[Federal Register Volume 82, Number 11 (Wednesday, January 18, 2017)]
[Rules and Regulations]
[Pages 5650-5743]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-31666]
[[Page 5649]]
Vol. 82
Wednesday,
No. 11
January 18, 2017
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for
Dedicated-Purpose Pool Pumps; Direct Final Rule
Federal Register / Vol. 82 , No. 11 / Wednesday, January 18, 2017 /
Rules and Regulations
[[Page 5650]]
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DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket Number EERE-2015-BT-STD-0008]
RIN 1904-AD52
Energy Conservation Program: Energy Conservation Standards for
Dedicated-Purpose Pool Pumps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Direct final rule.
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SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, sets forth a variety of provisions designed to improve energy
efficiency. Part C of Title III establishes the ``Energy Conservation
Program for Certain Industrial Equipment.'' The covered equipment
includes pumps. In this direct final rule, DOE is adopting new energy
conservation standards for dedicated-purpose pool pumps. It has
determined that the energy conservation standards for these products
would result in significant conservation of energy, and are
technologically feasible and economically justified.
DATES: The effective date of this rule is May 18, 2017 unless adverse
comment is received by May 8, 2017. If adverse comments are received
that DOE determines may provide a reasonable basis for withdrawal of
the direct final rule, a timely withdrawal of this rule will be
published in the Federal Register. If no such adverse comments are
received, compliance with the standards established for dedicated-
purpose pool pumps in this direct final rule is required on and after
July 19, 2021.
ADDRESSES: The docket for this rulemaking, which includes Federal
Register notices, public meeting attendee lists and transcripts,
comments, and other supporting documents/materials, is available for
review at www.regulations.gov. All documents in the docket are listed
in the www.regulations.gov index. However, not all documents listed in
the index may be publicly available, such as information that is exempt
from public disclosure.
A link to the docket Web page can be found at https://www.regulations.gov/docket?D=EERE-2015-BT-STD-0008. The docket Web page
contains simple instructions on how to access all documents, including
public comments, in the docket.
FOR FURTHER INFORMATION CONTACT:
Mr. John Cymbalsky, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Office, EE-5B,
1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone:
(202) 586-9507. Email: [email protected].
Ms. Johanna Jochum, U.S. Department of Energy, Office of the
General Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC
20585-0121. Telephone: (202) 287-6307. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Direct Final Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
III. General Discussion
A. Consensus Agreement
B. Compliance Date
C. Test Procedure
D. Scope
1. Performance-Based Energy Conservation Standards
2. Prescriptive Energy Conservation Standards
3. Dedicated-Purpose Pool Pump Motor
E. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
F. Energy Savings
1. Determination of Savings
G. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC
and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Equipment
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Significance of Savings
3. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Equipment Classes and Distinguishing Features
a. Strainer or Filtration Accessory
b. Self-Priming Ability
c. Pump Capacity (Flow, Head, and Power)
d. Rotational Speed
e. End User Safety
f. List of Proposed Equipment Classes
2. Manufacturers and Industry Structure
3. Existing Efficiency Programs
a. U.S. State-Level Programs
b. Voluntary Standards
4. Shipments Information
5. Market and Industry Trends
a. Equipment Efficiency
b. Pump Sizing
6. Technology Options
a. Improved Motor Efficiency
b. Ability To Operate at Reduced Speeds
c. Improved Hydraulic Design
d. Pool Pump Timer
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. Summary of Data Sources
a. Pool Pump Performance Database
b. Manufacturer Production Cost Dataset
2. Representative Equipment
a. Self-Priming Pool Filter Pumps
b. Non-Self-Priming Pool Filter Pumps
c. Pressure Cleaner Booster Pumps
d. Waterfall Pumps
e. Integral Sand and Cartridge Filter Pool Pump
f. Summary of Representative Units
3. Baseline Configuration and Performance
4. Efficiency Levels
a. Design Option Applicability and Ordering
b. Summary of Available Motor Efficiencies
c. Summary of Available Hydraulic Efficiencies
d. Representative Unit Performance at Each Efficiency Level
e. Efficiency Level Structure for All Pump Capacities
5. Manufacturer Production Costs
a. Principal Drivers of DPPP Manufacturing Costs
b. Pool Filter Pump and Pressure Cleaner Booster Pump Motor
Costs
c. Pool Filter Pump and Pressure Cleaner Booster Pump Non-Motor
Costs
d. Cost Analysis of Integral Filter Pool Pump Equipment Classes
e. Cost-Efficiency Results
f. MPC Cost Components
6. Other Analytical Outputs
7. Manufacturer Selling Price
D. Markups Analysis
1. Dedicated-Purpose Pool Pump Markups
2. Replacement Motor Markups
E. Energy Use Analysis
1. Dedicated-Purpose Pool Pump Consumer Samples
2. Energy Use Estimation
a. Power Inputs
b. Operating Hours
c. Annual Days of Operation
F. Life-Cycle Cost and Payback Period Analyses
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Repair and Maintenance Costs
6. Equipment Lifetime
7. Discount Rates
8. Energy Efficiency Distribution in the No-Standards Case
9. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. Equipment Efficiency Trends
2. National Energy Savings
3. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
[[Page 5651]]
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Forecasts
c. Product and Capital Conversion Costs
d. Markup Scenarios
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Current Approach
2. Social Cost of Methane and Nitrous Oxide
3. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Direct Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Dedicated-Purpose
Pool Pumps
2. Annualized Benefits and Costs of the Adopted Standards
VI. Other Prescriptive Requirements
VII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description of Reasons Why Action Is Being Considered
2. Objectives of, and Legal Basis for, the Rule
3. Description and Estimate of the Number of Small Entities
Affected
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participation
c. Dedicated-Purpose Pool Pump Industry Structure and Nature of
Competition
4. Description of Compliance Requirements
5. Duplication, Overlap, and Conflict With Other Rules and
Regulations
6. Significant Alternatives Considered and Steps Taken To
Minimize Significant Economic Impacts on Small Entities
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Information Quality
M. Congressional Notification
VIII. Approval of the Office of the Secretary
I. Synopsis of the Direct Final Rule
Title III of the Energy Policy and Conservation Act of 1975 (42
U.S.C. 6291, et seq; EPCA), sets forth a variety of provisions designed
to improve energy efficiency of appliances and commercial equipment.
Part C of Title III, which for editorial reasons was redesignated as
Part A-1 upon incorporation into the U.S. Code (42 U.S.C. 6311-6317),
establishes the ``Energy Conservation Program for Certain Industrial
Equipment.'' Covered industrial equipment includes pumps. (42 U.S.C.
6311(1)(H)) \1\ Pumps include dedicated-purpose pool pumps, the subject
of this document.
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\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Efficiency Improvement Act of 2015,
Public Law 114-11 (Apr. 30, 2015).
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The energy conservation standards for dedicated-purpose pool pumps
(also referred to as ``pool pumps'') established in this document
reflect the consensus of a negotiation among interested parties with a
broad cross-section of interests, including the manufacturers who
produce the subject equipment, environmental and energy-efficiency
advocacy organizations, and electric utility companies. A working group
representing these parties was established under the Appliance
Standards and Rulemaking Federal Advisory Committee (ASRAC) \2\ to
discuss and, if possible, reach consensus on proposed standards for
pool pump energy efficiency. On June 23, 2016, the dedicated-purpose
pool pumps (DPPP) Working Group successfully reached consensus on
recommended energy conservation standards for pool pumps. See section
III.A for further discussion of the Working Group and its
recommendations.
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\2\ In accordance with the Federal Advisory Committee Act and
the Negotiated Rulemaking Act (5 U.S.C. App.; 5 U.S.C. 561-570).
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After carefully considering the recommendations submitted by the
DPPP Working Group and adopted by ASRAC related to energy conservation
standards for pool pumps, DOE has determined that these recommendations
comprise a statement submitted by interested persons who represent
relevant points of view on this matter, and which, if compliant with
certain statutory requirements, could result in issuance of a direct
final rule.
Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that DOE determines is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A) and 6316(a))
Furthermore, the new or amended standard must result in significant
conservation of energy. (42 U.S.C. 6295(o)(3)(B) and 6316(a)).
In accordance with these and other statutory provisions discussed
in this document, DOE is adopting new energy conservation standards for
certain dedicated-purpose pool pumps. The adopted standards are shown
in Table I-1 and Table I-2. Standards for the equipment classes in
Table I-1 are performance based, expressed in terms of weighted energy
factor (WEF); standards in Table I-2 are prescriptive. These standards
apply to all equipment listed in Table I-1 and Table I-2 and
manufactured in or imported into the United States starting on July 19,
2021. DOE is not adopting standby or off-mode standards for this
equipment.
Table I-1--Performance-Based Energy Conservation Standards for Dedicated-Purpose Pool Pumps
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Equipment class
----------------------------------------------------------------------------------------- Minimum allowable WEF
Hydraulic horsepower ** score
Dedicated-purpose pool pump variety applicability * Motor phase
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Standard-Size Self-Priming Pool <2.5 hhp and >=0.711 Single................... WEF =-2.30 * ln (hhp)
Filter Pumps. hhp. + 6.59.
[[Page 5652]]
Small-Size Self-Priming Pool Filter hhp <0.711 hp.......... Single................... WEF = 5.55 for hhp
Pumps. <=0.13 hp,
-1.30 * ln (hhp) +
2.90 for hhp >0.13
hp.
Non-Self-Priming Pool Filter Pumps.. hhp <2.5 hp............ Any...................... WEF = 4.60 for hhp
<=0.13 hp,
-0.85 * ln (hhp) +
2.87 for hhp >0.13
hp.
Pressure Cleaner Booster Pumps...... Any.................... Any...................... WEF = 0.42.
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* All instances of hhp refer to rated hydraulic horsepower determined in accordance with the DOE test procedure
at 10 CFR 431.464 and applicable sampling plans.
** WEF is measured by kgal/kWh.
Table I-2--Prescriptive Energy Conservation Standards for Dedicated-Purpose Pool Pumps
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Equipment class
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Hydraulic horsepower Prescriptive standard
Dedicated-purpose pool pump variety applicability Motor phase
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Integral Sand Filter Pool Pump..... Any...................... Any...................... Must be distributed
in commerce with a
pool pump timer that
is either integral
to the pump or a
separate component
that is shipped with
the pump. *
Integral Cartridge Filter Pool Pump Any...................... Any...................... Must be distributed
in commerce with a
pool pump timer that
is either integral
to the pump or a
separate component
that is shipped with
the pump. *
All Dedicated-Purpose Pool Pumps Any...................... Any...................... The pump must be
Distributed in Commerce with shipped with freeze
Freeze Protection Controls. protection disabled
or with the
following default,
user-adjustable
settings:
The default
dry-bulb air
temperature setting
is no greater than
40 [deg]F;
The default
run time setting
shall be no greater
than 1 hour (before
the temperature is
rechecked); and
The default
motor speed shall
not be more than \1/
2\ of the maximum
available speed.
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* Pool pump timer means a pool pump control that automatically turns off a dedicated-purpose pool pump after a
run-time of no longer than 10 hours.
A. Benefits and Costs to Consumers \3\
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\3\ All monetary values in this document are expressed in 2015
dollars and, where appropriate, are discounted to 2016 unless
explicitly stated otherwise.
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Table I-3 presents DOE's evaluation of the economic impacts of the
adopted standards on consumers of pool pumps, as measured by the
average life-cycle cost (LCC) savings and the simple payback period
(PBP).\4\ The average LCC savings are positive for all equipment
classes, and the PBP is much less than the average lifetime of
dedicated-purpose pool pumps, which is estimated to range from 4 to 7
years, depending on equipment class (see section IV.F.6).
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\4\ The average LCC savings refer to consumers that are affected
by a standard are measured relative to the efficiency distribution
in the no-standards case, which depicts the market in the compliance
year in the absence of new or amended standards (see section
IV.H.2). The simple PBP, which is designed to compare specific
efficiency levels, is measured relative to the baseline model (see
section IV.C.3).
Table I-3--Impacts of Adopted Energy Conservation Standards on End Users
of Dedicated-Purpose Pool Pumps
------------------------------------------------------------------------
Average LCC
Equipment class savings Simple payback
(2015$) period (years)
------------------------------------------------------------------------
Standard-Size Self-Priming Pool Filter 2,140 0.7
Pump...................................
Small-Size Self-Priming Pool Filter Pump 295 0.8
Standard-Size Non-Self-Priming Pool 191 0.2
Filter Pump............................
Extra-Small Non-Self-Priming Pool Filter 36 0.9
Pump...................................
Pressure Cleaner Booster Pump........... 111 0.6
Integral Cartridge Filter Pool Pump..... 128 0.4
Integral Sand Filter Pool Pump.......... 73 0.5
------------------------------------------------------------------------
[[Page 5653]]
DOE's analysis of the impacts of the adopted standards on consumers
is described in section V.B.1 of this document.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the reference year through the end of
the analysis period 2016-2050. Using a real discount rate of 11.8
percent, DOE estimates that the INPV for manufacturers of dedicated-
purpose pool pumps in the case without standards is $212.8 million in
2015$. Under the new standards, DOE expects the change in INPV to range
from -21.8 percent to 3.3 percent, which is approximately -$46.3
million to $7.0 million. In order to bring equipment into compliance
with the new standards, DOE expects the industry to incur total
conversion costs of $35.6 million.
DOE's analysis of the impacts of the new standards on manufacturers
is described in section IV.J and section V.B.2 of this document.
C. National Benefits and Costs
DOE's analyses indicate that the adopted energy conservation
standards for dedicated-purpose pool pumps would save a significant
amount of energy. Relative to the case without new standards, the
lifetime energy savings for dedicated-purpose pool pumps purchased in
the 30-year period that begins in the anticipated year of compliance
with the standards (2021-2050), amount to 3.8 quadrillion British
thermal units (Btu), or quads.\5\ This represents an estimated savings
of 61 percent relative to the energy use of this equipment in the case
without standards (referred to as the ``no-standards case'').
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\5\ The quantity refers to full-fuel-cycle (FFC) energy savings.
FFC energy savings includes the energy consumed in extracting,
processing, and transporting primary fuels (i.e., coal, natural gas,
petroleum fuels), and, thus, presents a more complete picture of the
impacts of energy efficiency standards. For more information on the
FFC metric, see section IV.H.2.
