impact
analyses.
EISA 2007 prescribed energy
conservation standards for electric
motors built with a U-frame, whereas
previously only electric motors built
with a T-frame were covered.30
(Compare 42 U.S.C. 6311(13)(A)(1992)
with 42 U.S.C. 6311(13)(B)(2011)) In
general, for the same combination of
horsepower rating and pole
configuration, an electric motor built in
a U-frame is built with a larger ‘‘D’’
dimension than an electric motor built
in a T-frame. The ‘‘D’’ dimension is a
measurement of the distance from the
centerline of the shaft to the bottom of
the mounting feet. Consequently, Uframe motors should be able to reach
30 The terms ‘‘U-frame’’ and ‘‘T-frame’’ refer to
lines of frame size dimensions, with a T-frame
motor having a smaller frame size for the same
horsepower rating as a comparable U-frame motor.
In general, ‘‘T’’ frame became the preferred motor
design around 1964 because it provided more
horsepower output in a smaller package.
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efficiencies as high, or higher, than Tframe motors with similar ratings (i.e.,
horsepower, pole-configuration, and
enclosure) because the larger frame size
allows for more active materials, such as
copper wiring and electrical steel,
which help reduce I2R (i.e., losses
arising from the resistivity of the
current-carrying material) and core
losses (losses that result from magnetic
field stability changes). Furthermore,
U-frame motors do not have any unique
utility relative to comparable T-frame
motors. In general, a T-frame design
could replace an equivalent U-frame
design with minor modification of the
mounting configuration for the driven
equipment. By comparison, a U-frame
design that is equivalent to a T-frame
design could require substantial
modification to the mounting
configuration for the same piece of
driven equipment because of its larger
size. DOE’s research indicated that
manufacturers sell conversion brackets
for installing T-frame motors into
applications where a U-frame motor had
previously been used.31
Regarding NEMA’s contention that
U-frame motors will become unavailable
if DOE does not separate these motors
from T-frame motors when developing
efficiency standards, DOE understands
NEMA’s concerns regarding the
diminishing market size of U-frame
motors and the potential for them to
disappear. However, DOE believes that
such an occurrence would not be the
31 See, for example, https://www.overlyhautz.com/
adaptomounts1.html.
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result of an efficiency standard that is
technologically infeasible for U-frame
motors, but because U-frame motors
offer no unique utility relative to
T-frame motors. Furthermore, DOE
believes that the proposed standards are
unlikely to result in the unavailability of
U-frame motors. Based on catalog data
from several large electric motor
manufacturers, DOE observed that 70
percent of currently available U-frame
models meet the proposed standard
(TSL 2). With much of the U-frame
market already at the proposed
standard, DOE sees no technical reason
that U-frame manufacturers would not
be able to comply with TSL 2.
DOE also notes that under 42 U.S.C.
6295(o)(4), EPCA proscribes the
promulgation of standards that would
result in the ‘‘unavailability in the
United States in any covered product
type (or class) of performance
characteristics (including reliability),
features, sizes, capacities, and volumes
that are substantially the same as those
generally available in the United States
at the time of the Secretary’s finding.’’
The provision does not require the
continued protection of particular
classes or types of product—or in this
case, electric motors—if the same utility
continues to be available for the
consumers who are purchasing the
given product. Consequently, based on
available information, DOE has not
separated U-frame motors into a unique
equipment class group. DOE welcomes
any additional data relevant to this
finding, including data that would
suggest the need for an alternate
approach. DOE also requests additional
information from manufacturers on
whether covering U-frame motors would
cause them to be unavailable in the U.S.
and whether U-frame motors have any
particular performance characteristics,
features, sizes, capacities, or volumes.
Finally, NEMA questioned DOE’s use
of the term ‘‘equipment class’’ to
describe a combination of horsepower
rating, pole configuration, and enclosure
type instead of using the term ‘‘rating,’’
which is defined in 10 CFR 431.12, as
part of the definition of a ‘‘basic model.’’
(NEMA, No. 54 at p. 25) NEMA believes
that this could cause confusion because
of proposals regarding certification,
alternative efficiency determination
methods (AEDMs), and enforcement in
a separate rulemaking, which are all
centered around ‘‘equipment classes.’’
(NEMA, No. 54 at p. 25) NEMA stated
that DOE’s definition in this rulemaking
has the adverse impact of requiring
substantiation of an AEDM separately
for every rating for which it is to be used
and would constitute a significant
increase in compliance burden. (NEMA,
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No. 54 at p. 25) DOE understands
NEMA’s concerns regarding the
potential of undue compliance burden.
DOE notes that it has not proposed a
regulatory definition for the term
‘‘equipment class.’’ It is merely a
construct for use in the various analyses
in today’s rulemaking. The term
‘‘equipment class’’ as described in this
rulemaking should not be misconstrued
as having any regulatory meaning as it
relates to the definition of ‘‘basic
model.’’ In today’s rulemaking, DOE is
continuing to use the terminology as
described in the preliminary analysis
and above. DOE intends to address
NEMA’s concerns regarding the
potential compliance burden in a
separate rulemaking that will address
compliance, certification and
enforcement-related issues.
a. Electric Motor Design Letter
The first criterion that DOE
considered when disaggregating
equipment class groups was based on
the NEMA (and IEC) design letter. The
NEMA Standards Publication MG 1–
2011, ‘‘Motors and Generators,’’ defines
a series of standard electric motor
designs that are differentiated by
variations in performance requirements.
These designs are designated by letter—
Designs A, B, and C. (See NEMA MG 1–
2011, paragraph 1.19.1). These designs
are categorized by performance
requirements for full-voltage starting
and developing locked-rotor torque,
breakdown torque, and locked-rotor
current, all of which affect an electric
motor’s utility and efficiency. DOE is
proposing to regulate the efficiency of
each of these design types.
The primary difference between a
NEMA Design A and NEMA Design B
electric motor is that they have different
locked-rotor current requirements.
NEMA Design B motors must not exceed
the applicable locked-rotor current level
specified in NEMA MG 1–2011,
paragraph 12.35.1. NEMA Design A
motors, on the other hand, do not have
a maximum locked-rotor current limit.
In most applications, NEMA Design B
motors are generally preferred because
locked-rotor current is constrained to
established industry standards, making
it easier to select suitable motor-starting
devices. However, certain applications
have special load torque or inertia
requirements, which result in a design
with high locked-rotor current (NEMA
Design A). When selecting starting
devices for NEMA Design A motors,
extra care must be taken in properly
sizing electrical protective devices to
avoid nuisance tripping during motor
startup. The distinction between NEMA
Design A and NEMA Design B motors is
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important to users who are sensitive to
high locked-rotor current; however, both
NEMA Design A and Design B motors
have identical performance
requirements in all other metrics, which
indicates that they offer similar levels
and types of utility. Given these
similarities, DOE is proposing to group
these motors together into a single
equipment class grouping for the
purposes of this rulemaking.
In contrast, DOE believes that the
different torque requirements for NEMA
Design C electric motors represent a
change in utility that can affect
efficiency performance. NEMA Design C
motors are characterized by high
starting torques. Applications that are
hard to start, such as heavily loaded
conveyors and rock crushers, require
this higher starting torque. The
difference in torque requirements will
restrict which applications can use
which NEMA Design types. As a result,
NEMA Design C motors cannot always
be replaced with NEMA Design A or B
motors, or vice versa. Therefore, as in
the preliminary analysis, DOE has
analyzed NEMA Design C motors in an
equipment class group separate from
NEMA Design A and B motors.
In chapter two, ‘‘Analytical
Framework,’’ of the preliminary
technical support document, DOE noted
numerous instances where
manufacturers were marketing electric
motors rated greater than 200
horsepower as NEMA Design C motors.
DOE understands that NEMA MG 1–
2011 specifies Design C performance
requirements for motors rated 1–200 hp
in four-, six-, and eight-pole
configurations—a motor rated above 200
hp or using a two-pole configuration
would not meet the Design C
specifications. DOE requested public
comment about whether motors that are
name-plated as NEMA Design C, but
that fall outside the ratings for which
NEMA Design C is defined, can be
considered to be NEMA Design C
motors. In its comments, NEMA
asserted it did not support marking a
motor as NEMA Design C where no
standard exists for two-pole designs, or
four-, six- or eight-pole motors over 200
horsepower. NEMA recommended that
any such improperly marked motor be
examined for determination of its
proper Design letter relative to the
applicable standards in NEMA MG 1.
Furthermore, NEMA recommended that
DOE not include efficiency standards
for motors of any design type for which
NEMA or IEC standards do not exist.
(NEMA, No. 54 at p. 19)
DOE understands that without
established performance standards that
form the basis for a two-pole NEMA
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Design C motor or a NEMA Design C
motor with a horsepower rating above
200, motors labeled as such would not
meet the proposed regulatory definition
for ‘‘NEMA Design C motor.’’ 78 FR
38456 (June 26, 2013). DOE considers
motors at these ratings to be improperly
labeled if they are name-plated as
NEMA Design C. Mislabeled NEMA
Design C motors, however, are still
subject to energy conservation standards
if they meet the definitions and
performance standards for a regulated
motor—e.g. NEMA Design A or B. And
since these motors either need to meet
the same efficiency levels or would be
required by customers to meet specific
performance criteria expected of a given
design letter (i.e. Design A, B, or C),
DOE does not foresee at this time any
incentive that would encourage a
manufacturer to identify a Design A or
B motor as a Design C motor for
standards compliance purposes. DOE
understands, however, that NEMA
Design C motors as a whole constitute
an extremely small percentage of motor
shipments—less than two percent of
shipments—covered by this rulemaking,
which would appear to create an
unlikely risk that mislabeling motors as
NEMA Design C will be used as an
avenue to circumvent standards.
Nevertheless, DOE will monitor the
potential presence of such motors and
may reconsider standards for them
provided such practice becomes
prevalent.
b. Fire Pump Electric Motors
In addition to considering the NEMA
design type when establishing
equipment class groups, DOE
considered whether an electric motor is
a fire pump electric motor. EISA 2007
prescribed energy conservation
standards for fire pump electric motors
(42 U.S.C. 6313(b)(2)(B)) and,
subsequently, DOE adopted a definition
for the term ‘‘fire pump electric motor,’’
which incorporated portions of National
Fire Protection Association Standard
(NFPA) 20, ‘‘Standard for the
Installation of Stationary Pumps for Fire
Protection’’ (2010). Pursuant to NFPA
20, a fire pump electric motor must
comply with NEMA Design B
performance standards and must
continue to run in spite of any risk of
damage stemming from overheating or
continuous operation. The additional
requirements for a fire pump electric
motor constitutes a change in utility that
DOE believes could also affect its
performance and efficiency. Therefore,
DOE established a separate equipment
class group for such motors in the
preliminary analysis to account for the
special utility offered by these motors.
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In its comments, NEMA agreed with
DOE’s decision to separate fire pump
electrical motors as a separate
equipment class group. (NEMA, No. 54
at p. 20) Consequently, DOE is
proposing to continue using a separate
equipment class group for fire pump
electric motors.
c. Brake Motors
In its NOPR analyses, DOE considered
whether the term ‘‘electric motor’’
should include an integral brake electric
motor or a non-integral brake electric
motor (collectively, ‘‘brake motors’’). In
the test procedure NOPR, DOE proposed
definitions both for integral and nonintegral brake electric motors. 78 FR
38456 (June 26, 2013). Both of these
electric motor types are contained in
one equipment class group as separate
from the equipment class groups
established for NEMA Design A and B
motors, NEMA Design C motors, and
fire pump electric motors.
DOE understands that brake motors
contain multiple features that can affect
both utility and efficiency. In most
applications, electric motors are not
required to stop immediately. Instead,
electric motors typically slow down and
gradually stop after power is removed
from the motor due to a buildup of
friction and windage from the internal
components of the motor. However,
some applications require electric
motors to stop quickly. Such motors
may employ a brake component that,
when engaged, abruptly slows or stops
shaft rotation. The brake component
attaches to one end of the motor and
surrounds a section of the motor’s shaft.
During normal operation of the motor,
the brake is disengaged from the motor’s
shaft—it neither touches nor interferes
with the motor’s operation. However,
under normal operating conditions, the
brake is drawing power from the electric
motor’s power source and may also be
contributing to windage losses, because
the brake is an additional rotating
component on the motor’s shaft. When
power is removed from the electric
motor (and therefore the brake
component), the brake component deenergizes and engages the motor shaft,
quickly slowing or stopping rotation of
the rotor and shaft components. Because
of these utility related features that
affect efficiency, DOE has preliminarily
established a separate equipment class
group for electric motors with an
integral or non-integral brake.
d. Horsepower Rating
In its preliminary analysis, DOE
considered three criteria when
differentiating equipment classes. The
first criterion was horsepower, a critical
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performance attribute of an electric
motor that is directly related to the
capacity of an electric motor to perform
useful work and that generally scales
with efficiency. For example, a 50horsepower electric motor would
generally be considered more efficient
than a 10-horsepower electric motor. In
view of the direct correlation between
horsepower and efficiency, DOE
preliminarily used horsepower rating as
a criterion for distinguishing equipment
classes in the framework document and
continued with that approach for the
preliminary analysis.
NEMA agreed with DOE’s view that
horsepower is a performance attribute
that must be considered when
evaluating efficiency and urged that this
long-established and workable concept
not be abandoned. (NEMA, No. 54 at p.
40) In today’s proposal, DOE continues
to use horsepower as an equipment
class-setting criterion.
e. Pole Configuration
The number of poles in an induction
motor determines the synchronous
speed (i.e., revolutions per minute) of
that motor. There is an inverse
relationship between the number of
poles and a motor’s speed. As the
number of poles increases from two to
four to six to eight, the synchronous
speed drops from 3,600 to 1,800 to 1,200
to 900 revolutions per minute,
respectively. In addition, manufacturer
comments and independent analysis
performed on behalf of DOE indicate
that the number of poles has a direct
impact on the electric motor’s
performance and achievable efficiency
because some pole configurations utilize
the space inside of an electric motor
enclosure more efficiently than other
pole configurations. DOE used the
number of poles as a means of
differentiating equipment classes in the
preliminary analysis.
In response to the preliminary
analysis, NEMA agreed that the number
of poles of an electric motor has impacts
a motor’s achievable efficiency and
supported DOE’s decision to take this
characteristic into consideration.
(NEMA, No. 54 at p. 41) In today’s
proposal, DOE continues to use poleconfiguration as an equipment classsetting criterion.
f. Enclosure Type
EISA 2007 prescribes separate energy
conservation standards for open and
enclosed electric motors. (42 U.S.C.
6313(b)(1)) Electric motors
manufactured with open construction
allow a free interchange of air between
the electric motor’s interior and exterior.
Electric motors with enclosed
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construction have no direct air
interchange between the motor’s interior
and exterior (but are not necessarily airtight) and may be equipped with an
internal fan for cooling (see NEMA MG
1–2011, paragraph 1.26). Whether an
electric motor is open or enclosed
affects its utility; open motors are
generally not used in harsh operating
environments, whereas totally enclosed
electric motors often are. The enclosure
type also affects an electric motor’s
ability to dissipate heat, which directly
affects efficiency. For these reasons,
DOE used an electric motor’s enclosure
type (open or enclosed) as an equipment
class setting criterion in the preliminary
analysis.
NEMA acknowledged in its comments
that the enclosure type is an important
characteristic that affects the achievable
efficiency for any particular electric
motor. NEMA added that it may become
necessary to consider separate groups
for various enclosures as DOE continues
to expand the scope of electric motors
subject to energy conservation
standards, but did not make any specific
suggestions regarding which enclosures
could be considered separately. (NEMA,
No. 54 at p. 42)
At this time, DOE is continuing to use
separate equipment class groups for
open and enclosed electric motors but is
declining to further break out separate
equipment classes for different types of
open or enclosed enclosures because
DOE does not have data supporting such
separation.
g. Other Motor Characteristics
In the preliminary analysis, DOE
addressed various other motor
characteristics, but did not use them to
disaggregate equipment classes. In the
preliminary analysis TSD, DOE
provided its rationale for not
disaggregating equipment classes for
vertical electric motors, electric motors
with thrust or sleeve bearings, closecoupled pump motors, or by rated
voltage or mounting feet. DOE believes
that none of these electric motor
characteristics provide any special
utility that would impact efficiency and
justify separate equipment classes.
In response to the preliminary
analysis, DOE received comments about
how it should treat other motor
characteristics. NEMA agreed with
DOE’s decision that vertical motors,
motors with thrust or sleeve bearings,
and close-coupled pump motors do not
merit separate equipment classes.
(NEMA, No. 54 at p. 20) With no
comments suggesting that DOE use any
one of the alternative characteristics as
a criterion for equipment class, DOE is
using the approach it laid out in its
preliminary analysis.
DOE also requests additional
information from manufacturers on
whether covering any of these
technology options would reduce
consumer utility or performance or
cause any of the covered electric motors
to be unavailable in the U.S. and
whether U-frame motors have any
particular performance characteristics,
features, sizes, capacities, or volumes. In
particular, DOE requests any
information or data if these technology
options would lead to increases in the
size of the motors such that it would no
longer work in a particular space
constricted application, to decreases in
power thereby affecting their usability
of these motors, or to changes in any
other characteristics that would affect
the performance or utility of the motor.
5. Technology Assessment
The technology assessment provides
information about existing technology
options and designs used to construct
more energy-efficient electric motors.
Electric motors have four main types of
losses that can be reduced to improve
efficiency: Losses due to the resistance
of conductive materials (stator and rotor
I2R losses), core losses, friction and
windage losses, and stray load losses.
These losses are interrelated such that
measures taken to reduce one type of
loss can result in an increase in another
type of losses. In consultation with
interested parties, DOE identified
several technology options that could be
used to reduce such losses and improve
motor efficiency. These technology
options are presented in Table IV.6. (See
chapter 3 of the TSD for details).
TABLE IV.6—TECHNOLOGY OPTIONS TO INCREASE ELECTRIC MOTOR EFFICIENCY
Type of loss to reduce
Technology option
Stator I2R Losses .......................................................................................
Rotor I2R Losses ........................................................................................
Core Losses ...............................................................................................
Friction and Windage Losses .....................................................................
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Stray-Load Losses .....................................................................................
In response to the preliminary
analysis, DOE received multiple
comments about these options.
At the preliminary analysis public
meeting, NEMA requested clarification
on what was meant by the technology
option listed as ‘‘improving rotor bar
insulation.’’ (NEMA, Public Meeting
Transcript, No. 60 at p. 158) NEMA
commented on the option of increasing
the cross sectional area of the stator
windings and clarified that this is one
way to decrease stator resistance, but
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Increase cross-sectional area of copper in stator slots.
Decrease the length of coil extensions.
Use a die-cast copper rotor cage.
Increase cross-sectional area of rotor conductor bars.
Increase cross-sectional area of end rings.
Use electrical steel laminations with lower losses (watts/lb).
Use thinner steel laminations.
Increase stack length (i.e., add electrical steel laminations).
Optimize bearing and lubrication selection.
Improve cooling system design.
Reduce skew on rotor cage.
Improve rotor bar insulation.
not necessarily a separate technology
option. (NEMA, No. 54 at p. 44) NEMA
also clarified that reducing rotor
resistance through a change in volume
is synonymous with an increase in rotor
slot size, unless DOE intends to include
variations in the volume of the end
rings. (NEMA, No. 54 at p. 45)
NEMA also noted that chapter 3 of
DOE’s preliminary TSD did not discuss
the option of increasing the flux density
in the air gap, while chapter 4 did.
(NEMA, No. 54 at p. 46) NEMA added
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that the air gap flux density is not a
design option that can be independently
adjusted and that for a given core length
the only option available for changing
the air gap flux density is to change the
number of effective turns in the stator
winding. (NEMA, No. 54 at pp. 62, 63)
NEMA also commented on the
limitations associated with reducing a
motor’s air gap by noting that
manufacturers must ensure that the
motor is still functional and that the air
gap is not so small such that the rotor
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and stator may strike each other during
operation. (NEMA, No. 54 at pp. 44–45)
Lastly, during the preliminary
analysis public meeting, Danfoss
commented that the term ‘‘technology
options’’ is a bit misleading because of
the design tradeoffs that must be made
in order to maintain motor performance
(other than efficiency). (Danfoss, Public
Meeting Transcript, No. 60 at pp. 98, 99)
Regarding the requested clarifications,
DOE notes the listed option of
‘‘improved rotor insulation’’ refers to
increasing the resistance between the
rotor squirrel-cage and the rotor
laminations. Manufacturers use
different methods to insulate rotor
cages, such as applying an insulating
coating on the rotor slot prior to diecasting or heating and quenching 32 the
rotor to separate rotor bars from rotor
laminations after die-casting. DOE has
updated the discussion in the TSD
chapter to clarify that there are multiple
ways to implement this technology
option.
DOE agrees with NEMA that
increasing the cross-sectional area of
copper in the stator is synonymous with
reducing the stator resistance, and has
updated the discussion in TSD chapter
3 for clarity. Furthermore, DOE agrees
with NEMA that increasing rotor slot
size is a technique that reduces rotor
resistivity. DOE also considered other
techniques to reduce rotor resistivity
such as increasing the volume of the
rotor end rings and using die-cast
copper rotors. For the sake of clarity,
DOE has replaced the technology option
‘‘reduce rotor resistance’’ in the TSD
discussion with the specific techniques
that DOE considered in its analysis:
Increasing the cross-sectional area of the
rotor conductor bars, increasing the
cross-sectional area of the end rings, and
using a die-cast copper rotor cage.
With regard to increasing the flux
density in the air gap, DOE consulted
with its subject matter expert and
acknowledges that this approach is not
necessarily an independently adjustable
design parameter used to increase motor
efficiency and has removed it from its
discussion in chapters 3 and 4 of the
TSD. DOE notes that it understands that
the technology options that it discusses
do have limits, both practical limits in
terms of manufacturing and design
limits in terms of their effectiveness.
DOE also understands that a
manufacturer must balance any options
to improve efficiency against the
possible impacts on the performance
attributes of its motor designs.
32 Quenching is rapid cooling, generally by
immersion in a fluid instead of allowing the rotor
temperature to equalize to ambient
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a. Decrease the Length of Coil
Extensions
One method of reducing resistance
losses in the stator is decreasing the
length of the coil extensions at the end
turns. Reducing the length of copper
wire outside the stator slots not only
reduces the resistive losses, but also
reduces the material cost of the electric
motor because less copper is being used.
NEMA submitted comments
acknowledging decreased coil extension
as an option to increase efficiency, but
did not see the practicability. NEMA
asserted that decreasing the length of a
coil extension has been a common
industry practice for over 50 years and
it would be difficult to achieve any
further reductions in motor losses under
this option. NEMA added that any
design changes that would decrease the
length of a coil extension must be
carefully considered to ensure that the
coil heads meet all applicable creep and
strike distance requirements.33 (NEMA,
No. 54 at p. 57)
DOE understands that there may be
limited efficiency gains, if any, for most
electric motors using this technology
option. DOE also understands that
electric motors have been produced for
many decades and that many
manufacturers have improved their
production techniques to the point
where certain design parameters may
already be fully optimized. However,
DOE maintains that this is a design
parameter that affects efficiency and
should be considered when designing
an electric motor.
b. Increase Cross-Sectional Area of Rotor
Conductor Bars
Increasing the cross-sectional area of
the rotor bars, by changing the crosssectional geometry of the rotor, can
improve motor efficiency. Increasing the
cross-sectional area of the rotor bars
reduces the resistance and thus lowers
the I2R losses. However, changing the
shape of the rotor bars may affect the
size of the end rings and can also
change the torque characteristics of the
motor.
NEMA acknowledged that increasing
the cross-sectional area of rotor bars is
an option to increase efficiency, but
doubted whether any additional
reductions in motor losses were possible
by using this method. After 50 years of
33 Creep distance is the shortest path between two
conductive parts. An adequate creep distance
protects against tracking, a process that can lead to
insulation deterioration and eventual short circuit.
Strike distance is the shortest distance through air
from one conductor to another conductor or to
ground. Adequate strike distance is required to
prevent electrical discharge between two
conductors or between conductors and ground.
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increasing efficiency through this
technique, NEMA questioned whether
manufacturers could further increase
the cross-sectional area of the rotor bars,
adding that the increase in rotor current
cannot exceed the square of the decrease
in the rotor resistance in order for the
rotor losses to decrease. NEMA added
that any design changes using this
option must be carefully considered to
ensure that the motor will meet the
applicable NEMA MG 1 performance
requirements (i.e., stall time,
temperature rise, overspeed) and, for
certain applications, any other industry
standards (i.e., IEEE 841 34) to maintain
the same level of utility. (NEMA, No. 54
at pp. 57, 58)
DOE recognizes that increasing the
cross-sectional area of a conductor rotor
bar may yield limited efficiency gains
for most electric motors. However, DOE
maintains that this is a design parameter
that affects efficiency and must be
considered when designing an electric
motor. Additionally, when creating its
software models, DOE considered rotor
slot design, including cross sectional
areas, such that any software model
produced was designed to meet the
appropriate NEMA performance
requirements for torque and locked rotor
current.
c. Increase Cross-Sectional Area of End
Rings
End rings are the components of a
squirrel-cage rotor that create electrical
connections between the rotor bars.
Increasing the cross-sectional area of the
end rings reduces the resistance and
thus lowers the I2R losses in the end
rings. A reduction in I2R losses will
occur only when any proportional
increase in current as a result of an
increase in the size of the end ring is
less than the square of the proportional
reduction in the end ring resistance.
NEMA commented that increasing the
end ring size increases the rotor weight,
and consideration must be given to the
effects a heavier end ring will have on
the life of the rotor. NEMA added that
any design changes using this option
must be carefully considered to ensure
that the applicable design requirements
are met and intended utility retained.
(NEMA, No. 54 at p. 58)
When developing its software models,
DOE relied on the expertise of its
subject matter expert. Generally,
34 IEEE 841–2009, ‘‘IEEE Standard for Petroleum
and Chemical Industry—Premium-Efficiency,
Severe-Duty, Totally Enclosed Fan-Cooled (TEFC)
Squirrel Cage Induction Motors—Up to and
Including 370 kW (500 hp),’’ identifies the
recommended practice for petroleum and chemical
industry severe duty squirrel-cage induction
motors.
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increases to end ring area were limited
to 10–20% are unlikely to have
significant impacts on the mechanical
aspects of the rotor. Furthermore, DOE
ensured that the appropriate NEMA
performance requirements for torque
and locked-rotor current were
maintained with its software modeled
motors.
d. Increase the Number of Stator Slots
Increasing the number of stator slots
associated with a given motor design
can, in some cases, improve motor
efficiency. Similar to increasing the
amount of copper wire in a particular
slot, increasing the number of slots may
in some cases permit the manufacturer
to incorporate more copper into the
stator slots. This option would decrease
the losses in the windings, but can also
affect motor performance. Torque, speed
and current can vary depending on the
combination of stator and rotor slots
used.
NEMA indicated that increasing the
number of slots to allow the motor
design engineer to incorporate
additional copper into the stator slots is
contrary to any practical analysis.
NEMA elaborated that the stator core
holds the stator winding in the slots and
carries the magnetic flux in the
electrical steel. As stator slots increase,
insulating material will increase,
reducing the total amount of crosssectional area for stator winding.
Additionally, too large of an increase in
the number of stator slots may make it
impractical to wind the stator on
automated equipment and the same may
be true for a low number of stator slots.
NEMA also commented that while it
agrees with DOE that the number of
stator slots can affect motor torque and
efficiency, there is a relationship
between the number of rotor slots and
stator slots, and the combination of the
two can have significant effects on
starting torque, sound levels, and stray
load losses. NEMA concluded that all of
these effects must be considered to
ensure the practicability of
manufacturing the affected motors.
Other factors NEMA noted included
winding and potential sound levels—all
of which could impact utility along with
health and safety concerns. (NEMA, No.
54 at p. 61)
With respect to stator slot numbers,
DOE understands that a motor
manufacturer would not add stator slots
without any appreciation of the impacts
on the motor’s performance. DOE also
understands that there is an optimum
combination of stator and rotor slots for
any particular frame size and
horsepower combination. DOE
consulted with its subject matter expert
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and understands that optimum stator
and rotor slot combinations have been
determined by manufacturers and are in
use on existing production lines.’’
Consequently, DOE has removed this
technology option from chapter 4 of the
TSD.
e. Electrical Steel with Lower Losses
Losses generated in the electrical steel
in the core of an induction motor can be
significant and are classified as either
hysteresis or eddy current losses.
Hysteresis losses are caused by magnetic
domains resisting reorientation to the
alternating magnetic field. Eddy
currents are physical currents that are
induced in the steel laminations by the
magnetic flux produced by the current
in the windings. Both of these losses
generate heat in the electrical steel.
In studying the techniques used to
reduce steel losses, DOE considered two
types of materials: Conventional silicon
steels, and ‘‘exotic’’ steels, which
contain a relatively high percentage of
boron or cobalt. Conventional steels are
commonly used in electric motors
manufactured today. There are three
types of steel that DOE considers
‘‘conventional:’’ cold-rolled magnetic
laminations, fully processed nonoriented electrical steel, and semiprocessed non-oriented electrical steel.
One way to reduce core losses is to
incorporate a higher grade of core steel
into the electric motor design (e.g.,
switching from an M56 to an M19
grade). In general, higher grades of
electrical steel exhibit lower core losses.
Lower core losses can be achieved by
adding silicon and other elements to the
steel, thereby increasing its electrical
resistivity. Lower core losses can also be
achieved by subjecting the steel to
special heat treatments during
processing.
The exotic steels are not generally
manufactured for use specifically in the
electric motors covered in this
rulemaking. These steels include
vanadium permendur and other alloyed
steels containing a high percentage of
boron or cobalt. These steels offer a
lower loss level than the best electrical
steels, but are more expensive per
pound. In addition, these steels can
present manufacturing challenges
because they come in nonstandard
thicknesses that are difficult to
manufacture.
NEMA and Baldor submitted multiple
comments concerning DOE’s discussion
during the preliminary analysis
regarding the use of Epstein testing to
determine an electrical steel grade that
would improve the efficiency of an
electric motor. (NEMA, No. 54 at pp.
21–23, 62; NEMA, Public Meeting
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Transcript, No. 60 at pp. 100, 102, 103)
The grading of electrical steel is made
through a standardized test known
worldwide as the Epstein Test.35 This
test provides a standardized method of
measuring the core losses of different
types of electrical steels. NEMA
commented that relying solely on
Epstein test results to select grades of
steel could result in a motor designer
inadvertently selecting a steel grade that
performs poorly in a motor design.
NEMA supplied data on two different
samples of steel supplied by different
manufacturers, but consisting of the
same steel grade. The data illustrated
how the lower loss steel (as determined
by Epstein test results) resulted in a less
efficient motor when used in a
prototype. NEMA noted that this
situation poses a problem for computer
software modeling because a model that
represents only the general class of
electrical steel and not the steel source
(manufacturer) would not be able to
calculate the difference in the results
between the supposedly equivalent
grades of steels from separate
manufacturers.
DOE clarifies that its computer
software did not model general classes
of electrical steel, but instead modeled
vendor-specific electrical steel. DOE’s
software utilized core loss vs. flux
density curves supplied by an electrical
steel vendor as one component of the
core loss calculated by the program. A
second component was also added to
account for high frequency losses. DOE
agrees with NEMA’s claim that relative
performance derived from Epstein
testing might not be indicative of
relative performance in actual motor
prototypes. DOE did not solely rely on
relative steel grade when selecting
electrical steels for its designs. To
illustrate this point, DOE notes that
almost all of its software modeled
designs utilized M36 grade steel, even
though it was not the highest grade of
electrical steel considered in the
analysis. When higher grade M15 steel
was evaluated in DOE’s software
modeled designs, the resulting
efficiencies were actually lower than the
efficiencies when using M36 grade steel
for several reasons including the reasons
cited by NEMA. The Epstein test results
for various grades of steel provided in
chapter 3 of the preliminary analysis
TSD were purely informational and
intended to give an indication of the
relative performance of a sample of
35 ASTM Standard A343/A343M, 2003 (2008),
‘‘Standard Test Method for Alternating-Current
Magnetic Properties of Materials at Power
Frequencies Using Wattmeter-Ammeter-Voltmeter
Method and 25-cm Epstein Test Frame,’’ ASTM
International, West Conshohocken, PA 2008.
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electrical steels considered. That
information has been removed from
chapter 3 of the TSD to avoid any
further confusion.
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f. Thinner Steel Laminations
As addressed earlier, there are two
types of core losses that develop in the
electrical steel of induction motors—
hysteresis losses and losses due to eddy
current. Electric motors can use thinner
laminations of core steel to reduce eddy
currents. The magnitude of the eddy
currents induced by the magnetic field
become smaller in thinner laminations,
making the motor more energy efficient.
In the preliminary analysis, DOE only
considered conventional steels with
standard gauges available in the market.
NEMA agreed with DOE’s initial
decision to consider only lamination
thicknesses that are currently used in
motor manufacturing, as there is a
practical limit on how thick the
laminations can be in electric motors
before additional losses may become
significant. (NEMA, No. 54 at p. 62)
DOE continues to consider this as a
viable technology option in the NOPR
analysis.
g. Increase Stack Length
Adding electrical steel to the rotor
and stator to lengthen the motor can
also reduce the core losses in an electric
motor. Lengthening the motor by
increasing stack length reduces the
magnetic flux density, which reduces
core losses. However, increasing the
stack length affects other performance
attributes of the motor, such as starting
torque. Issues can arise when installing
a more efficient motor with additional
stack length because the motor becomes
longer and may not fit into applications
with dimensional constraints.
NEMA requested clarification of the
phrase ‘‘add stack height,’’ which DOE
included in its summary of technology
options for improving efficiency in
chapter 3 of the preliminary TSD.
NEMA was unsure if this meant
increasing the length of the core or
increasing the outer diameter of the
stator core laminations. (NEMA, no. 54
at p. 45)
DOE clarifies that it was referring to
increasing the length of the stator and
rotor. However, increasing the outside
diameter of the stator core is another
way in which manufacturers could add
active material to their electric motor
designs and potentially increase
efficiency.
NEMA agreed that changing the stack
length of an electric motor can improve
core losses (i.e. reduce them), but may
also change other performance
characteristics such as torque, speed
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and current. However, NEMA stressed
that there are limits to this technology
option because too much additional
stack could cause the motor to increase
in size (i.e., frame length), which might
introduce utility problems in spaceconstrained applications (NEMA, No. 54
at p. 62) NEMA also commented that
since the EISA 2007 standards were
enacted, only a limited number of motor
ratings above NEMA Premium have
been offered because there is not
sufficient space available in most frame
ratings to increase the efficiency.
(NEMA, No. 54 at p. 7) DOE
understands that there are limits to
increased stack length and, as discussed
in IV.C, DOE established criterion to
limit the length of the stack considered
in the engineering analysis. DOE also
understands that stack length affects
consumer utility, which is a factor that
DOE considers in its selection of a
standard.
h. More Efficient Cooling System
Optimizing a motor’s cooling system
that circulates air through the motor is
another technology option to improve
the efficiency of electric motors.
Improving the cooling system reduces
air resistance and associated frictional
losses and decreases the operating
temperature (and associated electrical
resistance) by cooling the motor during
operation. This can be accomplished by
changing the fan or adding baffles to the
current fan to help redirect airflow
through the motor.
NEMA agreed that changes in the
cooling system may reduce the total
losses of a motor, but did not agree that
this is equivalent to a more efficient
cooling system, as DOE described.
NEMA elaborated that when the design
of an electric motor is changed, losses
associated with the cooling system may
increase in order to provide a decrease
in losses associated with some other
part of the design. (NEMA, No. 54 at p.
63) DOE appreciates NEMA’s comments
and has clarified its phrasing of this
technology option to reflect the fact that
it is the motor that becomes more
efficient, not necessarily the cooling
system.
i. Reduce Skew on Conductor Cage
In the rotor, the conductor bars are
not straight from one end to the other,
but skewed or twisted slightly around
the axis of the rotor. Decreasing the
degree of skew can improve a motor’s
efficiency. The conductor bars are
skewed to help eliminate harmonics
that add cusps, losses, and noise to the
motor’s speed-torque characteristics.
Reducing the degree of skew can help
reduce the rotor resistance and
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reactance, which helps improve
efficiency. However, overly reducing the
skew also may have adverse effects on
starting, noise, and the speed-torque
characteristics.
NEMA inquired if this design option
was considered for any of the designs
used in the engineering analysis, as the
preliminary TSD did not indicate if any
rotors were skewed. (NEMA, No. 54 at
p. 63) NEMA also inquired why the
option to reduce skew on the conductor
cage, was associated with I2R losses in
chapter 3 of the preliminary TSD, but in
chapter 4 of the preliminary TSD this
option was associated with reducing
stray load losses. (NEMA, No. 54 at p.
46)
DOE notes that all software designs
used in the analysis had skewed rotor
designs and, in general, the skews used
were approximately 100 percent of a
stator or rotor slot pitch, whichever had
the smaller number of slots.
Additionally, DOE intended for the
option of reducing the skew on the
conductor cage to be an option
associated with reducing stray load
losses and has made the appropriate
adjustments to its text and tables.
B. Screening Analysis
After DOE identified the technologies
that might improve the energy efficiency
of electric motors, DOE conducted a
screening analysis. The purpose of the
screening analysis is to determine
which options to consider further and
which to screen out. DOE consulted
with industry, technical experts, and
other interested parties in developing a
list of design options. DOE then applied
the following set of screening criteria,
under sections 4(a)(4) and 5(b) of
appendix A to subpart C of 10 CFR Part
430, ‘‘Procedures, Interpretations and
Policies for Consideration of New or
Revised Energy Conservation Standards
for Consumer Products,’’ to determine
which design options are unsuitable for
further consideration in the rulemaking:
• Technological Feasibility: DOE will
consider only those technologies
incorporated in commercial equipment
or in working prototypes to be
technologically feasible.
• Practicability to Manufacture,
Install, and Service: If mass production
of a technology in commercial
equipment and reliable installation and
servicing of the technology could be
achieved on the scale necessary to serve
the relevant market at the time of the
effective date of the standard, then DOE
will consider that technology
practicable to manufacture, install, and
service.
• Adverse Impacts on Equipment
Utility or Equipment Availability: DOE
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will not further consider a technology if
DOE determines it will have a
significant adverse impact on the utility
of the equipment to significant
subgroups of customers. DOE will also
not further consider a technology that
will result in the unavailability of any
covered equipment type with
performance characteristics (including
reliability), features, sizes, capacities,
and volumes that are substantially the
same as equipment generally available
in the United States at the time.
• Adverse Impacts on Health or
Safety: DOE will not further consider a
technology if DOE determines that the
technology will have significant adverse
impacts on health or safety.
Table IV.7 below presents a general
summary of the methods that a
manufacturer may use to reduce losses
in electric motors. The approaches
presented in this table refer either to
specific technologies (e.g., aluminum
versus copper die-cast rotor cages,
different grades of electrical steel) or
physical changes to the motor
geometries (e.g., cross-sectional area of
rotor conductor bars, additional stack
height). For additional details on the
screening analysis, please refer to
chapter 4 of the preliminary TSD.
TABLE IV.7—SUMMARY LIST OF OPTIONS FROM TECHNOLOGY ASSESSMENT
Type of loss to reduce
Technology option
Stator I2R Losses .......................................................................................
Rotor I2R Losses ........................................................................................
Core Losses ...............................................................................................
Friction and Windage Losses .....................................................................
Stray-Load Losses .....................................................................................
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1. Technology Options Not Screened
Out of the Analysis
The technology options in this section
are options that passed the screening
criteria of the analysis. DOE considers
the technology options in this section to
be viable means of improving the
efficiency of electric motors. In NEMA’s
view, DOE’s screening analysis lacked
sufficient supporting information
regarding whether a particular
technology is included or screened out
of the analysis. NEMA agreed that it is
necessary to look at new technologies,
but added that DOE did not provide
adequate supporting information in its
analysis and the group asserted that
commenters were left without adequate
material upon which to base comments
in support of or in opposition to
statements made in the preliminary
TSD. NEMA suggested that a form
clearly identifying the issues pertinent
to the topic be provided for each option
analyzed. NEMA stated that providing
these forms for each technology option
would supply adequate material on
which commenters can develop public
comments. (NEMA, No. 54 at p. 45)
Additionally, when discussing the
seven criteria that DOE must consider in
its analysis, NEMA expressed that there
are more criteria that should be
considered. NEMA stated that DOE
must consider 4(d)(7) of 10 CFR part
430, subpart C, appendix A which lists
under sections 4.(d)(7)(viii) impacts of
non-regulatory approaches and (ix) new
information relating to the factors used
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Increase cross-sectional area of copper in stator slots.
Decrease the length of coil extensions.
Use a die-cast copper rotor cage.
Increase cross-sectional area of rotor conductor bars.
Increase cross-sectional area of end rings.
Use electrical steel laminations with lower losses (watts/lb).
Use thinner steel laminations.
Increase stack length (i.e., add electrical steel laminations).
Optimize bearing and lubrication selection.
Improve cooling system design.
Reduce skew on rotor cage.
Improve rotor bar insulation.
for screening design options. (NEMA,
No. 54 at p. 13)
Regarding NEMA’s request for a form
for each technology option considered,
today’s NOPR provides detailed
information about each technology
option considered and DOE is
requesting comment on each option.
DOE understands NEMA’s concerns
about the technology options not
screened out of the DOE analysis. With
the exception of copper rotor motors,
DOE understands that each technology
option that it has not screened out is a
design option that a manufacturer
would consider in each motor designed
and built. DOE recognizes that
manufacturers design their motors to
balance a number of competing factors
that all inter-relate with each other,
including performance, reliability, and
energy efficiency. Because the options
DOE has identified can be modified to
improve efficiency while maintaining
performance, it is DOE’s tentative view
that at least some significant level of
energy efficiency improvement is
possible with each technology option
not screened out by DOE.
Furthermore, DOE notes that it did
not explicitly use each of the technology
options that passed the screening
criteria in the engineering analysis. As
discussed in section IV.C, DOE’s
engineering analysis was a mixture of
two approaches that DOE routinely uses
in its engineering analysis methodology:
The reverse-engineering approach (in
which DOE has no control over the
design parameters) and the efficiency-
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level approach (in which DOE tried to
achieve a certain level of efficiency,
rather than applying specific design
options). This hybrid of methods did
not allow for DOE to fully control which
design parameters were ultimately used
for each representative unit in the
analysis. Without the ability to apply
specific design options, DOE could not
include every option that was not
screened out of the analysis. Finally,
DOE appreciates NEMA’s comments
regarding Appendix A to Subpart U of
part 430. DOE has considered all
comments related to the two factors
identified by NEMA in its rule.
In addition, DOE notes that its
analysis neither assumes nor requires
manufacturers to use identical
technology for all motor types,
horsepower ratings, or equipment
classes. In other words, DOE’s standards
are technology-neutral and permit
manufacturers design flexibility.
a. Copper Die-Cast Rotors
Aluminum is the most common
material used today to create die-cast
rotor bars for electric motors. Some
manufacturers that focus on producing
high-efficiency designs have started to
offer electric motors with die-cast rotor
bars made of copper. Copper offers
better performance than aluminum
because it has better electrical
conductivity (i.e., a lower electrical
resistance). However, because copper
also has a higher melting point than
aluminum, the casting process becomes
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more difficult and is likely to increase
both production time and cost.
NEMA commented that performance
is a relative term, and that the NEMA
MG 1–2011 standard specifies
performance characteristics and
specifications for various types of
motors. NEMA added that tradeoffs
among various performance
characteristics related to the
conductivity of copper are required
when designing a NEMA Design B
electric motor that is in full
conformance with the NEMA MG 1–
2011 standards. NEMA commented that
DOE did not address all aspects of
motor performance specified in the
NEMA MG 1–2011 standard, especially
some of the performance requirements
related to the choice of conductive
material in the rotor. (NEMA, No. 54 at
p. 46)
DOE acknowledges that using copper
in rotors may require different design
approaches and considerations. In its
own modeling and testing of copper
rotor motors, DOE ensured that
performance parameters stayed within
MG 1–2011 limits (i.e., met NEMA
Design B criteria). DOE seeks comment
on any particular aspects of copper rotor
design, especially those on parameters
widely viewed as challenging to meet,
and requests explanation of why such
parameters are especially challenging
when using copper.
The Advocates (NEEA, NPCC, ACEEE,
ASAP, Earthjustice, and ASE) disagreed
with DOE’s tentative decision during
the preliminary analysis phase to
include copper die-cast rotors. It urged
DOE to exclude this option in order to
avoid analyzing a technology that is not
ready for use across all motor types,
configurations, and horsepower ratings
that DOE would cover as part of its
rulemaking. (Advocates, No. 56 at pp.
3–4)
On a related note, NEMA commented
that DOE has not publicly established
what determines a ‘‘mass quantity.’’
NEMA elaborated that a ‘‘mass
quantity’’ should mean the ability to be
produced in significant volume for the
entire industry. NEMA commented that
DOE screened out certain electrical
steels because they could not be
produced in significant volume for the
entire industry, and this same logic
should apply to copper rotor
technology. (NEMA, No. 54 at p. 24)
DOE did not screen out copper as a
die-cast rotor conductor material
because copper die-cast rotors passed
the four screening criteria. Because
copper is in commercial use today, DOE
concluded that this material is
technologically feasible and practicable
to manufacture, install, and service.
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Additionally, manufacturers are already
producing such equipment, which
suggests that such equipment can be
safely produced in mass quantities. For
example, Siemens produces copper
rotor motors for 1–20 hp and SEWEurodrive manufactures a full line of
motors from 1–30 hp. In addition, DOE
notes that its analysis neither assumes
nor requires manufacturers to use
identical technology for all motor types,
horsepower ratings, or equipment
classes.
DOE received considerable feedback
concerning copper rotor technology.
Consequently, DOE has organized those
comments into sections below as they
pertain to the four screening criteria.
Technological Feasibility
As part of its analysis, DOE intends to
ensure that utility, which includes
frame size considerations, is
maintained. Increased shipping costs
are also taken into account in the
national impact analysis (NIA) and the
life-cycle cost (LCC) analysis portions of
DOE’s analytical procedures.
NEMA commented that the use of a
technology in a limited subclass of
electric motors does not imply that the
technology can be applied to every
equipment class covered in this
rulemaking. NEMA is not aware of any
available complete product line of
NEMA Design A, B, or C copper die-cast
rotor electric motors manufactured in
the United States, and stated that further
investigation is required to prove this
technology is valid for an entire range
of designs. (NEMA, No. 54 at pp. 2, 48,
49) NEMA was able to find two
manufacturers currently producing
copper rotor motors in a total of only 33
out of over 600 equipment classes
covered in this rulemaking.36 NEMA
and Baldor added that none of those
motors are produced in the United
States, and only about half of those
ratings met NEMA Design B
performance requirements. (NEMA, No.
54 at pp. 48, 49; Baldor, Public Meeting
Transcript, No. 60 at pp. 109, 110)
NEMA commented that the diecasting process for copper rotors can
increase core or stray load losses in the
motor, and this is a problem with
copper die-casting that has not been
solved in all rotor sizes. (NEMA, No. 54
at p. 46)
NEMA cited recently conducted U.S.
Army studies involving die-cast copper
36 The equipment classes NEMA found included
NEMA Design A motors from 1 to 30 hp, 4-pole
configurations, and NEMA Design B motors from
1.5 to 20 hp in a 2-pole configuration, 1 to 20 hp
in a 4-pole configuration, and 1 hp and 3–10 hp in
a 6-pole configuration. All motor configurations
NEMA mentioned were enclosed frame motors.
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rotor motors. It explained that the first
study evaluated the advantages of a diecast copper rotor versus an aluminum
rotor. The study also attempted to
optimize the process and estimate
manufacturing costs for die-cast copper
rotors. NEMA commented that the
results of the study showed that the diecast copper rotor motor was unable to
stay within the NEMA Design B lockedrotor current limits, and that efficiency
increased by less than one full NEMA
band over the comparable NEMA Design
B aluminum cast-copper rotor motor.
The study reported that continued
investment in cast copper rotor motor
technology development is needed to
improve design optimization methods,
improve the casting process, and to
investigate utilization of cast copper in
larger motor sizes. NEMA commented
that the number of die-cast copper
rotors manufactured in the study was
insufficient to make any determination
that die-casting could be performed on
a high and consistent quality basis
necessary for general production.
(NEMA, No. 54 at p. 50, 51)
NEMA also described a different U.S.
Army study where a 75-hp aluminum
rotor motor driving a pump was to be
replaced with a 75-hp copper rotor
motor. NEMA explained that in the
study the die-cast copper rotor motor’s
optimization study indicated the motor
would have a one NEMA band increase
in efficiency over the aluminum die-cast
rotor motor it was replacing. However,
once built, the 75-hp die-cast copper
rotor motor had an actual efficiency of
more than 1 NEMA band below the
aluminum die-cast rotor motor, with
core and stray load losses of the
physical motor being higher than the
computer model had predicted. NEMA
concluded that neither study was
successful in demonstrating that copper
rotor die-casting technology is possible
or feasible in its current state in the
U.S., and that continued investment in
die-cast copper rotor technology
development is necessary to improve
the copper die-casting process and
reduce stray load losses. (NEMA, No. 54
at pp. 51–53)
BBF, a consulting company working
on behalf of the Copper Development
Association (CDA), commented that test
data of multiple die-cast copper rotor
motors resulted in an average tested
efficiency above the motors’ nameplate
efficiency, whereas the test results from
a similar model aluminum rotor motor
tested below its nameplate efficiency. In
its view, these results fall within the
allowable variances prescribed by
NEMA with respect to measuring
electric motor energy efficiency and
demonstrate the higher energy
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efficiency potential of die-cast copper
rotor motors. (BBF, No. 51 at p. 3)
NEMA summarized that it is not
aware of any prototypes or
commercially available products that
have demonstrated the technical
feasibility of utilizing die-cast copper
rotors sufficient to cover all equipment
classes covered in this rulemaking.
NEMA disagreed with DOE’s conclusion
that die-cast copper rotors successfully
passed the screening criteria for
technological feasibility relative to the
class of all covered electric motors,
including the 75-hp copper rotor motor
which DOE used as a representative unit
in the engineering analysis. NEMA
added that DOE has not provided any
evidence that die-casting copper can
successfully be applied to all electric
motors covered in this rulemaking by
December 19, 2015. NEMA added that
the recent studies conducted by the
United States Army noted above
showed that, in the U.S. at present or in
any foreseeable future time, this
technology is not currently feasible over
the range of motor ratings regulated
under this rulemaking. (NEMA, No. 54
at pp. 3, 53, 56; NEMA, Public Meeting
Transcript, No. 60 at p. 111)
The CDA disagreed with NEMA, and
stated that die-cast copper rotor motors
are a feasible technology because
manufacturers have already successfully
entered the copper rotor motor market.
The CDA added that a range of
development issues have been
overcome, again suggesting that it is
technologically feasible, but copper diecast rotors require redesign and
optimization to take advantage of
copper’s different electrical properties
compared to aluminum, and many
motor manufacturers have undertaken
this redesign and optimization to take
advantage of the properties of copper.
(BBF, No. 51 at p. 3) The CDA agreed,
however, that current manufacturing
capacity would be unable to produce
motors on the scale of five million units
yearly. (CDA, Public Meeting
Transcript, No. 60 at p. 119)
DOE acknowledges that the industry
is not equipped to produce all motors
with copper rotors, but has estimated
the costs of both capital and product
development through interviews with
manufacturers of motors and included
these costs in its engineering analysis.
DOE welcomes comment on the
methodology, and on the resulting
motor prices. As noted earlier, EPCA, as
amended, does not require
manufacturers to use identical
technology for all motor types,
horsepower ratings, or equipment
classes.
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DOE recognizes that assessing the
technological feasibility of highhorsepower copper die-cast rotors is
made more complex by the fact that
manufacturers do not offer them
commercially. That could be for a
variety of reasons, among them:
1. Large copper die-cast rotors are
physically impossible to construct;
2. They are possible to construct, but
impossible to construct to required
specifications;
3. They are possible to construct to
required specifications, but would
require manufacturing capital
investment to do so and be so costly that
few (if any) consumers would choose
them.
Some exploratory research suggests
that different organizations have
developed and used copper rotors in
high-horsepower traction (i.e., vehicle
propulsion) motors. For example, Tesla
Motors powers its Roadster 37 and
Model S 38 vehicles with copper
induction motors generating 300 39 or
more peak horsepower and Oshkosh
die-cast copper rotor induction motors
rated at 140 peak hp.40 Remy
International, Inc. (Remy) also builds
high-horsepower copper motors that are
claimed to exceed 300 horsepower at
600V.41 DOE seeks comment on these,
and on other high-horsepower motors
that use copper rotors.
DOE recognizes that these motors are
designed for a different purpose than
most motors in the current scope of this
rulemaking. Their existence suggests
that copper has been successfully used
at high power levels in an application
where efficiency is critical and casts
doubt on the idea that copper die-cast
rotors can be screened out with
certainty.
Another reason to be cautious about
screening out copper die-cast rotors
comes from an analogous product:
Distribution transformers. DOE
conducted a recent rulemaking on
distribution transformers,42 which (as
with motors) have two sets of
conductors that surround electrical steel
to transfer power. Although distribution
transformers do not rotate, many of the
ways that they lose energy (e.g.,
conductor losses) are the same as
electric motors. They also face
37 https://www.teslamotors.com/roadster/
technology/motor.
38 https://www.teslamotors.com/models/specs.
39 https://www.teslamotors.com/roadster/specs.
40 See https://www.coppermotor.com/wp-content/
uploads/2012/04/casestudy_army-truck.pdf.
41 https://www.remyinc.com/docs/hybrid/REM–
12_HVH410_DataSht.pdf.
42 Available at: https://www.regulations.gov/
#!documentDetail;D=EERE-2010-BT-STD-00480762.
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constraints (as motors do) on
performance aspects unrelated to
efficiency; inrush current and overall
volume are two examples. At current
prices, copper is generally not viewed as
economical for most efficiency levels
but, if properly designed, copper
windings almost always result in
smaller, cooler, and more efficient
transformers.
In general, copper may improve
efficiency relative to aluminum because
it carries an inherently higher level of
electrical conductivity. Several
organizations have conducted research
and built prototype 43 motors that use
materials even more conductive than
copper, such as ‘‘superconductive’’
materials that have no conductive losses
to achieve even greater electric motor
efficiency. While DOE is not
considering the use of these more
conductive materials at this time, DOE
notes their existence for purposes of
demonstrating the potential advantages
of using materials that lower conductive
losses.
While recognizing that motors are not
transformers, the parallels that can be
drawn leave DOE hesitant to screen out
copper die-cast rotors on the basis of
technological feasibility. Relative to the
above list of possible reasons for their
absence from the high-horsepower
market, DOE’s analysis does not
conclude copper die-cast rotors are
either: (1) Physically impossible to
construct or (2) possible to construct,
but impossible to construct to required
specifications.
Practicability To Manufacture, Install,
and Service
Regarding DOE’s projections that the
annual sales of electric motors, as
defined by EISA 2007 will have grown
to 5,089,000 units by 2015, including
over 24,000 possible motor
configurations, NEMA commented that
only a single manufacturer is currently
producing die-cast copper rotor motors,
and in a very limited range. In its view,
without sufficient data and analysis to
support DOE’s conclusion that ‘‘mass
production’’ of die-cast copper rotors is
possible, NEMA asserts that this
technology would not pass the
screening criterion of practicability to
manufacture, install, and service. It
argues that, based on the limited
advances of the technology from 1995 to
present day in the United States, this
technology is unlikely to be mature
enough by the compliance date for this
rulemaking to meet the required
production of over 5 million motors in
43 See General Atomics marine propulsion motor
at: https://www.ga.com/electric-drive-motors.
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the U.S., even if all manufacturing were
shifted overseas. (NEMA, No. 54 at pp.
3, 47, 53, 54, 56; NEMA, Public Meeting
Transcript, No. 60 at p. 114) NEMA
noted that mandating this technology
may also have the indirect effect of
establishing a monopoly market in the
U.S. for those manufacturers who can
produce copper rotor motors, or to push
production jobs overseas and penalize
motor manufacturers that do not have
the capability to produce copper rotor
motors. (NEMA, No. 54 at p. 24)
DOE recognizes the importance of
maintaining a competitive market.
However, because there are at least two
domestic manufacturers of motors with
copper rotors and because several more
are manufacturing internationally, DOE
believes the opportunity for price
manipulation is limited. Furthermore,
DOE has seen no evidence to suggest
that a monopoly would be likely to
occur. DOE requests comment and
further information that would
demonstrate the likelihood of a future
monopoly.
BBF and the CDA commented that
there are copper die-casting facilities in
the U.S.—specifically in Colorado and
Ohio—as well as in Mexico. They added
that die-cast rotor motors have been
produced for North American service
since 2005, and some of these motors
meet NEMA Design B requirements. The
CDA and BBF added that multiple highvolume manufacturers in Europe and
Asia have produced tens of thousands of
die-cast copper rotor motors that satisfy
the NEMA-specified performance
requirements that meet or exceed the
NEMA Premium levels. These motors
have been sold to North American users.
(BBF, No. 51 at pp. 2, 3) DOE was able
to purchase and tear down a 5-hp
copper rotor motor from an Asian
manufacturer that performed at DOE’s
max-tech efficiency level, as well as the
performance requirements for NEMA
Design B.
SEW Eurodrive stated that it offers
only three models of cast-copper rotor
motors and cited the expenses and
difficulty of casting copper rotors as the
reason why it does not offer more diecast copper rotor motor models. (SEWE,
Public Meeting Transcript, No. 60 at p.
121) The company did not elaborate
why it manufactures die-cast copper
rotor motors in the configurations it
offers for sale.
Based on these comments, DOE does
not believe it has grounds to screen out
copper die-cast rotors on the basis of
practicability to manufacture, install,
and service. The available facts indicate
that manufacturers are already
producing smaller motors with die-cast
copper rotors, leaving the question of
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whether larger motors are being
manufactured with die-cast copper
rotors. DOE recognizes that as
technology scales upward in size, it can
require different equipment and
processes. Nonetheless, Tesla’s 44 and
Remy’s 45 300+ horsepower motors with
copper rotors cast doubt on the assertion
that copper is impracticable in this size
range.
DOE understands that full-scale
deployment of copper would likely
require considerable capital investment
(see detailed discussion in
SectionIV.J.2.a) and that such
investment could increase the
production cost of large copper rotor
motors considerably. DOE believes that
its current engineering analysis reflects
this likelihood, and welcomes comment
on this issue.
engineering analysis reflects its
estimates of these costs and discusses
them in detail in section IV.C. DOE was
able to model copper rotor motors
adhering to the specifications of NEMA
Design B 46, including the reduced
(relative to Design A) locked-rotor
current.
Finally, based on DOE’s own
shipments analysis (see TSD Chapter 9)
and estimates of worldwide annual
copper production,47 DOE estimates
that .01-.02% of worldwide copper
supply would be required to use copper
rotors for every single motor within
DOE’s scope of coverage. At the present,
DOE does not believe there is sufficient
evidence to screen copper die-cast
rotors from the analysis on the basis of
adverse impacts to equipment utility or
availability.
Adverse Impacts on Equipment Utility
or Equipment Availability
Adverse Impacts on Health or Safety
NEMA commented that the
preliminary TSD does not sufficiently
explain how DOE concluded that
mandating performance levels that
would require copper rotor die-casting
would not have an adverse impact on
health or safety, with the implication
being on occupational health and safety.
NEMA commented that the preliminary
TSD mentioned potential impacts on the
health or safety caused by the higher
melting point of copper, but DOE did
not elaborate on what these potential
impacts were. NEMA disagreed with
DOE’s conclusion not to screen out diecast copper rotor technology on the
premise that handling molten copper is
similar to handling molten aluminum.
NEMA noted that copper has a pouring
temperature of 2100 degrees Fahrenheit
and a 150 percent higher casting
pressure than aluminum, and that,
combined, these two characteristics
would increase the severity of any
potential accidents. NEMA mentions an
incident involving the two U.S. Army
die-cast copper rotor studies previously
mentioned, which resulted in injuries
during the die-casting of aluminum 48
[sic] cage rotors and caused the only
U.S. manufacturer of copper die-casting
equipment to withdraw that equipment
from the market. NEMA added that the
equipment currently remains
unavailable for purchase. (NEMA, No.
54 at pp. 10, 55, 56; NEMA, Public
NEMA commented that DOE failed to
address the adverse impacts on
equipment utility or availability caused
by die-cast copper rotors. It asserted that
the process for manufacturing die-cast
copper rotors is underdeveloped, and
energy conservation standards based on
this technology, and implemented in
2015, would result in product
unavailability of over 99 percent of the
electric motors that would be impacted
if DOE were to set a standard that would
require the use of die-cast copper.
NEMA reiterated that there is no
justification as to how motors that are
not available today, made from a
technology that is not practiced in the
U.S. today, will become available within
three years, especially when taking into
account the time needed for
prototyping, testing, and AEDM
certification. (NEMA, No. 54 at pp. 3,
47, 48, 54, 55, 56; NEMA, Public
Meeting Transcript, No. 60 at pp. 114,
115)
NEMA also commented that it is
difficult for die-cast copper rotor motors
to stay under the maximum locked-rotor
current limit for NEMA Design B
motors. If this technology were adopted,
in its view, many current NEMA Design
B motors would become NEMA Design
A motors. This would reduce the utility
of a motor, because a NEMA Design A
motor is not a direct drop-in place
replacement for a NEMA Design B
motor. (NEMA, No. 54 at p. 3)
DOE agrees that, in some cases,
redesigning product lines to use copper
would entail substantial cost. DOE’s
44 https://www.teslamotors.com/roadster/
technology/motor.
45 https://www.remyinc.com/docs/hybrid/REM-12_
HVH410_DataSht.pdf.
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46 The parameters DOE believed to present the
largest risk of rendering a motor noncompliant with
NEMA MG 1–2011 standards were those related to
NEMA design letter, which were adhered to in
DOE’s modeling efforts.
47 https://minerals.usgs.gov/minerals/pubs/
commodity/copper/mcs-2012-coppe.pdf.
48 From the context of NEMA’s comment, DOE
believes the use of the word ‘‘aluminum’’ was a
typographical error and that NEMA had intended
this passage to use the word ‘‘copper’’ instead.
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Meeting Transcript, No. 60 at p. 115)
NEMA added that, especially regarding
die-casting copper on larger motor sizes,
DOE cannot justifiably claim that there
are no adverse impacts on health or
safety until they conduct a thorough
investigation or feasibility study
regarding this topic. (NEMA, No. 54 at
p. 3)
However, BBF also commented that
copper die-cast rotors can be safely
manufactured, as one major
manufacturer indicated that they have
had no worker injuries in volume
production over multiple years. (BBF,
No. 51 at p. 3)
BBF commented that, with the
extensive capabilities of copper die-cast
rotors and commercial availability of
copper die-cast rotors with efficiencies
higher than NEMA MG 1–2011 Table
12–12 efficiencies, DOE should include
in its evaluations copper die-cast rotor
motors. BBF also added that they
strongly disagree with the NEMA
representatives’ contrary verbal
suggestions towards copper rotor motor
technology presented during the public
meeting. (BBF, No. 51 at p. 4)
DOE is aware of the higher melting
point of copper (1084 degrees Celsius
versus 660 degrees Celsius for
aluminum) and the potential impacts
this may have on the health or safety of
plant workers. However, DOE does not
believe at this time that this potential
impact is sufficiently adverse to screen
out copper as a die cast material for
rotor conductors. The process for die
casting copper rotors involves risks
similar to those of die casting
aluminum. DOE believes that
manufacturers who die-cast metal at 660
Celsius or 1085 Celsius (the respective
temperatures required for aluminum
and copper) would need to observe
strict protocols to operate safely. DOE
understands that many plants already
work with molten aluminum die casting
processes and believes that similar
processes could be adopted for copper.
DOE has not received any supporting
data about the increased risks associated
with copper die casting, and could not
locate any studies suggesting that the
die-casting of copper inherently
represented incrementally more risks to
worker safety and health. DOE notes
that several OSHA standards relate to
the safety of ‘‘Nonferrous Die-Castings,
Except Aluminum,’’ of which die-cast
copper is part. DOE seeks comment on
any adverse safety or health impacts and
on these OSHA standards,49 and on any
other specific information document the
49 For a list, see: https://www.osha.gov/pls/imis/
citedstandard.sic?p_esize=&p_state=FEFederal&p_
sic=3364.
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safety of die-casting for both copper and
aluminum.
b. Increase the Cross-Sectional Area of
Copper in the Stator Slots
Increasing the slot fill by either
adding windings or changing the gauge
of wire used in the stator winding can
also increase motor efficiency. Motor
design engineers can achieve this by
manipulating the wire gauges to allow
for a greater total cross-sectional area of
wire to be incorporated into the stator
slots. This could mean either an
increase or decrease in wire gauge,
depending on the dimensions of the
stator slots and insulation thicknesses.
As with the benefits associated with
larger cross-sectional area of rotor
conductor bars, using more total crosssectional area in the stator windings
decreases the winding resistance and
associated losses. However, this change
could affect the slot fill factor of the
stator. The stator slot openings must be
able to fit the wires so that automated
machinery or manual labor can pull (or
push) the wire into the stator slots. In
the preliminary analysis, DOE increased
the cross-sectional area of copper in the
stator slots of the representative units by
employing a combination of additional
windings, thinner gauges of copper
wire, and larger slots.
In response to the preliminary
analysis, NEMA commented that a
majority of stator windings are
manufactured on automated equipment.
NEMA and Baldor noted that there is a
practical limit of 82 percent slot fill for
automated winding equipment for
motors with four or more poles; motors
with two poles have a limit of 78
percent. (NEMA, No. 54 at p. 58; Baldor,
Public Meeting Transcript, No. 60 at p.
146) NEMA commented that the values
for maximum slot fill for the automated
winding models was approximately 82
percent and those based on hand
winding were 85 percent. NEMA noted
that this is not a practical change based
on a change in conductor size alone
because conductors are sized in a larger
increment than this difference would
suggest. Therefore, it would appear that
the size of the stator slot in each case
was selected to purposely result in the
corresponding level of slot fill. (NEMA,
No. 54 at p. 59) In other words, instead
of only adjusting the conductor gauge to
the slot size, the slot size could be
adjusted to the conductor gauge.50
(NEMA, No. 54 at p. 59) Baldor added
that slot fills above 85 percent would be
very difficult to do in current
production volumes (5 million motors
50 In practice, of course, a manufacturer may opt
to do either or both.
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annually) and noted that this slot fill
percentage was based on a DOEpresented software model and has not
been proven in a prototype. (Baldor,
Public Meeting Transcript, No. 60 at pp.
146, 147) NEMA requested that DOE
clarify the method it used for
calculating slot fill to avoid confusion
among other interested parties who may
have used a different calculation
method. (NEMA, No. 54 at p. 58)
DOE calculated the slot fill by
measuring the total area of the stator slot
and then subtracting the cross sectional
area for the slot insulation. This method
gave DOE a net area of the slot available
to house copper winding. DOE then
identified the slot with the most
windings and found the cross sectional
area of the insulated copper wires to get
the total copper cross sectional area per
slot. DOE then divided the total copper
cross sectional area by the total slot area
to derive the slot fill. DOE’s estimated
slot fills for its teardowns and software
models are all provided in chapter 5 of
the TSD.
NEMA commented that several of
DOE’s designs presented maximum
values of slot fill at 85 percent, whereas
the closest automated winding slot fill
was 82-percent. NEMA questioned the
significant benefit DOE projected in
designing the stator slot such that a
hand winding would be required to gain
a 3-percent change in slot fill. In
NEMA’s view, the change in core loss
that might result from increasing the
stator slot area by 3 percent would not
be significant enough to warrant handwinding the stator. (NEMA, No. 54 at p.
59) DOE notes that the software designs
exhibiting these changes in slot fill were
used when switching from aluminum to
a copper rotor design. Therefore,
changing slot geometries impacted the
design’s slot fill and the slot fill changes
resulted from different motor designs.
Consequently, a 3 percent increase in
slot fill does not imply that this change
was made to increase the efficiency of
another design, but could have been
made to change other performance
criteria of the motor, such as lockedrotor current.
In the preliminary analysis, DOE
indicated that motor design engineers
can adjust slot fill by changing the gauge
of wire used in fractions of half a gauge.
NEMA commented that it did not
understand DOE’s statement, and
indicated that manufacturers limit the
number of gauges used at any particular
manufacturing plant, and few of those
gauges are ‘‘fractions of a half a gauge.’’
NEMA added that manufacturers may
use multiple wire gauges in a particular
winding, but DOE’s examples in chapter
5 gave no indication that any sizes other
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than a single conductor size was used in
each winding. (NEMA, No. 54 at pp. 58,
59) DOE clarifies that all the modeled
motors utilized standard AWG wire
sizes, either whole- or half-gauge sizes
(i.e., 18 or 181⁄2). DOE clarifies that the
statement of ‘‘fractions of a half gauge’’
referred to sizes in between a whole
gauge (i.e. 181⁄2 of a gauge is a fraction
of 18 gauge wire). DOE did not end up
using fractions consisting of a half gauge
of wire sizes to conduct its modeling,
but did indicate that this was a design
option used by the motor industry.
NEMA also commented that it is not
uncommon for a manufacturer to use
the same stator lamination design for all
horsepower ratings built in the same
NEMA MG 1–2011 Standard frame
series. NEMA indicated that a high slot
fill may require hand winding for one of
the ratings and automated winding for
the other rating, and that a good design
practice for stator laminations will take
into consideration more than just one
motor rating to determine the best
design for all ratings in that frame
series. (NEMA, No. 54 at p. 59)
NEMA and Baldor questioned DOE’s
decision not to screen out hand-wound
stators, and both parties commented
that moving to hand-wound technology
would be a reversal of the trend to
automate manufacturing practices
whenever possible. (NEMA, No. 54 at p.
59; Baldor, Public Meeting Transcript,
No. 60 at pp. 122, 123) NEMA noted
that none of the teardown motors in
DOE’s analysis appeared to use hand
winding technology. (NEMA, No. 54 at
p. 59)
While NEMA agrees that hand
winding cannot be ruled out on the
grounds of technological feasibility, it
does believe that hand winding would
not be practicable to use in mass
production. A NEMA member survey
indicated that hand winding can take up
to 25 times longer than machine
winding. NEMA added that the
manpower required to replace
automated winding would require an
increase in manpower in excess of 20
times the number of automated
machines. (NEMA, No. 54 at p. 60)
NEMA and Baldor commented that
moving to an energy conservation level
based on hand-wound technology
would not be achievable on the scale
necessary to serve the relevant market at
the time of the effective date of the
standard. (NEMA, No. 54 at p. 60;
Baldor, Public Meeting Transcript, No.
60 at p. 123) NEMA added that it would
not be aware if such an expansion of the
infrastructure would be required until
after any amended or new standards are
announced. (NEMA, No. 54 at p. 60)
DOE is aware of the extra time involved
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with hand winding and has attempted
to incorporate this time into efficiency
levels (ELs) that it believes would
require hand winding. DOE reiterates
that should the increase in
infrastructure, manpower, or motor cost
increase beyond a reasonable means,
then ELs utilizing this technology will
be screened out during the downstream
analysis.
NEMA also expressed concern that
standards based on hand winding
would shift U.S. manufacturing jobs to
locations outside of the U.S. which have
lower labor rates, and Nidec added that
most U.S. manufacturers are currently
globally positioned to move laborintensive work into low-cost labor
countries if energy conservation
requirements force them to do so.
(Nidec, Public Meeting Transcript, No.
60 at p. 124) DOE intends to fully
capture this impact during the
manufacturer impact analysis (MIA)
portion of DOE’s analysis. Please see
section IV.J for a discussion of the
manufacturer impact analysis.
NEMA also commented that handwound technology would have an
adverse impact on product utility or
product availability, saying that the
infrastructure would not be in place in
sufficient time to support the hand
winding of all of the stators, and there
will be an adverse impact on the
availability of various ratings of electric
motors at the time of effective standards.
(NEMA, No. 54 at p. 60)
NEMA commented that hand winding
would have adverse impacts on worker
health or safety, as both hand winding
and hand insertion of stator coils
require operations performed by hand
with repetitive motions, and such hand
winding of stators also involves the
moving and lifting of various stator and
winding components, which may be of
substantial size in larger horsepower
rated electric motors. NEMA added that
any increase in personnel performing
the repetitive tasks required by hand
winding can have an adverse effect on
the overall health and safety record of
any facility. (NEMA, No. 54 at p. 60;
NEMA, Public Meeting Transcript, No.
60 at p. 123)
DOE disagrees with NEMA’s assertion
concerning the adverse impacts on
health or safety, and notes that hand
winding is currently practiced by
industry. Furthermore, DOE is not
aware of any data or studies suggesting
hand-winding leads to negative health
consequences. DOE acknowledges that,
were hand-winding to become
widespread, manufacturers would need
to hire more workers to perform handwinding to maintain person-windinghour equivalence, and has accounted for
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the added costs of hand-winding in its
engineering analysis. DOE requests
comment on its cost estimates for handwound motors, as well as on the matter
of hand-winding in general and on
studies suggesting negative health
impacts in particular.
NEMA summarized its concerns,
saying that hand winding is not a viable
technology option, especially for a slot
fill increase of less than 5 percent.
NEMA believes that the engineering
analysis should not be based on stator
slot fill levels which require hand
winding, which are generally slot fills
above 78 percent for 2-pole motor and
82 percent for 4-, 6-, and 8-pole motors.
(NEMA, No. 54 at p. 60)
DOE acknowledges that the industry
is moving towards increased
automation. However, hand winding is
currently practiced by manufacturers,
making it a viable option for DOE to
consider as part of its engineering
analysis. Considering the four screening
criteria for this technology option, DOE
did not screen out the possibility of
changing gauges of copper wire in the
stator as a means of improving
efficiency. Motor design engineers
adjust this option by using different
wire gauges when manufacturing an
electric motor to achieve desired
performance and efficiency targets.
Because this design technique is in
commercial use today, DOE considers
this technology option both
technologically feasible and practicable
to manufacture, install, and service.
DOE is not aware of any adverse
impacts on consumer utility, reliability,
health, or safety associated with
changing the wire gauges in the stator to
obtain increased efficiency. Should the
technology option prove to not be
economical on a scale necessary to
supply the entire industry, then this
technology option would be likely not
be selected for in the analysis, either in
the LCC or MIA.
DOE seeks comment generally on the
process of increasing the cross-section
of copper in the stator, and in particular
on the costs and reliability of the hand
winding process.
2. Technology Options Screened Out of
the Analysis
DOE developed an initial list of
design options from the technologies
identified in the technology assessment.
DOE reviewed the list to determine if
the design options are practicable to
manufacture, install, and service; would
adversely affect equipment utility or
equipment availability; or would have
adverse impacts on health and safety. In
the engineering analysis, DOE did not
consider any of those options that failed
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to satisfy one or more of the screening
criterion. The design options screened
out are summarized in Table IV.8.
TABLE IV.8—DESIGN OPTIONS
SCREENED OUT OF THE ANALYSIS
Design option
excluded
Eliminating screening
criterion
Plastic Bonded Iron
Powder (PBIP).
Amorphous Steels .....
Technological Feasibility.
Technological Feasibility.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
NEMA agreed with DOE in that
plastic bonded iron powder has not
been proven to be a technologically
feasible method of construction of stator
and rotor cores in induction motors.
(NEMA, No. 54 at p. 64) NEMA also
agreed that amorphous metal
laminations are not a type of material
that lends itself to use in electric motors
in the foreseeable future. However,
NEMA expressed concern that this
technology was only screened out on
the basis of technological feasibility
because it had not been used in a
prototype. (NEMA, No. 54 at p. 63)
Baldor and NPCC also agreed with
DOE’s decision to exclude PBIP and
amorphous steels from the engineering
analysis. (Baldor, Public Meeting
Transcript, No. 60 at p. 108; Advocates,
No. 56 at p. 3)
DOE is continuing to screen out both
of these technology options from further
consideration in the engineering
analysis. Additionally, DOE
understands the concerns expressed by
NEMA regarding technological
feasibility, but DOE maintains that if a
working prototype exists, which implies
that the motor has performance
characteristics consistent with other
motors using a different technology,
then that technology would be deemed
technologically feasible. However, that
fact would not necessarily mean that a
technology option would pass all three
of the remaining screening criteria.
Chapter 4 of this preliminary TSD
discusses each of these screened out
design options in more detail, as well as
the design options that DOE considered
in the electric motor engineering
analysis.
C. Engineering Analysis
The engineering analysis develops
cost-efficiency relationships for the
equipment that are the subject of a
rulemaking by estimating manufacturer
costs of achieving increased efficiency
levels. DOE uses manufacturing costs to
determine retail prices for use in the
LCC analysis and MIA. In general, the
engineering analysis estimates the
efficiency improvement potential of
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individual design options or
combinations of design options that
pass the four criteria in the screening
analysis. The engineering analysis also
determines the maximum
technologically feasible energy
efficiency level.
When DOE proposes to adopt a new
or amended standard for a type or class
of covered product, it must determine
the maximum improvement in energy
efficiency or maximum reduction in
energy use that is technologically
feasible for such product. (42 U.S.C.
6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined
the maximum technologically feasible
(‘‘max-tech’’) improvements in energy
efficiency for electric motors, using the
design parameters for the most efficient
products available on the market or in
working prototypes. (See chapter 5 of
the NOPR TSD.) The max-tech levels
that DOE determined for this
rulemaking are described in IV.C.3 of
this proposed rule.
In general, DOE can use three
methodologies to generate the
manufacturing costs needed for the
engineering analysis. These methods
are:
(1) The design-option approach—
reporting the incremental costs of
adding design options to a baseline
model;
(2) the efficiency-level approach—
reporting relative costs of achieving
improvements in energy efficiency; and
(3) the reverse engineering or cost
assessment approach—involving a
‘‘bottoms up’’ manufacturing cost
assessment based on a detailed bill of
materials derived from electric motor
teardowns.
1. Engineering Analysis Methodology
DOE’s analysis for the electric motor
rulemaking is based on a combination of
the efficiency-level approach and the
reverse engineering approach. Primarily,
DOE elected to derive its production
costs by tearing down electric motors
and recording detailed information
regarding individual components and
designs. DOE used the costs derived
from the engineering teardowns and the
corresponding nameplate nominal
efficiency of the torn down motors to
report the relative costs of achieving
improvements in energy efficiency. DOE
derived material prices from current,
publicly available data as well as input
from subject matter experts and
manufacturers. For most representative
units analyzed, DOE was not able to test
and teardown a max-tech unit because
such units are generally cost-prohibitive
and are not readily available. Therefore,
DOE supplemented the results of its test
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and teardown analysis with software
modeling.
When developing its engineering
analysis for electric motors, DOE
divided covered equipment into
equipment class groups. As discussed,
there are four electric motor equipment
class groups: NEMA Design A and B
motors (ECG 1), NEMA Design C motors
(ECG 2), fire pump electric motors (ECG
3), and brake motors (ECG 4). The
motors within these ECGs are further
divided into equipment classes based on
pole-configuration, enclosure type, and
horsepower rating. For DOE’s
rulemaking, there are 580 equipment
classes.
2. Representative Units
Due to the high number of equipment
classes for electric motors, DOE selected
and analyzed only a few representative
units from each ECG and based its
overall analysis for all equipment
classes within that ECG on those
representative units. During the NOPR
analysis, DOE selected three units to
represent ECG 1 and two units to
represent ECG 2. DOE based the analysis
of ECG 3 on the representative units for
ECG 1 because of the low shipment
volume and run time of fire pump
electric motors. DOE also based the
analysis of ECG 4 on the analysis of ECG
1 because the vast majority of brake
motors are NEMA Design B motors.
When selecting representative units for
each ECG, DOE considered NEMA
design type, horsepower rating, poleconfiguration, and enclosure.
a. Electric Motor Design Type
For ECG 1, which includes all NEMA
Design A and B motors that are not fire
pump or brake motors, DOE only
selected NEMA Design B motors as
representative units to analyze in the
preliminary analysis engineering
analysis. DOE chose NEMA Design B
motors because NEMA Design B motors
have slightly more stringent
performance requirements, namely their
locked-rotor current has a maximum
allowable level for a given rating.
Consequently, NEMA Design B motors
are slightly more restricted in terms of
their maximum efficiency levels.
Therefore, by analyzing a NEMA Design
B motor, DOE could ensure
technological feasibility for all designs
covered in ECG 1. Additionally, NEMA
Design B units have much higher
shipment volumes than NEMA Design A
motors because most motor driven
equipment is designed (and UL listed)
to run with NEMA Design B motors.
NEMA agreed with DOE’s decision to
base any amended or new standards for
ECG 1 motors on NEMA Design B motor
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types because consumers generally
prefer NEMA Design B motors due to
the fact that locked-rotor current is
constrained to established industry
standards in these motors, making it
easier to select suitable motor-starting
devices. NEMA pointed out that, on the
other hand, the use of a NEMA Design
A motor may require the purchaser of
the motor to expend a significant
amount of time and expense in selecting
suitable motor-starting devices to
operate the motor in an appropriate and
safe manner. NEMA elaborated that it is
important to base the analysis on NEMA
Design B motors in order to minimize
any disruption to consumers based on
their preference for NEMA Design B.
(NEMA, No. 54 at p. 64) DOE
appreciates NEMA’s feedback. For its
NOPR engineering analysis, DOE has
continued to select NEMA Design B
motors as its representative units in
ECG 1.
As mentioned for ECG 2, DOE
selected two representative units to
analyze. Because NEMA Design C is the
only NEMA design type covered by this
ECG, DOE only selected NEMA Design
C motors as its representative units.
For ECG 3, which consists of fire
pump electric motors, DOE based its
engineering analysis on the NEMA
Design B units analyzed for ECG 1 in the
preliminary analysis. As noted, in order
to be in compliance with section 9.5 of
National Fire Protection Association
(NFPA) ‘‘Standard for the Installation of
Stationary Pumps for Fire Protection’’
Standard 20–2010, which is a
requirement for a motor to meet DOE’s
current definition of a fire pump electric
motor, the motor must comply with
NEMA Design B (or IEC Design N)
requirements.51 Although DOE
understands that fire pump electric
motors have additional performance
requirements, DOE believed that
analysis of the ECG 1 motors would
serve as a sufficient approximation for
the cost-efficiency relationship for fire
pump electric motors. The design
differences between a NEMA Design B
motor (or IEC-equivalent) and fire pump
electric motor are small and unlikely to
greatly affect incremental cost behavior.
NEMA disagreed with DOE’s assertion
that fire pump electric motors are
required to meet NEMA Design B
standards, and commented that, as
51 With the exception of having a thermal shutoff
switch, which could prevent a fire pump motor
from performing its duty in hot conditions, NFPA
20 also excludes several motor types not considered
in this rulemaking from the NEMA Design B
requirement. They are direct current, high-voltage
(over 600 V), large-horsepower (over 500 hp),
single-phase, universal-type, and wound-rotor
motors.
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defined in 10 CFR 431.12, fire pump
electric motors are not limited to NEMA
Design B performance standards. NEMA
requested that DOE clarify DOE’s
statement in the preliminary analysis
that currently, efficiency standards have
only been established for fire pump
electric motors that are NEMA Design B.
(NEMA, No. 54 at p. 25) NEMA also
commented that the additional
performance requirements for fire pump
electric motors (e.g., the ability to
withstand stall conditions for longer
periods of time) mean they are usually
designed with lower locked-rotor
current limits. Therefore, NEMA stated
that fire pump electric motors may have
a maximum efficiency potential slightly
lower than typical, general purpose
NEMA Design B motors. (NEMA, No. 54
at pp. 24–25, 40, 64, 70; NEMA, Public
Meeting Transcript, No. 60 at pp. 135,
136) NEMA added that they support
DOE’s decision to analyze fire pump
motors in a separate equipment class
group because of the short run time of
fire pump electric motors. (NEMA, No.
54 at p. 71)
Regarding DOE’s fire pump electric
motor definition, as detailed in the final
electric motors test procedure, DOE
intends its fire pump electric motor
definition to cover both NEMA Design
B motors and IEC-equivalents that meet
the requirements of section 9.5 of NFPA
20. See 77 FR 26617–18. As stated in the
final electric motors test procedure,
DOE agrees with stakeholders that IECequivalent motors should be included
within the scope of the definition of
‘‘fire pump electric motor,’’ although
NFPA 20 does not explicitly recognize
the use of IEC motors with fire pumps.
77 FR 26617. DOE realizes that section
9.5 of NFPA 20 specifically requires that
fire pump motors shall be marked as
complying with NEMA Design B. The
fire pump electric motor definition that
DOE created focuses on ensuring that
compliance with the energy efficiency
requirements are applied in a consistent
manner. DOE believes that there are IEC
motors that can be used in fire pump
applications that meet both NEMA
Design B and IEC Design N criteria, as
well as NEMA MG1 service factors.
DOE’s definition encompasses both
NEMA Design B motors and IECequivalents. To the extent that there is
any ambiguity as to how DOE would
apply this definition, in DOE’s view,
any Design B or IEC-equivalent motor
that otherwise satisfies the relevant
NFPA requirements would meet the fire
pump electric motor definition in 10
CFR 431.12. To the extent that there is
confusion regarding this view, DOE
invites comments on this issue, along
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with any data demonstrating whether
any IEC-equivalent motors are listed for
fire pump service either under the
NFPA 20 or another relevant industry
standard.
Regarding NEMA’s other fire pump
electric motor comment, DOE agrees
that some fire pump electric motors may
not be required to meet the NEMA
Design B performance requirements (or
IEC-equivalent comments). However,
those motors that are not required to
meet the NEMA Design B performance
requirements are direct-current motors,
motors with high voltages (i.e., greater
than 600 V), motors with high
horsepower ratings (i.e., greater than
500 horsepower), single-phase motors,
universal-type motors, or wound-rotor
motors. Any motor with such attributes
would not meet the nine motor
characteristics that define the scope of
electric motors covered in this
rulemaking. Additionally, any fire
pump electric motor that is not rated for
continuous duty is not, and would not
be, covered by the scope of today’s
rulemaking. Therefore, DOE clarifies
that any fire pump electric motor
currently subject to, or potentially
subject to, energy conservation
standards as a result of this rulemaking,
would have to meet the NEMA Design
B (or IEC-equivalent) performance
requirements. As indicated above, DOE
seeks comment on whether its current
regulatory definition requires further
clarification.
Additionally, DOE understands
NEMA’s comments regarding the
potential limitations of fire pump
electric motors. However, DOE believes
that its approximation, by using the
NEMA Design B electric motors from
ECG 1 is sufficient, at this time. In
DOE’s preliminary analysis, DOE found
that all efficiency levels analyzed for
fire pump electric motors resulted in
negative life-cycle cost savings for
consumers and a negative net present
values for the Nation. This was the
result of extremely low operating hours
and therefore, limited energy cost
savings potential. DOE notes that there
are minimal shipments and no
efficiency levels are likely to be deemed
economically justifiable.
Additionally, DOE understands that
fire pump motors are similar in both
performance and architecture to NEMA
Design B motors, the chief difference
being the absence of thermal cutoff
capability that would render a fire
pump motor unable to perform its
function in a hot environment. For
compliance purposes, however, the
distinction is less important. DOE
welcomes comment on the similarity
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between fire pump and NEMA Design B
motors.
Equipment class group 4, consisting
of brake motors, is also based on ECG
1 because DOE is only aware of brake
motors being built to NEMA Design B
specifications. Furthermore, DOE
understands that there is no
fundamental difference in design
between brake and non-brake electric
motors, other than the presence of the
brake. Therefore, the same design
options could be used on both sets of
electric motors and both motor types are
likely to exhibit similar cost versus
efficiency relationships.
For the final rule, DOE may consider
combining ECGs 1 and 4 again, as was
done for the preliminary analysis, but
such a decision depends, in part, on the
outcome of its concurrent electric
motors test procedure rulemaking.
Currently, DOE believes that its
proposed approach to testing brake
motors will mitigate the impact of the
brake component’s contributions to
motor losses such that the demonstrated
efficiency would be the same as if the
motor had been tested with the brake
completely removed (essentially making
it no different from the motors covered
by ECG 1). (See 78 FR 38467) With this
approach, a separate ECG would not be
necessary.
b. Horsepower Rating
Horsepower rating is an important
equipment class setting criterion. When
DOE selected its preliminary analysis
representative units, DOE chose those
horsepower ratings that constitute a
high volume of shipments in the market
and provide a wide range upon which
DOE could reasonably base a scaling
methodology. For NEMA Design B
motors, for example, DOE chose 5-,
30-, and 75-horsepower-rated electric
motors to analyze as representative
units. DOE selected the 5-horsepower
rating because these motors have the
highest shipment volume of all motors.
DOE selected the 30-horsepower rating
as an intermediary between the small
and large frame number series electric
motors. Finally, DOE selected a 75horsepower unit because there is
minimal variation in efficiency for
motors with horsepower ratings above
75-horsepower. Based on this fact, DOE
determined it was unnecessary to
analyze a higher horsepower motor.
Additionally, as horsepower levels
increase, shipments typically decrease.
Therefore, DOE believed there would be
minimal gains to its analysis had it
examined a higher horsepower
representative unit.
During the public meeting, Baldor
commented that the representative units
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should have been selected based on
energy consumption and not shipment
numbers. Baldor indicated that using
this approach, the 10-horspower motor
would have been designated as a
representative unit rather than the 5horsepower motors. (Baldor, Public
Meeting Transcript, No. 58 at p. 132,
133) NEMA reiterated Baldor’s stance in
its submitted comments, saying that the
5-horsepower motor would not appear
to be the only choice for the
representative unit. (NEMA, No. 54 at
p. 65) NEMA and Baldor also
commented that there are motors built
in frame series larger than the standard
75-horsepower frame series and DOE
should select a motor built in the largest
NEMA MG 1 frame series as a
representative unit. (NEMA, No. 54 at
p. 65; Baldor, Public Meeting
Transcript, No. 60 at p. 133) NEMA
added that efficiency ratings start to
level off once horsepower ratings exceed
150-horsepower, not above 75horsepower. Therefore, they argued that
selecting a horsepower rating above 150horsepower would have been a better
indicator if the perceived increase in
efficiency calculated for lower
horsepower ratings would be achievable
by larger horsepower ranges. (NEMA,
No. 54 at pp. 27, 65) Baldor reiterated
this comment in the preliminary
analysis public meeting. (Baldor, Public
Meeting Transcript, No. 60 at pp. 133–
134)
While DOE agrees with NEMA that
the 5-horsepower electric motor was not
the only choice for the representative
unit, it selected the 5-horsepower motor
for multiple reasons. The 5-horsepower
unit had the highest percentage of
shipments for all covered electric
motors, which ensured that there would
be multiple efficiency levels from
multiple manufacturers available for
comparison during the teardown
analysis. In addition, because DOE later
employed scaling, it attempted to find a
frame series and D-dimension 52 that
could serve as a strong basis from which
to scale to a relatively small set of
unanalyzed frame series. The standard
NEMA MG 1–2011 frame series for the
5-horsepower enclosed motor was a
midpoint between the standard frame
series for 1 horsepower and 10horsepower motors, which was the
group of ratings covered by the 5horsepower representative unit. A larger
representative unit would have meant a
52 ‘‘D’’ dimension is the length from the centerline
of the shaft to the mounting feet of the motor, and
impacts how large the motor’s laminations can be,
impacting the achievable efficiency of the motor.
‘‘D’’ dimensions are designated in NEMA MG 1–
2011 Section 4.2.1, Table 4–2.
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larger range of frame series on which to
apply the scaling methodology.
As to DOE’s selection of the 75horsepower representative unit as a
maximum, DOE understands that the
75-horsepower motor is not built in the
largest NEMA MG 1–2011 frame series
covered, but maintains that its selection
is appropriate for this analysis. As
stated previously, efficiency changes
slowly when approaching the highest
horsepower ratings, and choosing a
higher horsepower rating would not
have provided any appreciable
improvement over the data DOE already
developed for its analysis. DOE has
found minimal variation in efficiency
for motors above 75-horsepower.
Because the change in efficiency
diminishes with increasing horsepower,
one may achieve a similar level of
analytical accuracy with fewer data
points at higher horsepower. Stated
inversely, one needs more data points to
accurately characterize a curve where it
has a greater rate of change, such as
lower horsepower. Finally, DOE notes
that its scaling methodology mirrors the
scaling methodology used in NEMA’s
MG 1–2011 tables of efficiencies,
including the rate of change in
efficiency with horsepower.
DOE also notes that section 13 of
NEMA MG 1–2011 does not standardize
frame series for NEMA Design B motors
at the highest horsepower levels covered
in today’s proposal. Therefore, motors
with the highest capacity have
variability in their frame series. This
added flexibility would give
manufacturers more options to improve
the efficiency of their largest motors
covered by this rulemaking. Although
altering the frame size of a motor may
be costly, DOE believes that its selection
of a 75-hp representative unit for higher
horsepower motors is appropriate for
scaling higher horsepower efficiency
levels and the efficiency levels
examined are technologically feasible
for the largest capacity motors.
For NEMA Design C electric motors,
DOE again selected the 5-horsepower
rating because of its prevalence. In
addition, DOE selected a 50-horsepower
rating as an incrementally higher
representative unit. DOE only selected
two horsepower ratings for these electric
motors because of their low shipment
volumes. For more information on how
DOE selected these horsepower ratings
see chapter 5 of the TSD.
In submitted comments, NEMA
expressed confusion over DOE’s
selection of the 50-horsepower
representative unit for the NEMA
Design C equipment class group. NEMA
stated that the NEMA T-frame size for
such a rating is 326T, which is three
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NEMA T-frame number series below the
largest frame number series of 440.
NEMA requested that DOE clarify why
it limited its NEMA Design C
representative unit to such a low value
in its engineering analysis. (NEMA, No.
54 at p. 66) Finally, NEMA commented
that the 2011 shipment data that DOE
used to select its representative units
was not broken down by NEMA design
type. NEMA believed that using such
data to select representative units for
ECGs 1 and 2 was not appropriate and
requested clarification. (NEMA, No. 54
at p. 66)
As with ECG 1, DOE selected
representative units that fell in the
middle of the range of ratings covered
in this rulemaking and not necessarily
the largest frame size covered in the
rulemaking. Furthermore, as discussed
earlier, NEMA Design C motors are
produced in a smaller range of
horsepower ratings than NEMA Design
B motors (1 to 200 rather than 1 to 500).
With this smaller horsepower range, a
correspondingly smaller range of
representative units is needed.
Therefore, DOE selected a slightly lower
rating as its maximum for ECG 2. As for
the shipments data used to select the 5hp representative unit, DOE
acknowledges that it did not separate
the data by design type, and has revised
the text for the NOPR’s TSD to add
clarity. However, DOE still maintains
that the prevalence of 5-hp units make
it an appropriate selection as a
representative unit.
c. Pole-Configuration
Pole-configuration is another
important equipment class setting
criterion that DOE had to consider when
selecting its representative units. For the
preliminary analysis, DOE selected 4pole motors for all of its representative
units. DOE chose 4-pole motors because
they represent the highest shipment
volume of motors compared to other
pole configurations. DOE chose not to
alternate between pole configurations
for its representative units because it
wanted to keep as many design
characteristics constant as possible. By
doing so, it would allow DOE to more
accurately identify how design changes
affect efficiency across horsepower
ratings. Additionally, DOE believed that
the horsepower rating-versus-efficiency
relationship is the most important
(rather than pole-configuration and
enclosure type-versus-efficiency)
because there are significantly more
horsepower ratings to consider.
NEMA noted that efficiency gains
based on a 4-pole configuration do not
confirm that those same gains are
achievable in other pole configurations,
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and there is no foundation for scaling
across different pole configurations.
NEMA added that it is necessary to
know how designs change with respect
to pole-configuration, and analyzing
samples of one pole configuration limits
the ability to make decisions based on
other pole-configurations. NEMA
commented that designs significantly
vary across pole-configurations,
especially regarding torque
characteristics. (NEMA, No. 54 at pp.
26, 66–67) NEMA also stated that the
purpose of the engineering analysis is
not necessarily to determine the
‘‘reasons for efficiency improvements,’’
but to determine if efficiency can be
improved in accordance with meeting
the requirements of being
technologically feasible and
economically justified per 42 U.S.C.
6295(o)(A) and (B). (NEMA, No. 54 at p.
26) Baldor also commented on scaling
across pole configurations, saying that
the rotor diameter grows as the pole
number increases, which may cause
higher losses in 2-pole motors compared
to other pole configurations covered in
this rulemaking. (Baldor, Public Meeting
Transcript, No. 60 at pp. 130, 131)
As mentioned earlier, DOE is
assessing energy conservation standards
for 580 equipment classes. Analyzing
each of the classes individually is not
feasible, which requires DOE to select
representative units on which to base its
analysis. DOE understands that different
pole-configurations have different
design constraints. Originally, DOE
selected only 4-pole motors to analyze
because they were the most common,
allowing DOE to most accurately
characterize motor behavior at the pole
configuration consuming the majority of
motor energy. Additionally, by holding
pole-configuration constant across its
representative units, DOE would be able
to develop a baseline from which to
scale. By maintaining this baseline and
holding all other variables constant,
DOE is able to modify the horsepower
of the various representative units and
isolate which efficiency effects are due
to size.
As discussed in section IV.C.8, DOE
has used the simpler of two scaling
approaches presented in the preliminary
analysis because both methods had
similar results. This simpler approach
does not require DOE to develop a
relationship for 4-pole motors from
which to scale. Furthermore, DOE notes
that the scaling approach it selected
mirrors the scaling laid out in NEMA’s
MG 1–2011 tables, in which at least a
subset of the motors industry has
already presented a possible
relationship between efficiency and
pole count. DOE has continued to
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analyze 4-pole electric motors because
they are the most common and DOE
believes that all of the efficiency levels
it has developed are technologically
feasible.
d. Enclosure Type
The final equipment class setting
criterion that DOE considered when
selecting its representative units was
enclosure type. For the preliminary
analysis, DOE elected to analyze electric
motors with enclosed designs rather
than open designs for all of its
representative units. DOE selected
enclosed motors because, as with poleconfigurations, these motors have higher
shipments than open motors. Again,
DOE did not alternate between the two
design possibilities for its representative
units because it sought to keep design
characteristics as constant as possible in
an attempt to more accurately identify
the reasons for efficiency improvements.
NEMA commented that DOE’s
analysis did not consider the
significance of enclosure type as it
relates to efficiency, and that the NEMA
MG 1 frame designations for open frame
motors are often in a smaller frame
series than an enclosed-frame motor of
the same horsepower rating. NEMA and
Baldor commented that there is
generally a lower efficiency level
designated for open-frame motors, and
that there is no direct scaling
relationship between the efficiency
standards for open motors relative to
enclosed frame motors in the scope of
this rulemaking. (NEMA, No. 54 at p.
68; Baldor, Public Meeting Transcript,
No. 60 at p. 131) Baldor recommended
that DOE analyze motors of different
enclosures in order to understand the
difference between achievable efficiency
levels in open and enclosed electric
motors. (Baldor, Public Meeting
Transcript, No. 60 at pp. 131–132)
NEMA commented that the engineering
analysis should be supported by the
testing and analysis of both open and
enclosed frame motors. (NEMA, No. 54
at p. 68) Finally, NEMA commented that
by not selecting representative units
with different enclosure types, DOE fails
to meet the statutory requirement that
any prescribed amended or new
efficiency standards are in fact
technically feasible, practical to
manufacture, and have no adverse
impacts on product utility or product
availability. (NEMA, No. 54 at pp. 68–
69)
DOE acknowledges the comments
from interested parties regarding
enclosure type and its selection of
representative units. The final
equipment class setting criterion that
DOE had to consider when selecting its
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representative units was enclosure type.
For the preliminary analysis, DOE
analyzed only electric motors with
totally enclosed, fan-cooled (TEFC)
designs rather than open designs for all
of its representative units. DOE selected
TEFC motors because, as with pole
configurations, DOE wanted as many
design characteristics to remain
constant as possible. DOE believed that
such an approach would allow it to
more accurately pinpoint the factors
that affect efficiency. While DOE only
analyzed one enclosure type, it notes
that its scaling follows NEMA’s
efficiency tables (Table 12–11 and Table
12–12), which already map how
efficiency changes with enclosure type.
Finally, TEFC electric motors
represented more than three times the
shipment volume of open motors. DOE
chose ELs that correspond to the tables
of standards published in NEMA’s MG
1–2011 and to efficiency bands derived
from those tables, preserving the
relationship between NEMA’s standards
for open and enclosed motors.
In the preliminary analysis, DOE
stated that, given the same frame size,
open motors are more efficient than
enclosed motors. NEMA commented
that DOE should not compare open and
enclosed motors in the same frame size
because NEMA MG 1 specifies larger
frame sizes and a higher service factor
for enclosed motors of a given rating
than it does for open motors. NEMA
added that TEFC motors have a fan
which adds to the friction and windage
losses, and even with this fan the TEFC
motors can have higher efficiencies than
open frame motors of the same
horsepower and pole configuration.
(NEMA, No. 54 at p. 41) DOE
appreciates the clarification and has
altered its discussion in chapter 3 of the
TSD.
3. Efficiency Levels Analyzed
After selecting its representative units
for each electric motor equipment class
group, DOE examined the impacts on
the cost of improving the efficiency of
each of the representative units to
evaluate the impact and assess the
viability of potential energy
conservation standards. As described in
the technology assessment and
screening analysis, there are numerous
design options available for improving
efficiency and each incremental
improvement increases the electric
motor efficiency along a continuum.
The engineering analysis develops cost
estimates for several efficiency levels
(ELs) 53 along that continuum.
ELs are often based on: (1) Efficiencies
available in the market; (2) voluntary
specifications or mandatory standards
that cause manufacturers to develop
equipment at particular efficiency
levels; and (3) the max-tech level.
Currently, there are two energy
conservation standard levels that apply
to various types of electric motors. In
ECG 1, some motors currently must
meet efficiency standards that
correspond to NEMA MG 1–2011 Table
12–11 (i.e., EPACT 1992 levels 54),
others must meet efficiency standards
that correspond to NEMA MG 1–2011
Table 12–12 (i.e., NEMA Premium
levels), and some are not currently
required to meet any energy
conservation standard levels. Because
DOE cannot establish energy
conservation standards that are less
efficient than current standards (i.e., the
‘‘anti-backsliding’’ provision at 42
U.S.C. 6295(o)(1) as applied via 42
U.S.C. 6316(a)) but ECG 1 includes both
currently regulated and unregulated
electric motors, DOE’s analysis assumed
the respective EPACT 1992 or NEMA
Premium standard as the baseline for
ELs 1 and 2. For ECG 1, DOE established
an EL that corresponded to each of these
levels, with EL 0 as the baseline (i.e., the
lowest efficiency level available for
unregulated motors and EPACT 1992 or
NEMA Premium, as applicable, for
currently regulated motors), EL 1 as
equivalent to EPACT 1992 levels (or
NEMA Premium, as applicable, for
currently regulated motors), and EL 2 as
equivalent to NEMA Premium levels.
Additionally, DOE analyzed two ELs
above EL 2. One of these levels was the
max-tech level, denoted as EL 4 and one
was an incremental level that
approximated a best-in-market
efficiency level (EL 3). For all
equipment classes within ECG 1, EL 3
was a one ‘‘band’’ increase in NEMA
nominal efficiency relative to NEMA
Premium and EL 4 was a two ‘‘band’’
increase.55 For ECG 3 and 4, DOE used
the same ELs with one exception for
ECG 3. Because fire pump electric
motors are required to meet EPACT
1992 efficiency levels and those are the
only motors in that equipment class
group, EPACT 1992 levels were used as
the baseline efficiency level, which
means that fire pump electric motors
have one fewer EL than ECGs 1 and 4
for purposes of DOE’s analysis.
Following the preliminary analysis,
DOE adjusted one max-tech Design B
representative unit level (5 hp) after
receiving additional data. This allowed
this unit to be based more on physical
models for the NOPR analysis, thereby
reducing exposure to modeling errors.
Table IV.9 and Table IV.10 show the ELs
for ECGs 1, 3, and 4.
TABLE IV.9—EFFICIENCY LEVELS FOR EQUIPMENT CLASS GROUPS 1 AND 4
EL 0
(baseline)
(percent)
Representative unit
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5 hp (ECG 1 and 4) .............................................................
30 hp (ECG 1 and 4) ...........................................................
75 hp (ECG 1 only **) ..........................................................
EL 1
(EPACT 1992)
(percent)
82.5
89.5
93.0
EL 2
(NEMA
premium)
(percent)
87.5
92.4
94.1
89.5
93.6
95.4
EL 3
(best-inmarket) *
(percent)
90.2
94.1
95.8
EL 4
(max-tech)
(percent)
91.0
94.5
96.2
* Best-in-market represents the best or near best efficiency level at which current manufacturers are producing electric motors. Although these
efficiencies represent the best-in-market values found for the representative units, but when efficiency was scaled to the remaining equipment
classes, the scaled efficiency was sometimes above and sometimes below the best-in-market value for a particular rating.
