Energy Conservation Program: Energy Conservation Standards for Commercial and Industrial Electric Motors
Federal RegisterMay 29, 2014
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DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket No. 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:
Final rule.
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 final rule, DOE establishes 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, today's rulemaking would maintain the current energy conservation standards for some electric motor types and amend the energy conservation standards for other electric motor types. DOE has determined that the new and amended energy conservation standards for this equipment would result in significant conservation of energy, and are technologically feasible and economically justified.
DATES:
The effective date of this rule is July 28, 2014. Compliance with the standards established for commercial and industrial electric motors in today's final rule is required starting on June 1, 2016.
The incorporation by reference of a certain publication listed in this rule was approved by the
Federal Register
on May 4, 2012.
ADDRESSES:
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:
http://www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0027
. This Web page will contain a link to the docket for this rule 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.
For further information on how to review the docket, 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 Office, EE-5B, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-8654. Email:
medium_electric_motors@ee.doe.gov
.
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 Final Rule and Its Benefits
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
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. Compliance Date
B. Test Procedure
1. Vertical Electric Motors
C. Current Equipment Classes and Scope of Coverage
D. Updated Equipment Classes and Scope of Coverage
E. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
F. Energy Savings
1. Determination of Savings
2. Significance of Savings
G. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Life-Cycle Costs
c. Energy Savings
d. Lessening of Utility or Performance of Products
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
a. Summary
b. Definitions, Terminology, and Regulatory Language
c. Horsepower Rating
d. High-Horsepower Six- and Eight-Pole Motors
e. Frame Size
f. IEC Motors
g. Frequency
h. Random Winding
i. Duty Cycle
j. Gear Motors
k. Partial Electric Motors
l. Certification Considerations Related to Expanded Scope
m. Electric Motors With Separately Powered Blowers
3. Advanced Electric Motors
4. Equipment Class Groups and Equipment Classes
a. U-Frame Motors
b. Electric Motor Design Letter
c. Fire Pump Electric Motors
d. Brake Electric Motors
e. Horsepower Rating
f. Pole Configuration
g. Enclosure Type
h. Other Motor Characteristics
5. Technology Assessment
a. Increase the Cross-Sectional Area of Copper in the Stator Slots
b. Decrease the Length of Coil Extensions
c. Die-Cast Copper Rotor Cage
d. Increase Cross-Sectional Area of Rotor Conductor Bars
e. Increase Cross-Sectional Area of End Rings
f. Electrical Steel With Lower Losses
g. Thinner Steel Laminations
h. Increase Stack Length
i. Optimize Bearing and Lubrication
j. Improve Cooling System
k. Reduce Skew on Conductor Cage
l. Improve Rotor Bar Insulation
m. Technology Options Not Considered
B. Screening Analysis
1. Technology Options Not Screened Out of the Analysis
a. Die-Cast Copper Rotors
b. Increase the Cross-Sectional Area of Copper in the Stator Slots
c. Power Factor
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. Testing 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
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
13. Comments on Other Issues
G. Shipments Analysis
H. National Impact Analysis
1. Efficiency Trends
2. National Energy Savings
3. Electric Motor Weights
4. Equipment Price Forecast
5. Net Present Value of Customer Benefit
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Shipment Projections
3. Markup Scenarios
4. Product and Capital Conversion Costs
5. Other Comments from Interested Parties
a. Manufacturer Markups used in the MIA versus the NIA
b. Potential Trade Barriers
6. Manufacturer Interviews
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon Values
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. Conclusions
1. Benefits and Burdens of Trial Standard Levels Considered for Electric Motors
2. Summary of Benefits and Costs (Annualized) of Today's 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. Manufacturer Participation
b. Electric Motor Industry Structure and Nature of Competition
c. 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 Rule
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
M. Congressional Notification
VII. Approval of the Office of the Secretary
I. Summary of the Final Rule and Its Benefits
Title III of the Energy Policy and Conservation Act of 1975 (42 U.S.C. 6291,
et seq.;
“EPCA”), Public Law 94-163, sets forth a variety of provisions designed to improve energy efficiency. Part C of title III, which for editorial reasons was re-designated as Part A-1 upon incorporation into the U.S. Code (42 U.S.C. 6311-6317), establishes the “Energy Conservation Program for Certain Industrial Equipment,” including certain electric motors.
1
(Within this preamble, DOE will use the terms “electric motors” and “motors” interchangeably as today's rulemaking only pertains to electric motors.) Pursuant to EPCA, any new or amended energy conservation standard must 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, the new or amended standards must result in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B) and 6316(a))
1
All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (December 18, 2012).
In accordance with these and other statutory provisions discussed in this final rule, DOE is adopting new and amended energy conservation standards for electric motors by applying the standards currently in place to a wider scope of electric motors that DOE does not currently regulate. In setting these standards, DOE is addressing 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, today's rule, would require all currently regulated motors, with the exception of fire pump electric motors, to satisfy the efficiency levels (ELs) prescribed in Table 12-12 of National Electrical Manufacturers Association (NEMA) Standards Publication MG 1-2011, “Motors and Generators;” fire pump motors would continue to meet the current standards that apply. All other electric motors covered in today's rulemaking would also need to meet the efficiency levels found in MG 1-2011, Table 12-12. As a practical matter, most currently regulated motors would continue to be required to meet the same standards that they are already required to meet, but certain motors, such as those that satisfy the general purpose electric motors (subtype II) (
i.e.
“subtype II”) or that are NEMA Design B (or equivalent IEC Design N) motors with a power rating of more than 200 horsepower, but not greater than 500 horsepower, would now be required to meet the more stringent levels prescribed by MG 1-2011, Tables 12-12. These adopted efficiency levels (depicted here as trial standard levels or “TSLs”) and the motor types to which they apply are shown in Table I.1.
Table I.1—Energy Conservation Standards for Electric Motors
[Compliance starting June 1, 2016]
Equipment class group
Electric motor
design type
Horsepower
rating
Pole
configuration
Enclosure
Adopted TSL**
1
NEMA Design A & B*
1-500
2, 4, 6, 8
Open
2
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
*Indicates International Electrotechnical Commission (IEC) equivalent electric motors are included. Also, due to the elimination of an equipment class for brake motors, previously reported brake motor results are now reported in Equipment Class Group 1 (ECG 1).
**Tables I.2 through I.4 detail the various standard levels that compose TSL 2. Table I.2 applies to NEMA Design A & B, Table I.3 applies to NEMA Design C and Table I.4 applies to fire pump electric motors.
In determining where a particular motor with a certain horsepower (hp) or kilowatt (kW) rating would fall within the requirements, today's final rule establishes the same approach provided in current regulations to determine which rating would apply for compliance purposes. Namely:
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; and
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—Energy Conservation Standards for NEMA Design A and NEMA Design B Motors (Excluding Fire Pump Electric Motors)
[Compliance starting June 1, 2016]
Motor horsepower/standard kilowatt
equivalent
Nominal full-load efficiency
(percent)
2 Pole
Enclosed
Open
4 Pole
Enclosed
Open
6 Pole
Enclosed
Open
8 Pole
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
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
350/261
95.8
95.4
96.2
95.8
95.8
95.8
400/298
95.8
95.8
96.2
95.8
450/336
95.8
96.2
96.2
96.2
500/373
95.8
96.2
96.2
96.2
Table I.3—Energy Conservation Standards for NEMA Design C Motors
[Compliance starting June 1, 2016]
Motor horsepower/standard kilowatt equivalent
Nominal full-load efficiency
(percent)
4 Pole
Enclosed
Open
6 Pole
Enclosed
Open
8 Pole
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—Energy Conservation Standards for Fire Pump Electric Motors
[Compliance starting June 1, 2016]
Motor horsepower/standard kilowatt
equivalent
Nominal full-load efficiency
(percent)
2 Pole
Enclosed
Open
4 Pole
Enclosed
Open
6 Pole
Enclosed
Open
8 Pole
Enclosed
Open
1/.75
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
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
350/261
95.4
95.0
95.4
95.4
95.0
95.4
400/298
95.4
95.4
95.4
95.4
450/336
95.4
95.8
95.4
95.8
500/373
95.4
95.8
95.8
95.8
Note:
Energy conservation standards for fire pump electric motors have not changed and remain at the current efficiency levels.
A. Benefits and Costs to Consumers
Table I.5 presents DOE's evaluation of the economic impacts of today's standards on consumers of electric motors, as measured by the weighted average life-cycle cost (LCC) savings and the median payback period. The average LCC savings are positive for all equipment classes for which consumers are impacted by the standards.
Table I.5—Impacts of Today's Standards on Consumers of Electric Motors
Equipment class group
Weighted average LCC savings* (2013$)
Weighted median payback period* (years)
1
160
2.9
2
53
4.5
3
N/A**
N/A**
* 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, 3, 9, and 10; ECG 2: Representative units 4 and 5; ECG 3: Representative units 6, 7, and 8. The weighted average lifetime in each equipment class is 15 years and ranges from 8 to 29 years, depending on the motor horsepower and application.
** For the ECG 3 motor, the 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 (2014 to 2045). Using a real discount rate of 9.1 percent, DOE estimates that the industry net present value (INPV) for manufacturers of electric motors is $3,478 million in 2013$. Under today's standards, DOE expects that manufacturers may lose up to 10.0 percent of their INPV, which is approximately $348 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 rule.
C. National Benefits and Costs
2
2
All monetary values in this section are expressed in 2013 dollars and are discounted to 2014.
DOE's analyses indicate that today's 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 (2016-2045) would amount to 7.0 quads (full-fuel-cycle energy).
3
The annualized energy savings (0.23 quad) is equivalent to one percent of total U.S. industrial primary energy consumption in 2013.
4
3
The agency also conducted the site energy analysis as well (see TSD chapter 10). One quad (quadrillion Btu) is the equivalent of 293 billion kilowatt hours (kWh) or 172.3 million barrels of oil.
4
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 today's standards for electric motors ranges from $11.3 billion (at a 7-percent discount rate) to $28.8 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 2016-2045.
5
5
The analytic timeframe includes motors shipped each year from 2016 to 2045.
In addition, today's standards would have significant environmental benefits across the entire analysis period. Estimated energy savings would result in cumulative greenhouse gas emission reductions of approximately 395 million metric tons (Mt)
6
of carbon dioxide (CO
2
), 1,883 thousand tons of methane, 673 thousand tons of sulfur dioxide (SO
2
), 498 thousand tons of nitrogen oxides (NO
X
) and 0.8 tons of mercury (Hg).
7
The cumulative reduction in CO
2
emissions through 2030 amounts to 96 Mt.
6
A metric ton is equivalent to 1.1 short tons. Results for NO
X
and Hg are presented in short tons.