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The cumulative net present value (NPV) of total consumer benefits
of the standards for dedicated-purpose pool pumps ranges from $11
billion (at a 7-percent discount rate) to $24 billion (at a 3-percent
discount rate). This NPV expresses the estimated total value of future
operating-cost savings minus the estimated increased equipment costs
for dedicated-purpose pool pumps purchased in 2021-2050.
In addition, the standards for dedicated-purpose pool pumps are
projected to yield significant environmental benefits. DOE estimates
that the standards would result in cumulative greenhouse gas emission
reductions (over the same period as for energy savings) of 202 million
metric tons (Mt \6\ of carbon dioxide (CO2), 147 thousand
tons of sulfur dioxide (SO2), 257 thousand tons of nitrogen
oxides (NOX), 968 thousand tons of methane (CH4),
3.0 thousand tons of nitrous oxide (N2O), and 0.50 tons of
mercury (Hg).\7\ The cumulative reduction in CO2 emissions
through 2030 amounts to 48 Mt, which is equivalent to the emissions
resulting from the annual electricity use of 7.1 million homes.
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\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\7\ DOE calculated emissions reductions relative to the no-
standards-case, which reflects key assumptions in the Annual Energy
Outlook 2016 (AEO2016). AEO2016 generally represents current
legislation and environmental regulations for which implementing
regulations were available as of the end of February 2016.
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The value of the CO2 reduction is calculated using a
range of values per metric ton (t) of CO2 (otherwise known
as the ``Social Cost of Carbon Dioxide,'' or SC-CO2)
developed by a Federal interagency working group.\8\ The derivation of
the SC-CO2 values is discussed in section IV.L. Using
discount rates appropriate for each set of SC-CO2 values,
DOE estimates that the present value of the CO2 emissions
reduction is between $1.5 billion and $21 billion. Using the central
SCC case represented by $40.6/metric ton (t) in 2015 and a discount
rate of 3-percent produces a value of $6.8 billion.
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\8\ United States Government--Interagency Working Group on
Social Cost of Carbon. Technical Support Document: Technical Update
of the Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. May 2013. Revised July 2015. Available at
www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf.
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DOE also calculated the value of the reduction in emissions of the
non-CO2 greenhouse gases, methane and nitrous oxide, using
values for the social cost of methane (SC-CH4) and the
social cost of nitrous oxide (SC-N2O) recently developed by
the interagency working group.\9\ See section IV.L.2 for description of
the methodology and the values used for DOE's analysis. The estimated
present value of the methane emissions reduction is between $0.32
billion and $2.6 billion, with a value of $0.99billion using the
central SC-CH4 case, and the estimated present value of the
N2O emissions reduction is between $0.008 billion and $0.09
billion, with a value of $0.03 billion using the central SC-
N2O case.
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\9\ United States Government--Interagency Working Group on
Social Cost of Greenhouse Gases. Addendum to Technical Support
Document on Social Cost of Carbon for Regulatory Impact Analysis
under Executive Order 12866: Application of the Methodology to
Estimate the Social Cost of Methane and the Social Cost of Nitrous
Oxide. August 2016. https://www.whitehouse.gov/sites/default/files/omb/inforeg/august_2016_sc_ch4_sc_n2o_addendum_final_8_26_16.pdf.
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DOE also estimates the present value of the NOX
emissions reduction to be $0.21 billion using a 7-percent discount
rate, and $0.48 billion using a 3-percent discount rate.\10\ DOE is
still investigating appropriate valuation of the reduction in other
emissions, and therefore did not include any such values in the
analysis of this direct final rule.
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\10\ DOE estimated the monetized value of NOX
emissions reductions associated with electricity savings using
benefit per ton estimates from the Regulatory Impact Analysis for
the Clean Power Plan Final Rule, published in August 2015 by EPA's
Office of Air Quality Planning and Standards. Available at
www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis. See section IV.L for further discussion. The U.S.
Supreme Court has stayed the rule implementing the Clean Power Plan
until the current litigation against it concludes. Chamber of
Commerce, et al. v. EPA, et al., Order in Pending Case, 577 U.S. ___
(2016). However, the benefit-per-ton estimates established in the
Regulatory Impact Analysis for the Clean Power Plan are based on
scientific studies that remain valid irrespective of the legal
status of the Clean Power Plan. DOE is primarily using a national
benefit-per-ton estimate for NOX emitted from the
Electricity Generating Unit sector based on an estimate of premature
mortality derived from the ACS study (Krewski et al. 2009). If the
benefit-per-ton estimates were based on the Six Cities study
(Lepuele et al. 2011), the values would be nearly two-and-a-half
times larger.
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Table I-4 summarizes the economic benefits and costs expected to
result from the adopted standards for dedicated-purpose pool pumps.
[[Page 5654]]
Table I-4--Summary of Economic Benefits and Costs of Adopted Energy
Conservation Standards for Dedicated-Purpose Pool Pumps ***
------------------------------------------------------------------------
Present value
Category (billion Discount rate
2015$) (%)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Consumer Operating Cost Savings......... 13 7
26 3
GHG Reduction (using avg. social costs 1.9 5
at 5% discount rate) *.................
GHG Reduction (using avg. social costs 7.8 3
at 3% discount rate) *.................
GHG Reduction (using avg. social costs 12 2.5
at 2.5% discount rate) *...............
GHG Reduction (using 95th percentile 23 3
social costs at 3% discount rate) *....
NOX Reduction **........................ 0.21 7
0.48 3
Total Benefits [dagger]................. 21 7
35 3
------------------------------------------------------------------------
Costs
------------------------------------------------------------------------
Consumer Incremental Installed Costs.... 1.3 7
2.6 3
------------------------------------------------------------------------
Total Net Benefits
------------------------------------------------------------------------
Including GHG and NOX Reduction 19 7
Monetized Value........................ 32 3
------------------------------------------------------------------------
*** This table presents the costs and benefits associated with pool
pumps shipped in 2021-2050. These results include benefits to
consumers which accrue after 2050 from the equipment purchased in 2021-
2050. The incremental installed costs include incremental equipment
cost as well as installation costs. The costs account for the
incremental variable and fixed costs incurred by manufacturers due to
the proposed standards, some of which may be incurred in preparation
for the rule. The CO2 reduction benefits are global benefits due to
actions that occur domestically.
* The interagency group selected four sets of SC-CO2 SC-CH4, and SC-N2O
values for use in regulatory analyses. Three sets of values are based
on the average social costs from the integrated assessment models, at
discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth
set, which represents the 95th percentile of the social cost
distributions calculated using a 3-percent discount rate, is included
to represent higher-than-expected impacts from climate change further
out in the tails of the social cost distributions. The social cost
values are emission year specific. See section IV.L.1 for more
details.
** DOE estimated the monetized value of NOX emissions reductions
associated with electricity savings using benefit per ton estimates
from the Regulatory Impact Analysis for the Clean Power Plan Final
Rule, published in August 2015 by EPA's Office of Air Quality Planning
and Standards. (Available at www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See section IV.L.3 for
further discussion. DOE is primarily using a national benefit-per-ton
estimate for NOX emitted from the electricity generating unit sector
based on an estimate of premature mortality derived from the ACS study
(Krewski et al. 2009). If the benefit-per-ton estimates were based on
the Six Cities study (Lepuele et al. 2011), the values would be nearly
two-and-a-half times larger.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are
presented using only the average social costs with 3-percent discount
rate.
The benefits and costs of the adopted standards for dedicated-
purpose pool pumps sold between 2021-2050 can also be expressed in
terms of annualized values. The monetary values for the total
annualized net benefits are (1) the reduced consumer operating costs,
minus (2) the increases in equipment purchase prices and installation
costs, plus (3) the value of the benefits of CO2 and
NOX emission reductions, all annualized.\11\
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\11\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2016, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2020 or 2030), and then discounted the present value from
each year to 2016. The calculation uses discount rates of 3 and 7
percent for all costs and benefits except for the value of
CO2 reductions, for which DOE used case-specific discount
rates, as shown in Table . Using the present value, DOE then
calculated the fixed annual payment over a 30-year period, starting
in the compliance year, which yields the same present value.
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The national operating cost savings are domestic private U.S.
consumer monetary savings that occur as a result of purchasing the
covered equipment and are measured for the lifetime of dedicated-
purpose pool pumps shipped in 2021-2050. The benefits associated with
reduced CO2 emissions achieved as a result of the adopted
standards are also calculated based on the lifetime of dedicated-
purpose pool pumps shipped in 2021-2050. Because CO2
emissions have a very long residence time in the atmosphere, the SC-
CO2 values for emissions in future years reflect
CO2-emissions impacts that continue through 2300. The
CO2 reduction is a benefit that accrues globally. DOE
maintains that consideration of global benefits is appropriate because
of the global nature of the climate change problem.
Estimates of annualized benefits and costs of the adopted standards
are shown in Table I-5. The results under the primary estimate are as
follows. Using a 7-percent discount rate for benefits and costs other
than GHG reduction (for which DOE used average social costs with a 3-
percent discount rate),\12\ the estimated cost of the standards in this
rule is $138 million per year in increased equipment costs, while the
estimated annual benefits are $1.3 billion in reduced equipment
operating costs, $449 million in GHG reductions, and $22 million in
reduced NOX emissions. In this case, the net benefit amounts
to $1.7 billion per year. Using a 3-percent discount rate for all
benefits and costs, the estimated cost of the standards is $149 million
per year in increased equipment costs, while the estimated annual
benefits are $1.5 billion in reduced operating costs, $449 million in
GHG reductions, and $27 million in reduced NOX emissions. In
this case, the net benefit amounts to $1.8 billion per year.
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\12\ DOE used average social costs with a 3-percent discount
rate because these values are considered as the ``central''
estimates by the interagency group.
[[Page 5655]]
Table I-5--Annualized Benefits and Costs of Adopted Standards for Dedicated-Purpose Pool Pumps *
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Discount rate (%) Primary estimate Low-net-benefits estimate High-net-benefits estimate
--------------------------------------------------------------------------------------------------------------------------------------------------------
Million 2015$/year
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings... 7............................... 1,340..................... 1,221..................... 1,467.
3............................... 1,516..................... 1,367..................... 1,678.
GHG Reduction (using avg. social 5............................... 147....................... 129....................... 164.
costs at 5% discount rate) **.
GHG Reduction (using avg. social 3............................... 449....................... 392....................... 504.
costs at 3% discount rate) **.
GHG Reduction (using avg. social 2.5............................. 642....................... 560....................... 721.
costs at 2.5% discount rate) **.
GHG Reduction (using 95th 3............................... 1,346..................... 1,175..................... 1,510.
percentile social costs at 3%
discount rate) **.
NOX Reduction [dagger]............ 7............................... 22........................ 20........................ 55.
3............................... 27........................ 24........................ 70.
Total Benefits [Dagger]........... 7% plus GHG range............... 1,509 to 2,708............ 1,369 to 2,416............ 1,686 to 3,032.
7%.............................. 1,811..................... 1,633..................... 2,026.
3% plus GHG range............... 1,690 to 2,890............ 1,520 to 2,566............ 1,912 to 3,258.
3............................... 1,993..................... 1,783..................... 2,252.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Incremental Product Costs 7............................... 138....................... 124....................... 151.
3............................... 149....................... 133....................... 164.
Manufacturer Conversion Costs 7............................... 3......................... 3......................... 3.
[dagger][dagger]. 3............................... 2......................... 2......................... 2.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total [Dagger].................... 7% plus GHG range............... 1,371 to 2,570............ 1,245 to 2,292............ 1,535 to 2,881.
7%.............................. 1,673..................... 1,509..................... 1,875.
3 plus GHG range................ 1,542 to 2,741............ 1,387 to 2,433............ 1,748 to 3,094.
3............................... 1,844..................... 1,651..................... 2,088.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with pool pumps shipped in 2021-2050. These results include benefits to consumers
which accrue after 2050 from the pool pumps purchased from 2021-2050. The incremental equipment costs include incremental equipment cost as well as
installation costs. The costs account for the incremental variable and fixed costs incurred by manufacturers due to the adopted standards, some of
which may be incurred in preparation for the rule. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices
and real GDP from the AEO2016 No-CPP case, a Low Economic Growth case, and a High Economic Growth case, respectively. In addition, incremental product
costs reflect the default price trend in the Primary Estimate, a high price trend in the Low Benefits Estimate, and a low price trend in the High
Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1. The benefits and costs are based on equipment
efficiency distributions as described in sections IV.F.8 and IV.H.1. Purchases of higher efficiency equipment are a result of many different factors
unique to each consumer including past purchases, expected usage, and others. For each consumer, all other factors being the same, it would be
anticipated that higher efficiency purchases in the no-new-standards case may correlate positively with higher energy prices. To the extent that this
occurs, it would be expected to result in some lowering of the consumer operating cost savings from those calculated in this rule. Note that the
Benefits and Costs may not sum to the Net Benefits due to rounding.
** The interagency group selected four sets of SC-CO2 SC-CH4, and SC-N2O values for use in regulatory analyses. Three sets of values are based on the
average social costs from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth set, which
represents the 95th percentile of the social cost distributions calculated using a 3-percent discount rate, is included to represent higher-than-
expected impacts from climate change further out in the tails of the social cost distributions. The social cost values are emission year specific. The
GHG reduction benefits are global benefits due to actions that occur nationally. See section IV.L for more details.
[dagger] DOE estimated the monetized value of NOX emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule, published in August 2015 by EPA's Office of Air Quality Planning and Standards.
(Available at www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See section IV.L.3 for further discussion. For the
Primary Estimate and Low Net Benefits Estimate, DOE used national benefit-per-ton estimates for NOX emitted from the Electric Generating Unit sector
based on an estimate of premature mortality derived from the ACS study (Krewski et al. 2009). For the High Net Benefits Estimate, the benefit-per-ton
estimates were based on the Six Cities study (Lepuele et al. 2011); these are nearly two-and-a-half times larger than those from the ACS study.
[Dagger] Total Benefits for both the 3-percent and 7-percent cases are presented using the average social costs with 3-percent discount rate. In the
rows labeled ``7% plus GHG range'' and ``3% plus GHG range,'' the operating cost and NOX benefits are calculated using the labeled discount rate, and
those values are added to the full range of social cost values.
[dagger][dagger] Manufacturers are estimated to incur $35.6 million in conversion costs between 2017 and 2020.
DOE's analysis of the national impacts of the adopted standards is
described in sections IV.H, IV.K, and IV.L of this document.