** ECG 4 does not have a 75-horsepower representative unit because DOE was unable to find brake motors built with such a high horsepower
rating. The maximum horsepower rating for ECG 4 is 30-horsepower.
53 For the purposes of the NOPR analysis, the
term ‘‘efficiency level’’ (EL) is equivalent to that of
Candidate Standard Level (CSL) in the preliminary
analysis.
54 EPACT 1992 only established efficiency
standards for motors up to and including 200 hp.
Eventually, NEMA MG 1–2011 added a table, 20–
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A, which functioned as an extension of Table 12–
11. So, although EPACT 1992 is a slight misnomer,
DOE is using it to refer to those ELs that were based
on Table 12–11.
55 Because motor efficiency varies from unit to
unit, even within a specific model, NEMA has
established a list of standardized efficiency values
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that manufacturers use when labeling their motors.
Each incremental step, or ‘‘band,’’ constitutes a 10
percent change in motor losses. NEMA MG 1–2011
Table 12–10 contains the list of NEMA nominal
efficiencies.
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TABLE IV.10—EFFICIENCY LEVELS FOR EQUIPMENT CLASS GROUP 3
EL 0
(EPACT 1992)
(percent)
Representative unit
(percent)
5 hp ..................................................................................................................
30 hp ................................................................................................................
75 hp ................................................................................................................
For ECG 2, DOE took a similar
approach in developing its ELs as it did
for ECG 1, but with two primary
differences. First, when DOE examined
catalog data, it found that no NEMA
Design C electric motors had efficiencies
below EPACT 1992 levels, which is the
current standard for all covered NEMA
Design C electric motors. For DOE’s
representative units, it also found no
catalog listings above the required
EPACT 1992 levels. Additionally, when
DOE’s subject matter expert modeled
NEMA Design C motors, the model
would only generate designs at NEMA
Premium levels and one incremental
EL 1
(NEMA
premium)
(percent)
87.5
92.4
94.1
level above that while maintaining
proper performance standards.
Therefore, ECG 2 only contains three
ELs: EPACT 1992 (EL 0), NEMA
Premium (EL 1), and a max-tech level
(EL 2).
These ELs differed slightly from the
CSLs presented in the preliminary
analysis for ECG2. In the preliminary
analysis, a CSL for the 50 hp unit
existed between two industry standard
levels in order to provide greater
resolution in selection of a standard
(NEMA MG–1 Table 12–11 and Table
12–12). For the NOPR analysis, this
level was removed so that the ELs
89.5
93.6
95.4
EL 2
(best-inmarket) *
(percent)
90.2
94.1
95.8
EL 3
(max-tech)
(percent)
91.0
94.5
96.2
analyzed would align with Tables 12–11
and 12–12. For the 5 hp rep unit, DOE
also removed one preliminary analysis
CSL, which was intended to represent
the ‘‘best in market’’ level in the
preliminary analysis. After further
market research, DOE found that few
Design C motors are offered above the
baseline, and those that were mainly
met the NEMA premium level, without
going higher in efficiency. It determined
that for the NOPR analysis, the
previously designated ‘‘max in market’’
level was not applicable. The ELs
analyzed for ECG2 in the NOPR are
shown in Table IV.11.
TABLE IV.11—EFFICIENCY LEVELS FOR EQUIPMENT CLASS GROUP 2
EL 1
(EPACT 1992)
(percent)
Representative unit
(percent)
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5 hp ..............................................................................................................................................
50 hp ............................................................................................................................................
In response to its preliminary
analysis, DOE received multiple
comments regarding CSLs. NEMA and
Baldor expressed confusion over the fact
that the CSLs for ECG 2 do not align
with the CSLs from ECG 1, and
requested that DOE line up CSLs across
different ECGs in an effort to avoid
confusion when discussing the CSLs.
(NEMA, No. 54 at p. 73; Baldor, Public
Meeting Transcript, No. 60 at pp. 171,
172) DOE understands NEMA’s
concerns regarding the nomenclature of
its ELs, however, it has maintained its
approach for the NOPR analysis. DOE
examines each ECG independently, and
because different motor types have
different baselines, the EL numbers do
not always align.
NEMA also asked if the baseline CSL
developed for ECG 1, which was
developed based on an analysis of
vertical, hollow-shaft motors, included
losses related to testing those motors
with thrust bearings. NEMA inquired
because, at the time of its comment,
DOE had not yet published the test
procedure NOPR, indicating how these
motor types might be tested. (NEMA,
No. 54 at pp. 71–72, 77)
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DOE clarifies that the vertical hollowshaft motors purchased and used to
determine the baseline efficiency level
for ECG 1 contained bearings capable of
horizontal operation. Therefore, DOE
tested these motors in a horizontal
configuration without any modifications
to the bearings. Additionally, when
tested, solid-shafts were welded inside
the hollow-shaft to permit the motor to
be attached to a dynamometer for
testing. These modifications are in line
with the proposals for vertical hollow
shaft motors as described in DOE’s
electric motors test procedure NOPR. 78
FR 38456 (June 26, 2013).
During the preliminary analysis
public meeting, NEMA noted that the
CSL 5 software-modeled efficiency was
96.4 percent and should have been
assigned a NEMA nominal efficiency
level of 96.2 percent rather than 96.5.
(NEMA, No. 54 at p. 80) NEMA and
Baldor added that CSL 5 should not be
included in any engineering analysis
because of the infeasibility of castcopper rotors, and that CSL 4 is the
proper max-tech level when CSL 5 is
eliminated from consideration. (NEMA,
No. 54 at p. 73; Baldor, Public Meeting
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87.5
92.4
EL 2
(NEMA
premium)
(percent)
89.5
93.6
EL 3
(max-tech)
(percent)
91.0
94.5
Transcript, No. 60 at p. 171) The
Efficiency Advocates also expressed
concern about some of the CSLs
analyzed by DOE and questioned the
viability of CSL 3. The Efficiency
Advocates noted that some of the CSL
3 designs were at the very limits of
critical motor performance parameters,
such as locked-rotor torque and current.
The Efficiency Advocates added that
DOE has not tested motors that perform
at the levels that would be required by
CSL 3, 4, and 5. Without having done
so, DOE cannot verify the predicted
performance of its representative units.
(NPCC, No. 56 at pp. 4, 5)
As discussed, DOE has removed EL 5
from consideration in the NOPR
analysis, but it has not eliminated the
use of copper-die cast rotor technology
(see I.A.1). With regards to the
comments from the Efficiency
Advocates, DOE notes that EL 3 for ECG
1 is based on teardown data from
commercially available motors, as it was
for the preliminary analysis.
Additionally, for the NOPR, DOE has
tested a unit at EL 4 for one of its
representative units. Furthermore, DOE
has found many instances of electric
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motors being sold and marketed one or
two NEMA bands of efficiency above
NEMA Premium, which suggests that
manufacturers have extended
technological performance where they
perceived market demand for higher
efficiencies. In other words, DOE has
seen no evidence suggesting that the
absence of products on the market at
any given EL implies that such products
could not be developed, were there
sufficient demand. DOE contends that
all of the ELs analyzed in its engineering
analysis are viable because equipment is
currently commercially available at
such levels 56 and, to the extent
possible, has been included in DOE’s
analysis. DOE welcomes comment on
the limits of technology, especially as it
varies by equipment class.
Additionally, NEMA and Baldor
commented on the design options
analyzed for the various CSLs. NEMA
and Baldor stressed that not using a
common design option across all CSLs
may result in a reduction of available
product. (NEMA, No. 54 at pp. 3, 27, 73;
Baldor, Public Meeting Transcript, No.
60 at pp. 169–171, 176–178) NEMA
indicated that it is a standard practice
of manufacturers to minimize the
number of types of electrical steel used
at a manufacturing facility and that
typically a single type of electrical steel
may be used for all electric motors
manufactured at the facility. NEMA
added that DOE should account for this
situation when performing engineering
analyses such that a common type of
electrical steel is used for the different
NEMA design types covered by a
common CSL. (NEMA, No. 54 at p. 62)
NEMA added that although NEMA
Design C motors constitute less than 1
percent of total motor shipments, the
electrical steel and die-cast rotor
material used for manufacturing NEMA
Design C electric motors is taken from
the same inventory as used for NEMA
Design B electric motors. Therefore,
they contended that DOE should select
the same material types for NEMA
Design C motors as it does for NEMA
Design B motors. (NEMA, No. 54 at p.
65, 74) Finally, NEMA stated that it did
not understand why DOE used different
steels and rotor conductors for CSLs 4
and 5 in some of the ECG 1
representative units but not in others.
(NEMA, No. 54 at pp. 3, 72; Baldor,
Public Meeting Transcript, No. 60 at p.
120)
56 DOE understands that this is not true for every
equipment classes covered by this rulemaking, but
has not seen evidence to suggest that the absence
of equipment in any particular classes is not due
to lack of market demand instead of technological
limitations.
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As noted earlier, DOE has
restructured its ELs for the NOPR
analysis. One consequence of this
restructuring is that DOE no longer
mixes rotor casting technologies for a
given EL. However, DOE does not limit
the number of electrical steels used at a
given EL to one. DOE understands that
manufacturers try to limit the number of
electrical steels at a given
manufacturing facility, but most
manufacturers have more than one
manufacturing facility. Therefore,
manufacturers could produce motors
with multiple grades of electrical steel.
Additionally, DOE believes that this
approach is in line with current
industry practice. For its analysis, DOE
obtained multiple units for teardowns
from the same manufacturer. After a
steel analysis was conducted on its
teardowns, DOE found that one
manufacturer utilized multiple grades of
steel, both across ELs within a
representative unit and across
representative units within an EL.
Finally, DOE believes that the
restructuring of the ELs should also
address concerns over the technology
differences between preliminary
analysis ELs 4 and 5 because in the
NOPR analysis there is no EL 5. DOE
has updated chapter 5 of the TSD to
include as pertinent design data.
During the preliminary analysis
public meeting, ACEEE commented that
new energy conservation levels would
have to be raised by at least two NEMA
bands because an increase of only one
NEMA band is not statistically
significant. (ACEEE, Public Meeting
Transcript, No. 60 at p. 168) DOE
disagrees with this assessment.
Although the unit-to-unit efficiency of a
specific electric motor design may vary
by multiple NEMA bands of efficiency,
an increase in the required efficiency
level by one band would be significant.
If efficiency standards are raised by one
NEMA band, there is no evidence to
suggest that manufacturing practices
would change such that the distribution
of unit-to-unit efficiencies for a given
motor design would change. Therefore,
if the required efficiency standard were
changed by one band of efficiency, one
would assume that the entire population
of motors of a given design would shift
by one band of efficiency as
manufacturers begin to produce motors
around a higher mean value.
Finally, NEMA commented that
another important factor for defining
CSLs is the ability for CSLs to provide
efficiency values to be used in the
scaling process and that it is important
that the relative difference between the
efficiency values for CSLs is selected
such that the relativity is maintained
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across all of the representative units if
it is to be applied by scaling to all
electric motors included in an ECG. In
other words, NEMA argues that CSLs
must be chosen carefully to correspond
with similar technologies and materials
across the range of scaling (i.e., the
entire equipment class) and that they
should not be chosen to merely to align
with NEMA’s own tables and efficiency
bands. (NEMA, No. 54 at p. 73)
Responding to this concern, for each EL
above the established NEMA Premium
levels, DOE has incremented efficiency
by one nominal band for all equipment
classes. This equates to, roughly, a 10
percent decrease in motor losses for all
equipment classes for each jump in EL.
4. Test and Teardowns
Whenever possible, DOE attempted to
base its engineering analysis on actual
electric motors being produced and sold
in the market today. First, DOE
identified electric motors in
manufacturer catalogs that represented a
range of efficiencies corresponding to
the ELs discussed in the previous
sections. Next, DOE had the electric
motors shipped to a certified testing
laboratory where each was tested in
accordance with IEEE Standard 112
(Test Method B) to verify its nameplaterated efficiency. After testing, DOE
derived production and material costs
by having a professional motor
laboratory 57 disassemble and inventory
the purchased electric motors. For ECG
1, DOE obtained tear-down results for
all of the 5-horsepower ELs and all of
the 30- and 75-horsepower ELs except
the max-tech levels. For ECG 2, DOE
obtained tear-down results only for the
baseline EL, which corresponds to
EPACT 1992 efficiency levels.
These tear-downs provided DOE with
the necessary data to construct a bill of
materials (BOM), which, along with a
standardized cost model and markup
structure, DOE could use to estimate a
manufacturer selling price (MSP). DOE
paired the MSP derived from the teardown with the corresponding nameplate
nominal efficiency to report the relative
costs of achieving improvements in
energy efficiency. DOE’s estimates of
material prices came from a
combination of current, publicly
available data, manufacturer feedback,
and conversations with its subject
matter experts. DOE supplemented the
57 The Center for Electromechanics at the
University of Texas at Austin, a 140,000 sq. ft. lab
with 40 years of operating experience, performed
the teardowns, which were overseen by Dr. Angelo
Gattozzi, an electric motor expert with previous
industry experience. DOE also used Advanced
Energy Corporation of North Carolina to perform
some of the teardowns.
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findings from its tests and tear-downs
through: (1) A review of data collected
from manufacturers about prices,
efficiencies, and other features of
various models of electric motors, and
(2) interviews with manufacturers about
the techniques and associated costs
used to improve efficiency.
As discussed earlier, DOE’s
engineering analysis documents the
design changes and associated costs
when improving electric motor
efficiency from the baseline level up to
a max-tech level. This includes
considering improved electrical steel for
the stator and rotor, interchanging
aluminum and copper rotor bar
material, increasing stack length, and
any other applicable design options
remaining after the screening analysis.
As each of these design options are
added, the manufacturer’s cost increases
and the electric motor’s efficiency
improves. DOE received multiple
comments regarding its test and teardown analysis.
NEMA commented that the cost for
manufacturing an electric motor can
increase as the efficiency level is
increased even when the material and
technology is not changed. It added that
an increase in core length, without any
change in the material used, will result
in a higher cost not only due to the
increase in the amount of steel, but also
due to the increase in the amount of
wire for the stator winding and
aluminum for the rotor core. (NEMA,
No. 54 at p. 74) Notwithstanding, DOE
believes that it has accurately captured
such changes. When each electric motor
was torn down, components such as
electrical steel and copper wiring were
weighed. Therefore, any increase in
stack length would result in increased
costs associated with the increased
amount of electrical steel and copper
wiring.
NEMA also commented that the best
known value of efficiency for a tested
and torn down motor is the tested
efficiency and the accuracy of this value
improves as sample size increases.
Because DOE only used a sample size of
one, NEMA recommended that DOE
should increase its sample size to
something more statistically significant.
(NEMA, No. 54 at p. 75) NEMA also
referred to the small electric motors
rulemaking and said that a sufficient
sample size for testing was proven to be
necessary. (NEMA, No. 54 at p. 27)
NEMA also commented that Appendix
A to Subpart U designates the
appropriate sample size to support the
conclusion that the name-plated
efficiency of a motor is correctly stated.
(NEMA, No. 54 at p. 79) NEMA and
Baldor added that Appendix A to
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Subpart U requires the determination of
a standard deviation from the sample,
and it is not possible to determine a
standard deviation when testing a
sample of one motor, which was the
sample size of DOE’s motor testing.
(NEMA, No. 54 at p. 79; Baldor, Public
Meeting Transcript, No. 60 at p. 154)
DOE agrees that an increased sample
size would improve the value of
efficiency used in its analysis, but only
if DOE were using an average full-load
efficiency value, as it did for the small
electric motors rulemaking engineering
analysis, which did not have the benefit
of NEMA-developed nominal efficiency
values. For today’s analysis, DOE did
not use the tested efficiency value and
believes that to do so would be
erroneous precisely because it only
tested and tore down one unit for a
given representative unit and EL. Rather
than using an average efficiency of a
sample of multiple units that is likely to
change with each additional motor
tested, DOE elected to use the
nameplate NEMA nominal efficiency
given. DOE understands that this value,
short of testing data, is the most
accurate value to use to describe a
statistically valid population of motors
of a given design; that is, in part, why
manufacturers use NEMA nominal
efficiencies on their motors’ nameplates.
Furthermore, when DOE conducts its
tear-downs, the bill of materials
generated is most representative of the
tested value of efficiency, not
necessarily the NEMA nominal value.
However, DOE believes that the
variance from unit-to-unit, in terms of
materials, is likely to be insignificant
because manufacturers have an
incentive to produce equipment with
consistent performance (i.e.,
characteristics other than efficiency) as
possible. Changes in the tested
efficiency are likely to occur because of
variations in production that motor
manufacturers have less control over
(e.g., the quality of the electrical steel).
DOE does not believe that the amount
of material (in particular, electrical
steel, copper wiring, and die-cast
material) from unit-to-unit for a given
design is likely to change significantly,
if at all, because manufacturers have
much greater control of those
production variables. Therefore,
additional tests and tear-downs are
unlikely to change the MSP estimated
for a given motor design and DOE
believes that its sample size of one is
appropriate.
In the preliminary engineering
analysis, DOE replaced a tear-down
result with a software model for CSL 2
of its 30-horsepower representative unit
because it believed that it had
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73629
inadvertently tested and torn down a
motor with an efficiency equivalent to
CSL 3. DOE noted that it removed the
tear-down because there was conflicting
efficiency information on the Web site,
in the catalog, and on the physical
nameplate. Subsequently, NEMA and
Baldor commented that the 30horsepower, CSL 2 motor should not
have been replaced with a softwaremodeled motor, stating that the test
result was statistically viable. (NEMA,
No. 54 at pp. 76–79; Baldor, Public
Meeting Transcript, No. 60 at pp. 150–
155) NEMA and Baldor also asserted
that DOE had placed emphasis on the
use of purchased motors in its analysis
only when the tested value of efficiency
was less than or not significantly greater
than the marked value of NEMA
efficiency. (NEMA, No. 54 at p. 80;
Baldor, Public Meeting Transcript, No.
60 at pp. 156, 157)
DOE understands that the test result
may have been viable for either of the
efficiency ratings that the manufacturer
had assigned. Given the uncertainty,
however, DOE elected to replace the
motor. DOE did not discard the unit
simply because it tested significantly
above its nameplate efficiency. Rather,
the motor was listed with different
values of efficiency depending upon the
source and when torn down, the
resulting MSP was higher than the MSP
for the next CSL. These facts suggested
that the calculated results were
erroneous because it is unlikely (based
on available data) that it would be
cheaper to build a more efficient motor
than a less efficient one of comparable
specifications. If DOE had included
these data in its analysis, it would likely
have resulted in a projection that even
higher CSLs would be economically
justified. The combination of these
factors resulted in DOE eliminating that
motor from the analysis. For its updated
NOPR engineering analysis, DOE has
tested and torn down a new 30horsepower motor to describe CSL 2. As
stated previously, DOE always prefers to
base its analysis using motors purchased
in the market when possible.
NEMA commented that the
disproportionate variation in frame
weights between the CSLs suggests that
the CSLs of some representative units
were not of similar construction.
(NEMA, No. 54 at p. 78) When selecting
motors for tear-down, DOE selected
motors with increasing efficiencies.
These motors may not have used the
same frame material. For example, the
CSL 0 for the 30-horsepower
representative units was made out of
cast aluminum, but CSL 1 unit used cast
iron. This material change accounts for
the large difference in frame weight.
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During the preliminary analysis
public meeting, Nidec requested
clarification for the increase in stator
copper weight for the 75-horsepower,
ECG 1 representative unit between CSL
2 and CSL 3 since the reported slot fills
were the same and the motors had
similar stack lengths. (Nidec, Public
Meeting Transcript, No. 60 at pp. 164,
165) After DOE’s tear-down lab
determined that the torn-down motors
were machine-wound a precise
measurement of the slot fill was not
taken. Although the actual measurement
of slot fill has no bearing on the
estimates of the MSP, because the actual
copper weights were measured and not
calculated, DOE did ask its lab to
provide actual measurements of slot fill
on any subsequent tear-downs and has
included the data in chapter 5 of the
TSD.
5. Software Modeling
In the preliminary analysis, DOE
worked with technical experts to
develop certain CSLs, in particular, the
max-tech efficiency levels for each
representative unit analyzed. DOE
retained an electric motors subject
matter expert (SME) 58 with design
experience and software, who prepared
a set of designs with increasing
efficiency. The SME also checked his
designs against tear-down data and
calibrated his software using the
relevant test results. As new designs
were created, DOE’s SME ensured that
the critical performance characteristics
that define a NEMA design letter, such
as locked-rotor torque, breakdown
torque, pull-up torque and locked-rotor
currents were maintained. For a given
representative unit, DOE ensured that
the modeled electric motors met the
same set of torque and locked-rotor
current requirements as the purchased
electric motors. This was done to ensure
that the utility of the baseline unit was
maintained as efficiency improved.
Additionally, DOE limited its modeled
stack length increases based on
teardown data and maximum ‘‘C’’
dimensions found in manufacturer’s
catalogs.59
In response to the preliminary
analysis, Baldor and NEMA requested
clarification on how DOE compared its
software modeled results to the electric
motors that it had tested and torn down.
(NEMA, No. 54 at p. 74; Baldor, Public
58 Dr. Howard Jordan, Ph.D., an electric motor
design expert with over 40 years of industry
experience, served as DOE’s subject matter expert.
59 The ‘‘C’’ dimension of an electric motor is the
length of the electric motor from the end of the shaft
to the end of the opposite side’s fan cover guard.
Essentially, the ‘‘C’’ dimension is the overall length
of an electric motor including its shaft extension.
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Meeting Transcript, No. 60 at p. 148)
NEMA requested that more details
regarding that comparison and the name
of the software program used to be
included in an updated technical
support document. (NEMA, No. 54 at p.
12) Per the request of NEMA and
Baldor, DOE has provided comparisons
of software estimates and tested
efficiencies in appendix 5C of the TSD.
Additionally, the software program that
DOE used for its analysis is a
proprietary software program called
VICA.60
NEMA expressed concern over
efficiency standards based on the
software platform DOE used and stated
that DOE should build working
prototypes of its software modeled
motors to prove the designs work.
(NEMA, No. 54 at pp. 24–25 and 74–75)
Baldor reiterated this point in verbal
comments and suggested that this was
particularly important for CSLs with
copper rotor designs given their
concerns with copper rotor motors.
(NEMA, No. 54 at pp. 76–77; Baldor
Public Meeting Transcript, No. 60 at pp.
160, 161) During the preliminary
analysis, DOE approached motor
laboratories in an attempt to prototype
its software models. DOE was unable to
identify a laboratory that could
prototype its software modeled motors
in a manner that would exactly replicate
the designs produced (i.e., they could
not die-cast copper). Consequently, at
this time, DOE has not built a prototype
of its software models. However, DOE
was able to procure a 5-horsepower
NEMA Design B die-cast copper rotor
motor with an efficiency two NEMA
bands above the NEMA Premium level.
Therefore, DOE elected to use this
design to represent the max-tech EL for
the 5-horsepower representative unit in
equipment class group 1, rather than the
software-modeled design used in the
preliminary analysis. DOE’s SME used
information gained from testing and
tearing down this motor to help
corroborate the software modeling.
In the preliminary analysis, DOE
indicated that its software modeling
expert made changes to his software
designs based on data collected during
the motor teardowns. NEMA
commented on this and asked why
DOE’s software modeling expert made
changes to some of his designs based on
teardown data. (NEMA, No. 54 at p. 75)
DOE clarifies that the software program
was updated using additional teardown
data (e.g., more accurate dimensions
and material types) to maintain as many
consistencies in design as possible. For
60 VICA stands for ‘‘Veinott Interactive Computer
Aid.’’
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example, DOE’s software modeling
expert used lamination diameters
measured during the teardowns as
limits for the software models.
In submitted comments, NEMA noted
that the NEMA nominal efficiency for
the software-modeled motors was
derived by selecting the value that was
lower than the calculated efficiency.
NEMA questioned this approach and
added that assigning a value of NEMA
nominal efficiency based on a
calculated value of efficiency requires
more knowledge than merely selecting
the closest NEMA nominal value that is
lower than the calculated value.
(NEMA, No. 54 at p. 76) DOE notes that
it selected the closest NEMA nominal
efficiency that is less than or equal to
the predicted efficiency of the software
for multiple reasons. First, DOE wanted
to maintain the use of nominal
efficiency values to remain consistent
with past electric motor efficiency
standards. Second, DOE chose a value
below its software estimate because this
method would provide a more
conservative approach. DOE believes its
approach was appropriate given the
various concerns raised with copper
rotor motor technologies.
During the preliminary analysis
public meeting, Regal-Beloit commented
that calibration of the software-modeled
motors is extremely important. RegalBeloit added that the calibration of
select models is very important due to
the amount of interpolation that DOE is
basing on these models. (Regal-Beloit,
Public Meeting Transcript, No. 60 at pp.
159–160) Alluding to copper rotor
motors, NEMA commented on DOE’s
software modeling, claiming that
verifying the accuracy of a software
program with respect to performance
obtained from testing purchased motors
does not verify the accuracy of the
software program when it is used for a
technology which has not been verified
by tests. (NEMA, No. 54 at p. 76; Baldor,
Public Meeting Transcript, No. 60 at pp.
160, 161) DOE appreciates these
comments and, as stated, has conducted
calibration of its software program using
data obtained from motor teardowns.
DOE has provided comparisons of
software estimates and tested
efficiencies for both aluminum and
copper rotor motors in appendix 5C of
the TSD.
NEMA commented that the
preliminary TSD did not show that the
software platform DOE used had been
substantiated as being sufficiently
accurate for motors incorporating
existing and new technologies. (NEMA,
No. 54 at p. 12) NEMA asserted that it
is necessary to substantiate the software
platform used for modeling as an
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alternate efficiency determination
method (AEDM) such that the
calculated efficiencies can be verified as
accurate for the types of technologies
included in a motor design. NEMA
urged that DOE substantiate the
software platform used by its SME as an
AEDM. (NEMA, No. 54 at p. 76) Baldor
added that DOE expects manufacturers
to prototype five motors to certify a
program, but DOE has not designed and
built any of the motors designed in its
own program. (Baldor, Public Meeting
Transcript, No. 60 at p. 162) Nidec
commented during the public meeting,
asking if the software modeling suite
DOE used has gone through the same
scrutiny that manufacturers are subject
to when they must submit their 25
samples to correlate their estimated
computer data with actual testing data.
(Nidec, Public Meeting Transcript, No.
60 at p. 147)
DOE understands the comments
received regarding its software program,
but maintains that substantiation of an
AEDM is a concept intended for
certifying compliance with energy
efficiency standards. It is a tool that
manufacturers use to help ensure that
the equipment they manufacture
comply with a Federal standard (which
is the manufacturers’ duty). It is not a
tool for assessing whether a particular
energy efficiency level under
consideration by DOE satisfies the EPCA
criteria. Accordingly, the use of the
AEDM in the manner suggested by
industry would not be relevant for the
purposes of this engineering analysis,
which is geared toward DOE’s standards
rulemaking.
NEMA also commented that to
properly determine the impact of
increased efficiency on motor utility,
DOE must recognize the consequences
of how motor performance, including
parameters such as acceleration, safe
stall time, overspeed, service factor,
thermal performance, and in-rush
current will be affected by more
stringent energy conservation standards.
NEMA also specifically referred to
performance characteristics found in
NEMA MG 1 sections 12.44, 12.45,
12.48, 12.49, 12.53, 12.54, and 12.56.
(NEMA, No. 54 at pp. 5, 77) NEMA
added that the narrow margin between
the NEMA MG 1–2011 limits for lockedrotor current and the calculated lockedrotor current for some of the softwaremodeled designs in the preliminary
analysis suggest that there will be
problems with these motors meeting the
NEMA MG 1 limits if they were
prototyped. (NEMA, No. 54 at p. 77)
Finally, NEMA indicated that two of the
DOE software-modeled motors in the
preliminary analysis, representing the
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75-horsepower CSLs 4 and 5 for ECG 1,
had torque ratings twice that of a U.S.
Army 75-horsepower electric motor
software model, and suggested that the
software models used in DOE’s analysis
are not accurate in modeling copper
rotor motor performance. (NEMA, No.
54 at p. 77)
DOE has carefully considered
NEMA’s comments in its updated NOPR
analysis. As noted, DOE has eliminated
designs from its preliminary analysis
because of concerns regarding the
feasibility of those efficiency levels.
Regarding the additional performance
parameters, DOE agrees that these
characteristics must be maintained
when improving an electric motor’s
efficiency. However, the performance
parameters DOE believed to present the
largest risk of rendering a motor
noncompliant with NEMA MG 1–2011
standards were those related to NEMA
design letter, which were adhered to in
DOE’s modeling efforts. Based on
comparisons of motor teardowns and
software estimates, DOE has no reason
at this time to believe that its modeled
designs would violate the additional
performance parameters mentioned by
NEMA.
DOE believes that its subject matter
expert, who has been designing electric
motors for several decades, is well
qualified to understand the design
tradeoffs that must be considered.
Although the SME’s primary task was to
design a more efficient motor using
various technologies, it was of critical
importance that the designs be feasible.
Even though DOE was unable to
prototype its modeled designs, DOE has
conducted comparisons of software
estimates and tested efficiencies for both
aluminum and copper rotor motors and
believes this corroborates the modeled
designs. Based on this work and its total
analysis, which included input from its
SME, DOE believes it developed a
sufficiently robust set of technically
feasible efficiency levels for its
engineering analysis.
NEMA asked how DOE intended to
take into consideration motor utility as
motor size increases. (NEMA, No. 54 at
pp. 23, 24) During the preliminary
analysis public meeting, Baldor asked if
the higher CSLs would fit into existing
frame sizes, or if those motors would
have to be redesigned to allow for the
increased stack length. Baldor added
that if the frame size increases, the
motor may no longer fit current
applications, which would cause
additional burden for end-users or
original equipment manufacturers.
(Baldor, Public Meeting Transcript, No.
60 at pp. 164, 245) Baldor added that
IEC frame motors are more constrained
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in terms of size and space than NEMA
frame motors, and it is more difficult to
increase the efficiency on IEC frame
motors without changing frame size
designations, which would lead to space
constraint issues. (Baldor and ABB,
Public Meeting Transcript, No. 60 at pp.
245, 246) Flolo Corporation also
commented on motor length during the
public meeting, insisting that it is
important that DOE recognize the
difference in ‘‘C’’ dimension that any
new energy conservation standard
would mandate, as increasing the ‘‘C’’
dimension will make it difficult for a
motor to fit into its originally intended
machine. (Flolo, Public Meeting
Transcript, No. 60 at pp. 243, 244) The
Efficiency Advocates also commented
on motor length, indicating that DOE
should be aware of absolute motor
length limits when considering
increased stack length, and that these
changes could greatly increase the
installed cost of many of the higher
CSLs, impacting field and original
equipment manufacturer (OEM)
installation. (Advocates, No. 56 at p. 4)
In the preliminary TSD, DOE
stipulated that any increase in stack
length would fit into the existing frame
designation for that particular motor
rating. DOE noted that the frame
designation does not limit frame length,
but rather frame diameter. DOE also
understands that manufacturers have
fixed-length frames that they use when
manufacturing motors. In addition to
generating per unit costs associated with
redesigning motors with new frames at
all ELs above the NEMA Premium levels
(see IV.C.6), DOE sought to maintain
motor length by limiting how much it
would modify stack dimensions to
improve efficiency. First, the software
models created by DOE used lamination
diameters observed during teardowns,
which ensured that the softwaremodeled designs would fit into existing
frame designations. However, for some
designs DOE increased the number of
laminations (i.e., length of the stack of
laminations, or stack length) beyond the
stack lengths observed during the motor
teardowns in order to achieve the
desired efficiency gains.
DOE limited the amount by which it
would increase the stack length of its
software-modeled electric motors in
order to preserve the motor’s utility. The
maximum stack lengths used in the
software-modeled ELs were determined
by first analyzing the stack lengths and
‘‘C’’ dimensions of torn-down electric
motors. Then, DOE analyzed the ‘‘C’’
dimensions of various electric motors in
the marketplace conforming to the same
design constraints as the representative
units (same horsepower rating, NEMA
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frame size, enclosure type, and pole
configuration). For each representative
unit, DOE found the largest ‘‘C’’
dimension currently available on the
marketplace and estimated a maximum
stack length based on the stack length to
‘‘C’’ dimension ratios of motors it tore
down. The resulting product was the
value that DOE chose to use as the
maximum stack length considered in its
software modeled designs, although
DOE notes that it did not always model
a motor with that maximum stack
length. In most instances, the SME was
able to achieve the desired improvement
in efficiency with a stack length shorter
than DOE’s estimated maximum. Table
IV.12 shows the estimated maximum
stack length, the maximum stack length
found during tear-downs, and the
maximum stack length modeled for a
given representative unit. DOE
welcomes additional comments on
software modeling in general, and on
specific data that could be used to
calibrate its software designs.
TABLE IV.12—MAXIMUM STACK LENGTH DATA
30 Horsepower
Design B ...........................................
75 Horsepower
Design B ...........................................
5 Horsepower
Design C ..........................................
50 Horsepower
Design C ..........................................
Maximum stack length of a
torn down motor
8.87 in. ....................................................
8.02 in. (EL 2) .........................................
7.00 in.
13.06 in. ..................................................
11.33 in. (EL 3) .......................................
12.00 in.
5.80 in. ....................................................
4.75 in. (EL 0) .........................................
5.32 in.
9.55 in. ....................................................
8.67 in. (EL 0) .........................................
9.55 in.
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6. Cost Model
When developing manufacturer
selling prices (MSPs) for the motor
designs obtained from DOE’s tear-downs
and software models, DOE used a
consistent approach to generate a more
accurate approximation of the costs
necessary to improve electric motor
efficiency. DOE derived the
manufacturer’s selling price for each
design in the engineering analysis by
considering the full range of production
and non-production costs. The full
production cost is a combination of
direct labor, direct materials, and
overhead. The overhead contributing to
full production cost includes indirect
labor, indirect material, maintenance,
depreciation, taxes, and insurance
related to company assets. Nonproduction cost includes the cost of
selling, general and administrative items
(market research, advertising, sales
representatives, logistics), research and
development (R&D), interest payments,
warranty and risk provisions, shipping,
and profit factor. Because profit factor is
included in the non-production cost, the
sum of production and non-production
costs is an estimate of the MSP. DOE
utilized various markups to arrive at the
total cost for each component of the
electric motor and these markups are
detailed in chapter 5 of the TSD.
a. Copper Pricing
DOE conducted the engineering
analysis using material prices based on
manufacturer feedback, industry
experts, and publicly available data. In
the preliminary analysis, most material
prices were based on 2011 prices, with
the exception of cast copper and copper
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Maximum
stack length
modeled
Estimated maximum stack length
Representative unit
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wire pricing, which were based on a
five-year (2007–2011) average price.
DOE received comments regarding its
copper price development. NPCC
supported DOE’s decision to use a fiveyear price average for copper materials
and suggested that this method should
be used whenever a commodity price
shows a pattern of irregular spikes or
valleys. (Advocates, No. 56 at p. 4)
Conversely, the Industrial Energy
Consumers of America (IECA) stated
that material costs for high efficiency
motors are very volatile and cannot be
reliably projected from a simple fiveyear average, as DOE did with copper
prices during the preliminary analysis.
IECA added that as a result of using a
five-year average, the high efficiency
motor material costs may be highly
underestimated in DOE’s engineering
analysis, and IECA suggested that a
range of material costs rather than
averages could better inform a range of
life-cycle costs and payback periods for
each CSL. (IECA, No. 52 at p. 3)
Based on these comments, DOE has
slightly modified its approach. First,
DOE added updated data for 2012
pricing. Second, rather than a five-year
average, DOE changed to a three-year
average price for copper materials. DOE
made this modification based on
feedback received during manufacturer
interviews. By reducing to a three-year
average, DOE eliminated data from 2008
and 2009, which manufacturers
believed were unrepresentative data
points due to the recession. Data from
those two years had the effect of
depressing the five-year average
calculated.
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b. Labor Rate and Non-Production
Markup
In the preliminary analysis, DOE
looked at the percentage of electric
motors imported into the U.S. and the
percentage of electric motors built
domestically and based the balance of
foreign and domestic labor rates on
these percentages. During the
preliminary analysis public meeting,
Nidec commented that the labor rate
DOE used in its analysis seems high if
that number is weighted towards
offshore labor. Nidec also agreed with
DOE’s smaller markup on the lowerhorsepower motors, but commented that
the overall markups DOE used seem to
be high. (Nidec, Public Meeting
Transcript, No. 60 at p. 184) WEG added
to these comments, indicating that they
believed DOE was adequately
addressing the cost structure variations
among the different motor
manufacturers. Additionally, WEG
believed that basing a labor rate on both
foreign and domestic labor rates
increases accuracy of the analysis, but
warned that DOE should be careful not
encourage production moving outside
the United States. (WEG, Public Meeting
Transcript, No. 60 at pp. 184–186)
At this time, DOE has elected to keep
the same labor rates and markups as
were used in the preliminary analysis.
DOE is basing this decision on
additional feedback received during
interviews with manufacturers and the
absence of any alternative labor rate or
markups to apply.
Finally, DOE is aware of potential cost
increases caused by increased slot fill,
including the transition to hand-wound
stators in motors requiring higher slot
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fills. In the preliminary analysis, DOE
assigned a higher labor hour to any teardown motor which it determined to be
hand-wound. NEMA commented that
DOE did not assign a hand-wound
labor-hour assumption to any of the
tear-down motors, and requested
clarification about whether there were
instances of hand winding in these
motors. (NEMA, No. 54 at p. 23) DOE
found that none of the tear-down motors
were hand-wound, and therefore no
hand-winding labor-hour amounts were
assigned. This has been clarified in the
NOPR analysis. Additionally, DOE has
assumed that all of its max-tech
software models require hand-winding,
which is reflected in its increased labor
time assumptions for those motors. For
additional details please see chapter 5 of
the TSD.
In response to DOE’s request for
comment on the possibility of higher
labor costs for lower-volume electric
motors, NEMA indicated that plants
with few manufacturing setup changes,
because they may focus on standard
motor designs with no special motors,
have the ability to produce more motors
per employee, and that this is the case
with many offshore companies that
build designs for import to the U.S.
(NEMA, No. 54 at pp. 27, 28). For other
companies that cater to OEMs that
require special designs and small lot
production, setup changes eat into the
capacity of these plants, particularly in
the 56/140T through 250T frame series
where there is high volume. A plant
where the lot (i.e., batch) size per order
is smaller has less impact from setup.
DOE acknowledges that lower-volume
products will often realize higher per
unit costs, and believes this reality is
common to most or all manufacturing
processes in general. Because DOE’s
analysis focuses on the differential
impacts on cost due to standards, and
because DOE has no evidence to suggest
a significant market shift to lower
production volume in a post-standards
scenario, DOE expects that the relative
mix of high- and low-volume
production would be preserved. Indeed,
because DOE is proposing to expand
scope of coverage and bring many
previously-excluded motor types to
NEMA Premium levels, DOE sees the
possibility that standardization may
increase and average production volume
may, in fact, rise.61 DOE welcomes
additional comment on how standards
may cause average production run
61 Labor
costs may rise starkly at max-tech levels,
where hand-winding is employed in order to
maximize slot fill. DOE’s engineering analysis
reflects this fact.
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volume to rise or fall, and how labor
costs may vary as a result.
c. Catalog Prices
NEMA also requested that DOE
publish the purchase price for its torn
down motors, so that they could be
compared to the MSPs DOE derived
from its motor tear-downs. (NEMA, No.
54 at p. 27; Baldor, Public Meeting
Transcript, No. 60 at pp. 181, 182) At
this time, DOE is electing not to include
the purchase price for its torn down
motors. DOE believes that such
information is not relevant and could
lead to erroneous conclusions. Some of
the purchased motors were more
expensive to purchase based on certain
features that do not affect efficiency,
which could skew the price curves
incorrectly and indicate incorrect
trends. For these reasons, in the
engineering analysis, DOE develops its
own cost model so that a consistent cost
structure can be applied to similar
equipment. The details of this model are
available in appendix 5A. Because DOE
purchased electric motors that were
built by different manufacturers and
sold by different distributors, who all
have different costs structures, DOE
does not believe that such a comparison
is a meaningful evaluation.
d. Product Development Cost
In response to the preliminary
analysis, NEMA commented that DOE
presumes that the incremental cost
between motors of different designs and
different technologies is based solely on
the difference in material costs and
markups. NEMA also commented that
there is a higher cost of manufacturing
a die-cast copper rotor compared to an
aluminum die-cast rotor motor that is
not captured in material costs. (NEMA,
No. 54 at p. 12, 74) During the
preliminary analysis public meeting,
ACEEE commented that the Motor
Coalition has concerns about CSL 3 for
ECG 1, stating that DOE’s analysis may
not have captured the full cost of an
industry-transition to that efficiency
level. (ACEEE, Public Meeting
Transcript, No. 60 at p. 20)
DOE has made some additions to its
cost model for the NOPR analysis based
on NEMA’s comments. However, DOE
clarifies that its cost model for the
preliminary analysis did include an
incremental markup used to account for
higher production costs associated with
manufacturing copper die-cast rotors.
Although DOE used this incremental
markup in the preliminary analysis,
after conducting manufacturer
interviews for the NOPR analysis, it
believed that additional costs were
warranted for the examined ELs that
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exceeded the NEMA Premium level.
NEMA commented that the
manufacturer production costs (MPCs)
and subsequent LCCs must take into
account the large additional conversion
costs, since manufacturers would likely
attempt to recover the costs of meeting
a higher efficiency standard. (NEMA,
No. 54 at p. 4) Therefore, DOE
developed a per-unit adder 62 for the
MPCs intended to capture one-time
increased product development and
capital conversion costs that would
likely result if an efficiency level above
NEMA Premium were established.
DOE’s per-unit adder reflects the
additional cost passed along to the
consumer by manufacturers attempting
to recover the costs incurred from
having to redevelop their equipment
lines as a result of higher energy
conservation standards. The conversion
costs incurred by manufacturers include
capital investment (e.g., new tooling and
machinery), equipment development
(e.g., reengineering each motor design
offered), plus testing and compliance
certification costs.
The conversion cost adder was only
applied to ELs above NEMA Premium
based on manufacturer feedback. Most
manufacturers now offer NEMA
Premium motors for a significant
portion of their equipment lines as a
result of EISA 2007, which required
manufacturers to meet this level. Many
manufacturers also offer certain ratings
with efficiency levels higher than
NEMA Premium. However, DOE is not
aware of any manufacturer with a
complete line of motors above NEMA
Premium. Consequently, DOE believes
that energy conservation standards
above NEMA Premium would result in
manufacturers incurring significant
conversion costs to bring offerings of
electric motors up to the higher
standard.
DOE developed the various
conversion costs from data collected
during manufacturer interviews that
were conducted for the Manufacturer
Impact Analysis (MIA). For more
information on the MIA, see TSD
chapter 12. DOE used the manufacturersupplied data to estimate industry-wide
capital conversion costs and product
conversion costs for each EL above
NEMA Premium. DOE then assumed
that manufacturers would mark up their
motors to recover the total conversion
costs over a seven year period. By
dividing industry-wide conversion costs
by seven years of expected industry62 The ‘‘per-unit adder’’ discussed in this section
refers to a fixed adder for each motor that varies
based on horsepower and NEMA design letter. Each
representative unit has their own unique ‘‘per-unit
adder’’ that is fixed for the analysis.
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wide revenue, DOE obtained a
percentage estimate of how much each
motor would be marked up by
manufacturers. The conversion costs as
a percentage of 7-year revenue that DOE
derived for each NEMA band above
NEMA premium are shown below.
Details on these calculations are shown
in Chapter 5 of the TSD.
The percentage markup was then
TABLE IV.13—PRODUCT CONVERSION
COSTS AS A PERCENTAGE OF 7- applied to the full production cost
(direct material + direct labor +
YEAR REVENUE
Conversion costs
as a percentage
of 7-year
revenue
(percent)
NEMA
bands above
NEMA premium
1 ......................................
2 ......................................
overhead) at the NEMA Premium levels
to derive the per unit adder for levels
above NEMA Premium (see Table
IV.14).
4.1
6.5
TABLE IV.14—PRODUCT CONVERSION COSTS FOR EFFICIENCY LEVELS ABOVE NEMA PREMIUM
Per unit
adder for 1
band above
NEMA premium
Representative unit
Per unit
adder for 2
bands above
NEMA premium
$11.06
32.89
66.18
10.68
60.59
$17.36
1.61
103.86
16.75
95.08
5 HP, Design B ................................................................................................................................................
30 HP, Design B ..............................................................................................................................................
75 HP, Design B ..............................................................................................................................................
5 HP, Design C ................................................................................................................................................
50 HP, Design C ..............................................................................................................................................
7. Engineering Analysis Results
The results of the engineering analysis
are reported as cost versus efficiency
data in the form of MSP (in dollars)
versus nominal full-load efficiency (in
percentage). These data form the basis
for subsequent analyses in today’s
NOPR. Table IV.15 through Table IV.19
show the results of DOE’s updated
NOPR engineering analysis.
Results for Equipment Class Group 1
(NEMA Design A and B Electric Motors)
TABLE IV.15—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL
EL
EL
EL
EL
0
1
2
3
4
(Baseline) ................................................................................................................................................
(EPACT 1992) .........................................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
Manufacturer
selling price
($)
82.5
87.5
89.5
90.2
91.0
330
341
367
402
670
TABLE IV.16—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 30-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL
EL
EL
EL
EL
0
1
2
3
4
(Baseline) ................................................................................................................................................
(EPACT 1992) .........................................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
Manufacturer
selling price
($)
89.5
92.4
93.6
94.1
94.5
848
1,085
1,156
1,295
2,056
TABLE IV.17—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 75-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Efficiency level
EL
EL
EL
EL
EL
0
1
2
3
4
(Baseline) ................................................................................................................................................
(EPACT 1992) .........................................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
93.0
94.1
95.4
95.8
96.2
Results for Equipment Class Group 2
(NEMA Design C Electric Motors)
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Manufacturer
selling price
($)
1,891
2,048
2,327
2,776
3,620
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
73635
TABLE IV.18—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL 0 (Baseline/EPACT 1992) ..........................................................................................................................
EL 1 (NEMA Premium) ....................................................................................................................................
EL 2 (Max-Tech) ..............................................................................................................................................
Manufacturer
selling price
($)
87.5
89.5
91.0
331
355
621
TABLE IV.19—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 50-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL 0 (Baseline/EPACT 1992) ..........................................................................................................................
EL 1 (NEMA Premium) ....................................................................................................................................
EL 2 (Max-Tech) ..............................................................................................................................................
Manufacturer
selling price
($)
93.0
94.5
95.0
1,537
2,130
2,586
Results for Equipment Class Group 3
(Fire Pump Electric Motors)
TABLE IV.20—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL
EL
EL
EL
0
1
2
3
(Baseline/EPACT 1992) ..........................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
Manufacturing
selling price
($)
87.5
89.5
90.2
91.0
341
367
402
670
TABLE IV.21—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 30-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL
EL
EL
EL
0
1
2
3
(Baseline/EPACT 1992) ..........................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
Manufacturer
selling price
($)
92.4
93.6
94.1
94.5
1,085
1,156
1,295
2,056
TABLE IV.22—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 75-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL
EL
EL
EL
0
1
2
3
(Baseline/EPACT 1992) ..........................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
Manufacturer
selling price
($)
94.1
95.4
95.8
96.2
2,048
2,327
2,776
3,620
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Results for Equipment Class Group 4
(Brake Electric Motors)
TABLE IV.23—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 5-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
EL
EL
EL
EL
EL
0
1
2
3
4
(Baseline) ................................................................................................................................................
(EPACT 1992) .........................................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
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82.5
87.5
89.5
90.2
91.0
06DEP2
Manufacturer
selling price
($)
330
341
367
402
670
73636
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TABLE IV.24—MANUFACTURER SELLING PRICE AND EFFICIENCY FOR 30-HORSEPOWER REPRESENTATIVE UNIT
Efficiency
(%)
Efficiency level
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
EL
EL
EL
EL
EL
0
1
2
3
4
(Baseline) ................................................................................................................................................
(EPACT 1992) .........................................................................................................................................
(NEMA Premium) ....................................................................................................................................
(Best-in-Market) ......................................................................................................................................
(Max-Tech) ..............................................................................................................................................
8. Scaling Methodology
Once DOE has identified costefficiency relationships for its
representative units, it must
appropriately scale the efficiencies
analyzed for its representative units to
those equipment classes not directly
analyzed. DOE recognizes that scaling
motor efficiencies is a complicated
proposition that has the potential to
result in efficiency standards that are
not evenly stringent across all
equipment classes. However, between
DOE’s four ECGs, there are 580
combinations of horsepower rating, pole
configuration, and enclosure. Within
these combinations there are a large
number of standardized frame number
series. Given the sizable number of
frame number series and equipment
classes, DOE cannot feasibly analyze all
of these variants, hence, the need for
scaling. Scaling across horsepower
ratings, pole configurations, enclosures,
and frame number series is a necessity.
For the preliminary analysis, DOE
considered two methods to scaling, one
that develops a set of power law
equations based on the relationships
found in the EPACT 1992 and NEMA
Premium tables of efficiency in NEMA
Standard Publication MG 1, and one
based on the incremental improvement
of motor losses. As discussed in the
preliminary analysis, DOE did not find
a large discrepancy between the results
of the two approaches and, therefore,
used the simpler, incremental
improvement of motor losses approach
in its NOPR analysis.
As discussed in IV.C.3, some of the
ELs analyzed by DOE were based on
existing efficiency standards (i.e.,
EPACT 1992 and NEMA Premium).
Additionally, the baseline EL is based
on the lowest efficiency levels found for
each horsepower rating, pole
configuration, and enclosure type
observed in motor catalog data.
Therefore, DOE only required the use of
scaling when developing the two ELs
above NEMA Premium (only one EL
above NEMA Premium for ECG 2).
For the higher ELs in ECG 1, DOE’s
scaling approach relies on NEMA MG
1–2011 Table 12–10 of nominal
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efficiencies and the relative
improvement in motor losses of the
representative units. As has been
discussed, each incremental
improvement in NEMA nominal
efficiency (or NEMA band) corresponds
to roughly a 10 percent reduction in
motor losses. After ELs 3 and 4 were
developed for each representative unit,
DOE applied the same reduction in
motor losses (or the same number of
NEMA band improvements) to various
segments of the market based on its
representative units. DOE assigned a
segment of the electric motors market,
based on horsepower ratings, to each
representative unit analyzed. DOE’s
assignments of these segments of the
markets were in part based on the
standardized NEMA frame number
series that NEMA MG 1–2011 assigns to
horsepower and pole combinations. In
the end, EL 3 corresponded to a one
band improvement relative to NEMA
Premium and EL 4 corresponded to a
two-band improvement relative to
NEMA Premium. In response to the
preliminary analysis, DOE received
multiple comments regarding scaling.
NEMA commented that DOE states
that scaling is necessary for the national
impacts analysis, but NEMA contends
that the foremost reason for the scaling
is that the scaling is used to establish
the values of any amended or new
efficiency standards. (NEMA, No. 54 at
p. 68) NEMA also expressed its belief
that the scaling method used in the
preliminary analysis does not
adequately take into consideration
numbers of poles, stack length, and
frame enclosures and that scaling based
on changes in efficiency for lower
horsepower motor models, as
interpreted by software, does not
accurately reflect what is achievable for
higher horsepower ratings. (NEMA, No.
54 at p. 5)
During the preliminary analysis
public meeting, Baldor commented that
because some energy conservation
levels could not be reached without
using a different technology option, at
least 30 percent of the ratings in an
equipment classes could not achieve
energy conservation levels above CSL 2.
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92.4
93.6
94.1
94.5
Manufacturer
selling price
($)
848
1,085
1,156
1,295
2,056
Because of this, a scaling method based
on any particular set of technology is
not scalable across all equipment
classes. Baldor suggested that DOE
could use software modeling to check
some of the motor configurations not
directly analyzed. (Baldor, Public
Meeting Transcript, No. 60 at pp. 196,
197, 200)
Nidec commented during the public
meeting that scaling has too many
variables, and that manufacturers do not
use scaling because it is not possible.
(Nidec, Public Meeting Transcript, No.
60 at pp. 198–199) ACEEE added that
there is no underlying fundamental
physical theory associated with the
efficiencies listed in NEMA MG 1–2011
Table 12–11 or Table 12–12. (ACEEE,
Public Meeting Transcript, No. 60 at pp.
198–199)
DOE appreciates the comments
received regarding scaling; however, it
maintains that scaling is a tool
necessary to analyze the potential
effects of energy conservation standards
above NEMA Premium levels. As stated
earlier, DOE is evaluating energy
conservation standards for 580
equipment classes. DOE acknowledges
that analyzing every one of these classes
individually is not feasible, which
requires DOE to choose representative
units on which to base its analysis. DOE
agrees with Baldor that the primary
reason for scaling is to establish
efficiency levels for any potential new
or amended standards for electric
motors.
However, DOE notes that its analysis
neither assumes nor requires
manufacturers to use identical
technology for all motor types and
horsepower ratings. In other words,
although DOE may choose a certain set
of technologies to estimate cost behavior
across efficiency, DOE’s standards are
technology-neutral and permit
manufacturers design flexibility. DOE
clarifies that the national impacts
analysis is one of the primary ways in
which DOE analyses those potential
efficiency levels and determines if they
would be economically justified. As
DOE has stated, it is also important that
the levels be technically feasible. In
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order to maintain technical feasibility,
DOE has maintained the scaling
approach that it developed for the
preliminary analysis. DOE believes that
this approach, which is as conservative
as possible while maintaining the use of
NEMA nominal efficiencies,
accomplishes that. For each incremental
EL above the NEMA Premium level,
DOE has incremented possible
efficiency levels by just one band of
efficiency. Through the use of this
conservative approach to scaling, DOE
believes that it has helped conserve the
technological feasibility of each of its
ELs to the greatest extent practicable.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
D. Markups Analysis
The markups analysis develops
appropriate markups in the distribution
chain to convert the estimates of
manufacturer selling price derived in
the engineering analysis to customer
prices. (‘‘Customer’’ refers to purchasers
of the equipment being regulated). In
the preliminary analysis, DOE
determined the distribution channels for
electric motors, their shares of the
market, and the markups associated
with the main parties in the distribution
chain, distributors and contractors. For
the NOPR, DOE retained these
distribution channels.
DOE developed average distributor
and contractor markups by examining
the contractor cost estimates provided
by RS Means Electrical Cost Data
2013.63 DOE calculates baseline and
overall incremental markups based on
the equipment markups at each step in
the distribution chain. The incremental
markup relates the change in the
manufacturer sales price of higher
efficiency models (the incremental cost
increase) to the change in the customer
price. Chapter 6 of the NOPR TSD
addresses estimating markups.
E. Energy Use Analysis
The energy use analysis provides
estimates of the annual energy
consumption of commercial and
industrial electric motors at the
considered efficiency levels. DOE uses
these values in the LCC and PBP
analyses and in the NIA. DOE
developed energy consumption
estimates for all equipment analyzed in
the engineering analysis.
The annual energy consumption of an
electric motor that has a given nominal
full-load efficiency depends on the
electric motor’s sector (industry,
agriculture, or commercial) and
application (compressor, fans, pumps,
material handling, fire pumps, and
63 RS Means (2013), Electrical Cost Data, 36th
Annual Edition, Kingston, MA.
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others), which in turn determine the
electric motor’s annual operating hours
and load.
To calculate the annual kilowatthours (kWh) consumed at each
efficiency level in each equipment class,
DOE used the nominal efficiencies at
various loads from the engineering
analysis, along with estimates of
operating hours and electric motor load
for electric motors in various sectors
and applications.
In the preliminary analysis, DOE used
statistical information on annual electric
motor operating hours and load derived
from a database of more than 15,000
individual motor field assessments
obtained through the Washington State
University and the New York State
Energy Research and Development
Authority to determine the variation in
field energy use in the industrial sector.
For the agricultural and the commercial
sector, DOE relied on data found in the
literature.
As part of its NOPR analysis, for the
industrial sector, DOE re-examined its
initial usage profiles and recalculated
motor distribution across applications,
operating hours, and load information
based on additional motor field data
compiled by the Industrial Assessment
Center at the University of Oregon,
which includes over 20,000 individual
motor records. For the agricultural
sector, DOE revised its average annual
operating hours assumptions based on
additional data found in the literature.
No changes were made to the
commercial sector average annual
operating hours.
Chapter 7 of the NOPR TSD describes
the energy use analysis.
1. Comments on Operating Hours
Several interested parties commented
on the annual operating hours
assumptions. NEMA and UL
commented that fire pumps typically
operate when being tested on a monthly
basis and that the annual operating-hour
assumption for fire pump electric
motors in the industrial sector seemed
high but did not provide data to support
their comment. NEMA agreed with the
fire pump electric motor annual
operating-hour assumptions in the
commercial and agricultural sectors.
(NEMA, No. 54 at p. 83) (UL, No. 46 at
p. 1)
For the NOPR, DOE reviewed the field
data for fire pump electric motors used
in the preliminary analysis and noticed
some values were associated with
motors driving jockey pumps, which are
pressure maintenance pumps used to
maintain pressure in fire sprinkler
systems. After filtering out the motors
driving jockey pumps, DOE derived an
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average value of annual operating hours
similar to the fire pump electric motor
annual operating hours for the
commercial and agricultural sectors.
Therefore, DOE revised its fire pumps
operating hour assumption accordingly.
NEMA submitted data regarding
annual operating hour assumptions in
the industrial sector based on its expert
knowledge. These assumptions were
lower than those used in the
preliminary analysis. (NEMA, No. 54 at
p. 10)
As previously mentioned, DOE
revised the average operating hours
associated with applications in the
industrial sector (compressor, fans,
pump, material handling, and others)
based on additional individual motor
nameplate and field data compiled by
the Industrial Assessment Center at the
University of Oregon.64 The revised
average operating hour values are
generally lower than the estimates from
the preliminary analysis and differ from
what NEMA provided. DOE could not
verify the estimates provided by NEMA
and it is not clear that these estimates
represent an accurate picture of the
entire industrial sector. In contrast, the
average operating hours by motor
application that DOE used in the NOPR
were based on an analysis of annual
operating hours for over 35,000
individual motors. DOE notes that it
analyzed a sensitivity case that reflects
the NEMA estimates.
IECA commented that the database of
plant assessments is based on surveys
conducted between 2005 and 2011 and
there is no explanation of the effects of
the recession on these surveys. (IECA,
No. 52 at p. 2) DOE could not estimate
the impact of the recession on the
average operating hour values derived
from the database of field assessment
from the Washington State University
and the New York State Energy
Research and Development Authority,
as the year of the assessment was not
specified for all of the entries. The
additional data from the Industrial
Assessment Center cover a longer time
period (1987–2007). Thus, DOE believes
that its estimates of operating hours are
not unduly affected by lower industrial
activity during the recession.
64 Strategic Energy Group (January, 2008),
Northwest Industrial Motor Database Summary
from Regional Technical Forum. https://
rtf.nwcouncil.org/subcommittees/osumotor/
Default.htm. This database provides information on
motors collected by the Industrial Assessment
Center (IAC) at Oregon State University (OSU). The
database includes more than 22,000 records, each
with detailed motor application and field usage
data.
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2. Comments on Other Issues
In response to DOE’s energy use
discussion from the preliminary
analysis, NEMA commented that NEMA
Design C motors are not typically found
in pump applications. (NEMA, No. 54 at
p. 83) For NEMA Design C motors, DOE
re-examined its distribution by
application and agrees with NEMA that
NEMA Design C motors are not typically
found in pump applications. These
motors are characterized by high torque
and generally found in compressors and
other applications such as conveyors.
Consistent with this review, DOE
adjusted its analyses.
NEMA commented that the curve fit
for the polynomial equations modeling
the load versus losses relationships for
NEMA Design B motors did not seem to
represent the test data accurately.
(NEMA, No. 54 at p. 81)
For each representative unit, DOE
based its energy use calculation on
nominal values of efficiency. DOE
obtained data on part load losses from
test data developed in the engineering
analysis and fitted these data to derive
load versus losses relationships in the
form of a third degree polynomial
equation. The representative units
showed tested efficiencies which were
not equal to the nominal efficiencies
and DOE adjusted the coefficients of the
polynomial equations to match the full
load losses expected at nominal
efficiency. The adjusted equation,
therefore, calculates losses for a motor
with full load efficiency equal to the full
load nominal efficiency. For the NOPR,
DOE followed the same approach and
revised the polynomial equations to
reflect the NOPR engineering outputs.
NEMA commented that the
installation of a more efficient motor in
variable torque applications could lead
to less energy savings than anticipated.
Because a more efficient motor usually
has less slip 65 than a less efficient one
does, this attribute can result in a higher
operating speed and a potential
overloading of the motor. NEMA
recommended that DOE include the
consequence of a more efficient motor
operating at an increased speed in any
determination of energy savings.
(NEMA, No. 54 at p. 28)
DOE acknowledges that the arithmetic
cubic relation between speed and power
requirement in many variable torque
applications can affect the benefits
gained by using efficient electric motors,
which have a lower slip. DOE agrees
that it is possible to quantify this impact
65 The slip is the difference between the
synchronous speed of the magnetic field (as defined
by the number of poles), and the actual rotating
speed of the motor shaft.
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for one individual motor. However, DOE
was not able to extend this analysis to
the national level. DOE does not have
robust data related to the overall share
of motors that would be negatively
impacted by higher speeds in order to
incorporate this effect in the main
analysis. Further, in the engineering
analysis, DOE could not extend the
synchronous speed information from
the representative units to the full range
of electric motor configurations. Instead,
DOE developed assumptions 66 and
estimated the effects of higher operating
speeds as a sensitivity analysis in the
LCC spreadsheet. For the representative
units analyzed in the LCC analysis, the
LCC spreadsheet allows one to consider
this effect as a sensitivity analysis
according to a scenario described in
appendix 7–A of the NOPR TSD.
IECA commented that estimates of
regional shares of motors should be
based on current inventories of motors
rather than sector-specific indicators
and that the data from the 2006
Manufacturer Energy Consumption
Survey (MECS) is outdated. (IECA, No.
52 at p. 2) DOE did not find any
information regarding motor inventory
and instead used indirect indicators to
derive motor distribution. For the
NOPR, DOE updated its regional shares
of motors based on industrial electricity
consumption by region from AEO 2013.
F. Life-Cycle Cost and Payback Period
Analysis
For each representative unit analyzed
in the engineering analysis, DOE
conducts LCC and PBP analyses to
evaluate the economic impacts on
individual customers of potential energy
conservation standards for electric
motors. The LCC is the total customer
expense over the life of the motor,
consisting of equipment and installation
costs plus operating costs over the
lifetime of the equipment (expenses for
energy use, maintenance and repair).
DOE discounts future operating costs to
the time of purchase using customer
discount rates. The PBP is the estimated
amount of time (in years) it takes
customers to recover the increased total
installed cost (including equipment and
installation costs) of a more efficient
type of equipment through lower
operating costs. DOE calculates the PBP
66 DOE assumed that 60 percent of pumps, fans
and compressor applications are variable torque
applications. Of these 60 percent, DOE assumed
that all fans and a majority (70 percent) of
compressors and pumps would be negatively
impacted by higher operating speeds; and that 30
percent of compressors and pumps would not be
negatively impacted from higher operating speeds
as their time of use would decrease as the flow
increases with the speed (e.g. a pump filling a
reservoir).
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by dividing the change in total installed
cost (normally higher) due to a standard
by the change in annual operating cost
(normally lower) which results from the
standard.
For any given efficiency level, DOE
measures the PBP and the change in
LCC relative to an estimate of the basecase efficiency levels. The base-case
estimate reflects the market in the
absence of new or amended energy
conservation standards, including the
market for equipment that exceeds the
current energy conservation standards.
For each representative unit, DOE
calculated the LCC and PBP for a
distribution of individual electric
motors across a range of operating
conditions. DOE used Monte Carlo
simulations to model the distributions
of inputs. The Monte Carlo process
statistically captures input variability
and distribution without testing all
possible input combinations. Therefore,
while some atypical situations may not
be captured in the analysis, DOE
believes the analysis captures an
adequate range of situations in which
electric motors operate.
The following sections contain brief
discussions of comments on the inputs
and key assumptions of DOE’s LCC and
PBP analysis and explain how DOE took
these comments into consideration.
1. Equipment Costs
In the LCC and PBP analysis, the
equipment costs faced by electric motor
purchasers are derived from the MSPs
estimated in the engineering analysis
and the overall markups estimated in
the markups analysis.
To forecast a price trend for the
preliminary analysis, DOE derived an
inflation-adjusted index of the producer
price index (PPI) for integral
horsepower motors and generators
manufacturing from 1969 to 2011. These
data show a long-term decline from
1985 to 2003, and then a steep increase
since then. DOE also examined a
forecast based on the ‘‘chained price
index—industrial equipment’’ that was
forecasted for AEO2012 out to 2040.
This index is the most disaggregated
category that includes electric motors.
These data show a short-term increase
from 2011 to 2015, and then a steep
decrease since then. DOE believes that
there is considerable uncertainty as to
whether the recent trend has peaked,
and would be followed by a return to
the previous long-term declining trend,
or whether the recent trend represents
the beginning of a long-term rising trend
due to global demand for electric motors
and rising commodity costs for key
motor components. Given the
uncertainty, DOE chose to use constant
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prices (2010 levels) for both its LCC and
PBP analysis and the NIA. For the NIA,
DOE also analyzed the sensitivity of
results to alternative electric motor price
forecasts.
DOE did not receive comments on the
trend it used for electric motor prices,
and it retained the approach used in the
preliminary analysis for the NOPR.
engineering analysis, for equipment
class Group 1, all representative units
selected were NEMA Design B motors
and the NEMA Design B requirements
are maintained across all efficiency
levels. Therefore, DOE did not account
for additional installation costs related
to the replacement of NEMA Design B
motors with NEMA Design A motors.
2. Installation Costs
In the preliminary analysis, the
engineering analysis showed that for
some representative units, increased
efficiency led to increased stack length.
However, the electric motor frame
remained in the same NEMA frame size
requirements as the baseline electric
motor, and the motor’s ‘‘C’’ dimension
remained fairly constant across
efficiency levels. In addition, electric
motor installation cost data from RS
Means Electrical Cost Data 2013 showed
a variation in installation costs by
horsepower (for three-phase electric
motors), but not by efficiency.
Therefore, in the preliminary analysis,
DOE assumed there is no variation in
installation costs between a baseline
efficiency electric motor and a higher
efficiency electric motor.
Two interested parties commented
that DOE might have to consider
increased installation costs related to
larger diameter motors in comparison to
baseline motors. (CA IOUs, No. 57 at p.
2; NEMA, No. 54 at p. 83) NEMA added
that the size of a motor may need to be
increased to provide the necessary
material to obtain higher levels of
energy efficiency, such as CSL 3
examined for Design B electric motors.
(NEMA, No. 54 at p. 83)
DOE’s engineering data show that the
motor’s ‘‘C’’ dimension remained fairly
constant across efficiency levels. For
equipment class Group 1, the stack
length of higher efficiency motors (EL 3
and above) did not show significant
increases in size in comparison to
NEMA Premium level motors (EL 2). In
addition, the frame size remained the
same and the ‘‘C’’ dimension data did
not significantly vary. Therefore, for the
NOPR, DOE retained the same approach
as in the preliminary analysis and did
not incorporate changes in installation
costs for electric motors that are more
efficient than baseline equipment.
NEMA stated that when a user
replaces a baseline NEMA Design B
motor with a higher efficiency NEMA
Design A motor, the user might
experience additional installation costs
compared to replacing the motor with a
baseline NEMA Design B motor due to,
for example, potential needs for new
motor controller or motor protection
devices. (NEMA, No. 54 at p. 29) In the
3. Maintenance Costs
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In the preliminary analysis, DOE did
not find data indicating a variation in
maintenance costs between a baseline
efficiency and higher efficiency electric
motor. According to data from
Vaughen’s Price Publishing Company,67
which publishes an industry reference
guide on motor repair pricing, the price
of replacing bearings, which is the most
common maintenance practice, is the
same at all efficiency levels. Therefore,
DOE did not consider maintenance costs
for electric motors. DOE did not receive
comments on this issue and retained the
approach used for the preliminary
analysis for the NOPR.
4. Repair Costs
In the preliminary analysis, DOE
accounted for the differences in repair
costs of a higher efficiency motor
compared to a baseline efficiency motor
and defined a repair as including a
rewind and reconditioning. Based on
data from Vaughen’s, DOE derived a
model to estimate repair costs by
horsepower, enclosure and pole, for
each EL.
The Electrical Apparatus Service
Association (EASA), which represents
the electric motor repair service sector,
noted that DOE should clarify the
definition of repair as including
rewinding and reconditioning. (EASA,
No. 47 at p. 1) DOE agrees with this
suggestion and has modified its
terminology in chapter 7 of the NOPR
TSD.
One interested party, Flolo
Corporation, noted that since the 1990’s,
increased windings protection has led to
longer repair cycles and the repair
frequency values used in the
preliminary analysis were too low. (Pub.
Mtg. Tr., No. 58 at p. 234)
For the preliminary analysis, DOE
estimated that NEMA Design A, B and
C electric motors were repaired on
average after 32,000 hours of operation
based on data for the industrial sector.
This estimate reflected a situation where
electric motors from 1 to 20-horsepower,
with an average lifetime of 5 years, are
not repaired; motors from 25- to 7567 Vaughen’s (2011, 2013), Vaughen’s Motor &
Pump Repair Price Guide, 2011, 2013 Edition.
https://www.vaughens.com/.
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horsepower, with an average lifetime of
10 years, are repaired at half their
lifetime; and motors from 100- to 500horsepower, with an average lifetime of
15 years, are repaired at a third of their
lifetime. In the NOPR analysis, DOE
retained a similar approach for the
industrial and commercial sectors. For
the agricultural sector, DOE did not find
sufficient data to distinguish by
horsepower range and assumed that
motors are repaired on average at half of
their lifetime. With the revised NOPR
mechanical lifetime and operating hour
estimates, the repair frequency in hours
increased to 48,600 hours in the
industrial sector compared to DOE’s
earlier estimate of 32,000 hours.
5. Unit Energy Consumption
The NOPR analysis uses the same
approach for determining unit energy
consumptions (UECs) as the preliminary
analysis. The UEC was determined for
each application and sector based on
estimated load points and annual
operating hours. For the NOPR, DOE
refined the average annual operating
hours, average load, and shares of
motors by application and sector.
In the preliminary analysis, DOE
assumed that one-third of repairs are
done following industry recommended
practice as defined by EASA. (EASA
Standard AR100–2010, Recommended
Practice for the Repair of Rotating
Electrical Apparatus) and do not impact
the efficiency of the electric motor (i.e.,
no degradation of efficiency after
repair). DOE assumed that two-thirds of
repairs do not follow good practice and
that a slight decrease in efficiency
occurs when the electric motor is
repaired. DOE assumed the efficiency
decreases by 1 percent in the case of
electric motors of less than 40
horsepower, and by 0.5 percent in the
case of larger electric motors.
NEMA and EASA asked DOE to
clarify its assumption regarding the
share of repairs performed following
industry recommended practices.
(NEMA, No. 54 at p. 29) (EASA, No. 47
at p. 1) For the NOPR, DOE reviewed
data from the U.S. Economic Census 68
and EASA 69 and estimated that the
majority of motor repair shops are EASA
members and follow industry
recommended practices. DOE revised its
assumption for the NOPR analysis and
estimated that 90 percent of repairs are
done following industry recommended
practice and would not impact the
68 U.S. Economic Census 1997 and 2007 data on
the number of motor repair establishments (based
on NAICS 811, 811310, and SIC 7694).
69 Members of EASA available at: https://
www.easa.com/.
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efficiency of the motor (i.e. no
degradation of efficiency after repair).
NEMA also requested clarification on
whether the LCC is based on site energy
or full fuel cycle energy. (NEMA, No. 54
at p. 31) In the LCC, DOE considers site
energy use only.
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6. Electricity Prices and Electricity Price
Trends
In the preliminary analysis, DOE
derived sector-specific weighted average
electricity prices for four different U.S.
Bureau of the Census (Census) regions
(Northeast, Midwest, South, and West)
using data from the Energy Information
Administration (EIA Form 861). For
each utility in a region, DOE used the
average industrial or commercial price,
and then weighted the price by the
number of customers in each sector for
each utility.
For each representative motor, DOE
assigned electricity prices using a Monte
Carlo approach that incorporated
weightings based on the estimated share
of electric motors in each region. The
regional shares were derived based on
indicators specific to each sector (e.g.,
commercial floor space from the
Commercial Building Energy
Consumption Survey for the commercial
sector 70) and assumed to remain
constant over time. To estimate future
trends in energy prices, DOE used
projections from the EIA’s Annual
Energy Outlook 2011 (AEO 2011). The
NOPR retains the same approach for
determining electricity prices, and used
AEO 2013 to project electricity price
trends.
IECA commented that the sector
specific average electricity prices do not
account for differences across census
regions where industrial activity is
concentrated. (IECA, No. 52 at p. 2) As
noted above, the industrial electricity
price for each region is a weighted
average based on the number of
industrial customers of each utility.
Thus, the prices reasonably account for
concentration of industrial activity.
7. Lifetime
In the preliminary analysis, DOE
estimated the mechanical lifetime of
electric motors in hours (i.e., the total
number of hours an electric motor
operates throughout its lifetime),
depending on its horsepower size. DOE
then developed Weibull distributions of
mechanical lifetimes. The lifetime in
years for a sampled electric motor was
then calculated by dividing the sampled
mechanical lifetime by the sampled
70 U.S. Department of Energy Information
Administration (2003), Commercial Buildings
Energy Consumption Survey, https://www.eia.gov/
consumption/commercial/data/2003/pdf/a4.pdf.
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annual operating hours of the electric
motor. This model produces a negative
correlation between annual hours of
operation and electric motor lifetime:
Electric motors operated many hours
per year are likely to be retired sooner
than electric motors that are used for
only a few hundred hours per year. DOE
considered that electric motors of less
than 75-hp are most likely to be
embedded in a piece of equipment (i.e.,
an application). For such applications,
DOE developed Weibull distributions of
application lifetimes expressed in years
and compared the sampled motor
mechanical lifetime (in years) with the
sampled application lifetime. DOE
assumed that the electric motor would
be retired at the earlier of the two ages.
For the NOPR analysis, DOE retained
the same approach and revised some of
the lifetime assumptions based on
additional information collected.
NEMA and WEG commented that the
mechanical lifetime of agricultural
motors should be lower than in the
commercial or industrial sectors due to
lower levels of maintenance performed
in the field and the lighter duty steel
frame constructions of these motors.
(Pub. Mtg. Tr., No. 58 at p. 253) The
NOPR analysis estimates that the
average motor lifetime (across all sizes)
for the agricultural sector to be 20
years.71 This revised estimate translates
into average mechanical lifetimes
between 24,000 and 30,000 hours
depending on the horsepower range,
which is lower than in the industrial
sector.
For the NOPR, DOE collected sectorspecific mechanical motor lifetime
information where available and revised
the lifetime assumptions where
appropriate. For the industrial sector,
DOE estimated average mechanical
lifetimes of 5, 15, and 20 years,
depending on the horsepower range (the
values correspond to 43,800, 87,600,
and 131,400 hours respectively). These
values are higher than those used in the
preliminary analysis.
8. Discount Rate
The discount rate is the rate at which
future expenditures are discounted to
estimate their present value. The cost of
capital commonly is 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 to the firm of
71 Gallaher, M., Delhotal, K., & Petrusa, J. (2009).
Estimating the potential CO2 mitigation from
agricultural energy efficiency in the United States.
Energy Efficiency, 2 (2):207–220.
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equity and debt financing. DOE uses the
capital asset pricing model (CAPM) to
calculate the equity capital component,
and financial data sources to calculate
the cost of debt financing.
For the NOPR, DOE estimated a
statistical distribution of industrial and
commercial customer discount rates by
calculating the average cost of capital
for the different types of electric motor
owners (e.g., chemical industry, food
processing, and paper industry). For the
agricultural sector, DOE assumed
similar discount rates as in industry.
More details regarding DOE’s estimates
of motor customer discount rates are
provided in chapter 8 of the NOPR TSD.
9. Base Case Market Efficiency
Distributions
For the LCC analysis, DOE analyzed
the considered motor efficiency levels
relative to a base case (i.e., the case
without new or amended energy
efficiency standards). This requires an
estimate of the distribution of product
efficiencies in the base case (i.e., what
consumers would have purchased in the
compliance year in the absence of new
standards). DOE refers to this
distribution of product energy
efficiencies as the base case efficiency
distribution.
Data on motor sales by efficiency are
not available. In the preliminary
analysis, DOE used the number of
models meeting the requirements of
each efficiency level from six major
manufacturers and one distributor’s
catalog data to develop the base-case
efficiency distributions. The
distribution is estimated separately for
each equipment class group and
horsepower range and was assumed
constant and equal to 2012 throughout
the analysis period (2015–2044).
For the NOPR, DOE retained the same
approach to estimate the base case
efficiency distribution in 2012, but it
updated the base case efficiency
distributions to account for the NOPR
engineering analysis (revised ELs) and
for the update in the scope of electric
motors considered in the analysis.
Beyond 2012, DOE assumed the
efficiency distributions for equipment
class group 1 and 4 vary over time based
on historical data 72 for the market
penetration of NEMA Premium motors
within the market for integral
alternating current induction motors.
The assumed trend is shown in chapter
10 of the NOPR TSD. For equipment
class group 2 and 3, which represent a
very minor share of the market (less
72 Robert Boteler, USA Motor Update 2009,
Energy Efficient Motor Driven Systems Conference
(EEMODS) 2009.
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than 0.2 percent), DOE believes the
overall trend in efficiency improvement
for the total integral AC induction
motors may not be representative, so
DOE kept the base case efficiency
distributions in the compliance year
equal to 2012 levels.
Two interested parties commented on
the base case efficiency distributions.
Regal-Beloit stated that the share of 1to 5-horsepower motors in equipment
class 1 at CSL 0 in the base case
distribution was too low by at least one
percentage point. (Pub. Mtg. Tr., No. 58
at p. 263) NEMA requested clarifications
on how DOE derived its base case
efficiency distributions and commented
that it would expect CSL 0 to represent
60 percent of total units shipped when
considering the expanded scope as
proposed by NEMA. (NEMA, No. 54 at
p. 84) Neither stakeholder, however,
provided supporting data.
As mentioned previously, DOE
developed the 2012 base case efficiency
distributions based on catalog
information on the number of models
meeting the requirements of each
efficiency level. For the NOPR, DOE
retained the same methodology and
revised the catalog information to
account for the addition of brake motors
and NEMA 56-frame size enclosed
electric motors in the analysis. DOE has
no data to assess the stakeholders’ input
on the base case efficiency distributions.
10. Compliance Date
Any amended standard for electric
motors shall apply to electric motors
manufactured on or after a date which
is five years after the effective date of
the previous amendment. (42 U.S.C.
6313(b)(4)) In this case, the effective
date of the previous amendment
(established by EISA in 2007) is
December 19, 2010, and the compliance
date of any amended energy
conservation standards for electric
motors would be December 19, 2015. In
light of the proposal’s attempt to
establish amended or new standards for
currently regulated and unregulated
electric motor types, DOE has chosen to
retain the same compliance date for
both the amended and new energy
conservation standards to simplify the
requirements and to avoid any potential
confusion from manufacturers. The final
rule for this rulemaking is scheduled to
be published in early 2014. DOE
calculated the LCC and PBP for all endusers as if each would purchase a new
piece of equipment in the year that
compliance is required. As DOE notes
elsewhere, DOE is interested in
comments regarding the feasibility of
achieving compliance with this
proposed date.
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11. Payback Period Inputs
The payback period is the amount of
time it takes the consumer to recover the
additional installed cost of more
efficient equipment, compared to
baseline equipment, through energy cost
savings. Payback periods are expressed
in years. Payback periods that exceed
the life of the product mean that the
increased total installed cost is not
recovered in reduced operating
expenses.
The inputs to the PBP calculation are
the total installed cost of the product to
the customer for each efficiency level
and the average annual operating
expenditures for each efficiency level.
The PBP calculation uses the same
inputs as the LCC analysis, except that
discount rates are not needed.
12. Rebuttable-Presumption Payback
Period
EPCA establishes a rebuttable
presumption that a standard is
economically justified if the Secretary
finds that the additional cost to the
consumer of purchasing a product
complying with an energy conservation
standard level will be less than three
times the value of the energy (and, as
applicable, water) savings during the
first year that the consumer will receive
as a result of the standard, as calculated
under the test procedure in place for
that standard. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered
efficiency level, DOE determines the
value of the first year’s energy savings
by calculating the quantity of those
savings in accordance with the
applicable DOE test procedure, and
multiplying that amount by the average
energy price forecast for the year in
which compliance with the new or
amended standards would be required.
G. Shipments Analysis
DOE uses projections of product
shipments to calculate the national
impacts of standards on energy use,
NPV, and future manufacturer cash
flows. DOE develops shipment
projections based on historical data and
an analysis of key market drivers for
each product.
To populate the model with current
data, DOE used data from a market
research report,73 confidential inputs
from manufacturers, trade associations,
and other interested parties’ responses
to the Request for Information (RFI)
published in the Federal Register. 76 FR
17577 (March 30, 2011). DOE then used
estimates of market distributions to
73 IMS Research (February 2012), The World
Market for Low Voltage Motors, 2012 Edition,
Austin.
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73641
redistribute the shipments across pole
configurations, horsepower, and
enclosures within each electric motor
equipment class and also by sector.
DOE’s shipments projection assumes
that electric motor sales are driven by
machinery production growth for
equipment including motors. DOE
estimated that growth rates for total
motor shipments correlate to growth
rates in fixed investment in equipment
and structures including motors, which
is provided by the U.S. Bureau of
Economic Analysis (BEA).74 Projections
of real gross domestic product (GDP)
from AEO 2013 for 2015–2040 were
used to project fixed investments in the
equipment and structures including
motors. The current market
distributions are maintained over the
forecast period.
For the NOPR, with the expanded
scope by horsepower, DOE estimates
total shipments in scope were 5.43
million units in 2011. This estimate
represents an increase compared to the
shipments estimated in the preliminary
analysis because of the inclusion of
integral brake motors and of NEMA
integral enclosed 56-frame motors.
For the preliminary analysis, DOE
collected data on historical series of
shipment quantities and value for the
1990–2003 period, but concluded that
the data were not sufficient to estimate
motor price elasticity.75 Consequently,
DOE assumed zero price elasticity for all
efficiency standards cases and did not
estimate any impact of potential
standards levels on shipments. DOE
requested stakeholder recommendations
on data sources to help better estimate
the impacts of increased efficiency
levels on shipments.
The Motor Coalition commented that
higher equipment costs required to
achieve efficiency levels above CSL 2
(NEMA Premium) would encourage the
refurbishment of existing motors rather
than their replacement by new, more
efficient motors, leading to reduced cost
effective energy savings at CSL 3. (Motor
Coalition, No. 35 at p. 7)
DOE acknowledges that increased
electric motor prices could affect the
74 Bureau of Economic Analysis (March 01, 2012),
Private Fixed Investment in Equipment and
Software by Type and Private Fixed Investment in
Structures by Type. https://www.bea.gov/iTable/
iTable.cfm?ReqID=12&step=1.
75 Business Trend Analysts, The Motor and
Generator Industry, 2002; U.S. Census Bureau
(November 2004), Motors and Generators—
2003.MA335H(03)–1. https://www.census.gov/
manufacturing/cir/historical_data/discontinued/
ma335h/; and U.S. Census Bureau
(August 2003), Motors and Generators—
2002.MA335H(02)–1. https://www.census.gov/
manufacturing/cir/historical_data/discontinued/
ma335h/ma335h02.xls.
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‘‘repair versus replace’’ decision,
leading to the increased longevity of
existing electric motors and a decrease
in shipments of newly-manufactured
energy-efficient electric motors.
Considering the minimal cost increase
between EL 2 and EL 3 in the
preliminary analysis (approximately 3
percent for representative unit 1), DOE
does not believe it is reasonable to
consider non-zero price elasticity when
calculating the standards-case
shipments for levels above EL 2 and
zero price elasticity when calculating
shipments for the standards case at EL
2 of the preliminary analysis. For the
above reasons, DOE retained its
shipments projections, which do not
incorporate price elasticities, for the
NOPR. However, DOE also performed a
sensitivity analysis that demonstrates
the impact of possible price elasticities
on projected shipments and the NIA
results. See TSD appendix 10–C for
more details and results.
NEMA commented that shipments of
imported motors might decrease if
higher efficiency levels are mandated.
(NEMA, No. 54 at p. 29) NEMA,
however, provided no data in support of
its view. DOE has reviewed shipments
information from market reports, the
U.S. Census, as well as market
information provided by the Motor
Coalition and has been unable to obtain
any data to assess the potential
reduction in quantity of imported
motors due to standards and whether
this would impact the total number of
motors shipped in the U.S.76 DOE’s
shipments projection assumes that
electric motor sales are driven by
machinery production growth for
equipment including motors without
distinction between imported and
domestic motors.
H. National Impact Analysis
The NIA assesses the national energy
savings (NES) and the national NPV of
total customer costs and savings that
would be expected to result from new
and amended standards at specific
efficiency levels.
To make the analysis more accessible
and transparent to all interested parties,
DOE used an MS Excel spreadsheet
model to calculate the energy savings
and the national customer costs and
savings from each TSL.77 DOE used the
NIA spreadsheet to calculate the NES
and NPV, based on the annual energy
consumption and total installed cost
data from the energy use analysis and
the LCC analysis. DOE forecasted the
lifetime energy savings, energy cost
savings, equipment costs, and NPV of
customer benefits for each product class
for equipment sold from 2015 through
2044. In addition, DOE analyzed
scenarios that used inputs from the AEO
2013 Low Economic Growth and High
Economic Growth cases. These cases
have higher and lower energy price
trends compared to the reference case.
DOE evaluated the impacts of
potential new and amended standards
for electric motors by comparing basecase projections with standards-case
projections. The base-case projections
characterize energy use and customer
costs for each equipment class in the
absence of new and amended energy
conservation standards. DOE compared
these projections with projections
characterizing the market for each
equipment class if DOE were to adopt
new or amended standards at specific
energy efficiency levels (i.e., the
standards cases) for that class.
Table IV.25 summarizes all the major
preliminary analysis inputs to the NIA
and whether those inputs were revised
for the NOPR.
TABLE IV.25—INPUTS FOR THE NATIONAL IMPACT ANALYSIS
Input
Preliminary analysis description
Changes for NOPR
Shipments ......................................
Compliance date of standard .........
Annual shipments from shipments model ..............................................
Modeled used January 1, 2015 ..............................................................
Equipment Classes ........................
Three separate equipment class groups for NEMA Design A and B
motors, NEMA Design C motors, and Fire Electric Pump Motors.
Constant efficiency from 2015 through 2044 .........................................
No change.
December 19, 2015 (modeled as
January 1, 2016).
Added one equipment class group
for brake motors.
No change for Equipment Class 2
and 3. Added a trend for the efficiency distribution of equipment
class groups 1 and 4.
No change.
No change.
Base case efficiencies ...................
Standards case efficiencies ...........
Annual energy consumption per
unit.
Total installed cost per unit ............
Electricity expense per unit ............
Escalation of electricity prices ........
Electricity site-to-source conversion
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Discount rates ................................
Present year ...................................
Constant efficiency at the specified standard level from 2015 to 2044
Average unit energy use data are calculated for each horsepower rating and equipment class based on inputs from the Energy use analysis.
Based on the MSP and weight data from the engineering, and then
scaled for different hp and enclosure categories.
Annual energy use for each equipment class is multiplied by the corresponding average energy price.
AEO 2011 forecasts (to 2035) and extrapolation for 2044 and beyond
A time series conversion factor; includes electric generation, transmission, and distribution losses.
3% and 7% real ......................................................................................
2012 ........................................................................................................
76 IMS Research (February 2012), The World
Market for Low Voltage Motors, 2012 Edition,
Austin; Business Trend Analysts, The Motor and
Generator Industry, 2002; U.S. Census Bureau
(November 2004), Motors and Generators—
2003.MA335H(03)–1. https://www.census.gov/
manufacturing/cir/historical_data/discontinued/
ma335h/; and U.S. Census Bureau
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18:00 Dec 05, 2013
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(August 2003), Motors and Generators—
2002.MA335H(02)–1. https://www.census.gov/
manufacturing/cir/historical_data/discontinued/
ma335h/ma335h02.xls.
77 DOE understands that MS Excel is the most
widely used spreadsheet calculation tool in the
United States and there is general familiarity with
its basic features. Thus, DOE’s use of MS Excel as
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No change.
No change.
Updated to AEO 2013.
No change.
No change.
2013.
the basis for the spreadsheet models provides
interested parties with access to the models within
a familiar context. In addition, the TSD and other
documentation that DOE provides during the
rulemaking help explain the models and how to use
them, and interested parties can review DOE’s
analyses by changing various input quantities
within the spreadsheet.
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1. Efficiency Trends
In the preliminary analysis, DOE did
not include any change in base case
efficiency in its shipments and national
energy savings models. As explained in
section IV.F, for equipment class groups
1 and 4, for the NOPR, DOE presumed
that the efficiency distributions in the
base case change over time. The
projected share of 1 to 5 horsepower
NEMA Premium motors (EL 2) for
equipment class group 1 grows from
36.6 percent to 45.5 percent over the
analysis period, and for equipment class
group 4, it grows from 30.0 percent to
38.9 percent. For equipment class group
2 and 3, DOE assumed that the
efficiency remains constant from 2015
to 2044.
In the standards cases, equipment
with efficiency below the standard
levels ‘‘roll up’’ to the standard level in
the compliance year. Thereafter, for
equipment class groups 1 and 4, DOE
assumed that the level immediately
above the standard would show a
similar increase in market penetration
as the NEMA Premium motors in the
base case.
The presumed efficiency trends in the
base case and standards cases are
described in chapter 10 of the NOPR
TSD.
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2. National Energy Savings
For each year in the forecast period,
DOE calculates the lifetime national
energy savings for each standard level
by multiplying the shipments of electric
motors affected by the energy
conservation standards by the per-unit
lifetime annual energy savings.
Cumulative energy savings are the sum
of the NES for all motors shipped during
the analysis period, 2015–2044.
DOE estimated energy consumption
and savings based on site energy and
converted the electricity consumption
and savings to primary energy using
annual conversion factors derived from
the AEO 2013 version of the NEMS.
Cumulative energy savings are the sum
of the NES for each year over the
timeframe of the analysis.
DOE has historically presented NES
in terms of primary energy savings. In
response to the recommendations of a
committee on ‘‘Point-of-Use and FullFuel-Cycle Measurement Approaches to
Energy Efficiency Standards’’ appointed
by the National Academy of Science,
DOE announced its intention to use fullfuel-cycle (FFC) measures of energy use
and greenhouse gas and other emissions
in the national impact analyses and
emissions analyses included in future
energy conservation standards
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2011). 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 EIA’s National
Energy Modeling System (NEMS). After
evaluating both models and the
approaches discussed in the August 18,
2011 notice, DOE published a statement
of amended policy in the Federal
Register in which DOE explained its
determination that NEMS is a more
appropriate tool for this specific use. 77
FR 49701 (August 17, 2012). Therefore,
DOE is using NEMS to conduct FFC
analyses. The approach used for today’s
NOPR, and the FFC multipliers that
were applied, are described in appendix
10–C of the TSD.
3. Equipment Price Forecast
As noted in section IV.F.2, DOE
assumed no change in electric motor
prices over the 2015–2044 period. In
addition, DOE conducted a sensitivity
analysis using alternative price trends.
DOE developed one forecast in which
prices decline after 2011, and one in
which prices rise. These price trends,
and the NPV results from the associated
sensitivity cases, are described in
appendix 10–B of the NOPR TSD.
4. Net Present Value of Customer
Benefit
The inputs for determining the NPV
of the total costs and benefits
experienced by consumers of
considered equipment are: (1) Total
annual installed cost; (2) total annual
savings in operating costs; and (3) a
discount factor. DOE calculates the
lifetime net savings for motors shipped
each year as the difference between the
base case and each standards case in
total lifetime savings in lifetime
operating costs and total lifetime
increases in installed costs. DOE
calculates lifetime operating cost
savings over the life of each motor
shipped during the forecast period.
In calculating the NPV, DOE
multiplies the net savings in future
years by a discount factor to determine
their present value. DOE estimates the
NPV using both a 3-percent and a 7percent real discount rate, in accordance
with guidance provided by the Office of
Management and Budget (OMB) to
Federal agencies on the development of
regulatory analysis.78 The discount rates
for the determination of NPV are in
contrast to the discount rates used in the
78 OMB Circular A–4, section E (Sept. 17, 2003).
https://www.whitehouse.gov/omb/circulars_a004_a4.
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LCC analysis, which are designed to
reflect a consumer’s perspective. The 7percent real value is an estimate of the
average before-tax rate of return to
private capital in the U.S. economy. The
3-percent real value represents the
‘‘social rate of time preference,’’ which
is the rate at which society discounts
future consumption flows to their
present value.
I. Consumer Subgroup Analysis
In analyzing the potential impacts of
new or amended standards, DOE
evaluates impacts on identifiable groups
(i.e., subgroups) of customers that may
be disproportionately affected by a
national standard. For the NOPR, DOE
evaluated impacts on various subgroups
using the LCC spreadsheet model.
The customer subgroup analysis is
discussed in detail in chapter 11 of the
TSD.
J. Manufacturer Impact Analysis
1. Overview
DOE conducted an MIA for electric
motors to estimate the financial impact
of proposed new and amended energy
conservation standards on
manufacturers of covered electric
motors. The MIA has both quantitative
and qualitative aspects. The quantitative
part of the MIA primarily relies on the
GRIM, an industry cash flow model
customized for electric motors covered
in this rulemaking. The key GRIM
inputs are data on the industry cost
structure, equipment costs, shipments,
and assumptions about markups and
conversion expenditures. The key MIA
output is INPV. DOE used the GRIM to
calculate cash flows using standard
accounting principles and to compare
changes in INPV between a base case
and various TSLs (the standards case).
The difference in INPV between the
base and standards cases represents the
financial impact of new and amended
standards on manufacturers of covered
electric motors. Different sets of
assumptions (scenarios) produce
different INPV results. The qualitative
part of the MIA addresses factors such
as manufacturing capacity;
characteristics of, and impacts on, any
particular sub-group of manufacturers;
and impacts on competition.
DOE conducted the MIA for this
rulemaking in three phases. In the first
phase DOE prepared an industry
characterization based on the market
and technology assessment, preliminary
manufacturer interviews, and publicly
available information. In the second
phase, DOE estimated industry cash
flows in the GRIM using industry
financial parameters derived in the first
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phase and the shipment scenario used
in the NIA. In the third phase, DOE
conducted structured, detailed
interviews with a variety of
manufacturers that represent more than
75-percent of domestic electric motors
sales covered by this rulemaking.
During these interviews, DOE discussed
engineering, manufacturing,
procurement, and financial topics
specific to each company, and obtained
each manufacturer’s view of the electric
motor industry as a whole. The
interviews provided valuable
information that DOE used to evaluate
the impacts of new and amended
standards on manufacturers’ cash flows,
manufacturing capacities, and
employment levels. See section IV.J.4 of
this NOPR for a description of the key
issues manufacturers raised during the
interviews.
During the third phase, DOE also used
the results of the industry
characterization analysis in the first
phase and feedback from manufacturer
interviews to group manufacturers that
exhibit similar production and cost
structure characteristics. DOE identified
one sub-group for a separate impact
analysis—small business
manufacturers—using the small
business employee threshold published
by the Small Business Administration
(SBA). This threshold includes all
employees in a business’ parent
company and any other subsidiaries.
Based on this classification, DOE
identified 13 electric motor
manufacturers that qualify as small
businesses.
The complete MIA is presented in
chapter 12 of the NOPR TSD.
2. GRIM Analysis and Key Inputs
DOE uses the GRIM to quantify the
changes in cash flow over time due to
a standard. These changes in cash flow
result in either a higher or lower INPV
for the standards case compared to the
base case, the case where a standard is
not set. The GRIM analysis uses a
standard annual cash flow analysis that
incorporates manufacturer costs,
markups, shipments, and industry
financial information as inputs. It then
models changes in costs, investments,
and manufacturer margins that result
from new and amended energy
conservation standards. The GRIM
spreadsheet uses the inputs to calculate
a series of annual cash flows beginning
with the base year of the analysis, 2013,
and continuing to 2044. DOE computes
INPVs by summing the stream of annual
discounted cash flows during this
analysis period. DOE used a real
discount rate of 9.1 percent for electric
motor manufacturers. The discount rate
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estimates were derived from industry
corporate annual reports to the
Securities and Exchange Commission
(SEC 10–Ks) and then modified
according to feedback during
manufacturer interviews. Many inputs
into the GRIM come from the
engineering analysis, the NIA,
manufacturer interviews, and other
research conducted during the MIA. The
major GRIM inputs are described in
detail in the sections below.
a. Product and Capital Conversion Costs
DOE expects new and amended
energy conservation standards to cause
manufacturers to incur one-time
conversion costs to bring their
production facilities and product
designs into compliance with new and
amended standards. For the MIA, DOE
classified these one-time conversion
costs into two major groups: (1) Product
conversion costs and (2) capital
conversion costs. Product conversion
costs are one-time investments in
research, development, testing,
marketing, and other non-capitalized
costs necessary to make product designs
comply with new and amended
standards. Capital conversion costs are
one-time investments in property, plant,
and equipment necessary to adapt or
change existing production facilities
such that new product designs can be
fabricated and assembled.
DOE calculated the product and
capital conversion costs using both a
top-down approach and a bottom-up
approach based on feedback from
manufacturers during manufacturer
interviews and manufacturer submitted
comments. DOE then adjusted these
conversion costs if there were any
discrepancies in the final costs using the
two methods to arrive at a final product
and capital conversion cost estimate for
each representative unit at each EL.
During manufacturer interviews, DOE
asked manufacturers for their estimated
total product and capital conversion
costs needed to produce electric motors
at specific ELs. To arrive at top-down
industry wide product and capital
conversion cost estimates for each
representative unit at each EL, DOE
calculated a market share weighted
average value for product and capital
conversion costs based on the data
submitted during interviews and the
market share of the interviewed
manufacturers.
DOE also calculated bottom-up
conversion costs based on manufacturer
input on the types of costs and the
dollar amounts necessary to convert a
single electric motor frame size to each
EL. Some of the types of capital
conversion costs manufacturers
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identified were the purchase of
lamination die sets, winding machines,
frame casts, and assembly equipment as
well as other retooling costs. The two
main types of product conversion costs
manufacturers shared with DOE during
interviews were number of engineer
hours necessary to re-engineer frames to
meet higher efficiency standards and the
testing and certification costs to comply
with higher efficiency standards. DOE
then took average values (i.e. costs or
number of hours) based on the range of
responses given by manufacturers for
each product and capital conversion
costs necessary for a manufacturer to
increase the efficiency of one frame size
to a specific EL. DOE multiplied the
conversion costs associated with
manufacturing a single frame size at
each EL by the number of frames each
interviewed manufacturer produces.
DOE finally scaled this number based
on the market share of the
manufacturers DOE interviewed, to
arrive at industry wide bottom-up
product and capital conversion cost
estimates for each representative unit at
each EL. The bottom-up conversion
costs estimates DOE created were
consistent with the manufacturer top
down estimates provided, so DOE used
the bottom-up conversion cost estimates
as the final values for each
representative unit in the MIA.
In written comments and during
manufacturer interviews, electric motor
manufacturers stated there would be
very large product and capital
conversion costs associated with ELs
above NEMA Premium, especially for
any ELs that require manufacturers to
switch to die-cast copper rotors.
Manufacturers addressed the difficulties
associated with using copper die-cast
rotors and the uncertainty of a standard
that requires manufacturers to produce
electric motors on a commercial level
for all horsepower ranges using this
technology. NEMA stated that switching
to die-cast copper rotors would cost
each manufacturer approximately $80
million in retooling costs and
approximately $68 million to redesign,
test and certify electric motors at these
ELs. (NEMA, No. 54 at p. 11) NEMA
stated that significant conversion costs
associated with any EL above NEMA
Premium exist even if die-cast copper
rotors are not used. Several
manufacturers during interviews and in
comments stated they would need to
devote significant engineering time to
redesign their entire production line to
comply with ELs that are just one
NEMA band higher than NEMA
Premium. NEMA also stated that testing
and certifying electric motors to ELs
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above NEMA Premium would be a
significant cost to each manufacturer,
since each manufacturer could have
thousands or hundreds of thousands of
unique electric motor specifications
they would need to certify. (NEMA, No.
54 at p. 4) DOE took these submitted
comments into account when
developing the industry product and
capital conversion costs. The final
product and capital conversion cost
estimates were in the range of estimates
submitted by NEMA.
See chapter 12 of the TSD for a
complete description of DOE’s
assumptions for the product and capital
conversion costs.
b. Manufacturer Production Costs
Manufacturing a more efficient
electric motor is typically more
expensive than manufacturing a
baseline product due to the use of more
costly materials and components. The
higher MPCs for these more efficient
equipment can affect the revenue, gross
margin, and cash flows of electric motor
manufacturers.
DOE developed the MPCs for the
representative units at each EL analyzed
in one of two ways: (1) DOE purchased,
tested and then tore down a motor to
create a bill of materials (BOM) for the
motor; and (2) DOE created a BOM
based on a computer software model for
a specific motor that complies with the
associated efficiency level. This second
approach was used when DOE was
unable to find and purchase a motor
that matched the efficiency criteria for
a specific representative unit. Once DOE
created a BOM for a specific motor,
either by tear downs or software
modeling, DOE then estimated the labor
hours and the associated scrap and
overhead costs necessary to produce a
motor with that BOM. DOE was then
able to create an aggregated MPC based
on the material costs from the BOM and
the associated scrap costs, the labor
costs based on an average labor rate and
the labor hours necessary to
manufacture the motor, and the
overhead costs, including depreciation,
based on a markup applied to the
material, labor, and scrap costs based on
the materials used.
DOE created a BOM from tear downs
for 15 of the 21 analyzed representative
unit ELs and applied these BOM data to
create ELs for certain representative
units. The representative unit ELs based
on tear downs include: All five ELs for
the Design B, 5-horsepower
representative unit; the baseline and ELs
1, 2, and 3 for the Design B, 30horsepower and 75-horsepower
representative units; and the baseline
for the Design C, 5-horsepower and 50-
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horsepower representative units. DOE
created a BOM based on a computer
software model for the remaining six
analyzed representative unit ELs: EL 4
for the Design B, 30-horsepower and 75horsepower representative units; and
ELs 1 and 2 for the Design C, 5horsepower and 50-horsepower
representative units.
Due to the very large product and
capital conversion costs manufacturers
would face if standards forced
manufacturers to produce motors above
NEMA Premium ELs, DOE decided to
include the product and capital
conversion costs as a portion of the
MPCs for all ELs above NEMA
Premium. DOE applied a per unit adder,
which was a flat percentage of the MPC
at NEMA Premium, for all MPCs above
NEMA Premium. For a complete
description of MPCs and the inclusion
of manufacturer conversion costs into
the MPC see the engineering analysis
discussion in section IV.C of this NOPR.
c. Shipment Forecast
INPV, the key GRIM output, depends
on industry revenue, which in turn,
depends on the quantity and prices of
electric motors shipped in each year of
the analysis period. Industry revenue
calculations require forecasts of: (1)
Total annual shipment volume; (2) the
distribution of shipments across
analyzed representative units (because
prices vary by representative unit); and,
(3) the distribution of shipments across
efficiencies (because prices vary with
efficiency).
In the NIA, DOE estimated the total
number of electric motor shipments by
year for the analysis period. The NIA
projects electric motor shipments to
generally increase over time. This is
consistent with the estimates
manufacturers revealed to DOE during
manufacturer interviews. The NIA then
estimated the percentage of shipments
assigned to each ECG. DOE further
estimated the percentage of shipments
by horsepower rating, pole
configuration, and enclosure type
within each ECG. For the NIA, the
shipment distribution across ECG and
the shipment distribution across
horsepower rating, pole configuration,
and enclosure type do not change on a
percentage basis over time. Nor does the
shipment distribution across ECGs or
across horsepower rating, pole
configuration, and enclosure type
change on a percentage basis due to an
energy conservation standard (e.g. the
number of shipments of Design C, 1
horsepower, 4 pole, open motor are the
same in the base case as in the standards
case). Finally, the NIA estimated a
distribution of shipments across ELs (an
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efficiency distribution), for each
horsepower range within each ECG. As
described in further detail below, the
efficiency distributions for ECG 1 and
ECG 4 motors become more energy
efficient over time in the base case,
while the efficiency distributions for
ECG 2 and ECG 3 do not change on a
percentage basis over time (i.e., for ECG
2 and ECG 3 motors, the efficiency
distributions at the beginning of the
analysis period are the same as the
efficiency distributions at the end of the
analysis period). DOE also assumed the
total volume of shipments does not
decrease due to energy conservation
standards, so total shipments are the
same in the base case as in the standards
case.