7
DOE calculates emissions reductions relative to the Annual Energy Outlook (AEO) 2013 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 CO
2
reductions is calculated using a range of values per metric ton of CO
2
(otherwise known as the Social Cost of Carbon, or SCC) developed by a recent Federal interagency process.
8
The derivation of the SCC values is discussed in section IV.L. Using discount rates appropriate for each set of SCC values, DOE estimates that the present monetary value of the CO
2
emissions reductions is between $2.7 billion and $38.3 billion. DOE also estimates that the present monetary value of the NO
X
emissions reductions is $0.3 billion at a 7-percent discount rate, and $0.7 billion at a 3-percent discount rate.
9
8
Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866.
Interagency Working Group on Social Cost of Carbon, United States Government. May 2013; revised November 2013.
http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf
.
9
DOE is currently investigating valuation of avoided Hg and SO
2
emissions.
Table I.6 summarizes the national economic costs and benefits expected to result from today's standards for electric motors.
Table I.6—Summary of National Economic Benefits and Costs of Electric Motors Energy Conservation Standards, Present Value for Motors Shipped in 2016-2045 in Billion 2013$ *
Category
Present
value
billion
2013$
Discount
rate
%
Benefits
Consumer Operating Cost Savings
18.2
7
41.4
3
CO
2
Reduction Monetized Value ($12.0/t case) **
2.7
5
CO
2
Reduction Monetized Value ($40.5/t case) **
12.4
3
CO
2
Reduction Monetized Value ($62.4/t case) **
19.7
2.5
CO
2
Reduction Monetized Value ($119/t case) **
38.3
3
NO
X
Reduction Monetized Value (at $2,684/ton) **
0.3
7
0.7
3
Total Benefits †
30.9
7
54.4
3
Costs
Consumer Incremental Installed Costs
6.9
7
12.5
3
Net Benefits
Including CO
2
and NO
X
Reduction Monetized Value
24.0
7
41.9
3
* This table presents the costs and benefits associated with electric motors shipped in 2016-2045. These results include benefits to customers which accrue after 2045 from the equipment purchased in 2016-2045. The results account for the incremental variable and fixed costs incurred by manufacturers due to the amended standard, some of which may be incurred in preparation for this final rule.
** The CO
2
values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporates an escalation factor. The value for NO
X
is the average of the low and high 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 $40.5/t in 2015.
The benefits and costs of today's standards for electric motors, sold in 2016-2045, 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 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 CO
2
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 2014, 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 CO
2
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 (2016 through 2045) 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 value of operating savings and CO
2
emissions reductions provides a useful perspective, two issues should be considered. First, the national operating cost savings are domestic U.S. consumer monetary savings that occur as a result of market transactions, while the value of CO
2
reductions is based on a global value. Second, the assessments of operating cost savings and CO
2
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 2016-2045. 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 today's standards 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 CO
2
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 in today's rule is $517 million per year in increased equipment costs (incremental installed costs), while the estimated benefits are $1,367 million per year in reduced equipment operating costs, $614 million in CO
2
emission reductions, and $23.3 million in reduced NO
X
emissions. In this case, the net benefits would amount to $1,488 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 in today's rule is $621 million per year in increased equipment costs, while the estimated benefits are $2,048 million per year in reduced operating costs, $614 million in CO
2
emission reductions, and $32.9 million in reduced NO
X
emissions. In this case, the net benefit would amount to approximately $2,074 million per year.
Table I.8—Annualized Benefits and Costs of Energy Conservation Standards for Electric Motors
[Million 2013$/year]
Discount rate
Primary estimate *
Low net benefits estimate *
High net benefits estimate *
Benefits
Consumer Operating Cost Savings
7%
1,367
1,134
1,664
3%
2,048
1,684
2,521
CO
2
Reduction Monetized Value ($12.0/t case) *
5%
166
143
192
CO
2
Reduction Monetized Value ($40.5/t case) *
3%
614
531
712
CO
2
Reduction Monetized Value ($62.4/t case) *
2.5%
920
795
1,066
CO
2
Reduction Monetized Value ($119/t case) *
3%
1,899
1,641
2,200
NO
X
Reduction Monetized Value (at $2,684/ton) **
7%
23.3
20.1
26.8
3%
32.9
28.4
38.0
Total Benefits †
7% plus CO
2
range
1,556 to 3,289
1,297 to 2,795
1,882 to 3,890
7%
2,005
1,685
2,402
3% plus CO
2
range
2,247 to 3,980
1,855 to 3,353
2,750 to 4,758
3%
2,696
2,243
3,270
Costs
Incremental Installed Costs
7%
517
582
503
3%
621
697
616
Net Benefits
Total †
7% plus CO
2
range
1,039 to 2,772
716 to 2,213
1,380 to 3,388
7%
1,488
1,103
1,900
3% plus CO
2
range
1,626 to 3,359
1,158 to 2,656
2,134 to 4,143
3%
2,074
1,546
2,654
* This table presents the annualized costs and benefits associated with electric motors shipped in 2016-2045. These results include benefits to consumers which accrue after 2045 from the equipment purchased in years 2016-2045. Costs incurred by manufacturers, some of which may be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High Benefits Estimates are in view of projections of energy prices from the Annual Energy Outlook (AEO) 2013 Reference case, Low Estimate, and High Estimate, respectively. In addition, incremental equipment costs reflect a medium constant projected equipment price in the Primary Estimate, a declining rate for projected equipment price trends in the Low Benefits Estimate, and an increasing rate for projected equipment price trends in the High Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1.
** The CO
2
values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The value for NO
X
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 CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values.
D. Conclusion
DOE has concluded that the standards in today's final rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy. DOE further notes that equipment achieving these standard levels is already commercially available for most equipment classes covered by today's final rule. Based on the analyses described above, DOE has concluded that the benefits of the 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. However, DOE has concluded that the potential burdens of the more-stringent energy efficiency levels would outweigh the projected benefits.
II. Introduction
The following section briefly discusses the statutory authority underlying today's final rule, as well as some of the relevant historical background related to the establishment of standards for electric motors.
A. Authority
Title III of the Energy Policy and Conservation Act of 1975 (42 U.S.C. 6291,
et seq.;
“EPCA”), Public Law 94-163, sets forth a variety of provisions designed to improve energy efficiency. Part C of title III, which for editorial reasons was re-designated as Part A-1 upon incorporation into the U.S. Code (42 U.S.C. 6311-6317, as codified), establishes the “Energy Conservation Program for Certain Industrial Equipment,” including certain 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 enacted 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))
11
All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law 112-210 (December 18, 2012).
Pursuant to EPCA, DOE's energy conservation program for covered equipment 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 required test procedure is found at 10 CFR part 431, subpart B. 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))
As required by section 343(a)(5)(A) of EPCA, 42 U.S.C. 6314(a)(5)(A), DOE's electric motors test procedures are those procedures specified in two documents: National Electrical Manufacturers Association (NEMA) Standards Publication MG 1 and Institute of Electrical and Electronics Engineers (IEEE) Standard 112 (Test Method B) for motor efficiency.
12
12
DOE also added Canadian Standards Association (CSA) CAN/CSA C390-93, “Energy Efficiency Test Methods for Three-Phase Induction Motors” as an equivalent and acceptable test method, which aligns with industry practices.
Manufacturers of covered equipment must use these methods, as described in appendix B to subpart B of 10 CFR part 431as 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 complies with standards adopted pursuant to EPCA.
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 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 significant conservation of energy. (42 U.S.C. 6295(o)(3) and 6316(a)) Moreover, DOE may not prescribe a standard: (1) For certain commercial and industrial equipment, including electric motors, if no test procedure has been established for the equipment, or (2) if DOE determines by rule that the new and amended standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B) and 6316(a)) In deciding whether a new and amended 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 equipment subject to the standard;
2. The savings in operating costs throughout the estimated average life of the covered equipment in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered equipment 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 equipment 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 standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product or piece of equipment. (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- or equipment-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 equipment 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 equipment 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) Consumes a different kind of energy from that consumed by other covered equipment within such type (or class); or (B) has a capacity or other performance-related feature which other equipment within such type (or class) does not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1) and 6316(a)) In determining whether a performance-related feature justifies a different standard for a group of equipment, DOE must consider such factors as the utility to the consumer of such a 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 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 on or 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) and 6313(b)) The current standards for these motors (available at 10 CFR 431.25(a)-(e)), which are reproduced in the regulatory text at the end of this rulemaking, 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 codify the EPACT 1992 electric motor requirements. See 64 FR 54114. After EISA 2007's enactment, DOE updated, among other things, the corresponding electric motor regulations at 10 CFR part 431 by incorporating the new definitions and energy conservation standards that the law established.
See
74 FR 12058 (March 23, 2009). DOE subsequently updated its test procedures for electric motors and small electric motors,
see
73 FR 78220 (December 22, 2008), and later finalized key provisions related to small electric motor testing.
See
74 FR 32059 (July 7, 2009). Further updates to the test procedures for electric motors and small electric motors followed when DOE issued a rule that primarily focused on updating various definitions and incorporations by reference related to the current test procedure.
See
77 FR 26608 (May 4, 2012). That rule defined the term “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 also published a new test procedure on December 13, 2013, that further refined various electric motor definitions and added certain definitions and test procedure preparatory steps to address a wider variety of electric motor types than are currently regulated, including those electric motors that are largely considered to be special-or definite-purpose motors. 78 FR 75961.
DOE received numerous comments from interested parties who provided significant input to DOE in response to DOE's framework document and preliminary analysis for this rulemaking.
See
75 FR 59657 (September 28, 2010) (framework document notice of availability) and 77 FR 43015 (July 23, 2012) (preliminary analysis notice of availability). All such comments were addressed in the December 6, 2013, notice of proposed rulemaking (standards NOPR). 78 FR 73589 During the framework document comment period, 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”
13
) submitted the “Joint Petition to Adopt Joint Stakeholder Proposal As it Relates to the Rulemaking on Energy Conservation Standards for Electric Motors” (the “Petition”) to DOE asking the agency to adopt a consensus stakeholder proposal that would amend the energy conservation standards for electric motors.
14
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 adopts in today's notice (
i.e.,
efficiency levels in NEMA MG 1-2011 Tables 12-12).
15
(Motor Coalition, No. 35 at pp. 1-3) Several interested parties submitted comments supporting the Petition, including: U.S. Senators Lisa Murkowski and Jeff Bingaman, BBF and Associates, the Air Movement and Control Association International, Inc., the Hydraulic Institute, the Arkansas Economic Development and Commission—Energy Office, and the Power Transmission Distributors Association.
13
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.
14
The Petition is available at:
http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0027-0035
.
15
DOE's final rule differs from the Motor Coalition's proposal in that DOE's rule covers all types of brake electric motors and does not set separate, lower standards for U-frame motors and does not cover open, special- and definite-purpose 56-frame motors.