D. Conclusion
Based on the analyses in this direct final rule, DOE found the
benefits to the nation of the standards (energy savings, consumer LCC
savings, positive NPV of consumer benefit, and emission reductions)
outweigh the burdens (loss of INPV and LCC increases for some end users
of this equipment). DOE has concluded that the standards in this direct
final rule represent the maximum improvement in energy efficiency that
is technologically feasible and economically justified, and would
result in significant conservation of energy.
II. Introduction
The following sections briefly discuss the statutory authority
underlying this
[[Page 5656]]
direct final rule, as well as some of the relevant historical
background related to the establishment of standards for dedicated-
purpose pool pumps.
A. Authority
Title III, Part C \13\ of the Energy Policy and Conservation Act of
1975 (EPCA), (42 U.S.C. 6311-6317, as codified) established the Energy
Conservation Program for Certain Industrial Equipment, a program
covering certain industrial equipment.\14\ ``Pumps'' are listed as a
type of covered industrial equipment. (42 U.S.C. 6311(1)(A))
---------------------------------------------------------------------------
\13\ For editorial reasons, upon codification in the U.S. Code,
part C was re-designated part A-1.
\14\ All references to EPCA refer to the statute as amended
through the Energy Efficiency Improvement Act of 2015, Public Law
114-11 (April 30, 2015).
---------------------------------------------------------------------------
While pumps are listed as a type of covered equipment, EPCA does
not define the term ``pump.'' To address this, in January 2016, DOE
published a test procedure final rule (January 2016 general pumps test
procedure final rule) that established a definition for the term
``pump.'' 81 FR 4086, 4147 (January 25, 2016). In the December 2016
DPPP test procedure final rule (``test procedure final rule''),\15\ DOE
noted the applicability of the definition of ``pump'' and associated
terms to dedicated-purpose pool pumps.
---------------------------------------------------------------------------
\15\ See https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=41.
---------------------------------------------------------------------------
Pursuant to EPCA, DOE's energy conservation program for covered
equipment consists essentially of four parts: (1) Testing, (2)
labeling, (3) the establishment of Federal energy conservation
standards, and (4) certification and enforcement procedures. Subject to
certain criteria and conditions, DOE is required to develop test
procedures to measure the energy efficiency, energy use, or estimated
annual operating cost of covered equipment. (42 U.S.C. 6295(o)(3)(A)
and 6316(a)) Manufacturers of covered equipment must use the prescribed
DOE test procedure as the basis for certifying to DOE that their
equipment complies with the applicable energy conservation standards
adopted under EPCA, and when making representations to the public
regarding their energy use or efficiency. (42 U.S.C. 6314(d))
Similarly, DOE must use these test procedures to determine whether the
equipment complies with standards adopted pursuant to EPCA. Id. The DOE
test procedures for dedicated-purpose pool pumps appear at title 10 of
the Code of Federal Regulations (CFR) part 431, subpart Y, appendix B.
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered equipment, including dedicated-purpose
pool pumps. Any new or amended standard for covered equipment must be
designed to achieve the maximum improvement in energy efficiency that
the Secretary of Energy determines is technologically feasible and
economically justified. (42 U.S.C. 6313(a)(6)(C), 6295(o), and 6316(a))
Furthermore, DOE may not adopt any standard that would not result in
the significant conservation of energy. (42 U.S.C. 6295(o)(3)) and
6316(a)) Moreover, DOE may not prescribe a standard (1) for certain
equipment, including dedicated-purpose pool pumps, if no test procedure
has been established for the product, or (2) if DOE determines by rule
that the standard is not technologically feasible or economically
justified. (42 U.S.C. 6295(o) and 6316(a)) In deciding whether a
proposed standard is economically justified, DOE must determine whether
the benefits of the standard exceed its burdens. DOE must make this
determination after receiving comments on the proposed standard, and by
considering, to the greatest extent practicable, the following seven
statutory factors:
1. The economic impact of the standard on manufacturers and
consumers of the equipment subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered equipment in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered equipment that are likely to result from the standard;
3. The total projected amount of energy (or as applicable, water)
savings likely to result directly from the standard;
4. Any lessening of the utility or the performance of the covered
equipment likely to result from 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
standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)) and 6316(a))
Further, EPCA establishes a rebuttable presumption that a standard
is economically justified if the Secretary finds that the additional
cost to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii)) and 6316(a))
EPCA also contains what is known as an ``anti-backsliding''
provision, which prevents the Secretary from prescribing any amended
standard that either increases the maximum allowable energy use or
decreases the minimum required energy efficiency of a covered product.
(42 U.S.C. 6295(o)(1)) and 6316(a)) Also, the Secretary may not
prescribe an amended or new standard if interested persons have
established by a preponderance of the evidence that the standard is
likely to result in the unavailability in the United States in any
covered product type (or class) of performance characteristics
(including reliability), features, sizes, capacities, and volumes that
are substantially the same as those generally available in the United
States. (42 U.S.C. 6295(o)(4) and 6316(a))
Additionally, EPCA specifies requirements when promulgating an
energy conservation standard for a covered product that has two or more
subcategories. DOE must specify a different standard level for a type
or class of products that has the same function or intended use if DOE
determines that equipment within such group (a) consumes a different
kind of energy from that consumed by other covered equipment within
such type (or class); or (b) has a capacity or other performance-
related feature that other equipment within such type (or class) do not
have and such feature justifies a higher or lower standard. (42 U.S.C.
6295(q)(1) and 6316(a)) In determining whether a performance-related
feature justifies a different standard for a group of equipment, DOE
must consider such factors as the utility to the consumer of such a
feature and other factors DOE deems appropriate. Id. Any rule
prescribing such a standard must include an explanation of the basis on
which such higher or lower level was established. (42 U.S.C. 6295(q)(2)
and 6316(a))
Federal energy conservation requirements generally supersede State
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c) and 6316(a)) DOE may, however,
grant waivers of Federal preemption for particular State laws or
regulations, in accordance with the procedures and other provisions set
forth under 42 U.S.C. 6297(d).
With particular regard to direct final rules, the Energy
Independence and Security Act of 2007 (EISA 2007), Public
[[Page 5657]]
Law 110-140 (December 19, 2007), amended EPCA, in relevant part, to
grant DOE authority to issue a type of final rule (i.e., a ``direct
final rule'') establishing an energy conservation standard for a
product or equipment (including dedicated-purpose pool pumps) on
receipt of a statement submitted jointly by interested persons that are
fairly representative of relevant points of view (including
representatives of manufacturers of covered equipment, States, and
efficiency advocates), as determined by the Secretary. (42 U.S.C.
6295(p)(4)(A)) and 6316(a)) That statement must contain recommendations
with respect to an energy or water conservation standard that are in
accordance with the provisions of 42 U.S.C. 6295(o). (42 U.S.C.
6295(p)(4)(A)(i)) A notice of proposed rulemaking (NOPR) that proposes
an identical energy efficiency standard must be published
simultaneously with the direct final rule and a public comment period
of at least 110 days provided. (42 U.S.C. 6295(p)(4)(A)-(B)) Not later
than 120 days after issuance of the direct final rule, if DOE receives
one or more adverse comments or an alternative joint recommendation
relating to the direct final rule, the Secretary must determine whether
the comments or alternative joint recommendation may provide a
reasonable basis for withdrawal under 42 U.S.C. 6295(o) or other
applicable law. (42 U.S.C. 6295(p)(4)(C)(i)) If the Secretary makes
such a determination, DOE must withdraw the direct final rule and
proceed with the simultaneously published NOPR, and publish in the
Federal Register the reason why the direct final rule was withdrawn.
(42 U.S.C. 6295(p)(4)(C)(ii))
B. Background
Currently, no Federal energy conservation standards exist for
dedicated-purpose pool pumps. DOE excluded this category of pumps from
its recent consensus-based energy conservation standard final rule for
general pumps. 81 FR 4368 (January 26, 2016). The general pumps final
rule, which was also the product of a pumps working group that had been
created through the ASRAC, examined a variety of pump categories. While
dedicated-purpose pool pumps were one of the pump categories that were
considered during the working group's discussions, the working group
ultimately recommended that DOE initiate a separate rulemaking for
dedicated-purpose pool pumps. (Docket No. EERE-2013-BT-NOC-0039, No.
0092 at p. 2)
DOE began the separate rulemaking for dedicated-purpose pool pumps
on May 8, 2015, when it issued a Request for Information (RFI) (May
2015 DPPP RFI). 80 FR 26475. The May 2015 DPPP RFI presented
information and requested public comment about definitions, metrics,
test procedures, equipment characteristics, and typical applications
relevant to DPPP equipment. DOE received six written comments in
response to the May 2015 DPPP RFI. The commenters included the
Association of Pool and Spa Professionals (APSP); Pacific Gas and
Electric Company (PG&E), Southern California Gas Company (SCG),
Southern California Edison (SCE), and San Diego Gas and Electric
Company (SDG&E), collectively referred to herein as the California
Investor-Owned Utilities (CA IOUs); the Hydraulic Institute (HI); Ms.
Tamara Newman; the National Electrical Manufacturers Association
(NEMA); and River City Pool and Spa (River City).
In response to the May 2015 DPPP RFI, APSP, HI, and CA IOUs
encouraged DOE to pursue a negotiated rulemaking for dedicated-purpose
pool pumps. (Docket. No. EERE-2015-BT-STD-0008, APSP, No. 10 at p. 2;
HI, No. 8 at p. 2; CA IOUs, No. 11 at p. 2) Consistent with feedback
from these interested parties, DOE began a process through the ASRAC to
charter a working group to recommend energy conservation standards and
a test procedure for dedicated-purpose pool pumps rather than
continuing down the traditional notice and comment route that DOE had
already begun. (Docket No. EERE-2015-BT-STD-0008) On August 25, 2015,
DOE published a notice of intent to establish a working group for
dedicated-purpose pool pumps (the DPPP Working Group) 80 FR 51483. The
initial DPPP Working Group charter allowed for 3 months of DPPP Working
Group meetings to establish the scope, metric, definitions, and test
procedure for dedicated-purpose pool pumps. The charter reserved the
discussion of standards for a later set of meetings, after the working
group produced a term sheet recommending a scope, metric, definitions,
and test procedure for DPPPs. (Docket No. EERE-2013-BT-NOC-0005, No. 56
at p. 27) On October 15, 2015, DOE published a notice of public open
meetings of the DPPP Working Group to establish three additional
meetings under the initial charter. 80 FR 61996. DOE selected the
members of the DPPP Working Group to ensure a broad and balanced array
of interested parties and expertise, including representatives from
efficiency advocacy organizations and manufacturers, as well as one
representative from a state government organization. Additionally, one
member from ASRAC and one DOE representative were part of the group.
Table II-1 lists the 13 members of the DPPP Working Group and their
affiliations.
Table II-1--DPPP Working Group Members and Affiliations
------------------------------------------------------------------------
Member Affiliation Abbreviation
------------------------------------------------------------------------
John Caskey.................. National Electrical NEMA.
Manufacturers
Association (and
ASRAC
representative).
John Cymbalsky............... U.S. Department of DOE.
Energy.
Kristin Driskell............. California Energy CEC.
Commission.
Scott Durfee................. Nidec Motor Nidec.
Corporation.
Jeff Farlow.................. Pentair Aquatic Pentair.
Systems.
Gary Fernstrom............... California Investor- CA IOUs.
Owned Utilities.
(PG&E, SDG&E, SCG,
and SCE).
Patrizio Fumagalli........... Bestway USA, Inc..... Bestway.
Paul Lin..................... Regal Beloit Regal.
Corporation.
Joanna Mauer................. Appliance Standards ASAP.
Awareness Project.
Ray Mirzaei.................. Waterway Plastics.... Waterway.
Doug Philhower............... Hayward Industries, Hayward.
Inc.
Shajee Siddiqui.............. Zodiac Pool Systems, Zodiac.
Inc.
Meg Waltner.................. Natural Resources NRDC.
Defense Council.
------------------------------------------------------------------------
[[Page 5658]]
The DPPP Working Group commenced negotiations at an open meeting
between September 30 and October 1, 2015, and then held three
additional meetings to discuss scope, metrics, and the test
procedure.\16\ The DPPP Working Group completed its initial charter on
December 8, 2015, with a consensus vote to approve a term sheet
containing recommendations to DOE on scope, metric, and the basis of
test procedure (``December 2015 DPPP Working Group
recommendations'').\17\ The term sheet containing these recommendations
is available in the DPPP Working Group docket. (Docket No. EERE-2015-
BT-STD-0008, No. 51) ASRAC subsequently voted unanimously to approve
the December 2015 DPPP Working Group recommendations during its January
20, 2016 meeting. (Docket No. EERE-2015-BT-STD-0008, No. 0052) The
December 2015 DPPP Working Group recommendations pertinent to the test
procedure and metric are discussed in section III.C of this document
and reflected in DOE's DPPP test procedure final rule, issued in
December 2016.\18\ DOE's test procedure for dedicated-purpose pool
pumps appears at title 10 of the Code of Federal Regulations (CFR) part
431, subpart Y, appendix B.
---------------------------------------------------------------------------
\16\ Details of the negotiations sessions can be found in the
public meeting transcripts that are posted to the docket for the
Working Group (www.regulations.gov/#!docketDetail;D=EERE-2015-BT-
STD-0008).
\17\ The ground rules of the DPPP Working Group define consensus
as no more than three negative votes. (Docket No. EERE-2015-BT-0008-
0016 at p. 3) Abstention was not construed as a negative vote.
\18\ See https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=41.
---------------------------------------------------------------------------
At the January 20, 2016, ASRAC meeting, the DPPP Working Group also
requested more time to discuss potential energy conservation standards
for dedicated-purpose pool pumps. In response, ASRAC recommended that
the DPPP Working Group continue its work in a second phase of
negotiations to recommend potential energy conservation standards for
dedicated-purpose pool pumps. (Docket No. EERE-2013-BT-NOC-0005, No. 71
at pp. 20-52) The second phase of meetings commenced on March 21, 2016
(81 FR 10152, 10153) and concluded on June 23, 2016, with approval of a
second term sheet (June 2016 DPPP Working Group recommendations). This
term sheet contained DPPP Working Group recommendations on performance-
based energy conservation standard levels, scope of such standards,
certain prescriptive requirements, certain labeling requirements,
certain definitions, and certain amendments to its previous test
procedure recommendations. (Docket No. EERE-2015-BT-STD-0008, No. 82)
ASRAC subsequently voted unanimously to approve the June 2016 DPPP
Working Group recommendations during a July 29, 2016 meeting. (Docket
No. EERE-2013-BT-NOC-0005, No. 87) The energy conservation standards,
definitions, and prescriptive requirements established in this direct
final rule directly reflect the June 2016 DPPP Working Group
recommendations.