For the NIA, DOE modeled a ‘‘shift’’
shipment scenario for ECG 1 and ECG
4 motors and a ‘‘roll-up’’ shipment
scenario for ECG 2 and ECG 3 motors.
In the standards case of the ‘‘shift’’
shipment scenario, shipments continue
to become more efficient after a
standard is set—in this case,
immediately after the standards go into
effect, all shipments below the selected
TSL are brought up to meet that TSL.
However, motors at or above the
selected TSL migrate to even higher
efficiency levels and continue to do so
over time. In contrast, in the standards
case of the ‘‘roll-up’’ shipment scenario,
when a TSL is selected to become the
new energy conservation standard, all
shipments that fall below that selected
TSL roll-up to the selected TSL.
Therefore, the shipments that are at or
above the selected TSL remain
unchanged in the standards case of the
‘‘roll-up’’ shipment scenario compared
to the base case. For the ‘‘roll-up’’
shipment scenario, the only difference
in the efficiency distribution between
the standards case and the base case is
that in the standards case all shipments
falling below the selected TSL in the
base case are now at the selected TSL
in the standards case.
While the shipments from the NIA are
broken out into a total number of motor
shipments for each ECG, horsepower
rating, pole configuration, and enclosure
type, the MIA consolidates the number
of motor shipments into the
representative units for each ECG. For
example, the Design B, 5-horsepower, 4pole, enclosed motor was the
representative unit for all Design A and
B motors between 1 and 10-horsepower
regardless of the number of poles or
enclosure type. So in the MIA DOE
treated all ECG 1 (Design A and B)
motor shipments between 1 and 10horsepower as shipments of the Design
B, 5-horsepower representative unit; all
ECG 1 motor shipments between 15-
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and 50-horsepower as shipments of the
Design B, 30-horsepower representative
unit; and all ECG 1 motor shipments
between 60- and 500-horsepower as
shipments of the Design B, 75horsepower representative unit. For
ECG 2 (Design C) motors, ECG 3 (fire
pump) motors, and ECG 4 (brake)
motors the MIA consolidated shipments
in a similar manner, treating all
shipments in the representative units’
horsepower range as shipments of that
representative unit.
See the shipment analysis, chapter 9,
of this NOPR TSD for additional details.
d. Markup Scenarios
As discussed in the MPC section
above, the MPCs for the representative
units are the factory costs of electric
motor manufacturers; these costs
include material, direct labor, overhead,
depreciation, and any extraordinary
conversion cost recovery. The MSP is
the price received by electric motor
manufacturers from their direct
customer, typically either an OEM or a
distributor. The MSP is not the cost the
end-user pays for the electric motor
since there are typically multiple sales
along the distribution chain and various
markups applied to each sale. The MSP
equals the MPC multiplied by the
manufacturer markup. The
manufacturer markup covers all the
electric motor manufacturer’s nonproduction costs (i.e., selling, general
and administrative expenses (SG&A),
normal R&D, and interest, etc.) and
profit. Total industry revenue for
electric motor manufacturers equals the
MSPs at each EL for each representative
unit multiplied by the number of
shipments at that EL.
Modifying these manufacturer
markups in the standards case yields a
different set of impacts on
manufacturers than in the base case. For
the MIA, DOE modeled three standards
case markup scenarios to represent the
uncertainty regarding the potential
impacts on prices and profitability for
manufacturers following the
implementation of new and amended
energy conservation standards: (1) A flat
markup scenario, (2) a preservation of
operating profit scenario, and (3) a twotiered markup scenario. These scenarios
lead to different markup values, which,
when applied to the inputted MPCs,
result in varying revenue and cash flow
impacts on manufacturers.
The flat markup scenario assumed
that the cost of goods sold for each
product is marked up by a flat
percentage to cover SG&A expenses,
R&D expenses, interest expenses, and
profit. There were two values used for
the flat markup, a 1.37 markup for high
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volume representative units and a 1.45
markup for low volume representative
units. The 1.37 markup was used for the
Design B, 5-horsepower representative
unit; the Design C, 5-horsepower
representative unit; the fire pump, 5horsepower representative unit; and the
brake, 5-horsepower representative unit.
The 1.45 markup is used for the Design
B, 30-horsepower and 75-horsepower
representative units; the Design C, 50
horsepower representative unit; the fire
pump, 30-horsepower and 75horsepower representative units; and
the brake, 30-horsepower and 75horsepower representative units. This
scenario represents the upper bound of
industry profitability in the standards
case because manufacturers are able to
fully pass through additional costs due
to standards to their customers. To
derive the flat markup percentages, DOE
examined the SEC 10-Ks of publicly
traded electric motor manufacturers to
estimate the industry average gross
margin percentage. DOE then used that
estimate along with the flat
manufacturer markups used in the small
electric motors rulemaking at 75 FR
10874 (March 9, 2010), since several of
the small electric motor manufacturers
are also manufacturers of electric motors
covered in this rulemaking, to create a
final estimate of the flat markups used
for electric motors covered in this
rulemaking.
DOE included an alternative markup
scenario, the preservation of operating
profit markup, because manufacturers
stated that they do not expect to be able
to markup the full cost of production
given the highly competitive market, in
the standards case. The preservation of
operating profit markup scenario
assumes that manufacturers are able to
maintain only the base case total
operating profit in absolute dollars in
the standards case, despite higher
product costs and investment. The base
case total operating profit is derived
from marking up the cost of goods sold
for each product by the flat markup
described above. In the standards case
for the preservation of operating profit
markup scenario, DOE adjusted the
manufacturer markups in the GRIM at
each TSL to yield approximately the
same earnings before interest and taxes
in the standards case in the year after
the compliance date of the new and
amended standards as in the base case.
Under this scenario, while
manufacturers are not able to yield
additional operating profit from higher
production costs and the investments
that are required to comply with new
and amended energy conservation
standards, they are able to maintain the
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same operating profit in the standards
case that was earned in the base case.
DOE modeled a third profitability
scenario, a two-tiered markup scenario.
During interviews, several
manufacturers stated they offer two tiers
of motor lines that are differentiated, in
part, by efficiency level. For example,
several manufacturers offer Design B
motors that meet, and in some cases
exceed, NEMA Premium levels. Motors
that exceed these levels typically
command higher prices over NEMA
Premium level motors at identical
horsepower levels. These manufacturers
suggested that the premium currently
earned by the higher efficiency tiers
would erode as new and amended
standards are set at higher efficiency
levels, which would harm profitability.
To model this effect, DOE used
information from manufacturers to
estimate the higher and lower markups
for electric motors under a two-tier
pricing strategy in the base case. In the
standards case, DOE modeled the
situation in which product efficiencies
offered by a manufacturer are altered
due to standards. This change reduces
the markup of higher efficiency
equipment as they become the new
baseline caused by the energy
conservation standard. The change in
markup is based on manufacturer
statements made during interviews and
on DOE’s understanding of industry
pricing.
The preservation of operating profit
and two-tiered markup scenarios
represent the lower bound of industry
profitability in the standards case
because manufacturers are not able to
fully pass through the additional costs
due to standards, as manufacturers are
able to do in the flat markup scenario.
Therefore, manufacturers earn less
revenue in the preservation of operating
profit and two-tiered markup scenarios
than they do in the flat markup
scenario.
3. Discussion of Comments
During the August 2012 preliminary
analysis public meeting, interested
parties commented on the assumptions
and results of the preliminary analysis
TSD. Oral and written comments
addressed several topics, including the
scope of coverage, conversion costs,
enforcement of standards, and the
potential increase in the motor
refurbishment market. DOE addresses
these comments below.
a. Scope of Coverage
SEW-Eurodrive expressed concern
about establishing energy conservation
standards for integral gearmotors. SEWEurodrive stated that manufacturers
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would have to review and ensure the
compatibility between the motor and
the gearbox for all new integral
gearmotor designs. Setting standards for
these motors, in its view, may cause
manufacturers to review potentially
millions of motor-gear box
combinations. SEW-Eurodrive also
stated that since integral gearmotors
comprise a system whose overall
efficiency is limited by the low
efficiency of the mating gearing, an
increase in the efficiency of the motor
alone would have a very small effect on
the overall system efficiency. (SEWEurodrive, No. 53 at p. 3) DOE believes
that these integral gearmotors can be
tested by removing the gearbox and
simply testing the partial motor in
accordance with the partial motor test
procedure proposed at 78 FR 38455
(June 26, 2013). This approach would
allow integral gearmotor motor
manufacturers to test and certify the
electric motors and not every
combination of electric motor and
gearbox.
b. Conversion Costs
NEMA made a few comments
regarding the potential difficulties and
costs associated with increasing energy
conservation standards to efficiency
levels above NEMA Premium. First,
NEMA stated that DOE should consider
the current difficulties that
manufacturers from IEC countries are
having when meeting the efficiency
levels under NEMA MG 1 Table 12–12.
NEMA stated these manufacturers
already face difficulties due to the limits
of an electric motor frame size and stack
length, as these limits pose physical
constraints to higher efficiency levels.
Moreover, such limits to IEC frame size
and stack length are comparable to what
manufacturers of NEMA frame motors
would face if required efficiency levels
were increased above current NEMA
Premium efficiency levels. (NEMA, No.
54 at p. 84) NEMA did not provide any
cost data, in engineering time or dollars,
that these manufacturers were faced
with regarding their compliance with
NEMA MG 1 Table 12–12 efficiency
levels.
NEMA went on to give estimates for
the conversion costs associated with
manufacturers producing motors above
NEMA Premium efficiency levels.
NEMA stated that it would cost each
manufacturer approximately $80
million in retooling and $68 million in
reengineering, testing and prototyping
to switch from currently used materials
to die-cast copper rotor production.
NEMA also stated there are other costs
not directly related to the die-casting
process manufacturers would incur, if
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standards required copper rotor
technology. For example, NEMA noted
that there are additional costs associated
with redesigning the rotor and stator to
maintain compliance with NEMA MG 1
performance requirements. NEMA also
provided DOE with a few of the major
costs placed on the manufacturers if
energy conservation standards exceeded
NEMA Premium efficiency levels.
NEMA said manufacturers would incur
significant costs due to retooling slot
insulators, automatic winding
machines, and progressive lamination
stamping dies—the last of which can
cost between $500,000 and $750,000 per
set. Manufacturers would also need to
reengineer potentially 100,000 to
200,000 specifications per manufacturer
to comply with standards above NEMA
Premium levels. (NEMA, No. 54 at p.
11)
DOE took these difficulties and costs
that could be placed on manufacturers
into consideration when creating the
conversion costs of standards above
NEMA Premium efficiency levels. DOE
also recognizes the magnitude of the
conversion costs on the industry at
efficiency levels above NEMA Premium
and this was one of the main reasons
DOE included a portion of the
conversion costs in the MPC for
efficiency levels above NEMA Premium.
DOE believes it is likely that motor
manufacturers would attempt to recover
these large one-time extraordinary
conversion costs at standards above
NEMA Premium through a variable cost
increase in the MPCs of electric motors
sold by manufacturers.
c. Enforcement of Standards
NEMA stated that large domestic
manufacturers could be adversely
impacted by higher energy conservation
standards if DOE does not strictly
enforce those new and amended
standards, especially on imported
machinery with embedded motors.
NEMA commented that domestic
manufacturers are currently competing
with imported goods containing electric
motors that are below current motor
standards. This practice puts compliant
motor manufacturers at a disadvantage
because the machinery containing a
non-compliant motor is often sold at a
lower cost than machinery with a
compliant motor. (NEMA, No. 54 at p.
11) DOE recognizes the need to enforce
any energy conservation standard
established for motors manufactured
alone or as a component of another
piece of equipment to ensure that all
manufacturers are operating on a level
playing field and to realize the actual
reduction in energy consumption from
these standards.
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d. Motor Refurbishment
NEMA commented that if electric
motors had to be redesigned to achieve
higher energy conservation standards
potential new motor customers may be
forced to rewind older, less efficient
motors because the longer or larger
frame sizes that could be required to
satisfy more stringent efficiency
standards might not fit as drop-in
replacements for existing equipment.
(NEMA, No. 54 at p. 10) DOE agrees that
adopting higher energy conservation
standards for electric motors may force
motor manufacturers to increase the
length and/or the diameter of the frame.
Such increase in motor frame size may
cause some machinery using electric
motors to be incompatible with previous
electric motor designs. DOE requested
comment on the quantitative impacts
this could have on the electric motor
and OEM markets but did not receive
any quantitative responses regarding
this issue. DOE is aware this could be
a possible issue at the ELs above NEMA
Premium, but does not consider this to
be an issue at ELs that meet or are below
NEMA Premium, since the majority of
the electric motors used in existing
equipment should already be at NEMA
Premium efficiency levels. Therefore,
based on data available at this time,
DOE does not believe that motor
refurbishment is likely to act as a barrier
to the efficiency levels proposed in
today’s NOPR.
4. Manufacturer Interviews
DOE conducted additional interviews
with manufacturers following the
preliminary analysis in preparation for
the NOPR analysis. In these interviews,
DOE asked manufacturers to describe
their major concerns with this
rulemaking. The following section
describes the key issues identified by
manufacturers during these interviews.
a. Efficiency Levels above NEMA
Premium
During these interviews, several
manufacturers were concerned with the
difficulties associated with increasing
motor efficiency levels above NEMA
Premium. Manufacturers stated that
even increasing the efficiency of motors
to one band above NEMA Premium
would require each manufacturer to
make a significant capital investment to
retool their entire production line. It
would also require manufacturers to
completely redesign almost every motor
configuration offered, which could take
several years of engineering time.
According to manufacturers, another
potential problem with setting standards
above NEMA Premium is that this
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would misalign U.S. electric motor
standards with global motor standards
(e.g., IEC motor standards). They noted
that over the past few decades, there has
been an effort to harmonize global motor
standards that setting new U.S. electric
motor standards at a level exceeding the
NEMA Premium level would cause U.S.
electric motor markets to be out of
synchronization with the rest of the
world’s efficiency standards.
Several manufacturers also
commented they believe any standard
requiring die-casting copper rotors is
infeasible. One main concern
manufacturers have regarding copper is
that not only has the price of copper
significantly increased over the past
several years, there has been
tremendous volatility in the price as
well. Manufacturers worry that if
standards required manufacturers to use
copper rotors, they would be subject to
this volatile copper market.
Manufacturers also noted that motor
efficiency standards requiring copper
rotors for all electric motors would
likely increase the price of copper due
to the increase in demand from the
motors industry.
Another key concern that
manufacturers have regarding standards
that require using copper rotors is that
copper has a much higher melting
temperature than aluminum, and the
pressure required to die-cast copper is
much higher than aluminum. They
contend that there is a much greater
chance that a significant accident or
injury to their employees could occur if
manufacturers were required to produce
copper rotors rather than aluminum
rotors.
Lastly, several manufacturers stated
they would not be able to produce
copper die-cast rotors in-house and
would have to outsource this
production. Manufacturers stated that if
the entire motor industry had to
outsource their rotor production as a
result of standards that required the use
of die-cast copper rotors, there would be
significant supply chain problems in the
motor manufacturing process.
Manufacturers emphasized during
interviews that the capacity to produce
copper rotors on a large commercial
scale does not exist and would be very
difficult to implement in even a threeyear time period.
Overall, manufacturers are very
concerned if any electric motor standard
required motor efficiency levels beyond
NEMA Premium, especially if those
efficiency levels required the use of
copper rotor technology. According to
manufacturers, efficiency levels beyond
NEMA Premium would require a
significant level of investment from all
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electric motor manufacturers and would
cause the U.S. to be out of sync with the
electric motor standards around the
world. If standards required the use of
copper rotors, manufacturers would
experience further difficulties due to the
potential increase in copper prices and
the volatility of the copper market, as
well as the potential safety concerns
regarding the higher melting
temperature of copper than aluminum.
b. Increase in Equipment Repairs
Manufacturers have stated that as
energy conservation standards increase
customers are more likely to rewind old,
less efficient motors, as opposed to
purchasing newer more efficient and
compliant motors. Therefore, if motor
standards significantly increase the
price of motors, manufacturers believe
rewinding older motors might become a
more attractive option for some
customers. These customers would in
turn be using more energy than if they
simply purchased a currently compliant
motor, since rewound motors typically
do not operate at their original
efficiency level after being rewound.
Manufacturers believe that DOE must
take the potential consumer rewinding
decision into account when deciding on
an electric motors standard.
c. Enforcement
Manufacturers have stated that one of
their biggest concerns with additional
energy conservation standards is the
lack of enforcement of current electric
motor standards. In general, domestic
manufacturers have stated they comply
with the current electric motor
regulations and will continue to comply
with any future standards. However,
these manufacturers believe that there
are several foreign motor manufacturers
that do not comply with the current
electric motor regulations and will not
comply with any future standards if the
efficiency standards are increased. This
would cause compliant manufacturers
to be placed at a competitive
disadvantage, since complying with any
increased efficiency standards will be
very costly. Some domestic
manufacturers believe the most cost
effective way to reduce energy
consumption of electric motors is to
more strictly enforce the existing
electric motor standards rather than
increase the efficiency standards of
electric motors.
K. Emissions Analysis
In the emissions analysis, DOE
estimated the reduction in power sector
emissions of carbon dioxide (CO2),
nitrogen oxides (NOX), sulfur dioxide
(SO2), and mercury (Hg) from potential
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energy conservation standards for
electric motors. In addition, DOE
estimates 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 full-fuel-cycle
(FFC). In accordance with DOE’s FFC
Statement of Policy (76 FR 51282
(August 18, 2011) as amended at 77 FR
49701 (August 17, 2012)), the FFC
analysis includes impacts on emissions
of methane (CH4) and nitrous oxide
(N2O, both of which are recognized as
greenhouse gases.
DOE conducted the emissions
analysis using emissions factors that
were derived from data in the Energy
Information Agency’s (EIA’s) Annual
Energy Outlook 2013 (AEO 2013),
supplemented by data from other
sources. DOE developed separate
emissions factors for power sector
emissions and upstream emissions. The
method that DOE used to derive
emissions factors is described in chapter
13 of the NOPR TSD.
EIA prepares the Annual Energy
Outlook using the National Energy
Modeling System (NEMS). Each annual
version of NEMS incorporates the
projected impacts of existing air quality
regulations on emissions. AEO 2013
generally represents current legislation
and environmental regulations,
including recent government actions, for
which implementing regulations were
available as of December 31, 2012.
SO2 emissions from affected electric
generating units (EGUs) are subject to
nationwide and regional emissions capand-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 (DC). SO2 emissions from 28
eastern states and DC 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). On August 21,
2012, the DC 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.
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21, 2012). The court ordered EPA to
continue administering CAIR. The AEO
2013 emissions factors used for today’s
NOPR assumes that CAIR remains a
binding regulation through 2040.
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. 77 FR 9304
(Feb. 16, 2012). In the final MATS rule,
EPA established a standard for hydrogen
chloride as a surrogate for acid gas
hazardous air pollutants (HAP), and also
established a standard for SO2 (a nonHAP 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 2013 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 established by CAIR, 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.
CAIR established a cap on NOX
emissions in 28 eastern States and the
District of Columbia. Energy
conservation standards are expected to
have little effect on NOX emissions in
those States covered by CAIR because
excess NOX emissions allowances
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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 the caps, so DOE
estimated NOX emissions reductions
from the standards considered in
today’s NOPR 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. DOE
estimated mercury emissions reduction
using emissions factors based on AEO
2013, which incorporates the MATS.
NEMA commented that DOE should
consider emissions related to all aspects
involved in the production of higher
efficiency motors. (NEMA, No. 54 at p.
31) In response, DOE notes that EPCA
directs DOE to consider the total
projected amount of energy, or as
applicable, water, savings likely to
result directly from the imposition of
the standard when determining whether
a standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i)(III) and 6316(a))
DOE interprets this to include energy
used in the generation, transmission,
and distribution of fuels used by
appliances or equipment. In addition,
DOE is using the full-fuel-cycle
measure, which includes the energy
consumed in extracting, processing, and
transporting primary fuels. DOE’s
current accounting of primary energy
savings and the full-fuel-cycle measure
are directly linked to the energy used by
appliances or equipment. DOE believes
that energy used in manufacturing of
appliances or equipment falls outside
the boundaries of ‘‘directly’’ as intended
by EPCA. Thus, DOE did not consider
such energy use and air emissions in the
NIA or in the emissions analysis.
L. Monetizing Carbon Dioxide and Other
Emissions Impacts
As part of the development of this
proposed rule, DOE considered the
estimated monetary benefits from the
reduced emissions of CO2 and NOX that
are expected to result from each of the
TSLs considered. In order to make this
calculation similar to the calculation of
the NPV of consumer benefit, DOE
considered the reduced emissions
expected to result over the lifetime of
equipment shipped in the forecast
period for each TSL. This section
summarizes the basis for the monetary
values used for each of these emissions
and presents the values considered in
this rulemaking.
For today’s NOPR, DOE is relying on
a set of values for the social cost of
carbon (SCC) that was developed by an
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interagency process. A summary of the
basis for these values is provided below,
and a more detailed description of the
methodologies used is provided as an
appendix to chapter 14 of the NOPR
TSD.
1. Social Cost of Carbon
The SCC is an estimate of the
monetized damages associated with an
incremental increase in carbon
emissions in a given year. It is intended
to include (but is not limited to) changes
in net agricultural productivity, human
health, property damages from
increased flood risk, and the value of
ecosystem services. Estimates of the
SCC are provided in dollars per metric
ton of carbon dioxide. A domestic SCC
value is meant to reflect the value of
damages in the United States resulting
from a unit change in carbon dioxide
emissions, while a global SCC value is
meant to reflect the value of damages
worldwide.
Under section 1(b)(6) of Executive
Order 12866, ‘‘Regulatory Planning and
Review,’’ 58 FR 51735 (Oct. 4, 1993),
agencies must, to the extent permitted
by law, assess both the costs and the
benefits of the intended regulation and,
recognizing that some costs and benefits
are difficult to quantify, propose or
adopt a regulation only upon a reasoned
determination that the benefits of the
intended regulation justify its costs. The
purpose of the SCC estimates presented
here is to allow agencies to incorporate
the monetized social benefits of
reducing CO2 emissions into costbenefit analyses of regulatory actions
that have small, or ‘‘marginal,’’ impacts
on cumulative global emissions. The
estimates are presented with an
acknowledgement of the many
uncertainties involved and with a clear
understanding that they should be
updated over time to reflect increasing
knowledge of the science and
economics of climate impacts.
As part of the interagency process that
developed the SCC estimates, technical
experts from numerous agencies met on
a regular basis to consider public
comments, explore the technical
literature in relevant fields, and discuss
key model inputs and assumptions. The
main objective of this process was to
develop a range of SCC values using a
defensible set of input assumptions
grounded in the existing scientific and
economic literatures. In this way, key
uncertainties and model differences
transparently and consistently inform
the range of SCC estimates used in the
rulemaking process.
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a. Monetizing Carbon Dioxide Emissions
When attempting to assess the
incremental economic impacts of carbon
dioxide emissions, the analyst faces a
number of serious challenges. A recent
report from the National Research
Council points out that any assessment
will suffer from uncertainty,
speculation, and lack of information
about: (1) Future emissions of
greenhouse gases; (2) the effects of past
and future emissions on the climate
system; (3) the impact of changes in
climate on the physical and biological
environment; and (4) the translation of
these environmental impacts into
economic damages. As a result, any
effort to quantify and monetize the
harms associated with climate change
will raise serious questions of science,
economics, and ethics and should be
viewed as provisional.
Despite the serious limits of both
quantification and monetization, SCC
estimates can be useful in estimating the
social benefits of reducing carbon
dioxide emissions. Most Federal
regulatory actions can be expected to
have marginal impacts on global
emissions. For such policies, the agency
can estimate the benefits from reduced
emissions in any future year by
multiplying the change in emissions in
that year by the SCC value appropriate
for that year. The net present value of
the benefits can then be calculated by
multiplying the future benefits by an
appropriate discount factor and
summing across all affected years. This
approach assumes that the marginal
damages from increased emissions are
constant for small departures from the
baseline emissions path, an
approximation that is reasonable for
policies that have effects on emissions
that are small relative to cumulative
global carbon dioxide emissions. For
policies that have a large (non-marginal)
impact on global cumulative emissions,
there is a separate question of whether
the SCC is an appropriate tool for
calculating the benefits of reduced
emissions. This concern is not
applicable to this rulemaking, however.
It is important to emphasize that the
interagency process is committed to
updating these estimates as the science
and economic understanding of climate
change and its impacts on society
improves over time. In the meantime,
the interagency group will continue to
explore the issues raised by this analysis
and consider public comments as part of
the ongoing interagency process.
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b. Social Cost of Carbon Values Used in
Past Regulatory Analyses
Economic analyses for Federal
regulations have used a wide range of
values to estimate the benefits
associated with reducing carbon dioxide
emissions. In the final model year 2011
CAFE rule, the U.S. Department of
Transportation (DOT) used both a
‘‘domestic’’ SCC value of $2 per metric
ton of CO2 and a ‘‘global’’ SCC value of
$33 per metric ton of CO2 for 2007
emission reductions (in 2007$),
increasing both values at 2.4 percent per
year. DOT also included a sensitivity
analysis at $80 per metric ton of CO2.79
A 2008 regulation proposed by DOT
assumed a domestic SCC value of $7 per
metric ton of CO2 (in 2006$) for 2011
emission reductions (with a range of $0–
$14 for sensitivity analysis), also
increasing at 2.4 percent per year.80 A
regulation for packaged terminal air
conditioners and packaged terminal
heat pumps finalized by DOE in October
of 2008 used a domestic SCC range of
$0 to $20 per metric ton CO2 for 2007
emission reductions (in 2007$). 73 FR
58772, 58814 (Oct. 7, 2008). In addition,
EPA’s 2008 Advance Notice of Proposed
Rulemaking on Regulating Greenhouse
Gas Emissions Under the Clean Air Act
identified what it described as ‘‘very
preliminary’’ SCC estimates subject to
revision. 73 FR 44354 (July 30, 2008).
EPA’s global mean values were $68 and
$40 per metric ton CO2 for discount
rates of approximately 2 percent and 3
percent, respectively (in 2006$ for 2007
emissions).
In 2009, an interagency process was
initiated to offer a preliminary
assessment of how best to quantify the
benefits from reducing carbon dioxide
emissions. To ensure consistency in
how benefits are evaluated across
agencies, the Administration sought to
develop a transparent and defensible
method, specifically designed for the
rulemaking process, to quantify avoided
climate change damages from reduced
CO2 emissions. The interagency group
did not undertake any original analysis.
79 See Average Fuel Economy Standards
Passenger Cars and Light Trucks Model Year 2011,
74 FR 14196 (March 30, 2009) (Final Rule); Final
Environmental Impact Statement Corporate Average
Fuel Economy Standards, Passenger Cars and Light
Trucks, Model Years 2011–2015 at 3–90 (Oct. 2008)
(Available at: https://www.nhtsa.gov/fuel-economy)
(Last accessed December 2012).
80 See Average Fuel Economy Standards,
Passenger Cars and Light Trucks, Model Years
2011–2015, 73 FR 24352 (May 2, 2008) (Proposed
Rule); Draft Environmental Impact Statement
Corporate Average Fuel Economy Standards,
Passenger Cars and Light Trucks, Model Years
2011–2015 at 3–58 (June 2008) (Available at: https://
www.nhtsa.gov/fuel-economy) (Last accessed
December 2012).
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Instead, it combined SCC estimates from
the existing literature to use as interim
values until a more comprehensive
analysis could be conducted. The
outcome of the preliminary assessment
by the interagency group was a set of
five interim values: Global SCC
estimates for 2007 (in 2006$) of $55,
$33, $19, $10, and $5 per metric ton of
CO2. These interim values represented
the first sustained interagency effort
within the U.S. government to develop
an SCC for use in regulatory analysis.
The results of this preliminary effort
were presented in several proposed and
final rules.
c. Current Approach and Key
Assumptions
Since the release of the interim
values, the interagency group
reconvened on a regular basis to
generate improved SCC estimates.
Specifically, the group considered
public comments and further explored
the technical literature in relevant
fields. The interagency group relied on
three integrated assessment models
commonly used to estimate the SCC:
The FUND, DICE, and PAGE models.
These models are frequently cited in the
peer-reviewed literature and were used
in the last assessment of the
Intergovernmental Panel on Climate
Change. Each model was given equal
weight in the SCC values that were
developed.
Each model takes a slightly different
approach to model how changes in
emissions result in changes in economic
damages. A key objective of the
interagency process was to enable a
consistent exploration of the three
models while respecting the different
approaches to quantifying damages
taken by the key modelers in the field.
An extensive review of the literature
was conducted to select three sets of
input parameters for these models:
climate sensitivity, socio-economic and
emissions trajectories, and discount
rates. A probability distribution for
climate sensitivity was specified as an
input into all three models. In addition,
the interagency group used a range of
scenarios for the socio-economic
parameters and a range of values for the
discount rate. All other model features
were left unchanged, relying on the
model developers’ best estimates and
judgments.
In 2010, the interagency group
selected four sets of SCC values for use
in regulatory analyses.81 Three sets of
81 Social Cost of Carbon for Regulatory Impact
Analysis Under Executive Order 12866. Interagency
Working Group on Social Cost of Carbon, United
States Government, February 2010. https://
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values are based on the average SCC
from three integrated assessment
models, at discount rates of 2.5 percent,
3 percent, and 5 percent. The fourth set,
which represents the 95th-percentile
SCC estimate across all three models at
a 3-percent discount rate, is included to
represent higher-than-expected impacts
given to consideration of the global
benefits of reducing CO2 emissions.
Table IV.26 presents the values in the
2010 interagency group report, which is
reproduced in appendix 14–A of the
NOPR TSD.
from climate change further out in the
tails of the SCC distribution. The 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 preference is
TABLE IV.26—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050
[In 2007 dollars per metric ton CO2]
Discount rate %
Year
3
2.5
3
Average
2010
2015
2020
2025
2030
2035
2040
2045
2050
5
Average
Average
95th Percentile
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
4.7
5.7
6.8
8.2
9.7
11.2
12.7
14.2
15.7
21.4
23.8
26.3
29.6
32.8
36.0
39.2
42.1
44.9
64.9
72.8
80.7
90.4
100.0
109.7
119.3
127.8
136.2
SCC across models at 3-percent discount
rate. However, for purposes of capturing
the uncertainties involved in regulatory
impact analysis, the interagency group
emphasizes the importance of including
all four sets of SCC values.
updated sets of SCC estimates from the
2013 interagency update in five-year
increments from 2010 to 2050.
Appendix 14A of the NOPR TSD
provides the full set of values. The
central value that emerges is the average
The SCC values used for today’s
notice were generated using the most
recent versions of the three integrated
assessment models that have been
published in the peer-reviewed
literature.82 Table IV.27shows the
35.1
38.4
41.7
45.9
50.0
54.2
58.4
61.7
65.0
TABLE IV.27—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050
[In 2007 dollars per metric ton CO2]
Discount rate %
Year
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3
2.5
3
Average
2010
2015
2020
2025
2030
2035
2040
2045
2050
5
Average
Average
95th Percentile
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
11
11
12
14
16
19
21
24
26
32
37
43
47
52
56
61
66
71
51
57
64
69
75
80
86
92
97
89
109
128
143
159
175
191
206
220
It is important to recognize that a
number of key uncertainties remain, and
that current SCC estimates should be
treated as provisional and revisable
since they will evolve with improved
scientific and economic understanding.
The interagency group also recognizes
that the existing models are imperfect
and incomplete. The National Research
Council report mentioned above points
out that there is tension between the
goal of producing quantified estimates
of the economic damages from an
incremental ton of carbon and the limits
of existing efforts to model these effects.
There are a number of concerns and
problems that should be addressed by
the research community, including
research programs housed in many of
the Federal agencies participating in the
interagency process to estimate the SCC.
The interagency group intends to
periodically review and reconsider
those estimates to reflect increasing
knowledge of the science and
economics of climate impacts, as well as
improvements in modeling.
In summary, in considering the
potential global benefits resulting from
reduced CO2 emissions resulting from
today’s rule, DOE used the values from
the 2013 interagency report, adjusted to
2012$ using the Gross Domestic Product
www.whitehouse.gov/sites/default/files/omb/
inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf.
82 Technical Update of the Social Cost of Carbon
for Regulatory Impact Analysis Under Executive
Order 12866. Interagency Working Group on Social
Cost of Carbon, United States Government. May
2013; revised November 2013.https://
www.whitehouse.gov/sites/default/files/omb/assets/
inforeg/technical-update-social-cost-of-carbon-forregulator-impact-analysis.pdf.
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price deflator. For each of the four cases
specified, the values used for emissions
in 2015 were $11.8, $39.7, $61.2, and
$117 per metric ton avoided (values
expressed in 2012$). DOE derived
values after 2050 using the relevant
growth rate for the 2040–2050 period in
the interagency update.
DOE multiplied the CO2 emissions
reduction estimated for each year by the
SCC value for that year in each of the
four cases. To calculate a present value
of the stream of monetary values, DOE
discounted the values in each of the
four cases using the specific discount
rate that had been used to obtain the
SCC values in each case.
NEMS,85 which is a public domain,
multi-sectored, partial equilibrium
model of the U.S. energy sector. DOE
uses a variant of this model, referred to
as NEMS–BT,86 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.
The energy savings inputs associated
with each TSL come from the NIA.
Chapter 15 of the NOPR TSD describes
the utility impact analysis in further
detail.
2. Valuation of Other Emissions
Reductions
N. Employment Impact Analysis
Employment impacts from new or
amended energy conservation standards
include direct and indirect impacts.
Direct employment impacts are any
changes in the number of employees of
manufacturers of the equipment subject
to standards; the MIA addresses those
impacts. Indirect employment impacts
are changes in national employment
that occur due to the shift in
expenditures and capital investment
caused by the purchase and operation of
more efficient equipment. Indirect
employment impacts from standards
consist of the jobs created or eliminated
in the national economy, other than in
the manufacturing sector being
regulated, due to: (1) Reduced spending
by end users on energy; (2) reduced
spending on new energy supply by the
utility industry; (3) increased consumer
spending on the purchase of new
equipment; and (4) the effects of those
three factors throughout the economy.
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). 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
DOE investigated the potential
monetary benefit of reduced NOX
emissions from the TSLs it considered.
As noted above, DOE has taken into
account how new or amended energy
conservation standards would reduce
NOX emissions in those 22 states not
affected by the CAIR. DOE estimated the
monetized value of NOX emissions
reductions resulting from each of the
TSLs considered for today’s NOPR
based on estimates found in the relevant
scientific literature. Available estimates
suggest a very wide range of monetary
values per ton of NOX from stationary
sources, ranging from $468 to $4,809 per
ton in 2012$).83 In accordance with
OMB guidance,84 DOE calculated a
range of monetary benefits using each of
the economic values for NOX and real
discount rates of 3-percent and 7percent.
DOE is evaluating appropriate
monetization of avoided SO2 and Hg
emissions in energy conservation
standards rulemakings. It has not
included monetization in the current
analysis.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
M. Utility Impact Analysis
The utility impact analysis estimates
several effects on the power generation
industry that would result from the
adoption of new or amended energy
conservation standards. In the utility
impact analysis, DOE analyzes the
changes in installed electricity capacity
and generation that would result for
each trial standard level. The utility
impact analysis uses a variant of
83 For additional information, refer to 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.
84 OMB, Circular A–4: Regulatory Analysis (Sept.
17, 2003).
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85 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).
86 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 ‘‘NEMS–BT’’ (‘‘BT’’ is DOE’s
Building Technologies Program, under whose aegis
this work has been performed).
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sector generally create fewer jobs (both
directly and indirectly) than
expenditures in other sectors of the
economy. There are many reasons for
these differences, including wage
differences and the fact that the utility
sector is more capital-intensive 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). Thus, based on the
BLS data alone, DOE believes net
national employment may increase
because of shifts in economic activity
resulting from new and amended
standards.
For the standard levels considered in
the NOPR, DOE estimated 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).
ImSET is a special purpose version of
the ‘‘U.S. Benchmark National InputOutput’’ (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 the
187 sectors. ImSET’s national economic
I–O structure is based on a 2002 U.S.
benchmark table, specially aggregated to
the 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. For the NOPR, DOE
used ImSET only to estimate short-term
employment impacts.
For more details on the employment
impact analysis, see chapter 16 of the
NOPR TSD.
O. Other Comments Received
IECA commented that motor endusers have not participated in DOE’s
electric motor standards process, and
they urge DOE to provide an outreach
effort to include those who buy motors.
(IECA, No. 52 at p. 3) Throughout the
rulemaking process, DOE makes a
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considerable effort to understand
rulemaking impacts to consumers, most
specifically in the life-cycle cost
analysis. It encourages various
interested parties, including end-users
of electric motors, to attend public
meetings and submit comments. DOE
recognizes the central importance of the
consumer perspective, and welcomes
comment from IECA and any other
organizations serving consumer interest,
as well as from individual consumers,
themselves.
V. Analytical Results
A. Trial Standard Levels
DOE ordinarily considers several Trial
Standard Levels (TSLs) in its analytical
process. TSLs are formed by grouping
different Efficiency Levels (ELs), which
are standard levels for each Equipment
Class Grouping (ECG) of motors. DOE
analyzed the benefits and burdens of the
TSLs developed for today’s proposed
rule. DOE examined four TSLs for
electric motors. Table V.1 presents the
TSLs analyzed and the corresponding
efficiency level for each equipment class
group.
The efficiency levels in each TSL can
be characterized as follows: TSL 1
represents each equipment class group
moving up one efficiency level from the
current baseline, with the exception of
fire-pump motors, which remain at their
baseline level; TSL 2 represents NEMA
Premium levels for all equipment class
groups with the exception of fire-pump
motors, which remain at the baseline;
TSL 3 represents 1 NEMA band above
NEMA Premium for all groups except
fire-pump motors, which move up to
NEMA Premium; and TSL 4 represents
the maximum technologically feasible
level (max tech) for all equipment class
groups. Because today’s proposal
includes equipment class groups
containing both currently regulated
motors and those proposed to be
regulated, at certain TSLs, an equipment
class group may encompass different
standard levels, some of which may be
above one EL above the baseline. For
example, at TSL1, EL1 is being
proposed for equipment class group 1.
However, a large number of motors in
equipment class group 1 already have to
meet EL2. If TSL1 was selected, these
motors would continue to be required to
meet the standards at TSL2, while
currently un-regulated motors would be
regulated to TSL1.
TABLE V.1—SUMMARY OF PROPOSED TSLS
Equipment class group
1
2
3
4
TSL 1
................................................................................
................................................................................
................................................................................
................................................................................
B. Economic Justification and Energy
Savings
As discussed in section II.A, EPCA
provides seven factors to be evaluated in
determining whether a potential energy
conservation standard is economically
justified. (42 U.S.C. 6295(o)(2)(B)(i)) The
following sections generally discuss
how DOE is addressing each of those
seven factors in this rulemaking.
1. Economic Impacts on Individual
Customers
DOE analyzed the economic impacts
on electric motor customers by looking
at the effects standards would have on
the LCC and PBP. DOE also examined
the rebuttable presumption payback
EL
EL
EL
EL
1
1
0
1
TSL 2
................................
................................
................................
................................
EL
EL
EL
EL
2
1
0
2
TSL 3
................................
................................
................................
................................
periods for each equipment class, and
the impacts of potential standards on
customer subgroups. These analyses are
discussed below.
a. Life-Cycle Cost and Payback Period
To evaluate the net economic impact
of standards on electric motor
customers, DOE conducted LCC and
PBP analyses for each TSL. In general,
higher-efficiency equipment would
affect customers in two ways: (1)
Annual operating expense would
decrease, and (2) purchase price would
increase. Section IV.F of this notice
discusses the inputs DOE used for
calculating the LCC and PBP. The LCC
and PBP results are calculated from
EL
EL
EL
EL
3
2
1
3
TSL 4
................................
................................
................................
................................
EL
EL
EL
EL
4
2
3
4
electric motor cost and efficiency data
that are modeled in the engineering
analysis (section IV.C).
For each representative unit, the key
outputs of the LCC analysis are a mean
LCC savings and a median PBP relative
to the base case, as well as the fraction
of customers for which the LCC will
decrease (net benefit), increase (net
cost), or exhibit no change (no impact)
relative to the base-case product
forecast. No impacts occur when the
base-case efficiency equals or exceeds
the efficiency at a given TSL. Table V.2
through Table V.5 show the key
shipment weighted average of results for
the representative units in each
equipment class group.
TABLE V.2—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 1
1
2
3
4
Efficiency level
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Trial standard level *
1
2
3
4
0.3
9.7
90.0
43
1.1
8.4
32.0
59.6
132
3.3
38.0
40.4
21.5
68
6.7
Customers with Net LCC Cost (%) ** ......................................................................................................................
Customers with Net LCC Benefit (%) ** ..................................................................................................................
Customers with No Change in LCC (%) ** ..............................................................................................................
Mean LCC Savings ($) ............................................................................................................................................
Median PBP (Years) ................................................................................................................................................
* The results for equipment class group 1 are the shipment weighted averages of the results for representative units 1, 2, and 3.
** Rounding may cause some items to not total 100 percent.
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84.6
7.6
7.7
¥417
29.9
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TABLE V.3—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 2
Trial Standard level *
1
2
3
4
Efficiency level
1
1
2
2
21.5
68.6
9.9
38
5.0
21.5
68.6
9.9
38
5.0
94.7
5.3
0.0
¥285
22.8
94.7
5.3
0.0
¥285
22.8
Customers with Net LCC Cost (%) ** ......................................................................................................................
Customers with Net LCC Benefit (%) ** ..................................................................................................................
Customers with No Change in LCC (%) ** ..............................................................................................................
Mean LCC Savings ($) ............................................................................................................................................
Median PBP (Years) ................................................................................................................................................
* The results for equipment class group 2 are the shipment weighted averages of the results for representative units 4 and 5.
** Rounding may cause some items to not total 100 percent.
TABLE V.4—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 3
Trial standard level *
1
2
3
4
Efficiency level
0
0
1
3
Customers with Net LCC Cost (%) ** ....................................................................................................
Customers with Net LCC Benefit (%) ** ................................................................................................
Customers with No Change in LCC (%) ** ............................................................................................
Mean LCC Savings ($) ..........................................................................................................................
Median PBP (Years) ..............................................................................................................................
0.0
0.0
0.0
N/A ***
N/A ***
0.0
0.0
0.0
N/A ***
N/A ***
81.7
0.0
18.3
¥61
3,299
100.0
0.0
0.0
¥763
11,957
* The results for equipment class group 3 are the shipment weighted averages of the results for representative units 6, 7, and 8.
** Rounding may cause some items to not total 100 percent.
*** For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected.
TABLE V.5—SUMMARY LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS FOR EQUIPMENT CLASS GROUP 4
Trial standard level *
1
2
3
4
Efficiency level
1
2
3
4
1.0
31.8
67.3
137
1.2
10.8
60.8
28.4
259
1.9
33.1
65.8
1.1
210
3.7
Customers with Net LCC Cost (%) ** ......................................................................................................................
Customers with Net LCC Benefit (%) ** ..................................................................................................................
Customers with No Change in LCC (%) ** ..............................................................................................................
Mean LCC Savings ($) ............................................................................................................................................
Median PBP (Years) ................................................................................................................................................
79.6
19.9
0.3
¥291
16.0
* The results for equipment class group 4 are the shipment weighted averages of the results for representative units 9 and 10.
** Rounding may cause some items to not total 100 percent.
b. Consumer Subgroup Analysis
In the customer subgroup analysis,
DOE estimated the LCC impacts of the
electric motor TSLs on various groups of
customers. Table V.6 and Table V.7
compare the weighted average mean
LCC savings and median payback
periods for ECG 1 at each TSL for
different customer subgroups.
Chapter 11 of the TSD presents the
detailed results of the customer
subgroup analysis and results for the
other equipment class groups.
TABLE V.6—SUMMARY LIFE-CYCLE COST RESULTS FOR SUBGROUPS FOR EQUIPMENT CLASS GROUP 1: AVERAGE LCC
SAVINGS
Average LCC savings (2012$) *
EL
TSL
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Default
1
2
3
4
1
2
3
4
Low
energy
price
43
132
68
¥417
Small
business
38
115
46
¥447
37
111
45
¥448
Industrial
sector
only
Commercial
sector
only
53
169
111
¥356
40
118
53
¥440
* The results for equipment class group 1 are the shipment weighted averages of the results for representative units 1, 2, and 3.
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Agricultural
sector
only
16
5
¥103
¥675
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TABLE V.7—SUMMARY LIFE-CYCLE COST RESULTS FOR SUBGROUPS FOR EQUIPMENT CLASS GROUP 1: MEDIAN
PAYBACK PERIOD
Median payback period
(Years) *
EL
TSL
Low
energy
price
Default
1
2
3
4
1
2
3
4
1.1
3.3
6.7
29.9
Industrial
sector
only
Small
business
1.3
3.7
7.6
33.7
1.1
3.3
6.7
29.9
Commercial
sector
only
0.8
2.1
4.2
18.8
Agricultural
sector
only
1.3
3.9
7.9
34.7
3.5
7.0
22.7
123.5
* The results for equipment class group 1 are the shipment weighted averages of the results for representative units 1, 2, and 3.
c. Rebuttable Presumption Payback
As discussed in section IV.F.12, EPCA
establishes a rebuttable presumption
that an energy conservation standard is
economically justified if the increased
purchase cost for equipment that meets
the standard is less than three times the
value of the first-year energy savings
resulting from the standard. (42 U.S.C.
6295(o)(2)(B)(iii) and 6316(a)) DOE
calculated a rebuttable-presumption
PBP for each TSL to determine whether
DOE could presume that a standard at
that level is economically justified. DOE
based the calculations on average usage
profiles. As a result, DOE calculated a
single rebuttable-presumption payback
value, and not a distribution of PBPs, for
each TSL. Table V.8 shows the
rebuttable-presumption PBPs for the
considered TSLs. The rebuttable
presumption is fulfilled in those cases
where the PBP is three years or less.
However, DOE routinely conducts an
economic analysis that considers the
full range of impacts to the customer,
manufacturer, Nation, and environment,
as required under 42 U.S.C.
6295(o)(2)(B)(i) as applied to equipment
via 42 U.S.C. 6316(a). The results of that
analysis serve as the basis for DOE to
definitively evaluate the economic
justification for a potential standard
level (thereby supporting or rebutting
the results of any three-year PBP
analysis). Section V.C addresses how
DOE considered the range of impacts to
select today’s NOPR.
TABLE V.8—REBUTTABLE-PRESUMPTION PAYBACK PERIODS (YEARS)
Trial standard level
1
Equipment
Equipment
Equipment
Equipment
Class
Class
Class
Class
Group
Group
Group
Group
1*
2*
3*
4*
.....................................................................................................................
.....................................................................................................................
.....................................................................................................................
.....................................................................................................................
2
0.6
1.8
0.0
0.6
3
0.8
1.8
0.0
0.9
4
1.2
8.0
900
1.3
4.3
8.0
5,464
4.5
* The results for each equipment class group (ECG) are a shipment weighted average of results for the representative units in the group. ECG
1: Representative units 1, 2, and 3; ECG 2: Representative units 4 and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units
9 and10.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate
the impact of new and amended energy
conservation standards on
manufacturers of electric motors. The
section below describes the expected
impacts on manufacturers at each TSL.
Chapter 12 of the TSD explains the
analysis in further detail.
The tables below depict the financial
impacts (represented by changes in
INPV) of new and amended energy
conservation standards on
manufacturers as well as the conversion
costs that DOE estimates manufacturers
would incur at each TSL. DOE displays
the INPV impacts by TSL for each ECG
in accordance with the grouping
described in detail in section V.A. To
evaluate the range of cash flow impacts
on the electric motor industry, DOE
modeled three markup scenarios that
correspond to the range of anticipated
market responses to new and amended
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standards. Each markup scenario results
in a unique set of cash flows and
corresponding industry value at each
TSL. All three markup scenarios are
presented below. In the following
discussion, the INPV results refer to the
difference in industry value between the
base case and the standards case that
result from the sum of discounted cash
flows from the base year (2013) through
the end of the analysis period. The
results also discuss the difference in
cash flow between the base case and the
standards case in the year before the
compliance date for new and amended
energy conservation standards. This
figure represents how large the required
conversion costs are relative to the cash
flow generated by the industry in the
absence of new and amended energy
conservation standards. In the
engineering analysis, DOE enumerates
common technology options that
achieve the efficiencies for each of the
representative units within an ECG. For
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descriptions of these technology options
and the required efficiencies at each
TSL, see section IV.C of today’s notice.
a. Industry Cash-Flow Analysis Results
The results below show three INPV
tables representing the three markup
scenarios used for the analysis. The first
table reflects the flat markup scenario,
which is the upper (less severe) bound
of impacts. To assess the lower end of
the range of potential impacts, DOE
modeled two potential markup
scenarios, a two-tiered markup scenario
and a preservation of operating profit
markup scenario. As discussed in
section IV.J.2.d, the two-tiered markup
scenario assumes manufacturers offer
two different tiers of markups—one for
lower efficiency levels and one for
higher efficiency levels. Meanwhile the
preservation of operating profit markup
scenario assumes that in the standards
case, manufacturers would be able to
earn the same operating margin in
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absolute dollars in the standards case as
in the base case. In general, the larger
the product price increases, the less
likely manufacturers are able to fully
pass through additional costs due to
standards calculated in the flat markup
scenario.
Table V.9, Table V.10, and Table V.11
present the projected results for all
electric motors under the flat, two-tiered
and preservation of operating profit
markup scenarios. DOE examined all
four ECGs (Design A and B motors,
Design C motors, fire pump motors, and
brake motors) together. The INPV results
follow in the tables below.
TABLE V.9—MANUFACTURER IMPACT ANALYSIS FOR ELECTRIC MOTORS—FLAT MARKUP SCENARIO
Trial standard level
Units
Base case
1
INPV .............................................................
Change in INPV ...........................................
Product Conversion Costs ...........................
Capital Conversion Costs ............................
Total Conversion Costs ........................
(2012$ millions) .............
(2012$ millions) .............
(%) .................................
(2012$ millions) .............
(2012$ millions) .............
(2012$ millions) .............
$3,371.2
....................
....................
....................
....................
....................
2
$3,378.7
$7.5
0.2%
$6.1
$0.0
$6.2
$3,759.2
$388.0
11.5%
$57.4
$26.4
$83.7
3
$4,443.7
$1,072.5
31.8%
$611.7
$220.5
$832.3
4
$5,241.3
$1,870.1
55.5%
$620.6
$699.8
$1,320.4
TABLE V.10—MANUFACTURER IMPACT ANALYSIS FOR ELECTRIC MOTORS—TWO-TIERED MARKUP SCENARIO
Trial standard level
Units
Base case
1
INPV .............................................................
Change in INPV ...........................................
Product Conversion Costs ...........................
Capital Conversion Costs ............................
Total Conversion Costs ........................
(2012$ millions) .............
(2012$ millions) .............
(%) .................................
(2012$ millions) .............
(2012$ millions) .............
(2012$ millions) .............
$3,371.2
....................
....................
....................
....................
....................
2
$3,374.3
$3.2
0.1%
$6.1
$0.0
$6.2
$3,087.6
$(283.5)
¥8.4%
$57.4
$26.4
$83.7
3
$2,979.6
$(391.6)
¥11.6%
$611.7
$220.5
$832.3
4
$3,335.7
$(35.5)
¥1.1%
$620.6
$699.8
$1,320.4
TABLE V.11—MANUFACTURER IMPACT ANALYSIS FOR ELECTRIC MOTORS—PRESERVATION OF OPERATING PROFIT
MARKUP SCENARIO
Trial standard level
Units
Base case
1
INPV .......................................................
Change in INPV .....................................
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Product Conversion Costs .....................
Capital Conversion Costs ......................
Total Conversion Costs ..................
(2012$ millions) ...................
(2012$ millions) ...................
(%) .......................................
(2012$ millions) ...................
(2012$ millions) ...................
(2012$ millions) ...................
TSL 1 represents EL 1 for ECG 1, ECG
2 and ECG 4 motors and baseline for
ECG 2 motors. At TSL 1, DOE estimates
impacts on INPV to range from $7.5
million to ¥$351.7 million, or a change
in INPV of 0.2 percent to ¥10.4 percent.
At this proposed level, industry free
cash flow is estimated to decrease by
approximately 1.1 percent to $164.9
million, compared to the base case value
of $166.7 million in the year leading up
to the proposed energy conservation
standards.
The INPV impacts at TSL 1 range
from slightly positive to moderately
negative, however DOE does not
anticipate that manufacturers would
lose a significant portion of their INPV
at this TSL. This is because the vast
majority of shipments already meets or
exceeds the efficiency levels prescribed
at TSL 1. DOE estimates that in the year
of compliance, 90 percent of all electric
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....................
....................
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$3,019.5
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¥10.4%
$6.1
$0.0
$6.2
motor shipments (90 percent of ECG 1,
eight percent of ECG 2, 100 percent of
ECG 3, and 67 percent of ECG 4
shipments) would meet the efficiency
levels at TSL 1 or higher in the base
case. Since ECG 1 shipments account for
over 97 percent of all electric motor
shipments the effects on those motors
are the primary driver for the impacts at
this TSL. Only a few ECG 1 shipments
not currently covered by the existing
electric motors rule and a small amount
of ECG 2 and ECG 4 shipments would
need to be converted at TSL 1 to meet
this efficiency standard.
DOE expects conversion costs to be
small compared to the industry value
because most of the electric motor
shipments, on a volume basis, already
meet the efficiency levels analyzed at
this TSL. DOE estimates product
conversion costs of $6.1 million due to
the proposed expanded scope of this
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2
$3,089.7
$(281.5)
¥8.4%
$57.4
$26.4
$83.7
3
$2,356.8
$(1,014.4)
¥30.1%
$611.7
$220.5
$832.3
4
$1,383.1
$(1,988.1)
¥59.0%
$620.6
$699.8
$1,320.4
rulemaking which includes motors
previously not covered by the current
electric motor energy conservation
standards. DOE believes that at this
TSL, there will be some engineering
costs as well as testing and certification
costs associated with this proposed
scope expansion. DOE estimates the
capital conversion costs to be minimal
at TSL 1. This is mainly because almost
all manufacturers currently produce
some motors that are compliant at TSL
1 efficiency levels and it would not be
much of a capital investment to bring all
motor production to this efficiency
level.
TSL 2 represents EL 2 for ECG 1 and
ECG 4 motors; EL 1 for ECG 2 motors;
and baseline for ECG 3 motors. At TSL
2, DOE estimates impacts on INPV to
range from $388 million to ¥$283.5
million, or a change in INPV of 11.5
percent to ¥8.4 percent. At this
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proposed level, industry free cash flow
is estimated to decrease by
approximately 17.2 percent to $138
million, compared to the base case value
of $166.7 million in the year leading up
to the proposed energy conservation
standards.
The INPV impacts at TSL 2 range
from moderately positive to moderately
negative. DOE estimates that in the year
of compliance, 59 percent of all electric
motor shipments (60 percent of ECG 1,
eight percent of ECG 2, 100 percent of
ECG 3, and 30 percent of ECG 4
shipments) would meet the efficiency
levels at TSL 2 or higher in the base
case. The majority of shipments are
currently covered by an electric motors
standard that requires general purpose
Design A and B motors to meet this TSL.
Therefore, only previously non-covered
Design A and B motors and a few ECG
2 and ECG 4 motors would have to be
converted at TSL 2 to meet this
efficiency standard.
DOE expects conversion costs to
increase significantly from TSL 1,
however, these conversion costs do not
represent a large portion of the base case
INPV, since again the majority of
electric motor shipments already meet
the efficiency levels analyzed at this
TSL. DOE estimates product conversion
costs of $57.4 million due to the
proposed expanded scope of this
rulemaking, which includes motors
previously not covered by the current
electric motor energy conservation
standards and the inclusion of ECG 2
and ECG 4 motors. DOE believes there
will be sizable engineering costs as well
as testing and certification costs at this
TSL associated with this proposed
scope expansion. DOE estimates the
capital conversion costs to be
approximately $26.4 million at TSL 2.
While most manufacturers already
produce at least some motors that are
compliant at TSL 2, these manufacturers
would likely have to invest in expensive
machinery to bring all motor production
to these efficiency levels.
TSL 3 represents EL 3 for ECG 1 and
ECG 4 motors, EL 2 for ECG 2 motors
and EL 1 for ECG 3 motors. At TSL 3,
DOE estimates impacts on INPV to range
from $1,072.5 million to ¥$1,014.4
million, or a change in INPV of 31.8
percent to ¥30.1 percent. At this
proposed level, industry free cash flow
is estimated to decrease by
approximately 167.5 percent to ¥$112.5
million, compared to the base case value
of $166.7 million in the year leading up
to the proposed energy conservation
standards.
The INPV impacts at TSL 3 range
from significantly positive to
significantly negative. DOE estimates
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that in the year of compliance, 23
percent of all electric motor shipments
(24 percent of ECG 1, less than one
percent of ECG 2, 19 percent of ECG 3,
and four percent of ECG 4 shipments)
would meet the efficiency levels at TSL
3 or higher in the base case. The
majority of shipments would need to be
converted to meet energy conservation
standards at this TSL.
DOE expects conversion costs to
increase significantly at TSL 3 and
become a substantial investment for
manufacturers. DOE estimates product
conversion costs of $611.7 million at
TSL 3, since most electric motors in the
base case do not exceed the current
motor standards set at NEMA Premium
for Design A and B motors, which
represent EL 2 for ECG 1. DOE believes
there would be a massive reengineering
effort that manufacturers would have to
undergo to have all motors meet this
TSL. Additionally, motor manufacturers
would have to increase the efficiency
levels for ECG 2, ECG 3, and ECG 4
motors. DOE estimates the capital
conversion costs to be approximately
$220.5 million at TSL 3. Most
manufacturers would have to make
significant investments to their
production facilities in order to convert
all their motors to be compliant at TSL
3.
TSL 4 represents EL 4 for ECG 1 and
ECG 4 motors, EL 3 for ECG 3 motors
and EL 2 for ECG 2 motors. At TSL 4,
DOE estimates impacts on INPV to range
from $1,870.1 million to ¥$1,988.1
million, or a change in INPV of 55.5
percent to ¥59.0 percent. At this
proposed level, industry free cash flow
is estimated to decrease by
approximately 298.4 percent to ¥$330.8
million, compared to the base case value
of $166.7 million in the year leading up
to the proposed energy conservation
standards.
The INPV impacts at TSL 4 range
from significantly positive to
significantly negative. DOE estimates
that in the year of compliance only eight
percent of all electric motor shipments
(nine percent of ECG 1, less than one
percent of ECG 2, zero percent of ECG
3, and less than one percent of ECG 4
shipments) would meet the efficiency
levels at TSL 2 or higher in the base
case. Almost all shipments would need
to be converted to meet energy
conservation standards at this TSL.
DOE expects conversion costs again to
increase significantly from TSL 3 to TSL
4. Conversion costs at this TSL now
represent a massive investment for
electric motor manufacturers. DOE
estimates product conversion costs of
$620.6 million at TSL 4, which are the
same conversion costs at TSL 3. DOE
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believes that manufacturers would need
to completely reengineer almost all
electric motors sold as well as test and
certify those motors. DOE estimates
capital conversion costs of $699.8
million at TSL 4. This is a significant
increase in capital conversion costs
from TSL 3 since manufacturers would
need to adopt copper die-casting at this
TSL. This technology requires a
significant level of investment because
the majority of the machinery would
need to be replaced or significantly
modified.
b. Impacts on Employment
DOE quantitatively assessed the
impact of potential new and amended
energy conservation standards on direct
employment. DOE used the GRIM to
estimate the domestic labor
expenditures and number of domestic
production workers in the base case and
at each TSL from the announcement of
any potential new and amended energy
conservation standards in 2013 to the
end of the analysis period in 2044. DOE
used statistical data from the U.S.
Census Bureau’s 2011 Annual Survey of
Manufacturers (ASM), the results of the
engineering analysis, and interviews
with manufacturers to determine the
inputs necessary to calculate industrywide labor expenditures and domestic
employment levels. Labor expenditures
involved with the manufacturing of
electric motors are a function of the
labor intensity of the product, the sales
volume, and an assumption that wages
remain fixed in real terms over time.
In the GRIM, DOE used the labor
content of each product and the
manufacturing production costs to
estimate the annual labor expenditures
of the industry. DOE used Census data
and interviews with manufacturers to
estimate the portion of the total labor
expenditures attributable to domestic
labor.
The production worker estimates in
this employment section cover only
workers up to the line-supervisor level
who are directly involved in fabricating
and assembling an electric motor within
a motor facility. Workers performing
services that are closely associated with
production operations, such as material
handling with a forklift, are also
included as production labor. DOE’s
estimates account for only production
workers who manufacture the specific
equipment covered by this rulemaking.
For example, a worker on an electric
motor line manufacturing a fractional
horsepower motor (i.e. a motor with less
than one horsepower) would not be
included with this estimate of the
number of electric motor workers, since
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fractional motors are not covered by this
rulemaking.
The employment impacts shown in
the tables below represent the potential
production employment impact
resulting from new and amended energy
conservation standards. The upper
bound of the results estimates the
maximum change in the number of
production workers that could occur
after compliance with new and
amended energy conservation standards
when assuming that manufacturers
continue to produce the same scope of
covered equipment in the same
production facilities. It also assumes
that domestic production does not shift
to lower-labor-cost countries. Because
there is a real risk of manufacturers
evaluating sourcing decisions in
response to new and amended energy
conservation standards, the lower
bound of the employment results
includes the estimated total number of
U.S. production workers in the industry
who could lose their jobs if all existing
production were moved outside of the
U.S. While the results present a range of
employment impacts following 2015,
the sections below also include
qualitative discussions of the likelihood
of negative employment impacts at the
various TSLs. Finally, the employment
impacts shown are independent of the
indirect employment impacts from the
broader U.S. economy, which are
documented in chapter 16 of the NOPR
TSD.
Based on 2011 ASM data and
interviews with manufacturers, DOE
estimates approximately 60 percent of
electric motors sold in the U.S. are
manufactured domestically. Using this
assumption, DOE estimates that in the
absence of new and amended energy
conservation standards, there would be
approximately 7,237 domestic
production workers involved in
manufacturing all electric motors
covered by this rulemaking in 2015. The
table below shows the range of potential
impacts of new and amended energy
conservation standards for all ECGs on
U.S. production workers in the electric
motor industry. However, because ECG
1 motors comprise more than 97 percent
of the electric motors covered by this
rulemaking, DOE believes that potential
changes in domestic employment will
be driven primarily by the standards
that are selected for ECG 1, Design A
and B electric motors.
TABLE V.12—POTENTIAL CHANGES IN THE TOTAL NUMBER OF ALL DOMESTIC ELECTRIC MOTOR PRODUCTION WORKERS
IN 2015
Trial standard level
Base case
1
Total Number of Domestic Production Workers in 2015
(without changes in production locations) ......................
Potential Changes in Domestic Production Workers in
2015 * .............................................................................
2
3
4
7,237
7,270
7,420
8,287
15,883
......................
33¥0
183¥(362)
1,050¥(3,619)
8,646¥(7,237)
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* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
Most manufacturers agree that any
standards that involve expanding the
scope of equipment required to meet
NEMA Premium would not significantly
change domestic employment levels. At
this efficiency level (TSL 2),
manufacturers would not be required to
make major modifications to their
production lines nor would they have to
undertake new manufacturing
processes. A few small business
manufacturers who primarily make
electric motors currently out of the
scope of coverage, but whose equipment
would be covered by new electric motor
standards, could be impacted by
efficiency standards at TSL 2. These
impacts, including employment
impacts, are discussed in section VI.B of
today’s NOPR. Overall, DOE believes
there would not be a significant
decrease in domestic employment levels
at TSL 2. DOE created a lower bound of
the potential loss of domestic
employment at 362 employees for TSL
2. DOE estimated only five percent of
the electric motors market is comprised
of manufacturers that do not currently
produce any motors at NEMA Premium
efficiency levels. DOE estimated that at
most five percent of domestic electric
motor manufacturing could potentially
move abroad or exit the market entirely.
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DOE similarly estimated that all electric
motor manufacturers produce some
electric motors at or above TSL 1
efficiency levels. Therefore, DOE does
not believe that any potential loss of
domestic employment would occur at
TSL 1.
Manufacturers, however, cautioned
that any standard set above NEMA
Premium would require major changes
to production lines, large investments in
capital and labor, and would result in
extensive stranded assets. This is largely
because manufacturers would have to
design and build motors with larger
frame sizes and could potentially have
to use copper, rather than aluminum
rotors. Several manufacturers pointed
out that this would require extensive
retooling, vast engineering resources,
and would ultimately result in a more
labor-intensive production process.
Manufacturers generally agreed that a
shift toward copper rotors would have
uncertain impacts on energy efficiency
and would cause companies to incur
higher labor costs. These factors could
cause manufacturers to consider moving
production offshore to reduce labor
costs or they may choose to exit the
market entirely. Therefore, DOE believes
it is more likely that efficiency
standards set above NEMA Premium
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could result in a decrease of labor.
Accordingly, DOE set the lower bound
on the potential loss of domestic
employment at 50 percent of the
existing domestic labor market for TSL
3 and 100 percent of the domestic labor
market for TSL 4. However, these values
represent the worst case scenario DOE
modeled. Manufacturers also stated that
larger motor manufacturing (that is for
motors above 200 horsepower) would be
very unlikely to move abroad since the
shipping costs associated with those
motors are very large. Consequently,
DOE does not currently believe
standards set at TSL 3 and TSL 4 would
likely result in a large loss of domestic
employment.
c. Impacts on Manufacturing Capacity
Most manufacturers agreed that any
standard expanding the scope of
equipment required to meet NEMA
Premium would not have a significant
impact on manufacturing capacity.
Manufacturers pointed out, however,
that a standard that required them to use
copper rotors would severely disrupt
manufacturing capacity. Most
manufacturers emphasized they do not
currently have the machinery,
technology, or engineering resources to
produce copper rotors in-house. Some
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manufacturers claim that the few
manufacturers that do have the
capability of producing copper rotors
are not able to produce these motors in
volumes sufficient to meet the demands
of their customers. For manufacturers to
either completely redesign their motor
production lines or significantly expand
their fairly limited copper rotor
production line would require a massive
retooling and engineering effort, which
could take several years to complete.
Most manufacturers stated they would
have to outsource copper rotor
production because they would not be
able to modify their facilities and
production processes to produce copper
rotors in-house within a three year time
period. Most manufacturers agreed that
outsourcing rotor die casting would
constrain capacity by creating a
bottleneck in rotor production, as there
are very few companies that produce
copper rotors.
Manufacturers also pointed out that
there is substantial uncertainty
surrounding the global availability and
price of copper, which has the potential
to constrain capacity. Several
manufacturers expressed concern that
the combination of all of these factors
would make it difficult to support
existing business while redesigning
product lines and retooling. The need to
support existing business would also
cause the redesign effort to take several
years.
In summary, for those TSLs that
require copper rotors, DOE believes
there is a likelihood of capacity
constraints in the near term due to
fluctuations in the copper market and
limited copper die casting machinery
and expertise. However, for the levels
proposed in this rule, DOE does not
foresee any capacity constraints.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
d. Impacts on Sub-Group of
Manufacturers
Using average cost assumptions to
develop an industry cash-flow estimate
may not be adequate for assessing
differential impacts among
manufacturer subgroups. Small
manufacturers, niche equipment
manufacturers, and manufacturers
exhibiting cost structures substantially
different from the industry average
could be affected disproportionately.
DOE analyzed the impacts to small
businesses in section VI.B and did not
identify any other adversely impacted
electric motor-related subgroups for this
rulemaking based on the results of the
industry characterization.
e. Cumulative Regulatory Burden
While any one regulation may not
impose a significant burden on
manufacturers, the combined effects of
recent or impending regulations may
have serious consequences for some
manufacturers, groups of manufacturers,
or an entire industry. Assessing the
impact of a single regulation may
overlook this cumulative regulatory
burden. In addition to energy
conservation standards, other
regulations can significantly affect
manufacturers’ financial operations.
Multiple regulations affecting the same
manufacturer can strain profits and lead
companies to abandon product lines or
markets with lower expected future
returns than competing equipment. For
these reasons, DOE conducts an analysis
of cumulative regulatory burden as part
of its rulemakings pertaining to
appliance efficiency.
During previous stages of this
rulemaking, DOE identified a number of
requirements, in addition to new and
amended energy conservation standards
for electric motors, that manufacturers
will face for equipment they
manufacture approximately three years
prior to and three years after the
compliance date of the new and
amended standards. The following
section briefly addresses comments DOE
received with respect to cumulative
regulatory burden and summarizes other
key related concerns that manufacturers
raised during interviews.
Several manufacturers expressed
concern about the compliance date of
this rulemaking to the proximity of the
2015 compliance date for the small
electric motors rulemaking at 75 FR
10874 (March 9, 2010). Most
manufacturers of electric motors
covered by this rulemaking also produce
electric motors that are covered by the
small electric motors rulemaking.
Manufacturers stated that adopting
these two regulations in a potentially
short timeframe could strain R&D and
capital expenditure budgets for motor
manufacturers. Some manufacturers
also raised concerns about other existing
regulations separate from DOE’s energy
conservation standards that electric
motors must meet: the National Fire
Protection Association (NFPA) 70,
National Electric Code; the NFPA 20,
Standard for the Installation of
Stationary Pumps for Fire Protection;
and Occupational Safety and Health
Administration (OSHA) regulations.
DOE discusses these and other
requirements in chapter 12 of the NOPR
TSD. DOE takes into account the cost of
compliance with other published
Federal energy conservation standards
in weighing the benefits and burdens of
today’s proposed rulemaking. In the
2010 small motors final rule, DOE
estimated that manufacturers may lose
up to 11.3 percent of their INPV, which
was approximately $39.5 million, in
2009$. To see the range of impacts DOE
estimated for the small motors rule, see
chapter 12 of the NOPR TSD. DOE does
not describe the quantitative impacts of
standards that have not yet been
finalized because any impacts would be
highly speculative. DOE also notes that
certain standards are optional for
manufacturers and takes that into
account when creating the cumulative
regulatory burden analysis.
3. National Impact Analysis
a. Significance of Energy Savings
For each TSL, DOE projected energy
savings for electric motors purchased in
the 30-year period that begins in the
year of compliance with new and
amended standards (2015–2044). The
savings are measured over the entire
lifetime of equipment purchased in the
30-year period. DOE quantified the
energy savings attributable to each TSL
as the difference in energy consumption
between each standards case and the
base case. Table V.13 presents the
estimated primary energy savings for
each considered TSL, and Table V.14
presents the estimated FFC energy
savings for each considered TSL. The
approach for estimating national energy
savings is further described in section
IV.H.
TABLE V.13—CUMULATIVE PRIMARY ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR UNITS
SOLD IN 2015–2044
Trial standard level
Equipment class
1
2
3
4
9.86
12.64
quads
Group 1 (NEMA Design A and B) ...........................................................................................................
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TABLE V.13—CUMULATIVE PRIMARY ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR UNITS
SOLD IN 2015–2044—Continued
Trial standard level
Equipment class
1
Group 2 (NEMA Design C) ......................................................................................................................
Group 3 (Fire Pump Electric Motors) ......................................................................................................
Group 4 (Brake Motors) ...........................................................................................................................
Total All Classes ...............................................................................................................................
2
3
4
0.02
0.00
0.26
1.10
0.02
0.00
0.58
6.87
0.03
0.00
0.71
10.60
0.03
0.00
0.81
13.49
TABLE V.14—CUMULATIVE FULL-FUEL-CYCLE ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR
UNITS SOLD IN 2015–2044
Trial standard level
Equipment class
1
2
3
4
10.02
0.03
0.00
0.73
10.78
12.85
0.03
0.00
0.83
13.71
quads
Group 1 (NEMA Design A and B) ...........................................................................................................
Group 2 (NEMA Design C) ......................................................................................................................
Group 3 (Fire Pump Electric Motors) ......................................................................................................
Group 4 (Brake Motors) ...........................................................................................................................
Total All Classes ...............................................................................................................................
Circular A–4 requires agencies to
present analytical results, including
separate schedules of the monetized
benefits and costs that show the type
and timing of benefits and costs.
Circular A–4 also directs agencies to
consider the variability of key elements
underlying the estimates of benefits and
costs. For this rulemaking, DOE
undertook a sensitivity analysis using
nine rather than 30 years of equipment
shipments. The choice of a nine-year
period is a proxy for the timeline in
EPCA for the review of certain energy
conservation standards and potential
revision of and compliance with such
revised standards.87 We would note that
the review timeframe established in
EPCA generally does not overlap with
the equipment lifetime, equipment
0.83
0.02
0.00
0.26
1.11
6.38
0.02
0.00
0.59
6.98
manufacturing cycles or other factors
specific to electric motors. Thus, this
information is presented for
informational purposes only and is not
indicative of any change in DOE’s
analytical methodology. The NES
results based on a 9-year analytical
period are presented in Table V.15. The
impacts are counted over the lifetime of
electric motors purchased in 2015–2023.
TABLE V.15—CUMULATIVE NATIONAL ENERGY SAVINGS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR UNITS
SOLD IN 2015–2023
Trial standard level
Equipment class
1
2
3
4
2.168
0.006
0.000
0.152
2.326
2.833
0.006
0.000
0.176
3.015
quads
Group 1 (NEMA Design A and B) ...........................................................................................................
Group 2 (NEMA Design C) ......................................................................................................................
Group 3 (Fire Pump Electric Motors) ......................................................................................................
Group 4 (Brake Motors) ...........................................................................................................................
Total All Classes ...............................................................................................................................
1.440
0.004
0.000
0.125
1,569
DOE estimated the cumulative NPV of
the total costs and savings for customers
that would result from the TSLs
considered for electric motors. In
accordance with OMB’s guidelines on
regulatory analysis,88 DOE calculated
the NPV using both a 7-percent and a 3percent real discount rate. The 7-percent
rate is an estimate of the average beforetax rate of return on private capital in
the U.S. economy, and reflects the
returns on real estate and small business
capital as well as corporate capital. This
discount rate approximates the
opportunity cost of capital in the private
sector (OMB analysis has found the
average rate of return on capital to be
near this rate). The 3-percent rate
reflects the potential effects of standards
on private consumption (e.g., through
higher prices for equipment and
reduced purchases of energy). This rate
represents the rate at which society
discounts future consumption flows to
87 EPCA requires DOE to review its standards at
least once every 6 years, and requires, for certain
products, a 3-year period after any new standard is
promulgated before compliance is required, except
that in no case may any new standards be required
within 6 years of the compliance date of the
previous standards. While adding a 6-year review
to the 3-year compliance period adds up to 9 years,
DOE notes that it may undertake reviews at any
time within the 6 year period and that the 3-year
compliance date may yield to the 6-year backstop.
A 9-year analysis period may not be appropriate
given the variability that occurs in the timing of
standards reviews and the fact that for some
consumer products, the compliance period is 5
years rather than 3 years.
88 OMB Circular A–4, section E (Sept. 17, 2003).
https://www.whitehouse.gov/omb/circulars_a004_a–
4.
b. Net Present Value of Customer Costs
and Benefits
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
0.355
0.004
0.000
0.060
0.420
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their present value. It can be
approximated by the real rate of return
on long-term government debt (i.e.,
yield on United States Treasury notes),
which has averaged about 3 percent for
the past 30 years.
Table V.16 shows the customer NPV
results for each TSL considered for
electric motors. In each case, the
impacts cover the lifetime of equipment
purchased in 2015–2044.
TABLE V.16—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR
UNITS SOLD IN 2015–2044
[Billion 2012$]
1
2
3
4
3
Group 1 (NEMA Design A and B) .....................................................................
Group 2 (NEMA Design C) ................................................................................
Group 3 (Fire Pump Electric Motors) ................................................................
Group 4 (Brake Motors) .....................................................................................
Total All Classes .........................................................................................
4.5
0.0
0.0
1.3
5.8
20.7
0.0
0.0
2.5
23.3
1.5
0.0
0.0
1.5
3.0
¥41.2
0.0
0.0
¥1.2
¥42.4
7
Group 1 (NEMA Design A and B) .....................................................................
Group 2 (NEMA Design C) ................................................................................
Group 3 (Fire Pump Electric Motors) ................................................................
Group 4 (Brake Motors) .....................................................................................
Total All Classes .........................................................................................
The NPV results based on the aforementioned 9-year analytical period are
presented in Table V.17. The impacts
are counted over the lifetime of
Trial standard level
Discount
rate %
Equipment class
2.2
0.0
0.0
0.5
2.7
7.7
0.0
0.0
1.0
8.7
¥3.7
0.0
0.0
0.3
¥3.4
¥29.1
0.0
0.0
¥1.2
¥30.3
equipment purchased in 2015–2023. As
mentioned previously, this information
is presented for informational purposes
only and is not indicative of any change
in DOE’s analytical methodology or
decision criteria.
TABLE V.17—NET PRESENT VALUE OF CUSTOMER BENEFITS FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS FOR
UNITS SOLD IN 2015–2023
[Billion 2012$]
Group 1 (NEMA Design A and B) .....................................................................
Group 2 (NEMA Design C) ................................................................................
Group 3 (Fire Pump Electric Motors) ................................................................
Group 4 (Brake Motors) .....................................................................................
Total All Classes .........................................................................................
Group 1 (NEMA Design A and B) .....................................................................
Group 2 (NEMA Design C) ................................................................................
Group 3 (Fire Pump Electric Motors) ................................................................
Group 4 (Brake Motors) .....................................................................................
Total All Classes .........................................................................................
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
c. Indirect Impacts on Employment
DOE expects energy conservation
standards for electric motors to reduce
energy costs for equipment owners, and
the resulting net savings to be redirected
to other forms of economic activity.
Those shifts in spending and economic
activity could affect the demand for
labor. As described in section IV.N, DOE
used an input/output model of the U.S.
economy to estimate indirect
employment impacts of the TSLs that
DOE considered in this rulemaking.
DOE understands that there are
uncertainties involved in projecting
employment impacts, especially
changes in the later years of the
analysis. Therefore, DOE generated
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Trial standard level
Discount
rate %
Equipment class
1
2
3
2.253
0.011
0.000
0.389
2.654
6.473
0.011
0.000
0.706
7.190
2.541
¥0.012
¥0.001
0.495
3.023
¥12.055
¥0.012
¥0.009
¥0.372
¥12.448
7
1.344
0.005
0.000
0.225
1.574
3.492
0.005
0.000
0.391
3.887
¥0.102
¥0.016
¥0.001
0.201
0.083
¥12.017
¥0.016
¥0.007
¥0.498
¥12.537
results for near-term time frames (2015–
2019), where these uncertainties are
reduced.
The results suggest that today’s
standards are likely to have negligible
impact on the net demand for labor in
the economy. The net change in jobs is
so small that it would be imperceptible
in national labor statistics and might be
offset by other, unanticipated effects on
employment. Chapter 16 of the NOPR
TSD presents detailed results.
4. Impact on Utility or Performance
DOE believes that the standards it is
proposing today will not lessen the
utility or performance of electric motors.
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4
5. Impact of Any Lessening of
Competition
DOE has also considered any
lessening of competition that is likely to
result from new and amended
standards. The Attorney General
determines the impact, if any, of any
lessening of competition likely to result
from a proposed standard, and transmits
such determination to the Secretary,
together with an analysis of the nature
and extent of such impact. (42 U.S.C.
6295(o)(2)(B)(i)(V) and (B)(ii))
To assist the Attorney General in
making such determination, DOE will
provide DOJ with copies of this NOPR
and the TSD for review. DOE will
consider DOJ’s comments on the
proposed rule in preparing the final
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rule, and DOE will publish and respond
to DOJ’s comments in that document.
6. Need of the Nation To Conserve
Energy
Enhanced energy efficiency, where
economically justified, improves the
Nation’s energy security, strengthens the
economy, and reduces the
environmental impacts or costs of
energy production. Reduced electricity
demand due to energy conservation
standards is also likely to reduce the
cost of maintaining the reliability of the
electricity system, particularly during
peak-load periods. As a measure of this
reduced demand, chapter 15 in the
NOPR TSD presents the estimated
reduction in generating capacity in 2044
for the TSLs that DOE considered in this
rulemaking.
Energy savings from standards for
electric motors could also produce
environmental benefits in the form of
reduced emissions of air pollutants and
greenhouse gases associated with
electricity production. Table V.18
provides DOE’s estimate of cumulative
emissions reductions projected to result
from the TSLs considered in this
rulemaking. DOE reports annual
emissions reductions for each TSL in
chapter 13 of the NOPR TSD.
TABLE V.18—CUMULATIVE EMISSIONS REDUCTION ESTIMATED FOR ELECTRIC MOTORS TRIAL STANDARD LEVELS
Trial standard level
1
2
3
4
62.4
105.3
33.5
0.1
1.2
7.3
374.1
669.7
196.3
0.8
8.3
46.3
576.0
1,034.7
301.9
1.3
12.9
71.6
733.3
1,315.5
384.5
1.6
16.4
91.0
3.5
0.8
48.6
0.0
0.0
294.8
22.0
4.7
303.1
0.0
0.2
1,841.4
34.0
7.3
467.8
0.0
0.3
2,841.9
43.2
9.3
595.0
0.0
0.4
3,614.6
CO2 (million metric tons) ..........................................................................................................
NOX (thousand tons) ...............................................................................................................
SO2 (thousand tons) ................................................................................................................
Hg (tons) ..................................................................................................................................
N2O (thousand tons) ................................................................................................................
CH4 (thousand tons) ................................................................................................................
65.9
106.0
82.1
0.1
1.3
302.2
396.1
674.4
499.4
0.8
8.5
1,887.7
610.0
1,042.0
769.6
1.3
13.2
2,913.5
776.5
1,324.8
979.5
1.6
16.8
3,705.5
As part of the analysis for this rule,
DOE estimated monetary benefits likely
to result from the reduced emissions of
CO2 and NOX that DOE estimated for
each of the TSLs considered. As
discussed in section IV.L, DOE used
values for the SCC developed by an
interagency process. The four sets of
SCC values resulting from that process
(expressed in 2012$) are represented by
$12.9/metric ton (the average value from
a distribution that uses a 5-percent
discount rate), $40.8/metric ton (the
Table V.19 presents the global value
of CO2 emissions reductions at each
TSL. For each of the four cases, DOE
calculated a present value of the stream
of annual values using the same
discount rate as was used in the studies
upon which the dollar-per-ton values
are based. DOE calculated domestic
values as a range from 7 percent to 23
percent of the global values, and these
results are presented in chapter 14 of
the NOPR TSD.
Primary Energy Emissions
CO2 (million metric tons) ..........................................................................................................
NOX (thousand tons) ...............................................................................................................
SO2 (thousand tons) ................................................................................................................
Hg (tons) ..................................................................................................................................
N2O (thousand tons) ................................................................................................................
CH4 (thousand tons) ................................................................................................................
Upstream Emissions
CO2 (million metric tons) ..........................................................................................................
NOX (thousand tons) ...............................................................................................................
SO2 (thousand tons) ................................................................................................................
Hg (tons) ..................................................................................................................................
N2O (thousand tons) ................................................................................................................
CH4 (thousand tons) ................................................................................................................
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Total Emissions
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average value from a distribution that
uses a 3-percent discount rate), $62.2/
metric ton (the average value from a
distribution that uses a 2.5-percent
discount rate), and $117.0/metric ton
(the 95th-percentile value from a
distribution that uses a 3-percent
discount rate). These values correspond
to the value of emission reductions in
2015; the values for later years are
higher due to increasing damages as the
projected magnitude of climate change
increases.
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73663
TABLE V.19—ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER ELECTRIC MOTORS TRIAL
STANDARD LEVELS
[Million 2012$]
SCC Case *
TSL
5% discount
rate,
average *
3% discount
rate,
average *
2.5% discount
rate,
average *
3% discount
rate, 95th
percentile *
Primary Energy Emissions
1
2
3
4
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
433
2,366
3,622
4,622
1,961
11,179
17,159
21,871
3,113
17,876
27,452
34,985
6,040
34,552
53,047
67,609
24
136
209
266
110
650
1,001
1,274
174
1,042
1,604
2,042
338
2,012
3,097
3,943
457
2,502
3,831
4,888
2,071
11,829
18,159
23,145
3,287
18,918
29,056
37,027
6,378
36,564
56,143
71,552
Upstream Emissions
1
2
3
4
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
Total Emissions
1
2
3
4
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
* For
each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and $117.0 per metric ton (2012$).
DOE is well aware that scientific and
economic knowledge about the
contribution of CO2 and other
greenhouse gas (GHG) emissions to
changes in the future global climate and
the potential resulting damages to the
world economy continues to evolve
rapidly. Thus, any value placed on
reducing CO2 emissions in this
rulemaking is subject to change. DOE,
together with other Federal agencies,
will continue to review various
methodologies for estimating the
monetary value of reductions in CO2
and other GHG emissions. This ongoing
review will consider the comments on
this subject that are part of the public
record for this and other rulemakings, as
well as other methodological
assumptions and issues. However,
consistent with DOE’s legal obligations,
and taking into account the uncertainty
involved with this particular issue, DOE
has included in this proposed rule the
most recent values and analyses
resulting from the ongoing interagency
review process.
DOE also estimated a range for the
cumulative monetary value of the
economic benefits associated with NOX
emissions reductions anticipated to
result from new and amended standards
for electric motors. The low and high
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dollar-per-ton values that DOE used are
discussed in section IV.L present the
cumulative present values for each TSL
calculated using seven-percent and
three-percent discount rates.
TABLE V.20—ESTIMATES OF PRESENT
VALUE OF NOX EMISSIONS REDUCTION UNDER ELECTRIC MOTORS
TRIAL STANDARD LEVELS—Continued
[Million 2012$]
TABLE V.20—ESTIMATES OF PRESENT
VALUE OF NOX EMISSIONS REDUCTION UNDER ELECTRIC MOTORS
TRIAL STANDARD LEVELS
TSL
[Million 2012$]
4 ................
3% discount
rate
TSL
7% discount
rate
Power Sector Emissions
1
2
3
4
................
................
................
................
49.5
257.1
392.2
501.3
Upstream Emissions
1
2
3
4
................
................
................
................
68.0
378.4
579.9
739.7
Total Emissions
1 ................
2 ................
3 ................
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635.4
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3% discount
rate
7% discount
rate
1,241.0
553.8
7. Summary of National Economic
Impacts
The NPV of the monetized benefits
associated with emissions reductions
26.4 can be viewed as a complement to the
120.2 NPV of the customer savings calculated
181.6 for each TSL considered in this
233.2 rulemaking. Table V.21 presents the
NPV values that result from adding the
estimates of the potential economic
benefits resulting from reduced CO2 and
33.8 NO emissions in each of four valuation
X
164.8
scenarios to the NPV of customer
250.3
savings calculated for each TSL
320.6
considered in this rulemaking, at both a
seven-percent and three-percent
discount rate. The CO2 values used in
60.2 the columns of each table correspond to
285.0 the four sets of SCC values discussed
432.0 above.
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TABLE V.21—NET PRESENT VALUE OF CUSTOMER SAVINGS COMBINED WITH NET PRESENT VALUE OF MONETIZED
BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS
[Billion 2012$]
SCC Case
$39.7/metric
ton CO2* and
medium value
for NOX**
SCC Case
$11.8/metric
ton CO2* and
low value
for NOX**
TSL
SCC Case
$61.2/metric
ton CO2* and
medium value
for NOX**
SCC Case
$117.0/metric
ton CO2* and
high value
for NOX**
Customer NPV at 3% discount rate added with:
1
2
3
4
.......................................................................................................
.......................................................................................................
.......................................................................................................
.......................................................................................................
6.3
25.9
7.0
¥37.3
8.0
35.7
22.1
¥18.0
9.2
42.8
33.0
¥4.1
12.4
61.0
60.9
31.4
Customer NPV at 7% discount rate added with:
1
2
3
4
.......................................................................................................
.......................................................................................................
.......................................................................................................
.......................................................................................................
3.2
11.2
0.5
¥25.3
4.8
20.8
15.2
¥6.6
6.1
27.9
26.1
7.3
9.2
45.7
53.5
42.3
* These label values represent the global SCC in 2015, in 2012$.
** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton, and High Value corresponds to
$4,809 per ton.
Although adding the value of
customer savings to the values of
emission reductions provides a valuable
perspective, two issues should be
considered. First, the national operating
cost savings are domestic U.S. customer
monetary savings that occur as a result
of market transactions, while the value
of CO2 reductions is based on a global
value. Second, the assessments of
operating cost savings and the SCC are
performed with different methods that
use quite different time frames for
analysis. The national operating cost
savings is measured for the lifetime of
equipment shipped in 2015–2044. The
SCC values, on the other hand, reflect
the present value of future climaterelated impacts resulting from the
emission of one metric ton of CO2 in
each year. These impacts continue well
beyond 2100.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
8. Other Factors
The Secretary of Energy, in
determining whether a standard is
economically justified, may consider
any other factors that the Secretary
deems to be relevant. (42 U.S.C.
6295(o)(2)(B)(i)(VI)) No other factors
were considered in this analysis.
C. Proposed Standards
When considering proposed
standards, the new or amended energy
conservation standard that DOE adopts
for any type (or class) of covered
equipment shall be designed to achieve
the maximum improvement in energy
efficiency that the Secretary of Energy
determines is technologically feasible
and economically justified. (42 U.S.C.
6295(o)(2)(A) and 6316(a)) In
determining whether a standard is
economically justified, the Secretary
must determine whether the benefits of
the standard exceed its burdens to the
greatest extent practicable, considering
the seven statutory factors discussed
previously. (42 U.S.C. 6295(o)(2)(B)(i)
and 6316(a)) The new or amended
standard must also ‘‘result in significant
conservation of energy.’’ (42 U.S.C.
6295(o)(3)(B) and 6316(a))
For today’s NOPR, DOE considered
the impacts of standards at each TSL,
beginning with the max-tech level, to
determine whether that level was
economically justified. Where the maxtech level was not justified, DOE then
considered the next most efficient level
and undertook the same evaluation until
it reached the highest efficiency level
that is technologically feasible,
economically justified and saves a
significant amount of energy.
Throughout this process DOE also
considered the recommendations made
by the Motors Coalition and other
stakeholders in their submitted
comments. For more details on the
Motors Coalition see Section II.B.2.
To aid the reader in understanding
the benefits and/or burdens of each TSL,
tables in this section summarize the
quantitative analytical results for each
TSL, based on the assumptions and
methodology discussed herein. The
efficiency levels contained in each TSL
are described in section V.A. In addition
to the quantitative results presented in
the tables, DOE also considers other
burdens and benefits that affect
economic justification. These include
the impacts on identifiable subgroups of
customers who may be
disproportionately affected by a national
standard, and impacts on employment.
Section V.B.1.b presents the estimated
impacts of each TSL for the considered
subgroup. DOE discusses the impacts on
employment in electric motor
manufacturing in section V.B.2.b, and
discusses the indirect employment
impacts in section V.B.3.c.
1. Benefits and Burdens of Trial
Standard Levels Considered for Electric
Motors
Table V.22 and Table V.23 summarize
the quantitative impacts estimated for
each TSL for electric motors.
TABLE V.22—SUMMARY OF ANALYTICAL RESULTS FOR ELECTRIC MOTORS: NATIONAL IMPACTS
Category
Full-Fuel-Cycle
Energy
TSL 2
TSL 3
1.1 .............................
National
quads:
TSL 1
7.0 .............................
10.8 ...........................
Savings
NPV of Consumer Benefits 2012$ billion:
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TABLE V.22—SUMMARY OF ANALYTICAL RESULTS FOR ELECTRIC MOTORS: NATIONAL IMPACTS—Continued
Category
TSL 1
TSL 2
TSL 3
TSL 4
3% discount rate ..........................................
7% discount rate ..........................................
Cumulative Emissions Reduction (Total FFC
Emissions):
CO2 million metric tons ................................
SO2 thousand tons .......................................
NOX thousand tons ......................................
Hg tons .........................................................
N2O thousand tons .......................................
CH4 thousand tons .......................................
Value of Emissions Reduction (Total FFC
Emissions):
CO2 2012$ million* .......................................
NOX—3% discount rate 2012$ million .........
NOX—7% discount rate 2012$ million ................
5.8 .............................
2.7 .............................
23.3 ...........................
8.7 .............................
3.0 .............................
¥3.4 .........................
¥42.4
¥30.3
65.9 ...........................
106.0 .........................
82.1 ...........................
0.1 .............................
1.3 .............................
302.2 .........................
396.1 .........................
674.4 .........................
499.4 .........................
0.8 .............................
8.5 .............................
1,887.7 ......................
610.0 .........................
1,042.0 ......................
769.6 .........................
1.3 .............................
13.2 ...........................
2,913.5 ......................
776.5
1,324.8
979.5
1.6
16.8
3,705.5
457 to 6,378 .............
117.5 .........................
60.2 ...........................
2,502 to 36,564 ........
635.4 .........................
285.0 .........................
3,831 to 56,143 ........
972.2 .........................
432.0 .........................
4,888 to 71,552
1,241.0
553.8
* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
TABLE V.23—SUMMARY OF ANALYTICAL RESULTS FOR ELECTRIC MOTORS: MANUFACTURER AND CONSUMER IMPACTS
Category
TSL 1
Manufacturer Impacts:
Industry NPV 2012$ million ......................................................................
Industry NPV % change ...........................................................................
Consumer Mean LCC Savings * 2012$:
Equipment Class Group 1 ........................................................................
Equipment Class Group 2 ........................................................................
Equipment Class Group 3 ........................................................................
Equipment Class Group 4 ........................................................................
Consumer Median PBP * years:
Equipment Class Group 1 ........................................................................
Equipment Class Group 2 ........................................................................
Equipment Class Group 3 ........................................................................
Equipment Class Group 4 ........................................................................
Equipment Class Group 1:
Net Cost % ...............................................................................................
Net Benefit % ...........................................................................................
No Impact % .............................................................................................
Equipment Class Group 2:
Net Cost % ...............................................................................................
Net Benefit % ...........................................................................................
No Impact % .............................................................................................
Equipment Class Group 3:
Net Cost (%) .............................................................................................
Net Benefit (%) .........................................................................................
No Impact (%) ..........................................................................................
Equipment Class Group 4:
Net Cost (%) .............................................................................................
Net Benefit (%) .........................................................................................
No Impact (%) ..........................................................................................
TSL 2
TSL 3
TSL 4
3,378.7–
3,019.5
0.2–(10.4)
3,759.2–
3,087.6
11.5–(8.4)
4,443.7–
2,356.8
31.8–(30.1)
5,241.3–
1,383.1
55.5–(59.0)
43
38
N/A **
137
132
38
N/A **
259
68
¥285
¥61
210
¥417
¥285
¥763
¥291
1.1
5.0
N/A **
1.2
3.3
5.0
N/A **
1.9
6.7
22.8
3,299
3.7
29.9
22.8
11,957
16.0
0.3
9.7
90.0
8.4
32.0
59.6
38.0
40.4
21.5
84.6
7.6
7.7
21.5
68.6
9.9
21.5
68.6
9.9
94.7
5.3
0.0
94.7
5.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
81.7
0.0
18.3
100.0
0.0
0.0
1.0
31.8
67.3
10.8
60.8
28.4
33.1
65.8
1.1
79.6
19.9
0.3
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
** The results for each equipment class group (ECG) are a shipment weighted average of results for the representative units in the group. ECG
1: Representative units 1, 2, and 3; ECG 2: Representative units 4 and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units
9 and 10.
** For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected.
First, DOE considered TSL 4, the most
efficient level (max tech), which would
save an estimated total of 13.7 quads of
energy, an amount DOE considers
significant. TSL 4 has an estimated NPV
of customer benefit of ¥30.3 billion
using a 7 percent discount rate, and
¥42.4 billion using a 3 percent discount
rate.
The cumulative emissions reductions
at TSL 4 are 776.5 million metric tons
of CO2, 979.5 thousand tons of NOX,
VerDate Mar<15>2010
18:00 Dec 05, 2013
Jkt 232001
1,324.8 thousand tons of SO2, and 1.6
tons of Hg. The estimated monetary
value of the CO2 emissions reductions at
TSL 4 ranges from $4,888 million to
$71,552 million.
At TSL 4, the weighted average LCC
impact ranges from $¥763 for ECG 3 to
$¥285 for ECG 2. The weighted average
median PBP ranges from 16 years for
ECG 4 to 11,957 years for ECG 3. The
weighted average share of customers
experiencing a net LCC benefit ranges
PO 00000
Frm 00077
Fmt 4701
Sfmt 4702
from 0 percent for ECG 3 to 19.9 percent
for ECG 4.
At TSL 4, the projected change in
INPV ranges from a decrease of $1,988.1
million to an increase of $1,870.1
million. If the decrease of $1,988.1
million were to occur, TSL 4 could
result in a net loss of 59 percent in INPV
to manufacturers of covered electric
motors.
In view of the foregoing, DOE
concludes that, at TSL 4 for electric
E:\FR\FM\06DEP2.SGM
06DEP2
73666
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
motors, the benefits of energy savings,
emission reductions, and the estimated
monetary value of the emissions
reductions would be outweighed by the
potential multi-billion dollar negative
net economic cost; the economic burden
on customers as indicated by the
increase in customer LCC (negative
savings), large PBPs, the large
percentage of customers who would
experience LCC increases; the increase
in the cumulative regulatory burden on
manufacturers; and the capital and
engineering costs that could result in a
large reduction in INPV for
manufacturers at TSL 4. Additionally,
DOE believes that efficiency standards
at this level, could result in significant
impacts on OEMs due to larger and
faster motors. Although DOE has not
quantified these potential impacts, DOE
believes that it is possible that these
impacts could be significant and further
reduce any potential benefits of
standards established at this TSL.
Consequently, DOE has concluded that
TSL 4 is not economically justified.
Next, DOE considered TSL 3, which
would save an estimated total of 10.6
quads of energy, an amount DOE
considers significant. TSL 3 has an
estimated NPV of customer benefit of
$¥3.4 billion using a 7 percent discount
rate, and $3.0 billion using a 3 percent
discount rate.
The cumulative emissions reductions
at TSL 3 are 610.0 million metric tons
of CO2, 769.6 thousand tons of NOX,
1,042.0 thousand tons of SO2, and 1.3
tons of Hg. The estimated monetary
value of the CO2 emissions reductions at
TSL 4 ranges from $3,831 million to $
56,143 million.
At TSL 3, the weighted average LCC
impact ranges from $¥285 for ECG 2 to
$210 for ECG 4. The weighted average
median PBP ranges from 3.7 years for
ECG 4 to 3,299 years for ECG 3. The
share of customers experiencing a net
LCC benefit ranges from 0 percent for
ECG 3 to 65.8 percent for ECG 4.
At TSL 3, the projected change in
INPV ranges from a decrease of $1,014,4
million to an increase of $1,072.5
million. If the decrease of $1,014.4
million were to occur, TSL 3 could
result in a net loss of 30.1 percent in
INPV to manufacturers of covered
electric motors.
In view of the foregoing, DOE
concludes that, at TSL 3 for electric
motors, the benefits of energy savings,
positive weighted average customer LCC
savings for some ECGs, generating
capacity reductions, emission
reductions, and the estimated monetary
value of the emissions reductions would
be outweighed by the potential negative
net economic cost; the economic burden
on customers as indicated by the
increase in weighted average LCC for
some ECGs (negative savings), large
PBPs, the large percentage of customers
who would experience LCC increases;
the increase in the cumulative
regulatory burden on manufacturers;
and the capital and engineering costs
that could result in a large reduction in
INPV for manufacturers at TSL 3.
Additionally, DOE believes that
efficiency standards at this level could
result in significant impacts on OEMs
due to larger and faster motors.
Although DOE has not quantified these
potential impacts, DOE believes that it
is possible that these impacts could be
significant and further reduce any
potential benefits of standards
established at this TSL. Consequently,
DOE has concluded that TSL 3 is not
economically justified.
Next, DOE considered TSL 2, which
would save an estimated total of 7.0
quads of energy, an amount DOE
considers significant. TSL 2 has an
estimated NPV of customer benefit of
$8.7 billion using a 7 percent discount
rate, and $23.3 billion using a 3 percent
discount rate.
The cumulative emissions reductions
at TSL 2 are 396.1 million metric tons
of CO2, 674.4 thousand tons of NOX,
499.4 thousand tons of SO2, and 0.8 tons
of Hg. The estimated monetary value of
the CO2 emissions reductions at TSL 4
ranges from $2,502 million to $36,564
million.
At TSL 2, the weighted average LCC
impact ranges from no impacts for ECG
3 to $259 for ECG 4. The weighted
average median PBP ranges from 0 years
for ECG 3 to 5 years for ECG 2. The
share of customers experiencing a net
LCC benefit ranges from 0 percent for
ECG 3 to 68.6 percent for ECG 2. The
share of motors already at TSL 2
efficiency levels varies by equipment
class group and by horsepower range
(from 0 to 62 percent). For ECG 1, which
represents the most significant share of
the market, about 30 percent of motors
meet the TSL 2 levels.
At TSL 2, the projected change in
INPV ranges from a decrease of $283.5
million to an increase of $388 million.
If the decrease of $283.5 million were to
occur, TSL 2 could result in a net loss
of 8.4 percent in INPV to manufacturers
of covered electric motors.
After considering the analysis and
weighing the benefits and the burdens,
DOE has tentatively concluded that at
TSL 2 for electric motors, the benefits of
energy savings, positive NPV of
customer benefit, positive impacts on
consumers (as indicated by positive
weighted average LCC savings for all
ECGs impacted at TSL 2, favorable
PBPs, and the large percentage of
customers who would experience LCC
benefits, emission reductions, and the
estimated monetary value of the
emissions reductions would outweigh
the slight increase in the cumulative
regulatory burden on manufacturers and
the risk of small negative impacts if
manufacturers are unable to recoup
investments made to meet the standard.
In particular, the Secretary of Energy
has concluded that TSL 2 would save a
significant amount of energy and is
technologically feasible and
economically justified.
In addition, DOE notes that TSL 2
most closely corresponds to the
standards that were proposed by the
Motor Coalition, as described in section
II.B.2. Based on the above
considerations, DOE today proposes to
adopt the energy conservation standards
for electric motors at TSL 2. Table V.24
through Table V.27 present the
proposed energy conservation standards
for electric motors.
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
TABLE V.24—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC
MOTORS
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor
horsepower/standard
kilowatt equivalent
2 Pole
Enclosed
1/.75 .................................
1.5/1.1 ..............................
2/1.5 .................................
VerDate Mar<15>2010
20:13 Dec 05, 2013
77.0
84.0
85.5
Jkt 232001
4 Pole
Open
Enclosed
77.0
84.0
85.5
PO 00000
Frm 00078
85.5
86.5
86.5
Fmt 4701
6 Pole
Open
Enclosed
85.5
86.5
86.5
Sfmt 4702
82.5
87.5
88.5
E:\FR\FM\06DEP2.SGM
8 Pole
Open
82.5
86.5
87.5
06DEP2
Enclosed
75.5
78.5
84.0
Open
75.5
77.0
86.5
73667
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE V.24—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN A AND NEMA DESIGN B ELECTRIC
MOTORS—Continued
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor
horsepower/standard
kilowatt equivalent
2 Pole
Enclosed
3/2.2 .................................
5/3.7 .................................
7.5/5.5 ..............................
10/7.5 ...............................
15/11 ................................
20/15 ................................
25/18.5 .............................
30/22 ................................
40/30 ................................
50/37 ................................
60/45 ................................
75/55 ................................
100/75 ..............................
125/90 ..............................
150/110 ............................
200/150 ............................
250/186 ............................
300/224 ............................
350/261 ............................
400/298 ............................
450/336 ............................
500/373 ............................
4 Pole
Open
86.5
88.5
89.5
90.2
91.0
91.0
91.7
91.7
92.4
93.0
93.6
93.6
94.1
95.0
95.0
95.4
95.8
95.8
95.8
95.8
95.8
95.8
Enclosed
85.5
86.5
88.5
89.5
90.2
91.0
91.7
91.7
92.4
93.0
93.6
93.6
93.6
94.1
94.1
95.0
95.0
95.4
95.4
95.8
96.2
96.2
6 Pole
Open
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
94.1
94.5
95.0
95.4
95.4
95.4
95.8
96.2
96.2
96.2
96.2
96.2
96.2
96.2
Enclosed
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.8
95.8
95.8
95.8
95.8
95.8
96.2
96.2
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
94.1
94.1
94.5
94.5
95.0
95.0
95.8
95.8
95.8
95.8
95.8
95.8
95.8
95.8
8 Pole
Open
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
94.1
94.1
94.5
94.5
95.0
95.0
95.4
95.4
95.8
95.8
95.8
95.8
96.2
96.2
Enclosed
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
91.7
92.4
92.4
93.6
93.6
94.1
94.1
94.5
95.0
95.0
95.0
95.0
95.0
95.0
Open
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
91.7
92.4
93.0
94.1
94.1
94.1
94.1
94.1
95.0
95.0
95.0
95.0
95.0
95.0
TABLE V.25—PROPOSED ENERGY CONSERVATION STANDARDS FOR NEMA DESIGN C ELECTRIC MOTORS
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor
horsepower/standard
kilowatt equivalent
4 Pole
Enclosed
1/.75 .................................................................................