3. Process for Setting Energy Conservation Standards
Section 325(o) of EPCA (as applied to covered equipment via 42 U.S.C. 6316(a)), 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 seven factors listed at 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII) (as applied to commercial equipment via 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).
The Motor Coalition expressed concern that much of the relevant information regarding electric motors spans various rulemaking documents. It requested that DOE consolidate all documents related to electric motors at one place, which can serve as a quick and easy reference for any consumer or
manufacturer in the U.S or outside the U.S. (Motor Coalition, Pub. Mtg. Tr., No. 87 at p. 20-21) Baldor expressed similar concerns and suggested that DOE clearly state in the Code of Federal Regulations (CFR) whatever information manufacturers need to comply with standards. (Baldor, No. 100 at p. 2) NEMA commented that the notice needs to be clearer and unambiguous so that it is easier for anyone (such as offshore suppliers) to follow it. It added that the final rule should include all required information. (NEMA, Pub. Mtg. Tr., No. 87 at p. 46-47)
First, DOE notes that its regulatory requirements are incorporated into the CFR. The regulations laid out in the CFR comprise the official set of requirements that a regulated entity must follow. While any member of the public (including manufacturers) may seek guidance from DOE, the requirements laid out in the CFR provide the regulatory framework that manufacturers must follow and apply when determining which (if any) requirements a given motor must meet. DOE may issue related guidance documents, if needed, which are available on its Web site at
http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1
. Finally, it is worth noting that the division of regulations in 10 CFR 431.25(a)-(f) (for currently regulated electric motors) and 10 CFR 431.25(g)-(l) (for newly regulated electric motors) was developed as a mechanism to demonstrate the upcoming change in standards without creating confusion about existing standards. At some point in the future after the new standards being adopted in this final rule have been in effect for some time, DOE anticipates removing the standards currently at 10 CFR 431.25(a)-(f), as DOE has done in the past.
III. General Discussion
DOE developed today's 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 Association International, Inc.
AMCAI
Trade Association.
Alliance to Save Energy
ASE
Energy Efficiency Advocates.
American Council for an Energy-Efficient Economy
ACEEE
Energy Efficiency Advocates.
American Forest & Paper Association
AF&PA
Trade Association.
American Fuel & Petrochemical Manufacturers
AFPM
Trade Association.
Appliance Standards Awareness Project
ASAP
Energy Efficiency Advocates.
Baldor Electric Co.
Baldor
Manufacturers.
BBF & Associates
BBF
Representative for Trade Association.
California Energy Commission
CEC
State Government Agency.
California Investor Owned Utilities
CA IOUs
Utilities.
Cato Institute
Cato
Public Interest Group.
China WTO/TBT National Notification & Enquiry Center
China WTO/TBT
Chinese Government Agency.
Copper Development Association
CDA
Trade Association.
Earthjustice
Earthjustice
Energy Efficiency Advocates.
Edison Electric Institute
EEI
Association of U.S. investor-owned electric companies.
Electric Apparatus Service Association
EASA
Trade Association.
European Committee of Manufacturers of Electrical Machines and Power Electronics
CEMEP
Trade Association.
Flolo Corporation
Flolo
Electromechanical Repairer.
Greg Gerritsen
Gerritsen
Individual.
Industrial Energy Consumers of America
IECA
Trade Association.
Motor Coalition*
MC
Energy Efficiency Advocates, Trade Associations, Manufacturers, Utilities.
National Electrical Manufacturers Association
NEMA
Trade Association.
Natural Resources Defense Council
NRDC
Energy Efficiency Advocates.
Nidec Corporation
Nidec
Manufacturer.
NORD Gear Corporation
NORD Gear
Manufacturer.
Northwest Energy Efficiency Alliance
NEEA
Energy Efficiency Advocates.
Northeast Energy Efficiency Partnerships
NEEP
Energy Efficiency Advocates.
Northwest Power & Conservation Council
NPCC
Utilities.
Oakland University
OU
Academic Institution.
PlasticMetal
PlasticMetal
Non-motor Manufacturer.
Regal Beloit
Regal Beloit
Manufacturer.
Scott Mohs
Scott
Individual.
SEW-Eurodrive, Inc.
SEWE
Manufacturer.
Siemens
Siemens
Manufacturer.
Southern California Edison
SCE
Utility.
UL LLC
UL
Testing Laboratory.
University of Michigan
UMI
Academic Institution.
WEG Electric Corporation
WEG
Manufacturer.
* 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).
A. Compliance Date
During the NOPR public meeting and in written comments, many interested parties, including the Motor Coalition, requested that DOE provide at least two years for compliance from the date of publication of the final rule. (Motor Coalition, Pub. Mtg. Tr., No. 87 at pp. 21-22; NEMA, Pub. Mtg. Tr., No. 87 at p. 29; CA IOUs, Pub. Mtg. Tr., No. 87 at p. 31; ASAP, Pub. Mtg. Tr., No. 87 at p. 32; CEMEP, No. 89 at p. 2; Joint Advocates,
16
No. 97 at p. 3; NEMA, No. 93 at p. 7; CA IOUs, No. 99 at p. 2; Nidec, No. 98 at pp. 2-3; SCE, No. 101 at p. 2)
16
For the purposes of this document, “Joint Advocates” is a term used to describe NPCC, NEEA, ACEEE, ASAP, Earthjustice, ASE, NRDC, and NEEP, who commented jointly.
DOE received other comments on the proposed compliance date for the newly covered equipment requesting that DOE provide more than two years after publication of the final rule for newly covered motors to comply with today's standards because such motors may require testing and/or modification of original equipment manufacturer (OEM) equipment within which these motors are used. (NEMA, No. 93 at p. 7; NEMA, Pub. Mtg. Tr., No. 87 at p. 30-31) Regal Beloit commented that manufacturers of these newly covered motors should be given 48 months for compliance, whereas EEI argued for a three-year lead time for such motors. (Regal Beloit, Pub. Mtg. Tr., No. 87 at pp. 34-35; EEI, Pub. Mtg. Tr., No. 87 at pp. 24-25, 33) EEI also noted that many manufacturers should be fine with a two-year compliance lead time for already-covered equipment since they anticipated the change in regulatory requirements coming after EISA 2007. (EEI, Pub. Mtg. Tr., No. 87 at pp. 24-25, 33) DOE notes that NEMA, as part of the Motor Coalition, had commented earlier in the Petition that a two-year compliance lead time would be sufficient for all motors covered by today's rule and this stance was reiterated by the Motor Coalition representative at the NOPR public meeting and NEMA in their NOPR comments. (Motor Coalition, Pub. Mtg. Tr., No. 87 at pp. 21-22; Motor Coalition, No. 35 at p. 9; NEMA, No. 93 at p. 7)
Regarding the compliance date that would apply to the requirements of today's rule, the energy conservation standards established under EISA 2007 went into effect after the three-year period beginning on the date of enactment of EISA 2007. Under 42 U.S.C. § 6313(b)(4)(B), EPCA directs the Secretary of Energy to publish a final rule amending such standards and to apply the rule to electric motors manufactured five years after the effective date EISA 2007. DOE is relying on the Congressionally established two-year spread between the effective date of the latest amendments to electric motor energy conservation standards and the date by which DOE must amend such standards to arrive at the two-year lead-time for manufacturers to comply with today's rule after its date of issuance.
See
42 U.S.C. 6313(b).
B. 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 add some necessary steps to facilitate the testing of certain motor types that DOE does not currently require to meet standards. During the 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.
See
78 FR 38456.
On December 13, 2013, DOE published a test procedure final rule (2013 test procedure) that incorporated comments from the test procedure NOPR and added and clarified both definitions and testing instructions for a variety of electric motors that DOE was considering for regulation under this standards rulemaking. 78 FR 75961. The test procedure changes published in the 2013 final test procedure allow DOE to require testing and compliance to meet the energy conservation standards established today.
Commenting on DOE's recent round of electric motor rulemakings, Baldor raised concerns that developing the standards rulemaking and test procedures rulemaking in parallel has caused inconsistencies that need to be resolved. For example, the 2013 test procedure used the term “brake electric motor” to refer jointly to what the standards NOPR published earlier had called “integral” and “non-integral” brake electric motors. Baldor suggested that definitions for NEMA Design A and B motors in the 2013 test procedure should refer to nine characteristics for covered equipment that are laid out in the NOPR. (Baldor, No. 100 at p. 7)
Inconsistencies, if any, are resolved in today's rule. DOE developed the nine criteria in 10 CFR 431.25(g) below to characterize all of the newly covered and currently covered motor types. Therefore, adding these characteristics to the definitions for motor types is unnecessary. Moreover, as described earlier, the regulatory structure proposed by DOE and adopted in this rule preserves the existing standards and structure for currently regulated motors while providing a new section for new standards for motors being regulated for the first time and amended standards for currently regulated motors.
CEC recommended that DOE should add definitions of continuous duty and duty type S1 (IEC) in 10 CFR 431.12. It also recommended that DOE revise the current definitions of NEMA Design A, B, and C motors to update the reference from NEMA MG 1-2009 to the revised document ANSI/NEMA MG 1-2011. (CEC, No. 96 at p. 3)
DOE understands that “continuous” and “S1” are terms well understood by the motor industry, and DOE has therefore not established definitions for these terms. DOE clarifies in this rule that these terms are used to designate a motor that can operate indefinitely in rated conditions and reaches thermal equilibrium. This stands in contrast to motors that may be rated for intermittent operation or with specific loading, braking, or starting restrictions.
With respect to the MG 1 publication version, DOE notes that the terms mentioned by CEC are identical in both versions of MG 1. DOE, therefore, finds there is no reason to amend the reference.
1. Vertical Electric Motors
NEMA and Nidec both suggested several modifications in the test procedure for vertical electric motors and expressed concern that, without these changes, it will be difficult for manufacturers to test vertical electric motors correctly for compliance purposes. (NEMA, No. 93 at p. 29; Nidec, No. 98 at p. 9-10)
DOE recognizes the desire for clarification in the 2013 test procedure for vertical electric motors, but notes that the rule has now gone into effect and the changes suggested by commenters are beyond the scope of today's energy conservation standard. Based on stakeholder concerns, however, DOE will evaluate whether further clarification on the testing of vertical electric motors is necessary.
C. Current Equipment Classes and 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 justifies a different standard, DOE must consider factors such as the utility to the consumer of the feature and other factors 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 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.