In this direct final rule, DOE refers to both formal
recommendations of the DPPP Working Group, as well as informal
discussion and suggestions that were not formally recommended. All
references to approved recommendations are specified with a citation to
the June 2016 DPPP Working Group term sheet and noted with the
recommendation number (e.g., Docket No. EERE-2015-BT-STD-0008, No. #82
Recommendation #X at p. Y); all references to discussions or
suggestions of the DPPP Working Group not found in the June 2016 DPPP
Working Group recommendations will have a citation to meeting
transcripts and the commenter, if applicable (e.g., Docket No. EERE-
2015-BT-STD-0008, [Organization], No. X at p. Y).
In this direct final rule, DOE also refers to certain submitted
comments pertaining to the 2015 RFI that have to do with energy
conservation standards (e.g., Docket No. EERE-2015-BT-STD-0008, No. X
at p. Y). Any RFI comments related to the test procedure or
informational in nature are not included here. DOE notes that many of
the interested parties that submitted comments pertaining to the 2015
RFI later became members of the DPPP Working Group, or in the case of
APSP, several of their members became members of the Working Group. As
such, the concerns of these commenters were fully discussed as part of
the group's meetings, and their positions may have changed as a result
of the compromises inherent in a negotiation. Table II-2 lists the RFI
commenters, as well as whether they participated in the DPPP Working
Group.
Table II-2--List of RFI Commenters
------------------------------------------------------------------------
DPPP working
Commenter group member
------------------------------------------------------------------------
APSP.................................................... No.
CA IOU.................................................. Yes.
Hydraulic Institute..................................... No.
Ms. Newman.............................................. No.
NEMA.................................................... Yes.
River City Pool and Spa................................. No.
------------------------------------------------------------------------
III. General Discussion
A. Consensus Agreement
As discussed in section II.B, DOE established a working group to
negotiate a test procedure and energy conservation standards for
dedicated-purpose pool pumps. On June 23, 2016, the Working Group
reached unanimous consensus on a term sheet related to performance-
based energy conservation standards, scope of such standards, certain
definitions, certain prescriptive requirements, certain labeling
requirements, and certain test procedure aspects for dedicated-purpose
pool pumps. This term sheet included the following recommendations
related to energy conservation standards: \19\
---------------------------------------------------------------------------
\19\ Note that the recommendations appear as-written in the June
2016, Working Group recommendation (https://www.regulations.gov/document?D=EERE-2015-BT-STD-0008-0082); i.e., all text and tables
are verbatim.
---------------------------------------------------------------------------
Recommendation #1. Each dedicated-purpose pool pump shall be
required to meet the applicable minimum energy efficiency standards
(WEF) set forth in the following table on and after July 19, 2021:
[[Page 5659]]
[GRAPHIC] [TIFF OMITTED] TR18JA17.014
The working group does not recommend standards for: (1) Waterfall
pumps of any size or (2) self-priming and non-self-priming pool filter
pumps greater than or equal to 2.5 HHP.
All instances of HHP refer to hydraulic horsepower on Curve C at
Max Speed.\20\
---------------------------------------------------------------------------
\20\ The test procedure final rule contains a detailed
discussion of the system curves used in pump testing, and section
IV.A.1.c of this document describes how system curve C defines the
relationship between the power, head, and flow of a pump.
---------------------------------------------------------------------------
Recommendation #2. On and after July 19, 2021, integral cartridge-
filter pool pumps and integral sand-filter pool pumps must be
distributed in commerce with a timer. Timer may be integral to the pump
or a separate component that is shipped with the pump.
Recommendation #3. The scope of the recommended standards for self-
priming pool filter pumps are only applicable to self-priming pool
filter pumps served by single-phase power.
The recommended test procedure and reporting requirements would be
applicable to all self-priming pool filter pumps (served by single- and
three-phase power).
The recommended hydraulic horsepower limitation (<2.5 hydraulic hp)
still applies.
Recommendation #4. For the purposes of establishing compliance with
the standards for integral cartridge-filter and integral sand-filter
pool pumps discussed in Recommendation #2, pool pump timer is defined
as follows:
Pool pump timer means a pool pump control that automatically turns
off a dedicated-purpose pool pump after a run-time of no longer than 10
hours.
The recommended definition captures the intent of the working group
and should be adopted as-written or as modified in a manner that
captures the same intent.
Recommendation #6A. All dedicated-purpose pool pumps with freeze
protection controls distributed in commerce with the pump shall be
shipped with freeze protection disabled or with the following default,
user-adjustable settings:
1. The default dry-bulb air temperature setting is no greater than
40 [deg]F
2. The default run time setting shall be no greater than 1 hour
(before the temperature is rechecked); and
3. The default motor speed shall not be more than \1/2\ of the
maximum available speed
As part of certification reporting, manufacturers must include the
default dry-bulb air temperature setting (in [deg]F), default run time
setting (in minutes), and default motor speed (in rpm).
(Docket No. EERE-2015-BT-STD-0008, No. 82) This term sheet was
ultimately submitted to, and accepted by the ASRAC, on July 29, 2016
(Docket No. EERE-2013-BT-NOC-0005, No. 87). All recommendations not
shown here are related to test procedure or certification and were
addressed in the recently issued test procedure final rule.
After carefully considering the consensus recommendations submitted
by the DPPP Working Group and adopted by ASRAC related to energy
conservation standards for dedicated-purpose pool pumps, DOE has
determined that these recommendations, submitted in the previously
discussed term sheet, comprise a statement submitted by interested
persons who are fairly representative of relevant points of view on
this matter. If compliant with certain statutory requirements, the
recommendations could result in issuance of a direct final rule. In
reaching this determination, DOE considered that the DPPP Working
Group, in conjunction with ASRAC members who approved the
recommendations, consisted of representatives of manufacturers of the
covered equipment at issue, States, and efficiency advocates--all of
which are groups specifically identified by Congress as relevant
parties to any consensus recommendation. (42 U.S.C. 6295(p)(4)(A) and
6316(a)) As discussed above, the term sheet was signed and submitted by
a broad cross-section of interests, including the manufacturers who
produce the subject equipment, environmental and energy-efficiency
advocacy organizations, electric utility companies, and a member
representing a State.\21\ In addition, the ASRAC Committee approving
the DPPP Working Group's recommendations included at least two members
representing States, one representing the National Association of State
Energy Officials (NASEO) and one representing the State of
California.\22\ By explicit language of the statute, the Secretary has
the discretion to determine when a joint recommendation for an energy
or water conservation standard has met the requirement for
representativeness (i.e., ``as determined by the Secretary''). (42
U.S.C. 6295(p) (For today's direct final rule, DOE has determined that
the DPPP working group represents all relevant points of view of
interested parties.
---------------------------------------------------------------------------
\21\ This individual was Kristen Driskell (CEC).
\22\ These individuals were Deborah E. Miller (NASEO) and David
Hungerford (CEC).
---------------------------------------------------------------------------
Pursuant to 42 U.S.C. 6295(p)(4), the Secretary must also determine
whether a jointly submitted recommendation for an energy or water
conservation standard satisfies 42 U.S.C. 6295(o) or 42 U.S.C.
6313(a)(6)(B), as applicable. In making this determination, DOE has
conducted an analysis to evaluate whether the potential energy
conservation standards under consideration would meet these
requirements. This evaluation is the same comprehensive approach that
DOE typically conducts whenever it considers potential energy
conservation standards for a given type of product or equipment. DOE
applies the same principles to any consensus recommendations it may
receive to satisfy its statutory obligation to ensure that any energy
conservation standard it adopts achieves the maximum improvement in
energy efficiency that is technologically feasible and economically
justified and will result in
[[Page 5660]]
significant conservation of energy. Upon review, the Secretary
determined that the term sheet submitted in the dedicated-purpose pool
pump rulemaking comports with the standard-setting criteria set forth
under 42 U.S.C. 6295(o). Accordingly, the consensus-recommended
efficiency levels were included as Trial Standard Level (TSL) 3 for
dedicated-purpose pool pumps in this rule (see section V.A for
descriptions of all of the considered TSLs). Details regarding how the
consensus-recommended TSL complies with the standard-setting criteria
are discussed and demonstrated in the relevant sections throughout this
document.
In sum, as the relevant criteria under 42 U.S.C. 6295(p)(4) have
been satisfied, and the Secretary has determined that it is appropriate
to adopt the consensus-recommended energy conservation standards for
dedicated-purpose pool pumps through this direct final rule.
As required by the same statutory provision, DOE also is
simultaneously publishing a notice of proposed rulemaking (NOPR)
proposing that the identical standard levels contained in this direct
final rule be adopted. Consistent with the statute, DOE is providing a
110-day public comment period on the direct final rule. While DOE
typically provides a comment period of 60 days on proposed standards,
DOE is providing a 110-day comment period for this NOPR, which is the
same length as the comment period for the direct final rule. Based on
the comments received during this period, the direct final rule will
either become effective or DOE will withdraw it if one or more adverse
comments is received and if DOE determines that those comments, when
viewed in light of the rulemaking record related to the direct final
rule, provide a reasonable basis for withdrawal of the direct final
rule and for DOE to continue this rulemaking under the NOPR. Receipt of
an alternative joint recommendation may also trigger a DOE withdrawal
of the direct final rule in the same manner. 42 U.S.C. 6295(p)(4)(C).
Typical of other rulemakings, it is the substance, rather than the
quantity, of comments that will ultimately determine whether a direct
final rule will be withdrawn. To this end, the substance of any adverse
comment(s) received will be weighed against the anticipated benefits of
the jointly submitted recommendations and the likelihood that further
consideration of the comment(s) would change the results of the
rulemaking. To the extent an adverse issue had been previously raised
and addressed in the rulemaking proceeding, such a submission will not
typically provide a basis for withdrawal of a direct final rule. Under
the statute, withdrawal would occur by the 120th day after the direct
final rule's publication.
B. Compliance Date
EPCA does not prescribe a lead time for pumps, or the number of
years between the date of publication of a final standards rule and the
date on which manufacturers must comply with the new standard. The DPPP
Working Group recommended that the standards for dedicated-purpose pool
pumps be applicable 54 months following publication of the direct final
rule in the Federal Register. (EERE-2015-BT-STD-0008, No. 51,
Recommendations #1 and #2 at pp. 1-2) DOE has adopted this date for
this direct final rule.
C. Test Procedure
This section discusses DOE's requirements with respect to test
procedures as well as summarizes the test procedure for dedicated-
purpose pool pumps adopted by DOE.
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6314)
Manufacturers of covered equipment must use these test procedures to
certify to DOE that their equipment complies with energy conservation
standards and to quantify the efficiency of their equipment. As noted,
in December 2016, DOE issued the DPPP test procedure final rule to
establish test procedures for dedicated-purpose pool pumps.\23\ The
test procedure for dedicated-purpose pool pumps will appear at title 10
of the CFR part 431, subpart Y, appendix B.
---------------------------------------------------------------------------
\23\ See https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=41.
---------------------------------------------------------------------------
DOE notes that 10 CFR part 430, subpart C, Appendix A established
procedures, interpretations, and policies to guide DOE in the
consideration and promulgation of new or revised appliance efficiency
standards under EPCA. (See section 1.) These procedures are a general
guide to the steps DOE typically follows in promulgating energy
conservation standards. The guidance recognizes that DOE can and will,
on occasion, deviate from the typical process. (See 10 CFR part 430,
subpart C, appendix A, section 14(a)) In this particular instance, DOE
deviated from its typical process by conducting a negotiated rulemaking
process, per the request of multiple key stakeholders and as chartered
by ASRAC. The DPPP Working Group initially met four times and
successfully reached consensus on the recommended test procedure and
metric for different varieties of dedicated-purpose pool pumps.
Following ASRAC approval, the DPPP Working Group commenced a second
phase of meetings, resulting in consensus on the recommended energy
conservation standards as well as certain additional test procedure
recommendations. These recommendations are contained in the December
2015 and June 2016 DPPP Working Group term sheets, which ASRAC adopted.
(Docket No. EERE-2015-BT-STD-0008, No. 51 and 82, respectively)
As discussed in section III.A, the June 2016 term sheet meets the
criteria of a consensus recommendation, and DOE has determined that
these recommendations are in accordance with the statutory requirements
of 42 U.S.C. 6295(p)(4) (and 6316(a)) for the issuance of a direct
final rule. DOE ultimately adopted the test procedure provisions and
recommended standard levels that the DPPP Working Group included in the
term sheets, which illustrates that DOE's deviations from the typical
rulemaking process in this instance did not adversely impact the
manufacturers' ability to understand and provide input to DOE's
rulemaking process. The process that DOE used, in this case, was a more
collaborative negotiated rulemaking effort resulting in an agreement on
recommended standard levels, which DOE is fully implementing in this
direct final rule.
Consistent with the recommendations of the DPPP Working Group, in
September 2016 DOE published a test procedure notice of proposed
rulemaking proposing (September 2016 DPPP TP NOPR) to propose new
definitions, a new test procedure, new sampling and rating
requirements, and new enforcement provisions for dedicated-purpose pool
pumps. DOE held a public meeting on September 26, 2016, to discuss and
request public comment on the September 2016 DPPP test procedure NOPR.
Subsequently, DOE published a test procedure final rule reflecting
relevant recommendations of the DPPP Working Group, as well as input
from interested parties received in response to the September 2016 DPPP
test procedure NOPR. (Docket No. EERE-2016-BT-TP-0002)
In the test procedure final rule, DOE prescribed a test procedure
for measuring the WEF for certain varieties of dedicated-purpose pool
pumps. Specifically, the adopted test procedure applies only to self-
priming and non-
[[Page 5661]]
self-priming pool filter pumps,\24\ waterfall pumps, and pressure
cleaner booster pumps. The test procedure does not apply to integral
cartridge filter pool pumps, integral sand filter pool pumps, storable
electric spa pumps, or rigid electric spa pumps.
---------------------------------------------------------------------------
\24\ DOE's DPPP test procedure applies to certain varieties of
dedicated-purpose pool pumps that are served by both single-phase
and three-phase power, whereas this direct final rule only
establishes energy conservation standards for self-priming pool
filter pumps served by single-phase power.