1.5/1.1 ..............................................................................
2/1.5 .................................................................................
3/2.2 .................................................................................
5/3.7 .................................................................................
7.5/5.5 ..............................................................................
10/7.5 ...............................................................................
15/11 ................................................................................
20/15 ................................................................................
25/18.5 .............................................................................
30/22 ................................................................................
40/30 ................................................................................
50/37 ................................................................................
60/45 ................................................................................
75/55 ................................................................................
100/75 ..............................................................................
125/90 ..............................................................................
150/110 ............................................................................
200/150 ............................................................................
6 Pole
Open
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
94.1
94.5
95.0
95.4
95.4
95.4
95.8
96.2
Enclosed
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.8
95.8
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
94.1
94.1
94.5
94.5
95.0
95.0
95.8
95.8
8 Pole
Open
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
94.1
94.1
94.5
94.5
95.0
95.0
95.4
95.4
Enclosed
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
91.7
92.4
92.4
93.6
93.6
94.1
94.1
94.5
Open
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
91.7
92.4
93.0
94.1
94.1
94.1
94.1
94.1
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
TABLE V.26—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor
horsepower/standard
kilowatt equivalent
2 Pole
Enclosed
1/.75 .................................
1.5/1.1 ..............................
2/1.5 .................................
VerDate Mar<15>2010
18:00 Dec 05, 2013
75.5
82.5
84.0
Jkt 232001
4 Pole
Open
Enclosed
75.5
82.5
84.0
PO 00000
Frm 00079
82.5
84.0
84.0
Fmt 4701
6 Pole
Open
Enclosed
82.5
84.0
84.0
Sfmt 4702
80.0
85.5
86.5
E:\FR\FM\06DEP2.SGM
8 Pole
Open
80.0
84.0
85.5
06DEP2
Enclosed
74.0
77.0
82.5
Open
74.0
75.5
85.5
73668
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE V.26—PROPOSED ENERGY CONSERVATION STANDARDS FOR FIRE PUMP ELECTRIC MOTORS—Continued
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor
horsepower/standard
kilowatt equivalent
2 Pole
Enclosed
3/2.2 .................................
5/3.7 .................................
7.5/5.5 ..............................
10/7.5 ...............................
15/11 ................................
20/15 ................................
25/18.5 .............................
30/22 ................................
40/30 ................................
50/37 ................................
60/45 ................................
75/55 ................................
100/75 ..............................
125/90 ..............................
150/110 ............................
200/150 ............................
250/186 ............................
300/224 ............................
350/261 ............................
400/298 ............................
450/336 ............................
500/373 ............................
4 Pole
Open
85.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.5
94.5
95.0
95.4
95.4
95.4
95.4
95.4
95.4
Enclosed
84.0
85.5
87.5
88.5
89.5
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.0
93.6
93.6
94.5
94.5
95.0
95.0
95.4
95.8
95.8
6 Pole
Open
87.5
87.5
89.5
89.5
91.0
91.0
92.4
92.4
93.0
93.0
93.6
94.1
94.5
94.5
95.0
95.0
95.0
95.4
95.4
95.4
95.4
95.8
Enclosed
86.5
87.5
88.5
89.5
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.4
95.4
95.8
95.8
8 Pole
Open
87.5
87.5
89.5
89.5
90.2
90.2
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.1
95.0
95.0
95.0
95.0
95.0
95.0
95.0
95.0
Enclosed
86.5
87.5
88.5
90.2
90.2
91.0
91.7
92.4
93.0
93.0
93.6
93.6
94.1
94.1
94.5
94.5
95.4
95.4
95.4
95.4
95.4
95.4
Open
84.0
85.5
85.5
88.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.5
94.5
94.5
94.5
94.5
94.5
86.5
87.5
88.5
89.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.6
93.6
93.6
93.6
93.6
94.5
94.5
94.5
94.5
94.5
94.5
TABLE V.27—PROPOSED ENERGY CONSERVATION STANDARDS FOR BRAKE MOTORS
[Compliance starting December 19, 2015]
Nominal full load efficiency (%)
Motor
horsepower/standard
kilowatt equivalent
4 Pole
Enclosed
1/.75 .................................
1.5/1.1 ..............................
2/1.5 .................................
3/2.2 .................................
5/3.7 .................................
7.5/5.5 ..............................
10/7.5 ...............................
15/11 ................................
20/15 ................................
25/18.5 .............................
30/22 ................................
6 Pole
Open
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
Enclosed
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
8 Pole
Open
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
2. Summary of Benefits and Costs
(Annualized) of the Proposed Standards
benefits of emission reductions,
including CO2 emission reductions.89
The benefits and costs of today’s
proposed standards, for equipment sold
in 2015–2044, can also be expressed in
terms of annualized values. The
annualized monetary values are the sum
of: (1) The annualized national
economic value of the benefits from
consumer operation of equipment that
meet the proposed standards (consisting
primarily of operating cost savings from
using less energy, minus increases in
equipment purchase and installation
costs, which is another way of
representing consumer NPV), and (2)
the annualized monetary value of the
89 DOE used a two-step calculation process to
convert the time-series of costs and benefits into
annualized values. First, DOE calculated a present
value in 2013, the year used for discounting the
NPV of total consumer costs and savings, for the
time-series of costs and benefits using discount
rates of three and seven percent for all costs and
benefits except for the value of CO2 reductions. For
the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE
then calculated the fixed annual payment over a 30year period (2015 through 2044) that yields the
same present value. The fixed annual payment is
the annualized value. Although DOE calculated
annualized values, this does not imply that the
time-series of cost and benefits from which the
annualized values were determined is a steady
stream of payments.
VerDate Mar<15>2010
18:00 Dec 05, 2013
Jkt 232001
PO 00000
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Fmt 4701
Sfmt 4702
Enclosed
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
Open
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
Although combining the values of
operating savings and CO2 emission
reductions provides a useful
perspective, two issues should be
considered. First, the national operating
savings are domestic U.S. consumer
monetary savings that occur as a result
of market transactions while the value
of CO2 reductions is based on a global
value. Second, the assessments of
operating cost savings and CO2 savings
are performed with different methods
that use different time frames for
analysis. The national operating cost
savings is measured for the lifetime of
electric motors shipped in 2015 –2044.
The SCC values, on the other hand,
reflect the present value of some future
E:\FR\FM\06DEP2.SGM
06DEP2
73669
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
climate-related impacts resulting from
the emission of one ton of carbon
dioxide in each year. These impacts
continue well beyond 2100.
Estimates of annualized benefits and
costs of the proposed standards for
electric motors are shown in Table V.28.
The results under the primary estimate
are as follows. Using a 7-percent
discount rate for benefits and costs other
than CO2 reduction, for which DOE
used a 3-percent discount rate along
with the average SCC series that uses a
3-percent discount rate, the cost of the
standards proposed in today’s rule is
$462 million per year in increased
equipment costs; while the estimated
benefits are $1,114 million per year in
reduced equipment operating costs,
$586 million in CO2 reductions, and
$21.5 million in reduced NOX
emissions. In this case, the net benefit
would amount to $957 million per year.
Using a 3-percent discount rate for all
benefits and costs and the average SCC
series, the estimated cost of the
standards proposed in today’s rule is
$577 million per year in increased
equipment costs; while the estimated
benefits are $1,730 million per year in
reduced operating costs, $586 million in
CO2 reductions, and $31.5 million in
reduced NOX emissions. In this case, the
net benefit would amount to
approximately $1,354 million per year.
TABLE V.28—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR ELECTRIC MOTORS
[million 2012$/year]
Discount rate
Benefits:
Consumer Operating Cost Savings ..............
CO2 Reduction Monetized Value ($11.8/t
case) *.
CO2 Reduction Monetized Value ($39.7/t
case) *.
CO2 Reduction Monetized Value ($61.2/t
case) *.
CO2 Reduction Monetized Value $117.0/t
case) *.
NOX Reduction Monetized Value (at $2,639/
ton) **.
Total Benefits † ......................................
Costs:
Consumer Incremental Equipment Costs .....
Primary
estimate *
Low Net
benefits
estimate *
7% ...............................
3% ...............................
5% ...............................
1,114 ...........................
1,730 ...........................
155 ..............................
924 ..............................
1,421 ...........................
134 ..............................
1,358.
2,134.
179.
3% ...............................
586 ..............................
506 ..............................
679.
2.5% ............................
882 ..............................
762 ..............................
1022.
3% ...............................
1,811 ...........................
1,565 ...........................
2,098.
7% ...............................
21.46 ...........................
18.55 ...........................
24.68.
3%
7%
7%
3%
3%
31.48
1,290
1,721
1,916
2,347
27.20
1,077
1,449
1,583
1,955
36.39.
1,562 to 3,481.
2,061.
2,350 to 4,268.
2,849.
...............................
plus CO2 range ....
...............................
plus CO2 range ....
...............................
...........................
to 2,947 ............
...........................
to 3,572 ............
...........................
...........................
to 2,507 ............
...........................
to 3,014 ............
...........................
High Net
benefits
estimate *
7% ...............................
3% ...............................
462 ..............................
577 ..............................
492 ..............................
601 ..............................
447.
569.
7%
7%
3%
3%
585 to 2,016 ...............
957 ..............................
982 to 2,413 ...............
1,354 ...........................
1,115
1,614
1,781
2,280
1,353 to 3,438.
1,887.
1,957 to 4,043.
2,492.
Net Benefits:
Total † ....................................................
plus CO2 range ....
...............................
plus CO2 range ....
...............................
to 3,033 ............
...........................
to 3,700 ............
...........................
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* This table presents the annualized costs and benefits associated with electric motors shipped in 2015–2044. These results include benefits to
consumers which accrue after 2044 from the equipment purchased in years 2015–2044. Costs incurred by manufacturers, some of which may
be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The Primary,
Low Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy Outlook (AEO) 2013 Reference
case, Low Estimate, and High Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected equipment
price in the Primary Estimate, a decline rate for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC
from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile
SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature
change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate
an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount
rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled
discount rate, and those values are added to the full range of CO2 values.
VI. Procedural Issues and Regulatory
Review
A. Review Under Executive Orders
12866 and 13563
Section 1(b)(1) of Executive Order
12866, ‘‘Regulatory Planning and
Review,’’ 58 FR 51735 (Oct. 4, 1993),
requires each agency to identify the
problem that it intends to address,
including, where applicable, the failures
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of private markets or public institutions
that warrant new agency action, as well
as to assess the significance of that
problem. The problems that today’s
standards address are as follows:
(1) There are external benefits
resulting from improved energy
efficiency of covered electric motors
which are not captured by the users of
such equipment. These benefits include
externalities related to environmental
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protection and energy security that are
not reflected in energy prices, such as
emissions of greenhouse gases. DOE
attempts to quantify some of the
external benefits through use of Social
Cost of Carbon values.
In addition, DOE has determined that
today’s regulatory action is an
‘‘economically significant regulatory
action’’ under section 3(f)(1) of
Executive Order 12866. Accordingly,
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section 6(a)(3) of the Executive Order
requires that DOE prepare a regulatory
impact analysis (RIA) on today’s rule
and that the Office of Information and
Regulatory Affairs (OIRA) in the Office
of Management and Budget (OMB)
review this rule. DOE presented to OIRA
for review the draft rule and other
documents prepared for this
rulemaking, including the RIA, and has
included these documents in the
rulemaking record. The assessments
prepared pursuant to Executive Order
12866 can be found in the technical
support document for this rulemaking.
DOE has also reviewed this regulation
pursuant to Executive Order 13563,
issued on January 18, 2011 (76 FR 3281,
Jan. 21, 2011). EO 13563 is
supplemental to and explicitly reaffirms
the principles, structures, and
definitions governing regulatory review
established in Executive Order 12866.
To the extent permitted by law, agencies
are required by Executive Order 13563
to: (1) Propose or adopt a regulation
only upon a reasoned determination
that its benefits justify its costs
(recognizing that some benefits and
costs are difficult to quantify); (2) tailor
regulations to impose the least burden
on society, consistent with obtaining
regulatory objectives, taking into
account, among other things, and to the
extent practicable, the costs of
cumulative regulations; (3) select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits (including
potential economic, environmental,
public health and safety, and other
advantages; distributive impacts; and
equity); (4) to the extent feasible, specify
performance objectives, rather than
specifying the behavior or manner of
compliance that regulated entities must
adopt; and (5) identify and assess
available alternatives to direct
regulation, including providing
economic incentives to encourage the
desired behavior, such as user fees or
marketable permits, or providing
information upon which choices can be
made by the public.
DOE emphasizes as well that
Executive Order 13563 requires agencies
to use the best available techniques to
quantify anticipated present and future
benefits and costs as accurately as
possible. In its guidance, the Office of
Information and Regulatory Affairs has
emphasized that such techniques may
include identifying changing future
compliance costs that might result from
technological innovation or anticipated
behavioral changes. For the reasons
stated in the preamble, DOE believes
that today’s NOPR is consistent with
these principles, including the
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requirement that, to the extent
permitted by law, benefits justify costs
and that net benefits are maximized.
B. Review Under the Regulatory
Flexibility Act
The Regulatory Flexibility Act (5
U.S.C. 601 et seq.) requires preparation
of an initial regulatory flexibility
analysis (IRFA) for any rule that by law
must be proposed for public comment,
unless the agency certifies that the rule,
if promulgated, will not have a
significant economic impact on a
substantial number of small entities. As
required by Executive Order 13272,
‘‘Proper Consideration of Small Entities
in Agency Rulemaking,’’ 67 FR 53461
(August 16, 2002), DOE published
procedures and policies on February 19,
2003, to ensure that the potential
impacts of its rules on small entities are
properly considered during the
rulemaking process. 68 FR 7990 DOE
has made its procedures and policies
available on the Office of the General
Counsel’s Web site (https://energy.gov/
gc/office-general-counsel).
DOE has prepared an IRFA for this
rulemaking, a copy of which DOE will
transmit to the Chief Counsel for
Advocacy of the SBA for review under
5 U.S.C. 605(b). As presented and
discussed below, the IFRA describes
potential impacts on electric motors
manufacturers associated with capital
and product conversion costs and
discusses alternatives that could
minimize these impacts.
A statement of the objectives of, and
reasons and legal basis for, the proposed
rule are set forth elsewhere in the
preamble and not repeated here.
1. Description and Estimated Number of
Small Entities Regulated
a. Methodology for Estimating the
Number of Small Entities
For manufacturers of electric motors,
the Small Business Administration
(SBA) has set a size threshold, which
defines those entities classified as
‘‘small businesses’’ for the purposes of
the statute. DOE used the SBA’s small
business size standards to determine
whether any small entities would be
subject to the requirements of the rule.
The size standards are listed by North
American Industry Classification
System (NAICS) code and industry
description available at: https://
www.sba.gov/content/table-smallbusiness-size-standards. Electric motor
manufacturing is classified under
NAICS 335312, ‘‘Motor and Generator
Manufacturing.’’ The SBA sets a
threshold of 1,000 employees or less for
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an entity to be considered as a small
business for this category.
To estimate the number of companies
that could be small business
manufacturers of equipment covered by
this rulemaking, DOE conducted a
market survey using publicly available
information. DOE’s research involved
industry trade association membership
directories (including NEMA),
information from previous rulemakings,
UL qualification directories, individual
company Web sites, and market
research tools (e.g., Hoover’s reports).
DOE also asked stakeholders and
industry representatives if they were
aware of any other small manufacturers
during manufacturer interviews and
DOE public meetings. DOE used
information from these sources to create
a list of companies that potentially
manufacture electric motors covered by
this rulemaking. As necessary, DOE
contacted companies to determine
whether they met the SBA’s definition
of a small business manufacturer. DOE
screened out companies that do not
offer equipment covered by this
rulemaking, do not meet the definition
of a ‘‘small business,’’ or are foreign
owned and operated.
DOE initially identified 60 potential
manufacturers of electric motors sold in
the U.S. After reviewing publicly
available information DOE contacted 27
of the companies that DOE suspected
were small business manufacturers to
determine whether they met the SBA
definition of a small business and
whether they manufactured the
equipment that would be affected by
today’s proposal. Based on these efforts,
DOE estimates that there are 13 small
business manufacturers of electric
motors.
b. Manufacturer Participation
DOE contacted the 13 identified small
businesses to invite them to take part in
a small business manufacturer impact
analysis interview. Of the electric motor
manufacturers DOE contacted, 10
responded and three did not. Eight of
the 10 responding manufacturers
declined to be interviewed. Therefore,
DOE was able to reach and discuss
potential standards with two of the 13
small business manufacturers. DOE also
obtained information about small
business manufacturers and potential
impacts while interviewing large
manufacturers.
c. Electric Motor Industry Structure and
Nature of Competition
Eight major manufacturers supply
approximately 90 percent of the market
for electric motors. None of the major
manufacturers of electric motors
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covered in this rulemaking is a small
business. DOE estimates that
approximately 50 percent of the market
is served by imports. Many of the small
businesses that compete in the electric
motor market produce specialized
motors, many of which have not been
regulated under previous standards.
Most of these low-volume
manufacturers do not compete directly
with large manufacturers and tend to
occupy niche markets for their
equipment. There are a few small
business manufacturers that produce
general purpose motors; however, these
motors currently meet NEMA Premium
efficiency levels, the efficiency levels
being proposed in today’s notice.
d. Comparison Between Large and Small
Entities
For electric motors, small
manufacturers differ from large
manufacturers in several ways that
affect the extent to which a
manufacturer would be impacted by
proposed standards. Characteristics of
small manufacturers include: lower
production volumes, fewer engineering
resources, less technical expertise, and
less access to capital.
Lower production volumes lie at the
heart of most small business
disadvantages, particularly for a small
manufacturer that is vertically
integrated. A lower-volume
manufacturer’s conversion costs would
need to be spread over fewer units than
a larger competitor. Thus, unless the
small business can differentiate its
product in some way that earns a price
premium, the small business is a ‘price
taker’ and experiences a reduction in
profit per unit relative to the large
manufacturer. Therefore, because much
of the same equipment would need to be
purchased by both large and small
manufacturers in order to produce
electric motors at higher TSLs,
undifferentiated small manufacturers
would face a greater variable cost
penalty because they must depreciate
the one-time conversion expenditures
over fewer units.
Smaller companies are also more
likely to have more limited engineering
resources and they often operate with
lower levels of design and
manufacturing sophistication. Smaller
companies typically also have less
experience and expertise in working
with more advanced technologies.
Standards that required these
technologies could strain the
engineering resources of these small
manufacturers if they chose to maintain
a vertically integrated business model.
Small business electric motor
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manufacturers can also be at a
disadvantage due to their lack of
purchasing power for high performance
materials. For example, more expensive
low-loss steels are needed to meet
higher efficiency standards and steel
cost grows as a percentage of the overall
product cost. Small manufacturers who
pay higher per pound prices would be
disproportionately impacted by these
prices.
Lastly, small manufacturers typically
have less access to capital, which may
be needed by some to cover the
conversion costs associated with new
technologies.
2. Description and Estimate of
Compliance Requirements
In its market survey, DOE identified
three categories of small business
electric motor manufacturers that may
be impacted differently by today’s
proposed rule. The first group, which
includes approximately five of the 13
small businesses, consists of
manufacturers that produce specialty
motors that were not required to meet
previous Federal standards, but would
need to do so under the expanded scope
of today’s proposed rule. DOE believes
that this group would likely be the most
impacted by expanding the scope of
equipment required to meet NEMA
Premium efficiency levels. The second
group, which includes approximately
five different small businesses, consists
of manufacturers that produce a small
amount of covered equipment and
primarily focus on other types of motors
not covered in this rulemaking, such as
single-phase or direct-current motors.
Because generally less than 10 percent
of these manufacturers’ revenue comes
from covered equipment, DOE does not
believe new standards will substantially
impact their business. The third group,
which includes approximately three
small businesses, consists of
manufacturers that already offer NEMA
Premium general purpose and specialty
motors. DOE expects these
manufacturers to face similar
conversion costs as large manufacturers,
in that they will not experience high
capital conversion costs as they already
have the design and production
experience necessary to bring their
motors up to NEMA Premium efficiency
levels. It is likely, however, that some of
the specialty equipment these
manufacturers produce will be included
in the expanded scope of this proposed
rule and is likely to result in these small
businesses incurring additional
certification and testing costs. These
manufacturers could also face product
development costs if they have to
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redesign any motors that are not
currently meeting the NEMA Premium
level.
At TSL 2, the level proposed in
today’s notice, DOE estimates capital
conversion costs of $1.88 million and
product conversion costs of $3.75
million for a typical small manufacturer
in the first group (manufacturers that
produce specialized motors previously
not covered by Federal standards).
Meanwhile, DOE estimates a typical
large manufacturer would incur capital
and product conversion costs of $3.29
million and $7.25 million, respectively,
at the same TSL. Small manufacturers
that predominately produce specialty
motors would face higher relative
capital conversion costs at TSL 2 than
large manufacturers because large
manufacturers have been independently
pursuing higher efficiency motors as a
result of the efficiency standards
prescribed by EISA 2007 (10 CFR part
431.25) and consequently have built up
more design and production experience.
Large manufacturers have also been
innovating as a result of the small
electric motors rulemaking at 75 FR
10874 (March 9, 2010), which exempted
many of the specialized equipment that
these small business manufacturers
produce. Many large manufacturers of
general purpose motors offer equipment
that was covered by the 2010 small
electric motors rule, as well as
equipment that falls under this
proposed rule. Small manufactures
pointed out that this would give large
manufacturers an advantage in that they
already have experience with the
technology necessary to redesign their
equipment and are familiar with the
steps they will have to take to upgrade
their manufacturing equipment and
processes. Small manufactures, whose
specialized motors were not required to
meet the standards prescribed by the
small electric motors rule and EISA
2007 have not undergone these
processes and, therefore, would have to
put more time and resources into
redesign efforts.
The small businesses whose product
lines consist of a high percentage of
equipment that are not currently
required to meet efficiency standards
would need to make significant capital
investments relative to large
manufacturers to upgrade their
production lines with equipment
necessary to produce NEMA Premium
motors. As Table VI.1 illustrates, these
manufacturers would have to drastically
increase their capital expenditures to
purchase new lamination die sets, and
new winding and stacking equipment.
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TABLE VI.1—ESTIMATED CAPITAL AND PRODUCT CONVERSION COSTS AS A PERCENTAGE OF ANNUAL CAPITAL
EXPENDITURES AND R&D EXPENSE
Capital conversion
cost as a percentage of annual
capital
expenditures
(%)
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Typical Large Manufacturer .......................................................................................
Typical Small Manufacturer .......................................................................................
Table VI.1 also illustrates that small
manufacturers whose product lines
contain many motors that are not
currently required to meet Federal
standards face high relative product
conversion costs compared to large
manufacturers, despite the lower dollar
value. In interviews, these small
manufacturers expressed concern that
they would face a large learning curve
relative to large manufacturers, due to
the fact that many of the equipment they
produce has not had to meet Federal
standards. In its market survey, DOE
learned that for some manufacturers, the
expanded scope of specialized motors
that would have to meet NEMA
Premium could affect nearly half the
equipment they offer. They would need
to hire additional engineers and would
have to spend considerable time and
resources redesigning their equipment
and production processes. DOE does not
expect the small businesses that already
manufacture NEMA Premium
equipment or those that offer very few
alternating-current motors to incur these
high costs.
Manufacturers also expressed concern
about testing and certification costs
associated with new standards. They
pointed out that these costs are
particularly burdensome on small
businesses that produce a wide variety
of specialized equipment. As a result of
the wide variety of equipment they
produce and their relatively low output,
small manufacturers are forced to certify
multiple small batches of motors, the
costs of which need to be spread out
over far fewer units than large
manufacturers.
Small manufacturers that produce
equipment not currently required to
meet efficiency standards also pointed
out that they would face significant
challenges supporting current business
while making changes to their
production lines. While large
manufacturers could shift production of
certain equipment to different plants or
product lines while they made updates,
small businesses would have limited
options. Most of these small businesses
have only one plant and would have to
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14
188
find a way to continue to fulfill
customer needs while redesigning
production lines and installing new
equipment. In interviews with DOE,
small manufacturers said that it would
be difficult to quantify the impacts that
downtime and the possible need for
external support could have on their
businesses.
3. Duplication, Overlap, and Conflict
With Other Rules and Regulations
DOE is not aware of any rules or
regulations that duplicate, overlap, or
conflict with the rule being considered
today.
4. Significant Alternatives to the
Proposed Rule
The discussion above analyzes
impacts on small businesses that would
result from the TSL DOE is proposing in
today’s notice. Though TSLs lower than
the proposed TSL are expected to
reduce the impacts on small entities,
DOE is required by EPCA to establish
standards that achieve the maximum
improvement in energy efficiency that
are technically feasible and
economically justified, and result in a
significant conservation of energy.
Therefore, DOE rejected the lower TSLs.
In addition to the other TSLs being
considered, the NOPR TSD includes a
regulatory impact analysis in chapter
17. For electric motors, this report
discusses the following policy
alternatives: (1) Consumer rebates, (2)
consumer tax credits, and (3)
manufacturer tax credits. DOE does not
intend to consider these alternatives
further because they either are not
feasible to implement or are not
expected to result in energy savings as
large as those that would be achieved by
the standard levels under consideration.
DOE continues to seek input from
businesses that would be affected by
this rulemaking and will consider
comments received in the development
of any final rule.
5. Significant Issues Raised by Public
Comments
DOE’s MIA suggests that, while TSL
2 presents greater difficulties for small
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Product conversion cost as a
percentage of
annual R&D
expense
(%)
31
490
Total conversion
cost as a percentage of annual
revenue
(%)
2
75
businesses than lower efficiency levels,
the business impacts at higher TSLs
would be greater. DOE expects that most
small businesses will generally be able
to maintain profitability at the TSL
proposed in today’s rulemaking. It is
possible, however, that the small
manufacturers whose product lines
consist of a high percentage of
previously exempted motors could
incur significant costs as a result of this
proposed rule, and those high costs
could endanger their business. DOE’s
MIA is based on its interviews of both
small and large manufacturers, and
consideration of small business impacts
explicitly enters into DOE’s choice of
the TSLs proposed in this NOPR.
DOE did not receive any public
comments suggesting that small
businesses would not be able to achieve
the efficiency levels at TSL 2.
C. Review Under the Paperwork
Reduction Act
Manufacturers of electric motors that
are currently subject to energy
conservation standards must certify to
DOE that their equipment comply with
any applicable energy conservation
standards. In certifying compliance,
manufacturers must test their
equipment according to the DOE test
procedures for electric motors,
including any amendments adopted for
those test procedures. The collection-ofinformation requirement for the
certification and recordkeeping is
subject to review and approval by OMB
under the Paperwork Reduction Act
(PRA). This requirement has been
approved by OMB under OMB control
number 1910–1400. Public reporting
burden for the certification is estimated
to average 20 hours per response,
including the time for reviewing
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
DOE intends to address revised
certification requirements for electric
motors in a separate rulemaking.
Notwithstanding any other provision
of the law, no person is required to
respond to, nor shall any person be
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subject to a penalty for failure to comply
with, a collection of information subject
to the requirements of the PRA, unless
that collection of information displays a
currently valid OMB Control Number.
D. Review Under the National
Environmental Policy Act of 1969
Pursuant to the National
Environmental Policy Act (NEPA) of
1969, DOE has determined that the
proposed rule fits within the category of
actions included in Categorical
Exclusion (CX) B5.1 and otherwise
meets the requirements for application
of a CX. See 10 CFR Part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B,
B(1)–(5). The proposed rule fits within
the category of actions because it is a
rulemaking that establishes energy
conservation standards for consumer
products or industrial equipment, and
for which none of the exceptions
identified in CX B5.1(b) apply.
Therefore, DOE has made a CX
determination for this rulemaking, and
DOE does not need to prepare an
Environmental Assessment or
Environmental Impact Statement for
this proposed rule. DOE’s CX
determination for this proposed rule is
available at https://cxnepa.energy.gov/.
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E. Review Under Executive Order 13132
Executive Order 13132, ‘‘Federalism.’’
64 FR 43255 (Aug. 10, 1999) imposes
certain requirements on Federal
agencies formulating and implementing
policies or regulations that preempt
State law or that have Federalism
implications. The Executive Order
requires agencies to examine the
constitutional and statutory authority
supporting any action that would limit
the policymaking discretion of the
States and to carefully assess the
necessity for such actions. The
Executive Order also requires agencies
to have an accountable process to
ensure meaningful and timely input by
State and local officials in the
development of regulatory policies that
have Federalism implications. On
March 14, 2000, DOE published a
statement of policy describing the
intergovernmental consultation process
it will follow in the development of
such regulations. 65 FR 13735. EPCA
governs and prescribes Federal
preemption of State regulations as to
energy conservation for the equipment
that are the subject of today’s proposed
rule. States can petition DOE for
exemption from such preemption to the
extent, and based on criteria, set forth in
EPCA. (42 U.S.C. 6297) No further
action is required by Executive Order
13132.
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F. Review Under Executive Order 12988
With respect to the review of existing
regulations and the promulgation of
new regulations, section 3(a) of
Executive Order 12988, ‘‘Civil Justice
Reform,’’ imposes on Federal agencies
the general duty to adhere to the
following requirements: (1) Eliminate
drafting errors and ambiguity; (2) write
regulations to minimize litigation; and
(3) provide a clear legal standard for
affected conduct rather than a general
standard and promote simplification
and burden reduction. 61 FR 4729 (Feb.
7, 1996). Section 3(b) of Executive Order
12988 specifically requires that
Executive agencies make every
reasonable effort to ensure that the
regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly
specifies any effect on existing Federal
law or regulation; (3) provides a clear
legal standard for affected conduct
while promoting simplification and
burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. Section 3(c) of Executive Order
12988 requires Executive agencies to
review regulations in light of applicable
standards in section 3(a) and section
3(b) to determine whether they are met
or it is unreasonable to meet one or
more of them. DOE has completed the
required review and determined that, to
the extent permitted by law, this
proposed rule meets the relevant
standards of Executive Order 12988.
G. Review Under the Unfunded
Mandates Reform Act of 1995
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA) requires
each Federal agency to assess the effects
of Federal regulatory actions on State,
local, and Tribal governments and the
private sector. Public Law 104–4, sec.
201 (codified at 2 U.S.C. 1531). For a
proposed regulatory action likely to
result in a rule that may cause the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
in any one year (adjusted annually for
inflation), section 202 of UMRA requires
a Federal agency to publish a written
statement that estimates the resulting
costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a), (b))
The UMRA also requires a Federal
agency to develop an effective process
to permit timely input by elected
officers of State, local, and Tribal
governments on a proposed ‘‘significant
intergovernmental mandate,’’ and
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requires an agency plan for giving notice
and opportunity for timely input to
potentially affected small governments
before establishing any requirements
that might significantly or uniquely
affect small governments. On March 18,
1997, DOE published a statement of
policy on its process for
intergovernmental consultation under
UMRA. 62 FR 12820. DOE’s policy
statement is also available at https://
energy.gov/gc/downloads/unfundedmandates-reform-actintergovernmental-consultation.
Although today’s proposed rule does
not contain a Federal intergovernmental
mandate, it may require expenditures of
$100 million or more on the private
sector. Specifically, the proposed rule
will likely result in a final rule that
could require expenditures of $100
million or more. Such expenditures may
include: (1) Investment in research and
development and in capital
expenditures by electric motor
manufacturers in the years between the
final rule and the compliance date for
the new standards, and (2) incremental
additional expenditures by consumers
to purchase higher-efficiency electric
motors, starting at the compliance date
for the applicable standard.
Section 202 of UMRA authorizes a
Federal agency to respond to the content
requirements of UMRA in any other
statement or analysis that accompanies
the proposed rule. 2 U.S.C. 1532(c). The
content requirements of section 202(b)
of UMRA relevant to a private sector
mandate substantially overlap the
economic analysis requirements that
apply under section 325(o) of EPCA and
Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of
the NOPR and the ‘‘Regulatory Impact
Analysis’’ section of the TSD for this
proposed rule respond to those
requirements.
Under section 205 of UMRA, the
Department is obligated to identify and
consider a reasonable number of
regulatory alternatives before
promulgating a rule for which a written
statement under section 202 is required.
2 U.S.C. 1535(a). DOE is required to
select from those alternatives the most
cost-effective and least burdensome
alternative that achieves the objectives
of the proposed rule unless DOE
publishes an explanation for doing
otherwise, or the selection of such an
alternative is inconsistent with law. As
required by 42 U.S.C. 6295(d), (f), and
(o) and 6316(a), today’s proposed rule
would establish energy conservation
standards for electric motors that are
designed to achieve the maximum
improvement in energy efficiency that
DOE has determined to be both
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technologically feasible and
economically justified. A full discussion
of the alternatives considered by DOE is
presented in the ‘‘Regulatory Impact
Analysis’’ section of the TSD for today’s
proposed rule.
H. Review Under the Treasury and
General Government Appropriations
Act, 1999
Section 654 of the Treasury and
General Government Appropriations
Act, 1999 (Pub. L. 105–277) requires
Federal agencies to issue a Family
Policymaking Assessment for any rule
that may affect family well-being. This
proposed rule would not have any
impact on the autonomy or integrity of
the family as an institution.
Accordingly, DOE has concluded that it
is not necessary to prepare a Family
Policymaking Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive
Order 12630, ‘‘Governmental Actions
and Interference with Constitutionally
Protected Property Rights’’ 53 FR 8859
(Mar. 18, 1988), that this proposed
regulation would not result in any
takings that might require compensation
under the Fifth Amendment to the U.S.
Constitution.
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J. Review Under the Treasury and
General Government Appropriations
Act, 2001
Section 515 of the Treasury and
General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note)
provides for Federal agencies to review
most disseminations of information to
the public under guidelines established
by each agency pursuant to general
guidelines issued by OMB. OMB’s
guidelines were published at 67 FR
8452 (Feb. 22, 2002), and DOE’s
guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed
today’s NOPR under the OMB and DOE
guidelines and has concluded that it is
consistent with applicable policies in
those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ‘‘Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution, or Use’’ 66 FR 28355 (May
22, 2001), requires Federal agencies to
prepare and submit to OIRA at OMB, a
Statement of Energy Effects for any
proposed significant energy action. A
‘‘significant energy action’’ is defined as
any action by an agency that
promulgates or is expected to lead to
promulgation of a final rule, and that:
(1) Is a significant regulatory action
under Executive Order 12866, or any
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successor order; and (2) is likely to have
a significant adverse effect on the
supply, distribution, or use of energy, or
(3) is designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be implemented,
and of reasonable alternatives to the
action and their expected benefits on
energy supply, distribution, and use.
DOE has tentatively concluded that
today’s proposed regulatory action,
which sets forth potential energy
conservation standards for commercial
and industrial electric motors, is not a
significant energy action because the
proposed standards are not likely to
have a significant adverse effect on the
supply, distribution, or use of energy,
nor has it been designated as such by
the Administrator at OIRA. Accordingly,
DOE has not prepared a Statement of
Energy Effects on the proposed rule.
L. Review Under the Information
Quality Bulletin for Peer Review
On December 16, 2004, OMB, in
consultation with the Office of Science
and Technology Policy (OSTP), issued
its Final Information Quality Bulletin
for Peer Review (the Bulletin). 70 FR
2664 (Jan. 14, 2005). The Bulletin
establishes that certain scientific
information shall be peer reviewed by
qualified specialists before it is
disseminated by the Federal
Government, including influential
scientific information related to agency
regulatory actions. The purpose of the
bulletin is to enhance the quality and
credibility of the Government’s
scientific information. Under the
Bulletin, the energy conservation
standards rulemaking analyses are
‘‘influential scientific information,’’
which the Bulletin defines as scientific
information the agency reasonably can
determine will have, or does have, a
clear and substantial impact on
important public policies or private
sector decisions. 70 FR 2667.
In response to OMB’s Bulletin, DOE
conducted formal in-progress peer
reviews of the energy conservation
standards development process and
analyses and has prepared a Peer
Review Report pertaining to the energy
conservation standards rulemaking
analyses. Generation of this report
involved a rigorous, formal, and
documented evaluation using objective
criteria and qualified and independent
reviewers to make a judgment as to the
technical/scientific/business merit, the
actual or anticipated results, and the
productivity and management
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effectiveness of programs and/or
projects. The ‘‘Energy Conservation
Standards Rulemaking Peer Review
Report’’ dated February 2007 has been
disseminated and is available at the
following Web site:
www1.eere.energy.gov/buildings/
appliance_standards/peer_review.html.
VII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the
public meeting are listed in the DATES
and ADDRESSES sections at the beginning
of this notice. If you plan to attend the
public meeting, please notify Ms.
Brenda Edwards at (202) 586–2945 or
Brenda.Edwards@ee.doe.gov. As
explained in the ADDRESSES section,
foreign nationals visiting DOE
Headquarters are subject to advance
security screening procedures.
In addition, you can attend the public
meeting via webinar. Webinar
registration information, participant
instructions, and information about the
capabilities available to webinar
participants will be published on DOE’s
Web site at: https://
www1.eere.energy.gov/buildings/
appliance_standards/rulemaking.aspx/
ruleid/42. Participants are responsible
for ensuring their systems are
compatible with the webinar software.
B. Procedure for Submitting Prepared
General Statements For Distribution
Any person who has plans to present
a prepared general statement may
request that copies of his or her
statement be made available at the
public meeting. Such persons may
submit requests, along with an advance
electronic copy of their statement in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format, to the appropriate address
shown in the ADDRESSES section at the
beginning of this notice. The request
and advance copy of statements must be
received at least one week before the
public meeting and may be emailed,
hand-delivered, or sent by mail. DOE
prefers to receive requests and advance
copies via email. Please include a
telephone number to enable DOE staff to
make follow-up contact, if needed.
C. Conduct of the Public Meeting
DOE will designate a DOE official to
preside at the public meeting and may
also use a professional facilitator to aid
discussion. The meeting will not be a
judicial or evidentiary-type public
hearing, but DOE will conduct it in
accordance with section 336 of EPCA
(42 U.S.C. 6306). A court reporter will
be present to record the proceedings and
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prepare a transcript. DOE reserves the
right to schedule the order of
presentations and to establish the
procedures governing the conduct of the
public meeting. After the public
meeting, interested parties may submit
further comments on the proceedings as
well as on any aspect of the rulemaking
until the end of the comment period.
The public meeting will be conducted
in an informal, conference style. DOE
will present summaries of comments
received before the public meeting,
allow time for prepared general
statements by participants, and
encourage all interested parties to share
their views on issues affecting this
rulemaking. Each participant will be
allowed to make a general statement
(within time limits determined by DOE),
before the discussion of specific topics.
DOE will allow, as time permits, other
participants to comment briefly on any
general statements.
At the end of all prepared statements
on a topic, DOE will permit participants
to clarify their statements briefly and
comment on statements made by others.
Participants should be prepared to
answer questions by DOE and by other
participants concerning these issues.
DOE representatives may also ask
questions of participants concerning
other matters relevant to this
rulemaking. The official conducting the
public meeting will accept additional
comments or questions from those
attending, as time permits. The
presiding official will announce any
further procedural rules or modification
of the above procedures that may be
needed for the proper conduct of the
public meeting.
A transcript of the public meeting will
be included in the docket, which can be
viewed as described in the Docket
section at the beginning of this notice.
In addition, any person may buy a copy
of the transcript from the transcribing
reporter.
D. Submission of Comments
DOE will accept comments, data, and
information regarding this proposed
rule before or after the public meeting,
but no later than the date provided in
the DATES section at the beginning of
this proposed rule. Interested parties
may submit comments, data, and other
information using any of the methods
described in the ADDRESSES section at
the beginning of this notice.
Submitting comments via
regulations.gov. The regulations.gov
Web page will require you to provide
your name and contact information.
Your contact information will be
viewable to DOE Building Technologies
staff only. Your contact information will
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not be publicly viewable except for your
first and last names, organization name
(if any), and submitter representative
name (if any). If your comment is not
processed properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment itself or in any
documents attached to your comment.
Any information that you do not want
to be publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Otherwise, persons viewing comments
will see only first and last names,
organization names, correspondence
containing comments, and any
documents submitted with the
comments.
Do not submit to regulations.gov
information for which disclosure is
restricted by statute, such as trade
secrets and commercial or financial
information (hereinafter referred to as
Confidential Business Information
(CBI)). Comments submitted through
regulations.gov cannot be claimed as
CBI. Comments received through the
Web site will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section below.
DOE processes submissions made
through regulations.gov before posting.
Normally, comments will be posted
within a few days of being submitted.
However, if large volumes of comments
are being processed simultaneously,
your comment may not be viewable for
up to several weeks. Please keep the
comment tracking number that
regulations.gov provides after you have
successfully uploaded your comment.
Submitting comments via email, hand
delivery/courier, or mail. Comments and
documents submitted via email, hand
delivery, or mail also will be posted to
regulations.gov. If you do not want your
personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information in a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. If you
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submit via mail or hand delivery/
courier, please provide all items on a
CD, if feasible. It is not necessary to
submit printed copies. No facsimiles
(faxes) will be accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, that are written in English, and
that are free of any defects or viruses.
Documents should not contain special
characters or any form of encryption
and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit via email, postal mail, or
hand delivery/courier two well-marked
copies: One copy of the document
marked confidential including all the
information believed to be confidential,
and one copy of the document marked
non-confidential with the information
believed to be confidential deleted.
Submit these documents via email or on
a CD, if feasible. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by or available from
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure; (6) when
such information might lose its
confidential character due to the
passage of time; and (7) why disclosure
of the information would be contrary to
the public interest.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
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information deemed to be exempt from
public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments
on any aspect of this proposal, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
1. DOE requests comment on the
potential impacts of new and amended
standards on small electric motor
manufacturers, especially regarding
DOE’s proposed expansion of scope of
covered electric motors.
2. DOE requests comment on whether
the proposed standards help resolve the
potential issue on which it had
previously issued clarification of
whether a [IEC] motor may be
considered to be subject to two
standards.
3. DOE seeks comment on any
additional sources of data that could be
used to establish the distribution of
electric motors across equipment class
groups.
4. DOE seeks comment on any
additional sources of data that could be
used to establish the distribution of
electric motors across sectors by
horsepower range and within each
equipment class group.
5. DOE seeks comment on any
additional sources for determining the
frequency of motor repair depending on
equipment class group and sector.
6. DOE seeks comment on any
additional sources of data on motor
lifetime that could be used to validate
DOE’s estimates of motor mechanical
lifetime and its method of estimating
lifetimes. DOE defines equipment
lifetime as the lesser of the age at which
electric motors are retired from service
or the equipment in which they are
embedded is retired. For the NIA, DOE
uses motor average lifetime in years
derived from motor mechanical lifetime
in hours (see Chapter 8, Section 8.2.3)
and from annual operating hours (see
Section 10.2.2.2). DOE based expected
equipment lifetime on discussions with
industry experts and developed a
distribution of typical lifetimes for
several categories of electric motors.
DOE welcomes further input on the
average equipment lifetimes for the LCC
and NIA analyses.
7. DOE seeks comment on the
estimated base case distribution of
product efficiencies and on any
additional sources of data.
8. DOE seeks comments on its
decision to use efficiency trends for
equipment class groups 1 and 4 and
constant efficiencies for equipment class
groups 2 and 3 over the analysis period.
Specifically, DOE would like comments
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on additional sources of data on trends
in efficiency improvement.
9. DOE seeks comment on any sources
of data that could be used to establish
the elasticity of electric motor
shipments with respect to changes in
purchase price.
10. DOE seeks comment on its scaled
values for MSPs. In particular, DOE
seeks comments on its methodology for
scaling MSP data from the
representative equipment classes to the
remaining equipment classes.
11. DOE seeks comment on the scaled
values for motor weights. In particular,
DOE seeks comments on its
methodology for scaling weight data
from the representative equipment
classes to the remaining equipment
classes.
12. DOE seeks comment on the trial
standard levels (TSLs) developed for the
NOPR.
13. DOE seeks comment on its
proposed compliance date of December
19, 2015.
14. DOE seeks comment on its
decision to analyze brake motors in a
separate equipment class group.
15. DOE seeks comment on its
decision to limit standards for brake
motors to 1–30 hp, and 4, 6, and 8 pole
configurations. DOE selected these
ratings after reviewing manufacturer
catalogs and only finding brake motors
in these configurations.
16. DOE seeks comment on its
decision to not screen out copper diecast copper rotor motors.
17. DOE seeks comment on the
availability of copper in the market to
manufacture die-cast copper rotor
motors on a ‘‘mass quantity’’ scale.
18. DOE seeks comment on its
decision to not screen out hand winding
in its analysis.
19. DOE seeks comment on its
estimation for labor hours for each
representative unit.
20. DOE seeks comments on the cost
to manufacturers to change their
product lines to meet EL3.
21. DOE seeks comments on the cost
to manufacturers to change their
product lines to meet EL4.
22. DOE is aware that motors used in
fire pump applications may carry
various definitions, including, but not
limited to, NEMA, IEC, and NFPA
designations. DOE requests comment on
its current definition of fire pump
motors, the suitability of that definition
for the United States market, and on its
advantages or disadvantages relative to
other potential definitions.
23. In DOE’s view any Design B or
IEC-equivalent motor that otherwise
satisfies the relevant NFPA
requirements would meet the fire pump
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electric motor definition in 10 CFR
431.12. To the extent that there is
confusion regarding this view, DOE
invites comments on this issue, along
with any data demonstrating whether
any IEC-equivalent motors are listed for
fire pump service either under the
NFPA 20 or another relevant industry
standard.
24. DOE seeks data on any other
subsets of 56-frame motors, particularly
those motors that are: (1) Enclosed
general purpose electric motors that
have a rating of under 1 horsepower and
(2) open, special or definite purpose
(inclusive) electric motors. The types of
data that DOE seeks include, but are not
limited to, the following categories:
Efficiency distribution; shipment
breakdown between horsepower ratings,
open and enclosed motors, and between
general and special and definite purpose
electric motors; and typical applications
that use these motors.
25. Currently, DOE’s reference case
projects that prices for future shipments
of motors will remain constant. DOE is
seeking input on the appropriateness of
this assumption.
26. DOE requests comment on
whether there are features or attributes
of the more energy-efficient electric
motors that manufacturers would
produce to meet the standards in this
proposed rule that might affect how
they would be used by consumers. DOE
requests comment specifically on how
any such effects should be weighed in
the choice of standards for the electric
motors for the final rule.
27. For this rulemaking, DOE
analyzed the effects of this proposal
assuming that the electric motors would
be available to purchase for 30 years and
undertook a sensitivity analysis using 9
years rather than 30 years of product
shipments. The choice of a 30-year
period of shipments is consistent with
the DOE analysis for other products and
commercial equipment. The choice of a
9-year period is a proxy for the timeline
in EPCA for the review of certain energy
conservation standards and potential
revision of and compliance with such
revised standards. We are seeking input,
information and data on whether there
are ways to further refine the analytic
timeline.
28. DOE solicits comment on the
application of the new SCC values used
to determine the social benefits of CO2
emissions reductions over the
rulemaking analysis period. (The
rulemaking analysis period covers from
2015 to 2044 plus the appropriated
number of years to account for the
lifetime of the equipment purchased
between 2015 and 2044.) In particular,
the agency solicits comment on the
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agency’s derivation of SCC values after
2050 where the agency applied the
average annual growth rate of the SCC
estimates in 2040–2050 associated with
each of the four sets of values.
29. DOE solicits comment on whether
its proposal presents a sufficiently broad
scope of regulatory coverage to help
ensure that significant energy savings
would be met or whether further
adjustments to the proposed scope—
whether to exclude certain categories or
to include others—are necessary.
30. DOE requests comment on the
nine characteristics listed in section
III.C and their appropriateness for
outlining scope of coverage.
VIII. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of today’s proposed rule.
List of Subjects in 10 CFR Part 431
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Commercial and industrial equipment,
Imports, Intergovernmental relations,
Reporting and recordkeeping
requirements, and Small businesses.
Issued in Washington, DC, on November
25, 2013.
David T. Danielson,
Assistant Secretary, Energy Efficiency and
Renewable Energy.
For the reasons set forth in the
preamble, DOE proposes to amend part
431 of chapter II of title 10 of the Code
of Federal Regulations, as set forth
below:
PART 431—ENERGY CONSERVATION
PROGRAM FOR CERTAIN
COMMERCIAL AND INDUSTRIAL
EQUIPMENT
§ 431.25 Energy conservation standards
and effective dates.
(a) Except as provided for fire pump
electric motors in paragraph (b) of this
section, each general purpose electric
motor (subtype I) with a power rating of
1 horsepower or greater, but not greater
than 200 horsepower, including a
NEMA Design B or an equivalent IEC
Design N motor that is a general purpose
electric motor (subtype I), manufactured
(alone or as a component of another
piece of equipment) on or after
December 19, 2010, but before
December 19, 2015, shall have a
nominal full-load efficiency that is not
less than the following:
1. The authority citation for part 431
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6317
■
2. Revise § 431.25 to read as follows:
TABLE 1—NOMINAL FULL-LOAD EFFICIENCIES OF GENERAL PURPOSE ELECTRIC MOTORS (SUBTYPE I), EXCEPT FIRE
PUMP ELECTRIC MOTORS
Nominal full-load efficiency
Motor horsepower/
standard kilowatt
equivalent
Open motors
(number of poles)
Enclosed motors
(number of poles)
6
2
6
4
2
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
94.1
94.1
94.5
94.5
95.0
95.0
95.4
95.4
1/.75
1.5/1.1
2/1.5
3/2.2
5/3.7
7.5/5.5
10/7.5
15/11
20/15
25/18.5
30/22
40/30
50/37
60/45
75/55
100/75
125/90
150/110
200/150
4
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.8
95.8
77.0
84.0
85.5
85.5
86.5
88.5
89.5
90.2
91.0
91.7
91.7
92.4
93.0
93.6
93.6
93.6
94.1
94.1
95.0
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
94.1
94.1
94.5
94.5
95.0
95.0
95.8
95.8
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
94.1
94.5
95.0
95.4
95.4
95.4
95.8
96.2
77.0
84.0
85.5
86.5
88.5
89.5
90.2
91.0
91.0
91.7
91.7
92.4
93.0
93.6
93.6
94.1
95.0
95.0
95.4
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(b) Each fire pump electric motor that
is a general purpose electric motor
(subtype I) or general purpose electric
motor (subtype II) manufactured (alone
or as a component of another piece of
equipment) on or after December 19,
2010, but before December 19, 2015,
shall have a nominal full-load efficiency
that is not less than the following:
TABLE 2—NOMINAL FULL-LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS
Nominal full-load efficiency
Motor
horsepower/
standard kilowatt
equivalent
Open motors
(number of poles)
Enclosed motors
(number of poles)
8
1/.75
1.5/1.1
VerDate Mar<15>2010
6
4
2
8
6
4
2
74.0
75.5
80.0
84.0
82.5
84.0
—
82.5
74.0
77.0
80.0
85.5
82.5
84.0
75.5
82.5
18:00 Dec 05, 2013
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73678
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE 2—NOMINAL FULL-LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS—Continued
Nominal full-load efficiency
Motor
horsepower/
standard kilowatt
equivalent
Open motors
(number of poles)
Enclosed motors
(number of poles)
8
4
2
8
6
4
2
85.5
86.5
87.5
88.5
89.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.6
93.6
93.6
93.6
93.6
94.5
—
—
—
—
—
2/1.5
3/2.2
5/3.7
7.5/5.5
10/7.5
15/11
20/15
25/18.5
30/22
40/30
50/37
60/45
75/55
100/75
125/90
150/110
200/150
250/186
300/224
350/261
400/298
450/336
500/373
6
85.5
86.5
87.5
88.5
90.2
90.2
91.0
91.7
92.4
93.0
93.0
93.6
93.6
94.1
94.1
94.5
94.5
95.4
95.4
95.4
—
—
—
84.0
86.5
87.5
88.5
89.5
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.4
95.4
95.8
95.8
84.0
84.0
85.5
87.5
88.5
89.5
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.0
93.6
93.6
94.5
94.5
95.0
95.0
95.4
95.8
95.8
82.5
84.0
85.5
85.5
88.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.5
—
—
—
—
—
86.5
87.5
87.5
89.5
89.5
90.2
90.2
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.1
95.0
95.0
95.0
95.0
95.0
—
—
—
84.0
87.5
87.5
89.5
89.5
91.0
91.0
92.4
92.4
93.0
93.0
93.6
94.1
94.5
94.5
95.0
95.0
95.0
95.4
95.4
95.4
95.4
95.8
84.0
85.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.5
94.5
95.0
95.4
95.4
95.4
95.4
95.4
95.4
(c) Except as provided for fire pump
electric motors in paragraph (b) of this
section, each general purpose electric
motor (subtype II) with a power rating
of 1 horsepower or greater, but not
greater than 200 horsepower, including
a NEMA Design B or an equivalent IEC
Design N motor that is a general purpose
electric motor (subtype II),
manufactured (alone or as a component
of another piece of equipment) on or
after December 19, 2010, but before
December 19, 2015, shall have a
nominal full-load efficiency that is not
less than the following:
TABLE 3—NOMINAL FULL-LOAD EFFICIENCIES OF GENERAL PURPOSE ELECTRIC MOTORS (SUBTYPE II), EXCEPT FIRE
PUMP ELECTRIC MOTORS
Nominal full-load efficiency
Motor
horsepower/
standard kilowatt
equivalent
Open motors
(number of poles)
Enclosed motors
(number of poles)
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
8
1/.75
1.5/1.1
2/1.5
3/2.2
5/3.7
7.5/5.5
10/7.5
15/11
20/15
25/18.5
30/22
40/30
50/37
60/45
75/55
100/75
125/90
150/110
200/150
6
4
2
8
6
4
2
74.0
75.5
85.5
86.5
87.5
88.5
89.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.6
93.6
93.6
93.6
93.6
80.0
84.0
85.5
86.5
87.5
88.5
90.2
90.2
91.0
91.7
92.4
93.0
93.0
93.6
93.6
94.1
94.1
94.5
94.5
82.5
84.0
84.0
86.5
87.5
88.5
89.5
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
—
82.5
84.0
84.0
85.5
87.5
88.5
89.5
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.0
93.6
93.6
94.5
74.0
77.0
82.5
84.0
85.5
85.5
88.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
93.6
93.6
94.1
80.0
85.5
86.5
87.5
87.5
89.5
89.5
90.2
90.2
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.1
95.0
95.0
82.5
84.0
84.0
87.5
87.5
89.5
89.5
91.0
91.0
92.4
92.4
93.0
93.0
93.6
94.1
94.5
94.5
95.0
95.0
75.5
82.5
84.0
85.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.5
94.5
95.0
(d) Each NEMA Design B or an
equivalent IEC Design N motor that is a
general purpose electric motor (subtype
VerDate Mar<15>2010
20:13 Dec 05, 2013
Jkt 232001
I) or general purpose electric motor
(subtype II), excluding fire pump
electric motors, with a power rating of
PO 00000
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more than 200 horsepower, but not
greater than 500 horsepower,
manufactured (alone or as a component
E:\FR\FM\06DEP2.SGM
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73679
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
of another piece of equipment) on or
after December 19, 2010, but before
December 19, 2015 shall have a nominal
full-load efficiency that is not less than
the following:
TABLE 4—NOMINAL FULL-LOAD EFFICIENCIES OF NEMA DESIGN B GENERAL PURPOSE ELECTRIC MOTORS (SUBTYPE I
AND II), EXCEPT FIRE PUMP ELECTRIC MOTORS
Nominal full-load efficiency
Motor
horsepower/
standard kilowatt
equivalent
Enclosed motors
(number of poles)
8
6
4
2
8
6
4
94.5
—
—
—
—
—
250/186
300/224
350/261
400/298
450/336
500/373
Open motors
(number of
poles)
95.4
95.4
95.4
—
—
—
95.4
95.4
95.4
95.4
95.8
95.8
94.5
95.0
95.0
95.4
95.8
95.8
94.5
—
—
—
—
—
95.0
95.0
95.0
—
—
—
95.0
95.4
95.4
95.4
95.4
95.8
95.4
95.4
95.4
95.4
95.4
95.4
(e) For purposes of determining the
required minimum nominal full-load
efficiency of an electric motor that has
a horsepower or kilowatt rating between
two horsepower or two kilowatt ratings
listed in any table of energy
conservation standards in paragraphs (a)
through (d) of this section, each such
motor shall be deemed to have a listed
horsepower or kilowatt rating,
determined as follows:
(1) A horsepower at or above the
midpoint between the two consecutive
horsepowers shall be rounded up to the
higher of the two horsepowers;
(2) A horsepower below the midpoint
between the two consecutive
horsepowers shall be rounded down to
the lower of the two horsepowers; or
(3) A kilowatt rating shall be directly
converted from kilowatts to horsepower
using the formula 1 kilowatt = (1/0.746)
horsepower. The conversion should be
calculated to three significant decimal
places, and the resulting horsepower
shall be rounded in accordance with
paragraph (e)(1) or (2) of this section,
whichever applies.
(f) The standards in Table 1 through
Table 4 of this section do not apply to
definite purpose motors, special
purpose motors, or those motors
exempted by the Secretary.
(g) The standards in Table 5 through
Table 8 of this section apply to electric
motors that satisfy the following criteria:
(1) Are single-speed, induction
motors;
(2) Are rated for continuous duty (MG
1) operation or for duty type S1 (IEC);
(3) Contain a squirrel-cage (MG 1) or
cage (IEC) rotor;
(4) Operate on polyphase alternating
current 60-hertz sinusoidal line power;
(5) Are rated 600 volts or less;
(6) Have a 2-, 4-, 6-, or 8-pole
configuration,
(7) Have a three-digit NEMA frame
size (or IEC metric equivalent) or an
enclosed 56 NEMA frame size (or IEC
metric equivalent),
(8) Are rated no more than 500
horsepower, but greater than or equal to
1 horsepower (or kilowatt equivalent),
and
(9) Meet all of the performance
requirements of one of the following
motor types: a NEMA Design A, B, or C
motor or an IEC design N or H motor.
(h) Starting on December 19, 2015,
each NEMA Design A and NEMA
Design B motor that is an electric motor
meeting the criteria in paragraph (g) of
this section and with a power rating
from 1 horsepower through 500
horsepower, but excluding fire pump
electric motors, integral-brake electric
motors, and non-integral brake electric
motors, manufactured (alone or as a
component of another piece of
equipment) shall have a nominal fullload efficiency of not less than the
following:
TABLE 5—NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS
[Excluding fire pump electric motors, integral-brake electric motors, and non-integral brake electric motors]
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
Motor
horsepower/
standard kilowatt
equivalent
1/.75
1.5/1.1
2/1.5
3/2.2
5/3.7
7.5/5.5
10/7.5
15/11
20/15
25/18.5
30/22
40/30
50/37
60/45
75/55
100/75
VerDate Mar<15>2010
Nominal full load efficiency (%)
2 Pole
4 Pole
6 Pole
8 Pole
Enclosed
Open
Enclosed
Open
Enclosed
Open
Enclosed
Open
77.0
84.0
85.5
86.5
88.5
89.5
90.2
91.0
91.0
91.7
91.7
92.4
93.0
93.6
93.6
94.1
77.0
84.0
85.5
85.5
86.5
88.5
89.5
90.2
91.0
91.7
91.7
92.4
93.0
93.6
93.6
93.6
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
94.1
94.5
95.0
95.4
95.4
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
94.1
94.1
94.5
94.5
95.0
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
94.1
94.1
94.5
94.5
95.0
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
91.7
92.4
92.4
93.6
93.6
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
91.7
92.4
93.0
94.1
94.1
18:00 Dec 05, 2013
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PO 00000
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E:\FR\FM\06DEP2.SGM
06DEP2
73680
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE 5—NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN A AND NEMA DESIGN B ELECTRIC MOTORS—
Continued
[Excluding fire pump electric motors, integral-brake electric motors, and non-integral brake electric motors]
Motor
horsepower/
standard kilowatt
equivalent
Nominal full load efficiency (%)
2 Pole
4 Pole
6 Pole
8 Pole
Enclosed
Open
Enclosed
Open
Enclosed
Open
Enclosed
Open
95.0
95.0
95.4
95.8
95.8
95.8
95.8
95.8
95.8
94.1
94.1
95.0
95.0
95.4
95.4
95.8
96.2
96.2
95.4
95.8
96.2
96.2
96.2
96.2
96.2
96.2
96.2
95.4
95.8
95.8
95.8
95.8
95.8
95.8
96.2
96.2
95.0
95.8
95.8
95.8
95.8
95.8
95.8
95.8
95.8
95.0
95.4
95.4
95.8
95.8
95.8
95.8
96.2
96.2
94.1
94.1
94.5
95.0
95.0
95.0
95.0
95.0
95.0
94.1
94.1
94.1
95.0
95.0
95.0
95.0
95.0
95.0
125/90
150/110
200/150
250/186
300/224
350/261
400/298
450/336
500/373
(i) Starting on December 19, 2015,
each NEMA Design C electric motor that
is an electric motor meeting the criteria
in paragraph (g) of this section and with
a power rating from 1 horsepower
through 200 horsepower, but excluding
non-integral brake electric motors and
integral brake electric motors,
manufactured (alone or as a component
of another piece of equipment) shall
have a nominal full-load efficiency that
is not less than the following:
TABLE 6—NOMINAL FULL LOAD EFFICIENCIES OF NEMA DESIGN C ELECTRIC MOTORS
[excluding non-integral brake electric motors and integral brake electric motors]
Nominal Full Load Efficiency (%)
Motor horsepower/standard kilowatt equivalent
4 Pole
Enclosed
1/.75 .................................................................................
1.5/1.1 ..............................................................................
2/1.5 .................................................................................
3/2.2 .................................................................................
5/3.7 .................................................................................
7.5/5.5 ..............................................................................
10/7.5 ...............................................................................
15/11 ................................................................................
20/15 ................................................................................
25/18.5 .............................................................................
30/22 ................................................................................
40/30 ................................................................................
50/37 ................................................................................
60/45 ................................................................................
75/55 ................................................................................
100/75 ..............................................................................
125/90 ..............................................................................
150/110 ............................................................................
200/150 ............................................................................
(j) Starting on December 19, 2015,
each fire pump electric motor meeting
the criteria in paragraph (g) of this
6 Pole
Open
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
94.1
94.5
95.0
95.4
95.4
95.4
95.8
96.2
Enclosed
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.8
95.8
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
94.1
94.1
94.5
94.5
95.0
95.0
95.8
95.8
section and with a power rating of 1
horsepower through 500 horsepower,
manufactured (alone or as a component
8 Pole
Open
Enclosed
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
94.1
94.1
94.5
94.5
95.0
95.0
95.4
95.4
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
91.7
92.4
92.4
93.6
93.6
94.1
94.1
94.5
Open
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
91.7
92.4
93.0
94.1
94.1
94.1
94.1
94.1
of another piece of equipment) shall
have a nominal full-load efficiency that
is not less than the following:
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
TABLE 7—NOMINAL FULL LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS
Nominal full load efficiency (%)
Motor horsepower/
standard kilowatt
equivalent
2 Pole
Enclosed
1/.75 .................................
1.5/1.1 ..............................
2/1.5 .................................
3/2.2 .................................
5/3.7 .................................
7.5/5.5 ..............................
VerDate Mar<15>2010
18:00 Dec 05, 2013
4 Pole
Open
75.5
82.5
84.0
85.5
87.5
88.5
Jkt 232001
Enclosed
75.5
82.5
84.0
84.0
85.5
87.5
PO 00000
Frm 00092
82.5
84.0
84.0
87.5
87.5
89.5
Fmt 4701
6 Pole
Open
Enclosed
82.5
84.0
84.0
86.5
87.5
88.5
Sfmt 4702
80.0
85.5
86.5
87.5
87.5
89.5
E:\FR\FM\06DEP2.SGM
8 Pole
Open
80.0
84.0
85.5
86.5
87.5
88.5
06DEP2
Enclosed
74.0
77.0
82.5
84.0
85.5
85.5
Open
74.0
75.5
85.5
86.5
87.5
88.5
73681
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 / Proposed Rules
TABLE 7—NOMINAL FULL LOAD EFFICIENCIES OF FIRE PUMP ELECTRIC MOTORS—Continued
Nominal full load efficiency (%)
Motor horsepower/
standard kilowatt
equivalent
2 Pole
Enclosed
10/7.5 ...............................
15/11 ................................
20/15 ................................
25/18.5 .............................
30/22 ................................
40/30 ................................
50/37 ................................
60/45 ................................
75/55 ................................
100/75 ..............................
125/90 ..............................
150/110 ............................
200/150 ............................
250/186 ............................
300/224 ............................
350/261 ............................
400/298 ............................
450/336 ............................
500/373 ............................
4 Pole
Open
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.5
94.5
95.0
95.4
95.4
95.4
95.4
95.4
95.4
Enclosed
88.5
89.5
90.2
91.0
91.0
91.7
92.4
93.0
93.0
93.0
93.6
93.6
94.5
94.5
95.0
95.0
95.4
95.8
95.8
(k) Starting on December 19, 2015,
each integral brake electric motor and
non-integral brake electric motor
meeting the criteria in paragraph (g) of
6 Pole
Open
89.5
91.0
91.0
92.4
92.4
93.0
93.0
93.6
94.1
94.5
94.5
95.0
95.0
95.0
95.4
95.4
95.4
95.4
95.8
Enclosed
89.5
91.0
91.0
91.7
92.4
93.0
93.0
93.6
94.1
94.1
94.5
95.0
95.0
95.4
95.4
95.4
95.4
95.8
95.8
89.5
90.2
90.2
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.1
95.0
95.0
95.0
95.0
95.0
95.0
95.0
95.0
this section, and with a power rating of
1 horsepower through 30 horsepower,
manufactured (alone or as a component
of another piece of equipment) shall
8 Pole
Open
Enclosed
90.2
90.2
91.0
91.7
92.4
93.0
93.0
93.6
93.6
94.1
94.1
94.5
94.5
95.4
95.4
95.4
95.4
95.4
95.4
Open
88.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
93.6
93.6
94.1
94.5
94.5
94.5
94.5
94.5
94.5
89.5
89.5
90.2
90.2
91.0
91.0
91.7
92.4
93.6
93.6
93.6
93.6
93.6
94.5
94.5
94.5
94.5
94.5
94.5
have a nominal full-load efficiency that
is not less than the following:
TABLE 8—NOMINAL FULL LOAD EFFICIENCIES OF INTEGRAL BRAKE ELECTRIC MOTORS AND NON-INTEGRAL BRAKE
ELECTRIC MOTORS
Nominal full load efficiency (%)
Motor horsepower/standard kilowatt equivalent
4 Pole
Enclosed
maindgalligan on DSK5TPTVN1PROD with PROPOSALS
1/.75 .................................................................................
1.5/1.1 ..............................................................................
2/1.5 .................................................................................
3/2.2 .................................................................................
5/3.7 .................................................................................
7.5/5.5 ..............................................................................
10/7.5 ...............................................................................
15/11 ................................................................................
20/15 ................................................................................
25/18.5 .............................................................................
30/22 ................................................................................
(l) For purposes of determining the
required minimum nominal full-load
efficiency of an electric motor that has
a horsepower or kilowatt rating between
two horsepower or two kilowatt ratings
listed in any table of energy
conservation standards in paragraphs
(h) through (k) of this section, each such
motor shall be deemed to have a listed
horsepower or kilowatt rating,
determined as follows:
(1) A horsepower at or above the
midpoint between the two consecutive
horsepowers shall be rounded up to the
higher of the two horsepowers;
VerDate Mar<15>2010
18:00 Dec 05, 2013
Jkt 232001
85.5
86.5
86.5
89.5
89.5
91.7
91.7
92.4
93.0
93.6
93.6
6 Pole
Open
Enclosed
85.5
86.5
86.5
89.5
89.5
91.0
91.7
93.0
93.0
93.6
94.1
(2) A horsepower below the midpoint
between the two consecutive
horsepowers shall be rounded down to
the lower of the two horsepowers; or
(3) A kilowatt rating shall be directly
converted from kilowatts to horsepower
using the formula 1 kilowatt = (1/0.746)
horsepower. The conversion should be
calculated to three significant decimal
places, and the resulting horsepower
shall be rounded in accordance with
paragraph (l)(1) or (2) of this section,
whichever applies.
(m) The standards in Table 5 through
Table 8 of this section do not apply to
PO 00000
Frm 00093
Fmt 4701
Sfmt 9990
82.5
87.5
88.5
89.5
89.5
91.0
91.0
91.7
91.7
93.0
93.0
8 Pole
Open
Enclosed
82.5
86.5
87.5
88.5
89.5
90.2
91.7
91.7
92.4
93.0
93.6
Open
75.5
78.5
84.0
85.5
86.5
86.5
89.5
89.5
90.2
90.2
91.7
75.5
77.0
86.5
87.5
88.5
89.5
90.2
90.2
91.0
91.0
91.7
the following electric motors exempted
by the Secretary, or any additional
electric motors that the Secretary may
exempt:
(1) Air-over electric motors;
(2) Component sets of an electric
motor;
(3) Liquid-cooled electric motors;
(4) Submersible electric motors; and
(5) Definite-purpose, inverter-fed
electric motors.
[FR Doc. 2013–28776 Filed 12–5–13; 8:45 am]
BILLING CODE 6450–01–P
E:\FR\FM\06DEP2.SGM
06DEP2
]]>Agencies
[Federal Register Volume 78, Number 235 (Friday, December 6, 2013)]
[Proposed Rules]
[Pages 73589-73681]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-28776]
[[Page 73589]]
Vol. 78
Friday,
No. 235
December 6, 2013
Part II
Department of Energy
-----------------------------------------------------------------------
10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for
Commercial and Industrial Electric Motors; Proposed Rule
Federal Register / Vol. 78, No. 235 / Friday, December 6, 2013 /
Proposed Rules
[[Page 73590]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE-2010-BT-STD-0027]
RIN 1904-AC28
Energy Conservation Program: Energy Conservation Standards for
Commercial and Industrial Electric Motors
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking (NOPR) and public meeting.
-----------------------------------------------------------------------
SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, prescribes energy conservation standards for various consumer
products and certain commercial and industrial equipment, including
commercial and industrial electric motors. EPCA also requires the U.S.
Department of Energy (DOE) to determine whether more-stringent, amended
standards would be technologically feasible and economically justified,
and would save a significant amount of energy. In this notice, DOE
proposes energy conservation standards for a number of different groups
of electric motors that DOE has not previously regulated. For those
groups of electric motors currently regulated, the proposed standards
would maintain the current energy conservation standards for some
electric motor types and amend the energy conservation standards for
other electric motor types. The document also announces a public
meeting to receive comment on these proposed standards and associated
analyses and results.
DATES: DOE will hold a public meeting on Wednesday, December 11, 2013,
from 9 a.m. to 4 p.m., in Washington, DC. The meeting will also be
broadcast as a webinar. See section VII Public Participation for
webinar registration information, participant instructions, and
information about the capabilities available to webinar participants.
DOE will accept comments, data, and information regarding this NOPR
before and after the public meeting, but no later than February 4,
2014. See section VII Public Participation for details.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW.,
Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at
(202) 586-2945. Please note that foreign nationals visiting DOE
Headquarters are subject to advance security screening procedures. Any
foreign national wishing to participate in the meeting should advise
DOE as soon as possible by contacting Ms. Edwards to initiate the
necessary procedures. Please also note that those wishing to bring
laptops into the Forrestal Building will be required to obtain a
property pass. Visitors should avoid bringing laptops, or allow an
extra 45 minutes. Persons can attend the public meeting via webinar.
For more information, refer to the Public Participation section near
the end of this notice.
Any comments submitted must identify the NOPR for Energy
Conservation Standards for electric motors, and provide docket number
EE-2010-BT-STD-2027 and/or regulatory information number (RIN) number
1904-AC28. Comments may be submitted using any of the following
methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: ElecMotors-2010-STD-0027@ee.doe.gov. Include the docket
number and/or RIN in the subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Program, Mailstop EE-2J, 1000 Independence Avenue SW.,
Washington, DC 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
Written comments regarding the burden-hour estimates or other
aspects of the collection-of-information requirements contained in this
proposed rule may be submitted to Office of Energy Efficiency and
Renewable Energy through the methods listed above and by email to
Chad_S_Whiteman@omb.eop.gov.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section VII of this document
(Public Participation).
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at regulations.gov. All
documents in the docket are listed in the regulations.gov index.
However, some documents listed in the index, such as those containing
information that is exempt from public disclosure, may not be publicly
available.
A link to the docket Web page can be found at https://www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0027. This Web
page will contain a link to the docket for this notice on the
regulations.gov site. The regulations.gov Web page will contain simple
instructions on how to access all documents, including public comments,
in the docket. See section VII for further information on how to submit
comments through www.regulations.gov.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT: James Raba, U.S. Department of Energy,
Office of Energy Efficiency and Renewable Energy, Building Technologies
Program, EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 586-8654. Email: Jim.Raba@ee.doe.gov.
Ms. Ami Grace-Tardy, U.S. Department of Energy, Office of the
General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC
20585-0121. Telephone: (202) 586-5709. Email: Ami.Grace-Tardy@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Electric Motors
3. Process for Setting Energy Conservation Standards
III. General Discussion
A. Test Procedure
B. Equipment Classes and Current Scope of Coverage
C. Expanded Scope of Coverage
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
[[Page 73591]]
b. Life-Cycle Costs
c. Energy Savings
d. Lessening of Utility or Performance
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Current Scope of Electric Motors Energy Conservation
Standards
2. Expanded Scope of Electric Motor Energy Conservation
Standards
3. Advanced Electric Motors
4. Equipment Class Groups and Equipment Classes
a. Electric Motor Design Letter
b. Fire Pump Electric Motors
c. Brake Motors
d. Horsepower Rating
e. Pole Configuration
f. Enclosure Type
g. Other Motor Characteristics
5. Technology Assessment
a. Decrease the Length of Coil Extensions
b. Increase Cross-Sectional Area of Rotor Conductor Bars
c. Increase Cross-Sectional Area of End Rings
d. Increase the Number of Stator Slots
e. Electrical Steel With Lower Losses
f. Thinner Steel Laminations
g. Increase Stack Length
h. More Efficient Cooling System
i. Reduce Skew on Conductor Cage
B. Screening Analysis
1. Technology Options Not Screened Out of the Analysis
a. Copper Die-Cast Rotors
b. Increase the Cross-Sectional Area of Copper in the Stator
Slots
2. Technology Options Screened Out of the Analysis
C. Engineering Analysis
1. Engineering Analysis Methodology
2. Representative Units
a. Electric Motor Design Type
b. Horsepower Rating
c. Pole-Configuration
d. Enclosure Type
3. Efficiency Levels Analyzed
4. Test and Teardowns
5. Software Modeling
6. Cost Model
a. Copper Pricing
b. Labor Rate and Non-Production Markup
c. Catalog Prices
d. Product Development Cost
7. Engineering Analysis Results
8. Scaling Methodology
D. Markups Analysis
E. Energy Use Analysis
1. Comments on Operating Hours
2. Comments on Other Issues
F. Life-Cycle Cost and Payback Period Analysis
1. Equipment Costs
2. Installation Costs
3. Maintenance Costs
4. Repair Costs
5. Unit Energy Consumption
6. Electricity Prices and Electricity Price Trends
7. Lifetime
8. Discount Rate
9. Base Case Market Efficiency Distributions
10. Compliance Date
11. Payback Period Inputs
12. Rebuttable-Presumption Payback Period
G. Shipments Analysis
H. National Impact Analysis
1. Efficiency Trends
2. National Energy Savings
3. Equipment Price Forecast
4. Net Present Value of Customer Benefit
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
a. Product and Capital Conversion Costs
b. Manufacturer Production Costs
c. Shipment Forecast
d. Markup Scenarios
3. Discussion of Comments
a. Scope of Coverage
b. Conversion Costs
c. Enforcement of Standards
d. Motor Refurbishment
4. Manufacturer Interviews
a. Efficiency Levels above NEMA Premium
b. Increase in Equipment Repairs
c. Enforcement
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
M. Utility Impact Analysis
N. Employment Impact Analysis
O. Other Comments Received
V. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Customers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Sub-Group of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Customer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Summary of National Economic Impacts
8. Other Factors
C. Proposed Standards
1. Benefits and Burdens of Trial Standard Levels Considered for
Electric Motors
2. Summary of Benefits and Costs (Annualized) of the Proposed
Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participation
c. Electric Motor Industry Structure and Nature of Competition
d. Comparison Between Large and Small Entities
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict with Other Rules and
Regulations
4. Significant Alternatives to the Proposed Rule
5. Significant Issues Raised by Public Comments
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements For
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
1. The authority citation for part 431 continues to read as
follows:
2. Revise Sec. 431.25 to read as follows:
I. Summary of the Proposed Rule
Title III, Part B of the Energy Policy and Conservation Act of 1975
(EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as
codified), established the Energy Conservation Program for Consumer
Products Other Than Automobiles. Part C of Title III of EPCA (42 U.S.C.
6311-6317) established a similar program for ``Certain Industrial
Equipment,'' including certain electric motors.\1\ (Within this
preamble, DOE will use the terms ``electric motors'' and ``motors''
interchangeably.) Pursuant to EPCA, any new or amended energy
conservation standard that DOE may prescribe for certain equipment,
such as electric motors, shall be designed to achieve the maximum
improvement in energy efficiency that DOE determines is technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and
6316(a)). Furthermore, any new or amended standard must result in a
significant
[[Page 73592]]
conservation of energy. (42 U.S.C. 6295(o)(3)(B) and 6316(a)).
---------------------------------------------------------------------------
\1\ For editorial reasons, upon codification in the U.S. Code,
Parts B and C were redesignated as Parts A and A-1, respectively.
---------------------------------------------------------------------------
In accordance with these and other statutory provisions discussed
in this notice, the U.S. Department of Energy (DOE) proposes amending
the energy conservation standards for electric motors by applying the
standards currently in place to a wider scope of electric motors for
which DOE does not currently regulate. In setting these standards, DOE
is proposing to address a number of different groups of electric motors
that have, to date, not been required to satisfy the energy
conservation standards currently set out in 10 CFR part 431. In
addition, with the exception of fire pump electric motors, the proposal
would require all currently regulated motors to satisfy the efficiency
levels prescribed in Table 12-12 and Table 20-B \2\ of MG1-2011,
published by the National Electrical Manufacturers Association; fire
pump motors would continue to meet the current standards that apply.
All other electric motors that DOE is proposing to regulate would also
need to meet these efficiency levels (i.e. Tables 12-12 and 20-B). As a
practical matter, the many currently regulated motors would continue to
be required to meet the standards that they already meet, but certain
motors, such as those that satisfy the general purpose electric motors
(subtype II) (``subtype II'') or that are NEMA Design B motors from 201
through 500 horsepower, would need to meet the more stringent levels
prescribed by MG1-2011 Tables 12-12 and 20-B. These proposed efficiency
levels are shown in Table I.1. If adopted, the proposed standards would
apply to all covered motor types listed in Table I.1 that are
manufactured in, or imported into, the United States starting on
December 19, 2015. DOE may, however, depending on the nature of the
comments it receives, revisit this proposed compliance date.
---------------------------------------------------------------------------
\2\ Table 20-B of MG1-2011 provides nominal full-load
efficiencies for ratings without nominal full-load efficiencies in
Table 12-12 of MG1-2011.
Table I.1--Proposed Energy Conservation Standards for Electric Motors
[Compliance starting December 19, 2015]
----------------------------------------------------------------------------------------------------------------
Electric motor Horsepower Pole
Equipment class group design type rating configuration Enclosure Proposed TSL
----------------------------------------------------------------------------------------------------------------
1..................... NEMA Design A & 1-500 2, 4, 6, 8 Open............ 2
B *. Enclosed........ 2
2..................... NEMA Design C *. 1-200 4, 6, 8 Open............ 2
Enclosed........ 2
3..................... Fire Pump *..... 1-500 2, 4, 6, 8 Open............ 2
Enclosed........ 2
4..................... Brake Motors *.. 1-30 4, 6, 8 Open............ 2
Enclosed........ 2
----------------------------------------------------------------------------------------------------------------
* Indicates IEC equivalent electric motors are included.
The following tables (Tables I.2 to I.5) detail the various
proposed standard levels that comprise TSL 2 and that DOE would apply
to each group of motors. In determining where a particular motor with a
certain horsepower (hp) or kilowatt rating would fall within the
requirements, as in DOE's current regulations, DOE would apply the
following approach in determining which rating would apply for
compliance purposes:
(1) A horsepower at or above the midpoint between the two
consecutive horsepowers shall be rounded up to the higher of the two
horsepowers;
(2) A horsepower below the midpoint between the two consecutive
horsepowers shall be rounded down to the lower of the two horsepowers;
or
(3) A kilowatt rating shall be directly converted from kilowatts to
horsepower using the formula 1 kilowatt = (1/0.746) horsepower. The
conversion should be calculated to three significant decimal places,
and the resulting horsepower shall be rounded in accordance with the
rules listed in (1) and (2).
Table I.2--Proposed Energy Conservation Standards for NEMA Design A and NEMA Design B Electric Motors (Excluding Fire Pump Electric Motors, Integral
Brake Electric Motors, and Non-Integral Brake Electric Motors)
[Compliance starting December 19, 2015]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
---------------------------------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt 2 Pole 4 Pole 6 Pole 8 Pole
equivalent ---------------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75................................... 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1................................. 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5................................... 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2................................... 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7................................... 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5................................. 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5.................................. 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2
15/11................................... 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2
20/15................................... 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5................................. 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0
30/22................................... 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7
[[Page 73593]]
40/30................................... 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7
50/37................................... 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4
60/45................................... 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0
75/55................................... 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1
100/75.................................. 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1
125/90.................................. 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1
150/110................................. 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1
200/150................................. 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1
250/186................................. 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0
300/224................................. 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0
350/261................................. 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0
400/298................................. 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0
450/336................................. 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
500/373................................. 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table I.3--Proposed Energy Conservation Standards for NEMA Design C Electric Motors (Excluding Non-Integral
Brake Electric Motors and Integral Brake Electric Motors)
[Compliance starting December 19, 2015]
----------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-----------------------------------------------------------------------------------
Motor horsepower/standard 4 Pole 6 Pole 8 Pole
kilowatt equivalent -----------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open
----------------------------------------------------------------------------------------------------------------
1/.75....................... 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1..................... 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5....................... 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2....................... 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7....................... 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5..................... 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5...................... 91.7 91.7 91.0 91.7 89.5 90.2
15/11....................... 92.4 93.0 91.7 91.7 89.5 90.2
20/15....................... 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5..................... 93.6 93.6 93.0 93.0 90.2 91.0
30/22....................... 93.6 94.1 93.0 93.6 91.7 91.7
40/30....................... 94.1 94.1 94.1 94.1 91.7 91.7
50/37....................... 94.5 94.5 94.1 94.1 92.4 92.4
60/45....................... 95.0 95.0 94.5 94.5 92.4 93.0
75/55....................... 95.4 95.0 94.5 94.5 93.6 94.1
100/75...................... 95.4 95.4 95.0 95.0 93.6 94.1
125/90...................... 95.4 95.4 95.0 95.0 94.1 94.1
150/110..................... 95.8 95.8 95.8 95.4 94.1 94.1
200/150..................... 96.2 95.8 95.8 95.4 94.5 94.1
----------------------------------------------------------------------------------------------------------------
Table I.4--Proposed Energy Conservation Standards for Fire Pump Electric Motors
[Compliance starting December 19, 2015]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
---------------------------------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt 2 Pole 4 Pole 6 Pole 8 Pole
equivalent ---------------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75................................... 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0
1.5/1.1................................. 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5
2/1.5................................... 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5
3/2.2................................... 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5
5/3.7................................... 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5
7.5/5.5................................. 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5
10/7.5.................................. 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5
15/11................................... 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5
20/15................................... 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2
[[Page 73594]]
25/18.5................................. 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2
30/22................................... 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0
40/30................................... 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0
50/37................................... 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7
60/45................................... 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4
75/55................................... 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6
100/75.................................. 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6
125/90.................................. 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6
150/110................................. 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6
200/150................................. 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6
250/186................................. 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5
300/224................................. 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5
350/261................................. 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5
400/298................................. 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5
450/336................................. 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5
500/373................................. 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table I.5--Proposed Energy Conservation Standards for Integral Brake Electric Motors and Non-Integral Brake Electric Motors
[Compliance starting December 19, 2015]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-----------------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt equivalent 4 Pole 6 Pole 8 Pole
-----------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75................................................... 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1................................................. 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5................................................... 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2................................................... 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7................................................... 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5................................................. 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5.................................................. 91.7 91.7 91.0 91.7 89.5 90.2
15/11................................................... 92.4 93.0 91.7 91.7 89.5 90.2
20/15................................................... 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5................................................. 93.6 93.6 93.0 93.0 90.2 91.0
30/22................................................... 93.6 94.1 93.0 93.6 91.7 91.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
A. Benefits and Costs to Consumers
Table I.6 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of electric motors, as measured by the
weighted average life-cycle cost (LCC) savings and the weighted average
median payback period.
[[Page 73595]]
Table I.6--Impacts of Proposed Standards on Consumers of Electric Motors
------------------------------------------------------------------------
Weighted average Weighted average
LCC savings * median payback
(2012$) period * (years)
------------------------------------------------------------------------
Equipment Class Group 1......... 132............... 3.3
Equipment Class Group 2......... 38................ 5.0
Equipment Class Group 3......... N/A **............ N/A **
Equipment Class Group 4......... 259............... 1.9
------------------------------------------------------------------------
* The results for each equipment class group (ECG) are a shipment
weighted average of results for the representative units in the group.
ECG 1: Representative units 1, 2, and 3; ECG 2: Representative units 4
and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative
units 9 and 10. The weighted average lifetime in each equipment
classes is 15 years and ranges from 8 to 29 years depending on the
motor horsepower and application.
** For equipment class group 3, the proposed standard level is the same
as the baseline; thus, no customers are affected.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2013 to 2044). Using a real discount rate of 9.1
percent, DOE estimates that the industry net present value (INPV) for
manufacturers of electric motors is $3,371.2 million in 2012$. Under
the proposed standards, DOE expects that manufacturers may lose up to
8.4 percent of their INPV, which corresponds to approximately $283.5
million. Additionally, based on DOE's interviews with the manufacturers
of electric motors, DOE does not expect any plant closings or
significant loss of employment based on the energy conservation
standards chosen in today's Notice of Proposed Rulemaking (NOPR).
C. National Benefits and Costs \3\
---------------------------------------------------------------------------
\3\ All monetary values in this section are expressed in 2012
dollars and are discounted to 2013.
---------------------------------------------------------------------------
DOE's analyses indicate that the proposed standards would save a
significant amount of energy. Estimated lifetime savings for electric
motors purchased over the 30-year period that begins in the year of
compliance with new and amended standards (2015-2044) would amount to
7.0 quads (full-fuel-cycle energy).\4\ The annualized energy savings
(0.23 quads) are equivalent to one percent of total U.S. industrial
primary energy consumption in 2011.\5\
---------------------------------------------------------------------------
\4\ One quad (quadrillion Btu) is the equivalent of 293.1
billion kilowatt hours (kWh) or 172.3 million barrels of oil.
\5\ Based on U.S. Department of Energy, Energy Information
Administration, Annual Energy Outlook (AEO) 2013 data.
---------------------------------------------------------------------------
The estimated cumulative net present value (NPV) of total consumer
costs and savings attributed to the proposed standards for electric
motors ranges from $8.7 billion (at a 7-percent discount rate) to $23.3
billion (at a 3-percent discount rate). This NPV expresses the
estimated total value of future operating-cost savings minus the
estimated increased equipment costs for equipment purchased in 2015-
2044.
In addition, the proposed standards would have significant
environmental benefits. Estimated energy savings would result in
cumulative emission reductions of 396 million metric tons (Mt) \6\ of
carbon dioxide (CO2), 674 thousand tons of sulfur dioxide
(SO2), 499 thousand tons of nitrogen oxides (NOX)
and 0.8 tons of mercury (Hg).\7\ Through 2030, the estimated energy
savings would result in cumulative emissions reductions of 96 Mt of
CO2.
---------------------------------------------------------------------------
\6\ A metric ton is equivalent to 1.1 short tons. Results for
NOX and Hg are presented in short tons.
\7\ DOE calculates emissions reductions relative to the AEO2013
reference case, which generally represents current legislation and
environmental regulations for which implementing regulations were
available as of December 31, 2012.
---------------------------------------------------------------------------
The value of the CO2 reductions is calculated using a
range of values per metric ton of CO2 (otherwise known as
the Social Cost of Carbon (SCC) developed by an interagency
process).\8\ The derivation of the SCC values is discussed in section
IV.M. DOE estimates the present monetary value of the CO2
emissions reduction is between $2.5 and $36.6 billion. DOE also
estimates the present monetary value of the NOX emissions
reduction is $0.3 billion at a 7-percent discount rate and $0.6 billion
at a 3-percent discount rate.\9\
---------------------------------------------------------------------------
\8\ Technical Update of the Social Cost of Carbon for Regulatory
Impact Analysis Under Executive Order 12866. Interagency Working
Group on Social Cost of Carbon, United States Government. May 2013;
revised November 2013. https://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
\9\ DOE is currently investigating valuation of avoided Hg and
SO2 emissions.
---------------------------------------------------------------------------
Table I.7 summarizes the national economic costs and benefits
expected to result from the proposed standards for electric motors.
Table I.7--Summary of National Economic Benefits and Costs of Electric
Motors Energy Conservation Standards, Present Value for Motors Shipped
in 2015-2044 in Billion 2012$
------------------------------------------------------------------------
Present value
Category billion 2012$ Discount rate (%)
------------------------------------------------------------------------
Benefits:
Consumer Operating Cost 14.8 7
Savings...................... 34.9 3
CO2 Reduction Monetized Value 2.5 5
($11.8/t case) *.............
CO2 Reduction Monetized Value 11.8 3
($39.7/t case) *.............
CO2 Reduction Monetized Value 18.9 2.5
($61.2/t case) *.............
CO2 Reduction Monetized Value 36.6 3
($117.0/t case) *............
NOX Reduction Monetized Value 0.3 7
(at $2,639/ton) **........... 0.6 3
-------------------------------------
Total Benefits [dagger]..... 26.9 7
47.4 3
------------------------------------------------------------------------
Costs:
Consumer Incremental Installed 6.1 7
Costs........................ 11.7 3
------------------------------------------------------------------------
Net Benefits:
[[Page 73596]]
Including CO2 and NOX 20.8 7
Reduction Monetized Value.... 35.7 3
------------------------------------------------------------------------
* The interagency group selected four sets of SCC values for use in
regulatory analyses. Three sets of values are based on the average SCC
from the three integrated assessment models, at discount rates of 2.5,
3, and 5 percent. The fourth set, which represents the 95th percentile
SCC estimate across all three models at a 3-percent discount rate, is
included to represent higher-than-expected impacts from temperature
change further out in the tails of the SCC distribution. The values in
parentheses represent the SCC in 2015. The SCC time series incorporate
an escalation factor.
** The value represents the average of the low and high NOX values used
in DOE's analysis.
[dagger] Total Benefits for both the 3% and 7% cases are derived using
the series corresponding to SCC value of $39.7/t in 2015.
The benefits and costs of today's proposed standards for electric
motors, sold in years 2015-2044, can also be expressed in terms of
annualized values. The annualized monetary values are the sum of (1)
the annualized national economic value of the benefits from operation
of the commercial and industrial equipment that meet the proposed
standards (consisting primarily of operating cost savings from using
less energy, minus increases in equipment purchase and installation
costs, which is another way of representing consumer NPV), and (2) the
annualized monetary value of the benefits of emission reductions,
including CO2 emission reductions.\10\
---------------------------------------------------------------------------
\10\ DOE used a two-step calculation process to convert the
time-series of costs and benefits into annualized values. First, DOE
calculated a present value in 2013, the year used for discounting
the NPV of total consumer costs and savings, for the time-series of
costs and benefits using discount rates of three and seven percent
for all costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE then calculated the
fixed annual payment over a 30-year period (2015 through 2044) that
yields the same present value. The fixed annual payment is the
annualized value. Although DOE calculated annualized values, this
does not imply that the time-series of cost and benefits from which
the annualized values were determined is a steady stream of
payments.
---------------------------------------------------------------------------
Although combining the values of operating savings and
CO2 emission reductions provides a useful perspective, two
issues should be considered. First, the national operating savings are
domestic U.S. consumer monetary savings that occur as a result of
market transactions while the value of CO2 reductions is
based on a global value. Second, the assessments of operating cost
savings and CO2 savings are performed with different methods
that use different time frames for analysis. The national operating
cost savings is measured over the lifetime of electric motors shipped
in years 2015-2044. The SCC values, on the other hand, reflect the
present value of some future climate-related impacts resulting from the
emission of one ton of carbon dioxide in each year. These impacts
continue well beyond 2100.
Estimates of annualized benefits and costs of the proposed
standards for electric motors are shown in Table I.8. The results under
the primary estimate are as follows. Using a 7-percent discount rate
for benefits and costs other than CO2 reduction, for which
DOE used a 3-percent discount rate along with the average SCC series
that uses a 3-percent discount rate, the cost of the standards proposed
in today's rule is $462 million per year in increased equipment costs;
while the estimated benefits are $1,114 million per year in reduced
equipment operating costs, $586 million in CO2 reductions,
and $21.5 million in reduced NOX emissions. In this case,
the net benefit would amount to $957 million per year. Using a 3-
percent discount rate for all benefits and costs and the average SCC
series, the estimated cost of the standards proposed in today's rule is
$577 million per year in increased equipment costs; while the estimated
benefits are $1,730 million per year in reduced operating costs, $586
million in CO2 reductions, and $31.5 million in reduced
NOX emissions. In this case, the net benefit would amount to
approximately $1,354 million per year.
Table I.8--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Electric Motors, in
Million 2012$
----------------------------------------------------------------------------------------------------------------
Primary estimate Low net benefits High net benefits
Discount rate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
million 2012$/year
----------------------------------------------------------------------------------------------------------------
Benefits:
Consumer Operating Cost 7%.................. 1,114 924 1,358
Savings. 3%.................. 1,730 1,421 2,134
CO2 Reduction Monetized Value 5%.................. 155 134 179
($11.8/t case) *.
CO2 Reduction Monetized Value 3%.................. 586 506 679
($39.7/t case) *.
CO2 Reduction Monetized Value 2.5%................ 882 762 1022
($61.2/t case) *.
CO2 Reduction Monetized Value 3%.................. 1,811 1,565 2,098
($117.0/t case) *.
NOX Reduction Monetized Value 7%.................. 21.46 18.55 24.68
(at $2,639/ton) **. 3%.................. 31.48 27.20 36.39
------------------------------------------------------------------------------
Total Benefits [dagger].... 7% plus CO2 range... 1,290 to 2,947 1,077 to 2,507 1,562 to 3,481
7%.................. 1,721 1,449 2,061
3% plus CO2 range... 1,916 to 3,572 1,583 to 3,014 2,350 to 4,268
3%.................. 2,347 1,955 2,849
----------------------------------------------------------------------------------------------------------------
Costs:
[[Page 73597]]
Incremental Installed Costs.. 7%.................. 462 492 447
3%.................. 577 601 569
----------------------------------------------------------------------------------------------------------------
Net Benefits:
Total [dagger]............... 7% plus CO2 range... 585 to 2,016 1,115 to 3,033 1,353 to 3,438
7%.................. 957 1,614 1,887
3% plus CO2 range... 982 to 2,413 1,781 to 3,700 1,957 to 4,043
3%.................. 1,354 2,280 2,492
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with electric motors shipped in 2015-2044.
These results include benefits to consumers which accrue after 2044 from the equipment purchased in years 2015-
2044. Costs incurred by manufacturers, some of which may be incurred in preparation for the rule, are not
directly included, but are indirectly included as part of incremental equipment costs. The Primary, Low
Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy
Outlook (AEO) 2013 Reference case, Low Estimate, and High Estimate, respectively. In addition, incremental
equipment costs reflect a medium constant projected equipment price in the Primary Estimate, a declining rate
for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected
equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are
explained in section IV.F.1.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values
are based on the average SCC from the three integrated assessment models, at discount rates of 2.5, 3, and 5
percent. The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-
percent discount rate, is included to represent higher-than-expected impacts from temperature change further
out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time
series incorporate an escalation factor. The value for NOX is the average of the low and high values used in
DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to
average SCC with 3-percent discount rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,''
the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added
to the full range of CO2 values.
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. DOE further notes that equipment
achieving these standard levels are already commercially available for
most equipment classes covered by today's proposal. Based on the
analyses described above, DOE has tentatively concluded that the
benefits of the proposed standards to the Nation (energy savings,
positive NPV of consumer benefits, consumer LCC savings, and emission
reductions) would outweigh the burdens (loss of INPV for manufacturers
and LCC increases for some consumers).
DOE also considered more-stringent energy efficiency levels as
trial standard levels, and is still considering them in this
rulemaking. However, DOE has tentatively concluded that the potential
burdens of the more-stringent energy efficiency levels would outweigh
the projected benefits. Depending on the comments that DOE receives in
response to this notice and related information collected and analyzed
during the course of this rulemaking, DOE may adopt energy efficiency
levels presented in this notice that are either higher or lower than
the proposed standards, or some combination of level(s) that
incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying today's proposed rule, as well as some relevant historical
background related to the establishment of standards for electric
motors.
A. Authority
Title III, Part B of the Energy Policy and Conservation Act of 1975
(EPCA or the Act), Public Law 94-163, as amended (42 U.S.C. 6291-6309)
established the ``Energy Conservation Program for Consumer Products
Other Than Automobiles.'' Part C of Title III of EPCA (42 U.S.C. 6311-
6317) established a similar program for ``Certain Industrial
Equipment,'' including electric motors.\11\ The Energy Policy Act of
1992 (EPACT 1992) (Pub. L. 102-486) amended EPCA by establishing energy
conservation standards and test procedures for certain commercial and
industrial electric motors (in context, ``motors'') manufactured (alone
or as a component of another piece of equipment) after October 24,
1997. In December 2007, Congress passed into law the Energy
Independence and Security Act of 2007 (EISA 2007) (Pub. L. 110-140).
Section 313(b)(1) of EISA 2007 updated the energy conservation
standards for those electric motors already covered by EPCA and
established energy conservation standards for a larger scope of motors
not previously covered by standards. (42 U.S.C. 6313(b)(2)) EPCA
directs the Secretary of Energy to publish a final rule no later than
24 months after the effective date of the previous final rule to
determine whether to amend the standards already in effect. Any such
amendment shall apply to electric motors manufactured after a date
which is five years after either: (1) The effective date of the
previous amendment or (2) if the previous final rule did not amend the
standards, the earliest date by which a previous amendment could have
been effective. (42 U.S.C. 6313(b)(4)(B))
---------------------------------------------------------------------------
\11\ For editorial reasons, upon codification in the U.S. Code,
Parts B and C were redesignated as Parts A and A-1, respectively.
---------------------------------------------------------------------------
DOE is issuing today's proposal pursuant to Part C of Title III,
which establishes an energy conservation program for covered equipment
that consists essentially of four parts: (1) Testing; (2) labeling; (3)
the establishment of Federal energy conservation standards; and (4)
certification and enforcement procedures. For those electric motors for
which Congress established standards, or for which DOE amends or
establishes standards, the DOE test procedure must be the prescribed
procedures that currently appear at 10 CFR part 431 that apply to
electric motors. The test procedure is subject to review and revision
by the Secretary in accordance with certain criteria and conditions.
(See 42 U.S.C. 6314(a))
Section 343(a)(5)(B)-(C) of EPCA, 42 U.S.C. 6314(a)(5)(B)-(C),
provides in part that if the NEMA- and IEEE-developed test procedures
are amended, DOE shall so amend the test procedures
[[Page 73598]]
under 10 CFR part 431, unless the Secretary determines, by rule, that
the amended industry procedures would not meet the requirements for
test procedures to produce results that reflect energy efficiency,
energy use, and estimated operating costs of the tested motor, or,
would be unduly burdensome to conduct. (42 U.S.C. 6314(a)(2)-(3),
(a)(5)(B)) As newer versions of the NEMA and IEEE test procedures for
electric motors were developed, DOE updated 10 CFR part 431 to reflect
these changes. Manufacturers of covered equipment must use the
prescribed DOE test procedure as the basis for certifying to DOE that
their equipment complies with the applicable energy conservation
standards adopted under EPCA and when making representations to the
public regarding the energy use or efficiency of such equipment. (42
U.S.C. 6314(d)) Similarly, DOE must use these test procedures to
determine whether the equipment comply with standards adopted pursuant
to EPCA. Id.
DOE must follow specific statutory criteria for prescribing new and
amended standards for covered equipment. In the case of electric
motors, the criteria set out in relevant subsections of 42 U.S.C. 6295,
which normally applies to standards related to consumer products, also
apply to the setting of energy conservation standards for motors via 42
U.S.C. 6316(a). As indicated above, new and amended standards must be
designed to achieve the maximum improvement in energy efficiency that
is technologically feasible and economically justified. (42 U.S.C.
6295(o)(2)(A) and 6316(a)) Furthermore, DOE may not adopt any standard
that would not result in the significant conservation of energy. (42
U.S.C. 6295(o)(3) and 6316(a)) Moreover, DOE may not prescribe a
standard: (1) For certain equipment, including electric motors, if no
test procedure has been established for the product, or (2) if DOE
determines by rule that the proposed standard is not technologically
feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-6316(a))
In deciding whether a proposed standard is economically justified, DOE
must determine whether the benefits of the standard exceed its burdens.
(42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) DOE must make this
determination after receiving comments on the proposed standard, and by
considering, to the greatest extent practicable, the following seven
factors:
1. The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result from the imposition of the
standard;
3. The total projected amount of energy, or as applicable, water,
savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered
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 and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII) and 6316(a))
EPCA, as codified, also contains what is known as an ``anti-
backsliding'' provision, which prevents the Secretary from prescribing
any new or amended standards that either increase the maximum allowable
energy use or decrease the minimum required energy efficiency of a
covered product. (42 U.S.C. 6295(o)(1) and 6316(a)) Also, the Secretary
may not prescribe an amended or new standard if interested persons have
established by a preponderance of the evidence that the standard is
likely to result in the unavailability in the United States of any
covered product type (or class) of performance characteristics
(including reliability), features, sizes, capacities, and volumes that
are substantially the same as those generally available in the United
States. (42 U.S.C. 6295(o)(4) and 6316(a))
Further, EPCA, as codified, establishes a rebuttable presumption
that a standard is economically justified if the Secretary finds that
the additional cost to the consumer of purchasing a product complying
with an energy conservation standard level will be less than three
times the value of the energy savings during the first year that the
consumer will receive as a result of the standard, as calculated under
the applicable test procedure. (42 U.S.C. 6295(o)(2)(B)(iii) and
6316(a))
Additionally, 42 U.S.C. 6295(q)(1), as applied to covered equipment
via 42 U.S.C. 6316(a), specifies requirements when promulgating a
standard for a type or class of covered product that has two or more
subcategories. DOE must specify a different standard level than that
which applies generally to such type or class of equipment for any
group of covered equipment that have the same function or intended use
if DOE determines that equipment within such group: (A) Consume a
different kind of energy from that consumed by other covered equipment
within such type (or class); or (B) have a capacity or other
performance-related feature which other equipment within such type (or
class) do not have and such feature justifies a higher or lower
standard. (42 U.S.C. 6294(q)(1) and 6316(a)). In determining whether a
performance-related feature justifies a different standard for a group
of products, DOE must consider such factors as the utility to the
consumer of the feature and other factors DOE deems appropriate. Id.
Any rule prescribing such a standard must include an explanation of the
basis on which such higher or lower level was established. (42 U.S.C.
6295(q)(2) and 6316(a))
Federal energy conservation requirements generally supersede State
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c) and 6316(a)) DOE may, however,
grant waivers of Federal preemption for particular State laws or
regulations, in accordance with the procedures and other provisions set
forth under 42 U.S.C. 6297(d)).
B. Background
1. Current Standards
An electric motor is a device that converts electrical power into
rotational mechanical power. The outside structure of the motor is
called the frame, which houses a rotor (the spinning part of the motor)
and the stator (the stationary part that creates a magnetic field to
drive the rotor). Although many different technologies exist, DOE's
rulemaking is concerned with squirrel-cage induction motors, which
represent the majority of electric motor energy use. In squirrel-cage
induction motors, the stator drives the rotor by inducing an electric
current in the squirrel-cage, which then reacts with the rotating
magnetic field to propel the rotor in the same way a person can repel
one handheld magnet with another. The squirrel-cage used in the rotor
of induction motors consists of longitudinal conductive bars (rotor
bars) connected at both ends by rings (end rings) forming a cage-like
shape. Among other design parameters, motors can vary in horsepower,
number of ``poles'' (which determines how quickly the motor rotates),
and torque characteristics. Most motors have ``open'' frames that allow
cooling airflow through the motor body, though
[[Page 73599]]
some have enclosed frames that offer added protection from foreign
substances and bodies. DOE regulates various motor types from between 1
and 500 horsepower, with 2, 4, 6, and 8 poles, and with both open and
enclosed frames.