D. Updated Equipment Classes and 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 first provided DOE with the statutory authority to regulate “electric motors,” which were defined as including certain “general purpose” motors. (42 U.S.C. 6311(13)(A) (1992)) In addition to defining this term, Congress prescribed specific energy conservation standards for electric motors (
i.e.,
general purpose electric motors (subtype I). EPACT 1992 also defined the terms “definite purpose motors” and “special purpose motor”. (42 U.S.C. 6311(13)(C) and (D) (1992)) EPACT 1992 explicitly excluded definite purpose and special purpose motors from the prescribed standards. (42 U.S.C. 6313(b)(1) (1992)) However, EISA 2007 struck the narrow EPACT 1992 definition of “electric motor”. (42 U.S.C. 6311(13)) 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, it did not apply those standards to definite or special purpose motors. (42 U.S.C. 6313(b) (2012))
Consistent with EISA 2007's reworking of the “electric motor” definition, the 2012 test procedure broadly defined the term “electric motor”. 77 FR 26608 (codified at 10 CFR 431.12). In view of the changes introduced by EISA 2007 and the absence of energy conservation standards for special purpose and definite purpose motors, it is DOE's view that both of these motors are categories of “electric motors” covered under EPCA, as currently amended. Accordingly, DOE added the term “electric” to the definitions of “special purpose motor” and “definite purpose motor” in the 2013 test procedure.
See
78 FR 75994. Today's rule amends and establishes standards for a variety of electric motors, including certain definite purpose and special purpose motors. DOE is setting energy conservation standards for any electric motor exhibiting all of the following nine characteristics:
(1) Is a single-speed, induction motor,
(2) Is rated for continuous duty (MG 1) operation or for duty type S1 (IEC),
(3) Contains a squirrel-cage (MG 1) or cage (IEC) rotor,
(4) Operates on polyphase alternating current 60-hertz sinusoidal line power,
(5) Is rated 600 volts or less,
(6) Has a 2-, 4-, 6-, or 8-pole configuration,
(7) Is built in a three-digit or four-digit NEMA frame size (or IEC metric equivalent), including those designs between two consecutive NEMA frame sizes (or IEC metric equivalent), or an enclosed 56 NEMA frame size (or IEC metric equivalent),
(8) Produces at least 1 horsepower (0.746 kW) but not greater than 500 horsepower (373 kW), and
(9) Meets all of the performance requirements of a NEMA Design A, B, or C motor or of an IEC Design N or H motor.
However, the updated standards specifically do not apply to the following equipment:
• Air-over electric motors;
• Component sets of an electric motor;
• Liquid-cooled electric motors;
• Submersible electric motors; and
• Inverter-only electric motors.
To facilitate the potential application of energy conservation standards to special and definite purpose motors, DOE defined certain motors and provided certain preparatory test procedure steps in the 2013 test procedure.
See
78 FR 75961. DOE chose not to establish standards for the component sets of an electric motor, liquid-cooled, submersible, and inverter-only electric motors listed above because of the current absence of a reliable and repeatable method to test them for efficiency. If a test procedure becomes available, DOE may consider setting standards for these motors at that time. For air-over electric motors, during the course of the test procedure rulemaking, DOE learned about a possible test procedure for such motors but DOE does not currently have enough information to support the establishment of a test method. 78 FR 75975.
Finally, as discussed in the NOPR, although DOE believes that EPCA, as amended through EISA 2007, provides sufficient statutory authority to regulate a wider variety of electric motors (including those commonly referred to as special purpose or definite purpose motors) than those already regulated as “electric motors,” DOE notes that section 10 of the American Energy Manufacturing Technical Corrections Act (“AEMTCA”), Public Law 112-210 (December 18, 2012), amended DOE's authority to regulate commercial and industrial equipment by including “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 motors” that EPCA already treats as covered industrial equipment.
17
17
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 rule, DOE has 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.
In response to the NOPR, the Motor Coalition recognized that DOE's proposed broadening of the scope of motors that would be covered at TSL 2 efficiency levels is consistent with the Petition. (Motor Coalition, Pub. Mtg. Tr., No. 87 at pp. 18-19) NEMA agreed with DOE's proposed expansion of scope of coverage, noting that it is largely consistent with the Petition. (NEMA, No. 93 at p. 3) Nidec commented that DOE's proposal presents a sufficiently broad scope of coverage and that no further adjustment is needed. (Nidec, No. 98 at p. 5) The CA IOUs supported DOE in adopting TSL 2 for most equipment class groups. (CA IOUs, No. 99 at pp. 1-2) The Joint Advocates supported the proposed standards, noting that the standards will save 7 quads of energy over thirty years of equipment sales and will significantly contribute to the President's Climate Action Plan goal for new standards. It urged DOE to complete the final rule by May 2014 as previously committed to the Attorneys General of several states. (Joint Advocates, No. 97 at p. 2) The European Committee of Manufacturers of Electrical Machines and Power Electronics (CEMEP) expressed support for increasing certain motor efficiency standards to TSL 2, or NEMA Table 12-12. CEMEP noted that DOE is appropriately considering impacts on and perspectives of OEMs and end users, as well as global harmonization issues. (CEMEP, No. 89 at p. 2) Gerritsen supported the proposed standards, noting that is the standards are essential to curb carbon dioxide emissions. (Gerritsen, No. 81 at p. 1) Southern California Edison commented that they support DOE in adopting TSL 2,
i.e.
, NEMA Premium®
18
levels, noting that these will lead to “the maximum improvement in energy efficiency that is technologically feasible and economically justified” as well as significant energy savings. In view of significant energy savings and general stakeholder support, SCE requested that DOE publish final rule soon. (SCE, No. 101 at pp. 1-2)
18
DOE notes that “NEMA Premium” is a registered trademark of NEMA. NEMA has removed the term “NEMA” from the title of MG 1-2011, Table 12-12. Unless indicated otherwise, in the remainder of this document, any reference to “premium” standards should be considered a reference to MG 1-2011, Table 12-12.
The Copper Development Association (CDA) supported DOE's current rulemaking and the inclusion of additional motor categories and requiring motors that operate at 201 hp through 500 hp to meet premium standards. CDA suggested that DOE investigate covering motors over 500 hp and currently uncovered motors 1 hp through 500 hp for future rulemaking. CDA noted that motors over 500 hp consume 27 percent of all U.S. energy consumed by motors in operation. Noting that some manufacturers even currently offer motors significantly above premium efficiency levels, CDA suggested that DOE investigate the development of a new even higher energy efficiency category—“super premium” above the current premium efficiencies. (CDA, No. 90 at pp. 1-2)
DOE may consider expanding the scope of its regulations to large motors, which carry different technologies and usage patterns, in future updates to the rule. At that time, DOE would consider any efficiency levels beyond premium efficiency in place and evaluate them for standards.
E.
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.
After DOE has determined 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 equipment utility or availability; and (3) adverse impacts on health or safety. Section IV.B of this rule discusses 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 final TSD.
2. Maximum Technologically Feasible Levels
When DOE adopts a new or amended standard for a type or class of covered equipment, 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. (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 final TSD.) The max-tech levels that DOE determined for this rulemaking are described in section IV.C.3 of this final rule.
In response to the NOPR, CEC claimed that DOE has not provided the technological feasibility and economic justification as required by statute for updating the existing energy consumption standards for general purpose electric motors (subtype I or II) that are not NEMA Design A, B, or C, or IEC Design N or H, and for polyphase motors rated between 1 and 250 hp (2 poles) and motors between 1 and 350 hp (8 poles). It further stated that DOE did not provide market and technology analysis for motors greater than 500 hp, motors with more than 8 poles and shaded pole motors. (CEC, No. 96 at pp. 1, 3)
DOE acknowledges that the motors in the scope of today's rulemaking are not the only possible motors for which standards may produce economically justified energy savings. As detailed above, DOE's electric motor regulations came about due to statutory requirements that initially included a narrow scope of electric motors that DOE could regulate, but that has become increasingly broad with the changes brought about by EISA 2007 and AEMTCA. As that universe of electric motors that DOE is authorized to regulate expands, DOE considers other motor types that it may regulate under the statute and considers what types of electric motors use large amounts of energy, are produced in large volume, and have opportunities for efficiency gains. DOE may consider future regulation of some of the motor types which CEC mentions and welcomes data that illustrates savings potential of currently unregulated technologies.
The University of Michigan and Oakland University (UMI & OU)
suggested that before finalizing the current rulemaking, DOE should conduct a study to update National Electrical Code Table 430.250, which is used to design circuits of motors covered by current regulation. UMI & OU suggested that before finalizing the current rulemaking, a study should be conducted to determine the optional method of establishing the nameplate ratings of combination HVAC equipment rated according to running load amperes. (UMI & OU, No. 92 at pp. 1-2)
DOE understands that NEC Table 430.250, mentioned by UMI & OU, helps engineers specify wiring in building by providing current as a function of motor power, voltage, and power factor. DOE understands that more efficient motors may cause application engineers to differently design building circuits which contain electric motors. If such changes brought by a technology have adverse impacts to safety or equipment utility, DOE may opt to remove that technology from consideration in its screening analysis. Presently, DOE has not learned of any such expected impacts resulting from the standard levels selected in today's rule. Moreover, the National Electrical Code is developed by the National Fire Protection Association (NFPA) and DOE has no authority to change this code.
F. 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 (2016-2045). The savings are measured over the entire lifetime of equipment purchased in the 30-year period.
19
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.
19
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 energy savings from new and amended standards for electric motors subject to this rulemaking. The NIA spreadsheet model (described in section IV.H of this rule) 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, which is referred to as primary energy. To convert electricity in kWh to primary energy units, on-site electricity consumption is multiplied by the site-to-power plant energy use factor (see TSD chapter 10). The site-to-power plant energy use factor is defined as the ratio of the marginal change in total primary energy consumption by the electric power sector (in quadrillion Btu's) divided by the change in total electricity generation due to a standard. DOE derives site-to-power plant energy use factors from the model used to prepare the Energy Information Administration's (EIA)
Annual Energy Outlook (AEO).
DOE also estimates 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 (
i.e.,
coal, natural gas, petroleum 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.
20
The NAS report discusses that FFC was primarily intended for energy efficiency standards rulemakings where multiple fuels may be used by a particular product or piece of equipment. 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. Although, the addition of FFC energy savings in the rulemakings is consistent with the recommendations, 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 standards.
20
“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:
http://www.nap.edu/catalog.php?record_id=12670
.
2. Significance of Savings
As noted above, 42 U.S.C. 6295(o)(3)(B) (as applied to equipment via 6316(a)) 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.
G. 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) (as applied to equipment via 6316(a))) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a 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.
21
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.
21
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. These measures are discussed further 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. DOE also evaluates the LCC impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a national standard.
b. Life-Cycle Costs
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered equipment compared to any increase in the price of the covered equipment that are likely to result from the imposition of the standard. (42 U.S.C. 6295(o)(2)(B)(i)(II) and 6316(a)) DOE conducts this comparison in its LCC and PBP analysis.
