# Energy Conservation Program: Energy Conservation Standards for Small Electric Motors > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/fr%3AE9-27914 ## Record - **Collection:** Federal Register - **Document type:** Proposed Rule - **Published:** November 24, 2009 - **Citation:** 74 FR 61410 ## Text DEPARTMENT OF ENERGY 10 CFR Part 431 [Docket Number EERE-2007-BT-STD-0007] RIN 1904-AB70 Energy Conservation Program: Energy Conservation Standards for Small Electric Motors AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy. ACTION: Notice of proposed rulemaking and public meeting. SUMMARY: The Energy Policy and Conservation Act authorizes the U.S. Department of Energy (DOE) to establish energy conservation standards for various consumer products and commercial and industrial equipment. Such equipment includes those small electric motors for which DOE determines that energy conservation standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice, DOE proposes energy conservation standards for certain small electric motors and is announcing a public meeting. DATES: Public meeting: DOE will hold a public meeting on Thursday, December 17, 2009, from 9 a.m. to 5 p.m., in Washington, DC. DOE must receive requests to speak at the public meeting before 4 p.m., Thursday, December 3, 2009. DOE must receive a signed original and an electronic copy of statements to be given at the public meeting before 4 p.m., Thursday, December 10, 2009. Comments: DOE will also accept written comments, data, and information regarding this notice of proposed rulemaking (NOPR) before and after the public meeting, but received no later than January 25, 2010. See section VII, “Public Participation,” of this NOPR for details. ADDRESSES: The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585. Please note that foreign nationals visiting DOE Headquarters are subject to advance security screening procedures, requiring a 30-day advance notice. If you are a foreign national and wish to participate in the workshop, please inform DOE of this fact as soon as possible by contacting Ms. Brenda Edwards at (202) 586-2945 so that the necessary procedures can be completed. Any comments submitted must identify the NOPR for Energy Conservation Standards for Small Electric Motors, and provide the docket number EERE-2007-BT-STD-0007 and/or regulatory information number (RIN) number 1904-AB70. Comments may be submitted using any of the following methods: • Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments. • E-mail: small_electric_motors_std.rulemaking@hq.doe.gov. Include the docket number and/or RIN in the subject line of the message. • Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Please submit one signed original paper copy. • Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. Please submit one signed original paper copy. For detailed instructions on submitting comments and additional information on the rulemaking process, see section VII of this document (Public Participation). Docket: For access to the docket to read background documents or comments received, visit the U.S. Department of Energy, Resource Room of the Building Technologies Program, 950 L'Enfant Plaza, SW., Suite 600, Washington, DC, (202) 586-2945, between 9 a.m. and 4 p.m., Monday through Friday, except Federal holidays. Please call Ms. Brenda Edwards at the above telephone number for additional information regarding visiting the Resource Room. Please note: DOE's Freedom of Information Reading Room is no longer housing rulemaking materials. FOR FURTHER INFORMATION CONTACT: Mr. James Raba, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121, (202) 586-8654, e-mail: Jim.Raba@ee.doe.gov. Mr. Michael Kido, U.S. Department of Energy, Office of General Counsel, GC-72, 1000 Independence Avenue, SW., Washington, DC 20585, (202) 586-9507, e-mail: Michael.Kido@hq.doe.gov. For information on how to submit or review public comments and on how to participate in the public meeting, contact Ms. Brenda Edwards, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. E-mail: Brenda.Edwards@ee.doe.gov. SUPPLEMENTARY INFORMATION: I. Summary of the Proposed Rule II. Introduction A. Consumer Overview B. Authority C. Background 1. Current Standards 2. History of Standards Rulemaking for Small Electric Motors III. General Discussion A. Test Procedures B. Technological Feasibility 1. General 2. Maximum Technologically Feasible Levels C. Energy Savings 1. Determination of Savings 2. Significance of Savings D. 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 of the Nation To Conserve Energy g. Other Factors 2. Rebuttable Presumption IV. Methodology and Discussion A. Market and Technology Assessment 1. Definition of Small Electric Motor a. Motor Categories b. Motor Enclosures c. Service Factors d. Insulation Class Systems e. Metric Equivalents f. Frame Sizes g. Horsepower Ratings 2. Product Classes B. Screening Analysis C. Engineering Analysis 1. Approach 2. Product Classes Analyzed 3. Cost Model 4. Baseline Models 5. Design Options and Limitations a. Manufacturability b. Motor Size c. Service Factor d. Skew and Stay-Load Loss e. Air Gap f. Power Factor g. Speed h. Thermal Performance i. Slot Fill j. Current and Torque Characteristics 6. Scaling Methodology 7. Nominal Efficiency 8. Cost-Efficiency Results D. Markups To Determine Equipment Price 1. Distribution Channels 2. Estimation of Markups 3. Summary of Markups E. Energy Use Characterization F. Life-Cycle Cost and Payback Period Analysis 1. Baseline and Standard Level Efficiencies 2. Installed Equipment Cost 3. Motor Applications 4. Annual Operating Hours and Energy Use 5. Space Constraints 6. Power Factor 7. Energy Prices 8. Energy Price Trend 9. Maintenance and Repair Costs 10. Equipment Lifetime 11. Discount Rate 12. Standard Effective Date G. National Impact Analysis—National Energy Savings and Net Present Value Analysis 1. Shipments H. Consumer Sub-Group Analysis I. Manufacturer Impact Analysis 1. Overview 2. Phase 1, Industry Profile 3. Phase 2, Industry Cash-Flow Analysis 4. Phase 3, Sub-Group Impact Analysis 5. Government Regulatory Impact Model Analysis 6. Manufacturer Interviews 7. Government Regulatory Impact Model Key Inputs and Scenarios a. Base-Case Shipments Forecast b. Standards-Case Shipments Forecast c. Manufacturing Production Costs d. Manufacturing Markup Scenarios e. Equipment and Capital Conversion Costs J. Employment Impact Analysis K. Utility Impact Analysis L. Environmental Analysis 1. Power Sector Emissions 2. Valuation of CO 2 Emissions 3. Valuation of Other Emissions V. Analytical Results A. Trial Standard Levels B. Economic Justification and Energy Savings 1. Economic Impacts on Customers a. Life-Cycle Cost and Payback Period b. Life-Cycle Cost Sensitivity Calculations c. Customer Sub-Group Analysis d. Rebuttable Presumption Payback 2. Economic Impacts on Manufacturers a. Industry Cash-Flow Analysis Results b. Impacts on Direct Employment c. Impacts on Manufacturing Capacity d. Impacts on Manufacturer Subgroups e. Cumulative Regulatory Burden 3. National Impact Analysis a. Significance of Energy Savings b. Net Present Value c. Impacts on Employment 4. Impact on Utility or Performance of Products 5. Impact of Any Lessening of Competition 6. Need of the Nation To Conserve Energy 7. Other Factors C. Proposed Standard 1. Polyphase Small Electric Motors 2. Capacitor-Start Small Electric Motors VI. Procedural Issues and Regulatory Review A. Review Under Executive Order 12866 B. Review Under the Regulatory Flexibility Act C. Review Under the Paperwork Reduction Act D. Review Under the National Environmental Policy Act 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 of 1999 I. Review Under Executive Order 12630 J. Review Under the Treasury and General Government Appropriations Act of 2001 K. Review Under Executive Order 13211 L. Review Under the Information Quality Bulletin for Peer Review VII. Public Participation A. Attendance at Public Meeting B. Procedure for Submitting Requests To Speak C. Conduct of Public Meeting D. Submission of Comments E. Issues on Which DOE Seeks Comment VIII. Approval of the Office of the Secretary I. Summary of the Proposed Rule Pursuant to the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq .), as amended, (EPCA or the Act), the Department of Energy (DOE) is proposing new energy conservation standards for capacitor-start and polyphase small electric motors. These standards would achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified for this equipment, and would result in significant conservation of energy. The proposed standards are shown in Table I.1, Table I.2, and Table I.3, and would apply to all equipment manufactured in, or imported into, the United States on and after 5 years following the publication of the final rule. BILLING CODE 6450-01-P EP24NO09.000 BILLING CODE 6450-01-C DOE's analyses indicate that the proposed standards would save a significant amount of energy—an estimated 2.46 quads of cumulative energy over 30 years (2015-2045). Of this, 2.13 quads of savings result from standards on capacitor-start (single-phase) motors and 0.33 quads of savings result from standards on polyphase motors. 1 The energy savings results for single-phase motors represent the combined effect of standards on the capacitor-start, induction-run (CSIR) 2 and capacitor-start, capacitor-run (CSCR) 3 motors markets, because general purpose CSIR and CSCR motors generally meet similar performance criteria and can often be used in the same applications. 4 The amount of projected energy savings is equivalent to the total energy 7.8 million U.S. citizens use in 1 year. The economic impacts on owners (hereafter “customers”) of equipment containing single-phase small electric motors— i.e. , the average life-cycle cost (LCC) savings—are positive. Polyphase small electric motor customers experience, on average, small LCC increases as a result of the standard. 1 A polyphase motor is an electric motor that uses three-phase electricity and the phase changes of the electrical supply to induce a rotational magnetic field, thereby supplying torque to the rotor. 2 A capacitor-start induction-run motor is a single-phase motor with a main winding arranged for direct connection to a source of power and an auxiliary winding connected in series with a capacitor. The motor has a capacitor phase, which is in the circuit only during the starting period. 3 A capacitor-start capacitor-run motor is a single-phase motor which has different values of effective capacitance for the starting and running conditions. 4 Polyphase, CSIR, and CSCR motors can be found in a range of applications including, but not limited to the following: Pumps, blowers, fans, compressors, conveyors and general industrial equipment. The cumulative national net present value (NPV) of total customer costs and savings from the proposed standards from 2015 to 2065 in 2008$ ranges from $1.53 billion (at a 7-percent discount rate) to $14.15 billion (at a 3-percent discount rate). This is the estimated total value of future operating-cost savings minus the estimated increased equipment costs, discounted to 2009. If DOE were to adopt the proposed standards, it expects a −12.86 percent to 10.69 percent change in manufacturer industry net present value (INPV) for single-phase motors and −13.8 percent to 16.9 percent change in manufacturer INPV for polyphase motors, which is approximately −$44.67 to $40.70 million total. As a result, the NPV for customers (at the 7-percent discount rate) of $1.53 billion would thus exceed industry losses by about 33 times. Additionally, based on DOE's interviews with the major manufacturers of small electric motors, DOE does not expect any plant closings or loss of employment. The major small electric motor manufacturers include: A.O. Smith Electrical Products Company, Baldor Electric Company, Emerson Motor Technologies, Regal-Beloit Corporation, and WEG. Except for WEG, all of these manufacturers are U.S.-based. WEG is based in Brazil. The proposed standards would have significant environmental benefits. All of the energy saved would be in the form of electricity. DOE expects the energy savings to eliminate the need for approximately 2.49 gigawatts (GW) of generating capacity by 2030. The reduction in electricity generation would result in cumulative (undiscounted) greenhouse gas emission reductions of 124.8 million tons (Mt) of carbon dioxide (CO 2 ) from 2015 to 2045. During this period, the standard would result in power plant emission reductions of 89.6 kilotons (kt) of nitrogen oxides (NO X ) and 0.561 tons of mercury (Hg). These reductions have a value of up to $2,737 million for CO 2 , $67.7 million for NO X , and $5.31 million for Hg, at a discount rate of 7-percent. The benefits and costs of today's proposed rule can also be expressed in terms of annualized (2008$) values from 2015-2045. Estimates of annualized values are shown in Table I.4. The annualized monetary values are the sum of the annualized national economic value of operating savings benefits (energy, maintenance and repair), expressed in 2008$, plus the monetary value of the benefits of CO 2 emission reductions, otherwise known as the Social Cost of Carbon (SCC), expressed as $20 per metric ton of CO 2 , in 2008$. The $20 value is a central interim value from a recent interagency process. The monetary benefits of cumulative emissions reductions are reported in 2008$ so that they can be compared with the other costs and benefits in the same dollar units. The derivation of this value is discussed in section V.B.6. Although comparing the value of operating savings to the value of CO 2 reductions provides a valuable perspective, please note the following: (1) The national operating savings are domestic U.S. consumer monetary savings found in market transactions while the CO 2 value of reductions is based on a central value from a range of estimates of imputed marginal SCC from $5 to $56 per metric ton (2008$), which are meant to reflect the global benefits of CO 2 reductions; and (2) the assessments of operating savings and CO 2 savings are performed with different computer models, leading to different time frames for analysis. The national operating cost savings is measured for the lifetime of small electric motors shipped in the 31-year period 2015-2045. The value of CO 2 , on the other hand, is