EPACT 1992 amended EPCA by establishing energy conservation
standards and test procedures for certain commercial and industrial
electric motors manufactured either alone or as a component of another
piece of equipment after October 24, 1997. Section 313 of EISA 2007
amended EPCA by: (1) Striking the definition of ``electric motor''
provided under EPACT 1992, (2) setting forth definitions for ``general
purpose electric motor (subtype I)'' and ``general purpose electric
motor (subtype II),'' and (3) prescribing energy conservation standards
for ``general purpose electric motors (subtype I),'' ``general purpose
electric motors (subtype II), ``fire pump electric motors,'' and ``NEMA
Design B general purpose electric motors'' with a power rating of more
than 200 horsepower but not greater than 500 horsepower. (42 U.S.C.
6311(13), 6313(b)). The current standards for these motors, which are
reproduced in the proposed regulatory text at the end of this notice,
are divided into four tables that prescribe specific efficiency levels
for each of those groups of motors.
2. History of Standards Rulemaking for Electric Motors
On October 5, 1999, DOE published in the Federal Register, a final
rule to implement the EPACT 1992 electric motor requirements. 64 FR
54114. In response to EISA 2007, on March 23, 2009, DOE updated, among
other things, the corresponding electric motor regulations at 10 CFR
part 431 with the new definitions and energy conservation standards. 74
FR 12058. On December 22, 2008, DOE proposed to update the test
procedures under 10 CFR part 431 both for electric motors and small
electric motors. 73 FR 78220. DOE finalized key provisions related to
small electric motor testing in a 2009 final rule at 74 FR 32059 (July
7, 2009), and further updated the test procedures for electric motors
and small electric motors at 77 FR 26608 (May 4, 2012). The May 2012
final rule primarily focused on updating various definitions and
incorporations by reference related to the current test procedure. In
that rule, DOE promulgated a regulatory definition of ``electric
motor'' to account for EISA 2007's removal of the previous statutory
definition of ``electric motor.'' DOE also clarified definitions
related to those motors that EISA 2007 laid out as part of EPCA's
statutory framework, including motor types that DOE had not previously
regulated. See generally, id. at 26613-26619. DOE published a new
proposed test procedure rulemaking on June 26, 2013, that proposes to
further refine some existing electric motor definitions and add certain
definitions and test procedure preparatory steps to address a wider
variety of electric motor types than are currently regulated. 78 FR
38456.
Regarding the compliance date that would apply to the requirements
of today's proposed rule, EPCA directs the Secretary of Energy to
publish a final rule no later than 24 months after the effective date
of the previous final rule to determine whether to amend the standards
in effect for such equipment. Any such amendment shall apply to
electric motors manufactured after a date which is five years after:
(i) The effective date of the previous amendment; or (ii) if the
previous final rule did not amend the standards, the earliest date by
which a previous amendment could have been effective. (42 U.S.C.
6313(b)(4))
As described previously, EISA 2007 constitutes the most recent
amendment to EPCA and energy conservation standards for electric
motors. Because these amendments required compliance on December 19,
2010, DOE had indicated during the course of public meetings held in
advance of today's proposal that motors manufactured after December 19,
2015, would need to comply with any applicable new standards that DOE
may set as part of this rulemaking. Today's proposed standards would
apply to motors manufactured starting on December 19, 2015. As noted in
detail later in this notice, however, DOE is interested in receiving
comments on the ability of manufacturers to meet this deadline.
DOE received numerous comments from interested parties who provided
significant input to DOE in response to the framework document and
preliminary analysis that the agency had issued. See 75 FR 59657 (Sept.
28, 2010) (framework document notice of availability) and 77 FR 43015
(July 23, 2012) (preliminary analysis notice of availability). During
the framework document comment period for this rulemaking, several
interested parties urged DOE to consider including additional motor
types currently without energy conservation standards in DOE's analyses
and establishing standards for such motor types. In the commenters'
view, this approach would more effectively increase energy savings than
setting more stringent standards for currently regulated electric
motors. In response, DOE published a Request for Information (RFI)
seeking public comments from interested parties regarding establishment
of energy conservation standards for several types of definite and
special purpose motors for which EISA 2007 did not provide energy
conservation standards. 76 FR 17577 (March 30, 2011). DOE received
comments responding to the RFI advocating that DOE regulate many of the
electric motors discussed in the RFI, as well as many additional motor
types.
Then, on August 15, 2012, a group of interested parties (the
``Motor Coalition'' \12\) submitted a Petition to DOE asking the agency
to adopt a consensus stakeholder proposal that would amend the energy
conservation standards for electric motors. The Motor Coalition's
proposal advocated expanding the scope of coverage to a broader range
of motors than what DOE currently regulates and it recommended that
energy conservation standards for all covered electric motors be set at
levels that are largely equivalent to what DOE proposes in today's NOPR
(i.e., efficiency levels in NEMA MG1-2011 Tables 12-12 and 20-B).\13\
---------------------------------------------------------------------------
\12\ The members of the Motor Coalition include: National
Electrical Manufacturers Association, American Council for an
Energy[hyphen]Efficient Economy, Appliance Standards Awareness
Project, Alliance to Save Energy, Earthjustice, Natural Resources
Defense Council, Northwest Energy Efficiency Alliance, Northeast
Energy Efficiency Partnerships, and Northwest Power and Conservation
Council.
\13\ DOE's proposal differs from that of the Motor Coalition in
that DOE's proposal covers brake motors and does not set separate
standards for U-frame motors. It also seeks supplemental information
regarding certain 56-frame motors. See section IV.A.2 for details.
---------------------------------------------------------------------------
DOE received several comments from NEMA regarding the December 19,
2015, compliance date. First, NEMA pointed out that all publications
and presentations prior to that preliminary analysis public meeting on
August 21, 2012, indicated that DOE's statutory deadline for any final
rule was December 19, 2012, but at the public meeting DOE showed a
final rule completion date as the end of 2013. (NEMA, No. 54 at pp. 2,
6-7) NEMA questioned the authority by which DOE has decided to delay
the Final Rule beyond the date of December 19, 2012, as stipulated in
EPCA. (NEMA, No. 54 at p. 2)
Second, NEMA commented that shortening the time to comply with any
new standards from three years to two years would place additional
burdens on manufacturers considering all of the electric motors types
that DOE is considering in the preliminary TSD, the burdensome
candidate standard levels that DOE is considering, and the
[[Page 73600]]
possibility of expanding the scope of energy conservation standards.
(NEMA, No. 54 at pp. 2, 7; NEMA, Public Meeting Transcript, No. 60 at
p. 30)
Third, NEMA also noted that when EPACT 1992 first added electric
motors as covered equipment, motor manufacturers were allowed five
years to modify motor designs and certify compliance to the new
standards. (NEMA, No. 54 at p. 7) It further noted that NEMA MG 1-1998
subsequently introduced NEMA Premium efficiency standards, and between
1998 and 2007 manufacturers voluntarily increased the number of NEMA
Premium efficiency motor models available. (NEMA, No. 54 at p. 7) NEMA
commented that this transition period eased the burden of satisfying
the added stringency of the standards set by EISA 2007, which allowed
three years to update energy conservation standards to mandatory NEMA
Premium levels for certain motor ratings. (NEMA, No. 54 at p. 7) NEMA
added that adhering to the statutory deadline for setting any new and
amended standards would minimize any disruption in the electric motor
market. (NEMA, No. 54 at p. 8) NEMA also commented that since the EISA
2007 standards were enacted, only a limited number of motor ratings
above NEMA Premium have been offered because there is not sufficient
space available in most frame ratings to increase the efficiency.
(NEMA, No. 54 at p. 7) NEMA added that any standards above NEMA Premium
would force manufacturers to redesign entire product lines and go
through the process of certification and compliance, all of which would
be expected to take longer than three years. (NEMA, No. 54 at pp. 7, 8)
Finally, NEMA also attempted to illustrate the difficulty of
reaching NEMA Premium levels in IEC frame motors, noting that a
comparison of certificates of compliance before and after EISA 2007
standards went into effect would demonstrate that some manufacturers
were forced to abandon the U.S. electric motor market for some period
of time before they could update their IEC frame motor product line.
(NEMA, No. 54 at p. 8) NEMA added that increasing the efficiency of
subtype II motors to NEMA Premium efficiency and expanding the scope of
motors subject to energy conservation standards (many of which
currently have efficiency levels below EPACT 1992 energy conservation
levels) will also require extensive redesign, and manufacturers would
be forced to comply in only three years. (NEMA, No. 54 at p. 8)
During the course of preparing for the electric motors energy
conservation standards rulemaking, information was submitted to DOE by
NEMA, ASAP, and CDA in response to DOE's RFI and then later in the
Petition from the Motors Coalition \14\ that caused DOE to reevaluate
the scope of electric motors it was considering in this rulemaking.
That Petition, and related supporting information, suggested that DOE
apply the NEMA Premium efficiency levels (``NEMA Premium'') to a much
broader swath of electric motors than are currently regulated by DOE,
rather than increase the stringency of the standards that had only
recently come into effect (i.e., EISA 2007 standards). As part of its
routine practice, DOE reviewed the information and the merits of the
Petition. With the potential prospect of expanding the types of motors
that would be regulated by standards, DOE recognized the need to amend
its test procedures to add the necessary testing preparatory steps
(i.e. test set-up procedures) to DOE's regulations. The inclusion of
these steps would help ensure that manufacturers of these new motor
types would be performing the same steps as are performed when testing
currently regulated motors.
---------------------------------------------------------------------------
\14\ The Petition is available at: https://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0027-0035.
---------------------------------------------------------------------------
The compliance date prescribed by statute would require
manufacturers to begin manufacturing compliant motors by December 19,
2015. Accordingly, DOE is proposing a December 19, 2015, compliance
date. DOE, however, recognizes that the statute also contemplated a
three-year lead time for manufacturers in order to account for the
potential logistical and production hurdles that manufacturers may face
when transitioning to the new standards. Accordingly, while DOE is
proposing a December 19, 2015 compliance deadline, it is also
interested in comments that detail any hurdles with meeting this
compliance deadline along with the merits of receiving the three-year
lead-time also set out in the statute.
3. Process for Setting Energy Conservation Standards
Section 325(o) provides criteria for prescribing new or amended
standards which are designed to achieve the maximum improvement in
energy efficiency and for which the Secretary of Energy determines are
technologically feasible and economically justified. Consequently, DOE
must consider, to the greatest extent practicable, the following seven
factors: (1) The economic impact of the standard on the manufacturers
and consumers of the products subject to the standard; (2) the savings
in operating costs throughout the estimated average life of the
products compared to any increase in the prices, initial costs, or
maintenance expenses for the products that are likely to result from
the imposition of the standard; (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
covered 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 6316(a))
Other statutory requirements are set forth in 42 U.S.C. 6295(o)(1)-
(2)(A), (2)(B)(ii)-(iii), and (3)-(4). These criteria apply to the
setting of standards for electric motors through 42 U.S.C. 6316(a).
III. General Discussion
DOE developed today's proposed rule after considering input,
including verbal and written comments, data, and information from
interested parties that represent a variety of interests. All
commenters, along with their corresponding abbreviations and
affiliations, are listed in Table III.1 below. The issues raised by
these commenters are addressed in the discussions that follow.
Table III.1--Summary of Commenters
------------------------------------------------------------------------
Company or organization Abbreviation Affiliation
------------------------------------------------------------------------
Air Movement and Control AMCAI............. Trade Association.
Association International, Inc.
[[Page 73601]]
Alliance to Save Energy........ ASE............... Energy Efficiency
Advocates.
American Council for an ACEEE............. Energy Efficiency
Energy-Efficient Economy...... Advocates.
Appliance Standards Awareness ASAP.............. Energy Efficiency
Project. Advocates.
Baldor Electric Co............. Baldor............ Manufacturers.
BBF & Associates............... BBF............... Representative for
Trade Association.
California Investor Owned CA IOUs........... Utilities.
Utilities.
Copper Development Association. CDA............... Trade Association.
Earthjustice................... Earthjustice...... Energy Efficiency
Advocates.
Electric Apparatus Service EASA.............. Trade Association.
Association.
Flolo Corporation.............. Flolo............. Other.
Industrial Energy Consumers of IECA.............. Trade Association.
America.
Motor Coalition *.............. MC................ Energy Efficiency
Advocates, Trade
Associations,
Manufacturers,
Utilities.
National Electrical NEMA.............. Trade Association.
Manufacturers Association.
Northwest Energy Efficiency NEEA.............. Energy Efficiency
Alliance. Advocates.
Northwest Power & Conservation NPCC.............. Utilities.
Council.
SEW-Eurodrive, Inc............. SEWE.............. Manufacturer.
UL LLC......................... UL................ Testing Laboratory.
------------------------------------------------------------------------
* The members of the Motor Coalition include: National Electrical
Manufacturers Association (NEMA), American Council for an
Energy[hyphen]Efficient Economy (ACEEE), Appliance Standards Awareness
Project (ASAP), Alliance to Save Energy (ASE), Earthjustice, Natural
Resources Defense Council (NRDC), Northwest Energy Efficiency Alliance
(NEEA), Northeast Energy Efficiency Partnerships (NEEP), and Northwest
Power and Conservation Council (NPCC).
Subsequent to DOE's preliminary analysis public meeting, several
other interested parties submitted comments supporting the Petition.
Those supporters included: BBF and Associates, the Air Movement and
Control Association International, Inc., U.S. Senators Lisa Murkowski
and Jeff Bingaman, the Hydraulic Institute, the Arkansas Economic
Development and Commission-Energy Office, and the Power Transmission
Distributors Association.
A. Test Procedure
On June 26, 2013, DOE published a notice that proposed to
incorporate definitions for certain motor types not currently subject
to energy conservation standards (78 FR 38456). The notice also
proposed to clarify several definitions for motor types currently
regulated by energy conservation standards and adding some necessary
steps to facilitate the testing of certain motor types that DOE does
not currently require to meet standards. During its preliminary
analysis stage, DOE received comments concerning definitions and test
procedure set-up steps suggested for testing motors under an expanded
scope approach. DOE addressed the comments as part of the test
procedure NOPR. For additional details, see 78 FR 38456 (June 26,
2013).
B. Equipment Classes and Current Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered equipment into equipment classes by the type of energy
used or by capacity or other performance-related features that would
justify a different standard. In making a determination whether a
performance-related feature would justify a different standard, DOE
must consider factors such as the utility to the consumer of the
feature and other factors that DOE determines are appropriate. (42
U.S.C. 6295(q) and 6316(a))
Existing energy conservation standards cover electric motors that
fall into four categories based on physical design features of the
motor. These four categories are: General purpose electric motors
(subtype I), general purpose electric motors (subtype II), fire pump
electric motors, and NEMA Design B motors (with a horsepower rating
from 201 through 500). Definitions for each of these terms can be found
at 10 CFR 431.12.
C. Expanded Scope of Coverage
DOE has the authority to set energy conservation standards for a
wider range of electric motors than those classified as general purpose
electric motors (e.g., definite or special purpose motors). EPACT 1992
amended EPCA to include, among other things, a definition for the term
``electric motor''--which the statute defined as including certain
``general purpose'' motors. (42 U.S.C. 6311(13)(A) (1992)) The
amendments also defined the terms ``definite purpose motors'' and
``special purpose motor.'' (42 U.S.C. 6311(13)(C) and (D)) (1992))
EPACT 1992 initially prescribed energy conservation standards for
``electric motors'' (i.e., subtype I general purpose electric motors)
and explicitly stated that these standards did not apply to definite
purpose or special purpose motors. (42 U.S.C. 6313(b)(1) (1992))
However, EISA 2007 struck the narrow EPACT 1992 definition of
``electric motor.'' With the removal of this definition, the term
``electric motor'' became broader in scope. As a result of these
changes, both definite and special purpose motors fell under the broad
heading of ``electric motors'' that previously only applied to
``general purpose'' motors. While EISA 2007 prescribed standards for
general purpose motors, the Act did not apply those standards to
definite or special purpose motors. (42 U.S.C. 6313(b) (2012))
Although DOE believes that EPCA, as amended through EISA 2007,
provides sufficient statutory authority for the regulation of special
purpose and definite purpose motors as ``electric motors,'' DOE notes
it has additional authority under section 10 of the American Energy
Manufacturing Technical Corrections Act, Public Law 112-210, which
amended DOE's authority to regulate commercial and industrial equipment
under section 340(2)(B) of EPCA to include ``other motors,'' in
addition to ``electric motors''. (42 U.S.C. 6311(2)(B)(xiii)).
Therefore, even if special and definite purpose motors were not
``electric motors,'' special and definite purpose motors would be
considered as ``other
[[Page 73602]]
motors'' that EPCA already treats as covered industrial equipment.\15\
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\15\ EPCA specifies the types of industrial equipment that can
be classified as covered in addition to the equipment enumerated in
42 U.S.C. 6311(1). This equipment includes ``other motors'' (to be
codified at 42 U.S.C. 6311(2)(B)). Industrial equipment must also,
without regard to whether such equipment is in fact distributed in
commerce for industrial or commercial use, be of a type that: (1) In
operation consumes, or is designed to consume, energy in operation;
(2) to any significant extent, is distributed in commerce for
industrial or commercial use; and (3) is not a covered product as
defined in 42 U.S.C. 6291(a)(2) of EPCA, other than a component of a
covered product with respect to which there is in effect a
determination under 42 U.S.C. 6312(c). (42 U.S.C. 6311 (2)(A)). Data
from the 2002 United States Industrial Electric Motor Systems Market
Opportunities Assessment estimated total energy use from industrial
motor systems to be 747 billion kWh. Based on the expansion of
industrial activity, it is likely that current annual electric motor
energy use is higher than this figure. Electric motors are
distributed in commerce for both the industrial and commercial
sectors. According to data provided by the Motor Coalition, the
number of electric motors manufactured in, or imported into, the
United States is over five million electric motors annually,
including special and definite purpose motors. Finally, special and
definite purpose motors are not currently regulated under Title 10
of the Code of Federal Regulations, part 430 (10 CFR part 430).
To classify equipment as covered commercial or industrial
equipment, the Secretary must also determine that classifying the
equipment as covered equipment is necessary for the purposes of Part
A-1 of EPCA. The purpose of Part A-1 is to improve the efficiency of
electric motors, pumps and certain other industrial equipment to
conserve the energy resources of the nation. (42 U.S.C. 6312(a)-(b))
In today's proposal, DOE has tentatively determined that the
regulation of special and definite purpose motors is necessary to
carry out the purposes of part A-1 of EPCA because regulating these
motors will promote the conservation of energy supplies. Efficiency
standards that may result from coverage would help to capture some
portion of the potential for improving the efficiency of special and
definite purpose motors.
---------------------------------------------------------------------------
Consistent with EISA 2007's reworking of the definition, the 2012
test procedure final rule broadly defined the term ``electric motor.''
at 10 CFR 431.12. (77 FR 26608 (May 4, 2012)). That definition covers
``general purpose,'' ``special purpose'' and ``definite purpose''
electric motors (as defined by EPCA). As noted above, EPCA did not
require either ``special purpose'' or ``definite purpose'' motor types
to meet energy conservation standards because they were not considered
``general purpose'' under the EPCA definition of ``general purpose
motor''--a necessary element to meet the pre-EISA 2007 ``electric
motor'' definition. See 77 FR 26612. Because of the restrictive nature
of the prior electric motor definition, along with the restrictive
definition of the term ``industrial equipment,'' DOE would have been
unable to set standards for such motors without this change. (See 42
U.S.C. 6311(2)(B) (2006) (limiting the scope of equipment covered under
EPCA)) In view of the changes introduced by EISA 2007 and the absence
of energy conservation standards for special purpose and definite
purpose motors, as noted in chapter 2 of DOE's July 2012 electric
motors preliminary analysis technical support document (TSD),\16\ it is
DOE's view that both of these motors are categories of ``electric
motors'' covered under EPCA, as currently amended. Accordingly, DOE is
proposing standards for certain definite purpose and special purpose
motors. To this end, DOE is considering setting energy conservation
standards for those motors that exhibit all of the following nine
characteristics:
---------------------------------------------------------------------------
\16\ The preliminary TSD published in July 2012 is available at:
https://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0027-
0023.
---------------------------------------------------------------------------
Is a single-speed, induction motor,
Is rated for continuous duty (MG 1) operation or for duty
type S1 (IEC),
Contains a squirrel-cage (MG 1) or cage (IEC) rotor,
Operates on polyphase alternating current 60-hertz
sinusoidal line power,
Is rated 600 volts or less,
Has a 2-, 4-, 6-, or 8-pole configuration,
Has a three-digit NEMA frame size (or IEC metric
equivalent) or an enclosed 56 NEMA frame size (or IEC metric
equivalent),
Has no more than 500 horsepower, but greater than or equal
to 1 horsepower (or kilowatt equivalent), and
Meets all of the performance requirements of a NEMA Design
A, B, or C electric motor or an IEC design N or H electric motor.
However, motor types that exhibit all of the characteristics listed
above, but that DOE does not believe should be subject to energy
conservation standards at this time because of the current absence of a
reliable and repeatable method to test them for efficiency, would be
listed as motors that would not at this time be subject to energy
conservation standards. Once a test procedure becomes available, DOE
may consider setting standards for these motors at that time. See
generally, 78 FR 38456 (June 26, 2013). DOE requests comment on these
nine characteristics and their appropriateness for outlining scope of
coverage.
To facilitate the potential application of energy conservation
standards to special and definite purpose motors, DOE proposed to
define such motors and provide certain preparatory test procedure
steps. 78 FR 38456 (June 26, 2013). The definitions under consideration
would address motors currently subject to standards, specific motors
DOE is considering requiring to meet standards, and some motors that
will continue to not be required to meet particular energy conservation
standards. Some of the clarifying definitions, such as the definitions
for NEMA Design A and C electric motors, come from NEMA Standards
Publication MG 1-2009, ``Motors and Generators.'' DOE understands that
some of the motors addressed, such as partial motors and integral brake
motors, do not have standard industry-accepted definitions. For such
motor types, DOE worked with subject-matter experts (SMEs),
manufacturers, and the Motor Coalition to create the working
definitions that are proposed in the test procedure NOPR. (8 FR 38456
(June 26, 2013).
D. Technological Feasibility
1. General
EPCA requires that any new or amended energy conservation standard
that DOE prescribes shall be designed to achieve the maximum
improvement in energy efficiency that DOE determines is technologically
feasible. (42 U.S.C. 6295(o)(2)(A) and 6316(a)). In each standards
rulemaking, DOE conducts a screening analysis based on information
gathered on all current technology options and prototype designs that
could improve the efficiency of the products or equipment that are the
subject of the rulemaking. As the first step in such an analysis, DOE
develops a list of technology options for consideration in consultation
with manufacturers, design engineers, and other interested parties. DOE
then determines which of those means for improving efficiency are
technologically feasible.
Where DOE determines that particular technology options are
technologically feasible, it further evaluates each technology option
in view of the following additional screening criteria: (1)
Practicability to manufacture, install, or service; (2) adverse impacts
on product utility or availability; and (3) adverse impacts on health
or safety. Section IV.B of this notice addresses the results of the
screening analysis for electric motors, particularly the designs DOE
considered--those it screened out, and those that are the basis for the
trial standard levels (TSLs) in this rulemaking. For further details on
the screening analysis for this rulemaking, see chapter 4 of the NOPR
TSD.
[[Page 73603]]
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a new or amended standard for a type or
class of covered product, it must determine the maximum improvement in
energy efficiency or maximum reduction in energy use that is
technologically feasible for such product. (42 U.S.C. 6295(p)(1)) This
requirement also applies to DOE proposals to amend the standards for
electric motors. See 42 U.S.C. 6316(a). Accordingly, in its engineering
analysis, DOE determined the maximum technologically feasible (``max-
tech'') improvements in energy efficiency for electric motors, using
the design parameters for the most efficient motors available on the
market or in working prototypes. (See chapter 5 of the NOPR TSD.) The
max-tech levels that DOE determined for this rulemaking are described
in section IV.C.3 of this proposed rule.
E. Energy Savings
1. Determination of Savings
Section 325(o) of EPCA also provides that any new or amended energy
conservation standard that DOE prescribes shall be designed to achieve
the maximum improvement in energy efficiency that DOE determines is
economically justified. (42 U.S.C. 6295(o)(2)(A)-(B) and 6316(a)). In
addition, in determining whether such standard is technologically
feasible and economically justified, DOE may not prescribe standards
for certain types or classes of electric motors if such standards would
not result in significant energy savings. (42 U.S.C. 6295(o)(3)(B) and
6316(a)). For each TSL, DOE projected energy savings from the motors
that would be covered under this rulemaking and that would be purchased
in the 30-year period that begins in the year of compliance with the
new and amended standards (2015-2044). The savings are measured over
the entire lifetime of equipment purchased in the 30-year period.\17\
DOE quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
base case. The base case represents a projection of energy consumption
in the absence of new or amended mandatory efficiency standards, and
considers market forces and policies that affect demand for more
efficient equipment.
---------------------------------------------------------------------------
\17\ 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 equipment
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.
---------------------------------------------------------------------------
DOE used its national impact analysis (NIA) spreadsheet model to
estimate the energy savings from new and amended standards for the
equipment that would be subject to this rulemaking. The NIA spreadsheet
model (described in section IV.H of this notice) calculates energy
savings in site energy, which is the energy directly consumed by motors
at the locations where they are used. For electricity, DOE reports
national energy savings in terms of the savings in the energy that is
used to generate and transmit the site electricity. To calculate source
energy, DOE derives annual conversion factors from the model used to
prepare the Energy Information Administration's (EIA) Annual Energy
Outlook (AEO).
DOE has begun to also estimate full-fuel-cycle energy savings. 76
FR 51282 (August 18, 2011), as amended at 77 FR 49701 (August 17,
2012). The full-fuel-cycle (FFC) metric includes the energy consumed in
extracting, processing, and transporting primary fuels, and thus
presents a more complete picture of the impacts of energy efficiency
standards. DOE's evaluation of FFC savings is driven in part by the
National Academy of Science's (NAS) report on FFC measurement
approaches for DOE's Appliance Standards Program.\18\ The NAS report
discusses that FFC was primarily intended for energy efficiency
standards rulemakings where multiple fuels may be used by a particular
product. In the case of this rulemaking pertaining to electric motors,
only a single fuel--electricity--is consumed by the equipment. DOE's
approach is based on the calculation of an FFC multiplier for each of
the energy types used by covered equipment. The methodology for
estimating FFC does not project how fuel markets would respond to this
particular standard rulemaking. The FFC methodology simply estimates
how much additional energy, and in turn how many tons of emissions, may
be displaced if the estimated fuel were not consumed by the equipment
covered in this rulemaking. It is also important to note that inclusion
of FFC savings does not affect DOE's choice of proposed standards.
---------------------------------------------------------------------------
\18\ ``Review of Site (Point-of-Use) and Full-Fuel-Cycle
Measurement Approaches to DOE/EERE Building Appliance Energy-
Efficiency Standards,'' (Academy report) was completed in May 2009
and included five recommendations. A copy of the study can be
downloaded at: https://www.nap.edu/catalog.php?record_id=12670.
---------------------------------------------------------------------------
2. Significance of Savings
As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting
a standard for a covered product unless such standard would result in
``significant'' energy savings. Although the term ``significant'' is
not explicitly defined in EPCA, the U.S. Court of Appeals, in Natural
Resources Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir.
1985), indicated that Congress intended ``significant'' energy savings
in this context to be savings that were not ``genuinely trivial.'' DOE
believes that the energy savings for all of the TSLs considered in this
rulemaking (presented in section V.A) are nontrivial, and, therefore,
DOE considers them ``significant'' within the meaning of section 325 of
EPCA.
F. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be evaluated in determining whether
a potential energy conservation standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i)) The following sections detail how DOE
addresses each of those factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a new or amended standard on
manufacturers, DOE first uses an annual cash-flow approach to determine
the quantitative impacts. This step includes both a short-term
assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period.\19\ The industry-wide impacts analyzed include industry net
present value (INPV), which values the industry on the basis of
expected future cash flows; cash flows by year; changes in revenue and
income; and other measures of impact, as appropriate. Second, DOE
analyzes and reports the impacts on different types of manufacturers,
including impacts on small manufacturers. Third, DOE considers the
impact of standards on domestic manufacturer employment and
manufacturing capacity, as well as the potential for standards to
result in plant closures and loss of capital investment. Finally, DOE
takes into account cumulative impacts of various DOE regulations and
other regulatory requirements on manufacturers.
---------------------------------------------------------------------------
\19\ DOE also presents a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
For individual consumers, measures of economic impact include the
changes in life-cycle cost (LCC) and payback period (PBP) associated
with new or amended standards. The LCC, addressed
[[Page 73604]]
as ``savings in operating costs'' at 42 U.S.C. 6295(o)(2)(B)(i)(II), is
one of seven factors considered in determining the economic
justification for a new or amended standard and is discussed in the
following section. For consumers in the aggregate, DOE also calculates
the national net present value of the economic impacts applicable to a
particular rulemaking.
b. Life-Cycle Costs
The LCC is the sum of the purchase price of a piece of equipment
(including its installation) and the operating expense (including
energy, maintenance, and repair expenditures) discounted over the
lifetime of that equipment. The LCC savings for the considered
efficiency levels are calculated relative to a base case that reflects
projected market trends in the absence of new or amended standards. The
LCC analysis requires a variety of inputs, such as equipment prices,
equipment energy consumption, energy prices, maintenance and repair
costs, equipment lifetime, and consumer discount rates. For its
analysis, DOE assumes that consumers, as users of electric motors, will
purchase the considered equipment in the first year of compliance with
new or amended standards.
To account for uncertainty and variability in specific inputs, such
as equipment lifetime and discount rate, DOE uses a distribution of
values with probabilities attached to each value. DOE identifies the
percentage of consumers estimated to receive LCC savings or experience
an LCC increase, in addition to the average LCC savings associated with
a particular standard level. DOE also evaluates the LCC impacts of
potential standards on identifiable subgroups of consumers that may be
affected disproportionately by a national standard.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for imposing an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section IV.H, DOE uses the NIA spreadsheet to project
national energy savings.
d. Lessening of Utility or Performance
In establishing classes of products, and in evaluating design
options and the impact of potential standard levels, DOE evaluates
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) As noted earlier,
the substance of this provision applies to the equipment at issue in
today's proposal as well. DOE has determined that the standards
proposed in today's notice will not reduce the utility or performance
of the equipment under consideration in this rulemaking. One piece of
evidence for this claim includes the fact that many motors are already
commonly being sold at the proposed levels (NEMA's ``Premium''
designation). A second piece of evidence is that the proposed standards
closely track the recommendations of NEMA, which represents
manufacturers who understand deeply the design compromises entailed in
reaching higher efficiencies and who would be acting against the
interest of their customers in recommending standards that would harm
performance or utility.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from the imposition of a standard. (42 U.S.C.
6295(o)(2)(B)(i)(V). It also directs the Attorney General to determine
the impact, if any, of any lessening of competition likely to result
from a proposed standard and to transmit such determination to the
Secretary of Energy within 60 days of the publication of a proposed
rule, together with an analysis of the nature and extent of the impact.
(42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of today's
proposed rule to the Attorney General with a request that the
Department of Justice (DOJ) provide its determination on this issue.
DOE will address the Attorney General's determination in the final
rule.
f. Need for National Energy Conservation
The energy savings from the proposed standards are likely to
provide improvements to the security and reliability of the Nation's
energy system. Reductions in the demand for electricity also may result
in reduced costs for maintaining the reliability of the Nation's
electricity system. DOE conducts a utility impact analysis to estimate
how standards may affect the Nation's needed power generation capacity.
The proposed standards also are likely to result in environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases associated with energy production. DOE reports the
emissions impacts from today's standards, and from each TSL it
considered, in section V.B.4 of this notice. DOE also reports estimates
of the economic value of emissions reductions resulting from the
considered TSLs.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a
standard is economically justified, to consider any other factors that
the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effects that proposed
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the three-
year payback period contemplated under the rebuttable-presumption test.
In addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the Nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable presumption payback calculation
is discussed in section IV.F.12 of this proposed rule.
IV. Methodology and Discussion of Related Comments
DOE used four spreadsheet tools to estimate the impact of today's
proposed standards. The first spreadsheet calculates LCCs and PBPs of
potential new energy conservation standards. The second provides
shipments forecasts and the third calculates national energy savings
and net present value impacts of potential new energy conservation
standards. The fourth tool helps assess manufacturer impacts, largely
through use of the Government Regulatory Impact Model (GRIM).
Additionally, DOE estimated the impacts of energy conservation
standards for electric motors on utilities
[[Page 73605]]
and the environment. DOE used a version of EIA's National Energy
Modeling System (NEMS) for the utility and environmental analyses. The
NEMS model simulates the energy sector of the U.S. economy. EIA uses
NEMS to prepare its Annual Energy Outlook (AEO), a widely known energy
forecast for the United States. The version of NEMS used for appliance
standards analysis is called NEMS-BT \20\ and is based on the AEO
version with minor modifications.\21\ The NEMS-BT model offers a
sophisticated picture of the effect of standards because it accounts
for the interactions between the various energy supply and demand
sectors and the economy as a whole.
---------------------------------------------------------------------------
\20\ BT stands for DOE's Building Technologies Program.
\21\ The EIA allows the use of the name ``NEMS'' to describe
only an AEO version of the model without any modification to code or
data. Because the present analysis entails some minor code
modifications and runs the model under various policy scenarios that
deviate from AEO assumptions, the name ``NEMS-BT'' refers to the
model as used here. For more information on NEMS, refer to The
National Energy Modeling System: An Overview, DOE/EIA-0581 (98)
(Feb. 1998), available at: https://tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf.
---------------------------------------------------------------------------
A. Market and Technology Assessment
For the market and technology assessment, DOE develops information
that provides an overall picture of the market for the equipment
concerned, including the purpose of the equipment, the industry
structure, and market characteristics. This activity includes both
quantitative and qualitative assessments, based primarily on publicly
available information. The subjects addressed in the market and
technology assessment for this rulemaking include scope of coverage,
equipment classes, types of equipment sold and offered for sale, and
technology options that could improve the energy efficiency of the
equipment under examination. Chapter 3 of the TSD contains additional
discussion of the market and technology assessment.
1. Current Scope of Electric Motors Energy Conservation Standards
EISA 2007 amended EPCA to prescribe energy conservation standards
for four categories of electric motors: General purpose electric motors
(subtype I) (hereinafter, ``subtype I''), general purpose electric
motors (subtype II) (hereinafter, ``subtype II''), fire pump electric
motors, and NEMA Design B, general purpose electric motors that also
meet the subtype I or subtype II definitions and are rated above 200
horsepower through 500 horsepower. DOE's most recent test procedure
final rule added clarity to the definitions for each of these motor
categories, which are now codified at 10 CFR 431.12. 77 FR 26608.
Although DOE is not proposing to modify these definitions,
commenters sought additional clarifications. During the preliminary
analysis public meeting, NEMA expressed confusion regarding whether IEC
frame motors would fall under the subtype I or subtype II designation,
as DOE defined them to be related to both definitions. NEMA added that
because subtype I and subtype II electric motors are subject to
different efficiency standards, manufacturers producing IEC frame
motors are confused as to whether IEC frame motors are subject to NEMA
MG 1 Table 12-11 or Table 12-12 efficiency standards.\22\ (NEMA, Public
Meeting Transcript, No. 60 at pp. 36, 37)
---------------------------------------------------------------------------
\22\ The efficiency levels found in Table 12-12 are the more
stringent of the two sets of efficiency tables.
---------------------------------------------------------------------------
DOE understands that an IEC frame motor could be treated as either
a subtype I or subtype II motor depending on its other characteristics.
Having an IEC frame alone does not dictate whether a motor is a general
purpose subtype I or subtype II motor; rather, other physical
characteristics, such as equivalency to a NEMA Design A, B, or C
electric motor, and whether it has mounting feet could determine the
subtype designation and associated energy efficiency standard level.
All of these elements flow directly from the statutory changes enacted
by EISA 2007. (See EISA 2007, sec. 313(a)(3), codified at 42 U.S.C.
6311(13)) Currently, electric motors are required to meet energy
conservation standards as follows:
Table IV.1--Current Electric Motor Energy Conservation Standards \23\
----------------------------------------------------------------------------------------------------------------
Electric motor category Horsepower range Energy conservation standard level
----------------------------------------------------------------------------------------------------------------
General Purpose Electric Motors 1 to 200 (inclusive)...... MG 1-2011 Table 12-12.
(Subtype I).
General Purpose Electric Motors 1 to 200 (inclusive)...... MG 1-2011 Table 12-11.
(Subtype II).
NEMA Design B and...................... 201 to 500 (inclusive).... MG 1-2011 Table 12-11.
IEC Design N Motors....................
Fire Pump Electric Motors.............. 1 to 500 (inclusive)...... MG 1-2011 Table 12-11.
----------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------
\23\ For the purposes of determining compliance, DOE assesses a
motors horsepower rating according to the provisions of 10 CFR
431.25(e).
---------------------------------------------------------------------------
Additionally, NEMA requested clarification on the terminology DOE
intends to use for NEMA Design B motors, namely whether the term is
``NEMA Design B motor'' or ``NEMA Design B electric motor'' and what,
if any, differences there are between the two terms. (NEMA, No. 54 at
p. 14) DOE understands that the terms ``motor'' and ``electric motor''
may refer to a variety of machines outside of its regulatory context.
However, because there are no NEMA Design B motors that are not
electrically-driven, in DOE's view, the potential for ambiguity is
minimal. DOE clarifies that it is using the term ``NEMA Design B
motor,'' as is currently codified in 10 CFR 431.12. Additionally, DOE
does not consider there to be any meaningful difference between the two
terms and notes that all motors currently regulated under 10 CFR part
431, subpart B, are electric motors.
DOE requests comment on whether the proposed standards help resolve
the potential issue on which it had previously issued clarification of
whether a [IEC] motor may be considered to be subject to two standards.
2. Expanded Scope of Electric Motor Energy Conservation Standards
As referenced above, on August 15, 2012, the Motor Coalition
petitioned DOE to adopt the Coalition's consensus agreement, which, in
part, formed the basis for today's proposal.\24\ The Motor Coalition
petitioned DOE to simplify coverage to address a broad array of
electric motors with a few clearly identified exceptions. The Motor
Coalition advocated this approach to
[[Page 73606]]
simplify manufacturer compliance and to help facilitate DOE's
enforcement efforts. The Petition highlighted potential energy savings
that would result from expanding the scope of covered electric motors.
(Motor Coalition, No 35 at pp. 1-30) Subsequent to DOE's preliminary
analysis public meeting, several other interested parties submitted
comments supporting the Petition. Those supporters included: BBF and
Associates, the Air Movement and Control Association International,
Inc., U.S. Senators Lisa Murkowski and Jeff Bingaman, the Hydraulic
Institute, the Arkansas Economic Development and Commission-Energy
Office, and the Power Transmission Distributors Association.
---------------------------------------------------------------------------
\24\ The Petition is available at: https://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0027-0035.
---------------------------------------------------------------------------
The California Investor Owned Utilities (CA IOUs), represented by
the Pacific Gas and Electric Company (PG&E), Southern California Gas
Company (SCGC), San Diego Gas and Electric (SDG&E), and Southern
California Edison (SCE) commented that they supported the Petition's
intent to expand the scope of coverage to the vast majority of single
speed, polyphase, and integral horsepower induction motors between 1
and 500 horsepower, as well as increasing energy conservation standards
for some covered products. (CA IOUs, No. 57 at p. 2)
The Air Movement and Control Association International, Inc. (AMCA
International) endorsed the Petition. AMCA International encouraged DOE
to adopt the Petition to save energy as soon as possible. (AMCA
International, No. 59 at p. 1)
The CDA and BBF supported DOE's preliminary analysis and the
Petition, indicating that the Petition sets minimum efficiency levels
that represent a challenge to the industry and can have a great impact
on U.S. energy use. (BBF & Associates, No. 51 at pp. 1, 2; CDA, No. 55
at p. 1) BBF also urged DOE to investigate energy conservation
standards for motors over 500 horsepower because preliminary
indications suggest that as much as 27 percent of total motor power
consumed in the U.S. is from motors over 500 horsepower, and higher
efficiencies can provide substantial savings. (BBF, No. 51 at p. 4)
EASA supported the Motor Coalition's Petition, asserting that it is
in the best interests of saving energy, U.S. jobs, and the economy
overall to adopt that Petition's approach. EASA strongly encouraged the
DOE to adopt the recommendations of the Motor Coalition, citing large
and economically justified energy savings. (EASA, No. 47 at p. 1)
ACEEE commented on behalf of the Motor Coalition, stating that
expanding the scope of energy conservation standards and only excluding
a small group of motor types will enhance enforcement efforts by the
government, by simplifying the standards to only include explicit
exclusions. (ACEEE, Public Meeting Transcript, No. 60 at p. 19)
After reviewing the Petition, DOE is proposing to require electric
motor types beyond those currently covered (and discussed in section
IV.A.1) to meet energy conservation standards. DOE's proposed expansion
is similar to the approach recommended by the Motor Coalition in its
Petition (Motor Coalition, No. 35 at pp. 1-3). DOE's proposal would
establish energy conservation standards for electric motors that
exhibit all of the characteristics listed in Table IV.2, with a limited
number of exceptions.
Table IV.2--Characteristics of Motors Regulated Under Expanded Scope of
Coverage
------------------------------------------------------------------------
Motor characteristic
-------------------------------------------------------------------------
Is a single-speed, induction motor,
Is rated for continuous duty (MG 1) operation or for duty type S1 (IEC),
Contains a squirrel-cage (MG 1) or cage (IEC) rotor,
Operates on polyphase alternating current 60-hertz sinusoidal power,
Is rated for 600 volts or less,
Is built with a 2-, 4-, 6-, or 8-pole configuration,
Is a NEMA Design A, B, or C motor (or IEC Design N or H)
Is built in a three-digit NEMA frame size or an enclosed 56-frame (or
any IEC equivalent), and
Is rated from 1 to 500 horsepower (inclusive).
------------------------------------------------------------------------
In response to its preliminary analysis, DOE received several
comments about the characteristics that DOE should use to define the
broad scope of electric motors potentially subject to energy
conservation standards. First, NEMA suggested that DOE define motor
types exhibiting the nine characteristics listed in Table IV.2. (NEMA,
No. 54 at p. 32) NEMA also requested that DOE clarify the range of
horsepower ratings included and the scope of 56- and IEC-frame motors
covered. The Energy Advocates (NPCC, NEEA, ACEEE, ASAP, Earthjustice,
ASE) also suggested that DOE include IEC-equivalents and NEMA 56-frame
sizes in the scope of coverage. (NPCC, No. 56 at p. 2)
Additionally, DOE is proposing to clarify the design, construction,
and performance characteristics of covered electric motors.
Specifically, DOE is proposing to clarify that only motors rated from 1
to 500 horsepower (inclusive), or their IEC equivalents, would be
covered by the standards being proposed in today's rulemaking. Finally,
with regard to IEC-frame motors, DOE would not cover IEC motors on the
singular basis of frame size, but would consider covering such motors
when they meet the criteria of Table IV.2. In other words, an IEC-frame
motor would need to satisfy these nine criteria for the proposed
standards to apply.
In its submitted Petition, the Coalition requested that DOE cover
all single-speed, polyphase, 56-frame induction motors rated at one
horsepower or greater that do not meet the regulatory definition for
``small electric motor'' in 10 CFR part 431, subpart X. This definition
applies to both single-phase and polyphase open-frame general purpose
AC induction motors built in a two-digit frame size. The proposal put
forth by the Coalition would expand energy conservation standards to
polyphase, enclosed 56-frame motors rated at one or more horsepower
along with polyphase, special and definite purpose open 56-frame motors
of horsepower greater than or equal to one that are not covered by
DOE's small electric motor regulations.
Regarding 56-frame motors at 1-hp or greater, DOE is proposing
standards for polyphase, enclosed 56-frame motors that are rated at 1-
hp or greater. DOE is also tentatively proposing TSL 2 for polyphase,
open 56-frame special and definite purpose motors that are rated at 1-
hp or greater as advocated by the Motor Coalition. With respect to
these motors (i.e. 56-frame, open, special and definite purpose), DOE
seeks additional data related to these motors, including, but not
limited to the following categories: Motor efficiency distributions;
shipment breakdowns between horsepower ratings, open and enclosed
motors, and between general and special and definite purpose electric
motors; and information regarding the typical applications that use
these motors. If this proposal is adopted in the final rule, DOE will
account for a substantial majority of 56-frame motors that are not
already regulated by efficiency standards and ensure coverage for all
general purpose motors along with a substantial number of special and
definite purpose motors.
Based on currently available data, DOE estimates that approximately
270,000 polyphase, open 56-frame special and definite purpose motors
(1-hp or greater) were shipped in 2011 and at least 70% of these motors
have
[[Page 73607]]
efficiency levels below NEMA Premium.\25\ In addition, based on this
data, DOE believes that establishing TSL 2 for this subset of 56-frame
motors would result in national energy savings of 0.58 quads (full-
fuel-cycle) and net present value savings of $1.11 billion (2012$),
with a 7 percent discount rate.\26\ DOE has not merged its data and
analyses related to this subset of 56-frame motors with the other
analyses in today's NOPR. As described above, DOE seeks additional
information that can be incorporated into its final analysis.
---------------------------------------------------------------------------
\25\ Shipments for these 56-open frame motors were estimated
from data provided by the Motor Coalition. DOE assumed 56-frame open
motors are distributed across 2-, 4-, and 6-pole configurations and
1 to 5 horsepower ratings. With this assumption, DOE used the
shipments distributions from ECG 1 motors across these motor
configurations and ratings to establish shipments data for open 56-
frame motors by motor configuration and horsepower rating.
Efficiency distributions were based on a limited survey of electric
motor models from six major manufacturer catalogs.
\26\ DOE used the same NIA model and inputs described in section
IV.H to estimate these values of NES and NPV, but adjusted the
shipments and efficiency distributions to match the data specific to
these 56-frame open motors.
---------------------------------------------------------------------------
DOE notes that enclosed 56-frame motors with horsepower ratings
below 1 horsepower would not, however, be covered as part of today's
proposal. DOE is not proposing to cover 56-frame size fractional motors
because EPCA, as amended, establishes energy conservation standards for
electric motors at 1-hp or greater and DOE requires the use of
different test procedures for motors above and below 1-hp. In
particular, DOE's regulations prescribe, consistent with industry
practice, the use of the Institute of Electrical and Electronics
Engineers (IEEE) Standard 112 (Test Method A) to test motors rated
below 1-hp, and IEEE Standard 112 (Test Method B) to test motor rated
at or above 1-hp. To ensure consistent testing results, DOE requires
application of the same test procedure to all electric motors.
Therefore, DOE is not proposing to regulate enclosed 56-frame size
motors rated under 1-hp.\27\ This tentative decision, however, does not
foreclose the possibility that DOE may regulate the efficiency of these
motors and may change depending on the nature of the feedback provided
by commenters with respect to this issue. DOE requests comment on its
tentative decision to not address fractional horsepower enclosed 56-
frame motors as part of today's proposal, along with any relevant
information and data.
---------------------------------------------------------------------------
\27\ DOE notes that general purpose, open 56-frame motors are
already addressed by the standards for small electric motors.
---------------------------------------------------------------------------
In view of Table IV.2, Table IV.3 lists the various electric motor
types that would be covered by DOE's proposed approach. Further details
and definitions for the motor types can be found in DOE's electric
motors test procedure NOPR, which was published on June 26, 2013 (78 FR
38456).
Table IV.3--Currently Unregulated Motor Types DOE Proposes To Cover
------------------------------------------------------------------------
------------------------------------------------------------------------
Electric Motor Type
------------------------------------------------------------------------
NEMA Design A from 201 to 500 Electric motors with non-standard
horsepower. endshields or flanges.
Electric motors with moisture Electric motors with non-standard
resistant windings. bases.
Electric motors with sealed Electric motors with special
windings. shafts.
Partial electric motors. Vertical hollow-shaft electric
motors.
Totally enclosed non-ventilated Electric motors with sleeve
(TENV) electric motors. bearings.
Immersible electric motors. Electric motors with thrust
bearings.
Integral brake electric motors. Non-integral brake electric motors.
------------------------------------------------------------------------
In view of DOE's proposed approach described in Table IV.3, DOE is
proposing to include certain motor types that some interested parties
have suggested that DOE continue to exclude from any energy efficiency
requirements. For example, the Motor Coalition would exclude integral
brake motors from coverage, as DOE once did through policy guidance,
see 62 FR 59978 (November 5, 1997), but which was subsequently removed.
See 77 FR 26638 (May 4, 2012). (Motor Coalition, No. 35 at p. 3) SEW-
Eurodrive also commented that there are two basic types of integral
gearmotor: (1) One that meets the definition in DOE's preliminary
analysis, and (2) another having a special shaft or mounting
configuration. SEW-Eurodrive contended that the second type of integral
gearmotor would require replacement of the entire rotor shaft and rotor
cage to be tested. (SEWE, No. 53, p. 3)
In view of the foregoing, DOE continues to believe that consistent
and repeatable test procedures can be prescribed for integral brake
motors, integral gearmotors, integral partial motors, and partial
[frac34] motors. See 78 FR 38456 (June 26, 2013). In particular, DOE
believes that an integral brake motor that meets the nine criteria in
Table IV.2, could be readily tested and satisfy the proposed standards.
In addition, DOE believes that the definition for ``partial electric
motor'' and ``component set'' proposed in its June test procedure NOPR
will clarify what types of items would meet these definitions, which
should help manufacturers determine whether the equipment they
manufacture fall under these terms. See 78 FR 38456 (June 26, 2013).
Furthermore, DOE believes that the type of integral gearmotor addressed
by SEW-Eurodrive (i.e., with a special shaft or mounting configuration)
would likely satisfy DOE's proposed definition of component set,
because it would require more than the addition of end shields and a
bearing to create an operable motor. (Component sets would not be
required to meet standards under today's proposal)
ACEEE supported the Motor Coalition's Petition in its approach to
expand the scope of covered motors to comply with the energy efficiency
levels found in Table 12-12 of NEMA Standards Publication MG 1-2011.
According to ACEEE, such approach could be easily accomplished by
manufacturers and, at the same time, allow them to refocus resources on
designing and building the next generation of electric motor. (ACEEE,
Public Meeting Transcript, No. 60 at pp. 18, 19) UL agreed with the
ACEEE approach and suggested that DOE clarify the scope of coverage
with a statement whereby all electric motors are subject to standards,
except for those specifically mentioned as excluded. (UL, Public
Meeting Transcript, No. 60 at pp. 60, 61) Finally, the California
Independently Owned Utilities (CA IOUs) submitted similar comments,
suggesting that DOE expand the scope of coverage and explicitly define
those motor types excluded from standards. The CA IOUs stressed that
this approach would provide clarity both to
[[Page 73608]]
compliance and enforcement efforts by government agencies and
manufacturers. (CA IOUs, No. 57 at p. 1)
After considering these comments, and further analyzing available
relevant information, DOE believes that a simplified approach to
determining coverage would help ensure consistency to the extent
possible when applying the proposed standards. Therefore, in today's
notice, DOE is proposing that an electric motor that meets the nine
characteristics in Table IV-3 would be covered and required to meet the
applicable energy conservation standards, either in NEMA MG 1 Table 12-
11 or 12-12. Additionally, DOE is proposing not to set standards at
this time for the following motors: component sets, liquid-cooled
motors, submersible motors, and definite-purpose inverter-fed motors.
DOE is not proposing to set standards for these motors in light of the
substantial difficulties and complexities that would be involved in
testing these motors at this time. In addition, DOE is proposing not to
set standards at this time for air-over motors, but intends to address
these types of motors in a separate rulemaking. Definitions for the
motor types and additional details about these issues are addressed at
78 FR 38456 (June 26, 2013).
3. Advanced Electric Motors
In its preliminary analysis, DOE addressed various ``advanced
electric motor,'' which included those listed in Table IV.4. While DOE
recognized that such motors could offer improved efficiency, regulating
them would represent a significant shift for DOE, which has primarily
focused on the efficiency of polyphase, single-speed induction motors.
Seeking more information, DOE solicited public comments about these
types of motors and how they would be tested for energy efficiency.
Table IV.4--Advanced Electric Motors
------------------------------------------------------------------------
Motor description
-------------------------------------------------------------------------
Inverter drives.
Permanent magnet motors.
Electrically commutated motors.
Switched-reluctance motors.
------------------------------------------------------------------------
DOE received comments about advanced motors from various interested
parties. NEMA asserted that, in certain applications, inverter drives,
permanent-magnet motors, electronically commutated motors, and
switched-reluctance motors, could offer improved efficiency. However,
NEMA also noted that these motors may include technologies where
standard test procedures are still being developed, making it unable to
comment. (NEMA, No. 54 at pp. 18-19) DOE understands that a test
procedure would be necessary before it contemplates setting energy
conservation standards for these types of motors. Additionally, during
the preliminary analysis public meeting, ACEEE commented that advanced
motor designs present the largest opportunity for future energy savings
within the motor marketplace and NEMA member manufacturers are already
exploring the standards-setting process for advanced motor designs in
the NEMA MG 1 standards publication. (ACEEE, Public Meeting Transcript,
No. 60 at p. 19)
Other interested parties submitted comments regarding the
efficiency of ``advanced motor systems'' and, in general, motor-driven
systems. Danfoss commented that system efficiency improvements would
provide significant energy savings, and cited variable frequency drives
(VFDs) as an example of a way to improve system efficiency. VFDs, or
inverter drives, are external components used in motor-driven systems
to control motor speed and torque by varying motor input frequency and
voltage Danfoss elaborated that VFDs could save 20 to 30 percent of the
energy that typical, non-VFD-motors consume and urged that DOE consider
this approach, instead of seeking minimal energy conservation
improvements in across-the-line start polyphase electric motors.\28\
(Danfoss, Public Meeting Transcript, No. 60 at pp. 21-23, 174, 175) UL
submitted similar comments during the preliminary analysis public
meeting, indicating that DOE and the industry should focus on improving
system-level efficiency. UL added that if a motor is not properly
matched to its load then the system efficiency could be 20 or 30
percent less efficient than possible. (UL, Public Meeting Transcript,
No. 60 at pp. 69, 70) BBF and the CDA commented that the overall
evaluation of system efficiency is very important, and the evaluation
of VFDs and the motor system represents many major opportunities for
improved efficiency. (BBF, No. 51, p. 4; CDA, No. 55, p. 2)
---------------------------------------------------------------------------
\28\ For this rulemaking, ``across-the-line start'' indicates
the electric motor is run directly on polyphase, alternating current
(AC) sinusoidal power, without any devices or controllers
manipulating the power signal fed to the motor.
---------------------------------------------------------------------------
DOE understands the concerns from interested parties regarding
advanced motor efficiency and its connection with the possible
regulation of advanced electric motors. At this time, however, DOE has
chosen not to regulate advanced motors and knows of no established
definitions or test procedures that could be applied to them. Because
DOE agrees that significant energy savings may be possible for some
advanced motors, DOE plans to keep abreast of changes to these
technologies and their use within industry, and may consider regulating
them in the future. DOE invites comment on the topic of advanced
motors, including any related definitions or test procedures that it
should consider applying as part of today's rulemaking.
4. Equipment Class Groups and Equipment Classes
When DOE prescribes or amends an energy conservation standard for a
type (or class) of covered equipment, it considers (1) the type of
energy used; (2) the capacity of the equipment; or (3) any other
performance-related feature that justifies different standard levels,
such as features affecting consumer utility. (42 U.S.C. 6295(q)) Due to
the large number of characteristics involved in electric motor design,
DOE has used two constructs to help develop its energy conservation
standards proposals for electric motors: ``equipment class groups'' and
``equipment classes.'' An equipment class represents a unique
combination of motor characteristics for which DOE is proposing a
specific energy conservation standard. There are 580 potential
equipment classes that consist of all permutations of electric motor
design types (i.e., NEMA Design A & B, NEMA Design C, fire pump
electric motor, or brake electric motor), standard horsepower ratings
(i.e., standard ratings from 1 to 500 horsepower), pole configurations
(i.e., 2-, 4-, 6-, or 8-pole), and enclosure types (i.e., open or
enclosed). An equipment class group is a collection of equipment
classes that share a common design type. For example, given a
combination of motor design type, horsepower rating, pole-
configuration, and enclosure type, the motor's design type dictates its
equipment class group, while the combination of the remaining
characteristics dictates its specific equipment class.\29\
---------------------------------------------------------------------------
\29\ At its core, the equipment class concept, which is being
applied only as a structural tool for purposes of this rulemaking,
is equivalent to a ``basic model.'' See 10 CFR 431.12. The
fundamental difference between these concepts is that a ``basic
model'' pertains to an individual manufacturer's equipment class.
Each equipment class for a given manufacturer would comprise a basic
model for that manufacturer.
---------------------------------------------------------------------------
[[Page 73609]]
In the preliminary analysis, DOE divided electric motors into three
groups based on two main characteristics: NEMA (or IEC) design letter
and whether the motor met the definition of a fire pump electric motor.
For the NOPR, DOE is keeping these three groups and adding a fourth
equipment class group for electric motors with brakes (integral and
non-integral). DOE's four resulting equipment class groups are: NEMA
Design A and B motors (ECG 1), NEMA Design C motors (ECG 2), fire pump
electric motors (ECG 3), and electric motors with brakes (ECG 4).
Within each of these groups, DOE would use combinations of other
pertinent motor characteristics to enumerate individual equipment
classes. To illustrate the differences between the two terms, consider
the following example. A NEMA Design B, 50 horsepower, two-pole
enclosed electric motor and a NEMA Design B, 100 horsepower, six-pole
open electric motor would be in the same equipment class group (ECG 1),
but each would represent a unique equipment class that will ultimately
have its own efficiency standard. Table IV.5 outlines the relationships
between equipment class groups and the characteristics used to define
equipment classes.
Table IV.5--Electric Motor Equipment Class Groups for the NOPR Analysis
----------------------------------------------------------------------------------------------------------------
Equipment class group Electric motor design Horsepower Poles Enclosure
----------------------------------------------------------------------------------------------------------------
1................................ NEMA Design A & B *... 1-500 2, 4, 6, 8 Open.
Enclosed.
2................................ NEMA Design C *....... 1-200 4, 6, 8 Open.
Enclosed.
3................................ Fire Pump *........... 1-500 2, 4, 6, 8 Open.
Enclosed.
4................................ Brake Motors *........ 1-30 4, 6, 8 Open.
Enclosed.
----------------------------------------------------------------------------------------------------------------
* Including IEC equivalents.
NEMA submitted multiple comments about DOE's equipment class groups
and equipment classes. First, NEMA argued that such expansive groups
could make it difficult to properly determine efficiency standards,
particularly given the large expansion of scope being contemplated by
DOE. (NEMA, No. 54 at p. 40) NEMA recommended that ``for `electric
motors' the term `equipment class' be identified as those electric
motors which are of the polyphase squirrel-cage induction type.'' It
added that:
``An `equipment class group' can be defined as a particular
`group' of such `electric motor' having a particular set of common
characteristics, such as NEMA Design A and B electric motors or NEMA
Design C electric motors, or fire pump electric motors. Each
`equipment class group' can be organized according to `rating' where
`rating' is as it is presently defined in Sec. 431.12 [of 10 CFR
Part 431]. When appropriate, an AEDM [alternative efficiency
determination method] can then be substantiated for the complete
`equipment class' of polyphase squirrel-cage induction electric
motors as is permitted and done today.''
Additionally, NEMA suggested that DOE separate U-frame motors from
T-frame motors during the analysis because any proposed increase in
efficiency standards for the low volume production of U-frame motors
would likely result in a reduction in the availability of U-frame
motors, which they assert, is not permitted under 42 U.S.C. 6295(o)(4).
(NEMA, No. 54 at pp. 20, 26) Citing the high cost of redesigning these
motors relative to the potential savings, the Motor Coalition predicted
manufacturers would exit the U-frame market leaving only one or two
manufacturers. (Motor Coalition, No. 35 at p. 13) NEMA also stated that
the demand for this type of motor has been declining since the 1960's
and U-frame motors have not been included in the NEMA MG 1 standard
since U-frame motors were replaced by T-frame motors as the NEMA
standard in the 1960s. (NEMA, No. 54 at pp. 19, 20) NEMA added that the
challenge created by substituting a U-frame motor with a T-frame motor
must be accounted for in the manufacturer and national impact analyses.
EISA 2007 prescribed energy conservation standards for electric
motors built with a U-frame, whereas previously only electric motors
built with a T-frame were covered.\30\ (Compare 42 U.S.C.
6311(13)(A)(1992) with 42 U.S.C. 6311(13)(B)(2011)) In general, for the
same combination of horsepower rating and pole configuration, an
electric motor built in a U-frame is built with a larger ``D''
dimension than an electric motor built in a T-frame. The ``D''
dimension is a measurement of the distance from the centerline of the
shaft to the bottom of the mounting feet. Consequently, U-frame motors
should be able to reach efficiencies as high, or higher, than T-frame
motors with similar ratings (i.e., horsepower, pole-configuration, and
enclosure) because the larger frame size allows for more active
materials, such as copper wiring and electrical steel, which help
reduce I\2\R (i.e., losses arising from the resistivity of the current-
carrying material) and core losses (losses that result from magnetic
field stability changes). Furthermore, U-frame motors do not have any
unique utility relative to comparable T-frame motors. In general, a T-
frame design could replace an equivalent U-frame design with minor
modification of the mounting configuration for the driven equipment. By
comparison, a U-frame design that is equivalent to a T-frame design
could require substantial modification to the mounting configuration
for the same piece of driven equipment because of its larger size.
DOE's research indicated that manufacturers sell conversion brackets
for installing T-frame motors into applications where a U-frame motor
had previously been used.\31\
---------------------------------------------------------------------------
\30\ The terms ``U-frame'' and ``T-frame'' refer to lines of
frame size dimensions, with a T-frame motor having a smaller frame
size for the same horsepower rating as a comparable U-frame motor.
In general, ``T'' frame became the preferred motor design around
1964 because it provided more horsepower output in a smaller
package.
\31\ See, for example, https://www.overlyhautz.com/adaptomounts1.html.
---------------------------------------------------------------------------
Regarding NEMA's contention that U-frame motors will become
unavailable if DOE does not separate these motors from T-frame motors
when developing efficiency standards, DOE understands NEMA's concerns
regarding the diminishing market size of U-frame motors and the
potential for them to disappear. However, DOE believes that such an
occurrence would not be the
[[Page 73610]]
result of an efficiency standard that is technologically infeasible for
U-frame motors, but because U-frame motors offer no unique utility
relative to T-frame motors. Furthermore, DOE believes that the proposed
standards are unlikely to result in the unavailability of U-frame
motors. Based on catalog data from several large electric motor
manufacturers, DOE observed that 70 percent of currently available U-
frame models meet the proposed standard (TSL 2). With much of the U-
frame market already at the proposed standard, DOE sees no technical
reason that U-frame manufacturers would not be able to comply with TSL
2.
DOE also notes that under 42 U.S.C. 6295(o)(4), EPCA proscribes the
promulgation of standards that would result in the ``unavailability in
the United States in any covered product type (or class) of performance
characteristics (including reliability), features, sizes, capacities,
and volumes that are substantially the same as those generally
available in the United States at the time of the Secretary's
finding.'' The provision does not require the continued protection of
particular classes or types of product--or in this case, electric
motors--if the same utility continues to be available for the consumers
who are purchasing the given product. Consequently, based on available
information, DOE has not separated U-frame motors into a unique
equipment class group. DOE welcomes any additional data relevant to
this finding, including data that would suggest the need for an
alternate approach. DOE also requests additional information from
manufacturers on whether covering U-frame motors would cause them to be
unavailable in the U.S. and whether U-frame motors have any particular
performance characteristics, features, sizes, capacities, or volumes.
Finally, NEMA questioned DOE's use of the term ``equipment class''
to describe a combination of horsepower rating, pole configuration, and
enclosure type instead of using the term ``rating,'' which is defined
in 10 CFR 431.12, as part of the definition of a ``basic model.''
(NEMA, No. 54 at p. 25) NEMA believes that this could cause confusion
because of proposals regarding certification, alternative efficiency
determination methods (AEDMs), and enforcement in a separate
rulemaking, which are all centered around ``equipment classes.'' (NEMA,
No. 54 at p. 25) NEMA stated that DOE's definition in this rulemaking
has the adverse impact of requiring substantiation of an AEDM
separately for every rating for which it is to be used and would
constitute a significant increase in compliance burden. (NEMA, No. 54
at p. 25) DOE understands NEMA's concerns regarding the potential of
undue compliance burden. DOE notes that it has not proposed a
regulatory definition for the term ``equipment class.'' It is merely a
construct for use in the various analyses in today's rulemaking. The
term ``equipment class'' as described in this rulemaking should not be
misconstrued as having any regulatory meaning as it relates to the
definition of ``basic model.'' In today's rulemaking, DOE is continuing
to use the terminology as described in the preliminary analysis and
above. DOE intends to address NEMA's concerns regarding the potential
compliance burden in a separate rulemaking that will address
compliance, certification and enforcement-related issues.
a. Electric Motor Design Letter
The first criterion that DOE considered when disaggregating
equipment class groups was based on the NEMA (and IEC) design letter.
The NEMA Standards Publication MG 1-2011, ``Motors and Generators,''
defines a series of standard electric motor designs that are
differentiated by variations in performance requirements. These designs
are designated by letter--Designs A, B, and C. (See NEMA MG 1-2011,
paragraph 1.19.1). These designs are categorized by performance
requirements for full-voltage starting and developing locked-rotor
torque, breakdown torque, and locked-rotor current, all of which affect
an electric motor's utility and efficiency. DOE is proposing to
regulate the efficiency of each of these design types.
The primary difference between a NEMA Design A and NEMA Design B
electric motor is that they have different locked-rotor current
requirements. NEMA Design B motors must not exceed the applicable
locked-rotor current level specified in NEMA MG 1-2011, paragraph
12.35.1. NEMA Design A motors, on the other hand, do not have a maximum
locked-rotor current limit. In most applications, NEMA Design B motors
are generally preferred because locked-rotor current is constrained to
established industry standards, making it easier to select suitable
motor-starting devices. However, certain applications have special load
torque or inertia requirements, which result in a design with high
locked-rotor current (NEMA Design A). When selecting starting devices
for NEMA Design A motors, extra care must be taken in properly sizing
electrical protective devices to avoid nuisance tripping during motor
startup. The distinction between NEMA Design A and NEMA Design B motors
is important to users who are sensitive to high locked-rotor current;
however, both NEMA Design A and Design B motors have identical
performance requirements in all other metrics, which indicates that
they offer similar levels and types of utility. Given these
similarities, DOE is proposing to group these motors together into a
single equipment class grouping for the purposes of this rulemaking.
In contrast, DOE believes that the different torque requirements
for NEMA Design C electric motors represent a change in utility that
can affect efficiency performance. NEMA Design C motors are
characterized by high starting torques. Applications that are hard to
start, such as heavily loaded conveyors and rock crushers, require this
higher starting torque. The difference in torque requirements will
restrict which applications can use which NEMA Design types. As a
result, NEMA Design C motors cannot always be replaced with NEMA Design
A or B motors, or vice versa. Therefore, as in the preliminary
analysis, DOE has analyzed NEMA Design C motors in an equipment class
group separate from NEMA Design A and B motors.
In chapter two, ``Analytical Framework,'' of the preliminary
technical support document, DOE noted numerous instances where
manufacturers were marketing electric motors rated greater than 200
horsepower as NEMA Design C motors. DOE understands that NEMA MG 1-2011
specifies Design C performance requirements for motors rated 1-200 hp
in four-, six-, and eight-pole configurations--a motor rated above 200
hp or using a two-pole configuration would not meet the Design C
specifications. DOE requested public comment about whether motors that
are name-plated as NEMA Design C, but that fall outside the ratings for
which NEMA Design C is defined, can be considered to be NEMA Design C
motors. In its comments, NEMA asserted it did not support marking a
motor as NEMA Design C where no standard exists for two-pole designs,
or four-, six- or eight-pole motors over 200 horsepower. NEMA
recommended that any such improperly marked motor be examined for
determination of its proper Design letter relative to the applicable
standards in NEMA MG 1. Furthermore, NEMA recommended that DOE not
include efficiency standards for motors of any design type for which
NEMA or IEC standards do not exist. (NEMA, No. 54 at p. 19)
DOE understands that without established performance standards that
form the basis for a two-pole NEMA
[[Page 73611]]
Design C motor or a NEMA Design C motor with a horsepower rating above
200, motors labeled as such would not meet the proposed regulatory
definition for ``NEMA Design C motor.'' 78 FR 38456 (June 26, 2013).
DOE considers motors at these ratings to be improperly labeled if they
are name-plated as NEMA Design C. Mislabeled NEMA Design C motors,
however, are still subject to energy conservation standards if they
meet the definitions and performance standards for a regulated motor--
e.g. NEMA Design A or B. And since these motors either need to meet the
same efficiency levels or would be required by customers to meet
specific performance criteria expected of a given design letter (i.e.
Design A, B, or C), DOE does not foresee at this time any incentive
that would encourage a manufacturer to identify a Design A or B motor
as a Design C motor for standards compliance purposes. DOE understands,
however, that NEMA Design C motors as a whole constitute an extremely
small percentage of motor shipments--less than two percent of
shipments--covered by this rulemaking, which would appear to create an
unlikely risk that mislabeling motors as NEMA Design C will be used as
an avenue to circumvent standards. Nevertheless, DOE will monitor the
potential presence of such motors and may reconsider standards for them
provided such practice becomes prevalent.
b. Fire Pump Electric Motors
In addition to considering the NEMA design type when establishing
equipment class groups, DOE considered whether an electric motor is a
fire pump electric motor. EISA 2007 prescribed energy conservation
standards for fire pump electric motors (42 U.S.C. 6313(b)(2)(B)) and,
subsequently, DOE adopted a definition for the term ``fire pump
electric motor,'' which incorporated portions of National Fire
Protection Association Standard (NFPA) 20, ``Standard for the
Installation of Stationary Pumps for Fire Protection'' (2010). Pursuant
to NFPA 20, a fire pump electric motor must comply with NEMA Design B
performance standards and must continue to run in spite of any risk of
damage stemming from overheating or continuous operation. The
additional requirements for a fire pump electric motor constitutes a
change in utility that DOE believes could also affect its performance
and efficiency. Therefore, DOE established a separate equipment class
group for such motors in the preliminary analysis to account for the
special utility offered by these motors. In its comments, NEMA agreed
with DOE's decision to separate fire pump electrical motors as a
separate equipment class group. (NEMA, No. 54 at p. 20) Consequently,
DOE is proposing to continue using a separate equipment class group for
fire pump electric motors.
c. Brake Motors
In its NOPR analyses, DOE considered whether the term ``electric
motor'' should include an integral brake electric motor or a non-
integral brake electric motor (collectively, ``brake motors''). In the
test procedure NOPR, DOE proposed definitions both for integral and
non-integral brake electric motors. 78 FR 38456 (June 26, 2013). Both
of these electric motor types are contained in one equipment class
group as separate from the equipment class groups established for NEMA
Design A and B motors, NEMA Design C motors, and fire pump electric
motors.
DOE understands that brake motors contain multiple features that
can affect both utility and efficiency. In most applications, electric
motors are not required to stop immediately. Instead, electric motors
typically slow down and gradually stop after power is removed from the
motor due to a buildup of friction and windage from the internal
components of the motor. However, some applications require electric
motors to stop quickly. Such motors may employ a brake component that,
when engaged, abruptly slows or stops shaft rotation. The brake
component attaches to one end of the motor and surrounds a section of
the motor's shaft. During normal operation of the motor, the brake is
disengaged from the motor's shaft--it neither touches nor interferes
with the motor's operation. However, under normal operating conditions,
the brake is drawing power from the electric motor's power source and
may also be contributing to windage losses, because the brake is an
additional rotating component on the motor's shaft. When power is
removed from the electric motor (and therefore the brake component),
the brake component de-energizes and engages the motor shaft, quickly
slowing or stopping rotation of the rotor and shaft components. Because
of these utility related features that affect efficiency, DOE has
preliminarily established a separate equipment class group for electric
motors with an integral or non-integral brake.
d. Horsepower Rating
In its preliminary analysis, DOE considered three criteria when
differentiating equipment classes. The first criterion was horsepower,
a critical performance attribute of an electric motor that is directly
related to the capacity of an electric motor to perform useful work and
that generally scales with efficiency. For example, a 50-horsepower
electric motor would generally be considered more efficient than a 10-
horsepower electric motor. In view of the direct correlation between
horsepower and efficiency, DOE preliminarily used horsepower rating as
a criterion for distinguishing equipment classes in the framework
document and continued with that approach for the preliminary analysis.
NEMA agreed with DOE's view that horsepower is a performance
attribute that must be considered when evaluating efficiency and urged
that this long-established and workable concept not be abandoned.
(NEMA, No. 54 at p. 40) In today's proposal, DOE continues to use
horsepower as an equipment class-setting criterion.
e. Pole Configuration
The number of poles in an induction motor determines the
synchronous speed (i.e., revolutions per minute) of that motor. There
is an inverse relationship between the number of poles and a motor's
speed. As the number of poles increases from two to four to six to
eight, the synchronous speed drops from 3,600 to 1,800 to 1,200 to 900
revolutions per minute, respectively. In addition, manufacturer
comments and independent analysis performed on behalf of DOE indicate
that the number of poles has a direct impact on the electric motor's
performance and achievable efficiency because some pole configurations
utilize the space inside of an electric motor enclosure more
efficiently than other pole configurations. DOE used the number of
poles as a means of differentiating equipment classes in the
preliminary analysis.
In response to the preliminary analysis, NEMA agreed that the
number of poles of an electric motor has impacts a motor's achievable
efficiency and supported DOE's decision to take this characteristic
into consideration. (NEMA, No. 54 at p. 41) In today's proposal, DOE
continues to use pole-configuration as an equipment class-setting
criterion.
f. Enclosure Type
EISA 2007 prescribes separate energy conservation standards for
open and enclosed electric motors. (42 U.S.C. 6313(b)(1)) Electric
motors manufactured with open construction allow a free interchange of
air between the electric motor's interior and exterior. Electric motors
with enclosed
[[Page 73612]]
construction have no direct air interchange between the motor's
interior and exterior (but are not necessarily air-tight) and may be
equipped with an internal fan for cooling (see NEMA MG 1-2011,
paragraph 1.26). Whether an electric motor is open or enclosed affects
its utility; open motors are generally not used in harsh operating
environments, whereas totally enclosed electric motors often are. The
enclosure type also affects an electric motor's ability to dissipate
heat, which directly affects efficiency. For these reasons, DOE used an
electric motor's enclosure type (open or enclosed) as an equipment
class setting criterion in the preliminary analysis.
NEMA acknowledged in its comments that the enclosure type is an
important characteristic that affects the achievable efficiency for any
particular electric motor. NEMA added that it may become necessary to
consider separate groups for various enclosures as DOE continues to
expand the scope of electric motors subject to energy conservation
standards, but did not make any specific suggestions regarding which
enclosures could be considered separately. (NEMA, No. 54 at p. 42)
At this time, DOE is continuing to use separate equipment class
groups for open and enclosed electric motors but is declining to
further break out separate equipment classes for different types of
open or enclosed enclosures because DOE does not have data supporting
such separation.
g. Other Motor Characteristics
In the preliminary analysis, DOE addressed various other motor
characteristics, but did not use them to disaggregate equipment
classes. In the preliminary analysis TSD, DOE provided its rationale
for not disaggregating equipment classes for vertical electric motors,
electric motors with thrust or sleeve bearings, close-coupled pump
motors, or by rated voltage or mounting feet. DOE believes that none of
these electric motor characteristics provide any special utility that
would impact efficiency and justify separate equipment classes.
In response to the preliminary analysis, DOE received comments
about how it should treat other motor characteristics. NEMA agreed with
DOE's decision that vertical motors, motors with thrust or sleeve
bearings, and close-coupled pump motors do not merit separate equipment
classes. (NEMA, No. 54 at p. 20) With no comments suggesting that DOE
use any one of the alternative characteristics as a criterion for
equipment class, DOE is using the approach it laid out in its
preliminary analysis.
DOE also requests additional information from manufacturers on
whether covering any of these technology options would reduce consumer
utility or performance or cause any of the covered electric motors to
be unavailable in the U.S. and whether U-frame motors have any
particular performance characteristics, features, sizes, capacities, or
volumes. In particular, DOE requests any information or data if these
technology options would lead to increases in the size of the motors
such that it would no longer work in a particular space constricted
application, to decreases in power thereby affecting their usability of
these motors, or to changes in any other characteristics that would
affect the performance or utility of the motor.
5. Technology Assessment
The technology assessment provides information about existing
technology options and designs used to construct more energy-efficient
electric motors. Electric motors have four main types of losses that
can be reduced to improve efficiency: Losses due to the resistance of
conductive materials (stator and rotor I\2\R losses), core losses,
friction and windage losses, and stray load losses. These losses are
interrelated such that measures taken to reduce one type of loss can
result in an increase in another type of losses. In consultation with
interested parties, DOE identified several technology options that
could be used to reduce such losses and improve motor efficiency. These
technology options are presented in Table IV.6. (See chapter 3 of the
TSD for details).
Table IV.6--Technology Options To Increase Electric Motor Efficiency
--------------------------------------------------------------------------------------------------------------------------------------------------------
Type of loss to reduce Technology option
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stator I\2\R Losses............................ Increase cross-sectional area of copper in stator slots.
Decrease the length of coil extensions.
Rotor I\2\R Losses............................. Use a die-cast copper rotor cage.
Increase cross-sectional area of rotor conductor bars.
Increase cross-sectional area of end rings.
Core Losses.................................... Use electrical steel laminations with lower losses (watts/lb).
Use thinner steel laminations.
Increase stack length (i.e., add electrical steel laminations).
Friction and Windage Losses.................... Optimize bearing and lubrication selection.
Improve cooling system design.
Stray-Load Losses.............................. Reduce skew on rotor cage.
Improve rotor bar insulation.
--------------------------------------------------------------------------------------------------------------------------------------------------------
In response to the preliminary analysis, DOE received multiple
comments about these options.
At the preliminary analysis public meeting, NEMA requested
clarification on what was meant by the technology option listed as
``improving rotor bar insulation.'' (NEMA, Public Meeting Transcript,
No. 60 at p. 158) NEMA commented on the option of increasing the cross
sectional area of the stator windings and clarified that this is one
way to decrease stator resistance, but not necessarily a separate
technology option. (NEMA, No. 54 at p. 44) NEMA also clarified that
reducing rotor resistance through a change in volume is synonymous with
an increase in rotor slot size, unless DOE intends to include
variations in the volume of the end rings. (NEMA, No. 54 at p. 45)
NEMA also noted that chapter 3 of DOE's preliminary TSD did not
discuss the option of increasing the flux density in the air gap, while
chapter 4 did. (NEMA, No. 54 at p. 46) NEMA added that the air gap flux
density is not a design option that can be independently adjusted and
that for a given core length the only option available for changing the
air gap flux density is to change the number of effective turns in the
stator winding. (NEMA, No. 54 at pp. 62, 63) NEMA also commented on the
limitations associated with reducing a motor's air gap by noting that
manufacturers must ensure that the motor is still functional and that
the air gap is not so small such that the rotor
[[Page 73613]]
and stator may strike each other during operation. (NEMA, No. 54 at pp.
44-45)
Lastly, during the preliminary analysis public meeting, Danfoss
commented that the term ``technology options'' is a bit misleading
because of the design tradeoffs that must be made in order to maintain
motor performance (other than efficiency). (Danfoss, Public Meeting
Transcript, No. 60 at pp. 98, 99)
Regarding the requested clarifications, DOE notes the listed option
of ``improved rotor insulation'' refers to increasing the resistance
between the rotor squirrel-cage and the rotor laminations.
Manufacturers use different methods to insulate rotor cages, such as
applying an insulating coating on the rotor slot prior to die-casting
or heating and quenching \32\ the rotor to separate rotor bars from
rotor laminations after die-casting. DOE has updated the discussion in
the TSD chapter to clarify that there are multiple ways to implement
this technology option.
---------------------------------------------------------------------------
\32\ Quenching is rapid cooling, generally by immersion in a
fluid instead of allowing the rotor temperature to equalize to
ambient
---------------------------------------------------------------------------
DOE agrees with NEMA that increasing the cross-sectional area of
copper in the stator is synonymous with reducing the stator resistance,
and has updated the discussion in TSD chapter 3 for clarity.
Furthermore, DOE agrees with NEMA that increasing rotor slot size is a
technique that reduces rotor resistivity. DOE also considered other
techniques to reduce rotor resistivity such as increasing the volume of
the rotor end rings and using die-cast copper rotors. For the sake of
clarity, DOE has replaced the technology option ``reduce rotor
resistance'' in the TSD discussion with the specific techniques that
DOE considered in its analysis: Increasing the cross-sectional area of
the rotor conductor bars, increasing the cross-sectional area of the
end rings, and using a die-cast copper rotor cage.
With regard to increasing the flux density in the air gap, DOE
consulted with its subject matter expert and acknowledges that this
approach is not necessarily an independently adjustable design
parameter used to increase motor efficiency and has removed it from its
discussion in chapters 3 and 4 of the TSD. DOE notes that it
understands that the technology options that it discusses do have
limits, both practical limits in terms of manufacturing and design
limits in terms of their effectiveness. DOE also understands that a
manufacturer must balance any options to improve efficiency against the
possible impacts on the performance attributes of its motor designs.
a. Decrease the Length of Coil Extensions
One method of reducing resistance losses in the stator is
decreasing the length of the coil extensions at the end turns. Reducing
the length of copper wire outside the stator slots not only reduces the
resistive losses, but also reduces the material cost of the electric
motor because less copper is being used.
NEMA submitted comments acknowledging decreased coil extension as
an option to increase efficiency, but did not see the practicability.
NEMA asserted that decreasing the length of a coil extension has been a
common industry practice for over 50 years and it would be difficult to
achieve any further reductions in motor losses under this option. NEMA
added that any design changes that would decrease the length of a coil
extension must be carefully considered to ensure that the coil heads
meet all applicable creep and strike distance requirements.\33\ (NEMA,
No. 54 at p. 57)
---------------------------------------------------------------------------
\33\ Creep distance is the shortest path between two conductive
parts. An adequate creep distance protects against tracking, a
process that can lead to insulation deterioration and eventual short
circuit. Strike distance is the shortest distance through air from
one conductor to another conductor or to ground. Adequate strike
distance is required to prevent electrical discharge between two
conductors or between conductors and ground.
---------------------------------------------------------------------------
DOE understands that there may be limited efficiency gains, if any,
for most electric motors using this technology option. DOE also
understands that electric motors have been produced for many decades
and that many manufacturers have improved their production techniques
to the point where certain design parameters may already be fully
optimized. However, DOE maintains that this is a design parameter that
affects efficiency and should be considered when designing an electric
motor.
b. Increase Cross-Sectional Area of Rotor Conductor Bars
Increasing the cross-sectional area of the rotor bars, by changing
the cross-sectional geometry of the rotor, can improve motor
efficiency. Increasing the cross-sectional area of the rotor bars
reduces the resistance and thus lowers the I\2\R losses. However,
changing the shape of the rotor bars may affect the size of the end
rings and can also change the torque characteristics of the motor.
NEMA acknowledged that increasing the cross-sectional area of rotor
bars is an option to increase efficiency, but doubted whether any
additional reductions in motor losses were possible by using this
method. After 50 years of increasing efficiency through this technique,
NEMA questioned whether manufacturers could further increase the cross-
sectional area of the rotor bars, adding that the increase in rotor
current cannot exceed the square of the decrease in the rotor
resistance in order for the rotor losses to decrease. NEMA added that
any design changes using this option must be carefully considered to
ensure that the motor will meet the applicable NEMA MG 1 performance
requirements (i.e., stall time, temperature rise, overspeed) and, for
certain applications, any other industry standards (i.e., IEEE 841
\34\) to maintain the same level of utility. (NEMA, No. 54 at pp. 57,
58)
---------------------------------------------------------------------------
\34\ IEEE 841-2009, ``IEEE Standard for Petroleum and Chemical
Industry--Premium-Efficiency, Severe-Duty, Totally Enclosed Fan-
Cooled (TEFC) Squirrel Cage Induction Motors--Up to and Including
370 kW (500 hp),'' identifies the recommended practice for petroleum
and chemical industry severe duty squirrel-cage induction motors.
---------------------------------------------------------------------------
DOE recognizes that increasing the cross-sectional area of a
conductor rotor bar may yield limited efficiency gains for most
electric motors. However, DOE maintains that this is a design parameter
that affects efficiency and must be considered when designing an
electric motor. Additionally, when creating its software models, DOE
considered rotor slot design, including cross sectional areas, such
that any software model produced was designed to meet the appropriate
NEMA performance requirements for torque and locked rotor current.
c. Increase Cross-Sectional Area of End Rings
End rings are the components of a squirrel-cage rotor that create
electrical connections between the rotor bars. Increasing the cross-
sectional area of the end rings reduces the resistance and thus lowers
the I\2\R losses in the end rings. A reduction in I\2\R losses will
occur only when any proportional increase in current as a result of an
increase in the size of the end ring is less than the square of the
proportional reduction in the end ring resistance.
NEMA commented that increasing the end ring size increases the
rotor weight, and consideration must be given to the effects a heavier
end ring will have on the life of the rotor. NEMA added that any design
changes using this option must be carefully considered to ensure that
the applicable design requirements are met and intended utility
retained. (NEMA, No. 54 at p. 58)
When developing its software models, DOE relied on the expertise of
its subject matter expert. Generally,
[[Page 73614]]
increases to end ring area were limited to 10-20% are unlikely to have
significant impacts on the mechanical aspects of the rotor.
Furthermore, DOE ensured that the appropriate NEMA performance
requirements for torque and locked-rotor current were maintained with
its software modeled motors.
d. Increase the Number of Stator Slots
Increasing the number of stator slots associated with a given motor
design can, in some cases, improve motor efficiency. Similar to
increasing the amount of copper wire in a particular slot, increasing
the number of slots may in some cases permit the manufacturer to
incorporate more copper into the stator slots. This option would
decrease the losses in the windings, but can also affect motor
performance. Torque, speed and current can vary depending on the
combination of stator and rotor slots used.
NEMA indicated that increasing the number of slots to allow the
motor design engineer to incorporate additional copper into the stator
slots is contrary to any practical analysis. NEMA elaborated that the
stator core holds the stator winding in the slots and carries the
magnetic flux in the electrical steel. As stator slots increase,
insulating material will increase, reducing the total amount of cross-
sectional area for stator winding. Additionally, too large of an
increase in the number of stator slots may make it impractical to wind
the stator on automated equipment and the same may be true for a low
number of stator slots. NEMA also commented that while it agrees with
DOE that the number of stator slots can affect motor torque and
efficiency, there is a relationship between the number of rotor slots
and stator slots, and the combination of the two can have significant
effects on starting torque, sound levels, and stray load losses. NEMA
concluded that all of these effects must be considered to ensure the
practicability of manufacturing the affected motors. Other factors NEMA
noted included winding and potential sound levels--all of which could
impact utility along with health and safety concerns. (NEMA, No. 54 at
p. 61)
With respect to stator slot numbers, DOE understands that a motor
manufacturer would not add stator slots without any appreciation of the
impacts on the motor's performance. DOE also understands that there is
an optimum combination of stator and rotor slots for any particular
frame size and horsepower combination. DOE consulted with its subject
matter expert and understands that optimum stator and rotor slot
combinations have been determined by manufacturers and are in use on
existing production lines.'' Consequently, DOE has removed this
technology option from chapter 4 of the TSD.
e. Electrical Steel with Lower Losses
Losses generated in the electrical steel in the core of an
induction motor can be significant and are classified as either
hysteresis or eddy current losses. Hysteresis losses are caused by
magnetic domains resisting reorientation to the alternating magnetic
field. Eddy currents are physical currents that are induced in the
steel laminations by the magnetic flux produced by the current in the
windings. Both of these losses generate heat in the electrical steel.
In studying the techniques used to reduce steel losses, DOE
considered two types of materials: Conventional silicon steels, and
``exotic'' steels, which contain a relatively high percentage of boron
or cobalt. Conventional steels are commonly used in electric motors
manufactured today. There are three types of steel that DOE considers
``conventional:'' cold-rolled magnetic laminations, fully processed
non-oriented electrical steel, and semi-processed non-oriented
electrical steel.
One way to reduce core losses is to incorporate a higher grade of
core steel into the electric motor design (e.g., switching from an M56
to an M19 grade). In general, higher grades of electrical steel exhibit
lower core losses. Lower core losses can be achieved by adding silicon
and other elements to the steel, thereby increasing its electrical
resistivity. Lower core losses can also be achieved by subjecting the
steel to special heat treatments during processing.
The exotic steels are not generally manufactured for use
specifically in the electric motors covered in this rulemaking. These
steels include vanadium permendur and other alloyed steels containing a
high percentage of boron or cobalt. These steels offer a lower loss
level than the best electrical steels, but are more expensive per
pound. In addition, these steels can present manufacturing challenges
because they come in nonstandard thicknesses that are difficult to
manufacture.
NEMA and Baldor submitted multiple comments concerning DOE's
discussion during the preliminary analysis regarding the use of Epstein
testing to determine an electrical steel grade that would improve the
efficiency of an electric motor. (NEMA, No. 54 at pp. 21-23, 62; NEMA,
Public Meeting Transcript, No. 60 at pp. 100, 102, 103) The grading of
electrical steel is made through a standardized test known worldwide as
the Epstein Test.\35\ This test provides a standardized method of
measuring the core losses of different types of electrical steels. NEMA
commented that relying solely on Epstein test results to select grades
of steel could result in a motor designer inadvertently selecting a
steel grade that performs poorly in a motor design. NEMA supplied data
on two different samples of steel supplied by different manufacturers,
but consisting of the same steel grade. The data illustrated how the
lower loss steel (as determined by Epstein test results) resulted in a
less efficient motor when used in a prototype. NEMA noted that this
situation poses a problem for computer software modeling because a
model that represents only the general class of electrical steel and
not the steel source (manufacturer) would not be able to calculate the
difference in the results between the supposedly equivalent grades of
steels from separate manufacturers.
---------------------------------------------------------------------------
\35\ ASTM Standard A343/A343M, 2003 (2008), ``Standard Test
Method for Alternating-Current Magnetic Properties of Materials at
Power Frequencies Using Wattmeter-Ammeter-Voltmeter Method and 25-cm
Epstein Test Frame,'' ASTM International, West Conshohocken, PA
2008.
---------------------------------------------------------------------------
DOE clarifies that its computer software did not model general
classes of electrical steel, but instead modeled vendor-specific
electrical steel. DOE's software utilized core loss vs. flux density
curves supplied by an electrical steel vendor as one component of the
core loss calculated by the program. A second component was also added
to account for high frequency losses. DOE agrees with NEMA's claim that
relative performance derived from Epstein testing might not be
indicative of relative performance in actual motor prototypes. DOE did
not solely rely on relative steel grade when selecting electrical
steels for its designs. To illustrate this point, DOE notes that almost
all of its software modeled designs utilized M36 grade steel, even
though it was not the highest grade of electrical steel considered in
the analysis. When higher grade M15 steel was evaluated in DOE's
software modeled designs, the resulting efficiencies were actually
lower than the efficiencies when using M36 grade steel for several
reasons including the reasons cited by NEMA. The Epstein test results
for various grades of steel provided in chapter 3 of the preliminary
analysis TSD were purely informational and intended to give an
indication of the relative performance of a sample of
[[Page 73615]]
electrical steels considered. That information has been removed from
chapter 3 of the TSD to avoid any further confusion.
f. Thinner Steel Laminations
As addressed earlier, there are two types of core losses that
develop in the electrical steel of induction motors--hysteresis losses
and losses due to eddy current. Electric motors can use thinner
laminations of core steel to reduce eddy currents. The magnitude of the
eddy currents induced by the magnetic field become smaller in thinner
laminations, making the motor more energy efficient. In the preliminary
analysis, DOE only considered conventional steels with standard gauges
available in the market.
NEMA agreed with DOE's initial decision to consider only lamination
thicknesses that are currently used in motor manufacturing, as there is
a practical limit on how thick the laminations can be in electric
motors before additional losses may become significant. (NEMA, No. 54
at p. 62) DOE continues to consider this as a viable technology option
in the NOPR analysis.
g. Increase Stack Length
Adding electrical steel to the rotor and stator to lengthen the
motor can also reduce the core losses in an electric motor. Lengthening
the motor by increasing stack length reduces the magnetic flux density,
which reduces core losses. However, increasing the stack length affects
other performance attributes of the motor, such as starting torque.
Issues can arise when installing a more efficient motor with additional
stack length because the motor becomes longer and may not fit into
applications with dimensional constraints.
NEMA requested clarification of the phrase ``add stack height,''
which DOE included in its summary of technology options for improving
efficiency in chapter 3 of the preliminary TSD. NEMA was unsure if this
meant increasing the length of the core or increasing the outer
diameter of the stator core laminations. (NEMA, no. 54 at p. 45)
DOE clarifies that it was referring to increasing the length of the
stator and rotor. However, increasing the outside diameter of the
stator core is another way in which manufacturers could add active
material to their electric motor designs and potentially increase
efficiency.
NEMA agreed that changing the stack length of an electric motor can
improve core losses (i.e. reduce them), but may also change other
performance characteristics such as torque, speed and current. However,
NEMA stressed that there are limits to this technology option because
too much additional stack could cause the motor to increase in size
(i.e., frame length), which might introduce utility problems in space-
constrained applications (NEMA, No. 54 at p. 62) NEMA also commented
that since the EISA 2007 standards were enacted, only a limited number
of motor ratings above NEMA Premium have been offered because there is
not sufficient space available in most frame ratings to increase the
efficiency. (NEMA, No. 54 at p. 7) DOE understands that there are
limits to increased stack length and, as discussed in IV.C, DOE
established criterion to limit the length of the stack considered in
the engineering analysis. DOE also understands that stack length
affects consumer utility, which is a factor that DOE considers in its
selection of a standard.
h. More Efficient Cooling System
Optimizing a motor's cooling system that circulates air through the
motor is another technology option to improve the efficiency of
electric motors. Improving the cooling system reduces air resistance
and associated frictional losses and decreases the operating
temperature (and associated electrical resistance) by cooling the motor
during operation. This can be accomplished by changing the fan or
adding baffles to the current fan to help redirect airflow through the
motor.
NEMA agreed that changes in the cooling system may reduce the total
losses of a motor, but did not agree that this is equivalent to a more
efficient cooling system, as DOE described. NEMA elaborated that when
the design of an electric motor is changed, losses associated with the
cooling system may increase in order to provide a decrease in losses
associated with some other part of the design. (NEMA, No. 54 at p. 63)
DOE appreciates NEMA's comments and has clarified its phrasing of this
technology option to reflect the fact that it is the motor that becomes
more efficient, not necessarily the cooling system.
i. Reduce Skew on Conductor Cage
In the rotor, the conductor bars are not straight from one end to
the other, but skewed or twisted slightly around the axis of the rotor.
Decreasing the degree of skew can improve a motor's efficiency. The
conductor bars are skewed to help eliminate harmonics that add cusps,
losses, and noise to the motor's speed-torque characteristics. Reducing
the degree of skew can help reduce the rotor resistance and reactance,
which helps improve efficiency. However, overly reducing the skew also
may have adverse effects on starting, noise, and the speed-torque
characteristics.
NEMA inquired if this design option was considered for any of the
designs used in the engineering analysis, as the preliminary TSD did
not indicate if any rotors were skewed. (NEMA, No. 54 at p. 63) NEMA
also inquired why the option to reduce skew on the conductor cage, was
associated with I\2\R losses in chapter 3 of the preliminary TSD, but
in chapter 4 of the preliminary TSD this option was associated with
reducing stray load losses. (NEMA, No. 54 at p. 46)
DOE notes that all software designs used in the analysis had skewed
rotor designs and, in general, the skews used were approximately 100
percent of a stator or rotor slot pitch, whichever had the smaller
number of slots. Additionally, DOE intended for the option of reducing
the skew on the conductor cage to be an option associated with reducing
stray load losses and has made the appropriate adjustments to its text
and tables.
B. Screening Analysis
After DOE identified the technologies that might improve the energy
efficiency of electric motors, DOE conducted a screening analysis. The
purpose of the screening analysis is to determine which options to
consider further and which to screen out. DOE consulted with industry,
technical experts, and other interested parties in developing a list of
design options. DOE then applied the following set of screening
criteria, under sections 4(a)(4) and 5(b) of appendix A to subpart C of
10 CFR Part 430, ``Procedures, Interpretations and Policies for
Consideration of New or Revised Energy Conservation Standards for
Consumer Products,'' to determine which design options are unsuitable
for further consideration in the rulemaking:
Technological Feasibility: DOE will consider only those
technologies incorporated in commercial equipment or in working
prototypes to be technologically feasible.
Practicability to Manufacture, Install, and Service: If
mass production of a technology in commercial equipment and reliable
installation and servicing of the technology could be achieved on the
scale necessary to serve the relevant market at the time of the
effective date of the standard, then DOE will consider that technology
practicable to manufacture, install, and service.
Adverse Impacts on Equipment Utility or Equipment
Availability: DOE
[[Page 73616]]
will not further consider a technology if DOE determines it will have a
significant adverse impact on the utility of the equipment to
significant subgroups of customers. DOE will also not further consider
a technology that will result in the unavailability of any covered
equipment type with performance characteristics (including
reliability), features, sizes, capacities, and volumes that are
substantially the same as equipment generally available in the United
States at the time.
Adverse Impacts on Health or Safety: DOE will not further
consider a technology if DOE determines that the technology will have
significant adverse impacts on health or safety.
Table IV.7 below presents a general summary of the methods that a
manufacturer may use to reduce losses in electric motors. The
approaches presented in this table refer either to specific
technologies (e.g., aluminum versus copper die-cast rotor cages,
different grades of electrical steel) or physical changes to the motor
geometries (e.g., cross-sectional area of rotor conductor bars,
additional stack height). For additional details on the screening
analysis, please refer to chapter 4 of the preliminary TSD.
Table IV.7--Summary List of Options From Technology Assessment
--------------------------------------------------------------------------------------------------------------------------------------------------------
Type of loss to reduce Technology option
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stator I\2\R Losses............................ Increase cross-sectional area of copper in stator slots.
Decrease the length of coil extensions.
Rotor I\2\R Losses............................. Use a die-cast copper rotor cage.
Increase cross-sectional area of rotor conductor bars.
Increase cross-sectional area of end rings.
Core Losses.................................... Use electrical steel laminations with lower losses (watts/lb).
Use thinner steel laminations.
Increase stack length (i.e., add electrical steel laminations).
Friction and Windage Losses.................... Optimize bearing and lubrication selection.
Improve cooling system design.
Stray-Load Losses.............................. Reduce skew on rotor cage.
Improve rotor bar insulation.
--------------------------------------------------------------------------------------------------------------------------------------------------------
1. Technology Options Not Screened Out of the Analysis
The technology options in this section are options that passed the
screening criteria of the analysis. DOE considers the technology
options in this section to be viable means of improving the efficiency
of electric motors. In NEMA's view, DOE's screening analysis lacked
sufficient supporting information regarding whether a particular
technology is included or screened out of the analysis. NEMA agreed
that it is necessary to look at new technologies, but added that DOE
did not provide adequate supporting information in its analysis and the
group asserted that commenters were left without adequate material upon
which to base comments in support of or in opposition to statements
made in the preliminary TSD. NEMA suggested that a form clearly
identifying the issues pertinent to the topic be provided for each
option analyzed. NEMA stated that providing these forms for each
technology option would supply adequate material on which commenters
can develop public comments. (NEMA, No. 54 at p. 45) Additionally, when
discussing the seven criteria that DOE must consider in its analysis,
NEMA expressed that there are more criteria that should be considered.
NEMA stated that DOE must consider 4(d)(7) of 10 CFR part 430, subpart
C, appendix A which lists under sections 4.(d)(7)(viii) impacts of non-
regulatory approaches and (ix) new information relating to the factors
used for screening design options. (NEMA, No. 54 at p. 13)
Regarding NEMA's request for a form for each technology option
considered, today's NOPR provides detailed information about each
technology option considered and DOE is requesting comment on each
option. DOE understands NEMA's concerns about the technology options
not screened out of the DOE analysis. With the exception of copper
rotor motors, DOE understands that each technology option that it has
not screened out is a design option that a manufacturer would consider
in each motor designed and built. DOE recognizes that manufacturers
design their motors to balance a number of competing factors that all
inter-relate with each other, including performance, reliability, and
energy efficiency. Because the options DOE has identified can be
modified to improve efficiency while maintaining performance, it is
DOE's tentative view that at least some significant level of energy
efficiency improvement is possible with each technology option not
screened out by DOE.
Furthermore, DOE notes that it did not explicitly use each of the
technology options that passed the screening criteria in the
engineering analysis. As discussed in section IV.C, DOE's engineering
analysis was a mixture of two approaches that DOE routinely uses in its
engineering analysis methodology: The reverse-engineering approach (in
which DOE has no control over the design parameters) and the
efficiency-level approach (in which DOE tried to achieve a certain
level of efficiency, rather than applying specific design options).
This hybrid of methods did not allow for DOE to fully control which
design parameters were ultimately used for each representative unit in
the analysis. Without the ability to apply specific design options, DOE
could not include every option that was not screened out of the
analysis. Finally, DOE appreciates NEMA's comments regarding Appendix A
to Subpart U of part 430. DOE has considered all comments related to
the two factors identified by NEMA in its rule.
In addition, DOE notes that its analysis neither assumes nor
requires manufacturers to use identical technology for all motor types,
horsepower ratings, or equipment classes. In other words, DOE's
standards are technology-neutral and permit manufacturers design
flexibility.
a. Copper Die-Cast Rotors
Aluminum is the most common material used today to create die-cast
rotor bars for electric motors. Some manufacturers that focus on
producing high-efficiency designs have started to offer electric motors
with die-cast rotor bars made of copper. Copper offers better
performance than aluminum because it has better electrical conductivity
(i.e., a lower electrical resistance). However, because copper also has
a higher melting point than aluminum, the casting process becomes
[[Page 73617]]
more difficult and is likely to increase both production time and cost.
NEMA commented that performance is a relative term, and that the
NEMA MG 1-2011 standard specifies performance characteristics and
specifications for various types of motors. NEMA added that tradeoffs
among various performance characteristics related to the conductivity
of copper are required when designing a NEMA Design B electric motor
that is in full conformance with the NEMA MG 1-2011 standards. NEMA
commented that DOE did not address all aspects of motor performance
specified in the NEMA MG 1-2011 standard, especially some of the
performance requirements related to the choice of conductive material
in the rotor. (NEMA, No. 54 at p. 46)
DOE acknowledges that using copper in rotors may require different
design approaches and considerations. In its own modeling and testing
of copper rotor motors, DOE ensured that performance parameters stayed
within MG 1-2011 limits (i.e., met NEMA Design B criteria). DOE seeks
comment on any particular aspects of copper rotor design, especially
those on parameters widely viewed as challenging to meet, and requests
explanation of why such parameters are especially challenging when
using copper.
The Advocates (NEEA, NPCC, ACEEE, ASAP, Earthjustice, and ASE)
disagreed with DOE's tentative decision during the preliminary analysis
phase to include copper die-cast rotors. It urged DOE to exclude this
option in order to avoid analyzing a technology that is not ready for
use across all motor types, configurations, and horsepower ratings that
DOE would cover as part of its rulemaking. (Advocates, No. 56 at pp. 3-
4)
On a related note, NEMA commented that DOE has not publicly
established what determines a ``mass quantity.'' NEMA elaborated that a
``mass quantity'' should mean the ability to be produced in significant
volume for the entire industry. NEMA commented that DOE screened out
certain electrical steels because they could not be produced in
significant volume for the entire industry, and this same logic should
apply to copper rotor technology. (NEMA, No. 54 at p. 24)
DOE did not screen out copper as a die-cast rotor conductor
material because copper die-cast rotors passed the four screening
criteria. Because copper is in commercial use today, DOE concluded that
this material is technologically feasible and practicable to
manufacture, install, and service. Additionally, manufacturers are
already producing such equipment, which suggests that such equipment
can be safely produced in mass quantities. For example, Siemens
produces copper rotor motors for 1-20 hp and SEW-Eurodrive manufactures
a full line of motors from 1-30 hp. In addition, DOE notes that its
analysis neither assumes nor requires manufacturers to use identical
technology for all motor types, horsepower ratings, or equipment
classes.
DOE received considerable feedback concerning copper rotor
technology. Consequently, DOE has organized those comments into
sections below as they pertain to the four screening criteria.
Technological Feasibility
As part of its analysis, DOE intends to ensure that utility, which
includes frame size considerations, is maintained. Increased shipping
costs are also taken into account in the national impact analysis (NIA)
and the life-cycle cost (LCC) analysis portions of DOE's analytical
procedures.