---------------------------------------------------------------------------
For those applicable varieties of dedicated-purpose pool pumps, DOE
prescribed methods to measure and calculate WEF, which is determined as
a weighted average of water flow rate over the input power to the
dedicated-purpose pool pump at different load points, depending on the
variety of dedicated-purpose pool pump and the number of operating
speeds with which it is distributed in commerce. The equation for WEF
is shown in Equation 1:
[GRAPHIC] [TIFF OMITTED] TR18JA17.000
Where:
WEF = weighted energy factor in kgal/kWh;
wi = weighting factor at each load point i;
Qi = flow at each load point i in gal/min;
Pi = input power to the motor (or controls, if present)
at each load point i in W;
i = load point(s), defined uniquely for each DPPP variety; and
n = number of load point(s), defined uniquely for each speed
configuration.
DOE prescribed unique load points for the different varieties and
speed configurations of dedicated-purpose pool pumps, as recommended by
the DPPP Working Group. The load points (i) and weights (wi) used in
determining WEF for each pump variety are presented in Table III-1.
[[Page 5662]]
[GRAPHIC] [TIFF OMITTED] TR18JA17.001
The test procedure final rule also contains methods to determine
the self-priming capability of pool filter pumps to effectively
differentiate self-priming and non-self-priming pool filter pumps, and
the rated hydraulic horsepower,
[[Page 5663]]
both of which are necessary to determine the applicable energy
conservation standard for certain varieties of dedicated-purpose pool
pumps.
D. Scope
In the test procedure final rule, DOE adopted the following
definition for dedicated-purpose pool pumps, consistent with that
recommended by the DPPP Working Group (EERE-2015-BT-STD-0008, No. 51
Recommendation #4 at p. 3):
``Dedicated-purpose pool pump'' means a self-priming pool filter
pump, a non-self-priming pool filter pump, a waterfall pump, a pressure
cleaner booster pump, an integral sand filter pool pump, an integral
cartridge filter pool pump, a storable electric spa pump, or a rigid
electric spa pump.
The test procedure final rule also specifically defines several
varieties of dedicated-purpose pool pumps, some of which are included
in the scope of energy conservation standards. The following sections
describe the scope for the adopted performance-based and prescriptive
energy conservation standards, respectively, for dedicated-purpose pool
pumps.
1. Performance-Based Energy Conservation Standards
The DPPP Working Group recommended energy conservation standards
for a subset of dedicated-purpose pool pumps to which the test
procedure applies. Specifically, while the test procedure applies to
self-priming pool filter pumps, non-self-priming pool filter pumps,
pressure cleaner booster pumps, and waterfall pumps, the DPPP Working
Group recommended energy conservation standards only for the first
three categories, excepting waterfall pumps due to limited economic
benefits. (EERE-2015-BT-STD-0008, No. 82 Recommendation #2 at pp. 1-2).
DOE agrees with the reasoning of the DPPP Working Group and is
establishing energy conservation standards in this direct final rule
only for those pump varieties recommended by the DPPP Working Group.
Further detail on the economic benefits and burdens for all dedicated-
purpose pool pump varieties analyzed, including waterfall pumps, can be
found in section V.B. The scope of the performance-based energy
conservation standards established in this document is summarized in
Table III-2.
Table III--2 Scope of Performance-Based Standards for Dedicated-Purpose
Pool Pumps
------------------------------------------------------------------------
Hydraulic Power that pump is
Pump variety horsepower range served by
------------------------------------------------------------------------
Self-priming pool filter pump. All pumps less Single Phase.
than 2.5 hhp.
Non-self-priming pool filter All pumps less No Restriction.
pumps. than 2.5 hhp.
Pressure cleaner booster pumps No Restriction... No Restriction.
------------------------------------------------------------------------
DOE notes that in response to the May 2015 DPPP RFI, HI suggested
that ``auxiliary pool pumps [now referred to as pressure cleaner
booster pumps] below 1 hp should be excluded because it will be
difficult to adequately differentiate them from other CIP ESCC pumps
below 1 hp. Including auxiliary pool pumps below 1 hp could potentially
extend the scope of the CIP rulemaking outside the ASRAC working group
negotiation. [sic]'' (Docket. No. EERE-2015-BT-STD-0008, HI, No. 8 at
p. 3) DOE acknowledges the concerns raised by HI, and clarifies that in
test procedure rulemaking, DOE proposed, received comment on, and
ultimately established, a definition for pressure cleaner booster pumps
that effectively differentiated these pumps from end suction close-
coupled pumps less than 1 horsepower. Specifically, pressure cleaner
booster pump was defined to mean an end suction, dry rotor pump
designed and marketed for pressure-side pool cleaner applications, and
which may be UL listed under ANSI/UL 1081-2014, ``Standard for Swimming
Pool Pumps, Filters, and Chlorinators.'' Because DOE was able to, in
the test procedure final rule, develop a definition to adequately
differentiate pressure cleaner booster pumps from other end suction
close-coupled pump, DOE will not exclude pressure cleaner booster pumps
from energy conservation standards, as recommended by HI.
As shown in Table III-2, the DPPP Working Group recommended a scope
of standards that restricts self-priming and non-self-priming pool
filter pumps to those with a hydraulic output power less than 2.5
horsepower (Docket No. EERE-2015-BT-STD-0008, No. 82, Recommendation #1
at p. 1). DOE notes that the DPPP Working Group first discussed a
cutoff point of 2.5 hydraulic horsepower in the March 21, 2016 DPPP
Working Group meeting. Initially, the DPPP Working Group members were
confused about whether the discussion of pump capacity was using terms
of hydraulic horsepower, nameplate horsepower, or shaft horsepower. DOE
clarified that capacity discussions are in terms of hydraulic
horsepower. (Docket No. EERE-2015-BT-STD-0008, No. 94 at p. 38-42) In a
subsequent April 19 Working Group meeting, DOE again clarified that the
scope metric is in terms of hydraulic horsepower. (Docket No. EERE-
2015-BT-STD-0008, No. 79 at p. 34-39)
Ultimately, the DPPP Working Group recommendation for horsepower
limitations is consistent with the scope of self-priming and non-self-
priming pool filter pumps established in the test procedure final rule.
The DPPP Working Group recommended this restriction based on the
combination of three key reasons: (1) Low shipments volume, (2) low
potential for energy savings (due to the prevalence of motors already
regulated by DOE), and (3) lack of performance data. (Docket No. EERE-
2015-BT-STD-0008, No. 79 at p. 36-47) DOE agrees with the reasoning of
the DPPP Working Group and is adopting this scope restriction in this
direct final rule.
DOE notes that prior to the formation of the DPPP Working Group,
APSP responded to the May 2015 DPPP RFI and recommended that DOE define
scope using total horsepower, noting that it was also open to
discussing and developing alternative or additional methods in which we
can rate covered pump systems by total input power draw. (Docket. No.
EERE-2015-BT-STD-0008, APSP, No. 10 at p. 5) APSP provided no further
rationale for their option. APSP's recommendation conflicts with the
use of hydraulic horsepower recommended by the DPPP Working Group and
discussed in the previous paragraphs. DOE notes that five members of
APSP (Waterway Plastics, Hayward Industries, Inc., Zodiac Pool Systems,
Inc., Pentair Aquatic Systems, and Bestway USA, Inc.) participated in
the DPPP Working Group and unanimously supported the
[[Page 5664]]
term sheet recommendations enumerated in the previous paragraphs.
(EERE-2015-BT-STD-0008, No. 51) Further, DOE notes that a
representative of APSP was present at the final DPPP Working Group
meeting, and offered no public comment in opposition to the term sheet
adopted by the DPPP Working Group. (Docket No. EERE-2015-BT-STD-0008,
June 23 DPPP Working Group Meeting, No. 92, at p. 3) For these reasons,
DOE believes that the interests of APSP were sufficiently satisfied by
the recommendations unanimously agreed upon by the DPPP Working
Group.Also as shown in Table III-2, the DPPP Working Group recommended
that the scope of the recommended standards for self-priming pool
filter pumps only be applicable to self-priming pool filter pumps
served by single-phase power. The DPPP Working Group clarified that the
recommended test procedure and reporting requirements would still be
applicable to all self-priming pool filter pumps--both those served by
single-phase power and those served by three-phase power. (Docket No.
EERE-2015-BT-STD-0008, No. 82 Recommendations #3 at p. 2) Regardless of
whether the pump is supplied by single- or three-phase power, the
recommended hydraulic horsepower limitation of 2.5 rated hydraulic
horsepower would still apply to such self-priming pool filter pumps.
The DPPP Working Group recommended this restriction based on low
shipments volume and low potential for energy savings (due to the
prevalence of motors already regulated by DOE) (Docket No. EERE-2015-
BT-STD-0008, No. 91 at p. 171). DOE agrees with the reasoning of the
DPPP Working Group and is adopting this scope restriction in this
direct final rule.
Finally, consistent with the test procedure scope, standards do not
apply to submersible pumps. In the test procedure final rule, DOE
defined a submersible pump as a pump that is designed to be operated
with the motor and bare pump fully submerged in the pumped liquid. As
discussed in the test procedure final rule, DOE determined that some
end suction submersible pond pumps may meet the definition of self-
priming or non-self-priming pool filter pump, but were not reviewed by
the DPPP Working Group and were not intended by the DPPP Working Group
to be in the scope of this rulemaking. In order to exclude these pumps
from this regulation, DOE excluded submersible pumps from the scope of
the test procedure final rule, and is in turn excluding them from the
scope of this direct final rule.
2. Prescriptive Energy Conservation Standards
Consistent with the DPPP Working Group recommendations, DOE is
setting prescriptive energy conservation standards for integral
cartridge filter pool pumps and integral sand filter pool pumps. This
equipment is specifically defined in the test procedure final rule.
DOE notes that before the formation of the DPPP Working Group, APSP
responded to the May 2015 DPPP RFI and generally recommended that DOE
pursue a performance-based metric versus a prescriptive regulation.
(Docket. No. EERE-2015-BT-STD-0008, APSP, No. 10 at p. 11) APSP
provided no further rationale for their option. APSP's recommendation
conflicts with the mix of performance-based and prescriptive standards
recommended by the DPPP Working Group and enumerated in section III.A.
DOE notes that five members of APSP (Waterway Plastics, Hayward
Industries, Inc., Zodiac Pool Systems, Inc., Pentair Aquatic Systems,
and Bestway USA, Inc.) participated in the DPPP Working Group and
unanimously supported the term sheet recommendations enumerated in
section III.A. (EERE-2015-BT-STD-0008, No. 51) Further, DOE notes that
a representative of APSP was present at the final DPPP Working Group
meeting, and offered no public comment in opposition to the term sheet
adopted by the DPPP Working Group. (Docket No. EERE-2015-BT-STD-0008,
June 23 DPPP Working Group Meeting, No. 92, at p. 3) For these reasons,
DOE believes that the interests of APSP were sufficiently satisfied by
the recommendations unanimously agreed upon by the DPPP Working Group.
3. Dedicated-Purpose Pool Pump Motor
In response to the May 2015 DPPP RFI, NEMA recommended that DOE
consider proposing a replacement motor standard for pool pumps, as has
been done in the California Title 20 Appliance Efficiency Program. NEMA
asserted that the replacement pool filter pump motor subject is one
that requires nationwide uniformity of compliance and enforcement
through specific language regarding replacement motors within the pool
filter pump system. (Docket. No. EERE-2015-BT-STD-0008, NEMA, No. 9 at
p. 2) DOE acknowledges that replacement dedicated-purpose pool pump
motors may have an impact on national energy consumption. However,
establishing energy conservation standards or prescriptive requirements
for dedicated-purpose pool pump motors is outside of the scope of
authority of this rulemaking, as replacement motors do not meet the
definition of ``dedicated-purpose pool pump'' or ``pump,'' as defined
in part 431 of title 10 of the Code of Federal Regulations. For this
reason, in this direct final rule, DOE will not establish energy
conservation standards for replacement dedicated-purpose pool pump
motors.
However, DOE notes that in the test procedure final rule, DOE
established an optional test procedure for rating replacement
dedicated-purpose pool pump motors. DOE believes that this optional
test procedure will aid the industry in moving towards uniformity in
the rating and labeling of replacement dedicated-purpose pool pump
motors.
E. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the products or equipment that are the subject of the
rulemaking. As the first step in such an analysis, DOE develops a list
of technology options for consideration in consultation with
manufacturers, industry experts, and other interested parties. DOE then
determines which of those means for improving efficiency are
technologically feasible. DOE considers technologies incorporated in
commercially available products or in working prototypes to be
technologically feasible. 10 CFR part 430, subpart C, appendix A,
section 4(a)(4)(i).
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
Practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; and (3) adverse impacts on
health or safety. 10 CFR part 430, subpart C, appendix A, section
4(a)(4)(ii)-(iv) Additionally, it is DOE policy not to include in its
analysis any proprietary technology that is a unique pathway to
achieving a certain efficiency level. Section IV.B of this notice
discusses the results of the screening analysis for dedicated-purpose
pool pumps, particularly the designs DOE considered, those it screened
out, and those that are the basis for the standards considered in this
rulemaking. For further details on the screening analysis for this
rulemaking, see chapter 4 of the direct
[[Page 5665]]
final rule technical support document (TSD).
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt or amend a standard for a type or class
of covered equipment, it must determine the maximum improvement in
energy efficiency or maximum reduction in energy use that is
technologically feasible for such product. (42 U.S.C. 6295(p)(1)) and
6316(a)) Accordingly, in the engineering analysis, DOE determined the
maximum technologically feasible (max-tech) improvements in energy
efficiency for dedicated-purpose pool pumps based on the most efficient
equipment available on the market for certain equipment classes, and
theoretical maximum attainable efficiency for others. The max-tech
levels that DOE determined for this rulemaking are described in section
IV.C.4 of this direct final rule and in chapter 5 of the direct final
rule TSD.
F. Energy Savings
1. Determination of Savings
For each trial standard level (TSL), DOE projected energy savings
from application of the TSL to pool pumps purchased in the 30-year
period that begins in the year of compliance with any new standards
(2021-2050).\25\ The savings are measured over the entire lifetime of
equipment purchased in the 30-year analysis period. DOE quantified the
energy savings attributable to each TSL as the difference in energy
consumption between each standards case and the no-standards case. The
no-standards case represents a projection of energy consumption that
reflects how the market for equipment would likely evolve in the
absence of energy conservation standards.