meant to reflect the present value of all future climate related impacts, even those beyond 2065. Using a 7-percent discount rate for the annualized cost analysis, the combined cost of the standards proposed in today's proposed rule for small electric motors is $515.4 million per year in increased equipment and installation costs, while the annualized benefits are $923.1 million per year in reduced equipment operating costs and $97.8 million in CO 2 reductions, for a net benefit of $505.5 million per year. Using a 3-percent discount rate, the cost of the standards proposed in today's proposed rule is $514.0 million per year in increased equipment and installation costs, while the benefits of today's standards are $1,071.5 million per year in reduced operating costs and $131.8 million in CO 2 reductions, for a net benefit of $689.3 million per year. BILLING CODE 6450-01-P EP24NO09.001 BILLING CODE 6450-01-C DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified and would result in significant conservation of energy. Based on the analyses culminating in this proposal, DOE found the benefits (energy savings, consumer LCC savings, national NPV increase, and emission reductions) outweigh the burdens (loss of INPV and LCC increases for some small electric motor users). For a discussion of the energy savings and NPV results, see TSD chapter 10. For LCC results, see TSD chapter 8. For emissions reductions, see TSD chapter 15. For INPV, see TSD chapter 12. DOE considered higher efficiency levels as trial standard levels, and is still considering them in this rulemaking; however, DOE has tentatively concluded that the burdens of the higher efficiency levels would outweigh the benefits. Based on consideration of public comments DOE receives in response to this notice and related information, DOE may adopt either higher or lower efficiency levels than those presented in this proposal or some level(s) in between. II. Introduction A. Consumer Overview Currently, no mandatory Federal energy conservation standards apply to small electric motors. DOE is proposing standards for the small motors shown in Table I.1, Table I.2, and Table I.3. The proposed standards would apply to equipment manufactured for sale in the United States, beginning 5 years after the final rule is published in the Federal Register . The final rule is expected to be published by February 28, 2010; therefore, the effective date would be February 28, 2015. The proposed standards represent an overall reduction of approximately 40 percent in motor energy losses. The capacitor-start induction-run (CSIR) standards represent a 45-percent reduction in losses for a 0.5 hp CSIR motor, relative to the current market average. The capacitor-start capacitor-run (CSCR) standards represent a 37-percent reduction in losses for a 0.75 hp CSCR motor. The polyphase standards represent a 45-percent reduction in losses for a 1 hp polyphase motor. DOE's analyses indicate that commercial and industrial customers would benefit from the proposed standards. Although DOE expects the installed cost of the higher-efficiency small motors to be greater (ranging from 9 percent for a 0.75 hp CSCR motor to 26 percent for a 1 hp polyphase motor than the average price of this equipment today, the energy efficiency gains will result in lower energy costs. A 0.5 hp CSIR customer will save an average of $25 per year on energy costs compared with an annual cost of losses of a baseline CSIR motor of $48 per year, while a 1 hp polyphase customer will save an average of $10 per year compared to an operational cost of motor losses of $34 per year for a baseline motor. A 0.75 hp CSCR customer will save $36 per year on their energy bill compared with a baseline CSCR motor that costs $57 per year in losses to operate on average. DOE estimates that the median payback period (PBP) for equipment meeting the proposed standards will be approximately 5 to 14 years. When these savings are summed over the lifetime of the higher efficiency equipment (and discounted to the present), a 0.5 hp CSIR consumer will save $49, on average, compared to a baseline 0.5 hp CSIR motor. A 0.75 hp CSCR consumer will save $28, on average, compared to a baseline CSCR motor, and $121, on average, compared to a baseline 0.75 hp CSIR motor. A consumer who purchases a 1 hp polyphase motor will experience an average net increase of $38 relative to the $1,274 life-cycle cost of a baseline polyphase small electric motor. DOE estimates that even though there will be a net national savings from the standard, a majority of motor customers may not receive net life-cycle cost benefits. This is because many small electric motors are installed in applications where the motor is running only a few hours per day. On the other hand, because a substantial minority of motors is running at nearly all hours of the day and are replaced more often than motors that run infrequently, these motors obtain relatively large savings from the standard and yield positive net benefits from the standard. B. Authority Title III of EPCA sets forth a variety of provisions designed to improve energy efficiency. Part A of Title III (42 U.S.C. 6291-6309) provides for the Energy Conservation Program for Consumer Products Other Than Automobiles. Part A-1 of Title III (42 U.S.C. 6311-6317) establishes a similar program for certain types of commercial and industrial equipment, which includes small electric motors. 5 DOE publishes today's notice of proposed rulemaking (NOPR) pursuant to Part A-1, which provides definitions, test procedures, labeling provisions, energy conservation standards, and the authority to require information and reports from manufacturers. The test procedures DOE recently adopted for small electric motors, 74 FR 32059 (July 7, 2009), appear at Title 10 Code of Federal Regulations (CFR) sections 431.343 and 431.344. 5 These two parts were titled Parts B and C, but were redesignated as Parts A and A-1 by the United States Code for editorial reasons. The Act defines “small electric motors” as follows: The term “small electric motor” means a NEMA [National Electrical Manufacturers Association] general purpose alternating current single-speed induction motor, built in a two-digit frame number series in accordance with NEMA Standards Publication MG1-1987. (42 U.S.C. 6311(13)(F)) Moreover, pursuant to section 346(b)(3) of EPCA (42 U.S.C. 6317(b)(3)), no standard prescribed for small electric motors shall apply to any such motor that is a component of a covered product under section 322(a) of EPCA (42 U.S.C. 6292(a)) or of covered equipment under section 340 (42 U.S.C. 6311). EPCA provides several criteria that govern adoption of new standards for small electric motors. After reviewing any comments received regarding today's notice, DOE will evaluate the information before it and decide whether today's proposed standards meet those criteria and are economically justified by determining whether the benefits of the standard exceed its burdens. DOE will make this determination by considering, to the greatest extent practicable, using the following seven factors set forth in 42 U.S.C. 6295(o)(2)(B)(i): 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 energy 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 conservation; and 7. Other factors the Secretary considers relevant. 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII) Additionally, pursuant to 42 U.S.C. 6317(c), DOE will consider the criteria outlined in 42 U.S.C. 6295(n)—whether the standards will result in a significant conservation of energy, are technologically feasible, and are cost effective as described in 42 U.S.C. 6295(o)(2)(B)(i)(II) (see criterion 2 listed above). These criteria are largely folded into the seven criteria that DOE routinely analyzes as part of its standards rulemaking analyses. Accordingly, DOE will continue to conduct its more comprehensive analyses under 42 U.S.C. 6295(o) as part of this rulemaking. DOE also notes that today's notice concerns types of “covered equipment” as defined in EPCA (42 U.S.C. 6311(1)(A)), rather than “covered products” as defined in EPCA (42 U.S.C. 6291(2)). Under 42 U.S.C. 6316(a), the criteria for prescribing new standards for consumer products (42 U.S.C. 6295(o)) apply when promulgating standards for certain specified commercial and industrial equipment, including small electric motors. EPCA substitutes the term “equipment” for “product” when the latter term appears in consumer product-related provisions that EPCA also applies to commercial and industrial equipment. (See 42 U.S.C. 6316(a)(3).) In developing energy conservation standards for small electric motors, DOE is also applying certain other provisions of 42 U.S.C. 6295. First, DOE will not prescribe a standard if interested parties have established by a preponderance of evidence that the standard is likely to result in the unavailability in the United States of any covered equipment type (or class) with performance characteristics, features, sizes, capacities, and volume that are substantially the same as those generally available in the United States. (See 42 U.S.C. 6295(o)(4)) Second, DOE is applying 42 U.S.C. 6295(o)(2)(B)(iii), which establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that “the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy * * * savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. * * *” in place for that standard. Third, in setting standards for a type or class of covered product that has two or more subcategories, DOE will specify a different standard level than that which applies generally to such type or class of equipment “for any group of covered products which have the same function or intended use, if * * * products within such group-(A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard” than applies or will apply to the other products. (See 42 U.S.C. 6295(q)(1).) In determining whether a performance-related feature justifies a different standard for a group of products, DOE considers such factors as the utility to the consumer of such a feature and other factors DOE deems appropriate. Any rule prescribing such a standard will include an explanation of the basis on which DOE established such higher or lower level. (See 42 U.S.C. 6295(q)(2)) Federal energy efficiency requirements for equipment covered by 42 U.S.C. 6317 generally supersede State laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c) and 6316(a)) DOE can, however, grant waivers of preemption for particular State laws or regulations, in accordance with the procedures and other provisions of section 327(d) of the Act. (42 U.S.C. 6297(d) and 6316(a)) C. Background 1. Current Standards As indicated above, there are no national energy conservation standards prescribed for small electric motors. 2. History of Standards Rulemaking for Small Electric Motors Pursuant to the requirements of the Energy Policy Act of 1992 (Pub. L. 102-486), DOE began to gather and analyze information to determine whether standards for small electric motors would meet its criteria. DOE began its determination analysis, by examining what motors were covered and concluded that the EPCA definition of “small electric motor” covers only those motors that meet the definition's frame-size requirements and are either three-phase, non-servo motors (polyphase motors) or single-phase, capacitor-start motors, including both CSIR and CSCR motors. 71 FR 38799, 38800-01 (July 10, 2006). DOE reached this conclusion because only these motor categories can meet the performance requirements set forth for general-purpose alternating-current motors by NEMA MG1-1987. DOE then analyzed the likely range of energy savings and economic benefits that would result from energy conservation standards for these small motors, and prepared a report describing its analysis and provided its projected estimated energy savings from potential standards. In June 2006, DOE made the report, “Determination Analysis Technical Support Document: Analysis of Energy Conservation Standards for Small Electric Motors,” available for public comment at http://www.eere.energy.gov/buildings/appliance_standards/commercial/small_electric_motors.html . Pursuant to section 346(b)(3) of EPCA (42 U.S.C. 6317(b)(3)), the analysis did not include motors that are a component of a covered product or equipment. Also, the report made no recommendation as to what determination DOE should make. DOE received comments concerning this analysis from NEMA, the Small Motors and Motion Association (SMMA, now the Motors and Motion Association), and the American Council for an Energy-Efficient Economy (ACEEE). Thereafter, DOE analyzed whether significant energy savings would result from energy conservation standards for the small electric motors considered in its previous analysis, and incorporated the results of this additional analysis into a technical support document (TSD). Based on these results, DOE issued the following determination on June 27, 2006: Based on its analysis of the information now available, the Department [of Energy] has determined that energy conservation standards for certain small electric motors appear to be technologically feasible and economically justified, and are likely to result in significant energy savings. Consequently, DOE will initiate the development of energy efficiency test procedures and standards for certain small electric motors. 71 FR 38807. DOE initiated this rulemaking to develop standards and another rulemaking to develop test procedures for small motors. DOE began this rulemaking by publishing “Energy Conservation Standards Rulemaking Framework Document for Small Electric Motors” on http://www.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/small_motors_framework_073007.pdf. DOE also published a notice announcing the availability of the framework document and a public meeting on the document, and requesting public comments on the matters raised in the document. 