NEMA commented that the use of a technology in a limited subclass
of electric motors does not imply that the technology can be applied to
every equipment class covered in this rulemaking. NEMA is not aware of
any available complete product line of NEMA Design A, B, or C copper
die-cast rotor electric motors manufactured in the United States, and
stated that further investigation is required to prove this technology
is valid for an entire range of designs. (NEMA, No. 54 at pp. 2, 48,
49) NEMA was able to find two manufacturers currently producing copper
rotor motors in a total of only 33 out of over 600 equipment classes
covered in this rulemaking.\36\ NEMA and Baldor added that none of
those motors are produced in the United States, and only about half of
those ratings met NEMA Design B performance requirements. (NEMA, No. 54
at pp. 48, 49; Baldor, Public Meeting Transcript, No. 60 at pp. 109,
110)
---------------------------------------------------------------------------
\36\ The equipment classes NEMA found included NEMA Design A
motors from 1 to 30 hp, 4-pole configurations, and NEMA Design B
motors from 1.5 to 20 hp in a 2-pole configuration, 1 to 20 hp in a
4-pole configuration, and 1 hp and 3-10 hp in a 6-pole
configuration. All motor configurations NEMA mentioned were enclosed
frame motors.
---------------------------------------------------------------------------
NEMA commented that the die-casting process for copper rotors can
increase core or stray load losses in the motor, and this is a problem
with copper die-casting that has not been solved in all rotor sizes.
(NEMA, No. 54 at p. 46)
NEMA cited recently conducted U.S. Army studies involving die-cast
copper rotor motors. It explained that the first study evaluated the
advantages of a die-cast copper rotor versus an aluminum rotor. The
study also attempted to optimize the process and estimate manufacturing
costs for die-cast copper rotors. NEMA commented that the results of
the study showed that the die-cast copper rotor motor was unable to
stay within the NEMA Design B locked-rotor current limits, and that
efficiency increased by less than one full NEMA band over the
comparable NEMA Design B aluminum cast-copper rotor motor. The study
reported that continued investment in cast copper rotor motor
technology development is needed to improve design optimization
methods, improve the casting process, and to investigate utilization of
cast copper in larger motor sizes. NEMA commented that the number of
die-cast copper rotors manufactured in the study was insufficient to
make any determination that die-casting could be performed on a high
and consistent quality basis necessary for general production. (NEMA,
No. 54 at p. 50, 51)
NEMA also described a different U.S. Army study where a 75-hp
aluminum rotor motor driving a pump was to be replaced with a 75-hp
copper rotor motor. NEMA explained that in the study the die-cast
copper rotor motor's optimization study indicated the motor would have
a one NEMA band increase in efficiency over the aluminum die-cast rotor
motor it was replacing. However, once built, the 75-hp die-cast copper
rotor motor had an actual efficiency of more than 1 NEMA band below the
aluminum die-cast rotor motor, with core and stray load losses of the
physical motor being higher than the computer model had predicted. NEMA
concluded that neither study was successful in demonstrating that
copper rotor die-casting technology is possible or feasible in its
current state in the U.S., and that continued investment in die-cast
copper rotor technology development is necessary to improve the copper
die-casting process and reduce stray load losses. (NEMA, No. 54 at pp.
51-53)
BBF, a consulting company working on behalf of the Copper
Development Association (CDA), commented that test data of multiple
die-cast copper rotor motors resulted in an average tested efficiency
above the motors' nameplate efficiency, whereas the test results from a
similar model aluminum rotor motor tested below its nameplate
efficiency. In its view, these results fall within the allowable
variances prescribed by NEMA with respect to measuring electric motor
energy efficiency and demonstrate the higher energy
[[Page 73618]]
efficiency potential of die-cast copper rotor motors. (BBF, No. 51 at
p. 3)
NEMA summarized that it is not aware of any prototypes or
commercially available products that have demonstrated the technical
feasibility of utilizing die-cast copper rotors sufficient to cover all
equipment classes covered in this rulemaking. NEMA disagreed with DOE's
conclusion that die-cast copper rotors successfully passed the
screening criteria for technological feasibility relative to the class
of all covered electric motors, including the 75-hp copper rotor motor
which DOE used as a representative unit in the engineering analysis.
NEMA added that DOE has not provided any evidence that die-casting
copper can successfully be applied to all electric motors covered in
this rulemaking by December 19, 2015. NEMA added that the recent
studies conducted by the United States Army noted above showed that, in
the U.S. at present or in any foreseeable future time, this technology
is not currently feasible over the range of motor ratings regulated
under this rulemaking. (NEMA, No. 54 at pp. 3, 53, 56; NEMA, Public
Meeting Transcript, No. 60 at p. 111)
The CDA disagreed with NEMA, and stated that die-cast copper rotor
motors are a feasible technology because manufacturers have already
successfully entered the copper rotor motor market. The CDA added that
a range of development issues have been overcome, again suggesting that
it is technologically feasible, but copper die-cast rotors require
redesign and optimization to take advantage of copper's different
electrical properties compared to aluminum, and many motor
manufacturers have undertaken this redesign and optimization to take
advantage of the properties of copper. (BBF, No. 51 at p. 3) The CDA
agreed, however, that current manufacturing capacity would be unable to
produce motors on the scale of five million units yearly. (CDA, Public
Meeting Transcript, No. 60 at p. 119)
DOE acknowledges that the industry is not equipped to produce all
motors with copper rotors, but has estimated the costs of both capital
and product development through interviews with manufacturers of motors
and included these costs in its engineering analysis. DOE welcomes
comment on the methodology, and on the resulting motor prices. As noted
earlier, EPCA, as amended, does not require manufacturers to use
identical technology for all motor types, horsepower ratings, or
equipment classes.
DOE recognizes that assessing the technological feasibility of
high-horsepower copper die-cast rotors is made more complex by the fact
that manufacturers do not offer them commercially. That could be for a
variety of reasons, among them:
1. Large copper die-cast rotors are physically impossible to
construct;
2. They are possible to construct, but impossible to construct to
required specifications;
3. They are possible to construct to required specifications, but
would require manufacturing capital investment to do so and be so
costly that few (if any) consumers would choose them.
Some exploratory research suggests that different organizations
have developed and used copper rotors in high-horsepower traction
(i.e., vehicle propulsion) motors. For example, Tesla Motors powers its
Roadster \37\ and Model S \38\ vehicles with copper induction motors
generating 300 \39\ or more peak horsepower and Oshkosh die-cast copper
rotor induction motors rated at 140 peak hp.\40\ Remy International,
Inc. (Remy) also builds high-horsepower copper motors that are claimed
to exceed 300 horsepower at 600V.\41\ DOE seeks comment on these, and
on other high-horsepower motors that use copper rotors.
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\37\ https://www.teslamotors.com/roadster/technology/motor.
\38\ https://www.teslamotors.com/models/specs.
\39\ https://www.teslamotors.com/roadster/specs.
\40\ See https://www.coppermotor.com/wp-content/uploads/2012/04/casestudy_army-truck.pdf.
\41\ https://www.remyinc.com/docs/hybrid/REM-12_HVH410_DataSht.pdf.
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DOE recognizes that these motors are designed for a different
purpose than most motors in the current scope of this rulemaking. Their
existence suggests that copper has been successfully used at high power
levels in an application where efficiency is critical and casts doubt
on the idea that copper die-cast rotors can be screened out with
certainty.
Another reason to be cautious about screening out copper die-cast
rotors comes from an analogous product: Distribution transformers. DOE
conducted a recent rulemaking on distribution transformers,\42\ which
(as with motors) have two sets of conductors that surround electrical
steel to transfer power. Although distribution transformers do not
rotate, many of the ways that they lose energy (e.g., conductor losses)
are the same as electric motors. They also face constraints (as motors
do) on performance aspects unrelated to efficiency; inrush current and
overall volume are two examples. At current prices, copper is generally
not viewed as economical for most efficiency levels but, if properly
designed, copper windings almost always result in smaller, cooler, and
more efficient transformers.
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\42\ Available at: https://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0048-0762.
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In general, copper may improve efficiency relative to aluminum
because it carries an inherently higher level of electrical
conductivity. Several organizations have conducted research and built
prototype \43\ motors that use materials even more conductive than
copper, such as ``superconductive'' materials that have no conductive
losses to achieve even greater electric motor efficiency. While DOE is
not considering the use of these more conductive materials at this
time, DOE notes their existence for purposes of demonstrating the
potential advantages of using materials that lower conductive losses.
---------------------------------------------------------------------------
\43\ See General Atomics marine propulsion motor at: https://www.ga.com/electric-drive-motors.
---------------------------------------------------------------------------
While recognizing that motors are not transformers, the parallels
that can be drawn leave DOE hesitant to screen out copper die-cast
rotors on the basis of technological feasibility. Relative to the above
list of possible reasons for their absence from the high-horsepower
market, DOE's analysis does not conclude copper die-cast rotors are
either: (1) Physically impossible to construct or (2) possible to
construct, but impossible to construct to required specifications.
Practicability To Manufacture, Install, and Service
Regarding DOE's projections that the annual sales of electric
motors, as defined by EISA 2007 will have grown to 5,089,000 units by
2015, including over 24,000 possible motor configurations, NEMA
commented that only a single manufacturer is currently producing die-
cast copper rotor motors, and in a very limited range. In its view,
without sufficient data and analysis to support DOE's conclusion that
``mass production'' of die-cast copper rotors is possible, NEMA asserts
that this technology would not pass the screening criterion of
practicability to manufacture, install, and service. It argues that,
based on the limited advances of the technology from 1995 to present
day in the United States, this technology is unlikely to be mature
enough by the compliance date for this rulemaking to meet the required
production of over 5 million motors in
[[Page 73619]]
the U.S., even if all manufacturing were shifted overseas. (NEMA, No.
54 at pp. 3, 47, 53, 54, 56; NEMA, Public Meeting Transcript, No. 60 at
p. 114) NEMA noted that mandating this technology may also have the
indirect effect of establishing a monopoly market in the U.S. for those
manufacturers who can produce copper rotor motors, or to push
production jobs overseas and penalize motor manufacturers that do not
have the capability to produce copper rotor motors. (NEMA, No. 54 at p.
24)
DOE recognizes the importance of maintaining a competitive market.
However, because there are at least two domestic manufacturers of
motors with copper rotors and because several more are manufacturing
internationally, DOE believes the opportunity for price manipulation is
limited. Furthermore, DOE has seen no evidence to suggest that a
monopoly would be likely to occur. DOE requests comment and further
information that would demonstrate the likelihood of a future monopoly.
BBF and the CDA commented that there are copper die-casting
facilities in the U.S.--specifically in Colorado and Ohio--as well as
in Mexico. They added that die-cast rotor motors have been produced for
North American service since 2005, and some of these motors meet NEMA
Design B requirements. The CDA and BBF added that multiple high-volume
manufacturers in Europe and Asia have produced tens of thousands of
die-cast copper rotor motors that satisfy the NEMA-specified
performance requirements that meet or exceed the NEMA Premium levels.
These motors have been sold to North American users. (BBF, No. 51 at
pp. 2, 3) DOE was able to purchase and tear down a 5-hp copper rotor
motor from an Asian manufacturer that performed at DOE's max-tech
efficiency level, as well as the performance requirements for NEMA
Design B.
SEW Eurodrive stated that it offers only three models of cast-
copper rotor motors and cited the expenses and difficulty of casting
copper rotors as the reason why it does not offer more die-cast copper
rotor motor models. (SEWE, Public Meeting Transcript, No. 60 at p. 121)
The company did not elaborate why it manufactures die-cast copper rotor
motors in the configurations it offers for sale.
Based on these comments, DOE does not believe it has grounds to
screen out copper die-cast rotors on the basis of practicability to
manufacture, install, and service. The available facts indicate that
manufacturers are already producing smaller motors with die-cast copper
rotors, leaving the question of whether larger motors are being
manufactured with die-cast copper rotors. DOE recognizes that as
technology scales upward in size, it can require different equipment
and processes. Nonetheless, Tesla's \44\ and Remy's \45\ 300+
horsepower motors with copper rotors cast doubt on the assertion that
copper is impracticable in this size range.
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\44\ https://www.teslamotors.com/roadster/technology/motor.
\45\ https://www.remyinc.com/docs/hybrid/REM-12_HVH410_DataSht.pdf.
---------------------------------------------------------------------------
DOE understands that full-scale deployment of copper would likely
require considerable capital investment (see detailed discussion in
SectionIV.J.2.a) and that such investment could increase the production
cost of large copper rotor motors considerably. DOE believes that its
current engineering analysis reflects this likelihood, and welcomes
comment on this issue.
Adverse Impacts on Equipment Utility or Equipment Availability
NEMA commented that DOE failed to address the adverse impacts on
equipment utility or availability caused by die-cast copper rotors. It
asserted that the process for manufacturing die-cast copper rotors is
underdeveloped, and energy conservation standards based on this
technology, and implemented in 2015, would result in product
unavailability of over 99 percent of the electric motors that would be
impacted if DOE were to set a standard that would require the use of
die-cast copper. NEMA reiterated that there is no justification as to
how motors that are not available today, made from a technology that is
not practiced in the U.S. today, will become available within three
years, especially when taking into account the time needed for
prototyping, testing, and AEDM certification. (NEMA, No. 54 at pp. 3,
47, 48, 54, 55, 56; NEMA, Public Meeting Transcript, No. 60 at pp. 114,
115)
NEMA also commented that it is difficult for die-cast copper rotor
motors to stay under the maximum locked-rotor current limit for NEMA
Design B motors. If this technology were adopted, in its view, many
current NEMA Design B motors would become NEMA Design A motors. This
would reduce the utility of a motor, because a NEMA Design A motor is
not a direct drop-in place replacement for a NEMA Design B motor.
(NEMA, No. 54 at p. 3)
DOE agrees that, in some cases, redesigning product lines to use
copper would entail substantial cost. DOE's engineering analysis
reflects its estimates of these costs and discusses them in detail in
section IV.C. DOE was able to model copper rotor motors adhering to the
specifications of NEMA Design B \46\, including the reduced (relative
to Design A) locked-rotor current.
---------------------------------------------------------------------------
\46\ The parameters DOE believed to present the largest risk of
rendering a motor noncompliant with NEMA MG 1-2011 standards were
those related to NEMA design letter, which were adhered to in DOE's
modeling efforts.
---------------------------------------------------------------------------
Finally, based on DOE's own shipments analysis (see TSD Chapter 9)
and estimates of worldwide annual copper production,\47\ DOE estimates
that .01-.02% of worldwide copper supply would be required to use
copper rotors for every single motor within DOE's scope of coverage. At
the present, DOE does not believe there is sufficient evidence to
screen copper die-cast rotors from the analysis on the basis of adverse
impacts to equipment utility or availability.
---------------------------------------------------------------------------
\47\ https://minerals.usgs.gov/minerals/pubs/commodity/copper/mcs-2012-coppe.pdf.
---------------------------------------------------------------------------
Adverse Impacts on Health or Safety
NEMA commented that the preliminary TSD does not sufficiently
explain how DOE concluded that mandating performance levels that would
require copper rotor die-casting would not have an adverse impact on
health or safety, with the implication being on occupational health and
safety. NEMA commented that the preliminary TSD mentioned potential
impacts on the health or safety caused by the higher melting point of
copper, but DOE did not elaborate on what these potential impacts were.
NEMA disagreed with DOE's conclusion not to screen out die-cast copper
rotor technology on the premise that handling molten copper is similar
to handling molten aluminum. NEMA noted that copper has a pouring
temperature of 2100 degrees Fahrenheit and a 150 percent higher casting
pressure than aluminum, and that, combined, these two characteristics
would increase the severity of any potential accidents. NEMA mentions
an incident involving the two U.S. Army die-cast copper rotor studies
previously mentioned, which resulted in injuries during the die-casting
of aluminum \48\ [sic] cage rotors and caused the only U.S.
manufacturer of copper die-casting equipment to withdraw that equipment
from the market. NEMA added that the equipment currently remains
unavailable for purchase. (NEMA, No. 54 at pp. 10, 55, 56; NEMA, Public
[[Page 73620]]
Meeting Transcript, No. 60 at p. 115) NEMA added that, especially
regarding die-casting copper on larger motor sizes, DOE cannot
justifiably claim that there are no adverse impacts on health or safety
until they conduct a thorough investigation or feasibility study
regarding this topic. (NEMA, No. 54 at p. 3)
---------------------------------------------------------------------------
\48\ From the context of NEMA's comment, DOE believes the use of
the word ``aluminum'' was a typographical error and that NEMA had
intended this passage to use the word ``copper'' instead.
---------------------------------------------------------------------------
However, BBF also commented that copper die-cast rotors can be
safely manufactured, as one major manufacturer indicated that they have
had no worker injuries in volume production over multiple years. (BBF,
No. 51 at p. 3)
BBF commented that, with the extensive capabilities of copper die-
cast rotors and commercial availability of copper die-cast rotors with
efficiencies higher than NEMA MG 1-2011 Table 12-12 efficiencies, DOE
should include in its evaluations copper die-cast rotor motors. BBF
also added that they strongly disagree with the NEMA representatives'
contrary verbal suggestions towards copper rotor motor technology
presented during the public meeting. (BBF, No. 51 at p. 4)
DOE is aware of the higher melting point of copper (1084 degrees
Celsius versus 660 degrees Celsius for aluminum) and the potential
impacts this may have on the health or safety of plant workers.
However, DOE does not believe at this time that this potential impact
is sufficiently adverse to screen out copper as a die cast material for
rotor conductors. The process for die casting copper rotors involves
risks similar to those of die casting aluminum. DOE believes that
manufacturers who die-cast metal at 660 Celsius or 1085 Celsius (the
respective temperatures required for aluminum and copper) would need to
observe strict protocols to operate safely. DOE understands that many
plants already work with molten aluminum die casting processes and
believes that similar processes could be adopted for copper. DOE has
not received any supporting data about the increased risks associated
with copper die casting, and could not locate any studies suggesting
that the die-casting of copper inherently represented incrementally
more risks to worker safety and health. DOE notes that several OSHA
standards relate to the safety of ``Nonferrous Die-Castings, Except
Aluminum,'' of which die-cast copper is part. DOE seeks comment on any
adverse safety or health impacts and on these OSHA standards,\49\ and
on any other specific information document the safety of die-casting
for both copper and aluminum.
---------------------------------------------------------------------------
\49\ For a list, see: https://www.osha.gov/pls/imis/citedstandard.sic?p_esize=&p_state=FEFederal&p_sic=3364.
---------------------------------------------------------------------------
b. Increase the Cross-Sectional Area of Copper in the Stator Slots
Increasing the slot fill by either adding windings or changing the
gauge of wire used in the stator winding can also increase motor
efficiency. Motor design engineers can achieve this by manipulating the
wire gauges to allow for a greater total cross-sectional area of wire
to be incorporated into the stator slots. This could mean either an
increase or decrease in wire gauge, depending on the dimensions of the
stator slots and insulation thicknesses. As with the benefits
associated with larger cross-sectional area of rotor conductor bars,
using more total cross-sectional area in the stator windings decreases
the winding resistance and associated losses. However, this change
could affect the slot fill factor of the stator. The stator slot
openings must be able to fit the wires so that automated machinery or
manual labor can pull (or push) the wire into the stator slots. In the
preliminary analysis, DOE increased the cross-sectional area of copper
in the stator slots of the representative units by employing a
combination of additional windings, thinner gauges of copper wire, and
larger slots.
In response to the preliminary analysis, NEMA commented that a
majority of stator windings are manufactured on automated equipment.
NEMA and Baldor noted that there is a practical limit of 82 percent
slot fill for automated winding equipment for motors with four or more
poles; motors with two poles have a limit of 78 percent. (NEMA, No. 54
at p. 58; Baldor, Public Meeting Transcript, No. 60 at p. 146) NEMA
commented that the values for maximum slot fill for the automated
winding models was approximately 82 percent and those based on hand
winding were 85 percent. NEMA noted that this is not a practical change
based on a change in conductor size alone because conductors are sized
in a larger increment than this difference would suggest. Therefore, it
would appear that the size of the stator slot in each case was selected
to purposely result in the corresponding level of slot fill. (NEMA, No.
54 at p. 59) In other words, instead of only adjusting the conductor
gauge to the slot size, the slot size could be adjusted to the
conductor gauge.\50\ (NEMA, No. 54 at p. 59) Baldor added that slot
fills above 85 percent would be very difficult to do in current
production volumes (5 million motors annually) and noted that this slot
fill percentage was based on a DOE-presented software model and has not
been proven in a prototype. (Baldor, Public Meeting Transcript, No. 60
at pp. 146, 147) NEMA requested that DOE clarify the method it used for
calculating slot fill to avoid confusion among other interested parties
who may have used a different calculation method. (NEMA, No. 54 at p.
58)
---------------------------------------------------------------------------
\50\ In practice, of course, a manufacturer may opt to do either
or both.
---------------------------------------------------------------------------
DOE calculated the slot fill by measuring the total area of the
stator slot and then subtracting the cross sectional area for the slot
insulation. This method gave DOE a net area of the slot available to
house copper winding. DOE then identified the slot with the most
windings and found the cross sectional area of the insulated copper
wires to get the total copper cross sectional area per slot. DOE then
divided the total copper cross sectional area by the total slot area to
derive the slot fill. DOE's estimated slot fills for its teardowns and
software models are all provided in chapter 5 of the TSD.
NEMA commented that several of DOE's designs presented maximum
values of slot fill at 85 percent, whereas the closest automated
winding slot fill was 82-percent. NEMA questioned the significant
benefit DOE projected in designing the stator slot such that a hand
winding would be required to gain a 3-percent change in slot fill. In
NEMA's view, the change in core loss that might result from increasing
the stator slot area by 3 percent would not be significant enough to
warrant hand-winding the stator. (NEMA, No. 54 at p. 59) DOE notes that
the software designs exhibiting these changes in slot fill were used
when switching from aluminum to a copper rotor design. Therefore,
changing slot geometries impacted the design's slot fill and the slot
fill changes resulted from different motor designs. Consequently, a 3
percent increase in slot fill does not imply that this change was made
to increase the efficiency of another design, but could have been made
to change other performance criteria of the motor, such as locked-rotor
current.
In the preliminary analysis, DOE indicated that motor design
engineers can adjust slot fill by changing the gauge of wire used in
fractions of half a gauge. NEMA commented that it did not understand
DOE's statement, and indicated that manufacturers limit the number of
gauges used at any particular manufacturing plant, and few of those
gauges are ``fractions of a half a gauge.'' NEMA added that
manufacturers may use multiple wire gauges in a particular winding, but
DOE's examples in chapter 5 gave no indication that any sizes other
[[Page 73621]]
than a single conductor size was used in each winding. (NEMA, No. 54 at
pp. 58, 59) DOE clarifies that all the modeled motors utilized standard
AWG wire sizes, either whole- or half-gauge sizes (i.e., 18 or 18\1/
2\). DOE clarifies that the statement of ``fractions of a half gauge''
referred to sizes in between a whole gauge (i.e. 18\1/2\ of a gauge is
a fraction of 18 gauge wire). DOE did not end up using fractions
consisting of a half gauge of wire sizes to conduct its modeling, but
did indicate that this was a design option used by the motor industry.
NEMA also commented that it is not uncommon for a manufacturer to
use the same stator lamination design for all horsepower ratings built
in the same NEMA MG 1-2011 Standard frame series. NEMA indicated that a
high slot fill may require hand winding for one of the ratings and
automated winding for the other rating, and that a good design practice
for stator laminations will take into consideration more than just one
motor rating to determine the best design for all ratings in that frame
series. (NEMA, No. 54 at p. 59)
NEMA and Baldor questioned DOE's decision not to screen out hand-
wound stators, and both parties commented that moving to hand-wound
technology would be a reversal of the trend to automate manufacturing
practices whenever possible. (NEMA, No. 54 at p. 59; Baldor, Public
Meeting Transcript, No. 60 at pp. 122, 123) NEMA noted that none of the
teardown motors in DOE's analysis appeared to use hand winding
technology. (NEMA, No. 54 at p. 59)
While NEMA agrees that hand winding cannot be ruled out on the
grounds of technological feasibility, it does believe that hand winding
would not be practicable to use in mass production. A NEMA member
survey indicated that hand winding can take up to 25 times longer than
machine winding. NEMA added that the manpower required to replace
automated winding would require an increase in manpower in excess of 20
times the number of automated machines. (NEMA, No. 54 at p. 60) NEMA
and Baldor commented that moving to an energy conservation level based
on hand-wound technology would not be achievable on the scale necessary
to serve the relevant market at the time of the effective date of the
standard. (NEMA, No. 54 at p. 60; Baldor, Public Meeting Transcript,
No. 60 at p. 123) NEMA added that it would not be aware if such an
expansion of the infrastructure would be required until after any
amended or new standards are announced. (NEMA, No. 54 at p. 60) DOE is
aware of the extra time involved with hand winding and has attempted to
incorporate this time into efficiency levels (ELs) that it believes
would require hand winding. DOE reiterates that should the increase in
infrastructure, manpower, or motor cost increase beyond a reasonable
means, then ELs utilizing this technology will be screened out during
the downstream analysis.
NEMA also expressed concern that standards based on hand winding
would shift U.S. manufacturing jobs to locations outside of the U.S.
which have lower labor rates, and Nidec added that most U.S.
manufacturers are currently globally positioned to move labor-intensive
work into low-cost labor countries if energy conservation requirements
force them to do so. (Nidec, Public Meeting Transcript, No. 60 at p.
124) DOE intends to fully capture this impact during the manufacturer
impact analysis (MIA) portion of DOE's analysis. Please see section
IV.J for a discussion of the manufacturer impact analysis.
NEMA also commented that hand-wound technology would have an
adverse impact on product utility or product availability, saying that
the infrastructure would not be in place in sufficient time to support
the hand winding of all of the stators, and there will be an adverse
impact on the availability of various ratings of electric motors at the
time of effective standards. (NEMA, No. 54 at p. 60)
NEMA commented that hand winding would have adverse impacts on
worker health or safety, as both hand winding and hand insertion of
stator coils require operations performed by hand with repetitive
motions, and such hand winding of stators also involves the moving and
lifting of various stator and winding components, which may be of
substantial size in larger horsepower rated electric motors. NEMA added
that any increase in personnel performing the repetitive tasks required
by hand winding can have an adverse effect on the overall health and
safety record of any facility. (NEMA, No. 54 at p. 60; NEMA, Public
Meeting Transcript, No. 60 at p. 123)
DOE disagrees with NEMA's assertion concerning the adverse impacts
on health or safety, and notes that hand winding is currently practiced
by industry. Furthermore, DOE is not aware of any data or studies
suggesting hand-winding leads to negative health consequences. DOE
acknowledges that, were hand-winding to become widespread,
manufacturers would need to hire more workers to perform hand-winding
to maintain person-winding-hour equivalence, and has accounted for the
added costs of hand-winding in its engineering analysis. DOE requests
comment on its cost estimates for hand-wound motors, as well as on the
matter of hand-winding in general and on studies suggesting negative
health impacts in particular.
NEMA summarized its concerns, saying that hand winding is not a
viable technology option, especially for a slot fill increase of less
than 5 percent. NEMA believes that the engineering analysis should not
be based on stator slot fill levels which require hand winding, which
are generally slot fills above 78 percent for 2-pole motor and 82
percent for 4-, 6-, and 8-pole motors. (NEMA, No. 54 at p. 60)
DOE acknowledges that the industry is moving towards increased
automation. However, hand winding is currently practiced by
manufacturers, making it a viable option for DOE to consider as part of
its engineering analysis. Considering the four screening criteria for
this technology option, DOE did not screen out the possibility of
changing gauges of copper wire in the stator as a means of improving
efficiency. Motor design engineers adjust this option by using
different wire gauges when manufacturing an electric motor to achieve
desired performance and efficiency targets. Because this design
technique is in commercial use today, DOE considers this technology
option both technologically feasible and practicable to manufacture,
install, and service. DOE is not aware of any adverse impacts on
consumer utility, reliability, health, or safety associated with
changing the wire gauges in the stator to obtain increased efficiency.
Should the technology option prove to not be economical on a scale
necessary to supply the entire industry, then this technology option
would be likely not be selected for in the analysis, either in the LCC
or MIA.
DOE seeks comment generally on the process of increasing the cross-
section of copper in the stator, and in particular on the costs and
reliability of the hand winding process.
2. Technology Options Screened Out of the Analysis
DOE developed an initial list of design options from the
technologies identified in the technology assessment. DOE reviewed the
list to determine if the design options are practicable to manufacture,
install, and service; would adversely affect equipment utility or
equipment availability; or would have adverse impacts on health and
safety. In the engineering analysis, DOE did not consider any of those
options that failed
[[Page 73622]]
to satisfy one or more of the screening criterion. The design options
screened out are summarized in Table IV.8.
Table IV.8--Design Options Screened Out of the Analysis
------------------------------------------------------------------------
Eliminating screening
Design option excluded criterion
------------------------------------------------------------------------
Plastic Bonded Iron Powder (PBIP)......... Technological Feasibility.
Amorphous Steels.......................... Technological Feasibility.
------------------------------------------------------------------------
NEMA agreed with DOE in that plastic bonded iron powder has not
been proven to be a technologically feasible method of construction of
stator and rotor cores in induction motors. (NEMA, No. 54 at p. 64)
NEMA also agreed that amorphous metal laminations are not a type of
material that lends itself to use in electric motors in the foreseeable
future. However, NEMA expressed concern that this technology was only
screened out on the basis of technological feasibility because it had
not been used in a prototype. (NEMA, No. 54 at p. 63)
Baldor and NPCC also agreed with DOE's decision to exclude PBIP and
amorphous steels from the engineering analysis. (Baldor, Public Meeting
Transcript, No. 60 at p. 108; Advocates, No. 56 at p. 3)
DOE is continuing to screen out both of these technology options
from further consideration in the engineering analysis. Additionally,
DOE understands the concerns expressed by NEMA regarding technological
feasibility, but DOE maintains that if a working prototype exists,
which implies that the motor has performance characteristics consistent
with other motors using a different technology, then that technology
would be deemed technologically feasible. However, that fact would not
necessarily mean that a technology option would pass all three of the
remaining screening criteria.
Chapter 4 of this preliminary TSD discusses each of these screened
out design options in more detail, as well as the design options that
DOE considered in the electric motor engineering analysis.
C. Engineering Analysis
The engineering analysis develops cost-efficiency relationships for
the equipment that are the subject of a rulemaking by estimating
manufacturer costs of achieving increased efficiency levels. DOE uses
manufacturing costs to determine retail prices for use in the LCC
analysis and MIA. In general, the engineering analysis estimates the
efficiency improvement potential of individual design options or
combinations of design options that pass the four criteria in the
screening analysis. The engineering analysis also determines the
maximum technologically feasible energy efficiency level.
When DOE proposes to adopt a new or amended standard for a type or
class of covered product, it must determine the maximum improvement in
energy efficiency or maximum reduction in energy use that is
technologically feasible for such product. (42 U.S.C. 6295(p)(1))
Accordingly, in the engineering analysis, DOE determined the maximum
technologically feasible (``max-tech'') improvements in energy
efficiency for electric motors, using the design parameters for the
most efficient products available on the market or in working
prototypes. (See chapter 5 of the NOPR TSD.) The max-tech levels that
DOE determined for this rulemaking are described in IV.C.3 of this
proposed rule.
In general, DOE can use three methodologies to generate the
manufacturing costs needed for the engineering analysis. These methods
are:
(1) The design-option approach--reporting the incremental costs of
adding design options to a baseline model;
(2) the efficiency-level approach--reporting relative costs of
achieving improvements in energy efficiency; and
(3) the reverse engineering or cost assessment approach--involving
a ``bottoms up'' manufacturing cost assessment based on a detailed bill
of materials derived from electric motor teardowns.
1. Engineering Analysis Methodology
DOE's analysis for the electric motor rulemaking is based on a
combination of the efficiency-level approach and the reverse
engineering approach. Primarily, DOE elected to derive its production
costs by tearing down electric motors and recording detailed
information regarding individual components and designs. DOE used the
costs derived from the engineering teardowns and the corresponding
nameplate nominal efficiency of the torn down motors to report the
relative costs of achieving improvements in energy efficiency. DOE
derived material prices from current, publicly available data as well
as input from subject matter experts and manufacturers. For most
representative units analyzed, DOE was not able to test and teardown a
max-tech unit because such units are generally cost-prohibitive and are
not readily available. Therefore, DOE supplemented the results of its
test and teardown analysis with software modeling.
When developing its engineering analysis for electric motors, DOE
divided covered equipment into equipment class groups. As discussed,
there are four electric motor equipment class groups: NEMA Design A and
B motors (ECG 1), NEMA Design C motors (ECG 2), fire pump electric
motors (ECG 3), and brake motors (ECG 4). The motors within these ECGs
are further divided into equipment classes based on pole-configuration,
enclosure type, and horsepower rating. For DOE's rulemaking, there are
580 equipment classes.
2. Representative Units
Due to the high number of equipment classes for electric motors,
DOE selected and analyzed only a few representative units from each ECG
and based its overall analysis for all equipment classes within that
ECG on those representative units. During the NOPR analysis, DOE
selected three units to represent ECG 1 and two units to represent ECG
2. DOE based the analysis of ECG 3 on the representative units for ECG
1 because of the low shipment volume and run time of fire pump electric
motors. DOE also based the analysis of ECG 4 on the analysis of ECG 1
because the vast majority of brake motors are NEMA Design B motors.
When selecting representative units for each ECG, DOE considered NEMA
design type, horsepower rating, pole-configuration, and enclosure.
a. Electric Motor Design Type
For ECG 1, which includes all NEMA Design A and B motors that are
not fire pump or brake motors, DOE only selected NEMA Design B motors
as representative units to analyze in the preliminary analysis
engineering analysis. DOE chose NEMA Design B motors because NEMA
Design B motors have slightly more stringent performance requirements,
namely their locked-rotor current has a maximum allowable level for a
given rating. Consequently, NEMA Design B motors are slightly more
restricted in terms of their maximum efficiency levels. Therefore, by
analyzing a NEMA Design B motor, DOE could ensure technological
feasibility for all designs covered in ECG 1. Additionally, NEMA Design
B units have much higher shipment volumes than NEMA Design A motors
because most motor driven equipment is designed (and UL listed) to run
with NEMA Design B motors.
NEMA agreed with DOE's decision to base any amended or new
standards for ECG 1 motors on NEMA Design B motor
[[Page 73623]]
types because consumers generally prefer NEMA Design B motors due to
the fact that locked-rotor current is constrained to established
industry standards in these motors, making it easier to select suitable
motor-starting devices. NEMA pointed out that, on the other hand, the
use of a NEMA Design A motor may require the purchaser of the motor to
expend a significant amount of time and expense in selecting suitable
motor-starting devices to operate the motor in an appropriate and safe
manner. NEMA elaborated that it is important to base the analysis on
NEMA Design B motors in order to minimize any disruption to consumers
based on their preference for NEMA Design B. (NEMA, No. 54 at p. 64)
DOE appreciates NEMA's feedback. For its NOPR engineering analysis, DOE
has continued to select NEMA Design B motors as its representative
units in ECG 1.
As mentioned for ECG 2, DOE selected two representative units to
analyze. Because NEMA Design C is the only NEMA design type covered by
this ECG, DOE only selected NEMA Design C motors as its representative
units.
For ECG 3, which consists of fire pump electric motors, DOE based
its engineering analysis on the NEMA Design B units analyzed for ECG 1
in the preliminary analysis. As noted, in order to be in compliance
with section 9.5 of National Fire Protection Association (NFPA)
``Standard for the Installation of Stationary Pumps for Fire
Protection'' Standard 20-2010, which is a requirement for a motor to
meet DOE's current definition of a fire pump electric motor, the motor
must comply with NEMA Design B (or IEC Design N) requirements.\51\
Although DOE understands that fire pump electric motors have additional
performance requirements, DOE believed that analysis of the ECG 1
motors would serve as a sufficient approximation for the cost-
efficiency relationship for fire pump electric motors. The design
differences between a NEMA Design B motor (or IEC-equivalent) and fire
pump electric motor are small and unlikely to greatly affect
incremental cost behavior.
---------------------------------------------------------------------------
\51\ With the exception of having a thermal shutoff switch,
which could prevent a fire pump motor from performing its duty in
hot conditions, NFPA 20 also excludes several motor types not
considered in this rulemaking from the NEMA Design B requirement.
They are direct current, high-voltage (over 600 V), large-horsepower
(over 500 hp), single-phase, universal-type, and wound-rotor motors.
---------------------------------------------------------------------------
NEMA disagreed with DOE's assertion that fire pump electric motors
are required to meet NEMA Design B standards, and commented that, as
defined in 10 CFR 431.12, fire pump electric motors are not limited to
NEMA Design B performance standards. NEMA requested that DOE clarify
DOE's statement in the preliminary analysis that currently, efficiency
standards have only been established for fire pump electric motors that
are NEMA Design B. (NEMA, No. 54 at p. 25) NEMA also commented that the
additional performance requirements for fire pump electric motors
(e.g., the ability to withstand stall conditions for longer periods of
time) mean they are usually designed with lower locked-rotor current
limits. Therefore, NEMA stated that fire pump electric motors may have
a maximum efficiency potential slightly lower than typical, general
purpose NEMA Design B motors. (NEMA, No. 54 at pp. 24-25, 40, 64, 70;
NEMA, Public Meeting Transcript, No. 60 at pp. 135, 136) NEMA added
that they support DOE's decision to analyze fire pump motors in a
separate equipment class group because of the short run time of fire
pump electric motors. (NEMA, No. 54 at p. 71)
Regarding DOE's fire pump electric motor definition, as detailed in
the final electric motors test procedure, DOE intends its fire pump
electric motor definition to cover both NEMA Design B motors and IEC-
equivalents that meet the requirements of section 9.5 of NFPA 20. See
77 FR 26617-18. As stated in the final electric motors test procedure,
DOE agrees with stakeholders that IEC-equivalent motors should be
included within the scope of the definition of ``fire pump electric
motor,'' although NFPA 20 does not explicitly recognize the use of IEC
motors with fire pumps. 77 FR 26617. DOE realizes that section 9.5 of
NFPA 20 specifically requires that fire pump motors shall be marked as
complying with NEMA Design B. The fire pump electric motor definition
that DOE created focuses on ensuring that compliance with the energy
efficiency requirements are applied in a consistent manner. DOE
believes that there are IEC motors that can be used in fire pump
applications that meet both NEMA Design B and IEC Design N criteria, as
well as NEMA MG1 service factors. DOE's definition encompasses both
NEMA Design B motors and IEC-equivalents. To the extent that there is
any ambiguity as to how DOE would apply this definition, in DOE's view,
any Design B or IEC-equivalent motor that otherwise satisfies the
relevant NFPA requirements would meet the fire pump electric motor
definition in 10 CFR 431.12. To the extent that there is confusion
regarding this view, DOE invites comments on this issue, along with any
data demonstrating whether any IEC-equivalent motors are listed for
fire pump service either under the NFPA 20 or another relevant industry
standard.
Regarding NEMA's other fire pump electric motor comment, DOE agrees
that some fire pump electric motors may not be required to meet the
NEMA Design B performance requirements (or IEC-equivalent comments).
However, those motors that are not required to meet the NEMA Design B
performance requirements are direct-current motors, motors with high
voltages (i.e., greater than 600 V), motors with high horsepower
ratings (i.e., greater than 500 horsepower), single-phase motors,
universal-type motors, or wound-rotor motors. Any motor with such
attributes would not meet the nine motor characteristics that define
the scope of electric motors covered in this rulemaking. Additionally,
any fire pump electric motor that is not rated for continuous duty is
not, and would not be, covered by the scope of today's rulemaking.
Therefore, DOE clarifies that any fire pump electric motor currently
subject to, or potentially subject to, energy conservation standards as
a result of this rulemaking, would have to meet the NEMA Design B (or
IEC-equivalent) performance requirements. As indicated above, DOE seeks
comment on whether its current regulatory definition requires further
clarification.
Additionally, DOE understands NEMA's comments regarding the
potential limitations of fire pump electric motors. However, DOE
believes that its approximation, by using the NEMA Design B electric
motors from ECG 1 is sufficient, at this time. In DOE's preliminary
analysis, DOE found that all efficiency levels analyzed for fire pump
electric motors resulted in negative life-cycle cost savings for
consumers and a negative net present values for the Nation. This was
the result of extremely low operating hours and therefore, limited
energy cost savings potential. DOE notes that there are minimal
shipments and no efficiency levels are likely to be deemed economically
justifiable.
Additionally, DOE understands that fire pump motors are similar in
both performance and architecture to NEMA Design B motors, the chief
difference being the absence of thermal cutoff capability that would
render a fire pump motor unable to perform its function in a hot
environment. For compliance purposes, however, the distinction is less
important. DOE welcomes comment on the similarity
[[Page 73624]]
between fire pump and NEMA Design B motors.
Equipment class group 4, consisting of brake motors, is also based
on ECG 1 because DOE is only aware of brake motors being built to NEMA
Design B specifications. Furthermore, DOE understands that there is no
fundamental difference in design between brake and non-brake electric
motors, other than the presence of the brake. Therefore, the same
design options could be used on both sets of electric motors and both
motor types are likely to exhibit similar cost versus efficiency
relationships.
For the final rule, DOE may consider combining ECGs 1 and 4 again,
as was done for the preliminary analysis, but such a decision depends,
in part, on the outcome of its concurrent electric motors test
procedure rulemaking. Currently, DOE believes that its proposed
approach to testing brake motors will mitigate the impact of the brake
component's contributions to motor losses such that the demonstrated
efficiency would be the same as if the motor had been tested with the
brake completely removed (essentially making it no different from the
motors covered by ECG 1). (See 78 FR 38467) With this approach, a
separate ECG would not be necessary.
b. Horsepower Rating
Horsepower rating is an important equipment class setting
criterion. When DOE selected its preliminary analysis representative
units, DOE chose those horsepower ratings that constitute a high volume
of shipments in the market and provide a wide range upon which DOE
could reasonably base a scaling methodology. For NEMA Design B motors,
for example, DOE chose 5-, 30-, and 75-horsepower-rated electric motors
to analyze as representative units. DOE selected the 5-horsepower
rating because these motors have the highest shipment volume of all
motors. DOE selected the 30-horsepower rating as an intermediary
between the small and large frame number series electric motors.
Finally, DOE selected a 75-horsepower unit because there is minimal
variation in efficiency for motors with horsepower ratings above 75-
horsepower. Based on this fact, DOE determined it was unnecessary to
analyze a higher horsepower motor. Additionally, as horsepower levels
increase, shipments typically decrease. Therefore, DOE believed there
would be minimal gains to its analysis had it examined a higher
horsepower representative unit.
During the public meeting, Baldor commented that the representative
units should have been selected based on energy consumption and not
shipment numbers. Baldor indicated that using this approach, the 10-
horspower motor would have been designated as a representative unit
rather than the 5-horsepower motors. (Baldor, Public Meeting
Transcript, No. 58 at p. 132, 133) NEMA reiterated Baldor's stance in
its submitted comments, saying that the 5-horsepower motor would not
appear to be the only choice for the representative unit. (NEMA, No. 54
at p. 65) NEMA and Baldor also commented that there are motors built in
frame series larger than the standard 75-horsepower frame series and
DOE should select a motor built in the largest NEMA MG 1 frame series
as a representative unit. (NEMA, No. 54 at p. 65; Baldor, Public
Meeting Transcript, No. 60 at p. 133) NEMA added that efficiency
ratings start to level off once horsepower ratings exceed 150-
horsepower, not above 75-horsepower. Therefore, they argued that
selecting a horsepower rating above 150-horsepower would have been a
better indicator if the perceived increase in efficiency calculated for
lower horsepower ratings would be achievable by larger horsepower
ranges. (NEMA, No. 54 at pp. 27, 65) Baldor reiterated this comment in
the preliminary analysis public meeting. (Baldor, Public Meeting
Transcript, No. 60 at pp. 133-134)
While DOE agrees with NEMA that the 5-horsepower electric motor was
not the only choice for the representative unit, it selected the 5-
horsepower motor for multiple reasons. The 5-horsepower unit had the
highest percentage of shipments for all covered electric motors, which
ensured that there would be multiple efficiency levels from multiple
manufacturers available for comparison during the teardown analysis. In
addition, because DOE later employed scaling, it attempted to find a
frame series and D-dimension \52\ that could serve as a strong basis
from which to scale to a relatively small set of unanalyzed frame
series. The standard NEMA MG 1-2011 frame series for the 5-horsepower
enclosed motor was a midpoint between the standard frame series for 1
horsepower and 10-horsepower motors, which was the group of ratings
covered by the 5- horsepower representative unit. A larger
representative unit would have meant a larger range of frame series on
which to apply the scaling methodology.
---------------------------------------------------------------------------
\52\ ``D'' dimension is the length from the centerline of the
shaft to the mounting feet of the motor, and impacts how large the
motor's laminations can be, impacting the achievable efficiency of
the motor. ``D'' dimensions are designated in NEMA MG 1-2011 Section
4.2.1, Table 4-2.
---------------------------------------------------------------------------
As to DOE's selection of the 75-horsepower representative unit as a
maximum, DOE understands that the 75-horsepower motor is not built in
the largest NEMA MG 1-2011 frame series covered, but maintains that its
selection is appropriate for this analysis. As stated previously,
efficiency changes slowly when approaching the highest horsepower
ratings, and choosing a higher horsepower rating would not have
provided any appreciable improvement over the data DOE already
developed for its analysis. DOE has found minimal variation in
efficiency for motors above 75-horsepower. Because the change in
efficiency diminishes with increasing horsepower, one may achieve a
similar level of analytical accuracy with fewer data points at higher
horsepower. Stated inversely, one needs more data points to accurately
characterize a curve where it has a greater rate of change, such as
lower horsepower. Finally, DOE notes that its scaling methodology
mirrors the scaling methodology used in NEMA's MG 1-2011 tables of
efficiencies, including the rate of change in efficiency with
horsepower.
DOE also notes that section 13 of NEMA MG 1-2011 does not
standardize frame series for NEMA Design B motors at the highest
horsepower levels covered in today's proposal. Therefore, motors with
the highest capacity have variability in their frame series. This added
flexibility would give manufacturers more options to improve the
efficiency of their largest motors covered by this rulemaking. Although
altering the frame size of a motor may be costly, DOE believes that its
selection of a 75-hp representative unit for higher horsepower motors
is appropriate for scaling higher horsepower efficiency levels and the
efficiency levels examined are technologically feasible for the largest
capacity motors.
For NEMA Design C electric motors, DOE again selected the 5-
horsepower rating because of its prevalence. In addition, DOE selected
a 50-horsepower rating as an incrementally higher representative unit.
DOE only selected two horsepower ratings for these electric motors
because of their low shipment volumes. For more information on how DOE
selected these horsepower ratings see chapter 5 of the TSD.
In submitted comments, NEMA expressed confusion over DOE's
selection of the 50-horsepower representative unit for the NEMA Design
C equipment class group. NEMA stated that the NEMA T-frame size for
such a rating is 326T, which is three
[[Page 73625]]
NEMA T-frame number series below the largest frame number series of
440. NEMA requested that DOE clarify why it limited its NEMA Design C
representative unit to such a low value in its engineering analysis.
(NEMA, No. 54 at p. 66) Finally, NEMA commented that the 2011 shipment
data that DOE used to select its representative units was not broken
down by NEMA design type. NEMA believed that using such data to select
representative units for ECGs 1 and 2 was not appropriate and requested
clarification. (NEMA, No. 54 at p. 66)
As with ECG 1, DOE selected representative units that fell in the
middle of the range of ratings covered in this rulemaking and not
necessarily the largest frame size covered in the rulemaking.
Furthermore, as discussed earlier, NEMA Design C motors are produced in
a smaller range of horsepower ratings than NEMA Design B motors (1 to
200 rather than 1 to 500). With this smaller horsepower range, a
correspondingly smaller range of representative units is needed.
Therefore, DOE selected a slightly lower rating as its maximum for ECG
2. As for the shipments data used to select the 5-hp representative
unit, DOE acknowledges that it did not separate the data by design
type, and has revised the text for the NOPR's TSD to add clarity.
However, DOE still maintains that the prevalence of 5-hp units make it
an appropriate selection as a representative unit.
c. Pole-Configuration
Pole-configuration is another important equipment class setting
criterion that DOE had to consider when selecting its representative
units. For the preliminary analysis, DOE selected 4-pole motors for all
of its representative units. DOE chose 4-pole motors because they
represent the highest shipment volume of motors compared to other pole
configurations. DOE chose not to alternate between pole configurations
for its representative units because it wanted to keep as many design
characteristics constant as possible. By doing so, it would allow DOE
to more accurately identify how design changes affect efficiency across
horsepower ratings. Additionally, DOE believed that the horsepower
rating-versus-efficiency relationship is the most important (rather
than pole-configuration and enclosure type-versus-efficiency) because
there are significantly more horsepower ratings to consider.
NEMA noted that efficiency gains based on a 4-pole configuration do
not confirm that those same gains are achievable in other pole
configurations, and there is no foundation for scaling across different
pole configurations. NEMA added that it is necessary to know how
designs change with respect to pole-configuration, and analyzing
samples of one pole configuration limits the ability to make decisions
based on other pole-configurations. NEMA commented that designs
significantly vary across pole-configurations, especially regarding
torque characteristics. (NEMA, No. 54 at pp. 26, 66-67) NEMA also
stated that the purpose of the engineering analysis is not necessarily
to determine the ``reasons for efficiency improvements,'' but to
determine if efficiency can be improved in accordance with meeting the
requirements of being technologically feasible and economically
justified per 42 U.S.C. 6295(o)(A) and (B). (NEMA, No. 54 at p. 26)
Baldor also commented on scaling across pole configurations, saying
that the rotor diameter grows as the pole number increases, which may
cause higher losses in 2-pole motors compared to other pole
configurations covered in this rulemaking. (Baldor, Public Meeting
Transcript, No. 60 at pp. 130, 131)
As mentioned earlier, DOE is assessing energy conservation
standards for 580 equipment classes. Analyzing each of the classes
individually is not feasible, which requires DOE to select
representative units on which to base its analysis. DOE understands
that different pole-configurations have different design constraints.
Originally, DOE selected only 4-pole motors to analyze because they
were the most common, allowing DOE to most accurately characterize
motor behavior at the pole configuration consuming the majority of
motor energy. Additionally, by holding pole-configuration constant
across its representative units, DOE would be able to develop a
baseline from which to scale. By maintaining this baseline and holding
all other variables constant, DOE is able to modify the horsepower of
the various representative units and isolate which efficiency effects
are due to size.
As discussed in section IV.C.8, DOE has used the simpler of two
scaling approaches presented in the preliminary analysis because both
methods had similar results. This simpler approach does not require DOE
to develop a relationship for 4-pole motors from which to scale.
Furthermore, DOE notes that the scaling approach it selected mirrors
the scaling laid out in NEMA's MG 1-2011 tables, in which at least a
subset of the motors industry has already presented a possible
relationship between efficiency and pole count. DOE has continued to
analyze 4-pole electric motors because they are the most common and DOE
believes that all of the efficiency levels it has developed are
technologically feasible.
d. Enclosure Type
The final equipment class setting criterion that DOE considered
when selecting its representative units was enclosure type. For the
preliminary analysis, DOE elected to analyze electric motors with
enclosed designs rather than open designs for all of its representative
units. DOE selected enclosed motors because, as with pole-
configurations, these motors have higher shipments than open motors.
Again, DOE did not alternate between the two design possibilities for
its representative units because it sought to keep design
characteristics as constant as possible in an attempt to more
accurately identify the reasons for efficiency improvements.
NEMA commented that DOE's analysis did not consider the
significance of enclosure type as it relates to efficiency, and that
the NEMA MG 1 frame designations for open frame motors are often in a
smaller frame series than an enclosed-frame motor of the same
horsepower rating. NEMA and Baldor commented that there is generally a
lower efficiency level designated for open-frame motors, and that there
is no direct scaling relationship between the efficiency standards for
open motors relative to enclosed frame motors in the scope of this
rulemaking. (NEMA, No. 54 at p. 68; Baldor, Public Meeting Transcript,
No. 60 at p. 131) Baldor recommended that DOE analyze motors of
different enclosures in order to understand the difference between
achievable efficiency levels in open and enclosed electric motors.
(Baldor, Public Meeting Transcript, No. 60 at pp. 131-132) NEMA
commented that the engineering analysis should be supported by the
testing and analysis of both open and enclosed frame motors. (NEMA, No.
54 at p. 68) Finally, NEMA commented that by not selecting
representative units with different enclosure types, DOE fails to meet
the statutory requirement that any prescribed amended or new efficiency
standards are in fact technically feasible, practical to manufacture,
and have no adverse impacts on product utility or product availability.
(NEMA, No. 54 at pp. 68-69)
DOE acknowledges the comments from interested parties regarding
enclosure type and its selection of representative units. The final
equipment class setting criterion that DOE had to consider when
selecting its
[[Page 73626]]
representative units was enclosure type. For the preliminary analysis,
DOE analyzed only electric motors with totally enclosed, fan-cooled
(TEFC) designs rather than open designs for all of its representative
units. DOE selected TEFC motors because, as with pole configurations,
DOE wanted as many design characteristics to remain constant as
possible. DOE believed that such an approach would allow it to more
accurately pinpoint the factors that affect efficiency. While DOE only
analyzed one enclosure type, it notes that its scaling follows NEMA's
efficiency tables (Table 12-11 and Table 12-12), which already map how
efficiency changes with enclosure type. Finally, TEFC electric motors
represented more than three times the shipment volume of open motors.
DOE chose ELs that correspond to the tables of standards published in
NEMA's MG 1-2011 and to efficiency bands derived from those tables,
preserving the relationship between NEMA's standards for open and
enclosed motors.
In the preliminary analysis, DOE stated that, given the same frame
size, open motors are more efficient than enclosed motors. NEMA
commented that DOE should not compare open and enclosed motors in the
same frame size because NEMA MG 1 specifies larger frame sizes and a
higher service factor for enclosed motors of a given rating than it
does for open motors. NEMA added that TEFC motors have a fan which adds
to the friction and windage losses, and even with this fan the TEFC
motors can have higher efficiencies than open frame motors of the same
horsepower and pole configuration. (NEMA, No. 54 at p. 41) DOE
appreciates the clarification and has altered its discussion in chapter
3 of the TSD.
3. Efficiency Levels Analyzed
After selecting its representative units for each electric motor
equipment class group, DOE examined the impacts on the cost of
improving the efficiency of each of the representative units to
evaluate the impact and assess the viability of potential energy
conservation standards. As described in the technology assessment and
screening analysis, there are numerous design options available for
improving efficiency and each incremental improvement increases the
electric motor efficiency along a continuum. The engineering analysis
develops cost estimates for several efficiency levels (ELs) \53\ along
that continuum.
---------------------------------------------------------------------------
\53\ For the purposes of the NOPR analysis, the term
``efficiency level'' (EL) is equivalent to that of Candidate
Standard Level (CSL) in the preliminary analysis.
---------------------------------------------------------------------------
ELs are often based on: (1) Efficiencies available in the market;
(2) voluntary specifications or mandatory standards that cause
manufacturers to develop equipment at particular efficiency levels; and
(3) the max-tech level.
Currently, there are two energy conservation standard levels that
apply to various types of electric motors. In ECG 1, some motors
currently must meet efficiency standards that correspond to NEMA MG 1-
2011 Table 12-11 (i.e., EPACT 1992 levels \54\), others must meet
efficiency standards that correspond to NEMA MG 1-2011 Table 12-12
(i.e., NEMA Premium levels), and some are not currently required to
meet any energy conservation standard levels. Because DOE cannot
establish energy conservation standards that are less efficient than
current standards (i.e., the ``anti-backsliding'' provision at 42
U.S.C. 6295(o)(1) as applied via 42 U.S.C. 6316(a)) but ECG 1 includes
both currently regulated and unregulated electric motors, DOE's
analysis assumed the respective EPACT 1992 or NEMA Premium standard as
the baseline for ELs 1 and 2. For ECG 1, DOE established an EL that
corresponded to each of these levels, with EL 0 as the baseline (i.e.,
the lowest efficiency level available for unregulated motors and EPACT
1992 or NEMA Premium, as applicable, for currently regulated motors),
EL 1 as equivalent to EPACT 1992 levels (or NEMA Premium, as
applicable, for currently regulated motors), and EL 2 as equivalent to
NEMA Premium levels. Additionally, DOE analyzed two ELs above EL 2. One
of these levels was the max-tech level, denoted as EL 4 and one was an
incremental level that approximated a best-in-market efficiency level
(EL 3). For all equipment classes within ECG 1, EL 3 was a one ``band''
increase in NEMA nominal efficiency relative to NEMA Premium and EL 4
was a two ``band'' increase.\55\ For ECG 3 and 4, DOE used the same ELs
with one exception for ECG 3. Because fire pump electric motors are
required to meet EPACT 1992 efficiency levels and those are the only
motors in that equipment class group, EPACT 1992 levels were used as
the baseline efficiency level, which means that fire pump electric
motors have one fewer EL than ECGs 1 and 4 for purposes of DOE's
analysis. Following the preliminary analysis, DOE adjusted one max-tech
Design B representative unit level (5 hp) after receiving additional
data. This allowed this unit to be based more on physical models for
the NOPR analysis, thereby reducing exposure to modeling errors. Table
IV.9 and Table IV.10 show the ELs for ECGs 1, 3, and 4.
---------------------------------------------------------------------------
\54\ EPACT 1992 only established efficiency standards for motors
up to and including 200 hp. Eventually, NEMA MG 1-2011 added a
table, 20-A, which functioned as an extension of Table 12-11. So,
although EPACT 1992 is a slight misnomer, DOE is using it to refer
to those ELs that were based on Table 12-11.
\55\ Because motor efficiency varies from unit to unit, even
within a specific model, NEMA has established a list of standardized
efficiency values that manufacturers use when labeling their motors.
Each incremental step, or ``band,'' constitutes a 10 percent change
in motor losses. NEMA MG 1-2011 Table 12-10 contains the list of
NEMA nominal efficiencies.
Table IV.9--Efficiency Levels for Equipment Class Groups 1 and 4
----------------------------------------------------------------------------------------------------------------
EL 0 EL 1 (EPACT EL 2 (NEMA EL 3 (best-in- EL 4 (max-
Representative unit (baseline) 1992) premium) market) * tech)
(percent) (percent) (percent) (percent) (percent)
----------------------------------------------------------------------------------------------------------------
5 hp (ECG 1 and 4).............. 82.5 87.5 89.5 90.2 91.0
30 hp (ECG 1 and 4)............. 89.5 92.4 93.6 94.1 94.5
75 hp (ECG 1 only **)........... 93.0 94.1 95.4 95.8 96.2
----------------------------------------------------------------------------------------------------------------
* Best-in-market represents the best or near best efficiency level at which current manufacturers are producing
electric motors. Although these efficiencies represent the best-in-market values found for the representative
units, but when efficiency was scaled to the remaining equipment classes, the scaled efficiency was sometimes
above and sometimes below the best-in-market value for a particular rating.
** ECG 4 does not have a 75-horsepower representative unit because DOE was unable to find brake motors built
with such a high horsepower rating. The maximum horsepower rating for ECG 4 is 30-horsepower.
[[Page 73627]]
Table IV.10--Efficiency Levels for Equipment Class Group 3
----------------------------------------------------------------------------------------------------------------
EL 0 (EPACT EL 1 (NEMA EL 2 (best-in- EL 3 (max-
Representative unit (percent) 1992) premium) market) * tech)
(percent) (percent) (percent) (percent)
----------------------------------------------------------------------------------------------------------------
5 hp............................................ 87.5 89.5 90.2 91.0
30 hp........................................... 92.4 93.6 94.1 94.5
75 hp........................................... 94.1 95.4 95.8 96.2
----------------------------------------------------------------------------------------------------------------
For ECG 2, DOE took a similar approach in developing its ELs as it
did for ECG 1, but with two primary differences. First, when DOE
examined catalog data, it found that no NEMA Design C electric motors
had efficiencies below EPACT 1992 levels, which is the current standard
for all covered NEMA Design C electric motors. For DOE's representative
units, it also found no catalog listings above the required EPACT 1992
levels. Additionally, when DOE's subject matter expert modeled NEMA
Design C motors, the model would only generate designs at NEMA Premium
levels and one incremental level above that while maintaining proper
performance standards. Therefore, ECG 2 only contains three ELs: EPACT
1992 (EL 0), NEMA Premium (EL 1), and a max-tech level (EL 2).
These ELs differed slightly from the CSLs presented in the
preliminary analysis for ECG2. In the preliminary analysis, a CSL for
the 50 hp unit existed between two industry standard levels in order to
provide greater resolution in selection of a standard (NEMA MG-1 Table
12-11 and Table 12-12). For the NOPR analysis, this level was removed
so that the ELs analyzed would align with Tables 12-11 and 12-12. For
the 5 hp rep unit, DOE also removed one preliminary analysis CSL, which
was intended to represent the ``best in market'' level in the
preliminary analysis. After further market research, DOE found that few
Design C motors are offered above the baseline, and those that were
mainly met the NEMA premium level, without going higher in efficiency.
It determined that for the NOPR analysis, the previously designated
``max in market'' level was not applicable. The ELs analyzed for ECG2
in the NOPR are shown in Table IV.11.
Table IV.11--Efficiency Levels for Equipment Class Group 2
----------------------------------------------------------------------------------------------------------------
EL 1 (EPACT EL 2 (NEMA EL 3 (max-
Representative unit (percent) 1992) premium) tech)
(percent) (percent) (percent)
----------------------------------------------------------------------------------------------------------------
5 hp............................................................ 87.5 89.5 91.0
50 hp........................................................... 92.4 93.6 94.5
----------------------------------------------------------------------------------------------------------------
In response to its preliminary analysis, DOE received multiple
comments regarding CSLs. NEMA and Baldor expressed confusion over the
fact that the CSLs for ECG 2 do not align with the CSLs from ECG 1, and
requested that DOE line up CSLs across different ECGs in an effort to
avoid confusion when discussing the CSLs. (NEMA, No. 54 at p. 73;
Baldor, Public Meeting Transcript, No. 60 at pp. 171, 172) DOE
understands NEMA's concerns regarding the nomenclature of its ELs,
however, it has maintained its approach for the NOPR analysis. DOE
examines each ECG independently, and because different motor types have
different baselines, the EL numbers do not always align.
NEMA also asked if the baseline CSL developed for ECG 1, which was
developed based on an analysis of vertical, hollow-shaft motors,
included losses related to testing those motors with thrust bearings.
NEMA inquired because, at the time of its comment, DOE had not yet
published the test procedure NOPR, indicating how these motor types
might be tested. (NEMA, No. 54 at pp. 71-72, 77)
DOE clarifies that the vertical hollow-shaft motors purchased and
used to determine the baseline efficiency level for ECG 1 contained
bearings capable of horizontal operation. Therefore, DOE tested these
motors in a horizontal configuration without any modifications to the
bearings. Additionally, when tested, solid-shafts were welded inside
the hollow-shaft to permit the motor to be attached to a dynamometer
for testing. These modifications are in line with the proposals for
vertical hollow shaft motors as described in DOE's electric motors test
procedure NOPR. 78 FR 38456 (June 26, 2013).
During the preliminary analysis public meeting, NEMA noted that the
CSL 5 software-modeled efficiency was 96.4 percent and should have been
assigned a NEMA nominal efficiency level of 96.2 percent rather than
96.5. (NEMA, No. 54 at p. 80) NEMA and Baldor added that CSL 5 should
not be included in any engineering analysis because of the
infeasibility of cast-copper rotors, and that CSL 4 is the proper max-
tech level when CSL 5 is eliminated from consideration. (NEMA, No. 54
at p. 73; Baldor, Public Meeting Transcript, No. 60 at p. 171) The
Efficiency Advocates also expressed concern about some of the CSLs
analyzed by DOE and questioned the viability of CSL 3. The Efficiency
Advocates noted that some of the CSL 3 designs were at the very limits
of critical motor performance parameters, such as locked-rotor torque
and current. The Efficiency Advocates added that DOE has not tested
motors that perform at the levels that would be required by CSL 3, 4,
and 5. Without having done so, DOE cannot verify the predicted
performance of its representative units. (NPCC, No. 56 at pp. 4, 5)
As discussed, DOE has removed EL 5 from consideration in the NOPR
analysis, but it has not eliminated the use of copper-die cast rotor
technology (see I.A.1). With regards to the comments from the
Efficiency Advocates, DOE notes that EL 3 for ECG 1 is based on
teardown data from commercially available motors, as it was for the
preliminary analysis. Additionally, for the NOPR, DOE has tested a unit
at EL 4 for one of its representative units. Furthermore, DOE has found
many instances of electric
[[Page 73628]]
motors being sold and marketed one or two NEMA bands of efficiency
above NEMA Premium, which suggests that manufacturers have extended
technological performance where they perceived market demand for higher
efficiencies. In other words, DOE has seen no evidence suggesting that
the absence of products on the market at any given EL implies that such
products could not be developed, were there sufficient demand. DOE
contends that all of the ELs analyzed in its engineering analysis are
viable because equipment is currently commercially available at such
levels \56\ and, to the extent possible, has been included in DOE's
analysis. DOE welcomes comment on the limits of technology, especially
as it varies by equipment class.
---------------------------------------------------------------------------
\56\ DOE understands that this is not true for every equipment
classes covered by this rulemaking, but has not seen evidence to
suggest that the absence of equipment in any particular classes is
not due to lack of market demand instead of technological
limitations.
---------------------------------------------------------------------------
Additionally, NEMA and Baldor commented on the design options
analyzed for the various CSLs. NEMA and Baldor stressed that not using
a common design option across all CSLs may result in a reduction of
available product. (NEMA, No. 54 at pp. 3, 27, 73; Baldor, Public
Meeting Transcript, No. 60 at pp. 169-171, 176-178) NEMA indicated that
it is a standard practice of manufacturers to minimize the number of
types of electrical steel used at a manufacturing facility and that
typically a single type of electrical steel may be used for all
electric motors manufactured at the facility. NEMA added that DOE
should account for this situation when performing engineering analyses
such that a common type of electrical steel is used for the different
NEMA design types covered by a common CSL. (NEMA, No. 54 at p. 62) NEMA
added that although NEMA Design C motors constitute less than 1 percent
of total motor shipments, the electrical steel and die-cast rotor
material used for manufacturing NEMA Design C electric motors is taken
from the same inventory as used for NEMA Design B electric motors.
Therefore, they contended that DOE should select the same material
types for NEMA Design C motors as it does for NEMA Design B motors.
(NEMA, No. 54 at p. 65, 74) Finally, NEMA stated that it did not
understand why DOE used different steels and rotor conductors for CSLs
4 and 5 in some of the ECG 1 representative units but not in others.
(NEMA, No. 54 at pp. 3, 72; Baldor, Public Meeting Transcript, No. 60
at p. 120)
As noted earlier, DOE has restructured its ELs for the NOPR
analysis. One consequence of this restructuring is that DOE no longer
mixes rotor casting technologies for a given EL. However, DOE does not
limit the number of electrical steels used at a given EL to one. DOE
understands that manufacturers try to limit the number of electrical
steels at a given manufacturing facility, but most manufacturers have
more than one manufacturing facility. Therefore, manufacturers could
produce motors with multiple grades of electrical steel. Additionally,
DOE believes that this approach is in line with current industry
practice. For its analysis, DOE obtained multiple units for teardowns
from the same manufacturer. After a steel analysis was conducted on its
teardowns, DOE found that one manufacturer utilized multiple grades of
steel, both across ELs within a representative unit and across
representative units within an EL. Finally, DOE believes that the
restructuring of the ELs should also address concerns over the
technology differences between preliminary analysis ELs 4 and 5 because
in the NOPR analysis there is no EL 5. DOE has updated chapter 5 of the
TSD to include as pertinent design data.
During the preliminary analysis public meeting, ACEEE commented
that new energy conservation levels would have to be raised by at least
two NEMA bands because an increase of only one NEMA band is not
statistically significant. (ACEEE, Public Meeting Transcript, No. 60 at
p. 168) DOE disagrees with this assessment. Although the unit-to-unit
efficiency of a specific electric motor design may vary by multiple
NEMA bands of efficiency, an increase in the required efficiency level
by one band would be significant. If efficiency standards are raised by
one NEMA band, there is no evidence to suggest that manufacturing
practices would change such that the distribution of unit-to-unit
efficiencies for a given motor design would change. Therefore, if the
required efficiency standard were changed by one band of efficiency,
one would assume that the entire population of motors of a given design
would shift by one band of efficiency as manufacturers begin to produce
motors around a higher mean value.
Finally, NEMA commented that another important factor for defining
CSLs is the ability for CSLs to provide efficiency values to be used in
the scaling process and that it is important that the relative
difference between the efficiency values for CSLs is selected such that
the relativity is maintained across all of the representative units if
it is to be applied by scaling to all electric motors included in an
ECG. In other words, NEMA argues that CSLs must be chosen carefully to
correspond with similar technologies and materials across the range of
scaling (i.e., the entire equipment class) and that they should not be
chosen to merely to align with NEMA's own tables and efficiency bands.
(NEMA, No. 54 at p. 73) Responding to this concern, for each EL above
the established NEMA Premium levels, DOE has incremented efficiency by
one nominal band for all equipment classes. This equates to, roughly, a
10 percent decrease in motor losses for all equipment classes for each
jump in EL.
4. Test and Teardowns
Whenever possible, DOE attempted to base its engineering analysis
on actual electric motors being produced and sold in the market today.
First, DOE identified electric motors in manufacturer catalogs that
represented a range of efficiencies corresponding to the ELs discussed
in the previous sections. Next, DOE had the electric motors shipped to
a certified testing laboratory where each was tested in accordance with
IEEE Standard 112 (Test Method B) to verify its nameplate-rated
efficiency. After testing, DOE derived production and material costs by
having a professional motor laboratory \57\ disassemble and inventory
the purchased electric motors. For ECG 1, DOE obtained tear-down
results for all of the 5-horsepower ELs and all of the 30- and 75-
horsepower ELs except the max-tech levels. For ECG 2, DOE obtained
tear-down results only for the baseline EL, which corresponds to EPACT
1992 efficiency levels.
---------------------------------------------------------------------------
\57\ The Center for Electromechanics at the University of Texas
at Austin, a 140,000 sq. ft. lab with 40 years of operating
experience, performed the teardowns, which were overseen by Dr.
Angelo Gattozzi, an electric motor expert with previous industry
experience. DOE also used Advanced Energy Corporation of North
Carolina to perform some of the teardowns.
---------------------------------------------------------------------------
These tear-downs provided DOE with the necessary data to construct
a bill of materials (BOM), which, along with a standardized cost model
and markup structure, DOE could use to estimate a manufacturer selling
price (MSP). DOE paired the MSP derived from the tear-down with the
corresponding nameplate nominal efficiency to report the relative costs
of achieving improvements in energy efficiency. DOE's estimates of
material prices came from a combination of current, publicly available
data, manufacturer feedback, and conversations with its subject matter
experts. DOE supplemented the
[[Page 73629]]
findings from its tests and tear-downs through: (1) A review of data
collected from manufacturers about prices, efficiencies, and other
features of various models of electric motors, and (2) interviews with
manufacturers about the techniques and associated costs used to improve
efficiency.
As discussed earlier, DOE's engineering analysis documents the
design changes and associated costs when improving electric motor
efficiency from the baseline level up to a max-tech level. This
includes considering improved electrical steel for the stator and
rotor, interchanging aluminum and copper rotor bar material, increasing
stack length, and any other applicable design options remaining after
the screening analysis. As each of these design options are added, the
manufacturer's cost increases and the electric motor's efficiency
improves. DOE received multiple comments regarding its test and tear-
down analysis.
NEMA commented that the cost for manufacturing an electric motor
can increase as the efficiency level is increased even when the
material and technology is not changed. It added that an increase in
core length, without any change in the material used, will result in a
higher cost not only due to the increase in the amount of steel, but
also due to the increase in the amount of wire for the stator winding
and aluminum for the rotor core. (NEMA, No. 54 at p. 74)
Notwithstanding, DOE believes that it has accurately captured such
changes. When each electric motor was torn down, components such as
electrical steel and copper wiring were weighed. Therefore, any
increase in stack length would result in increased costs associated
with the increased amount of electrical steel and copper wiring.
NEMA also commented that the best known value of efficiency for a
tested and torn down motor is the tested efficiency and the accuracy of
this value improves as sample size increases. Because DOE only used a
sample size of one, NEMA recommended that DOE should increase its
sample size to something more statistically significant. (NEMA, No. 54
at p. 75) NEMA also referred to the small electric motors rulemaking
and said that a sufficient sample size for testing was proven to be
necessary. (NEMA, No. 54 at p. 27) NEMA also commented that Appendix A
to Subpart U designates the appropriate sample size to support the
conclusion that the name-plated efficiency of a motor is correctly
stated. (NEMA, No. 54 at p. 79) NEMA and Baldor added that Appendix A
to Subpart U requires the determination of a standard deviation from
the sample, and it is not possible to determine a standard deviation
when testing a sample of one motor, which was the sample size of DOE's
motor testing. (NEMA, No. 54 at p. 79; Baldor, Public Meeting
Transcript, No. 60 at p. 154)
DOE agrees that an increased sample size would improve the value of
efficiency used in its analysis, but only if DOE were using an average
full-load efficiency value, as it did for the small electric motors
rulemaking engineering analysis, which did not have the benefit of
NEMA-developed nominal efficiency values. For today's analysis, DOE did
not use the tested efficiency value and believes that to do so would be
erroneous precisely because it only tested and tore down one unit for a
given representative unit and EL. Rather than using an average
efficiency of a sample of multiple units that is likely to change with
each additional motor tested, DOE elected to use the nameplate NEMA
nominal efficiency given. DOE understands that this value, short of
testing data, is the most accurate value to use to describe a
statistically valid population of motors of a given design; that is, in
part, why manufacturers use NEMA nominal efficiencies on their motors'
nameplates.
Furthermore, when DOE conducts its tear-downs, the bill of
materials generated is most representative of the tested value of
efficiency, not necessarily the NEMA nominal value. However, DOE
believes that the variance from unit-to-unit, in terms of materials, is
likely to be insignificant because manufacturers have an incentive to
produce equipment with consistent performance (i.e., characteristics
other than efficiency) as possible. Changes in the tested efficiency
are likely to occur because of variations in production that motor
manufacturers have less control over (e.g., the quality of the
electrical steel). DOE does not believe that the amount of material (in
particular, electrical steel, copper wiring, and die-cast material)
from unit-to-unit for a given design is likely to change significantly,
if at all, because manufacturers have much greater control of those
production variables. Therefore, additional tests and tear-downs are
unlikely to change the MSP estimated for a given motor design and DOE
believes that its sample size of one is appropriate.
In the preliminary engineering analysis, DOE replaced a tear-down
result with a software model for CSL 2 of its 30-horsepower
representative unit because it believed that it had inadvertently
tested and torn down a motor with an efficiency equivalent to CSL 3.
DOE noted that it removed the tear-down because there was conflicting
efficiency information on the Web site, in the catalog, and on the
physical nameplate. Subsequently, NEMA and Baldor commented that the
30-horsepower, CSL 2 motor should not have been replaced with a
software-modeled motor, stating that the test result was statistically
viable. (NEMA, No. 54 at pp. 76-79; Baldor, Public Meeting Transcript,
No. 60 at pp. 150-155) NEMA and Baldor also asserted that DOE had
placed emphasis on the use of purchased motors in its analysis only
when the tested value of efficiency was less than or not significantly
greater than the marked value of NEMA efficiency. (NEMA, No. 54 at p.
80; Baldor, Public Meeting Transcript, No. 60 at pp. 156, 157)
DOE understands that the test result may have been viable for
either of the efficiency ratings that the manufacturer had assigned.
Given the uncertainty, however, DOE elected to replace the motor. DOE
did not discard the unit simply because it tested significantly above
its nameplate efficiency. Rather, the motor was listed with different
values of efficiency depending upon the source and when torn down, the
resulting MSP was higher than the MSP for the next CSL. These facts
suggested that the calculated results were erroneous because it is
unlikely (based on available data) that it would be cheaper to build a
more efficient motor than a less efficient one of comparable
specifications. If DOE had included these data in its analysis, it
would likely have resulted in a projection that even higher CSLs would
be economically justified. The combination of these factors resulted in
DOE eliminating that motor from the analysis. For its updated NOPR
engineering analysis, DOE has tested and torn down a new 30-horsepower
motor to describe CSL 2. As stated previously, DOE always prefers to
base its analysis using motors purchased in the market when possible.
NEMA commented that the disproportionate variation in frame weights
between the CSLs suggests that the CSLs of some representative units
were not of similar construction. (NEMA, No. 54 at p. 78) When
selecting motors for tear-down, DOE selected motors with increasing
efficiencies. These motors may not have used the same frame material.
For example, the CSL 0 for the 30-horsepower representative units was
made out of cast aluminum, but CSL 1 unit used cast iron. This material
change accounts for the large difference in frame weight.
[[Page 73630]]
During the preliminary analysis public meeting, Nidec requested
clarification for the increase in stator copper weight for the 75-
horsepower, ECG 1 representative unit between CSL 2 and CSL 3 since the
reported slot fills were the same and the motors had similar stack
lengths. (Nidec, Public Meeting Transcript, No. 60 at pp. 164, 165)
After DOE's tear-down lab determined that the torn-down motors were
machine-wound a precise measurement of the slot fill was not taken.
Although the actual measurement of slot fill has no bearing on the
estimates of the MSP, because the actual copper weights were measured
and not calculated, DOE did ask its lab to provide actual measurements
of slot fill on any subsequent tear-downs and has included the data in
chapter 5 of the TSD.
5. Software Modeling
In the preliminary analysis, DOE worked with technical experts to
develop certain CSLs, in particular, the max-tech efficiency levels for
each representative unit analyzed. DOE retained an electric motors
subject matter expert (SME) \58\ with design experience and software,
who prepared a set of designs with increasing efficiency. The SME also
checked his designs against tear-down data and calibrated his software
using the relevant test results. As new designs were created, DOE's SME
ensured that the critical performance characteristics that define a
NEMA design letter, such as locked-rotor torque, breakdown torque,
pull-up torque and locked-rotor currents were maintained. For a given
representative unit, DOE ensured that the modeled electric motors met
the same set of torque and locked-rotor current requirements as the
purchased electric motors. This was done to ensure that the utility of
the baseline unit was maintained as efficiency improved. Additionally,
DOE limited its modeled stack length increases based on teardown data
and maximum ``C'' dimensions found in manufacturer's catalogs.\59\
---------------------------------------------------------------------------
\58\ Dr. Howard Jordan, Ph.D., an electric motor design expert
with over 40 years of industry experience, served as DOE's subject
matter expert.
\59\ The ``C'' dimension of an electric motor is the length of
the electric motor from the end of the shaft to the end of the
opposite side's fan cover guard. Essentially, the ``C'' dimension is
the overall length of an electric motor including its shaft
extension.
---------------------------------------------------------------------------
In response to the preliminary analysis, Baldor and NEMA requested
clarification on how DOE compared its software modeled results to the
electric motors that it had tested and torn down. (NEMA, No. 54 at p.
74; Baldor, Public Meeting Transcript, No. 60 at p. 148) NEMA requested
that more details regarding that comparison and the name of the
software program used to be included in an updated technical support
document. (NEMA, No. 54 at p. 12) Per the request of NEMA and Baldor,
DOE has provided comparisons of software estimates and tested
efficiencies in appendix 5C of the TSD. Additionally, the software
program that DOE used for its analysis is a proprietary software
program called VICA.\60\
---------------------------------------------------------------------------
\60\ VICA stands for ``Veinott Interactive Computer Aid.''
---------------------------------------------------------------------------
NEMA expressed concern over efficiency standards based on the
software platform DOE used and stated that DOE should build working
prototypes of its software modeled motors to prove the designs work.
(NEMA, No. 54 at pp. 24-25 and 74-75) Baldor reiterated this point in
verbal comments and suggested that this was particularly important for
CSLs with copper rotor designs given their concerns with copper rotor
motors. (NEMA, No. 54 at pp. 76-77; Baldor Public Meeting Transcript,
No. 60 at pp. 160, 161) During the preliminary analysis, DOE approached
motor laboratories in an attempt to prototype its software models. DOE
was unable to identify a laboratory that could prototype its software
modeled motors in a manner that would exactly replicate the designs
produced (i.e., they could not die-cast copper). Consequently, at this
time, DOE has not built a prototype of its software models. However,
DOE was able to procure a 5-horsepower NEMA Design B die-cast copper
rotor motor with an efficiency two NEMA bands above the NEMA Premium
level. Therefore, DOE elected to use this design to represent the max-
tech EL for the 5-horsepower representative unit in equipment class
group 1, rather than the software-modeled design used in the
preliminary analysis. DOE's SME used information gained from testing
and tearing down this motor to help corroborate the software modeling.
In the preliminary analysis, DOE indicated that its software
modeling expert made changes to his software designs based on data
collected during the motor teardowns. NEMA commented on this and asked
why DOE's software modeling expert made changes to some of his designs
based on teardown data. (NEMA, No. 54 at p. 75) DOE clarifies that the
software program was updated using additional teardown data (e.g., more
accurate dimensions and material types) to maintain as many
consistencies in design as possible. For example, DOE's software
modeling expert used lamination diameters measured during the teardowns
as limits for the software models.
In submitted comments, NEMA noted that the NEMA nominal efficiency
for the software-modeled motors was derived by selecting the value that
was lower than the calculated efficiency. NEMA questioned this approach
and added that assigning a value of NEMA nominal efficiency based on a
calculated value of efficiency requires more knowledge than merely
selecting the closest NEMA nominal value that is lower than the
calculated value. (NEMA, No. 54 at p. 76) DOE notes that it selected
the closest NEMA nominal efficiency that is less than or equal to the
predicted efficiency of the software for multiple reasons. First, DOE
wanted to maintain the use of nominal efficiency values to remain
consistent with past electric motor efficiency standards. Second, DOE
chose a value below its software estimate because this method would
provide a more conservative approach. DOE believes its approach was
appropriate given the various concerns raised with copper rotor motor
technologies.
During the preliminary analysis public meeting, Regal-Beloit
commented that calibration of the software-modeled motors is extremely
important. Regal-Beloit added that the calibration of select models is
very important due to the amount of interpolation that DOE is basing on
these models. (Regal-Beloit, Public Meeting Transcript, No. 60 at pp.
159-160) Alluding to copper rotor motors, NEMA commented on DOE's
software modeling, claiming that verifying the accuracy of a software
program with respect to performance obtained from testing purchased
motors does not verify the accuracy of the software program when it is
used for a technology which has not been verified by tests. (NEMA, No.
54 at p. 76; Baldor, Public Meeting Transcript, No. 60 at pp. 160, 161)
DOE appreciates these comments and, as stated, has conducted
calibration of its software program using data obtained from motor
teardowns. DOE has provided comparisons of software estimates and
tested efficiencies for both aluminum and copper rotor motors in
appendix 5C of the TSD.
NEMA commented that the preliminary TSD did not show that the
software platform DOE used had been substantiated as being sufficiently
accurate for motors incorporating existing and new technologies. (NEMA,
No. 54 at p. 12) NEMA asserted that it is necessary to substantiate the
software platform used for modeling as an
[[Page 73631]]
alternate efficiency determination method (AEDM) such that the
calculated efficiencies can be verified as accurate for the types of
technologies included in a motor design. NEMA urged that DOE
substantiate the software platform used by its SME as an AEDM. (NEMA,
No. 54 at p. 76) Baldor added that DOE expects manufacturers to
prototype five motors to certify a program, but DOE has not designed
and built any of the motors designed in its own program. (Baldor,
Public Meeting Transcript, No. 60 at p. 162) Nidec commented during the
public meeting, asking if the software modeling suite DOE used has gone
through the same scrutiny that manufacturers are subject to when they
must submit their 25 samples to correlate their estimated computer data
with actual testing data. (Nidec, Public Meeting Transcript, No. 60 at
p. 147)
DOE understands the comments received regarding its software
program, but maintains that substantiation of an AEDM is a concept
intended for certifying compliance with energy efficiency standards. It
is a tool that manufacturers use to help ensure that the equipment they
manufacture comply with a Federal standard (which is the manufacturers'
duty). It is not a tool for assessing whether a particular energy
efficiency level under consideration by DOE satisfies the EPCA
criteria. Accordingly, the use of the AEDM in the manner suggested by
industry would not be relevant for the purposes of this engineering
analysis, which is geared toward DOE's standards rulemaking.
NEMA also commented that to properly determine the impact of
increased efficiency on motor utility, DOE must recognize the
consequences of how motor performance, including parameters such as
acceleration, safe stall time, overspeed, service factor, thermal
performance, and in-rush current will be affected by more stringent
energy conservation standards. NEMA also specifically referred to
performance characteristics found in NEMA MG 1 sections 12.44, 12.45,
12.48, 12.49, 12.53, 12.54, and 12.56. (NEMA, No. 54 at pp. 5, 77) NEMA
added that the narrow margin between the NEMA MG 1-2011 limits for
locked-rotor current and the calculated locked-rotor current for some
of the software-modeled designs in the preliminary analysis suggest
that there will be problems with these motors meeting the NEMA MG 1
limits if they were prototyped. (NEMA, No. 54 at p. 77) Finally, NEMA
indicated that two of the DOE software-modeled motors in the
preliminary analysis, representing the 75-horsepower CSLs 4 and 5 for
ECG 1, had torque ratings twice that of a U.S. Army 75-horsepower
electric motor software model, and suggested that the software models
used in DOE's analysis are not accurate in modeling copper rotor motor
performance. (NEMA, No. 54 at p. 77)
DOE has carefully considered NEMA's comments in its updated NOPR
analysis. As noted, DOE has eliminated designs from its preliminary
analysis because of concerns regarding the feasibility of those
efficiency levels. Regarding the additional performance parameters, DOE
agrees that these characteristics must be maintained when improving an
electric motor's efficiency. However, the performance parameters DOE
believed to present the largest risk of rendering a motor noncompliant
with NEMA MG 1-2011 standards were those related to NEMA design letter,
which were adhered to in DOE's modeling efforts. Based on comparisons
of motor teardowns and software estimates, DOE has no reason at this
time to believe that its modeled designs would violate the additional
performance parameters mentioned by NEMA.
DOE believes that its subject matter expert, who has been designing
electric motors for several decades, is well qualified to understand
the design tradeoffs that must be considered. Although the SME's
primary task was to design a more efficient motor using various
technologies, it was of critical importance that the designs be
feasible. Even though DOE was unable to prototype its modeled designs,
DOE has conducted comparisons of software estimates and tested
efficiencies for both aluminum and copper rotor motors and believes
this corroborates the modeled designs. Based on this work and its total
analysis, which included input from its SME, DOE believes it developed
a sufficiently robust set of technically feasible efficiency levels for
its engineering analysis.
NEMA asked how DOE intended to take into consideration motor
utility as motor size increases. (NEMA, No. 54 at pp. 23, 24) During
the preliminary analysis public meeting, Baldor asked if the higher
CSLs would fit into existing frame sizes, or if those motors would have
to be redesigned to allow for the increased stack length. Baldor added
that if the frame size increases, the motor may no longer fit current
applications, which would cause additional burden for end-users or
original equipment manufacturers. (Baldor, Public Meeting Transcript,
No. 60 at pp. 164, 245) Baldor added that IEC frame motors are more
constrained in terms of size and space than NEMA frame motors, and it
is more difficult to increase the efficiency on IEC frame motors
without changing frame size designations, which would lead to space
constraint issues. (Baldor and ABB, Public Meeting Transcript, No. 60
at pp. 245, 246) Flolo Corporation also commented on motor length
during the public meeting, insisting that it is important that DOE
recognize the difference in ``C'' dimension that any new energy
conservation standard would mandate, as increasing the ``C'' dimension
will make it difficult for a motor to fit into its originally intended
machine. (Flolo, Public Meeting Transcript, No. 60 at pp. 243, 244) The
Efficiency Advocates also commented on motor length, indicating that
DOE should be aware of absolute motor length limits when considering
increased stack length, and that these changes could greatly increase
the installed cost of many of the higher CSLs, impacting field and
original equipment manufacturer (OEM) installation. (Advocates, No. 56
at p. 4)
In the preliminary TSD, DOE stipulated that any increase in stack
length would fit into the existing frame designation for that
particular motor rating. DOE noted that the frame designation does not
limit frame length, but rather frame diameter. DOE also understands
that manufacturers have fixed-length frames that they use when
manufacturing motors. In addition to generating per unit costs
associated with redesigning motors with new frames at all ELs above the
NEMA Premium levels (see IV.C.6), DOE sought to maintain motor length
by limiting how much it would modify stack dimensions to improve
efficiency. First, the software models created by DOE used lamination
diameters observed during teardowns, which ensured that the software-
modeled designs would fit into existing frame designations. However,
for some designs DOE increased the number of laminations (i.e., length
of the stack of laminations, or stack length) beyond the stack lengths
observed during the motor teardowns in order to achieve the desired
efficiency gains.
DOE limited the amount by which it would increase the stack length
of its software-modeled electric motors in order to preserve the
motor's utility. The maximum stack lengths used in the software-modeled
ELs were determined by first analyzing the stack lengths and ``C''
dimensions of torn-down electric motors. Then, DOE analyzed the ``C''
dimensions of various electric motors in the marketplace conforming to
the same design constraints as the representative units (same
horsepower rating, NEMA
[[Page 73632]]
frame size, enclosure type, and pole configuration). For each
representative unit, DOE found the largest ``C'' dimension currently
available on the marketplace and estimated a maximum stack length based
on the stack length to ``C'' dimension ratios of motors it tore down.
The resulting product was the value that DOE chose to use as the
maximum stack length considered in its software modeled designs,
although DOE notes that it did not always model a motor with that
maximum stack length. In most instances, the SME was able to achieve
the desired improvement in efficiency with a stack length shorter than
DOE's estimated maximum. Table IV.12 shows the estimated maximum stack
length, the maximum stack length found during tear-downs, and the
maximum stack length modeled for a given representative unit. DOE
welcomes additional comments on software modeling in general, and on
specific data that could be used to calibrate its software designs.
Table IV.12--Maximum Stack Length Data
----------------------------------------------------------------------------------------------------------------
Estimated maximum stack Maximum stack length Maximum stack length
Representative unit length of a torn down motor modeled
----------------------------------------------------------------------------------------------------------------
30 Horsepower
Design B........................ 8.87 in................ 8.02 in. (EL 2)....... 7.00 in.
75 Horsepower
Design B........................ 13.06 in............... 11.33 in. (EL 3)...... 12.00 in.
5 Horsepower
Design C........................ 5.80 in................ 4.75 in. (EL 0)....... 5.32 in.
50 Horsepower
Design C........................ 9.55 in................ 8.67 in. (EL 0)....... 9.55 in.
----------------------------------------------------------------------------------------------------------------
6. Cost Model
When developing manufacturer selling prices (MSPs) for the motor
designs obtained from DOE's tear-downs and software models, DOE used a
consistent approach to generate a more accurate approximation of the
costs necessary to improve electric motor efficiency. DOE derived the
manufacturer's selling price for each design in the engineering
analysis by considering the full range of production and non-production
costs. The full production cost is a combination of direct labor,
direct materials, and overhead. The overhead contributing to full
production cost includes indirect labor, indirect material,
maintenance, depreciation, taxes, and insurance related to company
assets. Non-production cost includes the cost of selling, general and
administrative items (market research, advertising, sales
representatives, logistics), research and development (R&D), interest
payments, warranty and risk provisions, shipping, and profit factor.
Because profit factor is included in the non-production cost, the sum
of production and non-production costs is an estimate of the MSP. DOE
utilized various markups to arrive at the total cost for each component
of the electric motor and these markups are detailed in chapter 5 of
the TSD.
a. Copper Pricing
DOE conducted the engineering analysis using material prices based
on manufacturer feedback, industry experts, and publicly available
data. In the preliminary analysis, most material prices were based on
2011 prices, with the exception of cast copper and copper wire pricing,
which were based on a five-year (2007-2011) average price.
DOE received comments regarding its copper price development. NPCC
supported DOE's decision to use a five-year price average for copper
materials and suggested that this method should be used whenever a
commodity price shows a pattern of irregular spikes or valleys.
(Advocates, No. 56 at p. 4) Conversely, the Industrial Energy Consumers
of America (IECA) stated that material costs for high efficiency motors
are very volatile and cannot be reliably projected from a simple five-
year average, as DOE did with copper prices during the preliminary
analysis. IECA added that as a result of using a five-year average, the
high efficiency motor material costs may be highly underestimated in
DOE's engineering analysis, and IECA suggested that a range of material
costs rather than averages could better inform a range of life-cycle
costs and payback periods for each CSL. (IECA, No. 52 at p. 3)
Based on these comments, DOE has slightly modified its approach.
First, DOE added updated data for 2012 pricing. Second, rather than a
five-year average, DOE changed to a three-year average price for copper
materials. DOE made this modification based on feedback received during
manufacturer interviews. By reducing to a three-year average, DOE
eliminated data from 2008 and 2009, which manufacturers believed were
unrepresentative data points due to the recession. Data from those two
years had the effect of depressing the five-year average calculated.
b. Labor Rate and Non-Production Markup
In the preliminary analysis, DOE looked at the percentage of
electric motors imported into the U.S. and the percentage of electric
motors built domestically and based the balance of foreign and domestic
labor rates on these percentages. During the preliminary analysis
public meeting, Nidec commented that the labor rate DOE used in its
analysis seems high if that number is weighted towards offshore labor.
Nidec also agreed with DOE's smaller markup on the lower-horsepower
motors, but commented that the overall markups DOE used seem to be
high. (Nidec, Public Meeting Transcript, No. 60 at p. 184) WEG added to
these comments, indicating that they believed DOE was adequately
addressing the cost structure variations among the different motor
manufacturers. Additionally, WEG believed that basing a labor rate on
both foreign and domestic labor rates increases accuracy of the
analysis, but warned that DOE should be careful not encourage
production moving outside the United States. (WEG, Public Meeting
Transcript, No. 60 at pp. 184-186)
At this time, DOE has elected to keep the same labor rates and
markups as were used in the preliminary analysis. DOE is basing this
decision on additional feedback received during interviews with
manufacturers and the absence of any alternative labor rate or markups
to apply.
Finally, DOE is aware of potential cost increases caused by
increased slot fill, including the transition to hand-wound stators in
motors requiring higher slot
[[Page 73633]]
fills. In the preliminary analysis, DOE assigned a higher labor hour to
any tear-down motor which it determined to be hand-wound. NEMA
commented that DOE did not assign a hand-wound labor-hour assumption to
any of the tear-down motors, and requested clarification about whether
there were instances of hand winding in these motors. (NEMA, No. 54 at
p. 23) DOE found that none of the tear-down motors were hand-wound, and
therefore no hand-winding labor-hour amounts were assigned. This has
been clarified in the NOPR analysis. Additionally, DOE has assumed that
all of its max-tech software models require hand-winding, which is
reflected in its increased labor time assumptions for those motors. For
additional details please see chapter 5 of the TSD.
In response to DOE's request for comment on the possibility of
higher labor costs for lower-volume electric motors, NEMA indicated
that plants with few manufacturing setup changes, because they may
focus on standard motor designs with no special motors, have the
ability to produce more motors per employee, and that this is the case
with many offshore companies that build designs for import to the U.S.
(NEMA, No. 54 at pp. 27, 28). For other companies that cater to OEMs
that require special designs and small lot production, setup changes
eat into the capacity of these plants, particularly in the 56/140T
through 250T frame series where there is high volume. A plant where the
lot (i.e., batch) size per order is smaller has less impact from setup.
DOE acknowledges that lower-volume products will often realize
higher per unit costs, and believes this reality is common to most or
all manufacturing processes in general. Because DOE's analysis focuses
on the differential impacts on cost due to standards, and because DOE
has no evidence to suggest a significant market shift to lower
production volume in a post-standards scenario, DOE expects that the
relative mix of high- and low-volume production would be preserved.
Indeed, because DOE is proposing to expand scope of coverage and bring
many previously-excluded motor types to NEMA Premium levels, DOE sees
the possibility that standardization may increase and average
production volume may, in fact, rise.\61\ DOE welcomes additional
comment on how standards may cause average production run volume to
rise or fall, and how labor costs may vary as a result.
---------------------------------------------------------------------------
\61\ Labor costs may rise starkly at max-tech levels, where
hand-winding is employed in order to maximize slot fill. DOE's
engineering analysis reflects this fact.
---------------------------------------------------------------------------
c. Catalog Prices
NEMA also requested that DOE publish the purchase price for its
torn down motors, so that they could be compared to the MSPs DOE
derived from its motor tear-downs. (NEMA, No. 54 at p. 27; Baldor,
Public Meeting Transcript, No. 60 at pp. 181, 182) At this time, DOE is
electing not to include the purchase price for its torn down motors.
DOE believes that such information is not relevant and could lead to
erroneous conclusions. Some of the purchased motors were more expensive
to purchase based on certain features that do not affect efficiency,
which could skew the price curves incorrectly and indicate incorrect
trends. For these reasons, in the engineering analysis, DOE develops
its own cost model so that a consistent cost structure can be applied
to similar equipment. The details of this model are available in
appendix 5A. Because DOE purchased electric motors that were built by
different manufacturers and sold by different distributors, who all
have different costs structures, DOE does not believe that such a
comparison is a meaningful evaluation.
d. Product Development Cost
In response to the preliminary analysis, NEMA commented that DOE
presumes that the incremental cost between motors of different designs
and different technologies is based solely on the difference in
material costs and markups. NEMA also commented that there is a higher
cost of manufacturing a die-cast copper rotor compared to an aluminum
die-cast rotor motor that is not captured in material costs. (NEMA, No.
54 at p. 12, 74) During the preliminary analysis public meeting, ACEEE
commented that the Motor Coalition has concerns about CSL 3 for ECG 1,
stating that DOE's analysis may not have captured the full cost of an
industry-transition to that efficiency level. (ACEEE, Public Meeting
Transcript, No. 60 at p. 20)
DOE has made some additions to its cost model for the NOPR analysis
based on NEMA's comments. However, DOE clarifies that its cost model
for the preliminary analysis did include an incremental markup used to
account for higher production costs associated with manufacturing
copper die-cast rotors. Although DOE used this incremental markup in
the preliminary analysis, after conducting manufacturer interviews for
the NOPR analysis, it believed that additional costs were warranted for
the examined ELs that exceeded the NEMA Premium level. NEMA commented
that the manufacturer production costs (MPCs) and subsequent LCCs must
take into account the large additional conversion costs, since
manufacturers would likely attempt to recover the costs of meeting a
higher efficiency standard. (NEMA, No. 54 at p. 4) Therefore, DOE
developed a per-unit adder \62\ for the MPCs intended to capture one-
time increased product development and capital conversion costs that
would likely result if an efficiency level above NEMA Premium were
established.
---------------------------------------------------------------------------
\62\ The ``per-unit adder'' discussed in this section refers to
a fixed adder for each motor that varies based on horsepower and
NEMA design letter. Each representative unit has their own unique
``per-unit adder'' that is fixed for the analysis.
---------------------------------------------------------------------------
DOE's per-unit adder reflects the additional cost passed along to
the consumer by manufacturers attempting to recover the costs incurred
from having to redevelop their equipment lines as a result of higher
energy conservation standards. The conversion costs incurred by
manufacturers include capital investment (e.g., new tooling and
machinery), equipment development (e.g., reengineering each motor
design offered), plus testing and compliance certification costs.
The conversion cost adder was only applied to ELs above NEMA
Premium based on manufacturer feedback. Most manufacturers now offer
NEMA Premium motors for a significant portion of their equipment lines
as a result of EISA 2007, which required manufacturers to meet this
level. Many manufacturers also offer certain ratings with efficiency
levels higher than NEMA Premium. However, DOE is not aware of any
manufacturer with a complete line of motors above NEMA Premium.
Consequently, DOE believes that energy conservation standards above
NEMA Premium would result in manufacturers incurring significant
conversion costs to bring offerings of electric motors up to the higher
standard.
DOE developed the various conversion costs from data collected
during manufacturer interviews that were conducted for the Manufacturer
Impact Analysis (MIA). For more information on the MIA, see TSD chapter
12. DOE used the manufacturer-supplied data to estimate industry-wide
capital conversion costs and product conversion costs for each EL above
NEMA Premium. DOE then assumed that manufacturers would mark up their
motors to recover the total conversion costs over a seven year period.
By dividing industry-wide conversion costs by seven years of expected
industry-
[[Page 73634]]
wide revenue, DOE obtained a percentage estimate of how much each motor
would be marked up by manufacturers. The conversion costs as a
percentage of 7-year revenue that DOE derived for each NEMA band above
NEMA premium are shown below. Details on these calculations are shown
in Chapter 5 of the TSD.
Table IV.13--Product Conversion Costs as a Percentage of 7-Year Revenue
------------------------------------------------------------------------
Conversion costs
as a percentage
NEMA bands above NEMA premium of 7-year revenue
(percent)
------------------------------------------------------------------------
1.................................................... 4.1
2.................................................... 6.5
------------------------------------------------------------------------
The percentage markup was then applied to the full production cost
(direct material + direct labor + overhead) at the NEMA Premium levels
to derive the per unit adder for levels above NEMA Premium (see Table
IV.14).
Table IV.14--Product Conversion Costs for Efficiency Levels Above NEMA
Premium
------------------------------------------------------------------------
Per unit adder
Per unit adder for 2 bands
Representative unit for 1 band above above NEMA
NEMA premium premium
------------------------------------------------------------------------
5 HP, Design B...................... $11.06 $17.36
30 HP, Design B..................... 32.89 1.61
75 HP, Design B..................... 66.18 103.86
5 HP, Design C...................... 10.68 16.75
50 HP, Design C..................... 60.59 95.08
------------------------------------------------------------------------
7. Engineering Analysis Results
The results of the engineering analysis are reported as cost versus
efficiency data in the form of MSP (in dollars) versus nominal full-
load efficiency (in percentage). These data form the basis for
subsequent analyses in today's NOPR. Table IV.15 through Table IV.19
show the results of DOE's updated NOPR engineering analysis.
Results for Equipment Class Group 1 (NEMA Design A and B Electric
Motors)
Table IV.15--Manufacturer Selling Price and Efficiency for 5-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline)..................... 82.5 330
EL 1 (EPACT 1992)................... 87.5 341
EL 2 (NEMA Premium)................. 89.5 367
EL 3 (Best-in-Market)............... 90.2 402
EL 4 (Max-Tech)..................... 91.0 670
------------------------------------------------------------------------
Table IV.16--Manufacturer Selling Price and Efficiency for 30-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline)..................... 89.5 848
EL 1 (EPACT 1992)................... 92.4 1,085
EL 2 (NEMA Premium)................. 93.6 1,156
EL 3 (Best-in-Market)............... 94.1 1,295
EL 4 (Max-Tech)..................... 94.5 2,056
------------------------------------------------------------------------
Table IV.17--Manufacturer Selling Price and Efficiency for 75-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline)..................... 93.0 1,891
EL 1 (EPACT 1992)................... 94.1 2,048
EL 2 (NEMA Premium)................. 95.4 2,327
EL 3 (Best-in-Market)............... 95.8 2,776
EL 4 (Max-Tech)..................... 96.2 3,620
------------------------------------------------------------------------
Results for Equipment Class Group 2 (NEMA Design C Electric Motors)
[[Page 73635]]
Table IV.18--Manufacturer Selling Price and Efficiency for 5-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline/EPACT 1992).......... 87.5 331
EL 1 (NEMA Premium)................. 89.5 355
EL 2 (Max-Tech)..................... 91.0 621
------------------------------------------------------------------------
Table IV.19--Manufacturer Selling Price and Efficiency for 50-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline/EPACT 1992).......... 93.0 1,537
EL 1 (NEMA Premium)................. 94.5 2,130
EL 2 (Max-Tech)..................... 95.0 2,586
------------------------------------------------------------------------
Results for Equipment Class Group 3 (Fire Pump Electric Motors)
Table IV.20--Manufacturer Selling Price and Efficiency for 5-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturing
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline/EPACT 1992).......... 87.5 341
EL 1 (NEMA Premium)................. 89.5 367
EL 2 (Best-in-Market)............... 90.2 402
EL 3 (Max-Tech)..................... 91.0 670
------------------------------------------------------------------------
Table IV.21--Manufacturer Selling Price and Efficiency for 30-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline/EPACT 1992).......... 92.4 1,085
EL 1 (NEMA Premium)................. 93.6 1,156
EL 2 (Best-in-Market)............... 94.1 1,295
EL 3 (Max-Tech)..................... 94.5 2,056
------------------------------------------------------------------------
Table IV.22--Manufacturer Selling Price and Efficiency for 75-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline/EPACT 1992).......... 94.1 2,048
EL 1 (NEMA Premium)................. 95.4 2,327
EL 2 (Best-in-Market)............... 95.8 2,776
EL 3 (Max-Tech)..................... 96.2 3,620
------------------------------------------------------------------------
Results for Equipment Class Group 4 (Brake Electric Motors)
Table IV.23--Manufacturer Selling Price and Efficiency for 5-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline)..................... 82.5 330
EL 1 (EPACT 1992)................... 87.5 341
EL 2 (NEMA Premium)................. 89.5 367
EL 3 (Best-in-Market)............... 90.2 402
EL 4 (Max-Tech)..................... 91.0 670
------------------------------------------------------------------------
[[Page 73636]]
Table IV.24--Manufacturer Selling Price and Efficiency for 30-Horsepower
Representative Unit
------------------------------------------------------------------------
Manufacturer
Efficiency level Efficiency (%) selling price
($)
------------------------------------------------------------------------
EL 0 (Baseline)..................... 89.5 848
EL 1 (EPACT 1992)................... 92.4 1,085
EL 2 (NEMA Premium)................. 93.6 1,156
EL 3 (Best-in-Market)............... 94.1 1,295
EL 4 (Max-Tech)..................... 94.5 2,056
------------------------------------------------------------------------
8. Scaling Methodology
Once DOE has identified cost-efficiency relationships for its
representative units, it must appropriately scale the efficiencies
analyzed for its representative units to those equipment classes not
directly analyzed. DOE recognizes that scaling motor efficiencies is a
complicated proposition that has the potential to result in efficiency
standards that are not evenly stringent across all equipment classes.