---------------------------------------------------------------------------
\25\ DOE also presents a sensitivity analysis that considers
impacts for equipment shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (NIA) spreadsheet model to
estimate national energy savings (NES) from potential standards for
pool pumps. The NIA spreadsheet model (described in section IV.H of
this document) calculates energy savings in terms of site energy, which
is the energy directly consumed by equipment at the locations where
they are used. For electricity, DOE reports national energy savings in
terms of primary energy savings, which is the savings in the energy
that is used to generate and transmit the site electricity. DOE also
calculates NES in terms of full-fuel-cycle (FFC) energy savings. The
FFC metric includes the energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas, petroleum fuels),
and thus presents a more complete picture of the impacts of energy
conservation standards.\26\ DOE's approach is based on the calculation
of an FFC multiplier for each of the energy types used by covered
products or equipment. For more information on FFC energy savings, see
section IV.H.2 of this direct final rule.
---------------------------------------------------------------------------
\26\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (August 18, 2011), as
amended at 77 FR 49701 (August 17, 2012).
---------------------------------------------------------------------------
G. Economic Justification
1. Specific Criteria
As noted, EPCA provides seven factors to be evaluated in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(I)(VII) and
6316(a)) The following sections discuss how DOE has addressed each of
those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on
manufacturers, DOE conducts a manufacturer impact analysis (MIA), as
discussed in section IV.J. DOE first uses an annual cash-flow approach
to determine the quantitative impacts. This step includes both a short-
term assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period. The industry-wide impacts analyzed include (1) INPV, which
values the industry on the basis of expected future cash flows; (2)
cash flows by year; (3) changes in revenue and income; and (4) other
measures of impact, as appropriate. Second, DOE analyzes and reports
the impacts on different types of manufacturers, including impacts on
small manufacturers. Third, DOE considers the impact of standards on
domestic manufacturer employment and manufacturing capacity, as well as
the potential for standards to result in plant closures and loss of
capital investment. Finally, DOE takes into account cumulative impacts
of various DOE regulations and other regulatory requirements on
manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and PBP associated with new or amended standards. These
measures are discussed further in the following section. For consumers
in the aggregate, DOE also calculates the national net present value of
the economic impacts applicable to a particular rulemaking. DOE also
evaluates the LCC impacts of potential standards on identifiable
subgroups of consumers that may be affected disproportionately by a
national standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a standard. (42 U.S.C.
6295(o)(2)(B)(i)(II) and 6316(a)) DOE conducts this comparison in its
LCC and PBP analyses.
The LCC is the sum of the purchase price of equipment (including
its installation) and the operating cost (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the equipment. The LCC analysis requires a variety of inputs, such as
equipment prices, equipment energy consumption, energy prices,
maintenance and repair costs, equipment lifetime, and discount rates
appropriate for consumers. To account for uncertainty and variability
in specific inputs, such as equipment lifetime and discount rate, DOE
uses a distribution of values, with probabilities attached to each
value.
The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of more efficient equipment through lower operating
costs. DOE calculates the PBP by dividing the change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year in which compliance is required with standards.
For its LCC and PBP analyses, DOE assumes that consumers will
purchase the covered equipment in the first year of compliance with new
standards. The LCC savings for the considered efficiency levels are
calculated relative to the case that reflects projected market trends
in the absence of new or amended standards. DOE's LCC and PBP analyses
are discussed in further detail in section IV.F.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic
[[Page 5666]]
justification of a standard, to consider the total projected energy
savings that are expected to result directly from the standard. (42
U.S.C. 6295(o)(2)(B)(i)(III) and 6316(a)) As discussed in section IV.H,
DOE uses the NIA spreadsheet model to project national energy savings.
d. Lessening of Utility or Performance of Equipment
In establishing equipment classes, and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered equipment. (42 U.S.C. 6295(o)(2)(B)(i)(IV) and 6316(a)) DOE
reviewed performance data and characteristics for dedicated-purpose
pool pump models that are currently available on the market, including
models that meet the standards adopted in this final rule and models
that do not meet the standards adopted in this final rule. For these
models, DOE examined characteristics such as the capacity, controls,
and physical size of the pumps. DOE was unable to identify any DPPP
features or associated end-user utility that would become unavailable
following the adoption of the standards in this final rule.
Consequently, DOE concludes that the standards adopted in this direct
final rule would not reduce the utility or performance of the equipment
subject to this rulemaking. DOE's assessment of available technology
options (see section IV.A.6) discusses, in detail, the features and
technologies associated with the select standard level.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, which is
likely to result from a standard. (42 U.S.C. 6295(o)(2)(B)(i)(V) and
6316(a)) It also directs the Attorney General to determine the impact,
if any, of any lessening of competition likely to result from a
standard and to transmit such determination to the Secretary within 60
days of the publication of a proposed rule, together with an analysis
of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)
and 6316(a)) DOE will transmit a copy of this direct final rule to the
Attorney General with a request that the Department of Justice (DOJ)
provide its determination on this issue. DOE will consider DOJ's
comments on the rule in determining whether to proceed with the direct
final rule. DOE will also publish and respond to the DOJ's comments in
the Federal Register in a separate notice.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water
conservation in determining whether a new or amended standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI) and 6316(a))
The energy savings from the adopted standards are likely to provide
improvements to the security and reliability of the nation's energy
system. Reductions in the demand for electricity also may result in
reduced costs for maintaining the reliability of the Nation's
electricity system. DOE conducts a utility impact analysis to estimate
how standards may affect the nation's needed power generation capacity,
as discussed in section IV.M.
DOE maintains that environmental and public health benefits
associated with the more efficient use of energy are important to take
into account when considering the need for national energy
conservation. The adopted standards are likely to result in
environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases (GHGs) associated with energy
production and use. DOE conducts an emissions analysis to estimate how
potential standards may affect these emissions, as discussed in section
IV.K; the estimated emissions impacts are reported in section V.B.6 of
this document. DOE also estimates the economic value of emissions
reductions resulting from the considered TSLs, as discussed in section
IV.L.
g. Other Factors
In determining whether an energy conservation standard is
economically justified, DOE may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII) and
6316(a)) To the extent DOE identifies any relevant information
regarding economic justification that does not fit into the other
categories described above, DOE could consider such information under
``other factors.''
2. Significance of Savings
To adopt standards for a covered product or equipment, DOE must
determine that such action would result in significant energy savings.
(42 U.S.C. 6295(o)(3)(B) and 6316(a)) Although EPCA does not define the
term ``significant,'' in Natural Resources Defense Council v.
Herrington, the U.S. Court of Appeals for the District of Columbia
indicated that Congress intended ``significant'' energy savings in the
context of EPCA to be savings that are not ``genuinely trivial.'' 768
F.2d 1355, 1373 (D.C. Cir. 1985). The energy savings for all the TSLs
considered in this rulemaking, including the adopted standards, are not
trivial, and, therefore, DOE considers them ``significant'' within the
meaning of section 325 of EPCA.
3. Rebuttable Presumption
EPCA creates a rebuttable presumption that an energy conservation
standard is economically justified if the additional cost to the
consumer of a product that meets the standard is less than three times
the value of the first year's energy savings resulting from the
standard, as calculated under the applicable DOE test procedure. (42
U.S.C. 6295(o)(2)(B)(iii)) DOE's LCC and PBP analyses generate values
used to calculate the effect potential amended energy conservation
standards would have on the payback period for consumers. These
analyses include, but are not limited to, the 3-year payback period
contemplated under the rebuttable-presumption test. In addition, DOE
routinely conducts an economic analysis that considers the full range
of impacts to consumers, manufacturers, the Nation, and the
environment, as required under EPCA. (42 U.S.C. 6295(o)(2)(B)(i)) The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable presumption payback results are
discussed in section V.B.1.cof this direct final rule.
IV. Methodology and Discussion of Related Comments
This section addresses the rulemaking analyses DOE performed for
this direct final rule. Separate subsections address each component of
DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards considered in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential amended or new
energy conservation standards. The national impacts analysis uses a
second spreadsheet set that provides shipments forecasts and calculates
national energy savings and net present value of total consumer costs
and savings expected to result from potential energy conservation
standards. DOE uses the third spreadsheet tool, the Government
Regulatory Impact Model (GRIM), to assess manufacturer impacts of
potential standards. These three spreadsheet tools
[[Page 5667]]
are available on the DOE Web site for this rulemaking: https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=67. Additionally, DOE used output from the
Energy Information Administration (EIA)'s Annual Energy Outlook 2016
(AEO2016), a widely known energy forecast for the United States, for
the emissions and utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment
that provides an overall picture of the market for dedicated-purpose
pool pumps, including purpose of the equipment, industry structure,
manufacturers, market characteristics, and technologies used in the
equipment. This activity includes both quantitative and qualitative
assessments, based primarily on publicly available information (e.g.,
manufacturer specification sheets and industry publications) and data
submitted by manufacturers, trade associations, and other stakeholders.
The market and technology assessment for this rulemaking addresses: (1)
Equipment classes, (2) manufacturers and industry structure, (3)
existing efficiency programs, (4) shipments information, (5) market and
industry trends, and (6) technologies or design options that could
improve the energy efficiency of dedicated-purpose pool pumps. The key
findings of DOE's market assessment are summarized below. See chapter 3
of the direct final rule TSD for further discussion of the market and
technology assessment.
1. Equipment Classes and Distinguishing Features
When evaluating and establishing energy conservation standards, DOE
divides covered equipment into equipment classes by the type of energy
used, by capacity, or by other performance-related features that
justify differing standards. In making a determination whether a
performance-related feature justifies a different standard, DOE must
consider such factors as the utility of the feature to the consumer and
other factors DOE determines are appropriate. (42 U.S.C. 6295(q) and
6316(a))
In the test procedure final rule, DOE defined different varieties
of DPPP equipment. A pool filter pump is an end suction pump that
either: (1) Includes an integrated basket strainer, or (2) does not
include an integrated basket strainer, but requires a basket strainer
for operation, as stated in manufacturer literature provided with the
pump; and may be distributed in commerce connected to, or packaged
with, a sand filter, removable cartridge filter, or other filtration
accessory, as long as the bare pump and filtration accessory are
connected with consumer-removable connections that allow the pump to be
plumbed to bypass the filtration accessory for testing.
A self-priming pool filter pump is a pool filter pump that is
certified under NSF/ANSI 50-2015 to be self-priming or is capable of
re-priming to a vertical lift of at least 5 feet with a true priming
time less than or equal to 10 minutes, when tested in accordance with
NSF/ANSI 50-2015, ``Equipment for Swimming Pools, Spas, Hot Tubs and
Other Recreational Water Facilities.''
A non-self-priming pool filter pump is a pool filter pump that is
not certified under NSF/ANSI 50-2015 to be self-priming and is not
capable of re-priming to a vertical lift of at least 5 feet with a true
priming time less than or equal to 10 minutes, when tested in
accordance with NSF/ANSI 50-2015.
A pressure cleaner booster pump is an end suction, dry rotor pump
designed and marketed for pressure-side pool cleaner applications, and
which may be UL listed under ANSI/UL 1081-2014, ``Standard for Swimming
Pool Pumps, Filters, and Chlorinators.''
A waterfall pump is a pool filter pump with maximum head less than
or equal to 30 feet, and a maximum speed less than or equal to 1,800
rpm.
An integral cartridge filter pool pump is a pump that requires a
removable cartridge filter, installed on the suction side of the pump,
for operation; and the pump cannot be plumbed to bypass the cartridge
filter for testing.
An integral sand filter pool pump is a pump distributed in commerce
with a sand filter that cannot be bypassed for testing.
The DPPP varieties defined above serve as the basis for the DPPP
equipment classes established in this direct final rule. Further, the
class of self-priming pool filter pumps is being subdivided into two
classes based on pump capacity. In this direct final rule, DOE is
establishing DPPP equipment classes based on the following performance-
related features:
Strainer or filtration accessory
self-priming ability
pump capacity (flow, head, and horsepower)
rotational speed
Stakeholder comments regarding equipment classes, the specific
separation of equipment classes based on the listed factors, and the
final list of proposed equipment classes are discussed further in
sections IV.A.1.a through IV.A.1.d.
a. Strainer or Filtration Accessory
Dedicated-purpose pool pumps employ several different varieties of
strainer and filtration accessories, each providing a different utility
to the end user. As defined in the test procedure final rule, a pool
filter pump either includes a basket strainer or requires a basket
strainer for operation. A basket strainer is a specific component that
the test procedure final rule defines as ``a perforated or otherwise
porous receptacle that prevents solid debris from entering a pump, when
mounted within a housing on the suction side of a pump. The basket
strainer receptacle is capable of passing spherical solids of 1 mm in
diameter, and can be removed by hand or with simple tools. Simple tools
include but are not limited to a screwdriver, pliers, and an open-ended
wrench.'' The basket strainer provides a direct utility to the pool
filter pump end user, as it protects the pump from debris that would
otherwise enter the impeller and cause damage to the pump. However,
this utility comes at the cost of pump efficiency. The basket strainer
has head-loss associated with it, which means a measurable amount of
hydraulic power is lost as water traverses the basket strainer and the
basket strainer housing. Ultimately, this reduces efficiency for pumps
that include or require a basket strainer, compared to those that do
not. Based on this relationship between end-user utility and achievable
efficiency, DOE concludes that the presence of or requirement for a
basket strainer is an appropriate feature to differentiate and
establish pool filter pump equipment classes (including standard-size
and small-size self-priming pool filter pumps, non-self-priming pool
filter pumps, and waterfall pumps).
Typically, if a pool utilizes a pool filter pump, the filtration of
particulates less than 1mm in diameter takes place in a separate
filtration device, which is either installed separately from the pump,
or is attached to the pump and may be removed using simple tools.
Alternatively, integral cartridge filter and integral sand filter pump
varieties include a filtration accessory, designed to remove
particulates less than 1mm in diameter, which is integrally and
permanently mounted to the pump. These integral filter pump varieties
are typically distributed in commerce with a storable pool (e.g.,
inflatable or collapsible pools) or as a replacement pump for such a
pool. These storable pools are intended for temporary or seasonal use,
and their application and
[[Page 5668]]
usage profile are unique from other dedicated-purpose pool pump
varieties. The end user is required to assemble the pump and pool at
the beginning of the season and disassemble the pump and pool for
storage at the end of the season. Combining the pump and filtration
equipment into one integral piece of equipment enables the user to
assemble, disassemble, and store the equipment more easily than if the
pump and filter were separate components. Thus, the integral nature of
the filtration accessory provides utility to the end user.