72 FR 44990 (August 10, 2007). On September 13, 2007, DOE held the public meeting at which it presented the contents of the framework document, described the analyses it planned to conduct during the rulemaking, sought comments from interested parties on these subjects, and sought to inform interested parties about, and facilitate their involvement in, the rulemaking. Interested parties that participated in the public meeting discussed eight major issues: the scope of covered small electric motors, definitions, test procedures, horsepower, and kilowatt equivalency, DOE's engineering analysis, life-cycle costs, efficiency levels, and energy savings. At the meeting and during the framework document comment period, DOE received many comments helping it identify and resolve issues involved in this rulemaking. DOE gathered additional information and performed preliminary analyses to inform the development of energy conservation standards. This process culminated in DOE's announcement of an informal public meeting to discuss and receive comments on the following matters: the product classes DOE planned to analyze; the analytical framework, models, and tools that DOE was using to evaluate standards; the results of the preliminary analyses DOE performed; and potential standard levels that DOE might consider. 73 FR 79723 (December 30, 2008). DOE also invited written comments on these subjects and announced the availability on its Web site of a preliminary TSD. Id. A PDF of the preliminary TSD is available at http://www1.eere.energy.gov/buildings/appliance_standards/commercial/small_electric_motors_nopr_tsd.html . Finally, DOE stated its interest in receiving comments on other issues that participants believe would affect energy conservation standards for small electric motors or that DOE should address in this NOPR. Id. at 79725. The preliminary TSD provided an overview of the activities DOE undertook and discussed the comments DOE received in developing standards for small electric motors. It also described the analytical framework that DOE used and each analysis DOE performed up to that point. These analyses included: • A market and technology assessment that addressed the scope of this rulemaking, identified the potential classes of this equipment, characterized the small electric motor market, and reviewed techniques and approaches for improving the efficiency of small electric motors; • A screening analysis that reviewed technology options to improve small electric motor efficiency and weighed them against DOE's four prescribed screening criteria; • An engineering analysis that estimated the manufacturer selling prices (MSPs) associated with more energy efficient small electric motors; • An energy use and end-use load characterization that estimated the annual energy use of small electric motors; • A markup methodology that converted average MSPs to consumer-installed prices; • An LCC analysis that calculated, at the consumer level, the discounted savings in operating costs throughout the estimated average life of the small electric motor, compared to any increase in installed costs likely to result directly from the imposition of the standard; • A PBP analysis that estimated the amount of time it takes consumers to recover the higher purchase expense of more energy efficient equipment through lower operating costs; • A shipments analysis that estimated shipments of small electric motors over the time period examined in the analysis, which was used in performing the national impact analysis; • A national impact analysis that assessed the aggregate impacts at the national level of potential energy conservation standards for small motors, as measured by the net present value of total consumer economic impacts and national energy savings; and • A preliminary manufacturer impact analysis that took the initial steps in evaluating the effects on manufacturers of new efficiency standards. The nature and function of the analyses in this rulemaking, including the engineering analysis, energy-use characterization, markups to determine installed prices, LCC and PBP analyses, and national impact analysis, are summarized in the December 2008 notice. Id. at 79725. The public meeting announced in the December 2008 notice took place on January 30, 2009. At this meeting, DOE presented the methodologies and results of the analyses set forth in the preliminary TSD. The comments received since publication of the December 2008 notice have helped DOE resolve the issues in this rulemaking. The submitted comments include a joint comment from Adjuvant Consulting, on behalf of the Northwest Energy Efficiency Alliance (NEEA) and Northwest Power and Conservation Council (NPCC); a comment from Earthjustice; a second joint comment from Energy Solutions, Pacific Gas and Electric Company (PG&E), Southern California Edison (SCE), Southern California Gas Company, and San Diego Gas and Electric (SDGE), a comment from NEMA); and a comment from Edison Electric Institute (EEI). This NOPR quotes and summarizes many of these comments and responds to the issues they raised. A parenthetical reference at the end of a quotation or paraphrase provides the location of the item in the public record. III. General Discussion A. Test Procedures Final test procedures were published on July 7, 2009 (74 FR 32059). The test procedures incorporated by reference Institute of Electrical and Electronics Engineers, Inc. (IEEE) Standard 112-2004 (Test Method A and Test Method B), IEEE Standard 114-2001, and Canadian Standards Association (CAN/CSA) Standard C747-94. In addition to incorporating by reference the above industry standard test procedures, the small electric motors test procedure final rule also codified the statutory definition for the term “small electric motor;” clarified the definition of the term “basic model” and the relationship of the term to certain product classes and compliance certification reporting requirements; and codified the ability of manufacturers to use an alternative efficiency determination method (AEDM) to reduce testing burden, while maintaining accuracy and ensuring compliance with potential future energy conservation standards. The test procedure notice also discussed matters of laboratory accreditation, compliance certification, and enforcement of energy conservation standards for small electric motors. At the public meeting presenting the preliminary analyses for the energy conservation standards rulemaking, WEG and Emerson voiced their concern about enforcement of energy efficiency standards for small electric motors. WEG stated that they believe that enforcement will become especially problematic for those small electric motors that come into the country embedded in a piece of equipment and are therefore difficult to view the nameplate and to test. (WEG, Public Meeting Transcript, No. 8.5 at pp. 325-26) Additionally, Emerson requested that DOE provide further information on how it plans on enforcing standards on small electric motors. (Emerson, Public Meeting Transcript, No. 8.5 at p. 297) DOE notes certification and enforcement provisions for small electric motors have not yet been developed. DOE plans on proposing such provisions in a separate test procedure supplementary NOPR, at which time DOE will welcome comment on how small electric motor efficiency standards can be effectively enforced. B. Technological Feasibility 1. General In each standards rulemaking, DOE conducts a screening analysis, which it bases on information it has gathered on all current technology options and prototype designs that could improve the efficiency of the product or equipment that is the subject of the rulemaking. In consultation with manufacturers, design engineers, and other interested parties, DOE develops a list of design options for consideration. Consistent with its Process Rule, DOE then determines which of these means for improving efficiency are technologically feasible. “Technologies incorporated in commercially available products or in working prototypes will be considered technologically feasible.” 10 CFR 430, subpart C, appendix A, section 4(a)(4)(i). DOE evaluates each of the acceptable design options in light of the following criteria: (1) Technological feasibility; (2) practicability to manufacture, install, or service; (3) adverse impacts on product utility or availability; and (4) adverse impacts on health or safety. Chapter 4 of the TSD contains a description of the screening analysis. Also, section IV.B includes a discussion of the design options DOE considered, those it screened out, and those that are the basis for the trial standard levels (TSLs) in this rulemaking. 2. Maximum Technologically Feasible Levels In the engineering analysis, DOE determined the maximum technologically (max-tech) feasible efficiency levels for small electric motors using the most efficient design parameters that lead to the highest equipment efficiencies. (See TSD chapter 5.) Table III.1 lists the max-tech levels that DOE determined for this rulemaking. EP24NO09.002 DOE developed maximum technology efficiencies by creating motor designs for each product class analyzed that use all of DOE's viable design options. The efficiency levels shown in Table III.1 correspond to designs that use a maximum increase in stack length, a copper rotor design, an exotic low-loss steel type, a maximum slot fill percentage, a change in run-capacitor rating (CSCR motors only), and an optimized end ring design. All of the design options used to create these max-tech motors remain in the analysis and are options that DOE considers technologically feasible. C. Energy Savings 1. Determination of Savings DOE used its national energy savings (NES) spreadsheet to estimate energy savings from new standards for the small electric motors that are the subject of this rulemaking. (The NES analysis is described in section IV.G and in chapter 10 of the TSD.) DOE forecasted energy savings beginning in 2015, the year that new standards would go into effect, and ending in 2045 for each TSL. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between the standards case and the base case. The base case represents the forecast of energy consumption in the absence of new energy conservation standards. DOE's base case assumes no change in the efficiency distribution of motors between 2008 and the end of the analysis period in 2045. The NES spreadsheet model calculates the energy savings in site energy expressed in kilowatt-hours (kWh). Site energy is the energy directly consumed by small electric motors at the locations where they are used. DOE reports national energy savings in terms of the source energy savings, which is the savings in the energy that is used to generate and transmit the site energy. To convert site energy to source energy, DOE derived conversion factors, which change with time, from the American Recovery and Reinvestment Act scenario of the Energy Information Administration's (EIA) Annual Energy Outlook 2009 ( AEO 2009 ), which is the latest forecast available. 2. Significance of Savings Standards for small electric motors must result in “significant” energy savings. (42 U.S.C. 6317(b)) While the term “significant” is not defined in the Act, the U.S. Court of Appeals, in Natural Resources Defense Council v. Herrington , 768 F.2d 1355, 1373 (DC Cir. 1985), indicated that Congress intended “significant” energy savings to be savings that were not “genuinely trivial.” The energy savings for all of the TSLs considered in this rulemaking are nontrivial, and therefore DOE considers them significant. D. Economic Justification 1. Specific Criteria As noted earlier, EPCA provides seven factors to be evaluated in determining whether an energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)) The following sections discuss how DOE has addressed each of those seven factors as part of its analysis. DOE invites comments on each of these elements. a. Economic Impact on Manufacturers and Consumers In determining the impacts on manufacturers of a new or amended standard, DOE first determines the quantitative impacts using an annual cash-flow approach. This includes both a short-term assessment—based on the cost and capital requirements during the period between the announcement of a regulation and when the regulation comes into effect—and a long-term assessment. The impacts analyzed include 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, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, paying particular attention to impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment, manufacturing capacity, plant closures, and loss of capital investment. Finally, DOE takes into account the cumulative impact of different DOE regulations on manufacturers. For small electric motor customers, measures of economic impact include the changes in LCC and the PBP for each TSL. The LCC, which is also separately specified as one of the seven factors to be considered in determining the economic justification for a new or amended standard, (42 U.S.C. 6295(o)(2)(B)(i)(II)) is discussed in the following section. b. Life-Cycle Costs The LCC is the sum of the purchase price of a product (including its installation) and the operating expense (including energy and maintenance expenditures) discounted over the lifetime of the product. DOE determines these costs by considering (1) total installed price to the purchaser (including manufacturer selling price, distribution channel markups, sales taxes, and installation cost), (2) the operating expenses of the equipment (energy cost and maintenance and repair cost), (3) equipment lifetime, and (4) a discount rate that reflects the real cost of capital and puts the LCC in present value terms. For each representative small electric motor product class, DOE calculated both LCC and LCC savings for various efficiency levels. The LCC analysis estimated the LCC for representative units used in various representative applications, and accounted for a mixture of space-constrained applications (20 percent) and non-space-constrained applications (80 percent) in the commercial, agricultural, industrial, and residential sectors. To account for uncertainty and variability in specific inputs, such as equipment lifetime, annual hours of operation, and discount rate, DOE used a distribution of values with probabilities attached to each value. DOE sampled a nationally representative set of input values from the distributions to produce a range of LCC estimates. A distinct advantage of this approach is that DOE can identify the percentage of consumers achieving LCC savings or attaining certain payback values due to an energy conservation standard. Thus, DOE presents the LCC savings as a distribution, with a mean value and a range. DOE assumed in