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 the equipment. 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. For its analysis, DOE assumes that consumers will purchase the covered equipment in the first year of compliance with amended standards.
The LCC savings for the considered efficiency levels are calculated relative to a base case that reflects projected market trends in the absence of amended standards.
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.
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) and 6316(a)) As discussed in section IV.H, DOE uses the NIA spreadsheet to project national site energy savings.
d. Lessening of Utility or Performance of Products
In establishing classes of equipment, 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 equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV) and 6316(a)) As noted earlier, the substance of this provision applies to the equipment at issue in today's rule as well. DOE has determined that the standards in today's notice will not reduce the utility or performance of the equipment under consideration in this rulemaking. Currently, many motors are already commonly being sold at the selected levels (
i.e.,
“premium efficiency” designation). In addition, the selected standards closely track the recommendations of NEMA, a trade association that represents electric motor manufacturers. DOE assumes that NEMA would not recommend efficiency levels that would harm electric motor performance or utility.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition that is likely to result from the imposition of a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V) and 6316(a)) It also directs the Attorney General of the United States to determine the impact, if any, of any lessening of competition likely to result from a 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)(i)(V) and (B)(ii)) To assist the Attorney General in making a determination for electric motor standards, DOE provided the Department of Justice (DOJ) with copies of the NOPR and the TSD for review. DOE received no adverse comments from DOJ regarding the proposal.
f. Need for National Energy Conservation
The energy savings from today's 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.
Today's 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 rule. 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) and 6316(a)) In developing this final rule, DOE has also considered the submission of the Petition, which DOE believes sets forth a statement by interested persons that are representative of relevant points of view (including representatives of manufacturers of covered equipment, and efficiency advocates) and contains recommendations with respect to an energy conservation standard. DOE has encouraged the submission of consensus agreements as a way to bring diverse interested parties together, to develop an independent and probative analysis useful in DOE standard setting, and to expedite the rulemaking process. DOE also believes that standard levels recommended in the Petition may increase the likelihood for regulatory compliance, while decreasing the risk of litigation.
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 or piece of equipment 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 effect potential amended energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-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 final rule.
IV. Methodology and Discussion of Related Comments
DOE used four spreadsheet tools to estimate the impact of today's standards. The first spreadsheet calculates LCCs and PBPs of potential new energy conservation standards. The second provides shipments forecasts and the third calculate 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 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 standards analysis is called NEMS-BT
22
and is based on the
AEO
version with minor modifications.
23
22
BT stands for DOE's Building Technologies Program.
23
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) (February 1998), available at:
http://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 2012 test procedure added clarity to the definitions for each of these motor categories, which are now codified at 10 CFR 431.12. 77 FR 26608.
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 characteristics provided in the definitions of general purpose electric motor (subtype I or subtype II) at 10 CFR 431.12 determine whether an IEC motor should be considered subtype I or II. All of these elements flow directly from the statutory changes enacted by EISA 2007. Currently, electric motors are required to meet energy conservation standards as follows:
Table IV.1—Current Electric Motor Energy Conservation Standards
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Electric motor category
Horsepower range
Energy conservation
standard level
General Purpose Electric Motors (Subtype I)
1 to 200 (inclusive)
MG 1-2011 Table 12-12.
General Purpose Electric Motors (Subtype II)
1 to 200 (inclusive)
MG 1-2011 Table 12-11.
NEMA Design B and IEC Design N Motors
201 to 500 (inclusive)
MG 1-2011 Table 12-11.
Fire Pump Electric Motors
1 to 500 (inclusive)
MG 1-2011 Table 12-11.
In response
to the NOPR, NEMA commented that the proposed standards do not resolve the confusion regarding IEC electric motors. NEMA explained that it is not clear whether an electric motor in an IEC frame size that meets the other criteria of a general purpose electric motor (subtype I) would be classified as equivalent to a T-frame, hence subtype I, or U-frame, hence subtype II. Therefore, NEMA suggested that IEC frame sizes be considered equivalent to NEMA T-frames. NEMA suggested that the pertinent portion of the definition of “general purpose electric motor (subtype II)” in 10 CFR 431.12 should be revised from “(i) A U-Frame motor” to read “(i) Is built in accordance with NEMA U-frame dimensions as described in NEMA MG 1-1967 (incorporated by reference, see § 431.15), including a frame size that is between two consecutive NEMA frame sizes.” (NEMA, No. 93 at pp. 3-5, 32)
24
For the purposes of determining compliance, DOE assesses a motors horsepower rating according to the provisions of 10 CFR 431.25(e).
Changes to the applicability of the electric motor standards currently in effect are outside the scope of this rulemaking. Additionally, DOE notes that NEMA's proposed changes to the definition of “general purpose electric motor (subtype II)” reflect that it may have been looking at an older version of the definition rather than the current
definition found at 10 CFR 431.12. DOE notes that the current definition of “general purpose electric motor (subtype II)” already includes the language being suggested by NEMA.
2. Expanded Scope of Electric Motor Energy Conservation Standards
a. Summary
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 rule. 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 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)
DOE is now requiring electric motor types beyond those currently covered 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 establishes energy conservation standards for electric motors that exhibit all of the characteristics listed in Table IV.2, with a limited number of exceptions, listed in Table IV.4.
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 built in a three-digit or four-digit NEMA frame size (or IEC metric equivalent), including those designs between two consecutive NEMA frame sizes (or IEC metric equivalent), or an enclosed 56 NEMA frame size (or IEC metric equivalent),
Produces at least 1 horsepower (0.746 kW) but not greater than 500 horsepower (373 kW) and
Meets all of the performance requirements of a NEMA Design A, B, or C motor or of an IEC Design N or H electric motor.
Table IV.3 lists the formerly unregulated electric motor types that will be covered by today's rule. Further details and definitions for the specific motor types can be found in DOE's 2013 test procedure. 78 FR 75961.
Table IV.3—Currently Unregulated Motor Types That Are Covered by This Rule
Electric Motor Type
NEMA Design A from 201 to 500 horsepower
Electric motors with non-standard endshields or flanges.
Electric motors with moisture resistant windings
Electric motors with non-standard bases.
Electric motors with sealed windings
Electric motors with special shafts.
Partial electric motors
Vertical hollow-shaft electric motors.
Totally enclosed non-ventilated (TENV) electric motors
Electric motors with sleeve bearings.
Immersible electric motors
Electric motors with thrust bearings.
Brake electric motors
Electric motors with encapsulated windings.
Electric motors with separately powered blowers
However, the new standards specifically do not apply to the following equipment:
Table IV.4—Equipment Specifically Excluded From Coverage
Electric Motor Type
Air-over electric motors.
Component sets of an electric motor.
Liquid-cooled electric motors.
Submersible electric motors.
Inverter-only electric motors.
Additionally, DOE is clarifying the design, construction, and performance characteristics of covered electric motors. Specifically, DOE is clarifying that only motors rated from 1 to 500 horsepower (inclusive), or their IEC equivalents, would be covered by the standards established in today's rulemaking. Finally, with regard to IEC-frame motors, DOE's standards would not regulate IEC motors on the singular basis of frame size, but would regulate such motors if they meet all the criteria of Table IV.2. In other words, an IEC-frame motor that meets these nine criteria and does not fit within one of the five exceptions would have to meet today's final standards.
In response to the NOPR, DOE received several comments on its scope criteria. CEMEP supported the nine characteristics to define electric motors, noting that using those criteria to define covered motors will lead to huge energy savings by covering millions of units. CEMEP believed that the nine characteristics definition can be applied by customs and other enforcement officers to improve overall enforcement activities. (CEMEP, No. 89 at p. 2).
Nidec commented that DOE should bring more clarity to characteristic #8 (
i.e.,
1-500 hp as proposed as (g)(8)) by including kilowatt values corresponding to the given horsepower values (
e.g.,
500 horsepower (343 kilowatts), 1 horsepower (0.75 kilowatt). (Nidec, No. 98 at pp. 2, 7-8) DOE believes this is a helpful suggestion that comports with the inclusion of IEC motors in today's rulemaking and is incorporating the suggestion into today's rule.
NEMA sought clarification regarding whether solid shaft medium and high thrust motors are included in the scope of coverage. (NEMA, No. 93 at p. 27) During the NOPR public meeting, CEC and EEI requested clarification on whether pool pump motors are covered under new standards or by the Small Electric Motors regulations. (CEC, Pub. Mtg. Tr., No. 87 at p. 55) The CA IOUs commented during the public meeting that most pump motors are single-phase and, sometimes, variable-speed, both of which would disqualify motors from coverage. (CA IOUs, Pub. Mtg. Tr., No. 87 at pp. 55-56). Nidec added its belief that the small motor rule does not cover variable speed motors. (Nidec, Pub. Mtg. Tr., No. 87 at p.56).
Any motor that meets the nine criteria as given in paragraph (g) and which is not explicitly exempted by criteria given in paragraph (m) is covered under the current rulemaking. Both single-phase and variable speed motors are not
covered in today's rule, and so any motor with those qualities would not be subject to today's standards.
b. Definitions, Terminology, and Regulatory Language
In response to the NOPR, DOE received a number of comments requesting clarification on its choice of terminology.
“Motor” and “Electric Motor”
Baldor commented that the use of the terms “motor” and “electric motor” interchangeably in the NOPR is very confusing. DOE understands that the terms “motor” and “electric motor” may refer to a variety of machines outside of its regulatory context. In the NOPR, DOE used the terms to mean the same thing. 78 FR 73589. In addition, because there are no NEMA Design B motors, for example, that are not electrically driven, in DOE's view, the potential for ambiguity is minimal.
The Department chose to not include the term “electric” in the NEMA-designated motor types to be consistent with NEMA's definitions. In the regulatory context, however, DOE does not consider there to be any difference between the two terms and notes that all motors currently regulated under 10 CFR part 431, subpart B, are electric motors as stated in the title to 10 CFR part 431, subpart B and the purpose and scope section at 10 CFR 431.11. Moreover, NEMA itself uses the term “motor” in MG 1 to refer to electric motors.
Specificity of Definitions
Baldor stated that the definitions for “NEMA Design A motor” and “NEMA Design B motor” in 2013 test procedure does not make reference to nine characteristics listed in paragraph (g) and, thus, implies that it includes multi-speed motors, motors rated for voltages greater than 600 volts, motors rated for only 50 Hz, and motors constructed with more than 8 poles. According to Baldor, this conflicts with DOE's proposed scope of coverage in Table 4 and Table 5 of the NOPR. It noted that paragraph (i) and Table 6 for NEMA Design C motor are similarly confusing. (Baldor, No. 100 at pp. 2-4)
DOE agrees with Baldor that minimizing ambiguity in regulatory text is critical. In this case, however, DOE does not see the potential for confusion. DOE believes that today's regulatory text is of sufficient clarity that stakeholders will understand that the new standards apply only to those motors that meet the nine criteria in the new 10 CFR 431.25(g).