Similar to the basket strainer, the integral filtration accessory
has head-loss associated with it, which means a measurable amount of
hydraulic power is lost as water traverses the integral filtration
accessory. However, due to the finer filtering capability of the
integral filtration accessory (designed to remove particulates less
than 1 mm in diameter), the integral filtration accessory will
experience a larger head-loss than a comparably sized strainer basket.
Ultimately, this translates to a reduced efficiency for integral
cartridge filter and integral sand filter pool pumps, as compared to
similarly sized pool filter pumps and other pumps not requiring a
basket strainer. Based on this relationship between end-user utility
and achievable efficiency, DOE concludes that the presence of an
integral filtration accessory is an appropriate feature to
differentiate and establish integral pump equipment classes (including
integral cartridge filter and integral sand filter pumps).
The two specific varieties of integral filter pumps (integral
cartridge and integral sand) offer different utility to end users. Sand
filter pumps typically weigh more (when filled with sand media), but
require less ongoing intervention and attention by the end user than
cartridge filters. However, integral sand filter pool pumps typically
have a greater head-loss across the filtration accessory than integral
cartridge filter pool pumps. Ultimately, this translates to a reduced
efficiency for integral sand filter pumps, compared to integral
cartridge filter pumps. Based on this relationship between end-user
utility and achievable efficiency, DOE concludes that the variety of
integral filtration accessory (sand filter versus cartridge filter) is
an appropriate feature to differentiate integral pumps into two
equipment classes, integral cartridge and integral sand filter pumps.
b. Self-Priming Ability
All pool filter pumps on the market are either self-priming or non-
self-priming. The test procedure final rule defines a self-priming pool
filter pump as, ``a pool filter pump that is certified under NSF/ANSI
50-2015 to be self-priming or is capable of re-priming to a vertical
lift of at least 5 feet with a true priming time less than or equal to
10 minutes, when tested in accordance with NSF/ANSI 50-2015.'' Self-
priming pumps are able to lift liquid that originates below the
centerline of the pump inlet and, after initial manual priming, are
able to subsequently re-prime without the use of external vacuum
sources, manual filling, or a foot valve. In contrast, non-self-priming
pumps must be re-primed in order to operate after an idle period. This
re-priming may be achieved by manually filling the pump with water, or
re-priming may be induced by placing the pump at a lower vertical
height than the surface of the water it will pump. The self-priming
capability of a pool filter pump affects typical applications for which
the pump is appropriate, and thus the utility to the end user. For
example, typical inground pool constructions consist of a pump at
ground level (above the water level), and main and skimmer drains below
the water level. In this configuration, when the pump is cycled off
(which will typically happen during the day), prime is lost. A self-
priming pump provides the end user with the ability to restart the pump
(typically using a timer) without any need for manual intervention.
Alternatively, a non-self-priming pump would require the end user to
manually refill the pump casing (re-prime) the pump, each time the end
user wanted to restart the pump.
To achieve self-priming capability, self-priming pumps are
constructed in a different manner than non-self-priming pumps.
Specifically, self-priming pool filter pumps typically incorporate
diffusers and reservoirs that work together to remove air from the
suction side of the pump and regain the prime after an idle period.
Prime is achieved by recirculating water that is trapped in the
reservoir. The water in the pump mixes with air entering the pump from
the suction line, and that mixture is discharged back into the
reservoir, where air is released out of the pump discharge. Once all of
the air is removed from the suction line, the pump is primed. However,
once the self-priming pump is primed and running, the diffuser and
reservoir configuration, by design, results in significant water
recirculation within the bare pump, compared to a non-self-priming
pump, where there is less internal recirculation. Internal water
recirculation means that a portion of the hydraulic output of the pump
is recirculated back to the reservoir of the pump, and is not
immediately discharged out of the pump; as such, recirculation reduces
the efficiency of the pump. Based on this relationship between end-user
utility and achievable efficiency, DOE concludes that self-priming
capability is an appropriate feature to differentiate equipment classes
(self-priming versus non-self-priming pool filter pumps).\27\
---------------------------------------------------------------------------
\27\ More information on the construction and capabilities of
self-priming and non-self-priming pumps is available at Hayward
Industries' Web page of frequently asked questions. In particular,
the descriptions of inground and aboveground pump operations discuss
priming. These descriptions are available at: https://www.hayward-pool.com/shop/en/pools/faqs#q188, and at https://www.hayward-pool.com/shop/en/pools/faqs#q192.
---------------------------------------------------------------------------
c. Pump Capacity (Flow, Head, and Power)
The capacity of a dedicated-purpose pool pump can be expressed
using measurements of head, flow, and hydraulic power. These three
parameters define the useful output to the end user and are
interrelated and bound by the Equation 2:
[GRAPHIC] [TIFF OMITTED] TR18JA17.003
Where:
Phydro = hydraulic power (hp)
Q = volumetric flow (gpm), and
H = total dynamic head (feet of water)
The requirements of a pool (or any water system), can be expressed
in terms of a system curve. When a pump is tested on a system curve
(such as
[[Page 5669]]
curve C),\28\ any one of these three measurements can be used to
calculate the other two measurements. Equation 3 and Equation 4
illustrate this relationship.
---------------------------------------------------------------------------
\28\ The test procedure final rule contains a detailed
discussion of the system curves used in pump testing.
[GRAPHIC] [TIFF OMITTED] TR18JA17.004
---------------------------------------------------------------------------
Where:
QCurveC = volumetric flow on system curve C (gpm) and
HCurveC = head on system curve C (feet of water)
[GRAPHIC] [TIFF OMITTED] TR18JA17.005
Where:
Phydro,CurveC = hydraulic power on system curve C (hp)
In this direct final rule, in agreement with DPPP Working Group
recommendations, DOE is subdividing self-priming pool filter pumps into
two equipment classes based on capacity, or more specifically,
hydraulic horsepower at maximum speed on curve C (which is also
referred to as rated hydraulic horsepower in test procedure final
rule).
During meetings, some DPPP Working Group members commented that
small pool filter pumps are inherently more efficient than large pool
filter pumps, and the group considered introducing a breakpoint to
divide the self-priming pool filter pump variety into two equipment
classes based on capacity. (Docket No. EERE-2015-BT-STD-0008-0101, May
19 DPPP Working Group Meeting, at pp. 78-87) Initially, several DPPP
Working Group members proposed to set this breakpoint at a level such
that pumps rated above 0.75 thp would fall in a larger equipment class.
(Docket No. EERE-2015-BT-STD-0008-0091, June 22 DPPP Working Group
Meeting, at pp. 44-50) DPPP manufacturers commented that pumps rated
below 1.0 thp make up a small portion of total pool filter pump
shipments, and manufacturers proposed a higher breakpoint for the
equipment classes, at a hydraulic horsepower corresponding to 1.25 thp.
(Docket No. EERE-2015-BT-STD-0008-0091, June 22 DPPP Working Group
Meeting, at pp. 54) To aid discussion, DPPP manufacturers provided pool
filter pump shipment data to DOE's contractor and DOE presented
aggregated shipment data to the DPPP Working Group. The aggregated
shipment data showed that approximately 10 percent of pool filter pump
shipments are rated below 1.0 thp and approximately 5 percent of pool
filter pump shipments are rated below 0.75 thp. (Docket No. EERE-2015-
BT-STD-0008-0092, June 23 DPPP Working Group Meeting, at pp. 233-239)
Based on these shipment data, the DPPP Working Group agreed on a
recommendation to set the breakpoint between small-size and standard-
size self-priming pool filter pumps at 0.711 hhp, so that most of the
currently available pool filter pumps rated at 1.0 thp and below would
fall below the 0.711-hhp breakpoint. (Docket No. EERE-2015-BT-STD-0008-
0092, June 23 DPPP Working Group Meeting, at pp. 276-277; No. 82
Recommendation #1 at p. 1) Equation 4 dictates that 0.711 hhp
corresponds to a flow rate of 70 gpm on curve C.
As discussed earlier in this subsection, pump capacity may also be
considered in terms of pump head (or total dynamic pressure). In this
direct final rule, DOE is distinguishing waterfall pump equipment from
other pool filter pump varieties using head limitations. Specifically,
as discussed by the DPPP Working Group, pumps used in waterfall
applications do not need to produce high heads because waterfall pumps
are typically not connected to pool circulation plumbing or to
ancillary pool components like heaters and chlorinators (Docket No.
EERE-2015-BT-STD-0008-0056, December 7 DPPP Working Group Meeting, at
p. 237). Therefore, the DPPP Working Group recommended distinguishing
the waterfall pump equipment class by establishing a maximum pump head
of 30 feet (inclusive) for the waterfall pump equipment class. (Docket
No. EERE-2015-BT-STD-0008, No. 51 Recommendation #4 at p. 3)
Finally, in this direct final rule, DOE is distinguishing pressure
cleaner booster pumps from other pumps based on their unique flow and
head output. DPPP Working Group members asked whether pressure cleaner
booster pumps would be covered by the energy conservation standard for
general pumps. DOE clarified that the pressure cleaner booster pumps
would not be covered by the general pumps standard since the general
pumps standard has a lower bound of 25 gpm at the pump's best
efficiency point, and the best efficiency point of pressure cleaner
booster pumps is typically less than 25 gpm. (Docket No. EERE-2015-BT-
STD-0008-0058, October 19 Working Group Meeting, at pp. 76-81) As
discussed by the DPPP Working Group, pressure cleaner booster pumps
must provide a high amount of head at a low flow rate to propel
pressure-side pool cleaners along the bottom of the pool and to remove
debris as the cleaner moves. Specifically, pressure-side pool cleaners
(and associated piping and hoses) require a pump that provides at least
60 feet of head at approximately 10 gpm of flow; noting that the actual
head requirements vary with each specific system, but will not
typically be lower than 60 feet of head. (Docket No. EERE-2015-BT-STD-
0008, March 22 Working Group Meeting, at pp. 207-210) Figure IV.1
illustrates the performance of four
[[Page 5670]]
pressure cleaner booster pump models from the three largest
manufacturers (representing the majority of the pressure cleaner
booster pump market) and highlights the range of head and flow rates
for which these pumps are currently designed.
[GRAPHIC] [TIFF OMITTED] TR18JA17.006
Although the pumps in Figure IV.1 all provide between 100 and 127
feet of head at 10 gpm, the DPPP Working Group concluded that certain
systems require less head (down to 60 feet of head). DPPP Working Group
members expressed a desire that the test procedure allow better ratings
for variable-speed pressure cleaner pumps that are able to reduce speed
and energy consumption to avoid supplying (and wasting) excess pressure
beyond what is required to drive the cleaner. (Docket No. EERE-2015-BT-
STD-0008-0101, May 19 Working Group Meeting, at pp. 49) The DPPP
Working Group recommended that, for the test procedure, pressure
cleaner booster pumps be evaluated at the lowest speed that can achieve
60 feet of head at a flow rate of 10 gpm. (Docket No. EERE-2015-BT-STD-
0008, No. 82 Recommendation #8 at pp. 4) Consequently, DOE has
concluded that the aforementioned capacity range provides a specific
utility to the consumer, or end user, and is therefore appropriate to
use as the basis for distinguishing pressure cleaner booster pumps from
other pump equipment classes.
d. Rotational Speed
For dedicated-purpose pool pumps, DOE has determined that
rotational speed is not a sufficient differentiator to establish an
equipment class without adding specific utility. However, the DPPP
Working Group recommended DOE define waterfall pumps as ``a pool filter
pump with maximum head less than or equal to 30 feet, and a maximum
speed less than or equal to 1,800 rpm'' and establish an equipment
class for this variety of pool filter pump (Docket No. EERE-2015-BT-
STD-0008, No. 44, Recommendation #4 at p. 3). Waterfall pumps are used
in applications with low head and high flow requirements; i.e.,
applications that require ``flat'' head versus flow performance curves.
This is because waterfall pumps are not typically plumbed through a
filter or other auxiliary equipment, and thus do not have a large
amount of head to overcome.
Pumps running at 1,800 rpm typically exhibit the fairly flat head
versus flow operating curve that is usually required by waterfall
applications. Figure IV.2 illustrates this property in contrast to the
steeper head-versus-flow curves that are typical for self-priming pool
filter pumps.
[[Page 5671]]
[GRAPHIC] [TIFF OMITTED] TR18JA17.007
Due to the inherent curve shape of 1,800 rpm pumps, this rotational
speed limitation in conjunction with the 30-foot head limitation serves
to establish a capacity differentiation. The limitations recommended by
the DPPP Working Group effectively categorize a set of pumps with
similar performance curves (heads, flows, and hydraulic horsepowers)
into one equipment class--waterfall pumps. Figure IV.3 illustrates this
phenomenon.
[[Page 5672]]
[GRAPHIC] [TIFF OMITTED] TR18JA17.008
e. End User Safety
Pressure cleaner booster pumps share many similar design features
with end suction close-coupled pumps. However, dedicated-purpose pool
pumps (including pressure cleaner booster pumps) must specifically
consider the safety of the pool operator (typically a homeowner or
renter) in their design (e.g., reduced electrocution or injury risk).
To do so, the dedicated-purpose pool pump industry relies on the safety
requirements established in the voluntary standard ANSI/UL 1081-2014,
``Standard for Swimming Pool Pumps, Filters, and Chlorinators.'' \29\
Based on DPPP Working Group discussion, DOE concludes that most pool
filter pumps and all pressure cleaner booster pumps comply with and are
currently listed to ANSI/UL 1081-2014. Conversely, general purpose end
suction close-coupled pumps are typically installed in commercial and
industrial applications and do not need to account for the same
specific safety concerns. Differences in safety consideration result in
differences in design choices that ultimately affect the performance of
the pump. Consequently, DOE concludes that safety considerations are
appropriate features to differentiate pressure cleaner booster pumps
from end suction close-coupled pumps.
---------------------------------------------------------------------------
\29\ ANSI/UL 1081-2014 is available for purchase at http://ulstandards.ul.com/standard/?id=1081_6.
---------------------------------------------------------------------------
f. List of Proposed Equipment Classes
Based on the performance-related features and distinguishing
characteristics described from section IV.A.1.a to section IV.A.1.d,
DOE is establishing the following equipment classes, listed in Table
IV-1 and Table IV-2:
Table IV-1--DOE Equipment Classes for Pool Filter Pumps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Pump capacity
Strainer or filtration accessory Priming capability ---------------------------------------------- Rotational speed Equipment class
Pump power Pump head designation
--------------------------------------------------------------------------------------------------------------------------------------------------------
Basket strainer................... Self-priming......... <2.5 hhp, >0.711 hhp. n/s *................ n/s *............... Self-priming pool filter
<=0.711 hhp.......... n/s*................. n/s*................ pump, standard-size.