its analysis that the consumer purchases the product in 2015. c. Energy Savings While significant conservation of energy is a separate statutory requirement for imposing an energy conservation standard, DOE considers the total projected energy savings that are expected to result directly from the standard in determining the economic justification of that standard. (See 42 U.S.C. 6295(o)(2)(B)(i)(III)) DOE used the NES spreadsheet results in its consideration of total projected 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 sought to develop standards for small electric motors that would not lessen the utility or performance of this equipment. None of the TSLs DOE considered would reduce the utility or performance of the small electric motors under consideration in the rulemaking. (See 42 U.S.C. 6295(o)(2)(B)(i)(IV).) The efficiency levels DOE considered maintain motor performance and power factor ( i.e., approximately 75 percent for polyphase motors and greater than 60 percent for capacitor start motors) so that consumer utility is not adversely affected. DOE considered end-user size constraints by developing designs with size increase restrictions (limited to a 20-percent increase in stack length), as well as designs with less stringent constraints (100-percent increase in stack length). Those designs adhering to the 20-percent increase in stack length maintain all aspects of consumer utility and were created for all efficiency levels, but they may become very expensive at higher efficiency levels when compared with DOE's other designs. e. Impact of Any Lessening of Competition DOE considers any lessening of competition likely to result from standards. Accordingly, DOE has requested that the Attorney General transmit to the Secretary, not later than 60 days after the publication of this proposed rule, a written determination of the impact, if any, of any lessening of competition likely to result from today's proposed standards, together with an analysis of the nature and extent of such impact. (See 42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii).) Along with this request, DOE has transmitted a copy of today's proposed rule to the Attorney General. DOE will address the Attorney General's determination in the final rule. f. Need of the Nation To Conserve Energy The non-monetary benefits of the proposed standards are likely to be reflected in reductions in the overall demand for electricity, which will result in reduced costs for maintaining reliability of the Nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the Nation's power generation capacity. This analysis captures the effects of efficiency improvements on electricity consumption by the covered equipment, including the reduction in electricity generation capacity by fuel type. The proposed standards will also result in improvements to the environment. In quantifying these improvements, DOE has defined a range of primary energy conversion factors and associated emission reductions based on the estimated level of power generation displaced by energy conservation standards. DOE reports the environmental effects from each TSL in the environmental assessment in chapter 15 of the TSD. (See 42 U.S.C. 6295(o)(2)(B)(i)(VI)). g. Other Factors The Act 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)) Under this provision, DOE considered three factors: (1) Harmonization of the proposed standards with standards for similar products, (2) the need of some consumers to continue to have access to CSIR motors, and (3) the impacts of reactive power 6 on electricity supply costs. 6 In an alternating current power system, the reactive power is the root mean square (RMS) voltage multiplied by the RMS current, multiplied by the sine of the phase difference between the voltage and the current. Reactive power occurs when the inductance or capacitance of the load shifts the phase of the voltage relative to the phase of the current. While reactive power does not consume energy, it can increase losses and costs for the electricity distribution system. Motors tend to create reactive power because the windings in the motor coils have high inductance. Medium-sized polyphase general-purpose motors in three-digit frame series with output power of 1 horsepower and above are currently regulated under the Energy Policy Act of 1992 (EPACT 1992). DOE proposes a standard for polyphase small motors with output power of 1 horsepower and above that is closely aligned with the EPACT 1992 standard for medium motors. Some of the highest TSLs for single-phase motors would lead to very high prices for CSIR motors while maintaining lower prices for CSCR motors, or vice versa. This shift in relative price may cause the effective disappearance of the more expensive category of motors from the market. In many applications, CSCR motors can replace CSIR motors. However, in some instances, the space required for a second capacitor is not available so that a CSCR motor may not be used to replace a CSIR motor in some specific applications. Under 42 U.S.C. 6295(o)(4), the Secretary may not prescribe a standard that is “likely to result in the unavailability in the United States in any covered product type (or class).” In today's notice, DOE proposes standards that it believes will maintain a supply of both categories of motors in the single-phase motor market. DOE also notes that induction motors produce reactive power that can result in increased electricity supply costs because reactive power creates extra electrical currents that can require increased electrical distribution capacity. Many individual customers are not charged directly for this cost, but DOE did consider the economic benefits of potential reactive power reductions when evaluating the national benefits of the proposed standards. 2. Rebuttable Presumption Section 325(o)(2)(B)(iii) of EPCA states that there is a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer that meets the standard level is less than three times the value of the first-year energy (and as applicable, water) savings resulting from the standard, as calculated under the applicable DOE test procedure. (42 U.S.C. 6295(o)(2)(B)(iii) and 42 U.S.C. 6316(e)(1)) DOE's LCC and payback period (PBP) analyses generate values that calculate the PBP for customers of potential energy conservation standards, which includes, but is not limited to, the 3-year PBP contemplated under the rebuttable presumption test discussed above. However, DOE routinely conducts a full economic analysis that considers the full range of impacts, including those to the customer, manufacturer, Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(e)(1). The results of this analysis serve as the basis for DOE to evaluate definitively the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). For comparison with the more detailed analysis results, DOE provides the results of a rebuttable presumption payback calculation in section V.B.1.d. IV. Methodology and Discussion DOE used three spreadsheet tools to estimate the impact of today's proposed standards. The first spreadsheet calculates the LCCs and payback periods of potential new energy conservation standards. The second, the National Impact Analysis (NIA) spreadsheet, provides shipment forecasts and then calculates national energy savings and net present value impacts of potential new energy conservation standards. DOE assessed manufacturer impacts largely through use of the third spreadsheet, the Government Regulatory Impact Model (GRIM). Additionally, DOE estimated the impacts of energy efficiency standards for small 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, a widely known energy forecast for the United States. The version of NEMS used for appliance standards analysis is called NEMS-BT, and is based on the AEO 2009 version with minor modifications. The NEMS offers a sophisticated picture of the effect of standards because it accounts for the interactions between the various energy supply and demand sectors and the economy as a whole. The EIA approves 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 used here. (“BT” stands for DOE's Building Technologies Program.) For more information on NEMS, refer to The National Energy Modeling System: An Overview, DOE/EIA-0581 (98) (Feb. 1998), available at http://tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf . A. Market and Technology Assessment When beginning an energy conservation standards rulemaking, 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 product classes, manufacturers, quantities, and types of equipment sold and offered for sale; retail market trends; and regulatory and non-regulatory programs. See chapter 3 of the TSD for further discussion of the market and technology assessment. 1. Definition of Small Electric Motor Except for small electric motors that are components of other products covered by EPCA (see 42 U.S.C. 6317(b)(3)), DOE analyzed all CSIR and CSCR single-phase motors and polyphase motors, including, for example, both open and enclosed motors. DOE determined that standards appear to be warranted for all of them. 71 FR 38807-08. However, DOE has tentatively concluded that EPCA does not cover certain small motors for which the determination concluded standards were warranted—the most significant group being enclosed motors. a. Motor Categories EPCA's definition of “small electric motor” is tied to the terminology and performance requirements in NEMA Standards Publication MG1-1987 (MG1-1987). These requirements were established for (1) general-purpose alternating-current motors, (2) single-speed induction motors, and (3) the NEMA system for designating (two-digit) frames. Single-speed induction motors, as delineated and described in MG1-1987, fall into five categories: split-phase, shaded-pole, capacitor-start (both CSIR and CSCR), permanent-split capacitor (PSC), and polyphase. Therefore, only motors in these categories meet the single-speed induction motor element of EPCA's definition of “small electric motor.” In paragraph MG1-1.05, MG1-1987 defines “general-purpose alternating-current motor” as follows: A general-purpose alternating-current motor is an induction motor, rated 200 horsepower and less, which incorporates all of the following: (1) Open construction, (2) rated continuous duty, (3) service factor in accordance with MG1-12.47, and (4) Class A insulation system with a temperature rise as specified in MG1-12.42 for small motors or Class B insulation system with a temperature rise as specified in MG1-12.43 for medium motors. It is designed in standard ratings with standard operating characteristics and mechanical construction for use under usual service conditions without restriction to a particular application or type of application. During the public meeting held on January 30, 2009, Emerson Motor Technologies commented that split-phase motors, shaded-pole motors, and PSC motors do not meet the torque requirements for NEMA general-purpose motors. Therefore, Emerson indicated that these motors should be excluded from the scope of coverage for this rulemaking. (Emerson, Public Meeting Transcript, No. 8.5 at p. 38) 7 7 A notation in the form “Emerson, Public Meeting Transcript, No. 8.5 at p. 38” refers to (1) a statement that was submitted by Emerson Motor Technologies and is recorded in the docket “Energy Efficiency Program for Certain Commercial and Industrial Equipment: Public Meeting and Availability of the Framework Document for Small Electric Motors,” Docket Number EERE-2008-BT-STD-0007, as comment number 8.5; and (2) a passage that appears on page 38 of the transcript, “Small Electric Motors Energy Conservation Standards Preliminary Analyses Public Meeting,” dated January 30, 2009. Likewise, a notation in the form “NEMA, No. 13 at p. 5” refers to (1) a statement by the National Electrical Manufacturers Association and is recorded in the docket as comment number 13; and (2) a passage that appears on page 5 of that document. DOE has examined this issue and, consistent with its position in the preliminary analyses, agrees that split-phase, shaded-pole, or PSC motors do not qualify as general-purpose alternating-current motors. Because split-phase motors are usually designed for specific purposes and applications, they are not designed “for use under usual service conditions without restriction to a particular application or type of application.” Additionally, split-phase, shaded-pole, and PSC motors all fail to meet MG1-1987's torque and current requirements for general-purpose motors, and hence are not “designed in standard ratings with standard operating characteristics.” The requirements that NEMA MG1-1987 defines for single-phase motors are locked-rotor torque at MG1-12.32.2, locked-rotor current at MG1-12.43, and breakdown torque at MG1-12.32. For small polyphase motors, NEMA MG1-1987 only defines breakdown torque in MG1-12.37. Because of these restrictions, none of the above motor categories are small electric motors as EPCA defines that term. DOE's determination that standards are warranted for small electric motors excluded the above motor categories, and none are covered by today's proposed standards. As for CSIR, CSCR, and polyphase motors, these motor categories do meet the performance requirements set forth by the MG1-1987 definition of “general-purpose alternating-current motor” and are therefore covered by the EPCA definition of a small electric motor. During the public meeting, PG&E, Earthjustice, and ACEEE expressed concern that small electric motors not covered by the scope of coverage of this rulemaking would be preempted from coverage as a result of energy conservation for standards for the covered small electric motors. (PG&E, Earthjustice, ACEEE, Public Meeting Transcript, No. 8.5 at pp. 320-323) In their comment, Earthjustice also requested that DOE clarify this issue. (Earthjustice, No. 11 at pp. 3-5) DOE appreciates these concerns and would like to clarify the issue of preemption. The statutory definition of small electric motors only gives DOE the authority to cover, CSIR, CSCR, and polyphase motors. Therefore, state standards for other, non-covered motor categories, such as those discussed above, would not be preempted by the standards set by this rulemaking. b. Motor Enclosures The first criterion listed in NEMA MG1-1987's definition of a “general-purpose