However, between DOE's four ECGs, there are 580 combinations of
horsepower rating, pole configuration, and enclosure. Within these
combinations there are a large number of standardized frame number
series. Given the sizable number of frame number series and equipment
classes, DOE cannot feasibly analyze all of these variants, hence, the
need for scaling. Scaling across horsepower ratings, pole
configurations, enclosures, and frame number series is a necessity. For
the preliminary analysis, DOE considered two methods to scaling, one
that develops a set of power law equations based on the relationships
found in the EPACT 1992 and NEMA Premium tables of efficiency in NEMA
Standard Publication MG 1, and one based on the incremental improvement
of motor losses. As discussed in the preliminary analysis, DOE did not
find a large discrepancy between the results of the two approaches and,
therefore, used the simpler, incremental improvement of motor losses
approach in its NOPR analysis.
As discussed in IV.C.3, some of the ELs analyzed by DOE were based
on existing efficiency standards (i.e., EPACT 1992 and NEMA Premium).
Additionally, the baseline EL is based on the lowest efficiency levels
found for each horsepower rating, pole configuration, and enclosure
type observed in motor catalog data. Therefore, DOE only required the
use of scaling when developing the two ELs above NEMA Premium (only one
EL above NEMA Premium for ECG 2).
For the higher ELs in ECG 1, DOE's scaling approach relies on NEMA
MG 1-2011 Table 12-10 of nominal efficiencies and the relative
improvement in motor losses of the representative units. As has been
discussed, each incremental improvement in NEMA nominal efficiency (or
NEMA band) corresponds to roughly a 10 percent reduction in motor
losses. After ELs 3 and 4 were developed for each representative unit,
DOE applied the same reduction in motor losses (or the same number of
NEMA band improvements) to various segments of the market based on its
representative units. DOE assigned a segment of the electric motors
market, based on horsepower ratings, to each representative unit
analyzed. DOE's assignments of these segments of the markets were in
part based on the standardized NEMA frame number series that NEMA MG 1-
2011 assigns to horsepower and pole combinations. In the end, EL 3
corresponded to a one band improvement relative to NEMA Premium and EL
4 corresponded to a two-band improvement relative to NEMA Premium. In
response to the preliminary analysis, DOE received multiple comments
regarding scaling.
NEMA commented that DOE states that scaling is necessary for the
national impacts analysis, but NEMA contends that the foremost reason
for the scaling is that the scaling is used to establish the values of
any amended or new efficiency standards. (NEMA, No. 54 at p. 68) NEMA
also expressed its belief that the scaling method used in the
preliminary analysis does not adequately take into consideration
numbers of poles, stack length, and frame enclosures and that scaling
based on changes in efficiency for lower horsepower motor models, as
interpreted by software, does not accurately reflect what is achievable
for higher horsepower ratings. (NEMA, No. 54 at p. 5)
During the preliminary analysis public meeting, Baldor commented
that because some energy conservation levels could not be reached
without using a different technology option, at least 30 percent of the
ratings in an equipment classes could not achieve energy conservation
levels above CSL 2. Because of this, a scaling method based on any
particular set of technology is not scalable across all equipment
classes. Baldor suggested that DOE could use software modeling to check
some of the motor configurations not directly analyzed. (Baldor, Public
Meeting Transcript, No. 60 at pp. 196, 197, 200)
Nidec commented during the public meeting that scaling has too many
variables, and that manufacturers do not use scaling because it is not
possible. (Nidec, Public Meeting Transcript, No. 60 at pp. 198-199)
ACEEE added that there is no underlying fundamental physical theory
associated with the efficiencies listed in NEMA MG 1-2011 Table 12-11
or Table 12-12. (ACEEE, Public Meeting Transcript, No. 60 at pp. 198-
199)
DOE appreciates the comments received regarding scaling; however,
it maintains that scaling is a tool necessary to analyze the potential
effects of energy conservation standards above NEMA Premium levels. As
stated earlier, DOE is evaluating energy conservation standards for 580
equipment classes. DOE acknowledges that analyzing every one of these
classes individually is not feasible, which requires DOE to choose
representative units on which to base its analysis. DOE agrees with
Baldor that the primary reason for scaling is to establish efficiency
levels for any potential new or amended standards for electric motors.
However, DOE notes that its analysis neither assumes nor requires
manufacturers to use identical technology for all motor types and
horsepower ratings. In other words, although DOE may choose a certain
set of technologies to estimate cost behavior across efficiency, DOE's
standards are technology-neutral and permit manufacturers design
flexibility. DOE clarifies that the national impacts analysis is one of
the primary ways in which DOE analyses those potential efficiency
levels and determines if they would be economically justified. As DOE
has stated, it is also important that the levels be technically
feasible. In
[[Page 73637]]
order to maintain technical feasibility, DOE has maintained the scaling
approach that it developed for the preliminary analysis. DOE believes
that this approach, which is as conservative as possible while
maintaining the use of NEMA nominal efficiencies, accomplishes that.
For each incremental EL above the NEMA Premium level, DOE has
incremented possible efficiency levels by just one band of efficiency.
Through the use of this conservative approach to scaling, DOE believes
that it has helped conserve the technological feasibility of each of
its ELs to the greatest extent practicable.
D. Markups Analysis
The markups analysis develops appropriate markups in the
distribution chain to convert the estimates of manufacturer selling
price derived in the engineering analysis to customer prices.
(``Customer'' refers to purchasers of the equipment being regulated).
In the preliminary analysis, DOE determined the distribution channels
for electric motors, their shares of the market, and the markups
associated with the main parties in the distribution chain,
distributors and contractors. For the NOPR, DOE retained these
distribution channels.
DOE developed average distributor and contractor markups by
examining the contractor cost estimates provided by RS Means Electrical
Cost Data 2013.\63\ DOE calculates baseline and overall incremental
markups based on the equipment markups at each step in the distribution
chain. The incremental markup relates the change in the manufacturer
sales price of higher efficiency models (the incremental cost increase)
to the change in the customer price. Chapter 6 of the NOPR TSD
addresses estimating markups.
---------------------------------------------------------------------------
\63\ RS Means (2013), Electrical Cost Data, 36th Annual Edition,
Kingston, MA.
---------------------------------------------------------------------------
E. Energy Use Analysis
The energy use analysis provides estimates of the annual energy
consumption of commercial and industrial electric motors at the
considered efficiency levels. DOE uses these values in the LCC and PBP
analyses and in the NIA. DOE developed energy consumption estimates for
all equipment analyzed in the engineering analysis.
The annual energy consumption of an electric motor that has a given
nominal full-load efficiency depends on the electric motor's sector
(industry, agriculture, or commercial) and application (compressor,
fans, pumps, material handling, fire pumps, and others), which in turn
determine the electric motor's annual operating hours and load.
To calculate the annual kilowatt-hours (kWh) consumed at each
efficiency level in each equipment class, DOE used the nominal
efficiencies at various loads from the engineering analysis, along with
estimates of operating hours and electric motor load for electric
motors in various sectors and applications.
In the preliminary analysis, DOE used statistical information on
annual electric motor operating hours and load derived from a database
of more than 15,000 individual motor field assessments obtained through
the Washington State University and the New York State Energy Research
and Development Authority to determine the variation in field energy
use in the industrial sector. For the agricultural and the commercial
sector, DOE relied on data found in the literature.
As part of its NOPR analysis, for the industrial sector, DOE re-
examined its initial usage profiles and recalculated motor distribution
across applications, operating hours, and load information based on
additional motor field data compiled by the Industrial Assessment
Center at the University of Oregon, which includes over 20,000
individual motor records. For the agricultural sector, DOE revised its
average annual operating hours assumptions based on additional data
found in the literature. No changes were made to the commercial sector
average annual operating hours.
Chapter 7 of the NOPR TSD describes the energy use analysis.
1. Comments on Operating Hours
Several interested parties commented on the annual operating hours
assumptions. NEMA and UL commented that fire pumps typically operate
when being tested on a monthly basis and that the annual operating-hour
assumption for fire pump electric motors in the industrial sector
seemed high but did not provide data to support their comment. NEMA
agreed with the fire pump electric motor annual operating-hour
assumptions in the commercial and agricultural sectors. (NEMA, No. 54
at p. 83) (UL, No. 46 at p. 1)
For the NOPR, DOE reviewed the field data for fire pump electric
motors used in the preliminary analysis and noticed some values were
associated with motors driving jockey pumps, which are pressure
maintenance pumps used to maintain pressure in fire sprinkler systems.
After filtering out the motors driving jockey pumps, DOE derived an
average value of annual operating hours similar to the fire pump
electric motor annual operating hours for the commercial and
agricultural sectors. Therefore, DOE revised its fire pumps operating
hour assumption accordingly.
NEMA submitted data regarding annual operating hour assumptions in
the industrial sector based on its expert knowledge. These assumptions
were lower than those used in the preliminary analysis. (NEMA, No. 54
at p. 10)
As previously mentioned, DOE revised the average operating hours
associated with applications in the industrial sector (compressor,
fans, pump, material handling, and others) based on additional
individual motor nameplate and field data compiled by the Industrial
Assessment Center at the University of Oregon.\64\ The revised average
operating hour values are generally lower than the estimates from the
preliminary analysis and differ from what NEMA provided. DOE could not
verify the estimates provided by NEMA and it is not clear that these
estimates represent an accurate picture of the entire industrial
sector. In contrast, the average operating hours by motor application
that DOE used in the NOPR were based on an analysis of annual operating
hours for over 35,000 individual motors. DOE notes that it analyzed a
sensitivity case that reflects the NEMA estimates.
---------------------------------------------------------------------------
\64\ Strategic Energy Group (January, 2008), Northwest
Industrial Motor Database Summary from Regional Technical Forum.
https://rtf.nwcouncil.org/subcommittees/osumotor/Default.htm. This
database provides information on motors collected by the Industrial
Assessment Center (IAC) at Oregon State University (OSU). The
database includes more than 22,000 records, each with detailed motor
application and field usage data.
---------------------------------------------------------------------------
IECA commented that the database of plant assessments is based on
surveys conducted between 2005 and 2011 and there is no explanation of
the effects of the recession on these surveys. (IECA, No. 52 at p. 2)
DOE could not estimate the impact of the recession on the average
operating hour values derived from the database of field assessment
from the Washington State University and the New York State Energy
Research and Development Authority, as the year of the assessment was
not specified for all of the entries. The additional data from the
Industrial Assessment Center cover a longer time period (1987-2007).
Thus, DOE believes that its estimates of operating hours are not unduly
affected by lower industrial activity during the recession.
[[Page 73638]]
2. Comments on Other Issues
In response to DOE's energy use discussion from the preliminary
analysis, NEMA commented that NEMA Design C motors are not typically
found in pump applications. (NEMA, No. 54 at p. 83) For NEMA Design C
motors, DOE re-examined its distribution by application and agrees with
NEMA that NEMA Design C motors are not typically found in pump
applications. These motors are characterized by high torque and
generally found in compressors and other applications such as
conveyors. Consistent with this review, DOE adjusted its analyses.
NEMA commented that the curve fit for the polynomial equations
modeling the load versus losses relationships for NEMA Design B motors
did not seem to represent the test data accurately. (NEMA, No. 54 at p.
81)
For each representative unit, DOE based its energy use calculation
on nominal values of efficiency. DOE obtained data on part load losses
from test data developed in the engineering analysis and fitted these
data to derive load versus losses relationships in the form of a third
degree polynomial equation. The representative units showed tested
efficiencies which were not equal to the nominal efficiencies and DOE
adjusted the coefficients of the polynomial equations to match the full
load losses expected at nominal efficiency. The adjusted equation,
therefore, calculates losses for a motor with full load efficiency
equal to the full load nominal efficiency. For the NOPR, DOE followed
the same approach and revised the polynomial equations to reflect the
NOPR engineering outputs.
NEMA commented that the installation of a more efficient motor in
variable torque applications could lead to less energy savings than
anticipated. Because a more efficient motor usually has less slip \65\
than a less efficient one does, this attribute can result in a higher
operating speed and a potential overloading of the motor. NEMA
recommended that DOE include the consequence of a more efficient motor
operating at an increased speed in any determination of energy savings.
(NEMA, No. 54 at p. 28)
---------------------------------------------------------------------------
\65\ The slip is the difference between the synchronous speed of
the magnetic field (as defined by the number of poles), and the
actual rotating speed of the motor shaft.
---------------------------------------------------------------------------
DOE acknowledges that the arithmetic cubic relation between speed
and power requirement in many variable torque applications can affect
the benefits gained by using efficient electric motors, which have a
lower slip. DOE agrees that it is possible to quantify this impact for
one individual motor. However, DOE was not able to extend this analysis
to the national level. DOE does not have robust data related to the
overall share of motors that would be negatively impacted by higher
speeds in order to incorporate this effect in the main analysis.
Further, in the engineering analysis, DOE could not extend the
synchronous speed information from the representative units to the full
range of electric motor configurations. Instead, DOE developed
assumptions \66\ and estimated the effects of higher operating speeds
as a sensitivity analysis in the LCC spreadsheet. For the
representative units analyzed in the LCC analysis, the LCC spreadsheet
allows one to consider this effect as a sensitivity analysis according
to a scenario described in appendix 7-A of the NOPR TSD.
---------------------------------------------------------------------------
\66\ DOE assumed that 60 percent of pumps, fans and compressor
applications are variable torque applications. Of these 60 percent,
DOE assumed that all fans and a majority (70 percent) of compressors
and pumps would be negatively impacted by higher operating speeds;
and that 30 percent of compressors and pumps would not be negatively
impacted from higher operating speeds as their time of use would
decrease as the flow increases with the speed (e.g. a pump filling a
reservoir).
---------------------------------------------------------------------------
IECA commented that estimates of regional shares of motors should
be based on current inventories of motors rather than sector-specific
indicators and that the data from the 2006 Manufacturer Energy
Consumption Survey (MECS) is outdated. (IECA, No. 52 at p. 2) DOE did
not find any information regarding motor inventory and instead used
indirect indicators to derive motor distribution. For the NOPR, DOE
updated its regional shares of motors based on industrial electricity
consumption by region from AEO 2013.
F. Life-Cycle Cost and Payback Period Analysis
For each representative unit analyzed in the engineering analysis,
DOE conducts LCC and PBP analyses to evaluate the economic impacts on
individual customers of potential energy conservation standards for
electric motors. The LCC is the total customer expense over the life of
the motor, consisting of equipment and installation costs plus
operating costs over the lifetime of the equipment (expenses for energy
use, maintenance and repair). DOE discounts future operating costs to
the time of purchase using customer discount rates. The PBP is the
estimated amount of time (in years) it takes customers to recover the
increased total installed cost (including equipment and installation
costs) of a more efficient type of equipment through lower operating
costs. DOE calculates the PBP by dividing the change in total installed
cost (normally higher) due to a standard by the change in annual
operating cost (normally lower) which results from the standard.
For any given efficiency level, DOE measures the PBP and the change
in LCC relative to an estimate of the base-case efficiency levels. The
base-case estimate reflects the market in the absence of new or amended
energy conservation standards, including the market for equipment that
exceeds the current energy conservation standards.
For each representative unit, DOE calculated the LCC and PBP for a
distribution of individual electric motors across a range of operating
conditions. DOE used Monte Carlo simulations to model the distributions
of inputs. The Monte Carlo process statistically captures input
variability and distribution without testing all possible input
combinations. Therefore, while some atypical situations may not be
captured in the analysis, DOE believes the analysis captures an
adequate range of situations in which electric motors operate.
The following sections contain brief discussions of comments on the
inputs and key assumptions of DOE's LCC and PBP analysis and explain
how DOE took these comments into consideration.
1. Equipment Costs
In the LCC and PBP analysis, the equipment costs faced by electric
motor purchasers are derived from the MSPs estimated in the engineering
analysis and the overall markups estimated in the markups analysis.
To forecast a price trend for the preliminary analysis, DOE derived
an inflation-adjusted index of the producer price index (PPI) for
integral horsepower motors and generators manufacturing from 1969 to
2011. These data show a long-term decline from 1985 to 2003, and then a
steep increase since then. DOE also examined a forecast based on the
``chained price index--industrial equipment'' that was forecasted for
AEO2012 out to 2040. This index is the most disaggregated category that
includes electric motors. These data show a short-term increase from
2011 to 2015, and then a steep decrease since then. DOE believes that
there is considerable uncertainty as to whether the recent trend has
peaked, and would be followed by a return to the previous long-term
declining trend, or whether the recent trend represents the beginning
of a long-term rising trend due to global demand for electric motors
and rising commodity costs for key motor components. Given the
uncertainty, DOE chose to use constant
[[Page 73639]]
prices (2010 levels) for both its LCC and PBP analysis and the NIA. For
the NIA, DOE also analyzed the sensitivity of results to alternative
electric motor price forecasts.
DOE did not receive comments on the trend it used for electric
motor prices, and it retained the approach used in the preliminary
analysis for the NOPR.
2. Installation Costs
In the preliminary analysis, the engineering analysis showed that
for some representative units, increased efficiency led to increased
stack length. However, the electric motor frame remained in the same
NEMA frame size requirements as the baseline electric motor, and the
motor's ``C'' dimension remained fairly constant across efficiency
levels. In addition, electric motor installation cost data from RS
Means Electrical Cost Data 2013 showed a variation in installation
costs by horsepower (for three-phase electric motors), but not by
efficiency. Therefore, in the preliminary analysis, DOE assumed there
is no variation in installation costs between a baseline efficiency
electric motor and a higher efficiency electric motor.
Two interested parties commented that DOE might have to consider
increased installation costs related to larger diameter motors in
comparison to baseline motors. (CA IOUs, No. 57 at p. 2; NEMA, No. 54
at p. 83) NEMA added that the size of a motor may need to be increased
to provide the necessary material to obtain higher levels of energy
efficiency, such as CSL 3 examined for Design B electric motors. (NEMA,
No. 54 at p. 83)
DOE's engineering data show that the motor's ``C'' dimension
remained fairly constant across efficiency levels. For equipment class
Group 1, the stack length of higher efficiency motors (EL 3 and above)
did not show significant increases in size in comparison to NEMA
Premium level motors (EL 2). In addition, the frame size remained the
same and the ``C'' dimension data did not significantly vary.
Therefore, for the NOPR, DOE retained the same approach as in the
preliminary analysis and did not incorporate changes in installation
costs for electric motors that are more efficient than baseline
equipment.
NEMA stated that when a user replaces a baseline NEMA Design B
motor with a higher efficiency NEMA Design A motor, the user might
experience additional installation costs compared to replacing the
motor with a baseline NEMA Design B motor due to, for example,
potential needs for new motor controller or motor protection devices.
(NEMA, No. 54 at p. 29) In the engineering analysis, for equipment
class Group 1, all representative units selected were NEMA Design B
motors and the NEMA Design B requirements are maintained across all
efficiency levels. Therefore, DOE did not account for additional
installation costs related to the replacement of NEMA Design B motors
with NEMA Design A motors.
3. Maintenance Costs
In the preliminary analysis, DOE did not find data indicating a
variation in maintenance costs between a baseline efficiency and higher
efficiency electric motor. According to data from Vaughen's Price
Publishing Company,\67\ which publishes an industry reference guide on
motor repair pricing, the price of replacing bearings, which is the
most common maintenance practice, is the same at all efficiency levels.
Therefore, DOE did not consider maintenance costs for electric motors.
DOE did not receive comments on this issue and retained the approach
used for the preliminary analysis for the NOPR.
---------------------------------------------------------------------------
\67\ Vaughen's (2011, 2013), Vaughen's Motor & Pump Repair Price
Guide, 2011, 2013 Edition. https://www.vaughens.com/.
---------------------------------------------------------------------------
4. Repair Costs
In the preliminary analysis, DOE accounted for the differences in
repair costs of a higher efficiency motor compared to a baseline
efficiency motor and defined a repair as including a rewind and
reconditioning. Based on data from Vaughen's, DOE derived a model to
estimate repair costs by horsepower, enclosure and pole, for each EL.
The Electrical Apparatus Service Association (EASA), which
represents the electric motor repair service sector, noted that DOE
should clarify the definition of repair as including rewinding and
reconditioning. (EASA, No. 47 at p. 1) DOE agrees with this suggestion
and has modified its terminology in chapter 7 of the NOPR TSD.
One interested party, Flolo Corporation, noted that since the
1990's, increased windings protection has led to longer repair cycles
and the repair frequency values used in the preliminary analysis were
too low. (Pub. Mtg. Tr., No. 58 at p. 234)
For the preliminary analysis, DOE estimated that NEMA Design A, B
and C electric motors were repaired on average after 32,000 hours of
operation based on data for the industrial sector. This estimate
reflected a situation where electric motors from 1 to 20-horsepower,
with an average lifetime of 5 years, are not repaired; motors from 25-
to 75-horsepower, with an average lifetime of 10 years, are repaired at
half their lifetime; and motors from 100- to 500-horsepower, with an
average lifetime of 15 years, are repaired at a third of their
lifetime. In the NOPR analysis, DOE retained a similar approach for the
industrial and commercial sectors. For the agricultural sector, DOE did
not find sufficient data to distinguish by horsepower range and assumed
that motors are repaired on average at half of their lifetime. With the
revised NOPR mechanical lifetime and operating hour estimates, the
repair frequency in hours increased to 48,600 hours in the industrial
sector compared to DOE's earlier estimate of 32,000 hours.
5. Unit Energy Consumption
The NOPR analysis uses the same approach for determining unit
energy consumptions (UECs) as the preliminary analysis. The UEC was
determined for each application and sector based on estimated load
points and annual operating hours. For the NOPR, DOE refined the
average annual operating hours, average load, and shares of motors by
application and sector.
In the preliminary analysis, DOE assumed that one-third of repairs
are done following industry recommended practice as defined by EASA.
(EASA Standard AR100-2010, Recommended Practice for the Repair of
Rotating Electrical Apparatus) and do not impact the efficiency of the
electric motor (i.e., no degradation of efficiency after repair). DOE
assumed that two-thirds of repairs do not follow good practice and that
a slight decrease in efficiency occurs when the electric motor is
repaired. DOE assumed the efficiency decreases by 1 percent in the case
of electric motors of less than 40 horsepower, and by 0.5 percent in
the case of larger electric motors.
NEMA and EASA asked DOE to clarify its assumption regarding the
share of repairs performed following industry recommended practices.
(NEMA, No. 54 at p. 29) (EASA, No. 47 at p. 1) For the NOPR, DOE
reviewed data from the U.S. Economic Census \68\ and EASA \69\ and
estimated that the majority of motor repair shops are EASA members and
follow industry recommended practices. DOE revised its assumption for
the NOPR analysis and estimated that 90 percent of repairs are done
following industry recommended practice and would not impact the
[[Page 73640]]
efficiency of the motor (i.e. no degradation of efficiency after
repair).
---------------------------------------------------------------------------
\68\ U.S. Economic Census 1997 and 2007 data on the number of
motor repair establishments (based on NAICS 811, 811310, and SIC
7694).
\69\ Members of EASA available at: https://www.easa.com/.
---------------------------------------------------------------------------
NEMA also requested clarification on whether the LCC is based on
site energy or full fuel cycle energy. (NEMA, No. 54 at p. 31) In the
LCC, DOE considers site energy use only.
6. Electricity Prices and Electricity Price Trends
In the preliminary analysis, DOE derived sector-specific weighted
average electricity prices for four different U.S. Bureau of the Census
(Census) regions (Northeast, Midwest, South, and West) using data from
the Energy Information Administration (EIA Form 861). For each utility
in a region, DOE used the average industrial or commercial price, and
then weighted the price by the number of customers in each sector for
each utility.
For each representative motor, DOE assigned electricity prices
using a Monte Carlo approach that incorporated weightings based on the
estimated share of electric motors in each region. The regional shares
were derived based on indicators specific to each sector (e.g.,
commercial floor space from the Commercial Building Energy Consumption
Survey for the commercial sector \70\) and assumed to remain constant
over time. To estimate future trends in energy prices, DOE used
projections from the EIA's Annual Energy Outlook 2011 (AEO 2011). The
NOPR retains the same approach for determining electricity prices, and
used AEO 2013 to project electricity price trends.
---------------------------------------------------------------------------
\70\ U.S. Department of Energy Information Administration
(2003), Commercial Buildings Energy Consumption Survey, https://www.eia.gov/consumption/commercial/data/2003/pdf/a4.pdf.
---------------------------------------------------------------------------
IECA commented that the sector specific average electricity prices
do not account for differences across census regions where industrial
activity is concentrated. (IECA, No. 52 at p. 2) As noted above, the
industrial electricity price for each region is a weighted average
based on the number of industrial customers of each utility. Thus, the
prices reasonably account for concentration of industrial activity.
7. Lifetime
In the preliminary analysis, DOE estimated the mechanical lifetime
of electric motors in hours (i.e., the total number of hours an
electric motor operates throughout its lifetime), depending on its
horsepower size. DOE then developed Weibull distributions of mechanical
lifetimes. The lifetime in years for a sampled electric motor was then
calculated by dividing the sampled mechanical lifetime by the sampled
annual operating hours of the electric motor. This model produces a
negative correlation between annual hours of operation and electric
motor lifetime: Electric motors operated many hours per year are likely
to be retired sooner than electric motors that are used for only a few
hundred hours per year. DOE considered that electric motors of less
than 75-hp are most likely to be embedded in a piece of equipment
(i.e., an application). For such applications, DOE developed Weibull
distributions of application lifetimes expressed in years and compared
the sampled motor mechanical lifetime (in years) with the sampled
application lifetime. DOE assumed that the electric motor would be
retired at the earlier of the two ages. For the NOPR analysis, DOE
retained the same approach and revised some of the lifetime assumptions
based on additional information collected.
NEMA and WEG commented that the mechanical lifetime of agricultural
motors should be lower than in the commercial or industrial sectors due
to lower levels of maintenance performed in the field and the lighter
duty steel frame constructions of these motors. (Pub. Mtg. Tr., No. 58
at p. 253) The NOPR analysis estimates that the average motor lifetime
(across all sizes) for the agricultural sector to be 20 years.\71\ This
revised estimate translates into average mechanical lifetimes between
24,000 and 30,000 hours depending on the horsepower range, which is
lower than in the industrial sector.
---------------------------------------------------------------------------
\71\ Gallaher, M., Delhotal, K., & Petrusa, J. (2009).
Estimating the potential CO2 mitigation from agricultural
energy efficiency in the United States. Energy Efficiency, 2
(2):207-220.
---------------------------------------------------------------------------
For the NOPR, DOE collected sector-specific mechanical motor
lifetime information where available and revised the lifetime
assumptions where appropriate. For the industrial sector, DOE estimated
average mechanical lifetimes of 5, 15, and 20 years, depending on the
horsepower range (the values correspond to 43,800, 87,600, and 131,400
hours respectively). These values are higher than those used in the
preliminary analysis.
8. Discount Rate
The discount rate is the rate at which future expenditures are
discounted to estimate their present value. The cost of capital
commonly is 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 to the firm of equity and debt
financing. DOE uses the capital asset pricing model (CAPM) to calculate
the equity capital component, and financial data sources to calculate
the cost of debt financing.
For the NOPR, DOE estimated a statistical distribution of
industrial and commercial customer discount rates by calculating the
average cost of capital for the different types of electric motor
owners (e.g., chemical industry, food processing, and paper industry).
For the agricultural sector, DOE assumed similar discount rates as in
industry. More details regarding DOE's estimates of motor customer
discount rates are provided in chapter 8 of the NOPR TSD.
9. Base Case Market Efficiency Distributions
For the LCC analysis, DOE analyzed the considered motor efficiency
levels relative to a base case (i.e., the case without new or amended
energy efficiency standards). This requires an estimate of the
distribution of product efficiencies in the base case (i.e., what
consumers would have purchased in the compliance year in the absence of
new standards). DOE refers to this distribution of product energy
efficiencies as the base case efficiency distribution.
Data on motor sales by efficiency are not available. In the
preliminary analysis, DOE used the number of models meeting the
requirements of each efficiency level from six major manufacturers and
one distributor's catalog data to develop the base-case efficiency
distributions. The distribution is estimated separately for each
equipment class group and horsepower range and was assumed constant and
equal to 2012 throughout the analysis period (2015-2044).
For the NOPR, DOE retained the same approach to estimate the base
case efficiency distribution in 2012, but it updated the base case
efficiency distributions to account for the NOPR engineering analysis
(revised ELs) and for the update in the scope of electric motors
considered in the analysis. Beyond 2012, DOE assumed the efficiency
distributions for equipment class group 1 and 4 vary over time based on
historical data \72\ for the market penetration of NEMA Premium motors
within the market for integral alternating current induction motors.
The assumed trend is shown in chapter 10 of the NOPR TSD. For equipment
class group 2 and 3, which represent a very minor share of the market
(less
[[Page 73641]]
than 0.2 percent), DOE believes the overall trend in efficiency
improvement for the total integral AC induction motors may not be
representative, so DOE kept the base case efficiency distributions in
the compliance year equal to 2012 levels.
---------------------------------------------------------------------------
\72\ Robert Boteler, USA Motor Update 2009, Energy Efficient
Motor Driven Systems Conference (EEMODS) 2009.
---------------------------------------------------------------------------
Two interested parties commented on the base case efficiency
distributions. Regal-Beloit stated that the share of 1- to 5-horsepower
motors in equipment class 1 at CSL 0 in the base case distribution was
too low by at least one percentage point. (Pub. Mtg. Tr., No. 58 at p.
263) NEMA requested clarifications on how DOE derived its base case
efficiency distributions and commented that it would expect CSL 0 to
represent 60 percent of total units shipped when considering the
expanded scope as proposed by NEMA. (NEMA, No. 54 at p. 84) Neither
stakeholder, however, provided supporting data.
As mentioned previously, DOE developed the 2012 base case
efficiency distributions based on catalog information on the number of
models meeting the requirements of each efficiency level. For the NOPR,
DOE retained the same methodology and revised the catalog information
to account for the addition of brake motors and NEMA 56-frame size
enclosed electric motors in the analysis. DOE has no data to assess the
stakeholders' input on the base case efficiency distributions.
10. Compliance Date
Any amended standard for electric motors shall apply to electric
motors manufactured on or after a date which is five years after the
effective date of the previous amendment. (42 U.S.C. 6313(b)(4)) In
this case, the effective date of the previous amendment (established by
EISA in 2007) is December 19, 2010, and the compliance date of any
amended energy conservation standards for electric motors would be
December 19, 2015. In light of the proposal's attempt to establish
amended or new standards for currently regulated and unregulated
electric motor types, DOE has chosen to retain the same compliance date
for both the amended and new energy conservation standards to simplify
the requirements and to avoid any potential confusion from
manufacturers. The final rule for this rulemaking is scheduled to be
published in early 2014. DOE calculated the LCC and PBP for all end-
users as if each would purchase a new piece of equipment in the year
that compliance is required. As DOE notes elsewhere, DOE is interested
in comments regarding the feasibility of achieving compliance with this
proposed date.
11. Payback Period Inputs
The payback period is the amount of time it takes the consumer to
recover the additional installed cost of more efficient equipment,
compared to baseline equipment, through energy cost savings. Payback
periods are expressed in years. Payback periods that exceed the life of
the product mean that the increased total installed cost is not
recovered in reduced operating expenses.
The inputs to the PBP calculation are the total installed cost of
the product to the customer for each efficiency level and the average
annual operating expenditures for each efficiency level. The PBP
calculation uses the same inputs as the LCC analysis, except that
discount rates are not needed.
12. Rebuttable-Presumption Payback Period
EPCA establishes a rebuttable presumption that a standard is
economically justified if the Secretary finds that the additional cost
to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy (and, as applicable, water) savings during the first year
that the consumer will receive as a result of the standard, as
calculated under the test procedure in place for that standard. (42
U.S.C. 6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determines the value of the first year's energy savings by calculating
the quantity of those savings in accordance with the applicable DOE
test procedure, and multiplying that amount by the average energy price
forecast for the year in which compliance with the new or amended
standards would be required.
G. Shipments Analysis
DOE uses projections of product shipments to calculate the national
impacts of standards on energy use, NPV, and future manufacturer cash
flows. DOE develops shipment projections based on historical data and
an analysis of key market drivers for each product.
To populate the model with current data, DOE used data from a
market research report,\73\ confidential inputs from manufacturers,
trade associations, and other interested parties' responses to the
Request for Information (RFI) published in the Federal Register. 76 FR
17577 (March 30, 2011). DOE then used estimates of market distributions
to redistribute the shipments across pole configurations, horsepower,
and enclosures within each electric motor equipment class and also by
sector.
---------------------------------------------------------------------------
\73\ IMS Research (February 2012), The World Market for Low
Voltage Motors, 2012 Edition, Austin.
---------------------------------------------------------------------------
DOE's shipments projection assumes that electric motor sales are
driven by machinery production growth for equipment including motors.
DOE estimated that growth rates for total motor shipments correlate to
growth rates in fixed investment in equipment and structures including
motors, which is provided by the U.S. Bureau of Economic Analysis
(BEA).\74\ Projections of real gross domestic product (GDP) from AEO
2013 for 2015-2040 were used to project fixed investments in the
equipment and structures including motors. The current market
distributions are maintained over the forecast period.
---------------------------------------------------------------------------
\74\ Bureau of Economic Analysis (March 01, 2012), Private Fixed
Investment in Equipment and Software by Type and Private Fixed
Investment in Structures by Type. https://www.bea.gov/iTable/iTable.cfm?ReqID=12&step=1.
---------------------------------------------------------------------------
For the NOPR, with the expanded scope by horsepower, DOE estimates
total shipments in scope were 5.43 million units in 2011. This estimate
represents an increase compared to the shipments estimated in the
preliminary analysis because of the inclusion of integral brake motors
and of NEMA integral enclosed 56-frame motors.
For the preliminary analysis, DOE collected data on historical
series of shipment quantities and value for the 1990-2003 period, but
concluded that the data were not sufficient to estimate motor price
elasticity.\75\ Consequently, DOE assumed zero price elasticity for all
efficiency standards cases and did not estimate any impact of potential
standards levels on shipments. DOE requested stakeholder
recommendations on data sources to help better estimate the impacts of
increased efficiency levels on shipments.
---------------------------------------------------------------------------
\75\ Business Trend Analysts, The Motor and Generator Industry,
2002; U.S. Census Bureau (November 2004), Motors and Generators--
2003.MA335H(03)-1. https://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/; and U.S. Census
Bureau (August 2003), Motors and Generators--2002.MA335H(02)-1.
https://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/ma335h02.xls.
---------------------------------------------------------------------------
The Motor Coalition commented that higher equipment costs required
to achieve efficiency levels above CSL 2 (NEMA Premium) would encourage
the refurbishment of existing motors rather than their replacement by
new, more efficient motors, leading to reduced cost effective energy
savings at CSL 3. (Motor Coalition, No. 35 at p. 7)
DOE acknowledges that increased electric motor prices could affect
the
[[Page 73642]]
``repair versus replace'' decision, leading to the increased longevity
of existing electric motors and a decrease in shipments of newly-
manufactured energy-efficient electric motors. Considering the minimal
cost increase between EL 2 and EL 3 in the preliminary analysis
(approximately 3 percent for representative unit 1), DOE does not
believe it is reasonable to consider non-zero price elasticity when
calculating the standards-case shipments for levels above EL 2 and zero
price elasticity when calculating shipments for the standards case at
EL 2 of the preliminary analysis. For the above reasons, DOE retained
its shipments projections, which do not incorporate price elasticities,
for the NOPR. However, DOE also performed a sensitivity analysis that
demonstrates the impact of possible price elasticities on projected
shipments and the NIA results. See TSD appendix 10-C for more details
and results.
NEMA commented that shipments of imported motors might decrease if
higher efficiency levels are mandated. (NEMA, No. 54 at p. 29) NEMA,
however, provided no data in support of its view. DOE has reviewed
shipments information from market reports, the U.S. Census, as well as
market information provided by the Motor Coalition and has been unable
to obtain any data to assess the potential reduction in quantity of
imported motors due to standards and whether this would impact the
total number of motors shipped in the U.S.\76\ DOE's shipments
projection assumes that electric motor sales are driven by machinery
production growth for equipment including motors without distinction
between imported and domestic motors.
---------------------------------------------------------------------------
\76\ IMS Research (February 2012), The World Market for Low
Voltage Motors, 2012 Edition, Austin; Business Trend Analysts, The
Motor and Generator Industry, 2002; U.S. Census Bureau (November
2004), Motors and Generators--2003.MA335H(03)-1. https://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/; and U.S. Census Bureau (August 2003), Motors and
Generators--2002.MA335H(02)-1. https://www.census.gov/manufacturing/cir/historical_data/discontinued/ma335h/ma335h02.xls.
---------------------------------------------------------------------------
H. National Impact Analysis
The NIA assesses the national energy savings (NES) and the national
NPV of total customer costs and savings that would be expected to
result from new and amended standards at specific efficiency levels.
To make the analysis more accessible and transparent to all
interested parties, DOE used an MS Excel spreadsheet model to calculate
the energy savings and the national customer costs and savings from
each TSL.\77\ DOE used the NIA spreadsheet to calculate the NES and
NPV, based on the annual energy consumption and total installed cost
data from the energy use analysis and the LCC analysis. DOE forecasted
the lifetime energy savings, energy cost savings, equipment costs, and
NPV of customer benefits for each product class for equipment sold from
2015 through 2044. In addition, DOE analyzed scenarios that used inputs
from the AEO 2013 Low Economic Growth and High Economic Growth cases.
These cases have higher and lower energy price trends compared to the
reference case.
---------------------------------------------------------------------------
\77\ DOE understands that MS Excel is the most widely used
spreadsheet calculation tool in the United States and there is
general familiarity with its basic features. Thus, DOE's use of MS
Excel as the basis for the spreadsheet models provides interested
parties with access to the models within a familiar context. In
addition, the TSD and other documentation that DOE provides during
the rulemaking help explain the models and how to use them, and
interested parties can review DOE's analyses by changing various
input quantities within the spreadsheet.
---------------------------------------------------------------------------
DOE evaluated the impacts of potential new and amended standards
for electric motors by comparing base-case projections with standards-
case projections. The base-case projections characterize energy use and
customer costs for each equipment class in the absence of new and
amended energy conservation standards. DOE compared these projections
with projections characterizing the market for each equipment class if
DOE were to adopt new or amended standards at specific energy
efficiency levels (i.e., the standards cases) for that class.
Table IV.25 summarizes all the major preliminary analysis inputs to
the NIA and whether those inputs were revised for the NOPR.
Table IV.25--Inputs for the National Impact Analysis
----------------------------------------------------------------------------------------------------------------
Input Preliminary analysis description Changes for NOPR
----------------------------------------------------------------------------------------------------------------
Shipments...................... Annual shipments from shipments No change.
model.
Compliance date of standard.... Modeled used January 1, 2015..... December 19, 2015 (modeled as January 1,
2016).
Equipment Classes.............. Three separate equipment class Added one equipment class group for brake
groups for NEMA Design A and B motors.
motors, NEMA Design C motors,
and Fire Electric Pump Motors.
Base case efficiencies......... Constant efficiency from 2015 No change for Equipment Class 2 and 3. Added
through 2044. a trend for the efficiency distribution of
equipment class groups 1 and 4.
Standards case efficiencies.... Constant efficiency at the No change.
specified standard level from
2015 to 2044.
Annual energy consumption per Average unit energy use data are No change.
unit. calculated for each horsepower
rating and equipment class based
on inputs from the Energy use
analysis.
Total installed cost per unit.. Based on the MSP and weight data No change.
from the engineering, and then
scaled for different hp and
enclosure categories.
Electricity expense per unit... Annual energy use for each No change.
equipment class is multiplied by
the corresponding average energy
price.
Escalation of electricity AEO 2011 forecasts (to 2035) and Updated to AEO 2013.
prices. extrapolation for 2044 and
beyond.
Electricity site-to-source A time series conversion factor; No change.
conversion. includes electric generation,
transmission, and distribution
losses.
Discount rates................. 3% and 7% real................... No change.
Present year................... 2012............................. 2013.
----------------------------------------------------------------------------------------------------------------
[[Page 73643]]
1. Efficiency Trends
In the preliminary analysis, DOE did not include any change in base
case efficiency in its shipments and national energy savings models. As
explained in section IV.F, for equipment class groups 1 and 4, for the
NOPR, DOE presumed that the efficiency distributions in the base case
change over time. The projected share of 1 to 5 horsepower NEMA Premium
motors (EL 2) for equipment class group 1 grows from 36.6 percent to
45.5 percent over the analysis period, and for equipment class group 4,
it grows from 30.0 percent to 38.9 percent. For equipment class group 2
and 3, DOE assumed that the efficiency remains constant from 2015 to
2044.
In the standards cases, equipment with efficiency below the
standard levels ``roll up'' to the standard level in the compliance
year. Thereafter, for equipment class groups 1 and 4, DOE assumed that
the level immediately above the standard would show a similar increase
in market penetration as the NEMA Premium motors in the base case.
The presumed efficiency trends in the base case and standards cases
are described in chapter 10 of the NOPR TSD.
2. National Energy Savings
For each year in the forecast period, DOE calculates the lifetime
national energy savings for each standard level by multiplying the
shipments of electric motors affected by the energy conservation
standards by the per-unit lifetime annual energy savings. Cumulative
energy savings are the sum of the NES for all motors shipped during the
analysis period, 2015-2044.
DOE estimated energy consumption and savings based on site energy
and converted the electricity consumption and savings to primary energy
using annual conversion factors derived from the AEO 2013 version of
the NEMS. Cumulative energy savings are the sum of the NES for each
year over the timeframe of the analysis.
DOE has historically presented NES in terms of primary energy
savings. In response to the recommendations of a committee on ``Point-
of-Use and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency
Standards'' appointed by the National Academy of Science, DOE announced
its intention to use full-fuel-cycle (FFC) measures of energy use and
greenhouse gas and other emissions in the national impact analyses and
emissions analyses included in future energy conservation standards
rulemakings. 76 FR 51281 (August 18, 2011). 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 EIA's National Energy Modeling System (NEMS).
After evaluating both models and the approaches discussed in the August
18, 2011 notice, DOE published a statement of amended policy in the
Federal Register in which DOE explained its determination that NEMS is
a more appropriate tool for this specific use. 77 FR 49701 (August 17,
2012). Therefore, DOE is using NEMS to conduct FFC analyses. The
approach used for today's NOPR, and the FFC multipliers that were
applied, are described in appendix 10-C of the TSD.
3. Equipment Price Forecast
As noted in section IV.F.2, DOE assumed no change in electric motor
prices over the 2015-2044 period. In addition, DOE conducted a
sensitivity analysis using alternative price trends. DOE developed one
forecast in which prices decline after 2011, and one in which prices
rise. These price trends, and the NPV results from the associated
sensitivity cases, are described in appendix 10-B of the NOPR TSD.
4. Net Present Value of Customer Benefit
The inputs for determining the NPV of the total costs and benefits
experienced by consumers of considered equipment are: (1) Total annual
installed cost; (2) total annual savings in operating costs; and (3) a
discount factor. DOE calculates the lifetime net savings for motors
shipped each year as the difference between the base case and each
standards case in total lifetime savings in lifetime operating costs
and total lifetime increases in installed costs. DOE calculates
lifetime operating cost savings over the life of each motor shipped
during the forecast period.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. DOE
estimates the NPV using both a 3-percent and a 7-percent real discount
rate, in accordance with guidance provided by the Office of Management
and Budget (OMB) to Federal agencies on the development of regulatory
analysis.\78\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
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\78\ OMB Circular A-4, section E (Sept. 17, 2003). https://www.whitehouse.gov/omb/circulars_a004_a-4.
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I. Consumer Subgroup Analysis
In analyzing the potential impacts of new or amended standards, DOE
evaluates impacts on identifiable groups (i.e., subgroups) of customers
that may be disproportionately affected by a national standard. For the
NOPR, DOE evaluated impacts on various subgroups using the LCC
spreadsheet model.
The customer subgroup analysis is discussed in detail in chapter 11
of the TSD.
J. Manufacturer Impact Analysis
1. Overview
DOE conducted an MIA for electric motors to estimate the financial
impact of proposed new and amended energy conservation standards on
manufacturers of covered electric motors. The MIA has both quantitative
and qualitative aspects. The quantitative part of the MIA primarily
relies on the GRIM, an industry cash flow model customized for electric
motors covered in this rulemaking. The key GRIM inputs are data on the
industry cost structure, equipment costs, shipments, and assumptions
about markups and conversion expenditures. The key MIA output is INPV.
DOE used the GRIM to calculate cash flows using standard accounting
principles and to compare changes in INPV between a base case and
various TSLs (the standards case). The difference in INPV between the
base and standards cases represents the financial impact of new and
amended standards on manufacturers of covered electric motors.
Different sets of assumptions (scenarios) produce different INPV
results. The qualitative part of the MIA addresses factors such as
manufacturing capacity; characteristics of, and impacts on, any
particular sub-group of manufacturers; and impacts on competition.
DOE conducted the MIA for this rulemaking in three phases. In the
first phase DOE prepared an industry characterization based on the
market and technology assessment, preliminary manufacturer interviews,
and publicly available information. In the second phase, DOE estimated
industry cash flows in the GRIM using industry financial parameters
derived in the first
[[Page 73644]]
phase and the shipment scenario used in the NIA. In the third phase,
DOE conducted structured, detailed interviews with a variety of
manufacturers that represent more than 75-percent of domestic electric
motors sales covered by this rulemaking. During these interviews, DOE
discussed engineering, manufacturing, procurement, and financial topics
specific to each company, and obtained each manufacturer's view of the
electric motor industry as a whole. The interviews provided valuable
information that DOE used to evaluate the impacts of new and amended
standards on manufacturers' cash flows, manufacturing capacities, and
employment levels. See section IV.J.4 of this NOPR for a description of
the key issues manufacturers raised during the interviews.
During the third phase, DOE also used the results of the industry
characterization analysis in the first phase and feedback from
manufacturer interviews to group manufacturers that exhibit similar
production and cost structure characteristics. DOE identified one sub-
group for a separate impact analysis--small business manufacturers--
using the small business employee threshold published by the Small
Business Administration (SBA). This threshold includes all employees in
a business' parent company and any other subsidiaries. Based on this
classification, DOE identified 13 electric motor manufacturers that
qualify as small businesses.
The complete MIA is presented in chapter 12 of the NOPR TSD.
2. GRIM Analysis and Key Inputs
DOE uses the GRIM to quantify the changes in cash flow over time
due to a standard. These changes in cash flow result in either a higher
or lower INPV for the standards case compared to the base case, the
case where a standard is not set. The GRIM analysis uses a standard
annual cash flow analysis that incorporates manufacturer costs,
markups, shipments, and industry financial information as inputs. It
then models changes in costs, investments, and manufacturer margins
that result from new and amended energy conservation standards. The
GRIM spreadsheet uses the inputs to calculate a series of annual cash
flows beginning with the base year of the analysis, 2013, and
continuing to 2044. DOE computes INPVs by summing the stream of annual
discounted cash flows during this analysis period. DOE used a real
discount rate of 9.1 percent for electric motor manufacturers. The
discount rate estimates were derived from industry corporate annual
reports to the Securities and Exchange Commission (SEC 10-Ks) and then
modified according to feedback during manufacturer interviews. Many
inputs into the GRIM come from the engineering analysis, the NIA,
manufacturer interviews, and other research conducted during the MIA.
The major GRIM inputs are described in detail in the sections below.
a. Product and Capital Conversion Costs
DOE expects new and amended energy conservation standards to cause
manufacturers to incur one-time conversion costs to bring their
production facilities and product designs into compliance with new and
amended standards. For the MIA, DOE classified these one-time
conversion costs into two major groups: (1) Product conversion costs
and (2) capital conversion costs. Product conversion costs are one-time
investments in research, development, testing, marketing, and other
non-capitalized costs necessary to make product designs comply with new
and amended standards. Capital conversion costs are one-time
investments in property, plant, and equipment necessary to adapt or
change existing production facilities such that new product designs can
be fabricated and assembled.
DOE calculated the product and capital conversion costs using both
a top-down approach and a bottom-up approach based on feedback from
manufacturers during manufacturer interviews and manufacturer submitted
comments. DOE then adjusted these conversion costs if there were any
discrepancies in the final costs using the two methods to arrive at a
final product and capital conversion cost estimate for each
representative unit at each EL.
During manufacturer interviews, DOE asked manufacturers for their
estimated total product and capital conversion costs needed to produce
electric motors at specific ELs. To arrive at top-down industry wide
product and capital conversion cost estimates for each representative
unit at each EL, DOE calculated a market share weighted average value
for product and capital conversion costs based on the data submitted
during interviews and the market share of the interviewed
manufacturers.
DOE also calculated bottom-up conversion costs based on
manufacturer input on the types of costs and the dollar amounts
necessary to convert a single electric motor frame size to each EL.
Some of the types of capital conversion costs manufacturers identified
were the purchase of lamination die sets, winding machines, frame
casts, and assembly equipment as well as other retooling costs. The two
main types of product conversion costs manufacturers shared with DOE
during interviews were number of engineer hours necessary to re-
engineer frames to meet higher efficiency standards and the testing and
certification costs to comply with higher efficiency standards. DOE
then took average values (i.e. costs or number of hours) based on the
range of responses given by manufacturers for each product and capital
conversion costs necessary for a manufacturer to increase the
efficiency of one frame size to a specific EL. DOE multiplied the
conversion costs associated with manufacturing a single frame size at
each EL by the number of frames each interviewed manufacturer produces.
DOE finally scaled this number based on the market share of the
manufacturers DOE interviewed, to arrive at industry wide bottom-up
product and capital conversion cost estimates for each representative
unit at each EL. The bottom-up conversion costs estimates DOE created
were consistent with the manufacturer top down estimates provided, so
DOE used the bottom-up conversion cost estimates as the final values
for each representative unit in the MIA.
In written comments and during manufacturer interviews, electric
motor manufacturers stated there would be very large product and
capital conversion costs associated with ELs above NEMA Premium,
especially for any ELs that require manufacturers to switch to die-cast
copper rotors. Manufacturers addressed the difficulties associated with
using copper die-cast rotors and the uncertainty of a standard that
requires manufacturers to produce electric motors on a commercial level
for all horsepower ranges using this technology. NEMA stated that
switching to die-cast copper rotors would cost each manufacturer
approximately $80 million in retooling costs and approximately $68
million to redesign, test and certify electric motors at these ELs.
(NEMA, No. 54 at p. 11) NEMA stated that significant conversion costs
associated with any EL above NEMA Premium exist even if die-cast copper
rotors are not used. Several manufacturers during interviews and in
comments stated they would need to devote significant engineering time
to redesign their entire production line to comply with ELs that are
just one NEMA band higher than NEMA Premium. NEMA also stated that
testing and certifying electric motors to ELs
[[Page 73645]]
above NEMA Premium would be a significant cost to each manufacturer,
since each manufacturer could have thousands or hundreds of thousands
of unique electric motor specifications they would need to certify.
(NEMA, No. 54 at p. 4) DOE took these submitted comments into account
when developing the industry product and capital conversion costs. The
final product and capital conversion cost estimates were in the range
of estimates submitted by NEMA.
See chapter 12 of the TSD for a complete description of DOE's
assumptions for the product and capital conversion costs.
b. Manufacturer Production Costs
Manufacturing a more efficient electric motor is typically more
expensive than manufacturing a baseline product due to the use of more
costly materials and components. The higher MPCs for these more
efficient equipment can affect the revenue, gross margin, and cash
flows of electric motor manufacturers.
DOE developed the MPCs for the representative units at each EL
analyzed in one of two ways: (1) DOE purchased, tested and then tore
down a motor to create a bill of materials (BOM) for the motor; and (2)
DOE created a BOM based on a computer software model for a specific
motor that complies with the associated efficiency level. This second
approach was used when DOE was unable to find and purchase a motor that
matched the efficiency criteria for a specific representative unit.
Once DOE created a BOM for a specific motor, either by tear downs or
software modeling, DOE then estimated the labor hours and the
associated scrap and overhead costs necessary to produce a motor with
that BOM. DOE was then able to create an aggregated MPC based on the
material costs from the BOM and the associated scrap costs, the labor
costs based on an average labor rate and the labor hours necessary to
manufacture the motor, and the overhead costs, including depreciation,
based on a markup applied to the material, labor, and scrap costs based
on the materials used.
DOE created a BOM from tear downs for 15 of the 21 analyzed
representative unit ELs and applied these BOM data to create ELs for
certain representative units. The representative unit ELs based on tear
downs include: All five ELs for the Design B, 5-horsepower
representative unit; the baseline and ELs 1, 2, and 3 for the Design B,
30-horsepower and 75-horsepower representative units; and the baseline
for the Design C, 5-horsepower and 50-horsepower representative units.
DOE created a BOM based on a computer software model for the remaining
six analyzed representative unit ELs: EL 4 for the Design B, 30-
horsepower and 75-horsepower representative units; and ELs 1 and 2 for
the Design C, 5-horsepower and 50-horsepower representative units.
Due to the very large product and capital conversion costs
manufacturers would face if standards forced manufacturers to produce
motors above NEMA Premium ELs, DOE decided to include the product and
capital conversion costs as a portion of the MPCs for all ELs above
NEMA Premium. DOE applied a per unit adder, which was a flat percentage
of the MPC at NEMA Premium, for all MPCs above NEMA Premium. For a
complete description of MPCs and the inclusion of manufacturer
conversion costs into the MPC see the engineering analysis discussion
in section IV.C of this NOPR.
c. Shipment Forecast
INPV, the key GRIM output, depends on industry revenue, which in
turn, depends on the quantity and prices of electric motors shipped in
each year of the analysis period. Industry revenue calculations require
forecasts of: (1) Total annual shipment volume; (2) the distribution of
shipments across analyzed representative units (because prices vary by
representative unit); and, (3) the distribution of shipments across
efficiencies (because prices vary with efficiency).
In the NIA, DOE estimated the total number of electric motor
shipments by year for the analysis period. The NIA projects electric
motor shipments to generally increase over time. This is consistent
with the estimates manufacturers revealed to DOE during manufacturer
interviews. The NIA then estimated the percentage of shipments assigned
to each ECG. DOE further estimated the percentage of shipments by
horsepower rating, pole configuration, and enclosure type within each
ECG. For the NIA, the shipment distribution across ECG and the shipment
distribution across horsepower rating, pole configuration, and
enclosure type do not change on a percentage basis over time. Nor does
the shipment distribution across ECGs or across horsepower rating, pole
configuration, and enclosure type change on a percentage basis due to
an energy conservation standard (e.g. the number of shipments of Design
C, 1 horsepower, 4 pole, open motor are the same in the base case as in
the standards case). Finally, the NIA estimated a distribution of
shipments across ELs (an efficiency distribution), for each horsepower
range within each ECG. As described in further detail below, the
efficiency distributions for ECG 1 and ECG 4 motors become more energy
efficient over time in the base case, while the efficiency
distributions for ECG 2 and ECG 3 do not change on a percentage basis
over time (i.e., for ECG 2 and ECG 3 motors, the efficiency
distributions at the beginning of the analysis period are the same as
the efficiency distributions at the end of the analysis period). DOE
also assumed the total volume of shipments does not decrease due to
energy conservation standards, so total shipments are the same in the
base case as in the standards case.
For the NIA, DOE modeled a ``shift'' shipment scenario for ECG 1
and ECG 4 motors and a ``roll-up'' shipment scenario for ECG 2 and ECG
3 motors. In the standards case of the ``shift'' shipment scenario,
shipments continue to become more efficient after a standard is set--in
this case, immediately after the standards go into effect, all
shipments below the selected TSL are brought up to meet that TSL.
However, motors at or above the selected TSL migrate to even higher
efficiency levels and continue to do so over time. In contrast, in the
standards case of the ``roll-up'' shipment scenario, when a TSL is
selected to become the new energy conservation standard, all shipments
that fall below that selected TSL roll-up to the selected TSL.
Therefore, the shipments that are at or above the selected TSL remain
unchanged in the standards case of the ``roll-up'' shipment scenario
compared to the base case. For the ``roll-up'' shipment scenario, the
only difference in the efficiency distribution between the standards
case and the base case is that in the standards case all shipments
falling below the selected TSL in the base case are now at the selected
TSL in the standards case.
While the shipments from the NIA are broken out into a total number
of motor shipments for each ECG, horsepower rating, pole configuration,
and enclosure type, the MIA consolidates the number of motor shipments
into the representative units for each ECG. For example, the Design B,
5-horsepower, 4-pole, enclosed motor was the representative unit for
all Design A and B motors between 1 and 10-horsepower regardless of the
number of poles or enclosure type. So in the MIA DOE treated all ECG 1
(Design A and B) motor shipments between 1 and 10-horsepower as
shipments of the Design B, 5-horsepower representative unit; all ECG 1
motor shipments between 15-
[[Page 73646]]
and 50-horsepower as shipments of the Design B, 30-horsepower
representative unit; and all ECG 1 motor shipments between 60- and 500-
horsepower as shipments of the Design B, 75-horsepower representative
unit. For ECG 2 (Design C) motors, ECG 3 (fire pump) motors, and ECG 4
(brake) motors the MIA consolidated shipments in a similar manner,
treating all shipments in the representative units' horsepower range as
shipments of that representative unit.
See the shipment analysis, chapter 9, of this NOPR TSD for
additional details.
d. Markup Scenarios
As discussed in the MPC section above, the MPCs for the
representative units are the factory costs of electric motor
manufacturers; these costs include material, direct labor, overhead,
depreciation, and any extraordinary conversion cost recovery. The MSP
is the price received by electric motor manufacturers from their direct
customer, typically either an OEM or a distributor. The MSP is not the
cost the end-user pays for the electric motor since there are typically
multiple sales along the distribution chain and various markups applied
to each sale. The MSP equals the MPC multiplied by the manufacturer
markup. The manufacturer markup covers all the electric motor
manufacturer's non-production costs (i.e., selling, general and
administrative expenses (SG&A), normal R&D, and interest, etc.) and
profit. Total industry revenue for electric motor manufacturers equals
the MSPs at each EL for each representative unit multiplied by the
number of shipments at that EL.
Modifying these manufacturer markups in the standards case yields a
different set of impacts on manufacturers than in the base case. For
the MIA, DOE modeled three standards case markup scenarios to represent
the uncertainty regarding the potential impacts on prices and
profitability for manufacturers following the implementation of new and
amended energy conservation standards: (1) A flat markup scenario, (2)
a preservation of operating profit scenario, and (3) a two-tiered
markup scenario. These scenarios lead to different markup values,
which, when applied to the inputted MPCs, result in varying revenue and
cash flow impacts on manufacturers.
The flat markup scenario assumed that the cost of goods sold for
each product is marked up by a flat percentage to cover SG&A expenses,
R&D expenses, interest expenses, and profit. There were two values used
for the flat markup, a 1.37 markup for high volume representative units
and a 1.45 markup for low volume representative units. The 1.37 markup
was used for the Design B, 5-horsepower representative unit; the Design
C, 5-horsepower representative unit; the fire pump, 5-horsepower
representative unit; and the brake, 5-horsepower representative unit.
The 1.45 markup is used for the Design B, 30-horsepower and 75-
horsepower representative units; the Design C, 50 horsepower
representative unit; the fire pump, 30-horsepower and 75-horsepower
representative units; and the brake, 30-horsepower and 75-horsepower
representative units. This scenario represents the upper bound of
industry profitability in the standards case because manufacturers are
able to fully pass through additional costs due to standards to their
customers. To derive the flat markup percentages, DOE examined the SEC
10-Ks of publicly traded electric motor manufacturers to estimate the
industry average gross margin percentage. DOE then used that estimate
along with the flat manufacturer markups used in the small electric
motors rulemaking at 75 FR 10874 (March 9, 2010), since several of the
small electric motor manufacturers are also manufacturers of electric
motors covered in this rulemaking, to create a final estimate of the
flat markups used for electric motors covered in this rulemaking.
DOE included an alternative markup scenario, the preservation of
operating profit markup, because manufacturers stated that they do not
expect to be able to markup the full cost of production given the
highly competitive market, in the standards case. The preservation of
operating profit markup scenario assumes that manufacturers are able to
maintain only the base case total operating profit in absolute dollars
in the standards case, despite higher product costs and investment. The
base case total operating profit is derived from marking up the cost of
goods sold for each product by the flat markup described above. In the
standards case for the preservation of operating profit markup
scenario, DOE adjusted the manufacturer markups in the GRIM at each TSL
to yield approximately the same earnings before interest and taxes in
the standards case in the year after the compliance date of the new and
amended standards as in the base case. Under this scenario, while
manufacturers are not able to yield additional operating profit from
higher production costs and the investments that are required to comply
with new and amended energy conservation standards, they are able to
maintain the same operating profit in the standards case that was
earned in the base case.
DOE modeled a third profitability scenario, a two-tiered markup
scenario. During interviews, several manufacturers stated they offer
two tiers of motor lines that are differentiated, in part, by
efficiency level. For example, several manufacturers offer Design B
motors that meet, and in some cases exceed, NEMA Premium levels. Motors
that exceed these levels typically command higher prices over NEMA
Premium level motors at identical horsepower levels. These
manufacturers suggested that the premium currently earned by the higher
efficiency tiers would erode as new and amended standards are set at
higher efficiency levels, which would harm profitability. To model this
effect, DOE used information from manufacturers to estimate the higher
and lower markups for electric motors under a two-tier pricing strategy
in the base case. In the standards case, DOE modeled the situation in
which product efficiencies offered by a manufacturer are altered due to
standards. This change reduces the markup of higher efficiency
equipment as they become the new baseline caused by the energy
conservation standard. The change in markup is based on manufacturer
statements made during interviews and on DOE's understanding of
industry pricing.
The preservation of operating profit and two-tiered markup
scenarios represent the lower bound of industry profitability in the
standards case because manufacturers are not able to fully pass through
the additional costs due to standards, as manufacturers are able to do
in the flat markup scenario. Therefore, manufacturers earn less revenue
in the preservation of operating profit and two-tiered markup scenarios
than they do in the flat markup scenario.
3. Discussion of Comments
During the August 2012 preliminary analysis public meeting,
interested parties commented on the assumptions and results of the
preliminary analysis TSD. Oral and written comments addressed several
topics, including the scope of coverage, conversion costs, enforcement
of standards, and the potential increase in the motor refurbishment
market. DOE addresses these comments below.
a. Scope of Coverage
SEW-Eurodrive expressed concern about establishing energy
conservation standards for integral gearmotors. SEW-Eurodrive stated
that manufacturers
[[Page 73647]]
would have to review and ensure the compatibility between the motor and
the gearbox for all new integral gearmotor designs. Setting standards
for these motors, in its view, may cause manufacturers to review
potentially millions of motor-gear box combinations. SEW-Eurodrive also
stated that since integral gearmotors comprise a system whose overall
efficiency is limited by the low efficiency of the mating gearing, an
increase in the efficiency of the motor alone would have a very small
effect on the overall system efficiency. (SEW-Eurodrive, No. 53 at p.
3) DOE believes that these integral gearmotors can be tested by
removing the gearbox and simply testing the partial motor in accordance
with the partial motor test procedure proposed at 78 FR 38455 (June 26,
2013). This approach would allow integral gearmotor motor manufacturers
to test and certify the electric motors and not every combination of
electric motor and gearbox.
b. Conversion Costs
NEMA made a few comments regarding the potential difficulties and
costs associated with increasing energy conservation standards to
efficiency levels above NEMA Premium. First, NEMA stated that DOE
should consider the current difficulties that manufacturers from IEC
countries are having when meeting the efficiency levels under NEMA MG 1
Table 12-12. NEMA stated these manufacturers already face difficulties
due to the limits of an electric motor frame size and stack length, as
these limits pose physical constraints to higher efficiency levels.
Moreover, such limits to IEC frame size and stack length are comparable
to what manufacturers of NEMA frame motors would face if required
efficiency levels were increased above current NEMA Premium efficiency
levels. (NEMA, No. 54 at p. 84) NEMA did not provide any cost data, in
engineering time or dollars, that these manufacturers were faced with
regarding their compliance with NEMA MG 1 Table 12-12 efficiency
levels.
NEMA went on to give estimates for the conversion costs associated
with manufacturers producing motors above NEMA Premium efficiency
levels. NEMA stated that it would cost each manufacturer approximately
$80 million in retooling and $68 million in reengineering, testing and
prototyping to switch from currently used materials to die-cast copper
rotor production. NEMA also stated there are other costs not directly
related to the die-casting process manufacturers would incur, if
standards required copper rotor technology. For example, NEMA noted
that there are additional costs associated with redesigning the rotor
and stator to maintain compliance with NEMA MG 1 performance
requirements. NEMA also provided DOE with a few of the major costs
placed on the manufacturers if energy conservation standards exceeded
NEMA Premium efficiency levels. NEMA said manufacturers would incur
significant costs due to retooling slot insulators, automatic winding
machines, and progressive lamination stamping dies--the last of which
can cost between $500,000 and $750,000 per set. Manufacturers would
also need to reengineer potentially 100,000 to 200,000 specifications
per manufacturer to comply with standards above NEMA Premium levels.
(NEMA, No. 54 at p. 11)
DOE took these difficulties and costs that could be placed on
manufacturers into consideration when creating the conversion costs of
standards above NEMA Premium efficiency levels. DOE also recognizes the
magnitude of the conversion costs on the industry at efficiency levels
above NEMA Premium and this was one of the main reasons DOE included a
portion of the conversion costs in the MPC for efficiency levels above
NEMA Premium. DOE believes it is likely that motor manufacturers would
attempt to recover these large one-time extraordinary conversion costs
at standards above NEMA Premium through a variable cost increase in the
MPCs of electric motors sold by manufacturers.
c. Enforcement of Standards
NEMA stated that large domestic manufacturers could be adversely
impacted by higher energy conservation standards if DOE does not
strictly enforce those new and amended standards, especially on
imported machinery with embedded motors. NEMA commented that domestic
manufacturers are currently competing with imported goods containing
electric motors that are below current motor standards. This practice
puts compliant motor manufacturers at a disadvantage because the
machinery containing a non-compliant motor is often sold at a lower
cost than machinery with a compliant motor. (NEMA, No. 54 at p. 11) DOE
recognizes the need to enforce any energy conservation standard
established for motors manufactured alone or as a component of another
piece of equipment to ensure that all manufacturers are operating on a
level playing field and to realize the actual reduction in energy
consumption from these standards.
d. Motor Refurbishment
NEMA commented that if electric motors had to be redesigned to
achieve higher energy conservation standards potential new motor
customers may be forced to rewind older, less efficient motors because
the longer or larger frame sizes that could be required to satisfy more
stringent efficiency standards might not fit as drop-in replacements
for existing equipment. (NEMA, No. 54 at p. 10) DOE agrees that
adopting higher energy conservation standards for electric motors may
force motor manufacturers to increase the length and/or the diameter of
the frame. Such increase in motor frame size may cause some machinery
using electric motors to be incompatible with previous electric motor
designs. DOE requested comment on the quantitative impacts this could
have on the electric motor and OEM markets but did not receive any
quantitative responses regarding this issue. DOE is aware this could be
a possible issue at the ELs above NEMA Premium, but does not consider
this to be an issue at ELs that meet or are below NEMA Premium, since
the majority of the electric motors used in existing equipment should
already be at NEMA Premium efficiency levels. Therefore, based on data
available at this time, DOE does not believe that motor refurbishment
is likely to act as a barrier to the efficiency levels proposed in
today's NOPR.
4. Manufacturer Interviews
DOE conducted additional interviews with manufacturers following
the preliminary analysis in preparation for the NOPR analysis. In these
interviews, DOE asked manufacturers to describe their major concerns
with this rulemaking. The following section describes the key issues
identified by manufacturers during these interviews.
a. Efficiency Levels above NEMA Premium
During these interviews, several manufacturers were concerned with
the difficulties associated with increasing motor efficiency levels
above NEMA Premium. Manufacturers stated that even increasing the
efficiency of motors to one band above NEMA Premium would require each
manufacturer to make a significant capital investment to retool their
entire production line. It would also require manufacturers to
completely redesign almost every motor configuration offered, which
could take several years of engineering time.
According to manufacturers, another potential problem with setting
standards above NEMA Premium is that this
[[Page 73648]]
would misalign U.S. electric motor standards with global motor
standards (e.g., IEC motor standards). They noted that over the past
few decades, there has been an effort to harmonize global motor
standards that setting new U.S. electric motor standards at a level
exceeding the NEMA Premium level would cause U.S. electric motor
markets to be out of synchronization with the rest of the world's
efficiency standards.
Several manufacturers also commented they believe any standard
requiring die-casting copper rotors is infeasible. One main concern
manufacturers have regarding copper is that not only has the price of
copper significantly increased over the past several years, there has
been tremendous volatility in the price as well. Manufacturers worry
that if standards required manufacturers to use copper rotors, they
would be subject to this volatile copper market. Manufacturers also
noted that motor efficiency standards requiring copper rotors for all
electric motors would likely increase the price of copper due to the
increase in demand from the motors industry.
Another key concern that manufacturers have regarding standards
that require using copper rotors is that copper has a much higher
melting temperature than aluminum, and the pressure required to die-
cast copper is much higher than aluminum. They contend that there is a
much greater chance that a significant accident or injury to their
employees could occur if manufacturers were required to produce copper
rotors rather than aluminum rotors.
Lastly, several manufacturers stated they would not be able to
produce copper die-cast rotors in-house and would have to outsource
this production. Manufacturers stated that if the entire motor industry
had to outsource their rotor production as a result of standards that
required the use of die-cast copper rotors, there would be significant
supply chain problems in the motor manufacturing process. Manufacturers
emphasized during interviews that the capacity to produce copper rotors
on a large commercial scale does not exist and would be very difficult
to implement in even a three-year time period.
Overall, manufacturers are very concerned if any electric motor
standard required motor efficiency levels beyond NEMA Premium,
especially if those efficiency levels required the use of copper rotor
technology. According to manufacturers, efficiency levels beyond NEMA
Premium would require a significant level of investment from all
electric motor manufacturers and would cause the U.S. to be out of sync
with the electric motor standards around the world. If standards
required the use of copper rotors, manufacturers would experience
further difficulties due to the potential increase in copper prices and
the volatility of the copper market, as well as the potential safety
concerns regarding the higher melting temperature of copper than
aluminum.
b. Increase in Equipment Repairs
Manufacturers have stated that as energy conservation standards
increase customers are more likely to rewind old, less efficient
motors, as opposed to purchasing newer more efficient and compliant
motors. Therefore, if motor standards significantly increase the price
of motors, manufacturers believe rewinding older motors might become a
more attractive option for some customers. These customers would in
turn be using more energy than if they simply purchased a currently
compliant motor, since rewound motors typically do not operate at their
original efficiency level after being rewound. Manufacturers believe
that DOE must take the potential consumer rewinding decision into
account when deciding on an electric motors standard.
c. Enforcement
Manufacturers have stated that one of their biggest concerns with
additional energy conservation standards is the lack of enforcement of
current electric motor standards. In general, domestic manufacturers
have stated they comply with the current electric motor regulations and
will continue to comply with any future standards. However, these
manufacturers believe that there are several foreign motor
manufacturers that do not comply with the current electric motor
regulations and will not comply with any future standards if the
efficiency standards are increased. This would cause compliant
manufacturers to be placed at a competitive disadvantage, since
complying with any increased efficiency standards will be very costly.
Some domestic manufacturers believe the most cost effective way to
reduce energy consumption of electric motors is to more strictly
enforce the existing electric motor standards rather than increase the
efficiency standards of electric motors.
K. Emissions Analysis
In the emissions analysis, DOE estimated 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 electric motors. In
addition, DOE estimates 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 full-fuel-cycle
(FFC). In accordance with DOE's FFC Statement of Policy (76 FR 51282
(August 18, 2011) as amended at 77 FR 49701 (August 17, 2012)), the FFC
analysis includes impacts on emissions of methane (CH4) and
nitrous oxide (N2O, both of which are recognized as
greenhouse gases.
DOE conducted the emissions analysis using emissions factors that
were derived from data in the Energy Information Agency's (EIA's)
Annual Energy Outlook 2013 (AEO 2013), supplemented by data from other
sources. DOE developed separate emissions factors for power sector
emissions and upstream emissions. The method that DOE used to derive
emissions factors is described in chapter 13 of the NOPR TSD.
EIA prepares the Annual Energy Outlook using the National Energy
Modeling System (NEMS). Each annual version of NEMS incorporates the
projected impacts of existing air quality regulations on emissions. AEO
2013 generally represents current legislation and environmental
regulations, including recent government actions, for which
implementing regulations were available as of December 31, 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 (DC). SO2 emissions from 28 eastern
states and DC 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). On August 21, 2012, the DC
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.
[[Page 73649]]
21, 2012). The court ordered EPA to continue administering CAIR. The
AEO 2013 emissions factors used for today's NOPR assumes that CAIR
remains a binding regulation through 2040.
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.
77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA established a
standard for hydrogen chloride 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
2013 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 established by CAIR, 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.
CAIR established a cap on NOX emissions in 28 eastern
States and the District of Columbia. Energy conservation standards are
expected to have little effect on NOX emissions in those
States covered by CAIR 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 the caps, so DOE estimated NOX
emissions reductions from the standards considered in today's NOPR 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. DOE estimated mercury
emissions reduction using emissions factors based on AEO 2013, which
incorporates the MATS.
NEMA commented that DOE should consider emissions related to all
aspects involved in the production of higher efficiency motors. (NEMA,
No. 54 at p. 31) In response, DOE notes that EPCA directs DOE to
consider the total projected amount of energy, or as applicable, water,
savings likely to result directly from the imposition of the standard
when determining whether a standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i)(III) and 6316(a)) DOE interprets this to
include energy used in the generation, transmission, and distribution
of fuels used by appliances or equipment. In addition, DOE is using the
full-fuel-cycle measure, which includes the energy consumed in
extracting, processing, and transporting primary fuels. DOE's current
accounting of primary energy savings and the full-fuel-cycle measure
are directly linked to the energy used by appliances or equipment. DOE
believes that energy used in manufacturing of appliances or equipment
falls outside the boundaries of ``directly'' as intended by EPCA. Thus,
DOE did not consider such energy use and air emissions in the NIA or in
the emissions analysis.
L. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of this proposed rule, DOE considered
the estimated monetary benefits from the reduced emissions of
CO2 and NOX that are expected to result from each
of the TSLs considered. In order to make this calculation similar to
the calculation of the NPV of consumer benefit, DOE considered the
reduced emissions expected to result over the lifetime of equipment
shipped in the forecast period for each TSL. This section summarizes
the basis for the monetary values used for each of these emissions and
presents the values considered in this rulemaking.
For today's NOPR, DOE is relying on a set of values for the social
cost of carbon (SCC) that was developed by an interagency process. A
summary of the basis for these values is provided below, and a more
detailed description of the methodologies used is provided as an
appendix to chapter 14 of the NOPR TSD.
1. Social Cost of Carbon
The SCC is an estimate of the monetized damages associated with an
incremental increase in carbon emissions in a given year. It is
intended to include (but is not limited to) changes in net agricultural
productivity, human health, property damages from increased flood risk,
and the value of ecosystem services. Estimates of the SCC are provided
in dollars per metric ton of carbon dioxide. A domestic SCC value is
meant to reflect the value of damages in the United States resulting
from a unit change in carbon dioxide emissions, while a global SCC
value is meant to reflect the value of damages worldwide.
Under section 1(b)(6) of Executive Order 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993), agencies must, to
the extent permitted by law, assess both the costs and the benefits of
the intended regulation and, recognizing that some costs and benefits
are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation
justify its costs. The purpose of the SCC estimates presented here is
to allow agencies to incorporate the monetized social benefits of
reducing CO2 emissions into cost-benefit analyses of
regulatory actions that have small, or ``marginal,'' impacts on
cumulative global emissions. The estimates are presented with an
acknowledgement of the many uncertainties involved and with a clear
understanding that they should be updated over time to reflect
increasing knowledge of the science and economics of climate impacts.
As part of the interagency process that developed the SCC
estimates, technical experts from numerous agencies met on a regular
basis to consider public comments, explore the technical literature in
relevant fields, and discuss key model inputs and assumptions. The main
objective of this process was to develop a range of SCC values using a
defensible set of input assumptions grounded in the existing scientific
and economic literatures. In this way, key uncertainties and model
differences transparently and consistently inform the range of SCC
estimates used in the rulemaking process.
[[Page 73650]]
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the incremental economic impacts of
carbon dioxide emissions, the analyst faces a number of serious
challenges. A recent report from the National Research Council points
out that any assessment will suffer from uncertainty, speculation, and
lack of information about: (1) Future emissions of greenhouse gases;
(2) the effects of past and future emissions on the climate system; (3)
the impact of changes in climate on the physical and biological
environment; and (4) the translation of these environmental impacts
into economic damages. As a result, any effort to quantify and monetize
the harms associated with climate change will raise serious questions
of science, economics, and ethics and should be viewed as provisional.
Despite the serious limits of both quantification and monetization,
SCC estimates can be useful in estimating the social benefits of
reducing carbon dioxide emissions. Most Federal regulatory actions can
be expected to have marginal impacts on global emissions. For such
policies, the agency can estimate the benefits from reduced emissions
in any future year by multiplying the change in emissions in that year
by the SCC value appropriate for that year. The net present value of
the benefits can then be calculated by multiplying the future benefits
by an appropriate discount factor and summing across all affected
years. This approach assumes that the marginal damages from increased
emissions are constant for small departures from the baseline emissions
path, an approximation that is reasonable for policies that have
effects on emissions that are small relative to cumulative global
carbon dioxide emissions. For policies that have a large (non-marginal)
impact on global cumulative emissions, there is a separate question of
whether the SCC is an appropriate tool for calculating the benefits of
reduced emissions. This concern is not applicable to this rulemaking,
however.
It is important to emphasize that the interagency process is
committed to updating these estimates as the science and economic
understanding of climate change and its impacts on society improves
over time. In the meantime, the interagency group will continue to
explore the issues raised by this analysis and consider public comments
as part of the ongoing interagency process.
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
Economic analyses for Federal regulations have used a wide range of
values to estimate the benefits associated with reducing carbon dioxide
emissions. In the final model year 2011 CAFE rule, the U.S. Department
of Transportation (DOT) used both a ``domestic'' SCC value of $2 per
metric ton of CO2 and a ``global'' SCC value of $33 per
metric ton of CO2 for 2007 emission reductions (in 2007$),
increasing both values at 2.4 percent per year. DOT also included a
sensitivity analysis at $80 per metric ton of CO2.\79\ A
2008 regulation proposed by DOT assumed a domestic SCC value of $7 per
metric ton of CO2 (in 2006$) for 2011 emission reductions
(with a range of $0-$14 for sensitivity analysis), also increasing at
2.4 percent per year.\80\ A regulation for packaged terminal air
conditioners and packaged terminal heat pumps finalized by DOE in
October of 2008 used a domestic SCC range of $0 to $20 per metric ton
CO2 for 2007 emission reductions (in 2007$). 73 FR 58772,
58814 (Oct. 7, 2008). In addition, EPA's 2008 Advance Notice of
Proposed Rulemaking on Regulating Greenhouse Gas Emissions Under the
Clean Air Act identified what it described as ``very preliminary'' SCC
estimates subject to revision. 73 FR 44354 (July 30, 2008). EPA's
global mean values were $68 and $40 per metric ton CO2 for
discount rates of approximately 2 percent and 3 percent, respectively
(in 2006$ for 2007 emissions).
---------------------------------------------------------------------------
\79\ See Average Fuel Economy Standards Passenger Cars and Light
Trucks Model Year 2011, 74 FR 14196 (March 30, 2009) (Final Rule);
Final Environmental Impact Statement Corporate Average Fuel Economy
Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at
3-90 (Oct. 2008) (Available at: https://www.nhtsa.gov/fuel-economy)
(Last accessed December 2012).
\80\ See Average Fuel Economy Standards, Passenger Cars and
Light Trucks, Model Years 2011-2015, 73 FR 24352 (May 2, 2008)
(Proposed Rule); Draft Environmental Impact Statement Corporate
Average Fuel Economy Standards, Passenger Cars and Light Trucks,
Model Years 2011-2015 at 3-58 (June 2008) (Available at: https://www.nhtsa.gov/fuel-economy) (Last accessed December 2012).
---------------------------------------------------------------------------
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing carbon dioxide emissions. To ensure consistency in how
benefits are evaluated across agencies, the Administration sought to
develop a transparent and defensible method, specifically designed for
the rulemaking process, to quantify avoided climate change damages from
reduced CO2 emissions. The interagency group did not
undertake any original analysis. Instead, it combined SCC estimates
from the existing literature to use as interim values until a more
comprehensive analysis could be conducted. The outcome of the
preliminary assessment by the interagency group was a set of five
interim values: Global SCC estimates for 2007 (in 2006$) of $55, $33,
$19, $10, and $5 per metric ton of CO2. These interim values
represented the first sustained interagency effort within the U.S.
government to develop an SCC for use in regulatory analysis. The
results of this preliminary effort were presented in several proposed
and final rules.
c. Current Approach and Key Assumptions
Since the release of the interim values, the interagency group
reconvened on a regular basis to generate improved SCC estimates.
Specifically, the group considered public comments and further explored
the technical literature in relevant fields. The interagency group
relied on three integrated assessment models commonly used to estimate
the SCC: The FUND, DICE, and PAGE models. These models are frequently
cited in the peer-reviewed literature and were used in the last
assessment of the Intergovernmental Panel on Climate Change. Each model
was given equal weight in the SCC values that were developed.
Each model takes a slightly different approach to model how changes
in emissions result in changes in economic damages. A key objective of
the interagency process was to enable a consistent exploration of the
three models while respecting the different approaches to quantifying
damages taken by the key modelers in the field. An extensive review of
the literature was conducted to select three sets of input parameters
for these models: climate sensitivity, socio-economic and emissions
trajectories, and discount rates. A probability distribution for
climate sensitivity was specified as an input into all three models. In
addition, the interagency group used a range of scenarios for the
socio-economic parameters and a range of values for the discount rate.
All other model features were left unchanged, relying on the model
developers' best estimates and judgments.
In 2010, the interagency group selected four sets of SCC values for
use in regulatory analyses.\81\ Three sets of
[[Page 73651]]
values are based on the average SCC from three integrated assessment
models, at discount rates of 2.5 percent, 3 percent, and 5 percent. The
fourth set, which represents the 95th-percentile SCC estimate across
all three models at a 3-percent discount rate, is included to represent
higher-than-expected impacts from climate change further out in the
tails of the SCC distribution. The 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 preference is given to
consideration of the global benefits of reducing CO2
emissions. Table IV.26 presents the values in the 2010 interagency
group report, which is reproduced in appendix 14-A of the NOPR TSD.
---------------------------------------------------------------------------
\81\ Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. Interagency Working Group on Social Cost of
Carbon, United States Government, February 2010. https://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
Table IV.26--Annual SCC Values From 2010 Interagency Report, 2010-2050
[In 2007 dollars per metric ton CO[ihel2]]
----------------------------------------------------------------------------------------------------------------
Discount rate %
---------------------------------------------------------------------------
Year 5 3 2.5 3
---------------------------------------------------------------------------
Average Average Average 95th Percentile
----------------------------------------------------------------------------------------------------------------
2010................................ 4.7 21.4 35.1 64.9
2015................................ 5.7 23.8 38.4 72.8
2020................................ 6.8 26.3 41.7 80.7
2025................................ 8.2 29.6 45.9 90.4
2030................................ 9.7 32.8 50.0 100.0
2035................................ 11.2 36.0 54.2 109.7
2040................................ 12.7 39.2 58.4 119.3
2045................................ 14.2 42.1 61.7 127.8
2050................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
The SCC values used for today's notice were generated using the
most recent versions of the three integrated assessment models that
have been published in the peer-reviewed literature.\82\ Table
IV.27shows the updated sets of SCC estimates from the 2013 interagency
update in five-year increments from 2010 to 2050. Appendix 14A of the
NOPR TSD provides the full set of values. The central value that
emerges is the average SCC across models at 3-percent discount rate.
However, for purposes of capturing the uncertainties involved in
regulatory impact analysis, the interagency group emphasizes the
importance of including all four sets of SCC values.
---------------------------------------------------------------------------
\82\ Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866. Interagency
Working Group on Social Cost of Carbon, United States Government.
May 2013; revised November 2013.https://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
Table IV.27--Annual SCC Values From 2013 Interagency Update, 2010-2050
[In 2007 dollars per metric ton CO[ihel2]]
----------------------------------------------------------------------------------------------------------------
Discount rate %
---------------------------------------------------------------------------
Year 5 3 2.5 3
---------------------------------------------------------------------------
Average Average Average 95th Percentile
----------------------------------------------------------------------------------------------------------------
2010................................ 11 32 51 89
2015................................ 11 37 57 109
2020................................ 12 43 64 128
2025................................ 14 47 69 143
2030................................ 16 52 75 159
2035................................ 19 56 80 175
2040................................ 21 61 86 191
2045................................ 24 66 92 206
2050................................ 26 71 97 220
----------------------------------------------------------------------------------------------------------------
It is important to recognize that a number of key uncertainties
remain, and that current SCC estimates should be treated as provisional
and revisable since they will evolve with improved scientific and
economic understanding. The interagency group also recognizes that the
existing models are imperfect and incomplete. The National Research
Council report mentioned above points out that there is tension between
the goal of producing quantified estimates of the economic damages from
an incremental ton of carbon and the limits of existing efforts to
model these effects. There are a number of concerns and problems that
should be addressed by the research community, including research
programs housed in many of the Federal agencies participating in the
interagency process to estimate the SCC. The interagency group intends
to periodically review and reconsider those estimates to reflect
increasing knowledge of the science and economics of climate impacts,
as well as improvements in modeling.
In summary, in considering the potential global benefits resulting
from reduced CO2 emissions resulting from today's rule, DOE
used the values from the 2013 interagency report, adjusted to 2012$
using the Gross Domestic Product
[[Page 73652]]
price deflator. For each of the four cases specified, the values used
for emissions in 2015 were $11.8, $39.7, $61.2, and $117 per metric ton
avoided (values expressed in 2012$). DOE derived values after 2050
using the relevant growth rate for the 2040-2050 period in the
interagency update.
DOE multiplied the CO2 emissions reduction estimated for
each year by the SCC value for that year in each of the four cases. To
calculate a present value of the stream of monetary values, DOE
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SCC values in each case.
2. Valuation of Other Emissions Reductions
DOE investigated the potential monetary benefit of reduced
NOX emissions from the TSLs it considered. As noted above,
DOE has taken into account how new or amended energy conservation
standards would reduce NOX emissions in those 22 states not
affected by the CAIR. DOE estimated the monetized value of
NOX emissions reductions resulting from each of the TSLs
considered for today's NOPR based on estimates found in the relevant
scientific literature. Available estimates suggest a very wide range of
monetary values per ton of NOX from stationary sources,
ranging from $468 to $4,809 per ton in 2012$).\83\ In accordance with
OMB guidance,\84\ DOE calculated a range of monetary benefits using
each of the economic values for NOX and real discount rates
of 3-percent and 7-percent.
---------------------------------------------------------------------------
\83\ For additional information, refer to 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.
\84\ OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
---------------------------------------------------------------------------
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. It has not included monetization in the current analysis.
M. Utility Impact Analysis
The utility impact analysis estimates several effects on the power
generation industry that would result from the adoption of new or
amended energy conservation standards. In the utility impact analysis,
DOE analyzes the changes in installed electricity capacity and
generation that would result for each trial standard level. The utility
impact analysis uses a variant of NEMS,\85\ which is a public domain,
multi-sectored, partial equilibrium model of the U.S. energy sector.
DOE uses a variant of this model, referred to as NEMS-BT,\86\ 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. The energy savings inputs associated with each TSL come from
the NIA. Chapter 15 of the NOPR TSD describes the utility impact
analysis in further detail.
---------------------------------------------------------------------------
\85\ 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).
\86\ 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
``NEMS-BT'' (``BT'' is DOE's Building Technologies Program, under
whose aegis this work has been performed).
---------------------------------------------------------------------------
N. Employment Impact Analysis
Employment impacts from new or amended energy conservation
standards include direct and indirect impacts. Direct employment
impacts are any changes in the number of employees of manufacturers of
the equipment subject to standards; the MIA addresses those impacts.
Indirect employment impacts are changes in national employment that
occur due to the shift in expenditures and capital investment caused by
the purchase and operation of more efficient equipment. Indirect
employment impacts from standards consist of the jobs created or
eliminated in the national economy, other than in the manufacturing
sector being regulated, due to: (1) Reduced spending by end users on
energy; (2) reduced spending on new energy supply by the utility
industry; (3) increased consumer spending on the purchase of new
equipment; and (4) the effects of those three factors throughout the
economy.
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). 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. There are many reasons for these differences, including wage
differences and the fact that the utility sector is more capital-
intensive 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). Thus, based
on the BLS data alone, DOE believes net national employment may
increase because of shifts in economic activity resulting from new and
amended standards.
For the standard levels considered in the NOPR, DOE estimated
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). 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 the 187
sectors. ImSET's national economic I-O structure is based on a 2002
U.S. benchmark table, specially aggregated to the 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. For the NOPR, DOE used ImSET only to
estimate short-term employment impacts.
For more details on the employment impact analysis, see chapter 16
of the NOPR TSD.
O. Other Comments Received
IECA commented that motor end-users have not participated in DOE's
electric motor standards process, and they urge DOE to provide an
outreach effort to include those who buy motors. (IECA, No. 52 at p. 3)
Throughout the rulemaking process, DOE makes a
[[Page 73653]]
considerable effort to understand rulemaking impacts to consumers, most
specifically in the life-cycle cost analysis. It encourages various
interested parties, including end-users of electric motors, to attend
public meetings and submit comments. DOE recognizes the central
importance of the consumer perspective, and welcomes comment from IECA
and any other organizations serving consumer interest, as well as from
individual consumers, themselves.
V. Analytical Results
A. Trial Standard Levels
DOE ordinarily considers several Trial Standard Levels (TSLs) in
its analytical process. TSLs are formed by grouping different
Efficiency Levels (ELs), which are standard levels for each Equipment
Class Grouping (ECG) of motors. DOE analyzed the benefits and burdens
of the TSLs developed for today's proposed rule. DOE examined four TSLs
for electric motors. Table V.1 presents the TSLs analyzed and the
corresponding efficiency level for each equipment class group.
The efficiency levels in each TSL can be characterized as follows:
TSL 1 represents each equipment class group moving up one efficiency
level from the current baseline, with the exception of fire-pump
motors, which remain at their baseline level; TSL 2 represents NEMA
Premium levels for all equipment class groups with the exception of
fire-pump motors, which remain at the baseline; TSL 3 represents 1 NEMA
band above NEMA Premium for all groups except fire-pump motors, which
move up to NEMA Premium; and TSL 4 represents the maximum
technologically feasible level (max tech) for all equipment class
groups. Because today's proposal includes equipment class groups
containing both currently regulated motors and those proposed to be
regulated, at certain TSLs, an equipment class group may encompass
different standard levels, some of which may be above one EL above the
baseline. For example, at TSL1, EL1 is being proposed for equipment
class group 1. However, a large number of motors in equipment class
group 1 already have to meet EL2. If TSL1 was selected, these motors
would continue to be required to meet the standards at TSL2, while
currently un-regulated motors would be regulated to TSL1.
Table V.1--Summary of Proposed TSLs
----------------------------------------------------------------------------------------------------------------
Equipment class group TSL 1 TSL 2 TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
1................................ EL 1................ EL 2................ EL 3............... EL 4
2................................ EL 1................ EL 1................ EL 2............... EL 2
3................................ EL 0................ EL 0................ EL 1............... EL 3
4................................ EL 1................ EL 2................ EL 3............... EL 4
----------------------------------------------------------------------------------------------------------------
B. Economic Justification and Energy Savings
As discussed in section II.A, EPCA provides seven factors to be
evaluated in determining whether a potential energy conservation
standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The
following sections generally discuss how DOE is addressing each of
those seven factors in this rulemaking.
1. Economic Impacts on Individual Customers
DOE analyzed the economic impacts on electric motor customers by
looking at the effects standards would have on the LCC and PBP. DOE
also examined the rebuttable presumption payback periods for each
equipment class, and the impacts of potential standards on customer
subgroups. These analyses are discussed below.
a. Life-Cycle Cost and Payback Period
To evaluate the net economic impact of standards on electric motor
customers, DOE conducted LCC and PBP analyses for each TSL. In general,
higher-efficiency equipment would affect customers in two ways: (1)
Annual operating expense would decrease, and (2) purchase price would
increase. Section IV.F of this notice discusses the inputs DOE used for
calculating the LCC and PBP. The LCC and PBP results are calculated
from electric motor cost and efficiency data that are modeled in the
engineering analysis (section IV.C).
For each representative unit, the key outputs of the LCC analysis
are a mean LCC savings and a median PBP relative to the base case, as
well as the fraction of customers for which the LCC will decrease (net
benefit), increase (net cost), or exhibit no change (no impact)
relative to the base-case product forecast. No impacts occur when the
base-case efficiency equals or exceeds the efficiency at a given TSL.
Table V.2 through Table V.5 show the key shipment weighted average of
results for the representative units in each equipment class group.
Table V.2--Summary Life-Cycle Cost and Payback Period Results for
Equipment Class Group 1
------------------------------------------------------------------------
Trial standard level * 1 2 3 4
------------------------------------------------------------------------
Efficiency level 1 2 3 4
------------------------------------------------------------------------
Customers with Net LCC Cost (%) **...... 0.3 8.4 38.0 84.6
Customers with Net LCC Benefit (%) **... 9.7 32.0 40.4 7.6
Customers with No Change in LCC (%) **.. 90.0 59.6 21.5 7.7
Mean LCC Savings ($).................... 43 132 68 -417
Median PBP (Years)...................... 1.1 3.3 6.7 29.9
------------------------------------------------------------------------
* The results for equipment class group 1 are the shipment weighted
averages of the results for representative units 1, 2, and 3.
** Rounding may cause some items to not total 100 percent.
[[Page 73654]]
Table V.3--Summary Life-Cycle Cost and Payback Period Results for
Equipment Class Group 2
------------------------------------------------------------------------
Trial Standard level * 1 2 3 4
------------------------------------------------------------------------
Efficiency level 1 1 2 2
------------------------------------------------------------------------
Customers with Net LCC Cost (%) **...... 21.5 21.5 94.7 94.7
Customers with Net LCC Benefit (%) **... 68.6 68.6 5.3 5.3
Customers with No Change in LCC (%) **.. 9.9 9.9 0.0 0.0
Mean LCC Savings ($).................... 38 38 -285 -285
Median PBP (Years)...................... 5.0 5.0 22.8 22.8
------------------------------------------------------------------------
* The results for equipment class group 2 are the shipment weighted
averages of the results for representative units 4 and 5.
** Rounding may cause some items to not total 100 percent.
Table V.4--Summary Life-Cycle Cost and Payback Period Results for
Equipment Class Group 3
------------------------------------------------------------------------
Trial standard level * 1 2 3 4
------------------------------------------------------------------------
Efficiency level 0 0 1 3
------------------------------------------------------------------------
Customers with Net LCC Cost (%) 0.0 0.0 81.7 100.0
**............................
Customers with Net LCC Benefit 0.0 0.0 0.0 0.0
(%) **........................
Customers with No Change in LCC 0.0 0.0 18.3 0.0
(%) **........................
Mean LCC Savings ($)........... N/A *** N/A *** -61 -763
Median PBP (Years)............. N/A *** N/A *** 3,299 11,957
------------------------------------------------------------------------
* The results for equipment class group 3 are the shipment weighted
averages of the results for representative units 6, 7, and 8.
** Rounding may cause some items to not total 100 percent.
*** For equipment class group 3, TSL 1 and 2 are the same as the
baseline; thus, no customers are affected.
Table V.5--Summary Life-Cycle Cost and Payback Period Results for
Equipment Class Group 4
------------------------------------------------------------------------
Trial standard level * 1 2 3 4
------------------------------------------------------------------------
Efficiency level 1 2 3 4
------------------------------------------------------------------------
Customers with Net LCC Cost (%) **...... 1.0 10.8 33.1 79.6
Customers with Net LCC Benefit (%) **... 31.8 60.8 65.8 19.9
Customers with No Change in LCC (%) **.. 67.3 28.4 1.1 0.3
Mean LCC Savings ($).................... 137 259 210 -291
Median PBP (Years)...................... 1.2 1.9 3.7 16.0
------------------------------------------------------------------------
* The results for equipment class group 4 are the shipment weighted
averages of the results for representative units 9 and 10.
** Rounding may cause some items to not total 100 percent.
b. Consumer Subgroup Analysis
In the customer subgroup analysis, DOE estimated the LCC impacts of
the electric motor TSLs on various groups of customers. Table V.6 and
Table V.7 compare the weighted average mean LCC savings and median
payback periods for ECG 1 at each TSL for different customer subgroups.
Chapter 11 of the TSD presents the detailed results of the customer
subgroup analysis and results for the other equipment class groups.
Table V.6--Summary Life-Cycle Cost Results for Subgroups for Equipment Class Group 1: Average LCC Savings
----------------------------------------------------------------------------------------------------------------
Average LCC savings (2012$) *
-----------------------------------------------------------------------------------------------
EL TSL Low energy Small Industrial Commercial Agricultural
Default price business sector only sector only sector only
----------------------------------------------------------------------------------------------------------------
1 1 43 38 37 53 40 16
2 2 132 115 111 169 118 5
3 3 68 46 45 111 53 -103
4 4 -417 -447 -448 -356 -440 -675
----------------------------------------------------------------------------------------------------------------
* The results for equipment class group 1 are the shipment weighted averages of the results for representative
units 1, 2, and 3.
[[Page 73655]]
Table V.7--Summary Life-Cycle Cost Results for Subgroups for Equipment Class Group 1: Median Payback Period
----------------------------------------------------------------------------------------------------------------
Median payback period (Years) *
-----------------------------------------------------------------------------------------------
EL TSL Low energy Small Industrial Commercial Agricultural
Default price business sector only sector only sector only
----------------------------------------------------------------------------------------------------------------
1 1 1.1 1.3 1.1 0.8 1.3 3.5
2 2 3.3 3.7 3.3 2.1 3.9 7.0
3 3 6.7 7.6 6.7 4.2 7.9 22.7
4 4 29.9 33.7 29.9 18.8 34.7 123.5
----------------------------------------------------------------------------------------------------------------
* The results for equipment class group 1 are the shipment weighted averages of the results for representative
units 1, 2, and 3.
c. Rebuttable Presumption Payback
As discussed in section IV.F.12, EPCA establishes a rebuttable
presumption that an energy conservation standard is economically
justified if the increased purchase cost for equipment that meets the
standard is less than three times the value of the first-year energy
savings resulting from the standard. (42 U.S.C. 6295(o)(2)(B)(iii) and
6316(a)) DOE calculated a rebuttable-presumption PBP for each TSL to
determine whether DOE could presume that a standard at that level is
economically justified. DOE based the calculations on average usage
profiles. As a result, DOE calculated a single rebuttable-presumption
payback value, and not a distribution of PBPs, for each TSL. Table V.8
shows the rebuttable-presumption PBPs for the considered TSLs. The
rebuttable presumption is fulfilled in those cases where the PBP is
three years or less. However, DOE routinely conducts an economic
analysis that considers the full range of impacts to the customer,
manufacturer, Nation, and environment, as required under 42 U.S.C.
6295(o)(2)(B)(i) as applied to equipment via 42 U.S.C. 6316(a). The
results of that analysis serve as the basis for DOE to definitively
evaluate the economic justification for a potential standard level
(thereby supporting or rebutting the results of any three-year PBP
analysis). Section V.C addresses how DOE considered the range of
impacts to select today's NOPR.
Table V.8--Rebuttable-Presumption Payback Periods (Years)
------------------------------------------------------------------------
Trial standard level
---------------------------------------
1 2 3 4
------------------------------------------------------------------------
Equipment Class Group 1 *....... 0.6 0.8 1.2 4.3
Equipment Class Group 2 *....... 1.8 1.8 8.0 8.0
Equipment Class Group 3 *....... 0.0 0.0 900 5,464
Equipment Class Group 4 *....... 0.6 0.9 1.3 4.5
------------------------------------------------------------------------
* The results for each equipment class group (ECG) are a shipment
weighted average of results for the representative units in the group.
ECG 1: Representative units 1, 2, and 3; ECG 2: Representative units 4
and 5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative
units 9 and10.
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of new and amended
energy conservation standards on manufacturers of electric motors. The
section below describes the expected impacts on manufacturers at each
TSL. Chapter 12 of the TSD explains the analysis in further detail.
The tables below depict the financial impacts (represented by
changes in INPV) of new and amended energy conservation standards on
manufacturers as well as the conversion costs that DOE estimates
manufacturers would incur at each TSL. DOE displays the INPV impacts by
TSL for each ECG in accordance with the grouping described in detail in
section V.A. To evaluate the range of cash flow impacts on the electric
motor industry, DOE modeled three markup scenarios that correspond to
the range of anticipated market responses to new and amended standards.
Each markup scenario results in a unique set of cash flows and
corresponding industry value at each TSL. All three markup scenarios
are presented below. In the following discussion, the INPV results
refer to the difference in industry value between the base case and the
standards case that result from the sum of discounted cash flows from
the base year (2013) through the end of the analysis period. The
results also discuss the difference in cash flow between the base case
and the standards case in the year before the compliance date for new
and amended energy conservation standards. This figure represents how
large the required conversion costs are relative to the cash flow
generated by the industry in the absence of new and amended energy
conservation standards. In the engineering analysis, DOE enumerates
common technology options that achieve the efficiencies for each of the
representative units within an ECG. For descriptions of these
technology options and the required efficiencies at each TSL, see
section IV.C of today's notice.
a. Industry Cash-Flow Analysis Results
The results below show three INPV tables representing the three
markup scenarios used for the analysis. The first table reflects the
flat markup scenario, which is the upper (less severe) bound of
impacts. To assess the lower end of the range of potential impacts, DOE
modeled two potential markup scenarios, a two-tiered markup scenario
and a preservation of operating profit markup scenario. As discussed in
section IV.J.2.d, the two-tiered markup scenario assumes manufacturers
offer two different tiers of markups--one for lower efficiency levels
and one for higher efficiency levels. Meanwhile the preservation of
operating profit markup scenario assumes that in the standards case,
manufacturers would be able to earn the same operating margin in
[[Page 73656]]
absolute dollars in the standards case as in the base case. In general,
the larger the product price increases, the less likely manufacturers
are able to fully pass through additional costs due to standards
calculated in the flat markup scenario.
Table V.9, Table V.10, and Table V.11 present the projected results
for all electric motors under the flat, two-tiered and preservation of
operating profit markup scenarios. DOE examined all four ECGs (Design A
and B motors, Design C motors, fire pump motors, and brake motors)
together. The INPV results follow in the tables below.