NEMA Design A, B or C motors are not defined to include these nine characteristics, which DOE is using to narrow the scope of covered electric motors. The definition of NEMA Design A may include multi-speed motors, motors rated for voltages greater than 600 volts, motors rated for only 50 Hz, and motors constructed with more than 8 poles. However, only NEMA Design A motors meeting all nine characteristics in § 431.25(g) are covered under today's rule. DOE's regulatory structure maintains the current standards at 10 CFR 431.25(a)-(f) while adding broader coverage in new paragraphs (g) through (l). The structure that DOE chose preserves the current regulatory text and allows DOE to use the same definitions for all motors covered under 10 CFR 431.25.
“NEMA Design A Motor” Correction
NEMA commented that the definition for NEMA Design A motor needs to be corrected by replacing the phrase “has a locked rotor current not to exceed” the values shown in NEMA MG 1-2009, as proposed in the NOPR with “has a locked rotor current higher than” the values shown in NEMA MG 1-2009. (NEMA, No. 93 at p. 29) The Joint Advocates requested that DOE consider NEMA's comments on definitions to bring clarity to the covered motors. (Joint Advocates, No. 97 at p. 3)
DOE agrees with NEMA that the Department inadvertently used the incorrect phrase when discussing the locked rotor current in the definition of a “NEMA Design A motor”. As evidenced in the preamble of the 2013 test procedure (78 FR 75968) and the preamble and regulatory text of the proposed test procedure (78 FR 38462, 38481), DOE intended to include locked rotor current that exceeds the maximum locked rotor current established for a NEMA Design B motor in the “NEMA Design A motor” definition. In today's rule, DOE is modifying the regulatory text accordingly.
“NEMA Design C Motor” Correction
NEMA suggested DOE revise paragraph (i) and the title of Table 6 of the proposed 10 CFR 431.25 by replacing “NEMA Design C electric motor” with “NEMA Design C motor” for consistency with DOE's regulatory definitions.
As described above, DOE agrees, and has made the corresponding change in the regulatory text for consistency with the definitions adopted in the 2013 test procedure. DOE notes that it has further corrected the reference to “NEMA Design A and B motors” in the title of Table 5 to be consistent with the DOE regulatory definitions.
“Inverter-Only Electric Motor” Definition
Baldor and NEMA raised concerns that DOE has defined “inverter-only electric motor” and not “definite-purpose, inverter-fed electric motors” which is the term that the NOPR referenced. Baldor noted that the term “definite-purpose, inverter-fed electric motors” is preferred and recognized by the motor industry as given in Part 31 of the NEMA MG 1 standard. (Baldor, No. 100 at p. 6; NEMA at pp. 2-3)
Although DOE has previously used the term “definite-purpose, inverter-fed electric motor,” DOE instead adopted the term “inverter-only electric motor” in its 2013 test procedure because ”definite-purpose'” is a term that has meaning in the context of many other motor types which DOE does not wish to be confused with those requiring inverters. DOE also wishes to define these motors in terms of their actual capabilities instead of design intent.
See
78 FR 75989.
c. Horsepower Rating
DOE's proposed standards include only motors rated from 1-500 horsepower, inclusive. In its comments, NEMA agreed with DOE's decision not to cover fractional hp motors, noting that these motors do not fall within the scope of rating for which NEMA Design A, B and C performance standards are defined. (NEMA, No. 93 at p. 15) Consequently, DOE is continuing not to regulate fractional horsepower, enclosed, 56-frame motors in today's notice.
d. High-Horsepower Six- and Eight-Pole Motors
NEMA noted that Table 2 does not contain the higher horsepower ratings for large motors in 6 and 8 poles that are added in Table 7 and it suggested that DOE conform Table 7 to Table 2. (NEMA, No. 93 at pp. 23-26) Baldor made a similar comment. (Baldor, No. 100 at p. 4)
In keeping with the Motor Coalition's Petition and with MG 1-2009, DOE had proposed standards for motors with certain high horsepower and pole ratings (8-pole above 250 hp and 6-pole above 350 hp) that NEMA commented do not exist under MG 1's medium motors designations. For example, it is impossible to produce a NEMA Design A 6-pole motor of 400 hp because the criteria required to qualify a medium
motor as Design A
25
do not extend to such a high horsepower motor. NEMA notes that the table in the 2011 version of MG 1 has corrected the mistake of MG 1-2009 and moved these higher horsepower motors to the large motor Table 20-20 of MG 1. In its written comments in response to the NOPR, NEMA asked DOE not to adopt standards for motors of this pole and horsepower configuration because NEMA Design A and B types are not defined for and are not applicable to large motors. (NEMA, No. 93 at pp. 23-26) Accordingly, DOE has removed several efficiency levels that were proposed in table 5. As the eliminated ratings are nonexistent—it is not possible to build motors meeting such specifications—motors shipments analyses used in today's rule are unaffected.
25
As described in both MG 1-2009 and 10 CFR 431.12.
e. Frame Size
In response to the NOPR, DOE received a number of comments related to frame size.
Scope Characteristic #7
NEMA requested that DOE amend the nine characteristics of regulated motor to include four-digit frame sizes because 500 hp and 6- and 8-pole motors only come in frame sizes larger than three-digit frame sizes. (NEMA, Pub. Mtg. Tr., No. 87 at pp. 42-43; NEMA, No. 93 at p 26)
NEMA also noted that IEC does not put design specifications on the motor, especially for larger-sized motors. Therefore, it requested that DOE use language that will include all such motors (through 500 hp) equivalent to covered NEMA motors. (NEMA, Pub. Mtg. Tr., No. 87 at pp. 42-44; NEMA, No. 93 at p. 26)
Nidec added that the higher horsepower ratings as shown in table 4 of the NOPR are above current three-digit frame size. (Nidec, Pub. Mtg. Tr., No. 87 at p. 45) Secondly, Nidec commented that while the proposed standard helps clarify the IEC motor coverage, removing characteristic #7 from the nine characteristics in paragraph (g) of 10 CFR 431.25 would remove any confusion about motor size. It commented that DOE may add electric motors covered by the regulations for small electric motors to the list of exempted motors in paragraph (m) of the proposed 10 CFR 431.25.
DOE agrees with the above commenters that it was DOE's intent to ensure that four-digit frame size motors and IEC equivalents of covered motors are covered by these new standards and has adopted revised language in paragraph (g)(7) of § 431.25 to reflect that fact. The updated language covers three-digit frame sizes, four-digit frame sizes, IEC equivalents, and equivalents between NEMA frame sizes.
NEMA 56-Frame Motors Coverage
NEMA 56-frame motors at 1 hp or greater have been the subject of considerable discussion, due to the fact that they may be covered as a small electric motor under subpart X of 10 CFR part 431, or as an electric motor under subpart B of 10 CFR part 431 depending on whether they are general-purpose, definite or special purpose, or have an open or enclosed frame. Currently, 56-frame motors are covered as small electric motors if the motor is an open, general-purpose motor that meets the “small electric motor” definition at 10 CFR 431.442. The NOPR proposed to extend coverage to 56-frame enclosed motors rated at 1 hp or greater. 78 FR 73589. For 56-frame open, special and definite purpose motors, the NOPR stated that DOE was considering establishing standards for these motor types as well, but requested additional information on those motor types. 78 FR 73606, 73679. Today's rule covers enclosed 56-frame motors rated at 1 hp or greater but does not establish standards for 56-frame open, definite or special purpose motors. DOE notes that, because today's rule covers all enclosed 56-frame motors, both general purpose and special and definite purpose enclosed 56-frame motors are covered under today's rule.
In response to the NOPR, NEMA provided detailed comments about how DOE should rephrase characteristic #7 and add a sixth exemption to 10 CFR 431.25 if DOE chose to include 56-frame open, definite or special purpose motors. This would also eliminate any confusion regarding covering all IEC frame sizes and all frame sizes between two consecutive NEMA or IEC frame sizes. It also commented that it is ambiguous as to whether a 56-frame, open general purpose motor has different efficiency levels and nameplate markings as compared to the 56-frame open, special and definite purpose motors. (NEMA, No. 93 at pp. 14-15; NEMA, Pub. Mtg. Tr., No. 87 at p. 61) NEMA noted that the current rulemaking cannot be compared with the small motors rule in terms of efficiency requirements and ELs, because the small motor rule requirements are based on average efficiency while electric motor rule are based on nominal full-load efficiency. (NEMA, No. 93 at pp. 28-29)
DOE agrees that coverage of 56-frame, open, special- and definite-purpose motors would require coordination with DOE's small electric motor requirements. In the NOPR, DOE requested additional data on this subset of 56-frame motors to allow DOE to fully assess these motor types. No commenter provided DOE such data. As a result of these complications and the need for more data, DOE does not cover them in today's rule, but may consider covering such motors in a future rulemaking. As explained in the “Scope Characteristic #7” section of this section, IVA.2.e, DOE has modified Characteristic #7 accordingly. Table IV.5 provides a summary of respective coverage of 56-frame electric motors.
Table IV.5—56-Frame Regulation, 1 Horsepower and Greater
Open
Enclosed
General Purpose
Covered as a “small electric motor” up to 3 hp.
26
Not currently covered; covered by this rule.
Special/Definite Purpose
Not currently covered; not covered by this rule
Not currently covered; covered by this rule.
f. IEC Motors
NEMA noted
that: (1) There is no one-to-one correspondence between NEMA frame sizes and IEC metric equivalents; (2) the phrase “NEMA frame” refers to specific NEMA T-frame sizes; and (3) IEC 100 frames are currently exempt but should be covered. Based on the above, NEMA commented that DOE has
removed nearly all IEC motors from any requirement to meet efficiency standards. In order to effectively include standards for IEC motors, it suggested DOE to change the titles of table 5 and 6 and the contents of paragraphs (h) and (i) within 10 CFR 431.25 to reflect that they included the IEC equivalents. (NEMA, No. 93 at p 4) DOE agrees that it was the intent to cover these motors and has amended the regulatory language to make this clear.
26
See
10 CFR 431.442.
In response to the NOPR, NEMA commented that it believed DOE may be of the opinion that because, in DOE's proposed rule, reference is no longer being made to T-frames and all covered frame sizes would have three digits, that DOE no longer needs the text “including a frame size that is between two consecutive NEMA frame sizes or their IEC metric equivalents” when describing coverage. NEMA noted, however, that manufacturers may mistakenly equate “NEMA frame” with “T-frame,” and mistakenly conclude that certain IEC motors (
e.g.,
IEC 100 frame) were uncovered. To remedy this ambiguity, NEMA suggested that DOE modify scope Characteristic #7. (NEMA, No. 93 at p. 26)
DOE appreciates the need to clarify coverage of NEMA versus IEC motors and their equivalents and, consistent with its stated intentions in the NOPR to cover IEC-equivalents of all covered motors, has modified characteristic #7 to make coverage of IEC equivalents more explicit.