alternating-current motor” is that the motor is of open construction. In the latest version of NEMA MG1, MG1-2006 with Revision 1 2007, NEMA modified this criterion and expanded it to include enclosed motors. At the preliminary analyses public meeting, Earthjustice commented that DOE could reinterpret the statutory definition of small electric motor such that NEMA MG1-1987 only applies to the definition of two-digit frame number series and later versions of MG1 could be used to expand coverage to include enclosed motors. Earthjustice reiterated this point in a comment submitted after the public meeting. (Earthjustice, Public Meeting Transcript, No. 8.5 at pp. 47-50; Earthjustice, No. 11 at p. 1) NEMA disagreed with this interpretation of the statutory definition, arguing that MG1-1987 was intended to apply to the entire definition of a small electric motor. Therefore, NEMA recommended that DOE only cover open motors. (NEMA, No. 13 at p. 17) DOE agrees with NEMA that the reference MG1-1987 applies to all facets of the statutory definition of a small electric motor. The language of the statute specifies that the requirements of MG1-1987 apply in determining what constitutes a small electric motor. DOE's application of that definition is consistent with that language. Similarly, because the statute specifically mentions MG1-1987 as the version of MG1 on which DOE should relay, the 1987 version is the only applicable version of NEMA MG1. Accordingly, consistent with MG1-1987, only CSIR, CSCR, and polyphase motors with open construction meet the statutory definition. c. Service Factors Additional CSIR, CSCR, and polyphase motors may fail to meet the NEMA definition because, for example, they fail to meet the service factor requirements. Service factor is a measure of the overload capacity at which a motor can operate without damage, while operating normally within the correct voltage tolerances. The rated horsepower multiplied by the service factor determines that overload capacity. For example, a 1 horsepower motor with a 1.25 service factor can operate at 1.25 horsepower (1 horsepower × 1.25 service factor). DOE has concluded that motors that fail to meet service factor requirements in MG1-12.47 are not “small electric motors” as EPCA uses that term. Therefore, today's proposed standards do not apply to them. d. Insulation Class Systems The statutory definition of a small electric motor is bound to the definition of a general-purpose alternating-current motor as defined in NEMA MG 1-1987. Part of that NEMA definition says that a general-purpose motor must incorporate a “Class A insulation system with a temperature rise as specified in MG 1-12.42 for small motors or Class B insulation system with a temperature rise as specified in MG 1-12.43 for medium motors.” The issue of insulation classes and how it pertains to DOE's scope of coverage was discussed at the preliminary analysis public meeting. Advanced Energy spoke about insulation classes and recommended that DOE's coverage should include Class F insulation systems. (Advanced Energy, Public Meeting Transcript, No. 8.5 at pp. 45-46) Advanced Energy noted that insulation class systems used in small electric motors have improved since this definition of general purpose was first standardized in NEMA MG1-1987. Further, as new insulation technologies have improved and material costs have decreased, it has become increasingly common for manufacturers to use insulation classes higher than A. Advanced Energy requested in written comments that DOE consider all insulation classes as covered (Advanced Energy, No. 16 at p. 4). Upon further examination of the market, DOE agrees with Advanced Energy. The vast majority of the motors manufactured, and otherwise covered by this rulemaking, satisfy the requirements for Class B or Class F insulation systems. DOE also found that according to MG1-1.66 and paragraph MG1-12.42, NEMA MG 1-1987 defines four insulation class systems. They are divided into classes based on the thermal endurance of the system for temperature rating purposes. A Class A insulation system must have suitable thermal endurance at a temperature rise. Class A insulation is a minimum level of thermal endurance. A Class B insulation system has a greater thermal endurance rating than Class A. Similarly, Class F thermal endurance exceeds Class B and Class H insulation has the highest level of endurance among all four classes. Therefore, the insulation class systems are defined in a way that permits a Class H system to satisfy Classes A, B, and F. DOE believes that this approach satisfies the statute and avoids creating a loophole through which all small electric motors equipped with non-Class A insulation would be eliminated from coverage. Commenters did not suggest that these insulation classes should be exempt from coverage and DOE is proposing to consider covering insulation Classes A or higher as covered under this rule. Therefore, DOE interprets the NEMA MG1-1987 definition of a “general-purpose, alternating-current motor” as being applicable to insulation class systems rated A or higher. e. Metric Equivalents EPCA defines a small electric motor based on the construction and rating system in MG1-1987. (42 U.S.C. 6311(13)(G)) This system uses English units of measurement and power output ratings in horsepower. In contrast, general-purpose electric motors manufactured outside the United States and Canada are defined and described with reference to the International Electrotechnical Commission (IEC) Standard 60034-1 series, “Rotating electrical machines,” which employs terminology and criteria different from those in EPCA. The performance attributes of these IEC motors are rated pursuant to IEC Standard 60034-1 Part 1: “Rating and performance,” which uses metric units of measurement and construction standards different from MG1-1987, and a rating system based on power output in kilowatts instead of power output in horsepower. The Institute of Electrical and Electronics Engineers (IEEE) Standard 112 recognizes this difference in the market and defines the relationship between horsepower and kilowatts. Furthermore, in 10 CFR 431.12, DOE defined “electric motor” in terms of both NEMA and IEC equivalents even though EPCA's corresponding definition and standards were articulated in terms of MG1-1987 criteria and English units of measurement. 64 FR 54114 (October 5, 1999) DOE received two comments on IEC-equivalent motors following the January 30, 2009, public meeting. NEMA commented that IEC-equivalent motors should be considered covered products to prevent the import of virtually identical products that are not compliant with energy efficiency standards. (NEMA, No. 13 at p. 17) A joint comment submitted by PG&E, SCE, SCGC, and SDGE also stated that IEC-equivalent motors should be covered to prevent a potential loophole in the standard. (Joint Comment, No. 12 at p. 2) Although the statutory definition of “small electric motor” does not address metric or kilowatt-rated motors, DOE agrees with the submitted comments. In general, IEC metric or kilowatt-equivalent motors can perform the identical functions of covered small electric motors and provide comparable rotational mechanical power to the same machines or equipment. Moreover, IEC metric or kilowatt-equivalent motors can be interchangeable with covered small electric motors. Therefore, DOE interprets EPCA to apply the definition of a “small electric motor” to any motor that is identical or equivalent to a motor constructed and rated in accordance with NEMA MG1. Additionally, as to motors with a standard kilowatt rating, DOE prescribed energy conservation standards for medium electric motors ( i.e., NEMA three-digit frame series motors) in section 431.25(a). In this section of the CFR DOE establishes equivalencies of standard horsepower and kilowatt ratings. As demonstrated by examination of these specified equivalencies in section 431.25(a) and the exact conversions of standard kilowatt ratings to horsepower ratings laid out in 431.25(b)(3)—no standard kilowatt rating exactly equals a standard horsepower rating—and therefore an IEC motor with a standard kilowatt rating must sometimes meet the efficiency standard for the next higher horsepower or the next lower depending on what converted horsepower value is relative to the surrounding standard horsepower ratings. In all cases the standard it must meet is prescribed for a horsepower that is very close to an exact conversion from its kilowatt rating. Second, as to electric motors with non-standard kilowatt or horsepower ratings, section 431.25(b)(3) provides that kilowatt rating would be arithmetically converted to its equivalent horsepower rating, and then, based on whether the motor falls above or below the midpoint between consecutive horsepower ratings, would be required to meet the corresponding higher or lower energy efficiency level, respectively. DOE proposes to adopt similar interpretations for small electric motors. f. Frame Sizes As to the frame sizes of motors that would be covered by DOE standards for small electric motors, EPCA defines small electric motor, in part, as a motor “built in a two-digit frame number series in accordance with MG1-1987.” (42 U.S.C. 6311(13)(G)) MG1-1987 establishes a system for designating frames of motors, which consists of a series of numbers in combination with letters. The 1987 version of MG1 only explicitly defines three two-digit frame series: 42, 48, and 56. These frame series have standard dimensions and tolerances necessary for mounting and interchangeability that are specified in sections MG1-11.31 and MG1-11.34. DOE understands that manufacturers produce other two-digit frame sizes, namely a 66 frame size. The 66 frame size is used for definite-purpose or special-purpose motors and not used in general-purpose applications and therefore not covered under the EPCA definition of “small electric motor.” DOE is unaware of any other motors with frame sizes that are built in accordance with NEMA MG1-1987. Should such frame sizes appear, DOE will evaluate whether or not they are included equipment at that time. g. Horsepower Ratings The definition of a small electric motor does not explicitly limit the scope of coverage to certain horsepower ratings. However, DOE notes that the small electric motor industry generally considers 3 hp as the upper limit for rated capacity of such motors. Nonetheless, some manufacturers produce motors that meet the EPCA definition of small electric motor but have higher horsepower ratings. DOE has tentatively concluded that such motors are still covered by and subject to standards adopted under EPCA. Chapter 3 of the TSD provides additional detail on the nature of the motors covered by the standards proposed in this NOPR. 2. Product Classes When evaluating and establishing energy conservation standards, DOE generally divides covered equipment into classes by the type of energy used, capacity, or other performance-related features that affect efficiency. (42 U.S.C. 6295(q)) DOE routinely establishes different energy conservation standards for different product classes based on these criteria. At the preliminary analyses public meeting, DOE presented its rationale for creating 72 product classes. The 72 product classes are based on the combinations of three different ratings or characteristics of a motor based on motor category, number of poles, and horsepower. As these motor characteristics change, so does the utility and efficiency of the small electric motor. The motor category divides the small electric motors market into three major motor categories: CSIR, CSCR, and polyphase. For each motor category, DOE broke down the product classes by all combinations of the eight different horsepower ratings ( i.e., 1/4 to ≥ 3) and three different pole configurations ( i.e., 2, 4, and 6). A number of reasons support this approach. First, the motor category depends on the type of energy used and its starting and running electrical characteristics. While all small electric motors use electricity, some motors operate on single phase electricity (which requires certain additional electronics for creating rotational torque) while others operate on polyphase electricity. Polyphase motors do not need additional circuitry to create rotational torque because they use the existing phase difference in the multiple phases of electricity applied to the motor. This difference impacts efficiency, and therefore becomes a factor around which DOE establishes a separate product class for polyphase motors. Within single phase small electric motors, there are characteristics which are important because they can affect the motor's utility and potential for improving efficiency. The design feature of incorporating a run capacitor into the small electric motor affects motor efficiency, making it more efficient than an induction run motor that does not incorporate a run capacitor. 8 This design constitutes a performance-related feature that affects efficiency. Furthermore, DOE notes that it is not always possible to replace a CSIR motor with a CSCR motor due to the run capacitor, which is often mounted in an external housing on the motor. In certain applications, the run capacitor mounted on the motor will physically prohibit it from replacing a CSIR motor. This is a design feature that affects utility. For all of these reasons, DOE treats CSIR and CSCR motors as separate product classes. 