Table V.9--Manufacturer Impact Analysis for Electric Motors--Flat Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
INPV......................... (2012$ millions) $3,371.2 $3,378.7 $3,759.2 $4,443.7 $5,241.3
Change in INPV............... (2012$ millions) ........... $7.5 $388.0 $1,072.5 $1,870.1
(%)............. ........... 0.2% 11.5% 31.8% 55.5%
Product Conversion Costs..... (2012$ millions) ........... $6.1 $57.4 $611.7 $620.6
Capital Conversion Costs..... (2012$ millions) ........... $0.0 $26.4 $220.5 $699.8
Total Conversion Costs... (2012$ millions) ........... $6.2 $83.7 $832.3 $1,320.4
----------------------------------------------------------------------------------------------------------------
Table V.10--Manufacturer Impact Analysis for Electric Motors--Two-Tiered Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
INPV......................... (2012$ millions) $3,371.2 $3,374.3 $3,087.6 $2,979.6 $3,335.7
Change in INPV............... (2012$ millions) ........... $3.2 $(283.5) $(391.6) $(35.5)
(%)............. ........... 0.1% -8.4% -11.6% -1.1%
Product Conversion Costs..... (2012$ millions) ........... $6.1 $57.4 $611.7 $620.6
Capital Conversion Costs..... (2012$ millions) ........... $0.0 $26.4 $220.5 $699.8
Total Conversion Costs... (2012$ millions) ........... $6.2 $83.7 $832.3 $1,320.4
----------------------------------------------------------------------------------------------------------------
Table V.11--Manufacturer Impact Analysis for Electric Motors--Preservation of Operating Profit Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
INPV......................... (2012$ millions) $3,371.2 $3,019.5 $3,089.7 $2,356.8 $1,383.1
Change in INPV............... (2012$ millions) ........... $(351.7) $(281.5) $(1,014.4) $(1,988.1)
(%)............. ........... -10.4% -8.4% -30.1% -59.0%
Product Conversion Costs..... (2012$ millions) ........... $6.1 $57.4 $611.7 $620.6
Capital Conversion Costs..... (2012$ millions) ........... $0.0 $26.4 $220.5 $699.8
Total Conversion Costs... (2012$ millions) ........... $6.2 $83.7 $832.3 $1,320.4
----------------------------------------------------------------------------------------------------------------
TSL 1 represents EL 1 for ECG 1, ECG 2 and ECG 4 motors and
baseline for ECG 2 motors. At TSL 1, DOE estimates impacts on INPV to
range from $7.5 million to -$351.7 million, or a change in INPV of 0.2
percent to -10.4 percent. At this proposed level, industry free cash
flow is estimated to decrease by approximately 1.1 percent to $164.9
million, compared to the base case value of $166.7 million in the year
leading up to the proposed energy conservation standards.
The INPV impacts at TSL 1 range from slightly positive to
moderately negative, however DOE does not anticipate that manufacturers
would lose a significant portion of their INPV at this TSL. This is
because the vast majority of shipments already meets or exceeds the
efficiency levels prescribed at TSL 1. DOE estimates that in the year
of compliance, 90 percent of all electric motor shipments (90 percent
of ECG 1, eight percent of ECG 2, 100 percent of ECG 3, and 67 percent
of ECG 4 shipments) would meet the efficiency levels at TSL 1 or higher
in the base case. Since ECG 1 shipments account for over 97 percent of
all electric motor shipments the effects on those motors are the
primary driver for the impacts at this TSL. Only a few ECG 1 shipments
not currently covered by the existing electric motors rule and a small
amount of ECG 2 and ECG 4 shipments would need to be converted at TSL 1
to meet this efficiency standard.
DOE expects conversion costs to be small compared to the industry
value because most of the electric motor shipments, on a volume basis,
already meet the efficiency levels analyzed at this TSL. DOE estimates
product conversion costs of $6.1 million due to the proposed expanded
scope of this rulemaking which includes motors previously not covered
by the current electric motor energy conservation standards. DOE
believes that at this TSL, there will be some engineering costs as well
as testing and certification costs associated with this proposed scope
expansion. DOE estimates the capital conversion costs to be minimal at
TSL 1. This is mainly because almost all manufacturers currently
produce some motors that are compliant at TSL 1 efficiency levels and
it would not be much of a capital investment to bring all motor
production to this efficiency level.
TSL 2 represents EL 2 for ECG 1 and ECG 4 motors; EL 1 for ECG 2
motors; and baseline for ECG 3 motors. At TSL 2, DOE estimates impacts
on INPV to range from $388 million to -$283.5 million, or a change in
INPV of 11.5 percent to -8.4 percent. At this
[[Page 73657]]
proposed level, industry free cash flow is estimated to decrease by
approximately 17.2 percent to $138 million, compared to the base case
value of $166.7 million in the year leading up to the proposed energy
conservation standards.
The INPV impacts at TSL 2 range from moderately positive to
moderately negative. DOE estimates that in the year of compliance, 59
percent of all electric motor shipments (60 percent of ECG 1, eight
percent of ECG 2, 100 percent of ECG 3, and 30 percent of ECG 4
shipments) would meet the efficiency levels at TSL 2 or higher in the
base case. The majority of shipments are currently covered by an
electric motors standard that requires general purpose Design A and B
motors to meet this TSL. Therefore, only previously non-covered Design
A and B motors and a few ECG 2 and ECG 4 motors would have to be
converted at TSL 2 to meet this efficiency standard.
DOE expects conversion costs to increase significantly from TSL 1,
however, these conversion costs do not represent a large portion of the
base case INPV, since again the majority of electric motor shipments
already meet the efficiency levels analyzed at this TSL. DOE estimates
product conversion costs of $57.4 million due to the proposed expanded
scope of this rulemaking, which includes motors previously not covered
by the current electric motor energy conservation standards and the
inclusion of ECG 2 and ECG 4 motors. DOE believes there will be sizable
engineering costs as well as testing and certification costs at this
TSL associated with this proposed scope expansion. DOE estimates the
capital conversion costs to be approximately $26.4 million at TSL 2.
While most manufacturers already produce at least some motors that are
compliant at TSL 2, these manufacturers would likely have to invest in
expensive machinery to bring all motor production to these efficiency
levels.
TSL 3 represents EL 3 for ECG 1 and ECG 4 motors, EL 2 for ECG 2
motors and EL 1 for ECG 3 motors. At TSL 3, DOE estimates impacts on
INPV to range from $1,072.5 million to -$1,014.4 million, or a change
in INPV of 31.8 percent to -30.1 percent. At this proposed level,
industry free cash flow is estimated to decrease by approximately 167.5
percent to -$112.5 million, compared to the base case value of $166.7
million in the year leading up to the proposed energy conservation
standards.
The INPV impacts at TSL 3 range from significantly positive to
significantly negative. DOE estimates that in the year of compliance,
23 percent of all electric motor shipments (24 percent of ECG 1, less
than one percent of ECG 2, 19 percent of ECG 3, and four percent of ECG
4 shipments) would meet the efficiency levels at TSL 3 or higher in the
base case. The majority of shipments would need to be converted to meet
energy conservation standards at this TSL.
DOE expects conversion costs to increase significantly at TSL 3 and
become a substantial investment for manufacturers. DOE estimates
product conversion costs of $611.7 million at TSL 3, since most
electric motors in the base case do not exceed the current motor
standards set at NEMA Premium for Design A and B motors, which
represent EL 2 for ECG 1. DOE believes there would be a massive
reengineering effort that manufacturers would have to undergo to have
all motors meet this TSL. Additionally, motor manufacturers would have
to increase the efficiency levels for ECG 2, ECG 3, and ECG 4 motors.
DOE estimates the capital conversion costs to be approximately $220.5
million at TSL 3. Most manufacturers would have to make significant
investments to their production facilities in order to convert all
their motors to be compliant at TSL 3.
TSL 4 represents EL 4 for ECG 1 and ECG 4 motors, EL 3 for ECG 3
motors and EL 2 for ECG 2 motors. At TSL 4, DOE estimates impacts on
INPV to range from $1,870.1 million to -$1,988.1 million, or a change
in INPV of 55.5 percent to -59.0 percent. At this proposed level,
industry free cash flow is estimated to decrease by approximately 298.4
percent to -$330.8 million, compared to the base case value of $166.7
million in the year leading up to the proposed energy conservation
standards.
The INPV impacts at TSL 4 range from significantly positive to
significantly negative. DOE estimates that in the year of compliance
only eight percent of all electric motor shipments (nine percent of ECG
1, less than one percent of ECG 2, zero percent of ECG 3, and less than
one percent of ECG 4 shipments) would meet the efficiency levels at TSL
2 or higher in the base case. Almost all shipments would need to be
converted to meet energy conservation standards at this TSL.
DOE expects conversion costs again to increase significantly from
TSL 3 to TSL 4. Conversion costs at this TSL now represent a massive
investment for electric motor manufacturers. DOE estimates product
conversion costs of $620.6 million at TSL 4, which are the same
conversion costs at TSL 3. DOE believes that manufacturers would need
to completely reengineer almost all electric motors sold as well as
test and certify those motors. DOE estimates capital conversion costs
of $699.8 million at TSL 4. This is a significant increase in capital
conversion costs from TSL 3 since manufacturers would need to adopt
copper die-casting at this TSL. This technology requires a significant
level of investment because the majority of the machinery would need to
be replaced or significantly modified.
b. Impacts on Employment
DOE quantitatively assessed the impact of potential new and amended
energy conservation standards on direct employment. DOE used the GRIM
to estimate the domestic labor expenditures and number of domestic
production workers in the base case and at each TSL from the
announcement of any potential new and amended energy conservation
standards in 2013 to the end of the analysis period in 2044. DOE used
statistical data from the U.S. Census Bureau's 2011 Annual Survey of
Manufacturers (ASM), the results of the engineering analysis, and
interviews with manufacturers to determine the inputs necessary to
calculate industry-wide labor expenditures and domestic employment
levels. Labor expenditures involved with the manufacturing of electric
motors are a function of the labor intensity of the product, the sales
volume, and an assumption that wages remain fixed in real terms over
time.
In the GRIM, DOE used the labor content of each product and the
manufacturing production costs to estimate the annual labor
expenditures of the industry. DOE used Census data and interviews with
manufacturers to estimate the portion of the total labor expenditures
attributable to domestic labor.
The production worker estimates in this employment section cover
only workers up to the line-supervisor level who are directly involved
in fabricating and assembling an electric motor within a motor
facility. Workers performing services that are closely associated with
production operations, such as material handling with a forklift, are
also included as production labor. DOE's estimates account for only
production workers who manufacture the specific equipment covered by
this rulemaking. For example, a worker on an electric motor line
manufacturing a fractional horsepower motor (i.e. a motor with less
than one horsepower) would not be included with this estimate of the
number of electric motor workers, since
[[Page 73658]]
fractional motors are not covered by this rulemaking.
The employment impacts shown in the tables below represent the
potential production employment impact resulting from new and amended
energy conservation standards. The upper bound of the results estimates
the maximum change in the number of production workers that could occur
after compliance with new and amended energy conservation standards
when assuming that manufacturers continue to produce the same scope of
covered equipment in the same production facilities. It also assumes
that domestic production does not shift to lower-labor-cost countries.
Because there is a real risk of manufacturers evaluating sourcing
decisions in response to new and amended energy conservation standards,
the lower bound of the employment results includes the estimated total
number of U.S. production workers in the industry who could lose their
jobs if all existing production were moved outside of the U.S. While
the results present a range of employment impacts following 2015, the
sections below also include qualitative discussions of the likelihood
of negative employment impacts at the various TSLs. Finally, the
employment impacts shown are independent of the indirect employment
impacts from the broader U.S. economy, which are documented in chapter
16 of the NOPR TSD.
Based on 2011 ASM data and interviews with manufacturers, DOE
estimates approximately 60 percent of electric motors sold in the U.S.
are manufactured domestically. Using this assumption, DOE estimates
that in the absence of new and amended energy conservation standards,
there would be approximately 7,237 domestic production workers involved
in manufacturing all electric motors covered by this rulemaking in
2015. The table below shows the range of potential impacts of new and
amended energy conservation standards for all ECGs on U.S. production
workers in the electric motor industry. However, because ECG 1 motors
comprise more than 97 percent of the electric motors covered by this
rulemaking, DOE believes that potential changes in domestic employment
will be driven primarily by the standards that are selected for ECG 1,
Design A and B electric motors.
Table V.12--Potential Changes in the Total Number of All Domestic Electric Motor Production Workers in 2015
----------------------------------------------------------------------------------------------------------------
Trial standard level
Base case ----------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Total Number of Domestic 7,237 7,270 7,420 8,287 15,883
Production Workers in 2015
(without changes in production
locations)......................
Potential Changes in Domestic ............ 33-0 183-(362) 1,050-(3,619) 8,646-(7,237)
Production Workers in 2015 *....
----------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
Most manufacturers agree that any standards that involve expanding
the scope of equipment required to meet NEMA Premium would not
significantly change domestic employment levels. At this efficiency
level (TSL 2), manufacturers would not be required to make major
modifications to their production lines nor would they have to
undertake new manufacturing processes. A few small business
manufacturers who primarily make electric motors currently out of the
scope of coverage, but whose equipment would be covered by new electric
motor standards, could be impacted by efficiency standards at TSL 2.
These impacts, including employment impacts, are discussed in section
VI.B of today's NOPR. Overall, DOE believes there would not be a
significant decrease in domestic employment levels at TSL 2. DOE
created a lower bound of the potential loss of domestic employment at
362 employees for TSL 2. DOE estimated only five percent of the
electric motors market is comprised of manufacturers that do not
currently produce any motors at NEMA Premium efficiency levels. DOE
estimated that at most five percent of domestic electric motor
manufacturing could potentially move abroad or exit the market
entirely. DOE similarly estimated that all electric motor manufacturers
produce some electric motors at or above TSL 1 efficiency levels.
Therefore, DOE does not believe that any potential loss of domestic
employment would occur at TSL 1.
Manufacturers, however, cautioned that any standard set above NEMA
Premium would require major changes to production lines, large
investments in capital and labor, and would result in extensive
stranded assets. This is largely because manufacturers would have to
design and build motors with larger frame sizes and could potentially
have to use copper, rather than aluminum rotors. Several manufacturers
pointed out that this would require extensive retooling, vast
engineering resources, and would ultimately result in a more labor-
intensive production process. Manufacturers generally agreed that a
shift toward copper rotors would have uncertain impacts on energy
efficiency and would cause companies to incur higher labor costs. These
factors could cause manufacturers to consider moving production
offshore to reduce labor costs or they may choose to exit the market
entirely. Therefore, DOE believes it is more likely that efficiency
standards set above NEMA Premium could result in a decrease of labor.
Accordingly, DOE set the lower bound on the potential loss of domestic
employment at 50 percent of the existing domestic labor market for TSL
3 and 100 percent of the domestic labor market for TSL 4. However,
these values represent the worst case scenario DOE modeled.
Manufacturers also stated that larger motor manufacturing (that is for
motors above 200 horsepower) would be very unlikely to move abroad
since the shipping costs associated with those motors are very large.
Consequently, DOE does not currently believe standards set at TSL 3 and
TSL 4 would likely result in a large loss of domestic employment.
c. Impacts on Manufacturing Capacity
Most manufacturers agreed that any standard expanding the scope of
equipment required to meet NEMA Premium would not have a significant
impact on manufacturing capacity. Manufacturers pointed out, however,
that a standard that required them to use copper rotors would severely
disrupt manufacturing capacity. Most manufacturers emphasized they do
not currently have the machinery, technology, or engineering resources
to produce copper rotors in-house. Some
[[Page 73659]]
manufacturers claim that the few manufacturers that do have the
capability of producing copper rotors are not able to produce these
motors in volumes sufficient to meet the demands of their customers.
For manufacturers to either completely redesign their motor production
lines or significantly expand their fairly limited copper rotor
production line would require a massive retooling and engineering
effort, which could take several years to complete. Most manufacturers
stated they would have to outsource copper rotor production because
they would not be able to modify their facilities and production
processes to produce copper rotors in-house within a three year time
period. Most manufacturers agreed that outsourcing rotor die casting
would constrain capacity by creating a bottleneck in rotor production,
as there are very few companies that produce copper rotors.
Manufacturers also pointed out that there is substantial
uncertainty surrounding the global availability and price of copper,
which has the potential to constrain capacity. Several manufacturers
expressed concern that the combination of all of these factors would
make it difficult to support existing business while redesigning
product lines and retooling. The need to support existing business
would also cause the redesign effort to take several years.
In summary, for those TSLs that require copper rotors, DOE believes
there is a likelihood of capacity constraints in the near term due to
fluctuations in the copper market and limited copper die casting
machinery and expertise. However, for the levels proposed in this rule,
DOE does not foresee any capacity constraints.
d. Impacts on Sub-Group of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate may not be adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche equipment
manufacturers, and manufacturers exhibiting cost structures
substantially different from the industry average could be affected
disproportionately. DOE analyzed the impacts to small businesses in
section VI.B and did not identify any other adversely impacted electric
motor-related subgroups for this rulemaking based on the results of the
industry characterization.
e. Cumulative Regulatory Burden
While any one regulation may not impose a significant burden on
manufacturers, the combined effects of recent or impending regulations
may have serious consequences for some manufacturers, groups of
manufacturers, or an entire industry. Assessing the impact of a single
regulation may overlook this cumulative regulatory burden. In addition
to energy conservation standards, other regulations can significantly
affect manufacturers' financial operations. Multiple regulations
affecting the same manufacturer can strain profits and lead companies
to abandon product lines or markets with lower expected future returns
than competing equipment. For these reasons, DOE conducts an analysis
of cumulative regulatory burden as part of its rulemakings pertaining
to appliance efficiency.
During previous stages of this rulemaking, DOE identified a number
of requirements, in addition to new and amended energy conservation
standards for electric motors, that manufacturers will face for
equipment they manufacture approximately three years prior to and three
years after the compliance date of the new and amended standards. The
following section briefly addresses comments DOE received with respect
to cumulative regulatory burden and summarizes other key related
concerns that manufacturers raised during interviews.
Several manufacturers expressed concern about the compliance date
of this rulemaking to the proximity of the 2015 compliance date for the
small electric motors rulemaking at 75 FR 10874 (March 9, 2010). Most
manufacturers of electric motors covered by this rulemaking also
produce electric motors that are covered by the small electric motors
rulemaking. Manufacturers stated that adopting these two regulations in
a potentially short timeframe could strain R&D and capital expenditure
budgets for motor manufacturers. Some manufacturers also raised
concerns about other existing regulations separate from DOE's energy
conservation standards that electric motors must meet: the National
Fire Protection Association (NFPA) 70, National Electric Code; the NFPA
20, Standard for the Installation of Stationary Pumps for Fire
Protection; and Occupational Safety and Health Administration (OSHA)
regulations. DOE discusses these and other requirements in chapter 12
of the NOPR TSD. DOE takes into account the cost of compliance with
other published Federal energy conservation standards in weighing the
benefits and burdens of today's proposed rulemaking. In the 2010 small
motors final rule, DOE estimated that manufacturers may lose up to 11.3
percent of their INPV, which was approximately $39.5 million, in 2009$.
To see the range of impacts DOE estimated for the small motors rule,
see chapter 12 of the NOPR TSD. DOE does not describe the quantitative
impacts of standards that have not yet been finalized because any
impacts would be highly speculative. DOE also notes that certain
standards are optional for manufacturers and takes that into account
when creating the cumulative regulatory burden analysis.
3. National Impact Analysis
a. Significance of Energy Savings
For each TSL, DOE projected energy savings for electric motors
purchased in the 30-year period that begins in the year of compliance
with new and amended standards (2015-2044). The savings are measured
over the entire lifetime of equipment purchased in the 30-year period.
DOE quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
base case. Table V.13 presents the estimated primary energy savings for
each considered TSL, and Table V.14 presents the estimated FFC energy
savings for each considered TSL. The approach for estimating national
energy savings is further described in section IV.H.
Table V.13--Cumulative Primary Energy Savings for Electric Motors Trial
Standard Levels for Units Sold in 2015-2044
------------------------------------------------------------------------
Trial standard level
Equipment class ---------------------------------------
1 2 3 4
------------------------------------------------------------------------
quads
------------------------------------------------------------------------
Group 1 (NEMA Design A and B)... 0.82 6.27 9.86 12.64
[[Page 73660]]
Group 2 (NEMA Design C)......... 0.02 0.02 0.03 0.03
Group 3 (Fire Pump Electric 0.00 0.00 0.00 0.00
Motors)........................
Group 4 (Brake Motors).......... 0.26 0.58 0.71 0.81
Total All Classes........... 1.10 6.87 10.60 13.49
------------------------------------------------------------------------
Table V.14--Cumulative Full-Fuel-Cycle Energy Savings for Electric
Motors Trial Standard Levels for Units Sold in 2015-2044
------------------------------------------------------------------------
Trial standard level
Equipment class ---------------------------------------
1 2 3 4
------------------------------------------------------------------------
quads
------------------------------------------------------------------------
Group 1 (NEMA Design A and B)... 0.83 6.38 10.02 12.85
Group 2 (NEMA Design C)......... 0.02 0.02 0.03 0.03
Group 3 (Fire Pump Electric 0.00 0.00 0.00 0.00
Motors)........................
Group 4 (Brake Motors).......... 0.26 0.59 0.73 0.83
Total All Classes........... 1.11 6.98 10.78 13.71
------------------------------------------------------------------------
Circular A-4 requires agencies to present analytical results,
including separate schedules of the monetized benefits and costs that
show the type and timing of benefits and costs. Circular A-4 also
directs agencies to consider the variability of key elements underlying
the estimates of benefits and costs. For this rulemaking, DOE undertook
a sensitivity analysis using nine rather than 30 years of equipment
shipments. The choice of a nine-year period is a proxy for the timeline
in EPCA for the review of certain energy conservation standards and
potential revision of and compliance with such revised standards.\87\
We would note that the review timeframe established in EPCA generally
does not overlap with the equipment lifetime, equipment manufacturing
cycles or other factors specific to electric motors. Thus, this
information is presented for informational purposes only and is not
indicative of any change in DOE's analytical methodology. The NES
results based on a 9-year analytical period are presented in Table
V.15. The impacts are counted over the lifetime of electric motors
purchased in 2015-2023.
---------------------------------------------------------------------------
\87\ EPCA requires DOE to review its standards at least once
every 6 years, and requires, for certain products, a 3-year period
after any new standard is promulgated before compliance is required,
except that in no case may any new standards be required within 6
years of the compliance date of the previous standards. While adding
a 6-year review to the 3-year compliance period adds up to 9 years,
DOE notes that it may undertake reviews at any time within the 6
year period and that the 3-year compliance date may yield to the 6-
year backstop. A 9-year analysis period may not be appropriate given
the variability that occurs in the timing of standards reviews and
the fact that for some consumer products, the compliance period is 5
years rather than 3 years.
Table V.15--Cumulative National Energy Savings for Electric Motors Trial
Standard Levels for Units Sold in 2015-2023
------------------------------------------------------------------------
Trial standard level
Equipment class ---------------------------------------
1 2 3 4
------------------------------------------------------------------------
quads
------------------------------------------------------------------------
Group 1 (NEMA Design A and B)... 0.355 1.440 2.168 2.833
Group 2 (NEMA Design C)......... 0.004 0.004 0.006 0.006
Group 3 (Fire Pump Electric 0.000 0.000 0.000 0.000
Motors)........................
Group 4 (Brake Motors).......... 0.060 0.125 0.152 0.176
Total All Classes........... 0.420 1,569 2.326 3.015
------------------------------------------------------------------------
b. Net Present Value of Customer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
customers that would result from the TSLs considered for electric
motors. In accordance with OMB's guidelines on regulatory analysis,\88\
DOE calculated the NPV using both a 7-percent and a 3-percent real
discount rate. The 7-percent rate is an estimate of the average before-
tax rate of return on private capital in the U.S. economy, and reflects
the returns on real estate and small business capital as well as
corporate capital. This discount rate approximates the opportunity cost
of capital in the private sector (OMB analysis has found the average
rate of return on capital to be near this rate). The 3-percent rate
reflects the potential effects of standards on private consumption
(e.g., through higher prices for equipment and reduced purchases of
energy). This rate represents the rate at which society discounts
future consumption flows to
[[Page 73661]]
their present value. It can be approximated by the real rate of return
on long-term government debt (i.e., yield on United States Treasury
notes), which has averaged about 3 percent for the past 30 years.
---------------------------------------------------------------------------
\88\ OMB Circular A-4, section E (Sept. 17, 2003). https://www.whitehouse.gov/omb/circulars_a004_a-4.
---------------------------------------------------------------------------
Table V.16 shows the customer NPV results for each TSL considered
for electric motors. In each case, the impacts cover the lifetime of
equipment purchased in 2015-2044.
Table V.16--Net Present Value of Customer Benefits for Electric Motors Trial Standard Levels for Units Sold in
2015-2044
[Billion 2012$]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class Discount -----------------------------------------------
rate % 1 2 3 4
----------------------------------------------------------------------------------------------------------------
Group 1 (NEMA Design A and B)....................... .......... 4.5 20.7 1.5 -41.2
Group 2 (NEMA Design C)............................. .......... 0.0 0.0 0.0 0.0
Group 3 (Fire Pump Electric Motors)................. 3 0.0 0.0 0.0 0.0
Group 4 (Brake Motors).............................. .......... 1.3 2.5 1.5 -1.2
Total All Classes............................... .......... 5.8 23.3 3.0 -42.4
----------------------------------------------------------------------------------------------------------------
Group 1 (NEMA Design A and B)....................... .......... 2.2 7.7 -3.7 -29.1
Group 2 (NEMA Design C)............................. .......... 0.0 0.0 0.0 0.0
Group 3 (Fire Pump Electric Motors)................. 7 0.0 0.0 0.0 0.0
Group 4 (Brake Motors).............................. .......... 0.5 1.0 0.3 -1.2
Total All Classes............................... .......... 2.7 8.7 -3.4 -30.3
----------------------------------------------------------------------------------------------------------------
The NPV results based on the afore-mentioned 9-year analytical
period are presented in Table V.17. The impacts are counted over the
lifetime of equipment purchased in 2015-2023. As mentioned previously,
this information is presented for informational purposes only and is
not indicative of any change in DOE's analytical methodology or
decision criteria.
Table V.17--Net Present Value of Customer Benefits for Electric Motors Trial Standard Levels for Units Sold in
2015-2023
[Billion 2012$]
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class Discount -----------------------------------------------
rate % 1 2 3 4
----------------------------------------------------------------------------------------------------------------
Group 1 (NEMA Design A and B)....................... .......... 2.253 6.473 2.541 -12.055
Group 2 (NEMA Design C)............................. .......... 0.011 0.011 -0.012 -0.012
Group 3 (Fire Pump Electric Motors)................. 3 0.000 0.000 -0.001 -0.009
Group 4 (Brake Motors).............................. .......... 0.389 0.706 0.495 -0.372
Total All Classes............................... .......... 2.654 7.190 3.023 -12.448
----------------------------------------------------------------------------------------------------------------
Group 1 (NEMA Design A and B)....................... .......... 1.344 3.492 -0.102 -12.017
Group 2 (NEMA Design C)............................. .......... 0.005 0.005 -0.016 -0.016
Group 3 (Fire Pump Electric Motors)................. 7 0.000 0.000 -0.001 -0.007
Group 4 (Brake Motors).............................. .......... 0.225 0.391 0.201 -0.498
Total All Classes............................... .......... 1.574 3.887 0.083 -12.537
----------------------------------------------------------------------------------------------------------------
c. Indirect Impacts on Employment
DOE expects energy conservation standards for electric motors to
reduce energy costs for equipment owners, and the resulting net savings
to be redirected to other forms of economic activity. Those shifts in
spending and economic activity could affect the demand for labor. As
described in section IV.N, DOE used an input/output model of the U.S.
economy to estimate indirect employment impacts of the TSLs that DOE
considered in this rulemaking. DOE understands that there are
uncertainties involved in projecting employment impacts, especially
changes in the later years of the analysis. Therefore, DOE generated
results for near-term time frames (2015-2019), where these
uncertainties are reduced.
The results suggest that today's standards are likely to have
negligible impact on the net demand for labor in the economy. The net
change in jobs is so small that it would be imperceptible in national
labor statistics and might be offset by other, unanticipated effects on
employment. Chapter 16 of the NOPR TSD presents detailed results.
4. Impact on Utility or Performance
DOE believes that the standards it is proposing today will not
lessen the utility or performance of electric motors.
5. Impact of Any Lessening of Competition
DOE has also considered any lessening of competition that is likely
to result from new and amended standards. The Attorney General
determines the impact, if any, of any lessening of competition likely
to result from a proposed standard, and transmits such determination to
the Secretary, together with an analysis of the nature and extent of
such impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii))
To assist the Attorney General in making such determination, DOE
will provide DOJ with copies of this NOPR and the TSD for review. DOE
will consider DOJ's comments on the proposed rule in preparing the
final rule, and DOE will publish and respond to DOJ's comments in that
document.
[[Page 73662]]
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the Nation's energy security, strengthens the economy, and reduces the
environmental impacts or costs of energy production. Reduced
electricity demand due to energy conservation standards is also likely
to reduce the cost of maintaining the reliability of the electricity
system, particularly during peak-load periods. As a measure of this
reduced demand, chapter 15 in the NOPR TSD presents the estimated
reduction in generating capacity in 2044 for the TSLs that DOE
considered in this rulemaking.
Energy savings from standards for electric motors could also
produce environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases associated with electricity production.
Table V.18 provides DOE's estimate of cumulative emissions reductions
projected to result from the TSLs considered in this rulemaking. DOE
reports annual emissions reductions for each TSL in chapter 13 of the
NOPR TSD.
Table V.18--Cumulative Emissions Reduction Estimated for Electric Motors Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Primary Energy Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................................... 62.4 374.1 576.0 733.3
NOX (thousand tons)............................................. 105.3 669.7 1,034.7 1,315.5
SO2 (thousand tons)............................................. 33.5 196.3 301.9 384.5
Hg (tons)....................................................... 0.1 0.8 1.3 1.6
N2O (thousand tons)............................................. 1.2 8.3 12.9 16.4
CH4 (thousand tons)............................................. 7.3 46.3 71.6 91.0
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................................... 3.5 22.0 34.0 43.2
NOX (thousand tons)............................................. 0.8 4.7 7.3 9.3
SO2 (thousand tons)............................................. 48.6 303.1 467.8 595.0
Hg (tons)....................................................... 0.0 0.0 0.0 0.0
N2O (thousand tons)............................................. 0.0 0.2 0.3 0.4
CH4 (thousand tons)............................................. 294.8 1,841.4 2,841.9 3,614.6
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................................... 65.9 396.1 610.0 776.5
NOX (thousand tons)............................................. 106.0 674.4 1,042.0 1,324.8
SO2 (thousand tons)............................................. 82.1 499.4 769.6 979.5
Hg (tons)....................................................... 0.1 0.8 1.3 1.6
N2O (thousand tons)............................................. 1.3 8.5 13.2 16.8
CH4 (thousand tons)............................................. 302.2 1,887.7 2,913.5 3,705.5
----------------------------------------------------------------------------------------------------------------
As part of the analysis for this rule, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2
and NOX that DOE estimated for each of the TSLs considered.
As discussed in section IV.L, DOE used values for the SCC developed by
an interagency process. The four sets of SCC values resulting from that
process (expressed in 2012$) are represented by $12.9/metric ton (the
average value from a distribution that uses a 5-percent discount rate),
$40.8/metric ton (the average value from a distribution that uses a 3-
percent discount rate), $62.2/metric ton (the average value from a
distribution that uses a 2.5-percent discount rate), and $117.0/metric
ton (the 95th-percentile value from a distribution that uses a 3-
percent discount rate). These values correspond to the value of
emission reductions in 2015; the values for later years are higher due
to increasing damages as the projected magnitude of climate change
increases.
Table V.19 presents the global value of CO2 emissions
reductions at each TSL. For each of the four cases, DOE calculated a
present value of the stream of annual values using the same discount
rate as was used in the studies upon which the dollar-per-ton values
are based. DOE calculated domestic values as a range from 7 percent to
23 percent of the global values, and these results are presented in
chapter 14 of the NOPR TSD.
[[Page 73663]]
Table V.19--Estimates of Global Present Value of CO2 Emissions Reduction Under Electric Motors Trial Standard
Levels
[Million 2012$]
----------------------------------------------------------------------------------------------------------------
SCC Case *
---------------------------------------------------------------
TSL 5% discount 3% discount 2.5% discount 3% discount
rate, average rate, average rate, average rate, 95th
* * * percentile *
----------------------------------------------------------------------------------------------------------------
Primary Energy Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 433 1,961 3,113 6,040
2............................................... 2,366 11,179 17,876 34,552
3............................................... 3,622 17,159 27,452 53,047
4............................................... 4,622 21,871 34,985 67,609
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 24 110 174 338
2............................................... 136 650 1,042 2,012
3............................................... 209 1,001 1,604 3,097
4............................................... 266 1,274 2,042 3,943
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 457 2,071 3,287 6,378
2............................................... 2,502 11,829 18,918 36,564
3............................................... 3,831 18,159 29,056 56,143
4............................................... 4,888 23,145 37,027 71,552
----------------------------------------------------------------------------------------------------------------
\*\ For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and
$117.0 per metric ton (2012$).
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other greenhouse gas (GHG) emissions
to changes in the future global climate and the potential resulting
damages to the world economy continues to evolve rapidly. Thus, any
value placed on reducing CO2 emissions in this rulemaking is
subject to change. DOE, together with other Federal agencies, will
continue to review various methodologies for estimating the monetary
value of reductions in CO2 and other GHG emissions. This
ongoing review will consider the comments on this subject that are part
of the public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this proposed rule the
most recent values and analyses resulting from the ongoing interagency
review process.
DOE also estimated a range for the cumulative monetary value of the
economic benefits associated with NOX emissions reductions
anticipated to result from new and amended standards for electric
motors. The low and high dollar-per-ton values that DOE used are
discussed in section IV.L present the cumulative present values for
each TSL calculated using seven-percent and three-percent discount
rates.
Table V.20--Estimates of Present Value of NOX Emissions Reduction Under
Electric Motors Trial Standard Levels
[Million 2012$]
------------------------------------------------------------------------
3% discount 7% discount
TSL rate rate
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1....................................... 49.5 26.4
2....................................... 257.1 120.2
3....................................... 392.2 181.6
4....................................... 501.3 233.2
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1....................................... 68.0 33.8
2....................................... 378.4 164.8
3....................................... 579.9 250.3
4....................................... 739.7 320.6
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
1....................................... 117.5 60.2
2....................................... 635.4 285.0
3....................................... 972.2 432.0
4....................................... 1,241.0 553.8
------------------------------------------------------------------------
7. Summary of National Economic Impacts
The NPV of the monetized benefits associated with emissions
reductions can be viewed as a complement to the NPV of the customer
savings calculated for each TSL considered in this rulemaking. Table
V.21 presents the NPV values that result from adding the estimates of
the potential economic benefits resulting from reduced CO2
and NOX emissions in each of four valuation scenarios to the
NPV of customer savings calculated for each TSL considered in this
rulemaking, at both a seven-percent and three-percent discount rate.
The CO2 values used in the columns of each table correspond
to the four sets of SCC values discussed above.
[[Page 73664]]
Table V.21--Net Present Value of Customer Savings Combined With Net Present Value of Monetized Benefits From CO2
and NOX Emissions Reductions
[Billion 2012$]
----------------------------------------------------------------------------------------------------------------
SCC Case $11.8/ SCC Case $39.7/ SCC Case $61.2/ SCC Case $117.0/
metric ton CO2* metric ton CO2* metric ton CO2* metric ton CO2*
TSL and low value and medium and medium and high value
for NOX** value for NOX** value for NOX** for NOX**
----------------------------------------------------------------------------------------------------------------
Customer NPV at 3% discount rate added with:
-----------------------------------------------------------------------
1....................................... 6.3 8.0 9.2 12.4
2....................................... 25.9 35.7 42.8 61.0
3....................................... 7.0 22.1 33.0 60.9
4....................................... -37.3 -18.0 -4.1 31.4
----------------------------------------------------------------------------------------------------------------
Customer NPV at 7% discount rate added with:
-----------------------------------------------------------------------
1....................................... 3.2 4.8 6.1 9.2
2....................................... 11.2 20.8 27.9 45.7
3....................................... 0.5 15.2 26.1 53.5
4....................................... -25.3 -6.6 7.3 42.3
----------------------------------------------------------------------------------------------------------------
* These label values represent the global SCC in 2015, in 2012$.
** Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton, and High
Value corresponds to $4,809 per ton.
Although adding the value of customer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. customer monetary savings that occur as a result of market
transactions, while the value of CO2 reductions is based on
a global value. Second, the assessments of operating cost savings and
the SCC are performed with different methods that use quite different
time frames for analysis. The national operating cost savings is
measured for the lifetime of equipment shipped in 2015-2044. The SCC
values, on the other hand, reflect the present value of future climate-
related impacts resulting from the emission of one metric ton of
CO2 in each year. These impacts continue well beyond 2100.
8. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) No
other factors were considered in this analysis.
C. Proposed Standards
When considering proposed standards, the new or amended energy
conservation standard that DOE adopts for any type (or class) of
covered equipment shall be designed to achieve the maximum improvement
in energy efficiency that the Secretary of Energy determines is
technologically feasible and economically justified. (42 U.S.C.
6295(o)(2)(A) and 6316(a)) In determining whether a standard is
economically justified, the Secretary must determine whether the
benefits of the standard exceed its burdens to the greatest extent
practicable, considering the seven statutory factors discussed
previously. (42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) The new or amended
standard must also ``result in significant conservation of energy.''
(42 U.S.C. 6295(o)(3)(B) and 6316(a))
For today's NOPR, DOE considered the impacts of standards at each
TSL, beginning with the max-tech level, to determine whether that level
was economically justified. Where the max-tech level was not justified,
DOE then considered the next most efficient level and undertook the
same evaluation until it reached the highest efficiency level that is
technologically feasible, economically justified and saves a
significant amount of energy. Throughout this process DOE also
considered the recommendations made by the Motors Coalition and other
stakeholders in their submitted comments. For more details on the
Motors Coalition see Section II.B.2.
To aid the reader in understanding the benefits and/or burdens of
each TSL, tables in this section summarize the quantitative analytical
results for each TSL, based on the assumptions and methodology
discussed herein. The efficiency levels contained in each TSL are
described in section V.A. In addition to the quantitative results
presented in the tables, DOE also considers other burdens and benefits
that affect economic justification. These include the impacts on
identifiable subgroups of customers who may be disproportionately
affected by a national standard, and impacts on employment. Section
V.B.1.b presents the estimated impacts of each TSL for the considered
subgroup. DOE discusses the impacts on employment in electric motor
manufacturing in section V.B.2.b, and discusses the indirect employment
impacts in section V.B.3.c.
1. Benefits and Burdens of Trial Standard Levels Considered for
Electric Motors
Table V.22 and Table V.23 summarize the quantitative impacts
estimated for each TSL for electric motors.
Table V.22--Summary of Analytical Results for Electric Motors: National Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
National Full-Fuel-Cycle Energy
Savings quads:
1.1............... 7.0............... 10.8.............. 13.7
NPV of Consumer Benefits 2012$
billion:
[[Page 73665]]
3% discount rate............ 5.8............... 23.3.............. 3.0............... -42.4
7% discount rate............ 2.7............... 8.7............... -3.4.............. -30.3
Cumulative Emissions Reduction
(Total FFC Emissions):
CO2 million metric tons..... 65.9.............. 396.1............. 610.0............. 776.5
SO2 thousand tons........... 106.0............. 674.4............. 1,042.0........... 1,324.8
NOX thousand tons........... 82.1.............. 499.4............. 769.6............. 979.5
Hg tons..................... 0.1............... 0.8............... 1.3............... 1.6
N2O thousand tons........... 1.3............... 8.5............... 13.2.............. 16.8
CH4 thousand tons........... 302.2............. 1,887.7........... 2,913.5........... 3,705.5
Value of Emissions Reduction
(Total FFC Emissions):
CO2 2012$ million*.......... 457 to 6,378...... 2,502 to 36,564... 3,831 to 56,143... 4,888 to 71,552
NOX--3% discount rate 2012$ 117.5............. 635.4............. 972.2............. 1,241.0
million.
NOX--7% discount rate 2012$ 60.2.............. 285.0............. 432.0............. 553.8
million.
----------------------------------------------------------------------------------------------------------------
* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2
emissions.
Table V.23--Summary of Analytical Results for Electric Motors: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts:
Industry NPV 2012$ million.................. 3,378.7- 3,759.2- 4,443.7- 5,241.3-
3,019.5 3,087.6 2,356.8 1,383.1
Industry NPV % change....................... 0.2-(10.4) 11.5-(8.4) 31.8-(30.1) 55.5-(59.0)
Consumer Mean LCC Savings * 2012$:
Equipment Class Group 1..................... 43 132 68 -417
Equipment Class Group 2..................... 38 38 -285 -285
Equipment Class Group 3..................... N/A ** N/A ** -61 -763
Equipment Class Group 4..................... 137 259 210 -291
Consumer Median PBP * years:
Equipment Class Group 1..................... 1.1 3.3 6.7 29.9
Equipment Class Group 2..................... 5.0 5.0 22.8 22.8
Equipment Class Group 3..................... N/A ** N/A ** 3,299 11,957
Equipment Class Group 4..................... 1.2 1.9 3.7 16.0
Equipment Class Group 1:
Net Cost %.................................. 0.3 8.4 38.0 84.6
Net Benefit %............................... 9.7 32.0 40.4 7.6
No Impact %................................. 90.0 59.6 21.5 7.7
Equipment Class Group 2:
Net Cost %.................................. 21.5 21.5 94.7 94.7
Net Benefit %............................... 68.6 68.6 5.3 5.3
No Impact %................................. 9.9 9.9 0.0 0.0
Equipment Class Group 3:
Net Cost (%)................................ 0.0 0.0 81.7 100.0
Net Benefit (%)............................. 0.0 0.0 0.0 0.0
No Impact (%)............................... 0.0 0.0 18.3 0.0
Equipment Class Group 4:
Net Cost (%)................................ 1.0 10.8 33.1 79.6
Net Benefit (%)............................. 31.8 60.8 65.8 19.9
No Impact (%)............................... 67.3 28.4 1.1 0.3
----------------------------------------------------------------------------------------------------------------
** The results for each equipment class group (ECG) are a shipment weighted average of results for the
representative units in the group. ECG 1: Representative units 1, 2, and 3; ECG 2: Representative units 4 and
5; ECG 3: Representative units 6, 7, and 8; ECG 4: Representative units 9 and 10.
** For equipment class group 3, TSL 1 and 2 are the same as the baseline; thus, no customers are affected.
First, DOE considered TSL 4, the most efficient level (max tech),
which would save an estimated total of 13.7 quads of energy, an amount
DOE considers significant. TSL 4 has an estimated NPV of customer
benefit of -30.3 billion using a 7 percent discount rate, and -42.4
billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 4 are 776.5 million
metric tons of CO2, 979.5 thousand tons of NOX,
1,324.8 thousand tons of SO2, and 1.6 tons of Hg. The
estimated monetary value of the CO2 emissions reductions at
TSL 4 ranges from $4,888 million to $71,552 million.
At TSL 4, the weighted average LCC impact ranges from $-763 for ECG
3 to $-285 for ECG 2. The weighted average median PBP ranges from 16
years for ECG 4 to 11,957 years for ECG 3. The weighted average share
of customers experiencing a net LCC benefit ranges from 0 percent for
ECG 3 to 19.9 percent for ECG 4.
At TSL 4, the projected change in INPV ranges from a decrease of
$1,988.1 million to an increase of $1,870.1 million. If the decrease of
$1,988.1 million were to occur, TSL 4 could result in a net loss of 59
percent in INPV to manufacturers of covered electric motors.
In view of the foregoing, DOE concludes that, at TSL 4 for electric
[[Page 73666]]
motors, the benefits of energy savings, emission reductions, and the
estimated monetary value of the emissions reductions would be
outweighed by the potential multi-billion dollar negative net economic
cost; the economic burden on customers as indicated by the increase in
customer LCC (negative savings), large PBPs, the large percentage of
customers who would experience LCC increases; the increase in the
cumulative regulatory burden on manufacturers; and the capital and
engineering costs that could result in a large reduction in INPV for
manufacturers at TSL 4. Additionally, DOE believes that efficiency
standards at this level, could result in significant impacts on OEMs
due to larger and faster motors. Although DOE has not quantified these
potential impacts, DOE believes that it is possible that these impacts
could be significant and further reduce any potential benefits of
standards established at this TSL. Consequently, DOE has concluded that
TSL 4 is not economically justified.
Next, DOE considered TSL 3, which would save an estimated total of
10.6 quads of energy, an amount DOE considers significant. TSL 3 has an
estimated NPV of customer benefit of $-3.4 billion using a 7 percent
discount rate, and $3.0 billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 3 are 610.0 million
metric tons of CO2, 769.6 thousand tons of NOX,
1,042.0 thousand tons of SO2, and 1.3 tons of Hg. The
estimated monetary value of the CO2 emissions reductions at
TSL 4 ranges from $3,831 million to $ 56,143 million.
At TSL 3, the weighted average LCC impact ranges from $-285 for ECG
2 to $210 for ECG 4. The weighted average median PBP ranges from 3.7
years for ECG 4 to 3,299 years for ECG 3. The share of customers
experiencing a net LCC benefit ranges from 0 percent for ECG 3 to 65.8
percent for ECG 4.
At TSL 3, the projected change in INPV ranges from a decrease of
$1,014,4 million to an increase of $1,072.5 million. If the decrease of
$1,014.4 million were to occur, TSL 3 could result in a net loss of
30.1 percent in INPV to manufacturers of covered electric motors.
In view of the foregoing, DOE concludes that, at TSL 3 for electric
motors, the benefits of energy savings, positive weighted average
customer LCC savings for some ECGs, generating capacity reductions,
emission reductions, and the estimated monetary value of the emissions
reductions would be outweighed by the potential negative net economic
cost; the economic burden on customers as indicated by the increase in
weighted average LCC for some ECGs (negative savings), large PBPs, the
large percentage of customers who would experience LCC increases; the
increase in the cumulative regulatory burden on manufacturers; and the
capital and engineering costs that could result in a large reduction in
INPV for manufacturers at TSL 3. Additionally, DOE believes that
efficiency standards at this level could result in significant impacts
on OEMs due to larger and faster motors. Although DOE has not
quantified these potential impacts, DOE believes that it is possible
that these impacts could be significant and further reduce any
potential benefits of standards established at this TSL. Consequently,
DOE has concluded that TSL 3 is not economically justified.
Next, DOE considered TSL 2, which would save an estimated total of
7.0 quads of energy, an amount DOE considers significant. TSL 2 has an
estimated NPV of customer benefit of $8.7 billion using a 7 percent
discount rate, and $23.3 billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 2 are 396.1 million
metric tons of CO2, 674.4 thousand tons of NOX,
499.4 thousand tons of SO2, and 0.8 tons of Hg. The
estimated monetary value of the CO2 emissions reductions at
TSL 4 ranges from $2,502 million to $36,564 million.
At TSL 2, the weighted average LCC impact ranges from no impacts
for ECG 3 to $259 for ECG 4. The weighted average median PBP ranges
from 0 years for ECG 3 to 5 years for ECG 2. The share of customers
experiencing a net LCC benefit ranges from 0 percent for ECG 3 to 68.6
percent for ECG 2. The share of motors already at TSL 2 efficiency
levels varies by equipment class group and by horsepower range (from 0
to 62 percent). For ECG 1, which represents the most significant share
of the market, about 30 percent of motors meet the TSL 2 levels.
At TSL 2, the projected change in INPV ranges from a decrease of
$283.5 million to an increase of $388 million. If the decrease of
$283.5 million were to occur, TSL 2 could result in a net loss of 8.4
percent in INPV to manufacturers of covered electric motors.
After considering the analysis and weighing the benefits and the
burdens, DOE has tentatively concluded that at TSL 2 for electric
motors, the benefits of energy savings, positive NPV of customer
benefit, positive impacts on consumers (as indicated by positive
weighted average LCC savings for all ECGs impacted at TSL 2, favorable
PBPs, and the large percentage of customers who would experience LCC
benefits, emission reductions, and the estimated monetary value of the
emissions reductions would outweigh the slight increase in the
cumulative regulatory burden on manufacturers and the risk of small
negative impacts if manufacturers are unable to recoup investments made
to meet the standard. In particular, the Secretary of Energy has
concluded that TSL 2 would save a significant amount of energy and is
technologically feasible and economically justified.
In addition, DOE notes that TSL 2 most closely corresponds to the
standards that were proposed by the Motor Coalition, as described in
section II.B.2. Based on the above considerations, DOE today proposes
to adopt the energy conservation standards for electric motors at TSL
2. Table V.24 through Table V.27 present the proposed energy
conservation standards for electric motors.
Table V.24--Proposed Energy Conservation Standards for NEMA Design A and NEMA Design B Electric Motors
[Compliance starting December 19, 2015]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-------------------------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt equivalent 2 Pole 4 Pole 6 Pole 8 Pole
-------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75........................................... 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1......................................... 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5........................................... 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5
[[Page 73667]]
3/2.2........................................... 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7........................................... 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5......................................... 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5.......................................... 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2
15/11........................................... 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2
20/15........................................... 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5......................................... 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0
30/22........................................... 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7
40/30........................................... 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7
50/37........................................... 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4
60/45........................................... 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0
75/55........................................... 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1
100/75.......................................... 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1
125/90.......................................... 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1
150/110......................................... 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1
200/150......................................... 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1
250/186......................................... 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0
300/224......................................... 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0
350/261......................................... 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0
400/298......................................... 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0
450/336......................................... 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
500/373......................................... 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.25--Proposed Energy Conservation Standards for NEMA Design C Electric Motors
[Compliance starting December 19, 2015]
----------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-----------------------------------------------------------------------------
Motor horsepower/standard kilowatt 4 Pole 6 Pole 8 Pole
equivalent -----------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open
----------------------------------------------------------------------------------------------------------------
1/.75............................. 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1........................... 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5............................. 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2............................. 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7............................. 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5........................... 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5............................ 91.7 91.7 91.0 91.7 89.5 90.2
15/11............................. 92.4 93.0 91.7 91.7 89.5 90.2
20/15............................. 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5........................... 93.6 93.6 93.0 93.0 90.2 91.0
30/22............................. 93.6 94.1 93.0 93.6 91.7 91.7
40/30............................. 94.1 94.1 94.1 94.1 91.7 91.7
50/37............................. 94.5 94.5 94.1 94.1 92.4 92.4
60/45............................. 95.0 95.0 94.5 94.5 92.4 93.0
75/55............................. 95.4 95.0 94.5 94.5 93.6 94.1
100/75............................ 95.4 95.4 95.0 95.0 93.6 94.1
125/90............................ 95.4 95.4 95.0 95.0 94.1 94.1
150/110........................... 95.8 95.8 95.8 95.4 94.1 94.1
200/150........................... 96.2 95.8 95.8 95.4 94.5 94.1
----------------------------------------------------------------------------------------------------------------
Table V.26--Proposed Energy Conservation Standards for Fire Pump Electric Motors
[Compliance starting December 19, 2015]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-------------------------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt equivalent 2 Pole 4 Pole 6 Pole 8 Pole
-------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75........................................... 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0
1.5/1.1......................................... 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5
2/1.5........................................... 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5
[[Page 73668]]
3/2.2........................................... 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5
5/3.7........................................... 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5
7.5/5.5......................................... 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5
10/7.5.......................................... 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5
15/11........................................... 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5
20/15........................................... 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2
25/18.5......................................... 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2
30/22........................................... 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0
40/30........................................... 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0
50/37........................................... 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7
60/45........................................... 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4
75/55........................................... 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6
100/75.......................................... 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6
125/90.......................................... 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6
150/110......................................... 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6
200/150......................................... 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6
250/186......................................... 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5
300/224......................................... 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5
350/261......................................... 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5
400/298......................................... 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5
450/336......................................... 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5
500/373......................................... 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V.27--Proposed Energy Conservation Standards for Brake Motors
[Compliance starting December 19, 2015]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-----------------------------------------------------------------------------------------------------------
Motor horsepower/standard kilowatt 4 Pole 6 Pole 8 Pole
equivalent -----------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75....................................... 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1..................................... 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5....................................... 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2....................................... 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7....................................... 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5..................................... 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5...................................... 91.7 91.7 91.0 91.7 89.5 90.2
15/11....................................... 92.4 93.0 91.7 91.7 89.5 90.2
20/15....................................... 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5..................................... 93.6 93.6 93.0 93.0 90.2 91.0
30/22....................................... 93.6 94.1 93.0 93.6 91.7 91.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
2. Summary of Benefits and Costs (Annualized) of the Proposed Standards
The benefits and costs of today's proposed standards, for equipment
sold in 2015-2044, can also be expressed in terms of annualized values.
The annualized monetary values are the sum of: (1) The annualized
national economic value of the benefits from consumer operation of
equipment that meet the proposed standards (consisting primarily of
operating cost savings from using less energy, minus increases in
equipment purchase and installation costs, which is another way of
representing consumer NPV), and (2) the annualized monetary value of
the benefits of emission reductions, including CO2 emission
reductions.\89\
---------------------------------------------------------------------------
\89\ DOE used a two-step calculation process to convert the
time-series of costs and benefits into annualized values. First, DOE
calculated a present value in 2013, the year used for discounting
the NPV of total consumer costs and savings, for the time-series of
costs and benefits using discount rates of three and seven percent
for all costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE then calculated the
fixed annual payment over a 30-year period (2015 through 2044) that
yields the same present value. The fixed annual payment is the
annualized value. Although DOE calculated annualized values, this
does not imply that the time-series of cost and benefits from which
the annualized values were determined is a steady stream of
payments.
---------------------------------------------------------------------------
Although combining the values of operating savings and
CO2 emission reductions provides a useful perspective, two
issues should be considered. First, the national operating savings are
domestic U.S. consumer monetary savings that occur as a result of
market transactions while the value of CO2 reductions is
based on a global value. Second, the assessments of operating cost
savings and CO2 savings are performed with different methods
that use different time frames for analysis. The national operating
cost savings is measured for the lifetime of electric motors shipped in
2015 -2044. The SCC values, on the other hand, reflect the present
value of some future
[[Page 73669]]
climate-related impacts resulting from the emission of one ton of
carbon dioxide in each year. These impacts continue well beyond 2100.
Estimates of annualized benefits and costs of the proposed
standards for electric motors are shown in Table V.28. The results
under the primary estimate are as follows. Using a 7-percent discount
rate for benefits and costs other than CO2 reduction, for
which DOE used a 3-percent discount rate along with the average SCC
series that uses a 3-percent discount rate, the cost of the standards
proposed in today's rule is $462 million per year in increased
equipment costs; while the estimated benefits are $1,114 million per
year in reduced equipment operating costs, $586 million in
CO2 reductions, and $21.5 million in reduced NOX
emissions. In this case, the net benefit would amount to $957 million
per year. Using a 3-percent discount rate for all benefits and costs
and the average SCC series, the estimated cost of the standards
proposed in today's rule is $577 million per year in increased
equipment costs; while the estimated benefits are $1,730 million per
year in reduced operating costs, $586 million in CO2
reductions, and $31.5 million in reduced NOX emissions. In
this case, the net benefit would amount to approximately $1,354 million
per year.
Table V.28--Annualized Benefits and Costs of Proposed Standards for Electric Motors
[million 2012$/year]
----------------------------------------------------------------------------------------------------------------
Primary estimate Low Net benefits High Net benefits
Discount rate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
Benefits:
Consumer Operating Cost 7%............... 1,114............ 924.............. 1,358.
Savings.
3%............... 1,730............ 1,421............ 2,134.
CO2 Reduction Monetized 5%............... 155.............. 134.............. 179.
Value ($11.8/t case) *.
CO2 Reduction Monetized 3%............... 586.............. 506.............. 679.
Value ($39.7/t case) *.
CO2 Reduction Monetized 2.5%............. 882.............. 762.............. 1022.
Value ($61.2/t case) *.
CO2 Reduction Monetized 3%............... 1,811............ 1,565............ 2,098.
Value $117.0/t case) *.
NOX Reduction Monetized 7%............... 21.46............ 18.55............ 24.68.
Value (at $2,639/ton) **.
3%............... 31.48............ 27.20............ 36.39.
7% plus CO2 range 1,290 to 2,947... 1,077 to 2,507... 1,562 to 3,481.
Total Benefits [dagger] 7%............... 1,721............ 1,449............ 2,061.
3% plus CO2 range 1,916 to 3,572... 1,583 to 3,014... 2,350 to 4,268.
3%............... 2,347............ 1,955............ 2,849.
Costs:
Consumer Incremental 7%............... 462.............. 492.............. 447.
Equipment Costs.
3%............... 577.............. 601.............. 569.
Net Benefits:
7% plus CO2 range 585 to 2,016..... 1,115 to 3,033... 1,353 to 3,438.
7%............... 957.............. 1,614............ 1,887.
Total [dagger]......... 3% plus CO2 range 982 to 2,413..... 1,781 to 3,700... 1,957 to 4,043.
3%............... 1,354............ 2,280............ 2,492.
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with electric motors shipped in 2015-2044.
These results include benefits to consumers which accrue after 2044 from the equipment purchased in years 2015-
2044. Costs incurred by manufacturers, some of which may be incurred in preparation for the rule, are not
directly included, but are indirectly included as part of incremental equipment costs. The Primary, Low
Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy
Outlook (AEO) 2013 Reference case, Low Estimate, and High Estimate, respectively. In addition, incremental
equipment costs reflect a medium constant projected equipment price in the Primary Estimate, a decline rate
for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected
equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are
explained in section IV.F.1.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values
are based on the average SCC from the three integrated assessment models, at discount rates of 2.5, 3, and 5
percent. The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-
percent discount rate, is included to represent higher-than-expected impacts from temperature change further
out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time
series incorporate an escalation factor. The value for NOX is the average of the low and high values used in
DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to
average SCC with 3-percent discount rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,''
the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added
to the full range of CO2 values.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that today's standards address are as follows:
(1) There are external benefits resulting from improved energy
efficiency of covered electric motors which are not captured by the
users of such equipment. These benefits include externalities related
to environmental protection and energy security that are not reflected
in energy prices, such as emissions of greenhouse gases. DOE attempts
to quantify some of the external benefits through use of Social Cost of
Carbon values.
In addition, DOE has determined that today's regulatory action is
an ``economically significant regulatory action'' under section 3(f)(1)
of Executive Order 12866. Accordingly,
[[Page 73670]]
section 6(a)(3) of the Executive Order requires that DOE prepare a
regulatory impact analysis (RIA) on today's rule and that the Office of
Information and Regulatory Affairs (OIRA) in the Office of Management
and Budget (OMB) review this rule. DOE presented to OIRA for review the
draft rule and other documents prepared for this rulemaking, including
the RIA, and has included these documents in the rulemaking record. The
assessments prepared pursuant to Executive Order 12866 can be found in
the technical support document for this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563
is supplemental to and explicitly reaffirms the principles, structures,
and definitions governing regulatory review established in Executive
Order 12866. To the extent permitted by law, agencies are required by
Executive Order 13563 to: (1) Propose or adopt a regulation only upon a
reasoned determination that its benefits justify its costs (recognizing
that some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, the Office of Information and Regulatory Affairs has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. For the reasons stated in the preamble,
DOE believes that today's NOPR is consistent with these principles,
including the requirement that, to the extent permitted by law,
benefits justify costs and that net benefits are maximized.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990 DOE has made its
procedures and policies available on the Office of the General
Counsel's Web site (https://energy.gov/gc/office-general-counsel).
DOE has prepared an IRFA for this rulemaking, a copy of which DOE
will transmit to the Chief Counsel for Advocacy of the SBA for review
under 5 U.S.C. 605(b). As presented and discussed below, the IFRA
describes potential impacts on electric motors manufacturers associated
with capital and product conversion costs and discusses alternatives
that could minimize these impacts.
A statement of the objectives of, and reasons and legal basis for,
the proposed rule are set forth elsewhere in the preamble and not
repeated here.
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
For manufacturers of electric motors, the Small Business
Administration (SBA) has set a size threshold, which defines those
entities classified as ``small businesses'' for the purposes of the
statute. DOE used the SBA's small business size standards to determine
whether any small entities would be subject to the requirements of the
rule. The size standards are listed by North American Industry
Classification System (NAICS) code and industry description available
at: https://www.sba.gov/content/table-small-business-size-standards.
Electric motor manufacturing is classified under NAICS 335312, ``Motor
and Generator Manufacturing.'' The SBA sets a threshold of 1,000
employees or less for an entity to be considered as a small business
for this category.
To estimate the number of companies that could be small business
manufacturers of equipment covered by this rulemaking, DOE conducted a
market survey using publicly available information. DOE's research
involved industry trade association membership directories (including
NEMA), information from previous rulemakings, UL qualification
directories, individual company Web sites, and market research tools
(e.g., Hoover's reports). DOE also asked stakeholders and industry
representatives if they were aware of any other small manufacturers
during manufacturer interviews and DOE public meetings. DOE used
information from these sources to create a list of companies that
potentially manufacture electric motors covered by this rulemaking. As
necessary, DOE contacted companies to determine whether they met the
SBA's definition of a small business manufacturer. DOE screened out
companies that do not offer equipment covered by this rulemaking, do
not meet the definition of a ``small business,'' or are foreign owned
and operated.
DOE initially identified 60 potential manufacturers of electric
motors sold in the U.S. After reviewing publicly available information
DOE contacted 27 of the companies that DOE suspected were small
business manufacturers to determine whether they met the SBA definition
of a small business and whether they manufactured the equipment that
would be affected by today's proposal. Based on these efforts, DOE
estimates that there are 13 small business manufacturers of electric
motors.
b. Manufacturer Participation
DOE contacted the 13 identified small businesses to invite them to
take part in a small business manufacturer impact analysis interview.
Of the electric motor manufacturers DOE contacted, 10 responded and
three did not. Eight of the 10 responding manufacturers declined to be
interviewed. Therefore, DOE was able to reach and discuss potential
standards with two of the 13 small business manufacturers. DOE also
obtained information about small business manufacturers and potential
impacts while interviewing large manufacturers.
c. Electric Motor Industry Structure and Nature of Competition
Eight major manufacturers supply approximately 90 percent of the
market for electric motors. None of the major manufacturers of electric
motors
[[Page 73671]]
covered in this rulemaking is a small business. DOE estimates that
approximately 50 percent of the market is served by imports. Many of
the small businesses that compete in the electric motor market produce
specialized motors, many of which have not been regulated under
previous standards. Most of these low-volume manufacturers do not
compete directly with large manufacturers and tend to occupy niche
markets for their equipment. There are a few small business
manufacturers that produce general purpose motors; however, these
motors currently meet NEMA Premium efficiency levels, the efficiency
levels being proposed in today's notice.
d. Comparison Between Large and Small Entities
For electric motors, small manufacturers differ from large
manufacturers in several ways that affect the extent to which a
manufacturer would be impacted by proposed standards. Characteristics
of small manufacturers include: lower production volumes, fewer
engineering resources, less technical expertise, and less access to
capital.
Lower production volumes lie at the heart of most small business
disadvantages, particularly for a small manufacturer that is vertically
integrated. A lower-volume manufacturer's conversion costs would need
to be spread over fewer units than a larger competitor. Thus, unless
the small business can differentiate its product in some way that earns
a price premium, the small business is a `price taker' and experiences
a reduction in profit per unit relative to the large manufacturer.
Therefore, because much of the same equipment would need to be
purchased by both large and small manufacturers in order to produce
electric motors at higher TSLs, undifferentiated small manufacturers
would face a greater variable cost penalty because they must depreciate
the one-time conversion expenditures over fewer units.
Smaller companies are also more likely to have more limited
engineering resources and they often operate with lower levels of
design and manufacturing sophistication. Smaller companies typically
also have less experience and expertise in working with more advanced
technologies. Standards that required these technologies could strain
the engineering resources of these small manufacturers if they chose to
maintain a vertically integrated business model. Small business
electric motor manufacturers can also be at a disadvantage due to their
lack of purchasing power for high performance materials. For example,
more expensive low-loss steels are needed to meet higher efficiency
standards and steel cost grows as a percentage of the overall product
cost. Small manufacturers who pay higher per pound prices would be
disproportionately impacted by these prices.
Lastly, small manufacturers typically have less access to capital,
which may be needed by some to cover the conversion costs associated
with new technologies.
2. Description and Estimate of Compliance Requirements
In its market survey, DOE identified three categories of small
business electric motor manufacturers that may be impacted differently
by today's proposed rule. The first group, which includes approximately
five of the 13 small businesses, consists of manufacturers that produce
specialty motors that were not required to meet previous Federal
standards, but would need to do so under the expanded scope of today's
proposed rule. DOE believes that this group would likely be the most
impacted by expanding the scope of equipment required to meet NEMA
Premium efficiency levels. The second group, which includes
approximately five different small businesses, consists of
manufacturers that produce a small amount of covered equipment and
primarily focus on other types of motors not covered in this
rulemaking, such as single-phase or direct-current motors. Because
generally less than 10 percent of these manufacturers' revenue comes
from covered equipment, DOE does not believe new standards will
substantially impact their business. The third group, which includes
approximately three small businesses, consists of manufacturers that
already offer NEMA Premium general purpose and specialty motors. DOE
expects these manufacturers to face similar conversion costs as large
manufacturers, in that they will not experience high capital conversion
costs as they already have the design and production experience
necessary to bring their motors up to NEMA Premium efficiency levels.
It is likely, however, that some of the specialty equipment these
manufacturers produce will be included in the expanded scope of this
proposed rule and is likely to result in these small businesses
incurring additional certification and testing costs. These
manufacturers could also face product development costs if they have to
redesign any motors that are not currently meeting the NEMA Premium
level.
At TSL 2, the level proposed in today's notice, DOE estimates
capital conversion costs of $1.88 million and product conversion costs
of $3.75 million for a typical small manufacturer in the first group
(manufacturers that produce specialized motors previously not covered
by Federal standards). Meanwhile, DOE estimates a typical large
manufacturer would incur capital and product conversion costs of $3.29
million and $7.25 million, respectively, at the same TSL. Small
manufacturers that predominately produce specialty motors would face
higher relative capital conversion costs at TSL 2 than large
manufacturers because large manufacturers have been independently
pursuing higher efficiency motors as a result of the efficiency
standards prescribed by EISA 2007 (10 CFR part 431.25) and consequently
have built up more design and production experience. Large
manufacturers have also been innovating as a result of the small
electric motors rulemaking at 75 FR 10874 (March 9, 2010), which
exempted many of the specialized equipment that these small business
manufacturers produce. Many large manufacturers of general purpose
motors offer equipment that was covered by the 2010 small electric
motors rule, as well as equipment that falls under this proposed rule.
Small manufactures pointed out that this would give large manufacturers
an advantage in that they already have experience with the technology
necessary to redesign their equipment and are familiar with the steps
they will have to take to upgrade their manufacturing equipment and
processes. Small manufactures, whose specialized motors were not
required to meet the standards prescribed by the small electric motors
rule and EISA 2007 have not undergone these processes and, therefore,
would have to put more time and resources into redesign efforts.
The small businesses whose product lines consist of a high
percentage of equipment that are not currently required to meet
efficiency standards would need to make significant capital investments
relative to large manufacturers to upgrade their production lines with
equipment necessary to produce NEMA Premium motors. As Table VI.1
illustrates, these manufacturers would have to drastically increase
their capital expenditures to purchase new lamination die sets, and new
winding and stacking equipment.
[[Page 73672]]
Table VI.1--Estimated Capital and Product Conversion Costs as a Percentage of Annual Capital Expenditures and
R&D Expense
----------------------------------------------------------------------------------------------------------------
Capital Product Total conversion
conversion cost conversion cost cost as a
as a percentage as a percentage percentage of
of annual capital of annual R&D annual revenue
expenditures (%) expense (%) (%)
----------------------------------------------------------------------------------------------------------------
Typical Large Manufacturer............................. 14 31 2
Typical Small Manufacturer............................. 188 490 75
----------------------------------------------------------------------------------------------------------------
Table VI.1 also illustrates that small manufacturers whose product
lines contain many motors that are not currently required to meet
Federal standards face high relative product conversion costs compared
to large manufacturers, despite the lower dollar value. In interviews,
these small manufacturers expressed concern that they would face a
large learning curve relative to large manufacturers, due to the fact
that many of the equipment they produce has not had to meet Federal
standards. In its market survey, DOE learned that for some
manufacturers, the expanded scope of specialized motors that would have
to meet NEMA Premium could affect nearly half the equipment they offer.
They would need to hire additional engineers and would have to spend
considerable time and resources redesigning their equipment and
production processes. DOE does not expect the small businesses that
already manufacture NEMA Premium equipment or those that offer very few
alternating-current motors to incur these high costs.
Manufacturers also expressed concern about testing and
certification costs associated with new standards. They pointed out
that these costs are particularly burdensome on small businesses that
produce a wide variety of specialized equipment. As a result of the
wide variety of equipment they produce and their relatively low output,
small manufacturers are forced to certify multiple small batches of
motors, the costs of which need to be spread out over far fewer units
than large manufacturers.
Small manufacturers that produce equipment not currently required
to meet efficiency standards also pointed out that they would face
significant challenges supporting current business while making changes
to their production lines. While large manufacturers could shift
production of certain equipment to different plants or product lines
while they made updates, small businesses would have limited options.
Most of these small businesses have only one plant and would have to
find a way to continue to fulfill customer needs while redesigning
production lines and installing new equipment. In interviews with DOE,
small manufacturers said that it would be difficult to quantify the
impacts that downtime and the possible need for external support could
have on their businesses.
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the rule being considered today.
4. Significant Alternatives to the Proposed Rule
The discussion above analyzes impacts on small businesses that
would result from the TSL DOE is proposing in today's notice. Though
TSLs lower than the proposed TSL are expected to reduce the impacts on
small entities, DOE is required by EPCA to establish standards that
achieve the maximum improvement in energy efficiency that are
technically feasible and economically justified, and result in a
significant conservation of energy. Therefore, DOE rejected the lower
TSLs.
In addition to the other TSLs being considered, the NOPR TSD
includes a regulatory impact analysis in chapter 17. For electric
motors, this report discusses the following policy alternatives: (1)
Consumer rebates, (2) consumer tax credits, and (3) manufacturer tax
credits. DOE does not intend to consider these alternatives further
because they either are not feasible to implement or are not expected
to result in energy savings as large as those that would be achieved by
the standard levels under consideration.
DOE continues to seek input from businesses that would be affected
by this rulemaking and will consider comments received in the
development of any final rule.
5. Significant Issues Raised by Public Comments
DOE's MIA suggests that, while TSL 2 presents greater difficulties
for small businesses than lower efficiency levels, the business impacts
at higher TSLs would be greater. DOE expects that most small businesses
will generally be able to maintain profitability at the TSL proposed in
today's rulemaking. It is possible, however, that the small
manufacturers whose product lines consist of a high percentage of
previously exempted motors could incur significant costs as a result of
this proposed rule, and those high costs could endanger their business.
DOE's MIA is based on its interviews of both small and large
manufacturers, and consideration of small business impacts explicitly
enters into DOE's choice of the TSLs proposed in this NOPR.
DOE did not receive any public comments suggesting that small
businesses would not be able to achieve the efficiency levels at TSL 2.
C. Review Under the Paperwork Reduction Act
Manufacturers of electric motors that are currently subject to
energy conservation standards must certify to DOE that their equipment
comply with any applicable energy conservation standards. In certifying
compliance, manufacturers must test their equipment according to the
DOE test procedures for electric motors, including any amendments
adopted for those test procedures. The collection-of-information
requirement for the certification and recordkeeping is subject to
review and approval by OMB under the Paperwork Reduction Act (PRA).
This requirement has been approved by OMB under OMB control number
1910-1400. Public reporting burden for the certification is estimated
to average 20 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information. DOE intends to address revised certification
requirements for electric motors in a separate rulemaking.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be
[[Page 73673]]
subject to a penalty for failure to comply with, a collection of
information subject to the requirements of the PRA, unless that
collection of information displays a currently valid OMB Control
Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that the proposed rule fits within the category of
actions included in Categorical Exclusion (CX) B5.1 and otherwise meets
the requirements for application of a CX. See 10 CFR Part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). The proposed rule fits
within the category of actions because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, and for which none of the exceptions identified
in CX B5.1(b) apply. Therefore, DOE has made a CX determination for
this rulemaking, and DOE does not need to prepare an Environmental
Assessment or Environmental Impact Statement for this proposed rule.
DOE's CX determination for this proposed rule is available at https://cxnepa.energy.gov/.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism.'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on Federal agencies formulating and
implementing policies or regulations that preempt State law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the States and
to carefully assess the necessity for such actions. The Executive Order
also requires agencies to have an accountable process to ensure
meaningful and timely input by State and local officials in the
development of regulatory policies that have Federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations. 65 FR 13735. EPCA governs and
prescribes Federal preemption of State regulations as to energy
conservation for the equipment that are the subject of today's proposed
rule. States can petition DOE for exemption from such preemption to the
extent, and based on criteria, set forth in EPCA. (42 U.S.C. 6297) No
further action is required by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on Federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity; (2) write regulations to minimize litigation; and (3)
provide a clear legal standard for affected conduct rather than a
general standard and promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Section 3(b) of Executive Order 12988 specifically
requires that Executive agencies make every reasonable effort to ensure
that the regulation: (1) Clearly specifies the preemptive effect, if
any; (2) clearly specifies any effect on existing Federal law or
regulation; (3) provides a clear legal standard for affected conduct
while promoting simplification and burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately defines key terms; and (6)
addresses other important issues affecting clarity and general
draftsmanship under any guidelines issued by the Attorney General.
Section 3(c) of Executive Order 12988 requires Executive agencies to
review regulations in light of applicable standards in section 3(a) and
section 3(b) to determine whether they are met or it is unreasonable to
meet one or more of them. DOE has completed the required review and
determined that, to the extent permitted by law, this proposed rule
meets the relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by State, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. DOE's policy
statement is also available at https://energy.gov/gc/downloads/unfunded-mandates-reform-act-intergovernmental-consultation.
Although today's proposed rule does not contain a Federal
intergovernmental mandate, it may require expenditures of $100 million
or more on the private sector. Specifically, the proposed rule will
likely result in a final rule that could require expenditures of $100
million or more. Such expenditures may include: (1) Investment in
research and development and in capital expenditures by electric motor
manufacturers in the years between the final rule and the compliance
date for the new standards, and (2) incremental additional expenditures
by consumers to purchase higher-efficiency electric motors, starting at
the compliance date for the applicable standard.
Section 202 of UMRA authorizes a Federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the proposed rule. 2 U.S.C. 1532(c). The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of the NOPR and the ``Regulatory
Impact Analysis'' section of the TSD for this proposed rule respond to
those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. 2 U.S.C. 1535(a). DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the proposed rule unless DOE publishes
an explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C. 6295(d),
(f), and (o) and 6316(a), today's proposed rule would establish energy
conservation standards for electric motors that are designed to achieve
the maximum improvement in energy efficiency that DOE has determined to
be both
[[Page 73674]]
technologically feasible and economically justified. A full discussion
of the alternatives considered by DOE is presented in the ``Regulatory
Impact Analysis'' section of the TSD for today's proposed rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This proposed rule would not have any impact on the autonomy or
integrity of the family as an institution. Accordingly, DOE has
concluded that it is not necessary to prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (Mar. 18, 1988), that this proposed regulation
would not result in any takings that might require compensation under
the Fifth Amendment to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for Federal agencies to
review most disseminations of information to the public under
guidelines established by each agency pursuant to general guidelines
issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22,
2002), and DOE's guidelines were published at 67 FR 62446 (Oct. 7,
2002). DOE has reviewed today's NOPR under the OMB and DOE guidelines
and has concluded that it is consistent with applicable policies in
those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OIRA
at OMB, a Statement of Energy Effects for any proposed significant
energy action. A ``significant energy action'' is defined as any action
by an agency that promulgates or is expected to lead to promulgation of
a final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
DOE has tentatively concluded that today's proposed regulatory
action, which sets forth potential energy conservation standards for
commercial and industrial electric motors, is not a significant energy
action because the proposed standards are not likely to have a
significant adverse effect on the supply, distribution, or use of
energy, nor has it been designated as such by the Administrator at
OIRA. Accordingly, DOE has not prepared a Statement of Energy Effects
on the proposed rule.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as scientific information the
agency reasonably can determine will have, or does have, a clear and
substantial impact on important public policies or private sector
decisions. 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal in-progress
peer reviews of the energy conservation standards development process
and analyses and has prepared a Peer Review Report pertaining to the
energy conservation standards rulemaking analyses. Generation of this
report involved a rigorous, formal, and documented evaluation using
objective criteria and qualified and independent reviewers to make a
judgment as to the technical/scientific/business merit, the actual or
anticipated results, and the productivity and management effectiveness
of programs and/or projects. The ``Energy Conservation Standards
Rulemaking Peer Review Report'' dated February 2007 has been
disseminated and is available at the following Web site:
www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.
VII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the public meeting are listed in
the DATES and ADDRESSES sections at the beginning of this notice. If
you plan to attend the public meeting, please notify Ms. Brenda Edwards
at (202) 586-2945 or Brenda.Edwards@ee.doe.gov. As explained in the
ADDRESSES section, foreign nationals visiting DOE Headquarters are
subject to advance security screening procedures.
In addition, you can attend the public meeting via webinar. Webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants will be
published on DOE's Web site at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/42. Participants are
responsible for ensuring their systems are compatible with the webinar
software.
B. Procedure for Submitting Prepared General Statements For
Distribution
Any person who has plans to present a prepared general statement
may request that copies of his or her statement be made available at
the public meeting. Such persons may submit requests, along with an
advance electronic copy of their statement in PDF (preferred),
Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to
the appropriate address shown in the ADDRESSES section at the beginning
of this notice. The request and advance copy of statements must be
received at least one week before the public meeting and may be
emailed, hand-delivered, or sent by mail. DOE prefers to receive
requests and advance copies via email. Please include a telephone
number to enable DOE staff to make follow-up contact, if needed.
C. Conduct of the Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also use a professional facilitator to aid discussion. The
meeting will not be a judicial or evidentiary-type public hearing, but
DOE will conduct it in accordance with section 336 of EPCA (42 U.S.C.
6306). A court reporter will be present to record the proceedings and
[[Page 73675]]
prepare a transcript. DOE reserves the right to schedule the order of
presentations and to establish the procedures governing the conduct of
the public meeting. After the public meeting, interested parties may
submit further comments on the proceedings as well as on any aspect of
the rulemaking until the end of the comment period.
The public meeting will be conducted in an informal, conference
style. DOE will present summaries of comments received before the
public meeting, allow time for prepared general statements by
participants, and encourage all interested parties to share their views
on issues affecting this rulemaking. Each participant will be allowed
to make a general statement (within time limits determined by DOE),
before the discussion of specific topics. DOE will allow, as time
permits, other participants to comment briefly on any general
statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly and comment on
statements made by others. Participants should be prepared to answer
questions by DOE and by other participants concerning these issues. DOE
representatives may also ask questions of participants concerning other
matters relevant to this rulemaking. The official conducting the public
meeting will accept additional comments or questions from those
attending, as time permits. The presiding official will announce any
further procedural rules or modification of the above procedures that
may be needed for the proper conduct of the public meeting.
A transcript of the public meeting will be included in the docket,
which can be viewed as described in the Docket section at the beginning
of this notice. In addition, any person may buy a copy of the
transcript from the transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. Interested parties may submit comments, data, and other
information using any of the methods described in the ADDRESSES section
at the beginning of this notice.
Submitting comments via regulations.gov. The regulations.gov Web
page will require you to provide your name and contact information.
Your contact information will be viewable to DOE Building Technologies
staff only. Your contact information will not be publicly viewable
except for your first and last names, organization name (if any), and
submitter representative name (if any). If your comment is not
processed properly because of technical difficulties, DOE will use this
information to contact you. If DOE cannot read your comment due to
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to regulations.gov information for which disclosure
is restricted by statute, such as trade secrets and commercial or
financial information (hereinafter referred to as Confidential Business
Information (CBI)). Comments submitted through regulations.gov cannot
be claimed as CBI. Comments received through the Web site will waive
any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section
below.
DOE processes submissions made through regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or mail.
Comments and documents submitted via email, hand delivery, or mail also
will be posted to regulations.gov. If you do not want your personal
contact information to be publicly viewable, do not include it in your
comment or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery/courier, please provide all items on a CD, if feasible. It is
not necessary to submit printed copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
One copy of the document marked confidential including all the
information believed to be confidential, and one copy of the document
marked non-confidential with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except
[[Page 73676]]
information deemed to be exempt from public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. DOE requests comment on the potential impacts of new and amended
standards on small electric motor manufacturers, especially regarding
DOE's proposed expansion of scope of covered electric motors.
2. DOE requests comment on whether the proposed standards help
resolve the potential issue on which it had previously issued
clarification of whether a [IEC] motor may be considered to be subject
to two standards.
3. DOE seeks comment on any additional sources of data that could
be used to establish the distribution of electric motors across
equipment class groups.
4. DOE seeks comment on any additional sources of data that could
be used to establish the distribution of electric motors across sectors
by horsepower range and within each equipment class group.
5. DOE seeks comment on any additional sources for determining the
frequency of motor repair depending on equipment class group and
sector.
6. DOE seeks comment on any additional sources of data on motor
lifetime that could be used to validate DOE's estimates of motor
mechanical lifetime and its method of estimating lifetimes. DOE defines
equipment lifetime as the lesser of the age at which electric motors
are retired from service or the equipment in which they are embedded is
retired. For the NIA, DOE uses motor average lifetime in years derived
from motor mechanical lifetime in hours (see Chapter 8, Section 8.2.3)
and from annual operating hours (see Section 10.2.2.2). DOE based
expected equipment lifetime on discussions with industry experts and
developed a distribution of typical lifetimes for several categories of
electric motors. DOE welcomes further input on the average equipment
lifetimes for the LCC and NIA analyses.
7. DOE seeks comment on the estimated base case distribution of
product efficiencies and on any additional sources of data.
8. DOE seeks comments on its decision to use efficiency trends for
equipment class groups 1 and 4 and constant efficiencies for equipment
class groups 2 and 3 over the analysis period. Specifically, DOE would
like comments on additional sources of data on trends in efficiency
improvement.
9. DOE seeks comment on any sources of data that could be used to
establish the elasticity of electric motor shipments with respect to
changes in purchase price.
10. DOE seeks comment on its scaled values for MSPs. In particular,
DOE seeks comments on its methodology for scaling MSP data from the
representative equipment classes to the remaining equipment classes.
11. DOE seeks comment on the scaled values for motor weights. In
particular, DOE seeks comments on its methodology for scaling weight
data from the representative equipment classes to the remaining
equipment classes.
12. DOE seeks comment on the trial standard levels (TSLs) developed
for the NOPR.
13. DOE seeks comment on its proposed compliance date of December
19, 2015.
14. DOE seeks comment on its decision to analyze brake motors in a
separate equipment class group.
15. DOE seeks comment on its decision to limit standards for brake
motors to 1-30 hp, and 4, 6, and 8 pole configurations. DOE selected
these ratings after reviewing manufacturer catalogs and only finding
brake motors in these configurations.
16. DOE seeks comment on its decision to not screen out copper die-
cast copper rotor motors.
17. DOE seeks comment on the availability of copper in the market
to manufacture die-cast copper rotor motors on a ``mass quantity''
scale.
18. DOE seeks comment on its decision to not screen out hand
winding in its analysis.
19. DOE seeks comment on its estimation for labor hours for each
representative unit.
20. DOE seeks comments on the cost to manufacturers to change their
product lines to meet EL3.
21. DOE seeks comments on the cost to manufacturers to change their
product lines to meet EL4.
22. DOE is aware that motors used in fire pump applications may
carry various definitions, including, but not limited to, NEMA, IEC,
and NFPA designations. DOE requests comment on its current definition
of fire pump motors, the suitability of that definition for the United
States market, and on its advantages or disadvantages relative to other
potential definitions.
23. In DOE's view any Design B or IEC-equivalent motor that
otherwise satisfies the relevant NFPA requirements would meet the fire
pump electric motor definition in 10 CFR 431.12. To the extent that
there is confusion regarding this view, DOE invites comments on this
issue, along with any data demonstrating whether any IEC-equivalent
motors are listed for fire pump service either under the NFPA 20 or
another relevant industry standard.
24. DOE seeks data on any other subsets of 56-frame motors,
particularly those motors that are: (1) Enclosed general purpose
electric motors that have a rating of under 1 horsepower and (2) open,
special or definite purpose (inclusive) electric motors. The types of
data that DOE seeks include, but are not limited to, the following
categories: Efficiency distribution; shipment breakdown between
horsepower ratings, open and enclosed motors, and between general and
special and definite purpose electric motors; and typical applications
that use these motors.
25. Currently, DOE's reference case projects that prices for future
shipments of motors will remain constant. DOE is seeking input on the
appropriateness of this assumption.
26. DOE requests comment on whether there are features or
attributes of the more energy-efficient electric motors that
manufacturers would produce to meet the standards in this proposed rule
that might affect how they would be used by consumers. DOE requests
comment specifically on how any such effects should be weighed in the
choice of standards for the electric motors for the final rule.
27. For this rulemaking, DOE analyzed the effects of this proposal
assuming that the electric motors would be available to purchase for 30
years and undertook a sensitivity analysis using 9 years rather than 30
years of product shipments. The choice of a 30-year period of shipments
is consistent with the DOE analysis for other products and commercial
equipment. The choice of a 9-year period is a proxy for the timeline in
EPCA for the review of certain energy conservation standards and
potential revision of and compliance with such revised standards. We
are seeking input, information and data on whether there are ways to
further refine the analytic timeline.
28. DOE solicits comment on the application of the new SCC values
used to determine the social benefits of CO2 emissions
reductions over the rulemaking analysis period. (The rulemaking
analysis period covers from 2015 to 2044 plus the appropriated number
of years to account for the lifetime of the equipment purchased between
2015 and 2044.) In particular, the agency solicits comment on the
[[Page 73677]]
agency's derivation of SCC values after 2050 where the agency applied
the average annual growth rate of the SCC estimates in 2040-2050
associated with each of the four sets of values.
29. DOE solicits comment on whether its proposal presents a
sufficiently broad scope of regulatory coverage to help ensure that
significant energy savings would be met or whether further adjustments
to the proposed scope--whether to exclude certain categories or to
include others--are necessary.
30. DOE requests comment on the nine characteristics listed in
section III.C and their appropriateness for outlining scope of
coverage.
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of today's
proposed rule.
List of Subjects in 10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation, Commercial and industrial equipment,
Imports, Intergovernmental relations, Reporting and recordkeeping
requirements, and Small businesses.
Issued in Washington, DC, on November 25, 2013.
David T. Danielson,
Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons set forth in the preamble, DOE proposes to amend
part 431 of chapter II of title 10 of the Code of Federal Regulations,
as set forth below:
PART 431--ENERGY CONSERVATION PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317
0
2. Revise Sec. 431.25 to read as follows:
Sec. 431.25 Energy conservation standards and effective dates.
(a) Except as provided for fire pump electric motors in paragraph
(b) of this section, each general purpose electric motor (subtype I)
with a power rating of 1 horsepower or greater, but not greater than
200 horsepower, including a NEMA Design B or an equivalent IEC Design N
motor that is a general purpose electric motor (subtype I),
manufactured (alone or as a component of another piece of equipment) on
or after December 19, 2010, but before December 19, 2015, shall have a
nominal full-load efficiency that is not less than the following:
Table 1--Nominal Full-Load Efficiencies of General Purpose Electric Motors (Subtype I), Except Fire Pump Electric Motors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full-load efficiency
Motor horsepower/ -----------------------------------------------------------------------------------------------------------------------------------
standard kilowatt Open motors (number of poles) Enclosed motors (number of poles)
equivalent -----------------------------------------------------------------------------------------------------------------------------------
6 4 2 6 4 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75 82.5 85.5 77.0 82.5 85.5 77.0
1.5/1.1 86.5 86.5 84.0 87.5 86.5 84.0
2/1.5 87.5 86.5 85.5 88.5 86.5 85.5
3/2.2 88.5 89.5 85.5 89.5 89.5 86.5
5/3.7 89.5 89.5 86.5 89.5 89.5 88.5
7.5/5.5 90.2 91.0 88.5 91.0 91.7 89.5
10/7.5 91.7 91.7 89.5 91.0 91.7 90.2
15/11 91.7 93.0 90.2 91.7 92.4 91.0
20/15 92.4 93.0 91.0 91.7 93.0 91.0
25/18.5 93.0 93.6 91.7 93.0 93.6 91.7
30/22 93.6 94.1 91.7 93.0 93.6 91.7
40/30 94.1 94.1 92.4 94.1 94.1 92.4
50/37 94.1 94.5 93.0 94.1 94.5 93.0
60/45 94.5 95.0 93.6 94.5 95.0 93.6
75/55 94.5 95.0 93.6 94.5 95.4 93.6
100/75 95.0 95.4 93.6 95.0 95.4 94.1
125/90 95.0 95.4 94.1 95.0 95.4 95.0
150/110 95.4 95.8 94.1 95.8 95.8 95.0
200/150 95.4 95.8 95.0 95.8 96.2 95.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
(b) Each fire pump electric motor that is a general purpose
electric motor (subtype I) or general purpose electric motor (subtype
II) manufactured (alone or as a component of another piece of
equipment) on or after December 19, 2010, but before December 19, 2015,
shall have a nominal full-load efficiency that is not less than the
following:
Table 2--Nominal Full-Load Efficiencies of Fire Pump Electric Motors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full-load efficiency
Motor horsepower/ --------------------------------------------------------------------------------------------------------------------------------------
standard kilowatt Open motors (number of poles) Enclosed motors (number of poles)
equivalent --------------------------------------------------------------------------------------------------------------------------------------
8 6 4 2 8 6 4 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75 74.0 80.0 82.5 -- 74.0 80.0 82.5 75.5
1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5
[[Page 73678]]
2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0
3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5
5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5
7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5
10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5
15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2
20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2
25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0
30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0
40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7
50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4
60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0
75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0
100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6
125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5
150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5
200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0
250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4
300/224 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4
350/261 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4
400/298 -- -- 95.4 95.4 -- -- 95.4 95.4
450/336 -- -- 95.8 95.8 -- -- 95.4 95.4
500/373 -- -- 95.8 95.8 -- -- 95.8 95.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
(c) Except as provided for fire pump electric motors in paragraph
(b) of this section, each general purpose electric motor (subtype II)
with a power rating of 1 horsepower or greater, but not greater than
200 horsepower, including a NEMA Design B or an equivalent IEC Design N
motor that is a general purpose electric motor (subtype II),
manufactured (alone or as a component of another piece of equipment) on
or after December 19, 2010, but before December 19, 2015, shall have a
nominal full-load efficiency that is not less than the following:
Table 3--Nominal Full-Load Efficiencies of General Purpose Electric Motors (Subtype II), Except Fire Pump Electric Motors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full-load efficiency
Motor horsepower/ --------------------------------------------------------------------------------------------------------------------------------------
standard kilowatt Open motors (number of poles) Enclosed motors (number of poles)
equivalent --------------------------------------------------------------------------------------------------------------------------------------
8 6 4 2 8 6 4 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75 74.0 80.0 82.5 -- 74.0 80.0 82.5 75.5
1.5/1.1 75.5 84.0 84.0 82.5 77.0 85.5 84.0 82.5
2/1.5 85.5 85.5 84.0 84.0 82.5 86.5 84.0 84.0
3/2.2 86.5 86.5 86.5 84.0 84.0 87.5 87.5 85.5
5/3.7 87.5 87.5 87.5 85.5 85.5 87.5 87.5 87.5
7.5/5.5 88.5 88.5 88.5 87.5 85.5 89.5 89.5 88.5
10/7.5 89.5 90.2 89.5 88.5 88.5 89.5 89.5 89.5
15/11 89.5 90.2 91.0 89.5 88.5 90.2 91.0 90.2
20/15 90.2 91.0 91.0 90.2 89.5 90.2 91.0 90.2
25/18.5 90.2 91.7 91.7 91.0 89.5 91.7 92.4 91.0
30/22 91.0 92.4 92.4 91.0 91.0 91.7 92.4 91.0
40/30 91.0 93.0 93.0 91.7 91.0 93.0 93.0 91.7
50/37 91.7 93.0 93.0 92.4 91.7 93.0 93.0 92.4
60/45 92.4 93.6 93.6 93.0 91.7 93.6 93.6 93.0
75/55 93.6 93.6 94.1 93.0 93.0 93.6 94.1 93.0
100/75 93.6 94.1 94.1 93.0 93.0 94.1 94.5 93.6
125/90 93.6 94.1 94.5 93.6 93.6 94.1 94.5 94.5
150/110 93.6 94.5 95.0 93.6 93.6 95.0 95.0 94.5
200/150 93.6 94.5 95.0 94.5 94.1 95.0 95.0 95.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
(d) Each NEMA Design B or an equivalent IEC Design N motor that is
a general purpose electric motor (subtype I) or general purpose
electric motor (subtype II), excluding fire pump electric motors, with
a power rating of more than 200 horsepower, but not greater than 500
horsepower, manufactured (alone or as a component
[[Page 73679]]
of another piece of equipment) on or after December 19, 2010, but
before December 19, 2015 shall have a nominal full-load efficiency that
is not less than the following:
Table 4--Nominal Full-Load Efficiencies of NEMA Design B General Purpose Electric Motors (Subtype I and II), Except Fire Pump Electric Motors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full-load efficiency
Motor horsepower/ -------------------------------------------------------------------------------------------------------------------------------------------
standard kilowatt Open motors Enclosed motors (number of poles)
equivalent (number of --------------------------------------------------------------------------------------------------------------------------
poles) 8 6 4 2 8 6 4
-------------------------------------------------------------------------------------------------------------------------------------------------------
250/186 94.5 95.4 95.4 94.5 94.5 95.0 95.0 95.4
300/224 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4
350/261 -- 95.4 95.4 95.0 -- 95.0 95.4 95.4
400/298 -- -- 95.4 95.4 -- -- 95.4 95.4
450/336 -- -- 95.8 95.8 -- -- 95.4 95.4
500/373 -- -- 95.8 95.8 -- -- 95.8 95.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
(e) For purposes of determining the required minimum nominal full-
load efficiency of an electric motor that has a horsepower or kilowatt
rating between two horsepower or two kilowatt ratings listed in any
table of energy conservation standards in paragraphs (a) through (d) of
this section, each such motor shall be deemed to have a listed
horsepower or kilowatt rating, determined as follows:
(1) A horsepower at or above the midpoint between the two
consecutive horsepowers shall be rounded up to the higher of the two
horsepowers;
(2) A horsepower below the midpoint between the two consecutive
horsepowers shall be rounded down to the lower of the two horsepowers;
or
(3) A kilowatt rating shall be directly converted from kilowatts to
horsepower using the formula 1 kilowatt = (\1\/0.746)
horsepower. The conversion should be calculated to three significant
decimal places, and the resulting horsepower shall be rounded in
accordance with paragraph (e)(1) or (2) of this section, whichever
applies.
(f) The standards in Table 1 through Table 4 of this section do not
apply to definite purpose motors, special purpose motors, or those
motors exempted by the Secretary.
(g) The standards in Table 5 through Table 8 of this section apply
to electric motors that satisfy the following criteria:
(1) Are single-speed, induction motors;
(2) Are rated for continuous duty (MG 1) operation or for duty type
S1 (IEC);
(3) Contain a squirrel-cage (MG 1) or cage (IEC) rotor;
(4) Operate on polyphase alternating current 60-hertz sinusoidal
line power;
(5) Are rated 600 volts or less;
(6) Have a 2-, 4-, 6-, or 8-pole configuration,
(7) Have a three-digit NEMA frame size (or IEC metric equivalent)
or an enclosed 56 NEMA frame size (or IEC metric equivalent),
(8) Are rated no more than 500 horsepower, but greater than or
equal to 1 horsepower (or kilowatt equivalent), and
(9) Meet all of the performance requirements of one of the
following motor types: a NEMA Design A, B, or C motor or an IEC design
N or H motor.
(h) Starting on December 19, 2015, each NEMA Design A and NEMA
Design B motor that is an electric motor meeting the criteria in
paragraph (g) of this section and with a power rating from 1 horsepower
through 500 horsepower, but excluding fire pump electric motors,
integral-brake electric motors, and non-integral brake electric motors,
manufactured (alone or as a component of another piece of equipment)
shall have a nominal full-load efficiency of not less than the
following:
Table 5--Nominal Full Load Efficiencies of NEMA Design A and NEMA Design B Electric Motors
[Excluding fire pump electric motors, integral-brake electric motors, and non-integral brake electric motors]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
Motor horsepower/ --------------------------------------------------------------------------------------------------------------------------------------
standard kilowatt 2 Pole 4 Pole 6 Pole 8 Pole
equivalent --------------------------------------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75 77.0 77.0 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1 84.0 84.0 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5 85.5 85.5 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2 86.5 85.5 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7 88.5 86.5 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5 89.5 88.5 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5 90.2 89.5 91.7 91.7 91.0 91.7 89.5 90.2
15/11 91.0 90.2 92.4 93.0 91.7 91.7 89.5 90.2
20/15 91.0 91.0 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5 91.7 91.7 93.6 93.6 93.0 93.0 90.2 91.0
30/22 91.7 91.7 93.6 94.1 93.0 93.6 91.7 91.7
40/30 92.4 92.4 94.1 94.1 94.1 94.1 91.7 91.7
50/37 93.0 93.0 94.5 94.5 94.1 94.1 92.4 92.4
60/45 93.6 93.6 95.0 95.0 94.5 94.5 92.4 93.0
75/55 93.6 93.6 95.4 95.0 94.5 94.5 93.6 94.1
100/75 94.1 93.6 95.4 95.4 95.0 95.0 93.6 94.1
[[Page 73680]]
125/90 95.0 94.1 95.4 95.4 95.0 95.0 94.1 94.1
150/110 95.0 94.1 95.8 95.8 95.8 95.4 94.1 94.1
200/150 95.4 95.0 96.2 95.8 95.8 95.4 94.5 94.1
250/186 95.8 95.0 96.2 95.8 95.8 95.8 95.0 95.0
300/224 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0
350/261 95.8 95.4 96.2 95.8 95.8 95.8 95.0 95.0
400/298 95.8 95.8 96.2 95.8 95.8 95.8 95.0 95.0
450/336 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
500/373 95.8 96.2 96.2 96.2 95.8 96.2 95.0 95.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
(i) Starting on December 19, 2015, each NEMA Design C electric
motor that is an electric motor meeting the criteria in paragraph (g)
of this section and with a power rating from 1 horsepower through 200
horsepower, but excluding non-integral brake electric motors and
integral brake electric motors, manufactured (alone or as a component
of another piece of equipment) shall have a nominal full-load
efficiency that is not less than the following:
Table 6--Nominal Full Load Efficiencies of NEMA Design C electric motors
[excluding non-integral brake electric motors and integral brake electric motors]
----------------------------------------------------------------------------------------------------------------
Nominal Full Load Efficiency (%)
-----------------------------------------------------------------------------
Motor horsepower/standard kilowatt 4 Pole 6 Pole 8 Pole
equivalent -----------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open
----------------------------------------------------------------------------------------------------------------
1/.75............................. 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1........................... 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5............................. 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2............................. 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7............................. 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5........................... 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5............................ 91.7 91.7 91.0 91.7 89.5 90.2
15/11............................. 92.4 93.0 91.7 91.7 89.5 90.2
20/15............................. 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5........................... 93.6 93.6 93.0 93.0 90.2 91.0
30/22............................. 93.6 94.1 93.0 93.6 91.7 91.7
40/30............................. 94.1 94.1 94.1 94.1 91.7 91.7
50/37............................. 94.5 94.5 94.1 94.1 92.4 92.4
60/45............................. 95.0 95.0 94.5 94.5 92.4 93.0
75/55............................. 95.4 95.0 94.5 94.5 93.6 94.1
100/75............................ 95.4 95.4 95.0 95.0 93.6 94.1
125/90............................ 95.4 95.4 95.0 95.0 94.1 94.1
150/110........................... 95.8 95.8 95.8 95.4 94.1 94.1
200/150........................... 96.2 95.8 95.8 95.4 94.5 94.1
----------------------------------------------------------------------------------------------------------------
(j) Starting on December 19, 2015, each fire pump electric motor
meeting the criteria in paragraph (g) of this section and with a power
rating of 1 horsepower through 500 horsepower, manufactured (alone or
as a component of another piece of equipment) shall have a nominal
full-load efficiency that is not less than the following:
Table 7--Nominal Full Load Efficiencies of Fire Pump Electric Motors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal full load efficiency (%)
-------------------------------------------------------------------------------------------------------
Motor horsepower/ standard kilowatt equivalent 2 Pole 4 Pole 6 Pole 8 Pole
-------------------------------------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open Enclosed Open
--------------------------------------------------------------------------------------------------------------------------------------------------------
1/.75........................................... 75.5 75.5 82.5 82.5 80.0 80.0 74.0 74.0
1.5/1.1......................................... 82.5 82.5 84.0 84.0 85.5 84.0 77.0 75.5
2/1.5........................................... 84.0 84.0 84.0 84.0 86.5 85.5 82.5 85.5
3/2.2........................................... 85.5 84.0 87.5 86.5 87.5 86.5 84.0 86.5
5/3.7........................................... 87.5 85.5 87.5 87.5 87.5 87.5 85.5 87.5
7.5/5.5......................................... 88.5 87.5 89.5 88.5 89.5 88.5 85.5 88.5
[[Page 73681]]
10/7.5.......................................... 89.5 88.5 89.5 89.5 89.5 90.2 88.5 89.5
15/11........................................... 90.2 89.5 91.0 91.0 90.2 90.2 88.5 89.5
20/15........................................... 90.2 90.2 91.0 91.0 90.2 91.0 89.5 90.2
25/18.5......................................... 91.0 91.0 92.4 91.7 91.7 91.7 89.5 90.2
30/22........................................... 91.0 91.0 92.4 92.4 91.7 92.4 91.0 91.0
40/30........................................... 91.7 91.7 93.0 93.0 93.0 93.0 91.0 91.0
50/37........................................... 92.4 92.4 93.0 93.0 93.0 93.0 91.7 91.7
60/45........................................... 93.0 93.0 93.6 93.6 93.6 93.6 91.7 92.4
75/55........................................... 93.0 93.0 94.1 94.1 93.6 93.6 93.0 93.6
100/75.......................................... 93.6 93.0 94.5 94.1 94.1 94.1 93.0 93.6
125/90.......................................... 94.5 93.6 94.5 94.5 94.1 94.1 93.6 93.6
150/110......................................... 94.5 93.6 95.0 95.0 95.0 94.5 93.6 93.6
200/150......................................... 95.0 94.5 95.0 95.0 95.0 94.5 94.1 93.6
250/186......................................... 95.4 94.5 95.0 95.4 95.0 95.4 94.5 94.5
300/224......................................... 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5
350/261......................................... 95.4 95.0 95.4 95.4 95.0 95.4 94.5 94.5
400/298......................................... 95.4 95.4 95.4 95.4 95.0 95.4 94.5 94.5
450/336......................................... 95.4 95.8 95.4 95.8 95.0 95.4 94.5 94.5
500/373......................................... 95.4 95.8 95.8 95.8 95.0 95.4 94.5 94.5
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(k) Starting on December 19, 2015, each integral brake electric
motor and non-integral brake electric motor meeting the criteria in
paragraph (g) of this section, and with a power rating of 1 horsepower
through 30 horsepower, manufactured (alone or as a component of another
piece of equipment) shall have a nominal full-load efficiency that is
not less than the following:
Table 8--Nominal Full Load Efficiencies of Integral Brake Electric Motors and Non-Integral Brake Electric Motors
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Nominal full load efficiency (%)
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Motor horsepower/standard kilowatt 4 Pole 6 Pole 8 Pole
equivalent -----------------------------------------------------------------------------
Enclosed Open Enclosed Open Enclosed Open
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1/.75............................. 85.5 85.5 82.5 82.5 75.5 75.5
1.5/1.1........................... 86.5 86.5 87.5 86.5 78.5 77.0
2/1.5............................. 86.5 86.5 88.5 87.5 84.0 86.5
3/2.2............................. 89.5 89.5 89.5 88.5 85.5 87.5
5/3.7............................. 89.5 89.5 89.5 89.5 86.5 88.5
7.5/5.5........................... 91.7 91.0 91.0 90.2 86.5 89.5
10/7.5............................ 91.7 91.7 91.0 91.7 89.5 90.2
15/11............................. 92.4 93.0 91.7 91.7 89.5 90.2
20/15............................. 93.0 93.0 91.7 92.4 90.2 91.0
25/18.5........................... 93.6 93.6 93.0 93.0 90.2 91.0
30/22............................. 93.6 94.1 93.0 93.6 91.7 91.7
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(l) For purposes of determining the required minimum nominal full-
load efficiency of an electric motor that has a horsepower or kilowatt
rating between two horsepower or two kilowatt ratings listed in any
table of energy conservation standards in paragraphs (h) through (k) of
this section, each such motor shall be deemed to have a listed
horsepower or kilowatt rating, determined as follows:
(1) A horsepower at or above the midpoint between the two
consecutive horsepowers shall be rounded up to the higher of the two
horsepowers;
(2) A horsepower below the midpoint between the two consecutive
horsepowers shall be rounded down to the lower of the two horsepowers;
or
(3) A kilowatt rating shall be directly converted from kilowatts to
horsepower using the formula 1 kilowatt = (1/0.746) horsepower. The
conversion should be calculated to three significant decimal places,
and the resulting horsepower shall be rounded in accordance with
paragraph (l)(1) or (2) of this section, whichever applies.
(m) The standards in Table 5 through Table 8 of this section do not
apply to the following electric motors exempted by the Secretary, or
any additional electric motors that the Secretary may exempt:
(1) Air-over electric motors;
(2) Component sets of an electric motor;
(3) Liquid-cooled electric motors;
(4) Submersible electric motors; and
(5) Definite-purpose, inverter-fed electric motors.
[FR Doc. 2013-28776 Filed 12-5-13; 8:45 am]
BILLING CODE 6450-01-P