See
78 FR 73589.
g. Frequency
NEMA noted that characteristic #4 in paragraph (g) is described as “operate on polyphase alternating current 60-hertz line power”. NEMA acknowledged that DOE has explained that this is intended to cover electric motors rated at 60 Hz and 50/60 Hz; however, as written, the provision could be read as requiring coverage of 50 Hz motors that are operated on 60 Hz. It is not clear from the proposed standards whether an efficiency standard would apply to a motor's operation at the frequency or frequencies marked on the nameplate of the electric motor or to operation just at 60 Hz. NEMA suggested that DOE add “at 60 Hz” to all efficiency table titles to make clear that the covered motors were required to meet the efficiency standard while operating at 60 Hz. (NEMA, No. 93 at p. 5)
DOE agrees that the suggestion brings clarity to the regulations and reflects DOE's intent in the NOPR. Therefore, corresponding changes were made in the regulatory text. Although the efficiency values apply at 60 Hz only, DOE points out that the ability to operate at other frequencies (
e.g.,
50 Hz) in addition to 60 Hz does not, itself, exclude a motor from coverage.
h. Random Winding
Noting that DOE has established the efficiency levels based on NEMA MG 1 Table 12-12, Nidec raised concern that Table 12-12 is intended only for random wound motors and, therefore, DOE, should amend characteristic #5 to include only electric motors that contain a random wound stator winding. (Nidec, No. 98 at pp. 2, 7-8)
DOE is not aware of any particular winding technique that would make it significantly more difficult for a motor to meet standards and has received no comment suggesting as much. DOE's understanding is that random winding is mostly done automatically to reduce assembly cost, and that more strategic winding (
e.g.,
on a form) is generally done for increased insulation performance at higher voltages. Hand winding is considered in DOE's analysis and generally exhibits performance superior to random winding and would more easily reach higher efficiencies. As a result, DOE perceives no reason to further constrain scope and does not alter scope with respect to the winding method in today's rule.
i. Duty Cycle
DOE's proposed standards applied only to motors rated for continuous duty, which means that a motor may operate indefinitely without pausing for heat to dissipate.
CEC suggested that DOE revise the criterion in proposed section 431.25(g)(2) such that motors not rated for continuous duty are also subject to standards. It suggested that both motors rated or not rated for continuous duty can meet the nominal full-load efficiency standards. (CEC, No. 96 at p. 3)
Although DOE did not receive data on the relative usages of continuous vs. intermittent duty motors, it understands that continuous duty motors account for the majority of the energy consumption of motors investigated within this rulemaking. Due to their inherent limitations, intermittent duty motors are more likely to be used in applications with a lower fraction of the time spent switched on. As a result, these motors use less energy than continuous duty motors. Although DOE has thus far focused its efforts on continuous duty motors, it remains possible that other motor types may achieve cost-effective energy savings through standards, and DOE may consider exploring their future inclusion. DOE notes that the scope of the MG 1 sections to which the standards listed in Tables 12-10, 12-11, and 12-12 apply is continuous duty motors. DOE also notes that today's rule represents an evolution of existing standards for General Purpose Electric Motors (Subtypes I and II), which are defined in 10 CFR part 431, subpart B to have continuous ratings.
j. Gear Motors
Presently, DOE does not define “gear motor” or “gearmotor,” but understands that these are motors that have gears attached to the motor body, usually for the purpose of trading speed for torque. Depending on the exact configuration, the motor may meet the definition of “partial electric motor” as defined in 10 CFR 431.12. In the NOPR, DOE stated that it believed that certain gearmotors could be tested as partial electric motors by first removing the gearbox, so that manufacturers could certify the partial electric motor and be freed from certifying every conceivable motor/gearbox combination. 78 FR 73647. In the 2013 test procedure, DOE specifically addressed integral gear motors and how to test such motors if they meet DOE's definition of “partial electric motor”.
See
78 FR 75979, 75994.
Baldor raised concern that the scope of coverage of integral gear motors (or other integral motors under the groupings of “partial electric motors”) is not clear. Moreover, DOE did not define or propose test procedures for “integral gearmotors” in the 2013 test procedure. (Baldor, No. 100 at p. 5-6) In response, DOE reiterates that it does not, at this time, treat gear motors as a distinct category of equipment. Gear motors would be subject to standards if they meet the definition of “partial electric motor” or of another type of equipment subject to standards. In those cases, gear motors would be required to certify using whichever test instructions were applicable to that type of motor. DOE notes that manufacturers may apply for a test procedure waiver if their equipment cannot be tested under the methods found in 10 CFR part 431, subpart B.
NORD Gear Corp. recommended that integral gear motors be excluded from the coverage as they do not meet the statutory definition of “electric motor”. It commented that if gearmotors are subject to rulemaking, it would require the NORD gear motors to be heavier due to the increased copper, steel and aluminum content. It will also require an increase in frame size for some motors and, thus, will prevent the combination of some gearmotors that are currently in use, leading to a product gap in the market for significant amount
of time and creating undue economic burden on gearmotor end users. Further, if gear motors are redesigned to meet the standard, millions of combinations of motors and gearboxes will have to be tested and this would place an undue economic burden on gearbox manufacturers. (NORD Gear, No. 91 at p. 2)
DOE understands that an investment of time and capital may be required by the imposition of any standard, and has attempted to discuss, quantify and consider those investments in its Manufacturer Impact Analysis in section IV.J. DOE believes that there should be sufficient time for manufacturers to make changes in designs (if needed) to comply with standards and make the integral gear motors available in the market. With respect to the question of statutory authority, DOE believes that EPCA, as amended through EISA 2007, provides sufficient statutory authority for the regulation of a wide variety of electric motors as described in detail in section II.A.
k. Partial Electric Motors
In response to the NOPR, NEMA raised concern that it is not clear whether the proposed standards in Tables 5 through 8 apply to partial electric motors. To clarify, NEMA recommended that DOE either revise paragraph (g) in 10 CFR 431.15 or add a tenth characteristic to include “partial electric motors”. (NEMA, No. 93 at pp. 26-27) Baldor raised concerns that the content of Table IV of the NOPR implies that DOE intends to cover partial electric motors, however, these motors are neither mentioned in the NOPR nor are efficiency standard levels proposed for them. (NEMA, No. 93 at pp. 26-27)
Under the new regulatory scheme in today's final rule, DOE considers partial electric motors to be electric motors subject to the new requirements listed in 10 CFR 431.25(h)-(l) if they meet the nine criteria specified in paragraph (g) of the new § 431.25. DOE's 2013 test procedure provides instructions for testing these motor types to ensure their nominal full-load efficiency can be assessed. 78 FR 75961. To make the inclusion of these motor types abundantly clear, DOE has taken NEMA's suggestion of modifying the regulatory text in 10 CFR 431.25(g) to expressly state that partial electric motors are included.
Additionally, DOE now refers in the to “special-purpose” and “definite-purpose” “
electric
motors”. The word “electric” was added in the 2013 test procedure. 78 FR 75961.
Finally, DOE notes that it has updated the definition of “partial electric motor” found in 10 CFR 431.12 to correct a typographical error: Repetition of the word “an” before “electric motor”.
l. Certification Considerations Related to Expanded Scope
Baldor sought clarification on which manufacturer should be responsible to file compliance certification report with DOE. Baldor asked whether it should be the manufacturer of the partial electric motor or if instead the manufacturer of the electric motor or assembly of which the partial electric motor is a component must certify it. (Baldor, No. 100 at pp. 5-7)
DOE noted in the 2011 certification, compliance and enforcement rule that it intends to undertake a rulemaking to moving and harmonize, where possible, the certification, compliance, and enforcement provisions for electric motors into Part 429. 76 FR 12422, 12447. DOE will address the party responsible for certifying in that rulemaking.
m. Electric Motors With Separately Powered Blowers
In its comments, NEMA provides an “Appendix B” in which it outlines the “industry interpretation” of which motor types are covered by the rule. DOE notes that NEMA lists electric motors with separately powered blowers under the “not a covered product” category. (NEMA, No. 93 at p. 37)
In the 2013 test procedure, DOE established a method of testing for this type of motor and stated that at least some non-immersible motors that are furnished with separately-powered blowers would meet the same nine criteria that DOE was, at that time, considering applying with respect to its standards rulemaking. 78 FR 75986. Moreover, DOE did not propose to exempt these types of motors from standards in the standards NOPR. 78 FR 73681. DOE maintains its position that electric motors with separately powered blowers that meet the requirements in the new 10 CFR 431.25(g) are covered in today's rule.
3. Advanced Electric Motors
In its final rule analysis, DOE addressed various “advanced electric motor”, which included those listed in Table IV.6. While DOE recognizes 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.
Table IV.6—Advanced Electric Motors
Motor Description
Inverter drives.
Permanent magnet motors.
Electrically commutated motors.
Switched-reluctance motors.
At this time, 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.
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) and 6316(a)) Due to the large number of characteristics involved in electric motor design, DOE has developed both “equipment class groups” and “equipment classes”. An equipment class represents a unique combination of motor characteristics for which DOE is establishing a specific energy conservation standard. There are 482 potential equipment classes that consist of all permutations of electric motor design types (
i.e.,
NEMA Design A & B, NEMA Design C (and IEC equivalents), and fire pump 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 motor design type. The NEMA Standards Publication MG 1-2011, “Motors and Generators,” defines a series of standard electric motor designs (
i.e.,
Designs A, B and C) that are differentiated by variations in performance requirements. DOE chose to use these design types to establish equipment class groups because design types affect an electric motor's utility and efficiency.
In the NOPR, DOE had divided electric motors into four groups based on three main characteristics: NEMA (or IEC) design letter, whether the motor met the definition of “fire pump electric
motor,” and whether the motor had a brake. Within each of these groups, DOE utilized 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.
27
27
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.
At the NOPR stage, brake electric motors were separated out because DOE was concerned that the presence of a brake (which provides utility in the form of hastened stopping of the motor) might cause additional losses, thereby reducing the motors' ability to meet standards cost-effectively. In its 2013 test procedure, however, DOE established a method of testing brake motors that allowed exclusion of losses attributable to the brake, thereby allowing brake electric motors to be tested without regard to the brake. 78 FR 75995.
For today's final rule, then, 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. DOE's three resulting equipment class groups are: NEMA Design A and B and IEC Design N motors (ECG 1), NEMA Design C and IEC Design H motors (ECG 2), and fire pump electric motors (ECG 3). Table IV.7 outlines the relationships between equipment class groups and the characteristics used to define equipment classes.