8 The run-capacitor and auxiliary windings in a CSCR motor help simulate a balanced two phase motor at full load, which helps minimize the current required to run the motor, thereby reducing the I 2 R losses (which are losses related to current flow). Second, the number of poles in an electric motor determines the synchronous speed ( i.e., revolutions per minute). There is an inverse relationship between the number of poles and the maximum speed a motor can run at, meaning that an increase in the number of poles equates to a decrease in the speed of the motor ( e.g., going from two to four to six poles, the synchronous speed drops from 3,600 to 1,800 to 1,200 revolutions per minute). Since the full range of motor applications requires a variety of motor speeds, DOE considers motor speed and, therefore, the number of poles to have a distinct impact on the utility of small electric motors. Therefore, DOE uses the number of poles in a motor as a means of differentiating product classes because it is this design change that creates a change in motor speed capabilities. Third, in general, efficiency scales with horsepower, a capacity-related metric of small electric motors. In other words, a 3 horsepower motor is usually more efficient than a 1/4 horsepower motor. Horsepower is a critical performance attribute of an electric motor, and since there is a correlation with efficiency, DOE uses this as a criterion for distinguishing among product classes. At the public meeting, Emerson and Baldor commented that frame size should be considered as an additional motor characteristic when establishing product classes. They both stated that motors of different frame sizes should not be subjected to the same standards because motors in the smaller frames will not be able to achieve as high an energy efficiency rating as the larger frame size. (Baldor, Public Meeting Transcript, No. 8.5 at pp. 70-71; Emerson, Public Meeting Transcript, No. 8.5 at pp. 75-76) DOE agrees that motors in a smaller frame size, and therefore made with a potentially smaller diameter, will not be able to achieve the same efficiency rating as a larger frame. The smaller diameter limits the amount of active material that is used to reduce motor losses and therefore limits the maximum efficiency rating possible as well. However, DOE believes that frame size does not adequately account for efficiency limits based on the physical size of the motor. The frame size only dictates what the “D” dimension ( i.e., the dimension comprising the length from the bottom of the feet of a motor to the center of its shaft). For example, a 56 frame motor could have a stator outside diameter ranging from 5.5 inches to 6.15 inches. Therefore, DOE accounts for how changes in diameter can affect product utility and efficiency in the engineering analysis. Additionally, if DOE were to add frame size to the class-setting criterion the number of product classes would increase from 72 to 216, which is a change by a factor of three for the frame sizes covered: 42, 48, and 56. Such a large number of product classes would result in a large number of basic models, which would be too burdensome on manufacturers when seeking certification of compliance. The three tables below lay out the 72 product classes, including a description of kilowatt and horsepower equivalents. BILLING CODE 6450-01-P EP24NO09.003 EP24NO09.004 Chapter 3 of the TSD accompanying this notice provides additional detail on the product classes defined for the standards proposed in this NOPR. B. Screening Analysis DOE uses the following four screening criteria to determine which design options are suitable for further consideration in a standards rulemaking: 1. Technological feasibility. DOE considers technologies incorporated in commercial products or in working prototypes to be technologically feasible. 2. Practicability to manufacture, install, and service. If mass production and reliable installation and servicing of a technology in commercial products could be achieved on the scale necessary to serve the relevant market at the time the standard comes into effect, then DOE considers that technology practicable to manufacture, install, and service. 3. Adverse impacts on product utility or product availability. If DOE determines a technology would have significant adverse impact on the utility of the product to significant subgroups of consumers, or would result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not consider this technology further. 4. Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider this technology further. See 10 CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b). DOE identified the following technology options that could improve the efficiency of small electric motors: utilizing a copper die-cast rotor, reducing skew on stack ( i.e. , straightening the rotor conductor bars), increasing the cross-sectional area of rotor conductor bars, increasing the end ring size, changing the copper wire gauge used in the stator, manipulating the stator slot size, changing capacitor ratings, decreasing the air gap between the rotor and stator, improving the grades of electrical steel, using thinner steel laminations, annealing steel laminations, adding stack height, using high efficiency lamination materials, using plastic bonded iron powder (PBIP), installing better ball bearings and lubricant, and installing a more efficient cooling system. For a description of how each of these technology options improves small electric motor efficiency please see TSD chapter 3. For the NOPR, DOE screened out two of these technology options: PBIP and decreasing the air gap below .0125″. PBIP is based on an iron powder alloy that is suspended in plastic, and is used in certain motor applications such as fans, pumps, and household appliances. The compound is then shaped into motor components using a centrifugal mold, reducing the number of manufacturing steps. Researchers claim that this technology option could cut losses by as much as 50 percent. 9 The Lund University team already produces inductors, transformers, and induction heating coils using PBIP, but has not yet produced a small electric motor. In addition, it appears that PBIP technology is aimed at torus, claw-pole, and transversal flux motors, none of which fit EPCA's definition of small motors. 9 Horrdin, H., and E. Olsson. Technology Shifts in Power Electronics and Electric Motors for Hybrid Electric Vehicles: A Study of Silicon Carbide and Iron Powder Materials. 2007. Chalmers University of Technology. Göteborg, Sweden. Considering the four screening criteria for this technology option, DOE screened out PBIP as a means of improving efficiency. Although PBIP has the potential to improve efficiency while reducing manufacturing costs, DOE does not consider this technology option technologically feasible, because it has not been incorporated into a working prototype of a small electric motor. Also, DOE is uncertain whether the material has the structural integrity to form into the necessary shape of a small electric motor steel frame. Furthermore, DOE is uncertain whether PBIP is practicable to manufacture, install, and service, because a prototype PBIP small electric motor has not been made and little information is available on the ability to manufacture this technology. However, DOE is not aware of any adverse impacts on product utility, product availability, health, or safety that may arise from the use of PBIP in small electric motors. Reducing the air gap between the rotor and stator can improve motor efficiency as well by reducing the magnetomotive force drop ( i.e., the force producing the magnetic flux needed to operate the motor), which occurs across the air gap. Reducing this drop means that the motor will require less current to operate. For small electric motors, the air gap is commonly set at 15 thousandths of an inch. Although reducing this air gap can improve efficiency, there is some point at which the air gap is too tight and becomes impracticable to manufacture. For the preliminary analyses DOE set an air gap reduction limit at 10 thousandths of an inch. During the public meeting and the comment period following it, DOE received comments on this technology option. At the public meeting, Baldor stated that reducing the air gap between the stator and rotor will not improve motor efficiency, but could potentially worsen it instead. (Baldor, Public Meeting Transcript, No. 8.5 at p. 119) Alternatively, in the comment submitted on behalf of Baldor and other manufacturers by NEMA, they stated that reducing the air gap could have a positive effect on efficiency for some motor designs, but not necessarily all. (NEMA, No. 13 at p. 5) NEMA also stated that a more practical limit on the air gap for small electric motors is 12.5 thousandths of an inch. (NEMA, No. 13 at p. 3) DOE agrees with NEMA's comments and screened out decreasing the radial air gap below 12.5 thousandths of an inch as a means of improving efficiency. DOE believes air gaps of 10 thousandths of an inch are possible; however, they are more practical in non-continuous, stepper motors (motors whose full rotation is completed in discrete movements) where potential contact is not as much of a concern. DOE considers air gap reduction below 12.5 thousandths of an inch technologically feasible, because smaller air gaps do not present any technological barrier. Also, DOE is not aware of any adverse impacts on health or safety associated with reducing the radial air gap below 12.5 thousandths of an inch. However, DOE believes that this technology option fails the screening criterion of being practicable to manufacture, install, and service because such a tight air gap may cause the rotor to come into contact with the stator and cause manufacturing and service problems. This technology option fails the screening criterion of adverse impacts on consumer utility and reliability, because the motor may experience higher failure rates in service when the manufactured air gaps are less than 12.5 thousandths of an inch. DOE received comments on two other technology options as well—increasing stack length and the use of different run capacitors. Baldor suggested that DOE screen out changing the stack length of the motor because it will force some original equipment manufacturers (OEMs) that use small electric motors to invest in redesigning their equipment to fit the potentially larger motor. (Baldor, Public Meeting Transcript, No. 8.5 at pp. 121-22) DOE cannot screen out a technology option because of cost, so DOE believes adding stack height and lengthening a motor is a viable technology option that passes all four screening criterion. Accordingly, these technology options will be included in the engineering analysis. See the engineering analysis, section IV.C. NEMA recommended that DOE consider varying the rating of capacitors used in small electric motors as a technology option. (NEMA, No. 13 at p. 18) In response, DOE notes that though varying capacitor ratings was not explicitly listed as a technology option, it was utilized in the preliminary engineering analysis. DOE agrees that changing the capacitor rating, specifically the run-capacitor rating used in CSCR motors, can provide increases in motor efficiency with minimal redesign effort. DOE believes that changing the capacitor rating meets all four screening criterion and is being included in the engineering analysis of this NOPR. DOE believes that all of the efficiency levels discussed in today's notice are technologically feasible. The evaluated technologies all have been used (or are being used) in commercially available products or working prototypes. These technologies all incorporate materials and components that are commercially available in today's supply markets for the motors that are the subject of this NOPR. Therefore, DOE believes all of the efficiency levels evaluated in this notice are technologically feasible. C. Engineering Analysis The engineering analysis develops cost-efficiency relationships to show the manufacturing costs of achieving increased efficiency. DOE has identified the following three methodologies to generate the manufacturing costs needed for the engineering analysis: (1) The design-option approach, which provides the incremental costs of adding to a baseline model design options that will improve its efficiency; (2) the efficiency-level approach, which provides the relative costs of achieving increases in energy efficiency levels, without regard to the particular design options used to achieve such increases; and (3) the cost-assessment (or reverse engineering) approach, which provides “bottom-up” manufacturing cost assessments for achieving various levels of increased efficiency, based on detailed data as to costs for parts and material, labor, shipping/packaging, and investment for models that operate at particular efficiency levels. 1. Approach In this rulemaking, DOE conducted the engineering analysis using a modified design-option approach where DOE employed a technical expert with motor design software to develop motor designs at several efficiency levels for each analyzed product class. Based on these simulated designs and manufacturer and component supplier data, DOE calculated manufacturing costs and selling prices associated with each efficiency level. DOE decided on this approach after receiving insufficient response to its request for the manufacturer data needed to execute an efficiency-level approach for the preliminary analyses. The design-option approach allows DOE to make its engineering analysis methodologies, assumptions, and results publicly available, thereby permitting all interested parties the opportunity to review and comment on this information. The design options considered in the engineering analysis include: copper die-cast rotor, reduce skew on stack, increase cross-sectional area of rotor conductor bars, increase end-ring size, change gauge of copper wire in stator, manipulate stator slot size, decrease air gap between rotor and stator to 12.5 thousandths of an inch, improve grades of electrical steel, use thinner steel laminations, anneal steel laminations, add stack height, use high efficiency lamination materials, change capacitors ratings, install better ball bearings and lubricant, and install a more efficient cooling system. Chapter 5 of the TSD contains a detailed description of the product classes analyzed and the analytical models DOE used to conduct the small electric motors engineering analysis and chapter 3 of the TSD contains a detailed description of how all the design options increase motor efficiency. 2. Product Classes Analyzed As discussed in section IV.A.2 of this notice, DOE proposes establishing a total of 72 product classes for small electric motors, based on the motor category (polyphase, CSIR, or CSCR), horsepower, and pole configuration. However, due to scheduling and resource constraints, DOE was not able to conduct a separate engineering analysis for each and every product class. Instead, DOE carefully selected certain product classes to analyze, and then scaled its analytical findings for those representative product classes to other product classes that were not analyzed. Further discussion of this issue is presented in section IV.C.6. For the engineering analysis conducted during the preliminary analysis, DOE analyzed three representative product classes, all with the most popular, 4-pole configuration. In response to that analysis, Baldor commented that two and six-pole motors may have significant design differences (such as the rotor outer diameter) from 4-pole motors. (Baldor, Public Meeting Transcript, No. 8.5 at pp. 196-99) Although DOE recognizes that these design differences exist and may affect efficiency, DOE has continued to directly model only 4-pole motors in its engineering analysis because it is the most popular configuration within each motor category and therefore the best basis for scaling. As discussed in section IV.C.3, DOE has revised its scaling relationships between product classes to account for efficiency-related differences between pole configurations. For the NOPR, similar to its approach in the preliminary analyses, DOE analyzed the three representative product classes depicted in Table IV.4. By choosing these three product classes, DOE ensures that each motor category (polyphase, CSIR, and CSCR) is represented. In addition, DOE has chosen horsepower ratings for each motor category that are commonly available across most manufacturers, thus increasing the quantity of available data on which to base the analysis. Finally, DOE chose four-pole motors for each motor category, consistent with NEMA-provided shipments data (see TSD chapter 9), which indicated that these motors have the highest shipment volume for 2007. See TSD chapter 5 for additional detail on the product classes analyzed. EP24NO09.005 3. Cost Model For the preliminary analyses and this NOPR, DOE developed a cost model to estimate the manufacturing production cost (MPC) of small electric motors. The model uses outputs of the design software to generate a complete bill of materials, specifying quantities and dimensions of parts associated with the manufacturing of each design. The bill of materials is multiplied by markups for scrap, overhead 10 (which includes depreciation) and associated non-production costs such as interest payments, research and development, and sales and general administration. The software output also includes an estimate of labor time associated with each step of motor construction. DOE multiplied these estimates by a fully burdened labor rate to obtain an estimate of labor costs. 10 DOE used a markup of 17.5% for overhead when the motor design used an aluminum rotor and 18.0% when the motor design used a copper rotor. The difference in markup is to account for increased depreciation of the manufacturing equipment associated with using a copper rotor. During the public meeting, DOE received two comments regarding inputs to the cost model. Edison Electric Institute expressed concern with how DOE would handle material pricing for input commodity prices since the past several years have seen drastic fluctuations in these prices. (EEI, Public Meeting Transcript, No. 8.5 at pp. 161-62) NEEA reiterated these concerns and suggested that DOE use a distribution of commodity prices and generate various pricing scenarios. (NEEA, Public Meeting Transcript, No. 8.5 at p. 164) DOE decided to estimate input costs by using an inflation-adjusted 5-year average of prices for each of the input commodities: steel laminations, copper wiring, and aluminum and copper for rotor die-casting. This method for calculating costs is consistent with past rulemakings where material costs were a significant part of manufacturers' costs. In calculating the 5-year average prices for these commodities, DOE adjusted historical prices to 2008 terms using the historical Producer Price Index (PPI) for that commodity's industry. DOE also performed a cost sensitivity analysis in which it examined both a high and low cost scenario for commodities. For all commodity prices, DOE used the PPI to determine the high and low cost points and then input those costs into the cost model. This allowed DOE to generate a high commodities cost case and a low commodities cost case for the engineering analysis results. Please refer to TSD chapter 5 for additional details on DOE's commodities cost scenario. DOE applied a manufacturer markup to the MPC estimates to arrive at the MSP. MSP is the price of equipment sold at which the manufacturer can recover both production and non-production costs and earn a profit. DOE developed a market-share-weighted average industry markup by examining gross margin information from the annual reports of several major small electric motor manufacturers and Securities and Exchange Commission (SEC) 10-K reports. 11 Because the SEC 10-K reports do not provide gross margin information for different product line offerings, the estimated markups represent the average markups that the company applies over its entire range of motor offerings. 11 Available at: http://www.sec.gov/edgar.shtml. Markups were evaluated for 2003 to 2008. The manufacturer markup is calculated as 100/(100—average gross margin), where average gross margin is calculated as revenue—cost of goods sold (COGS). To validate the information, DOE reviewed its assumptions with motor manufacturers. During interviews (see Chapter 12 of the TSD), motor manufacturers stated that many manufacturers generate different levels of revenue and profit for different product classes, but generally agreed with the end markup that was generated. For the NOPR engineering analysis, DOE used an industry-wide manufacturer markup of 1.45 based on the information described above. 4. Baseline Models As mentioned above, the engineering analysis calculates the incremental costs for equipment with efficiency levels above the baseline in each product class analyzed. During the preliminary analyses, NEMA provided DOE with baseline efficiency levels for the four motors DOE analyzed. The baseline efficiencies reported by NEMA were from a set of compiled data submitted by its members. The reported baseline efficiency levels also corresponded to the lowest efficiencies of motors manufactured and sold in the market by their members at that time. For the preliminary analyses, DOE used the expertise of its subcontractor to develop baseline design parameters that included dimensions, steel grades, copper wire gauges, operating temperatures, and other features necessary to calculate the motor's performance. The subcontractor used a software program to create a baseline design that had an efficiency rating equivalent to that provided by NEMA and torque and current restrictions compliant with NEMA MG1-1987. After the public meeting, a few commenters raised issues related to baseline models. NEMA stated that DOE should use the baseline efficiencies that had been provided for the preliminary analyses to select efficiencies for the baseline models in the NOPR. (NEMA, No. 13 at p. 5) For the NOPR analysis, DOE reexamined the baseline units selected. To establish the baseline motor for the three representative product classes DOE examined all available catalog data to find motors with the lowest efficiency on the market. The rated efficiencies for the polyphase and CSIR motors that DOE chose corresponded to the baseline efficiency levels that NEMA had recommended. However, for the CSCR motor DOE was unable to find a motor with as low an efficiency as that recommended by NEMA. Therefore, DOE selected the lowest efficiency level it could find in the market, which was 72 percent instead of the 66 percent recommended by NEMA. After purchasing the small electric motors, DOE had its design subcontractor, as well as an accredited laboratory, test the motors according to the appropriate IEEE test procedure. See Table IV.5 for the NEMA recommended efficiencies, the catalog rated efficiencies, and the tested efficiencies of the three baseline models. EP24NO09.006 DOE also received comment on removing a motor that was analyzed for the preliminary analysis from further analysis. In the preliminary analysis, DOE analyzed two CSIR motors of the same horsepower and pole configuration, but with different frame sizes. After the engineering analysis showed little difference in the cost-efficiency relationship, DOE decided not to include the motor with the larger frame size in the subsequent NIA and LCC analyses. Adjuvant Consulting stated that they agreed with this decision (Adjuvant Consulting, No. 9 at p. 4) However, NEMA disagreed with the implication that frame size makes little difference on the cost-efficiency relationship in their comment and stated that they believed the little differences shown between the motors analyzed was due to the differences in other design characteristics of the baseline motor. (NEMA, No. 12 at p. 19) DOE considered both of these comments when choosing appropriate product classes to analyze. DOE agrees with Adjuvant Consulting and believes that an analysis of two motors with different frame sizes, but in the same product class is not necessary. DOE also agrees with NEMA's assessment that the reason there was little difference between the two CSIR motors was due to the difference in the baseline design and not that there are little differences in cost-efficiency relationships for motors with the same ratings, but in different frame sizes. However, in the NOPR, DOE chose not to analyze two motors in the same product class with different frame sizes. Instead, DOE selected motors with the most restricted frame size seen in the respective product classes. DOE believes this is the best way to assess the efficiency capabilities of motors in the representative product classes. Emerson stated that the software program used by DOE in developing its baseline models should be validated by actual motor designs that are produced. (Emerson, Public Meeting Transcript, No. 8.5 at pp. 148-49) DOE established dimensional and performance specifications other than efficiency for the baseline models by examining all outputs of the IEEE test procedures and performing teardowns of the purchased motors. The IEEE test procedures provide several motor performance characteristics including speed, power factor, torque, and line current at various load points. After compiling these test data, DOE's subcontractor tore down each motor purchased to obtain internal dimensions, copper wire gauges, steel grade, and any other pertinent design information. Finally, the purchased motors were created in the designer's software and used as the baseline models in each analyzed product class for the engineering analysis. Again, the three product classes that were analyzed were: CSIR, 1/2 horsepower, 4-pole; CSCR 3/4 horsepower, 4-pole; and polyphase, 1 horsepower, 4-pole motors. The specifications of the baseline models can be found in detail in TSD chapter 5. 5. Design Options and Limitations In the market and technology assessment for the preliminary analyses, DOE defined an initial list of technologies that could increase the energy efficiency of small electric motors. In the screening analysis for the preliminary analyses, DOE screened out two of these technologies (PBIP and an air gap less than 12.5 thousandths of an inch) based on four screening criteria: technological feasibility; practicability to manufacture, install, and service; impacts on equipment utility or availability; and impacts on health or safety. The remaining technologies became inputs to the preliminary analyses engineering analysis as design options. In addition to the comments DOE received about the list of design options considered in the screening analysis, DOE also received several comments about design limitations that should be considered. Among these design limitations are limits on how much to apply certain design options and motor performance characteristics that should be monitored and maintained. The comments addressed all of the following issues: manufacturability, motor size, service factor, skew, the air gap between the rotor and stator, power factor, speed, service factor, slot fill, locked-rotor conditions, no-load conditions, breakdown torque, and thermal characteristics of the motor. a. Manufacturability Baldor commented during the public meeting that manufacturability was its primary concern and urged DOE to consider this factor. (Baldor, Public Meeting Transcript, No. 8.5 at p. 108) NEMA and the NEEA and the Northwest Power and Conservation Council reiterated this view in their respective comments submitted after the public meeting. (NEMA, No. 13 at p. 6; NEEA and NPCC, No. 9 at p. 4) DOE agrees with these comments and believes that through the application of the design limitations that follow in this section, DOE has maintained manufacturability in all motor designs it presents. b. Motor Size Motor size was a topic repeatedly addressed by interested parties. WEG and Emerson both commented that a result of energy conservation standards and increasing the efficiency of small electric motors could be that the motor length, diameter, or both will increase. (WEG, Public Meeting Transcript, No. 8.5 at p. 79; Emerson, Public Meeting Transcript, No. 8.5 at pp. 80-81) This concerned manufacturers because larger motors that result from higher efficiency standards may no longer fit into applications and OEMs would be forced to redesign their equipment. DOE recognizes that lower cost high efficiency motor designs can be produced either with larger diameters or a longer stack length. DOE constrained the motor diameter in its engineering analysis and simplified its analysis of space constrained applications by addressing space constraint issues in only the stack length dimension. DOE assumes that motor users whose applications are not space constrained in terms of diameter, would purchase a motor with the next higher frame size. At the public meeting, WEG stated that there is no set amount of additional stack height that can be added to a design without affecting end-use application because manufacturers often push those limits (WEG, Public Meeting Transcript, No. 8.5 at p. 129) NEMA suggested that DOE use a maximum stack length increase of less than 20 percent to account for the size restrictions that certain motor applications will have. (NEMA, No. 13 at p. 4) When establishing design limitations for the motor designs produced, DOE considered these comments. DOE decided that increasing the stack height of a motor can result in the motor no longer