Table IV.7—Electric Motor Equipment Class Groups for the Final Rule 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.
* Including IEC equivalents.
a. U-Frame Motors
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.
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(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 (
i.e.,
losses that result from magnetic field stability changes).
29
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.
30
In the NOPR, DOE proposed standards for both T-frame and U-frame motors.
28
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.
Under EPACT 1992, the only covered electric motors were T-frame electric motors.
See
42 U.S.C. 6311(13)(A)(1992). These motors were redefined to be “general purpose electric motor (subtype I)” under EISA 2007, which, at the time, DOE defined as a motor that can be used in most general purpose applications and that meets standard operating characteristics and mechanical construction for use under usual or unusual service conditions in accordance with specific provisions of NEMA MG 1-1993. That version of MG 1 only included specifications for T-frame motors because the last version of MG 1 to contain U-frame dimensions was published in 1967.
See
77 FR 266.8.
29
Several manufacturers provide premium efficient U-frame motors. See, for example,
http://www.usmotors.com/Our-Products/~/media/USMotors/Documents/Literature/Datasheets/PDS/PDS_PREMIUM_EFFICIENT.ashx
.
30
See, for example,
http://www.overlyhautz.com/adaptomounts1.html
.
In response to the NOPR, NEMA and the Joint Advocates recommended that DOE keep the standards for U-frame motors at current EPACT 1992 (NEMA MG 1-2011,Table 12-11) levels. These commenters argued that U-frame motors are a legacy design used only in the automotive manufacturing industry and that their market share is small and declining; according to these commenters, re-designing of U-frame motors would entail huge costs. NEMA commented that new U-frame motors are not being designed currently, and the old designs primarily cater to the replacement market. According to NEMA, there are no suppliers of U-frame general purpose motors (subtype II) at premium efficiency levels, and its review showed that only one manufacturer of U-frame general purpose electric motors (subtype II) would be impacted by the proposed change in efficiency standards. NEMA also stated that the cost of U-frame motors is generally significantly higher than T-frame motors of the same rating, as indicative of the larger size of the U-frame motor and the costs associated with maintaining of production equipment for old designs. Therefore, it would be highly unlikely that
consumers would increase purchases of U-frame motors of lower efficiency as substitutes for T-frame motors. NEMA claimed that DOE did not evaluate the cost burden on manufacturers from re-designing old U-frame motors, and if it did, the results would not support the increase in efficiency standards proposed in the NOPR. The Joint Advocates commented that leaving U-frame motor standards unchanged would enable manufacturers to direct scarce product design resources to product types with larger market shares. (NEMA, Pub. Mtg. Tr., No. 87 at pp. 69-70; NEMA, No. 93 at pp. 27-28; Joint Advocates, No. 97 at p. 2)
By contrast, Nidec supported DOE's proposal to raise efficiency standards of U-frame motors to EL2 (
i.e.,
Table 12-12) levels, noting that it is technologically feasible to increase the efficiency level of these motors. (Nidec, No. 98 at p. 5)
DOE understands NEMA's concerns regarding the diminishing market size of U-frame motors. However, DOE has determined that a complete phase-out of U-frame motors would not be the 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 has concluded that the updated standards are unlikely to result in the unavailability of U-frame motors. Based on catalog data from several large electric motor manufacturers, DOE has observed manufacturer offerings of premium efficiency U-frame motors on the market today.
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DOE sees no technical reason why U-frame manufacturers would not be able to comply with standards corresponding to TSL 2. DOE notes that it requested, but did not receive, data suggesting that U-frame motors would be eliminated from the market under the standard levels adopted in today's final rule.
See
78 FR 73610.
31
See, for example:
http://www.marathonelectric.com/motors/docs/manuals/SB547.pdf
.
Under 42 U.S.C. 6295(o)(4), as applied to commercial and industrial equipment via 42 U.S.C. 6316(a), DOE cannot prescribe a standard that would result in the “unavailability in the United States in any covered equipment 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”. However, DOE notes that this statutory provision does not require the continued protection of particular classes or types of equipment—in this case, electric motors—if the same utility continues to be available to consumers. Consequently, based on available information, DOE continues to believe that U-frame motors fail to merit a separate equipment class with lower standards and has not created one for them in this final rule.
b. 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 regulating the efficiency of motors of each of these design types.
The primary difference between a NEMA Design A and NEMA Design B 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 applications that 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 grouping these motors together into a single equipment class group for the purposes of this rulemaking.
In contrast, DOE believes that the different torque requirements for NEMA Design C 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 and NOPR, 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 technical support document, DOE noted numerous instances where manufacturers were marketing electric motors rated greater than 200 horsepower as NEMA Design C motors. (see Chapter 2 of TSD)
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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 understands that without established performance standards that form the basis for a two-pole NEMA Design C motor or a NEMA Design C motor with a horsepower rating above 200, motors labeled as such would not meet the regulatory definition for “NEMA Design C motor” as provided in the 2013 test procedure. 78 FR 75994. 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 circumvention 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. In addition, DOE received no comments suggesting this would be likely. Nevertheless, DOE will monitor the potential presence of such motors and may reconsider standards for them provided such practice becomes prevalent.
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For instructions on how to access the TSD, visit the rulemaking page at:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/42
.
c. 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). (
See
77 FR 26608 (codified at 10 CFR 431.12)) Pursuant to NFPA 20, a fire pump electric motor must comply with NEMA Design B performance standards and must continue to operate in spite of any risk of damage stemming from overheating or continuous operation. The additional requirements for a fire pump electric motor are intended to further the purpose of public safety and constitute 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 and maintained that practice through the NOPR and today's final rule.
Regarding the “fire pump electric motor” definition, as detailed in the 2012 test procedure (77 FR 26608), 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 26617-26618. As stated in the 2012 test procedure, DOE believes 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.
Id.
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 MG 1 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. See the standards NOPR for a historical discussion of comments related to fire pump electric motors. 78 FR 73623.
NEMA suggested that DOE should change the title of Table 7 and the content of paragraph (j) to specifically refer to NEMA Design B fire pump electric motors. NEMA commented that although DOE has stated that the standards for fire pump electric motors are based on NEMA Design B types, that fact it is not clear in the definition of “fire pump electric motor” in 10 CFR 431.12. (NEMA, No. 93 at p. 5) Baldor also raised concern that the scope of coverage of fire pump electric motors is not clear from only referring to the definition proposed in 10 CFR 431.12., nothing that it had to go through several documents to determine that fire pump electric motors that meet nine criteria and are limited to NEMA Design B and IEC equivalents are covered. (Baldor, No. 100 at p. 4)
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. Therefore, DOE considers it unnecessary to add further restrictions in its regulatory text. DOE also wishes to avoid the implication that IEC equivalents would not be covered. Regarding having to review the nine criteria in the new 10 CFR 431.25(g) to know if a fire pump motor is covered, as DOE explained above, the regulatory scheme used in the new regulations was chosen to maintain the existing regulations for currently regulated electric motors while providing the criteria that all motors must meet if they are regulated motors under the new standards.
NEMA commented that it is aware of few entities that have listed IEC motors for application with fire pumps in the U.S. It also commented that there is confusion regarding the coverage of the efficiency standards for fire pump electric motors. (NEMA, No. 93 at p. 14) By contrast, Nidec provided a link to data on companies that have a UL certification for IEC motors for fire pump applications. (Nidec, No. 98 at p. 5)
Regarding IEC fire pump motors, DOE views Nidec's comment and the fact that IEC motors can be built to very similar specifications as Design B motors (even though they may not be labeled as such) as sufficient cause to maintain the requirement that IEC designs comply with fire pump motor standards as well.
Specifically regarding standards for fire pump electric motors, NEMA and Baldor both raised concerns that the proposed standards for fire pump electric motors in Table 7 were not consistent with the current standards for fire pump electric motors in Table 2, as suggested in the Petition and as DOE intended to propose (
see
78 FR 73592). (NEMA, No. 93 at pp. 23, 26; Baldor, No. 100 at p. 4)
Finally, the NOPR had mistakenly listed a standard for 1 hp, 2 pole, open fire pump electric motors even though no standard for this configuration is currently in effect, as evidenced by the absence of a standard for this rating in DOE's regulations at 10 CFR 431.25(b). This standard has been removed from the final rule.
d. Brake Electric Motors
In its final rule analyses, DOE considered whether brake electric motors (both integral brake electric motors and non-integral brake electric motors). In the 2013 test procedure, DOE adopted a definition for brake electric motors. 78 FR 75993 In the NOPR, the two types of brake electric motor were 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 electric 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
33
require electric motors to stop quickly. Motors used in such applications 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 had proposed to establish a separate equipment class group for electric motors with a brake.
33
For example, some conveyor and other material-handling applications require motors to stop quickly.
During the NOPR public meeting, NEMA argued that DOE has captured most standard stock available and agreed with DOE's decision to limit standards for brake motors to 1-30 hp and 4-, 6- and 8-pole configurations. It commented that larger brake motors are generally design D or intermittent-duty motors for cranes and hoists, which are currently out of the scope of coverage. (NEMA, Pub. Mtg. Tr., No. 87 at pp. 70-71) In its written comments, NEMA noted that brakes can be treated as an accessory because in DOE's test procedure for brake motors, brake electrical losses are not included in the efficiency calculation. Therefore, it suggested that brake motors should not be put in separate equipment class but should be included in tables 5 and 6. (NEMA, No. 93 at pp. 7-8)
The Joint Advocates stated that they support inclusion of integral brake motors in the scope of coverage. However, they commented that establishing a separate class and table of standards for brake motors is unnecessary, because DOE has proposed setting standards for brake motors identical to other motors. Moreover, it requested that DOE include brake motors above 30 hp since there are some motors sold above 30 hp, and capping the brake motors coverage at 30 hp may create confusion about scope of coverage. (Joint Advocates, No. 97 at p. 2)
The Appliance Standards Awareness Project (ASAP) commented that if brake motors have the same standards as other motors, they would not require a separate equipment class group and would not only be regulated at the limited horsepower range proposed. (ASAP, Pub. Mtg. Tr., No. 87 at p. 74)
Regarding the brake motor standards proposed, Baldor raised concern that the title of table 8 does not fully identify the type of integral brake electric motors and non-integral brake electric motors to which the proposed standards apply. Baldor raised concern that DOE has not defined integral and non-integral brake motors in 10 CFR 431.12, even though it makes reference to these motors in the NOPR. Baldor raised concern that the term “dedicated mechanism for speed reduction” used in the definition of brake electric motors is ambiguous, stating that it is not clear what DOE intends to cover other than a “brake”. (Baldor, No
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