fitting into certain applications. Taking the concerns raised during the comment period into account, DOE utilized a maximum increase of stack height of no more than 20 percent from the baseline motor. However, DOE also believes that not all applications would be held to this 20 percent limitation. Because this design limitation has a drastic effect on the cost-efficiency relationship for small electric motors, and not all applications would be bound to that restriction, DOE provides a second set of engineering results for each product class analyzed. This second set of results has a much less stringent limit of increasing the stack height, of 100 percent. That is, DOE has two designs for each motor analyzed, at each efficiency level; one for the motor designs adhering to a maximum stack height increase of 20 percent and one adhering to 100 percent. However, for some of the lower efficiency levels, where a change in steel grade or an increase of stack height above 20 percent is not needed, both sets of designs are the same. DOE uses a weighted average of the MSPs from the 20 percent constrained designs and the 100 percent constrained designs based on the distribution of size-constrained applications that use small electric motors. c. Service Factor As discussed in section IV.A.1 service factor is a performance characteristic motor manufacturers must observe when designing their motors. In its comment, NEMA suggested that service factor be considered so that subsequent more efficient designs are still proper replacements of the baseline motor design. (NEMA, No. 13 at p. 7) DOE agrees with this comment and therefore, will maintain the service factor of the baseline motor design for each subsequent, more efficient design produced. d. Skew and Stay-Load Loss Another design limitation that was discussed at the public meeting was decreasing the degree of rotor skew. At the preliminary analyses public meeting, Emerson commented that if rotor skew is removed in a single-phase motor, the motor will not start. (Emerson, Public Meeting Transcript, No. 8.5 at p. 134) Regal-Beloit also had concerns about this design option and stated that reducing motor skew could cause the rotor to be noisy when running. (Regal-Beloit, Public Meeting Transcript, No. 8.5 at p. 135-36) DOE agrees that removing all of the skew from a single-phase motor will prevent it from starting. DOE also agrees that too much reduction of skew could cause the motor to become noisy. However, DOE does believe that reducing the degree of skew could provide efficiency gains depending upon the characteristics of the baseline model. DOE understands that this design option is subjective and relies heavily on the baseline motor design and experience of the motor design engineer. DOE did not use this design option for the motors analyzed in the engineering analysis because the skew of the baseline model was optimized. However DOE did not eliminate it as a design option prior to purchasing and tearing down its baseline motors. Additionally, Baldor said that changing skew will affect the stray-load losses in a motor. As mentioned DOE did not implement this design option, but did assume 1.0 percent for the value of stray-load loss. Baldor recommended that instead of assuming 1.0 percent, DOE should assume 1.8 percent because that is recommended in the IEEE standard. (Baldor, Public Meeting Transcript, No. 8.5 at p. 176) After examining the IEEE standard, DOE agrees with Baldor and has assumed 1.8 percent for the amount of stray-load loss in its motor designs. e. Air Gap The air gap between the rotor and stator was another topic discussed at the preliminary analyses public meeting and DOE received two pertinent comments. As discussed in the screening analysis, Baldor stated that reducing the air gap between the rotor and stator could have negative effects on efficiency. (Baldor, Public Meeting Transcript, No. 8.5 at p. 119) NEMA added that although reducing the air gap could improve small electric motor efficiency, it recommended that DOE not decrease the air gap in its designs to less than 12.5 thousandths of an inch because smaller air gaps could be problematic causing rotor and stator contact, especially as the motors get longer. (NEMA, No. 13, pp. 3, 5) After careful consideration of these comments, DOE agrees that decreasing the air gap between the stator and rotor down to 12.5 thousandths of an inch is a viable design option. Reducing the gap below that amount would increase the risk of creating potential performance and reliability issues that could arise with contact between the rotor and stator as well introduce manufacturability concerns regarding the ability of manufacturers to build motors with these significantly tighter tolerances. Therefore, DOE set one of its design limitations as maintaining at least 12.5 thousandths of inch for an air gap. f. Power Factor The rated power factor of a motor was an issue that was raised at the preliminary analyses public meeting. Baldor commented that the power factors of some designs in the preliminary analyses engineering analysis were extremely low and that such power factors would result in line losses that can negate gains in motor efficiency. (Baldor, Public Meeting Transcript, No. 8.5 at p. 174) NEMA followed up this comment suggesting that a minimum power factor needs to be established as a design limitation. (NEMA, No. 13 at p. 6) PG&E, SCE, SCGC, and SDGE reiterated these sentiments and suggested that a power factor of 75 percent should be maintained for all designs. (Joint Comment, No. 12 at p. 3) DOE understands that sacrificing power factor to obtain gains in efficiency is counterproductive because of the negative effects on line efficiency. Therefore DOE agrees that power factor must be considered when designing more efficient small electric motors. However, DOE does not believe that it is necessary to maintain a power factor of 75 percent for all designs. Instead, DOE has opted to maintain or increase the power factor of the baseline motor for each more efficient design and therefore does not negate any gains in efficiency. g. Speed DOE also received comment about the rated speed of its designs during the preliminary analyses public meeting. Baldor commented that DOE should monitor the trend of full-load speed as motor designs become more efficient and DOE should try to maintain the speed of the baseline as much as possible. (Baldor, Public Meeting Transcript, No. 8.5 at pp. 177-78) NEMA reaffirmed this position and stated that to maintain utility for some applications, for example a fan or pump, as efficiency is increased from design to design, full-load speed must be maintained (NEMA, No. 13 at pp. 6-7) DOE consulted with its own technical expert when setting a design limitation for full-load speed. DOE found that a decrease in full-load speed could have a negative impact on the utility of the motor design considered a replacement of the baseline. Additionally, DOE understands that speed is directly related to the I 2 R losses 12 found in a motor and by maintaining it, those losses are kept reasonable. Subsequently, by not increasing I 2 R losses, it is easier to increase the overall efficiency of the motor. Therefore, DOE agreed with the comments and decided that each design created by its subcontractor should maintain or increase the full-load speed of the baseline motor that was tested and modeled. 12 I 2 R losses stem from the current flow through the copper windings in the stator and conductor bars in the rotor. These losses are manifested as waste heat, which can shorten the service life of a motor. h. Thermal Performance After the preliminary analyses public meeting, NEMA suggested that DOE complete a thermal analysis and urged DOE to examine rotor temperature during operation. (NEMA, No. 13 at p. 8) DOE carefully considered this comment for the NOPR phase of this rulemaking. DOE decided to create a baseline design modeled after a small electric motor manufactured and sold on the market today. DOE purchased a baseline motor for each of the product classes analyzed in the engineering analysis. This motor was tested according to the corresponding IEEE test procedure and the rotor squirrel-cage temperature was monitored using thermocouples. DOE believes that by maintaining speed and increasing efficiency, the thermal integrity of the baseline motor will be maintained for each subsequent design of increased efficiency. By maintaining the baseline speed the rotor resistance is not increased and by increasing efficiency there is less heat that must be dissipated in the motor. DOE believes the thermal integrity of each motor design produced for this rulemaking's analysis is preserved as a result these factors. i. Slot Fill DOE received comments on the percentages of slot fill used in the designs presented for the preliminary analyses public meeting. The maximum level of slot fill DOE allowed in the preliminary engineering analysis was 75 percent. NEMA stated that a more typical limit of slot fill is 65 percent. (NEMA, No. 13 at p. 3) Emerson stated that manufacturers could surpass current limits on slot fill, but this would require a hand winding technique by individual workers instead of using automated winding machinery. (Emerson, Public Meeting Transcript, No. 8.5 at p. 130) Lastly, NEMA also recommended that DOE use a minimum slot fill. (NEMA, No. 13 at p. 8) DOE agrees that the level of slot fill is bound by a minimum and a maximum. DOE understands that a minimum slot fill is necessary in order for a motor to work. After consultation with technical experts DOE decided that a minimum slot fill of 50 percent should be maintained for all designs. DOE also agrees with the comments that a maximum level of slot fill is necessary and that that level should be 65 percent. Although it is possible to exceed this slot fill percentage and get closer to 75 percent, DOE found that this would take uncommon techniques that could inhibit mass production. j. Current and Torque Characteristics NEMA discussed in its written comments the performance characteristics that should be met for all motor designs produced by DOE for its analysis. These performance specifications include a minimum locked-rotor torque, a maximum locked-rotor current, a minimum breakdown torque, and a maximum no-load current. NEMA pointed out that MG1-1987 does not establish locked-rotor torque standards for polyphase motors, but it made no suggestion of what alternative should be used. NEMA also pointed out that MG1-1987 does not require a maximum locked-rotor current for small polyphase motors, but suggested that DOE use the standards for medium motors of corresponding horsepower, which are shown in MG 1-12.35. (NEMA, No. 13 at p. 6) Breakdown torque was another motor performance characteristic for which NEMA directed DOE to specific sections of MG1-1987 for both single and polyphase motors. (NEMA, No. 13 at p. 6) Finally, NEMA discussed no-load characteristics in their comment. While they made no suggestions for single-phase motors, NEMA believed that an average no-load current for polyphase small electric motors should be 25-35 percent of the rated-load current. (NEMA, No. 13 at p. 7) DOE appreciates NEMA's comments clarifying the performance specifications set forth by NEMA MG1-1987 for general-purpose small electric motors. DOE agrees with NEMA that any motor design produced should meet the specifications shown in MG1-1987. That is, for single-phase motors all designs should meet the locked-rotor torque shown in MG1-12.32.2, the locked-rotor current shown in MG1-12.33.2, and the breakdown torque shown in MG1-12.32.1. For polyphase motors, the breakdown torque should be in the range shown in MG1-12.37. DOE agrees that the locked-rotor current specifications for medium polyphase motors are a fair gauge, and therefore design limitation for small polyphase motors of corresponding horsepower ratings because of the similarities in design and performance. For the performance requirements not specified in NEMA MG1-1987, DOE believes that the best design limitation is to meet or exceed the performance of the baseline motor used for each product class analyzed because this prevents over-restricting the design. 6. Scaling Methodology As has been discussed in sections IV.C.2 and IV.C.4, DOE only analyzed three of the 72 product classes defined for small electric motors. Therefore, DOE needed to scale the results for these three product classes to the other 69. DOE presented an approach for scaling at the preliminary analyses public meeting. The first step in the previous scaling methodology was translating efficiency standards for medium motors into motor losses. DOE used two equations to obtain motor losses. DOE then examined these data sets to find a mathematical relationship explaining the change of motor losses relative to changes in horsepower and number of poles for medium motors. Finally, DOE assumed the relationships found in medium motors could be extrapolated to describe how losses, and thus efficiency, would scale for small electric motors. DOE received comments on the scaling methodology that was presented at the preliminary analyses public meeting. Baldor stated that using medium motor efficiency standards may not be accurate because medium motors are manufactured in three-digit frame sizes, and thus, the relationships found in medium motors may not be accurate for small electric motors with two-digit frames. (Baldor, Public Meeting Transcript, No. 8.5 at p. 191) Additionally, NEMA noted that for medium motor efficiency standards, frame size changes with each change in horsepower. This is not the case for small electric motors where frame sizes are used for a range of horsepower ratings, and in some instances overlap. Therefore, NEMA said medium motors data are not applicable to small electric motors and should not be used. (NEMA, No. 13 at p. 10) DOE appreciates these comments and considered them when reevaluating scaling relationships for small electric motors in the NOPR. Because there are no current standards for small electric motors, efficiency data are not as widely accessible for them. However, DOE did examine catalog efficiency data for small electric motors to determine if the relationships gleaned [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3AE9-27914. Public record. Not legal advice.