Self-priming pool filter
pump, small-size.
Non-self-priming..... <2.5 hhp............. n/s *................ n/s *............... Non-self-priming pool
filter pump.**
n/s *................ n/s *................ <=30 ft.............. <=1800 rpm.......... Waterfall pump.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* n/s indicates not specified.
** DOE analyzed non-self-priming pool filter pumps as two equipment classes: Extra-small (less than 0.13 hhp) and standard-size (less than 2.5 hhp and
greater than 0.13 hhp). These two equipment classes were ultimately merged into one after DOE selected the same efficiency level for both extra-small
and standard-size non-self-priming pool filter pumps.
[[Page 5673]]
Table IV-2--DOE Equipment Classes for Other Dedicated-Purpose Pool Pumps
------------------------------------------------------------------------
Distinguishing feature(s) Equipment class designation
------------------------------------------------------------------------
Integrated cartridge filter............... Integral cartridge filter
pool pump.
Integrated sand filter.................... Integral sand filter pool
pump.
Capacity (designed and Pressure cleaner booster
marketed for pressure-side pool pump.
cleaner applications).
End User Safety (UL listed
under ANSI/UL 1081-2014).
------------------------------------------------------------------------
2. Manufacturers and Industry Structure
Manufacturers of dedicated-purpose pool pumps can be categorized
into two distinct segments: (1) Those that primarily offer pool filter
pumps greater than 0.40 hhp and varieties of auxiliary pumps such as
waterfall and pressure cleaner booster pumps, (the pool filter pump
industry) and (2) those that offer integral filter pumps and pool
filter pumps smaller than 0.40 hhp, but not other auxiliary pumps (the
integral filter pump industry). The former typically offers larger
self-priming pool filter pumps, non-self-priming pool filter pumps,
waterfall pumps, and pressure cleaner booster pumps. The latter
typically offers very small pool filter pumps, as well as integral
cartridge and sand filter pumps that are sold as a package with a
seasonal pool, or as a replacement for a pump sold with a seasonal
pool. DOE is unaware of any manufacturers that participate in both
segments. Consequently, the two categories are discussed separately.
In the pool filter pump industry, DOE identified 17 manufacturers.
Of the 17, DOE found that three large manufacturers hold approximately
90 percent of the market in terms of equipment shipments: Hayward
Industries, Inc.; Pentair Aquatic Systems; and Zodiac Pool Systems,
Inc. These manufacturers primarily produce equipment at manufacturing
facilities in the United States. The remaining 10 percent of the market
is held by AquaPro Systems; Aquatech Corp.; Asia Connection LLC;
Bridging China International, Ltd.; Carvin Pool Equipment, Inc.; ECO
H2O Tech, Inc.; Fluidra USA, LLC; Hoffinger Industries; Raypak; Speck
Pumps; SpectraLight Technologies; Waterway Plastics, Inc.; Waterco
Ltd.; and Wayne Water Systems.
DOE identified four manufacturers in the integral filter pump
industry: Bestway (USA), Inc.; Great American Merchandise and Events
(GAME); Intex Recreation Corp.; and Polygroup. Based on public records
found in Hoovers,\30\ DOE determined that all four manufacturers are
U.S.-based entities. During the DPPP Working Group meeting on April 19,
2016, DOE presented the assumption that none of the integral cartridge
and integral sand filter pumps are manufactured domestically. (See
EERE-2015-BT-STD-0008-0067, at p. 104) When this information was
presented to the DPPP Working Group, there were no objections to this
assumption. (Docket No. EERE-2015-BT-STD-0008-0079, April 19 Working
Group Meeting, at pp. 132-134) DOE therefore concludes that all
manufacturers in the integral filter pump industry produce equipment
abroad and import it for sale in the United States.
---------------------------------------------------------------------------
\30\ Hoovers Inc., Company Profiles, Various Companies
(Available at www.hoovers.com/).
---------------------------------------------------------------------------
3. Existing Efficiency Programs
DOE reviewed several existing and proposed regulatory and voluntary
energy conservation programs for pool pumps. These programs are
described in the following sections.
a. U.S. State-Level Programs
The CEC first issued standards for residential pool pumps under the
California Code of Regulations (CCR) 2006.\31\ See 20CCR section 1601-
1608 (2013). The CEC standards (or similar variations) were
subsequently adopted by a number of other states.\32\ The CEC's
regulations cover all residential pool pump and motor combinations,
replacement residential pool pump motors, and portable electric spas.
---------------------------------------------------------------------------
\31\ California Energy Commission. ``Appliance Efficiency
Regulations.'' December 2006. CEC-400-2006-002-REV2. Available at
www.energy.ca.gov/2006publications/CEC-400-2006-002/CEC-400-2006-002-REV2.PDF.
\32\ See, e.g. Ariz. Rev. Stat. Sec. 44-1375 (2015);
Conn.Agencies Regs. Sec. 16a-48.4 (2015); Fla. Stat. Ann. Sec.
533.909 (2015); and Wash. Rev. Code Ann. Sec. 19.260.040 (2015).
---------------------------------------------------------------------------
The CEC's current standard (amended in 2008) has prescriptive
design requirements, rather than performance-based regulations for
residential pool pump and motor combinations. See 20CCR section
1605.3(g)(5). The CEC defines ``residential pool pump and motor
combination'' as a residential pool pump motor coupled to a residential
pool pump. ``Residential pool pump'' is defined as an impeller attached
to a motor that is used to circulate and filter pool water in order to
maintain clarity and sanitation. ``Residential pool pump motor'' refers
to a motor that is used as a replacement residential pool pump motor or
as part of a residential pool pump and motor combination. (Motors used
in these applications are electrically driven.) The CEC imposes a
design standard that prohibits the use of split-phase start \33\ and
capacitor-start-induction-run \34\ motor designs in residential pool
pump motors manufactured on or after January 1, 2006. (Id. section
1605.3(g)(5)(A)) The CEC also requires that residential pool pump
motors with a motor capacity \35\ of 1 hp or greater manufactured on or
after January 1, 2010, have the capability of operating at two or more
speeds. The low speed must have a rotation rate that is no more than
one-half of the motor's maximum rotation rate, and must be operated
with an applicable multi-speed pump control. (Id. section
1605.3(g)(5)(B))
---------------------------------------------------------------------------
\33\ Defined as: A motor that employs a main winding with a
starting winding to start the motor. After the motor has attained
approximately 75 percent of rated speed, the starting winding is
automatically disconnected by means of a centrifugal switch or by a
relay. 20 CCR1602(g).
\34\ Defined as: A motor that uses a capacitor via the starting
winding to start an induction motor, where the capacitor is switched
out by a centrifugal switch once the motor is up to speed. 20
CCR1602(g).
\35\ Defined as a value equal to the product of motor's
nameplate hp and service factor and also referred to a ``total hp,''
where ``service factor (of an AC motor)'' means a multiplier which,
when applied to the rated hp, indicates a permissible hp loading
which can be carried under the conditions specified for the service
factor. 20 CCR 1602(g).
---------------------------------------------------------------------------
The CEC also prescribes design requirements for pump controls. Pump
motor controls that are manufactured on or after January 1, 2008, and
are sold for use with a pump that has two or more speeds are required
to be capable of operating the pool pump at a minimum of two speeds.
The default circulation speed setting shall be no more than one half of
the motor's maximum rotation rate, and high speed overrides should be
temporary and not for a period exceeding 24 hours. (Id. section 1605.3
(g)(5)(B)) \36\
---------------------------------------------------------------------------
\36\ California Energy Commission, 2014 Appliance Efficiency
Regulations, available at www.energy.ca.gov/2014publications/CEC-400-2014-009/CEC-400-2014-009-CMF.pdf.
---------------------------------------------------------------------------
In addition to these prescriptive design requirements, the CEC also
requires manufacturers of residential pool pump and motor combinations
and
[[Page 5674]]
manufacturers of replacement residential pool pump motors \37\ to
report certain data regarding the characteristics of their certified
equipment. This includes information necessary to verify compliance
with the requirements of Section 1605.3(g)(5), as well as the tested
flow and input power of the equipment at several specific load points.
Manufacturers must also submit the pool pump and motor combinations'
energy factor (EF) in gallons per watt-hour (gal/Wh) when tested in
accordance with the specified test procedure for residential pool
pumps. See 20CCR 1604(g)(3).
---------------------------------------------------------------------------
\37\ Defined as a replacement motor intended to be coupled to an
existing residential pool pump that is used to circulate and filter
pool water in order to maintain clarity and sanitation. Cal. Code
Regs., tit. 20, Sec. 1602, subd. (g).
---------------------------------------------------------------------------
The CEC is considering revising its pool pump regulations. A recent
CEC report \38\ proposes updated regulations for all single-phase
dedicated-purpose pool pump motors under 5 total horsepower \39\ (thp).
This report recommends that pool pump motors be covered regardless of
whether they are sold with a new pump, or sold as replacement for use
with an existing pump wet-end. The report recommends a timer
requirement for integral filter pool pumps, and a requirement for
freeze protection for pool filter pumps. Additionally, the report
recommends that the CEC move to performance-based standards, rather
than prescriptive design standards. The prescriptive standards that
exist under the 2008 rule prohibit the use of certain motor
technologies, and the 2016 proposal would allow these previously-
prohibited technologies as long as they meet minimum efficiency
standards. Using the modified CSA C747-09 test procedure, the CEC
recommends that single-speed motors less than 0.5 thp use motors that
are at least 70 percent efficient. Single-speed pumps greater than or
equal to 0.5 thp and less than 1 thp must use motors that are at least
75 percent efficient. Variable-, multi-, and two-speed pumps greater
than or equal to 1 and less than or equal to 5 thp must use motors with
nameplate efficiency of at least 80 percent efficient at full speed and
at least 65 percent efficient at half speed.\40\ The CEC presented
portions of this report that are related to dedicated-purpose pool
pumps to the DPPP Working Group. Members of the DPPP Working Group
asked clarifying questions to confirm that with the proposed changes
(1) California's reporting requirements for pumps will not change, (2)
previously disallowed motor types would be allowed, provided they meet
the minimum CEC motor efficiency requirements. (Docket No. EERE-2015-
BT-STD-0008-0091, June 22 Working Group Meeting, at pp. 6-12) The DPPP
Working Group had no further comments or objections. DOE also notes
that the DPPP CEC regulations are preempted following the compliance
date of this DFR.
---------------------------------------------------------------------------
\38\ Revised Analysis of Efficiency Standards for Pool Pumps and
Motors, and Spas--Draft Staff Report, June 2016. Available at http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER-02/TN211842_20160616T124038_Revised_Analysis_of_Efficiency_Standards_for_Pool_Pumps_and_Mot.pdf.
\39\ Total hp is the product of motor service factor and motor
nameplate (rated) hp.
\40\ Revised Analysis of Efficiency Standards for Pool Pumps and
Motors, and Spas--Draft Staff Report. http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER-02/TN211842_20160616T124038_Revised_Analysis_of_Efficiency_Standards_for_Pool_Pumps_and_Mot.pdf.
---------------------------------------------------------------------------
b. Voluntary Standards
In response to the May 2015 DPPP RFI, APSP recommended that ``DOE
should rely on and reference, or recite the applicable language from
the ANSI/APSP/ICC-15 2013 standard for residential swimming pool and
spa energy efficiency.'' (Docket. No. EERE-2015-BT-STD-0008, APSP, No.
10 at p. 2) In response DOE thoroughly reviewed the 2013 version of the
American National Standards Institute (ANSI), APSP, and the
International Code Council (ICC) published standard ANSI/APSP/ICC-15a-
2013, ``American National Standard for Residential Swimming Pool and
Spa Energy Efficiency.'' Similar to the CEC's current standard (amended
in 2008), ANSI/APSP/ICC-15a-2013 has prescriptive design requirements,
rather than performance-based regulations for residential pool pump and
motor combinations. This voluntary standard prohibits split-phase,
shaded-pole, or capacitor start-induction run motors in dedicated-
purpose pool pumps, with the exception of motors that are powered
exclusively by onsite electricity generation from renewable energy
sources. The standard also requires that pool pump motors with a
capacity of 1.0 total horsepower or greater have the capability of
operating at two or more speeds, with the low speed having a rotation
rate that is no more than one-half of the motor's maximum rotation
rate. Ultimately, for the reasons discussed throughout this document,
DOE is adopting a mix of performance-based and prescriptive standards
that differ from those established in ANSI/APSP/ICC-15a-2013. DOE notes
that five members of APSP (Waterway Plastics, Hayward Industries, Inc.,
Zodiac Pool Systems, Inc., Pentair Aquatic Systems, and Bestway USA,
Inc.) participated in the DPPP Working Group and unanimously supported
the term sheet that serves as the basis for the standards established
in this direct final rule. (EERE-2015-BT-STD-0008, No. 51)
4. Shipments Information
DOE gathered annual DPPP shipment data from two general sources:
(1) Veris Consulting and PK Data; and (2) interviews with individual
manufacturers that were conducted under non-disclosure agreements with
DOE's contractors.\41\ The Veris Consulting and PK Data information
included industrywide shipment information for certain dedicated-
purpose pool pump varieties. This data was previously aggregated by
Veris Consulting and PK Data for use within the industry, DOE gathered
and aggregated shipments information for all varieties of dedicated-
purpose pool pump, specifically for this rulemaking. DOE used both
sources to shape its initial shipment estimates. These shipments
estimates were presented to the DPPP Working Group throughout the
negotiation process and were revised based on the group's feedback.
---------------------------------------------------------------------------
\41\ In developing standards, DOE may choose to contract with
third party organizations who specialize in various functions.
---------------------------------------------------------------------------
DOE's final estimates of historical shipments by equipment class
are shown in Table IV-3. The estimates show that the shipments of all
classes of dedicated-purpose pool pumps have increased over the past 5
years. In 2015, the shipments of self-priming pool filter pumps were
nearly double the shipments of non-self-priming pool filter pumps.
Waterfall pumps made up a small portion of the industry, less than 0.5
percent of total shipments in 2015. Since 2013, the integral cartridge
filter and integral sand filter pump classes have totaled over one
million shipments per year.
[[Page 5675]]
Table IV-3--Estimates of Historical Dedicated-Purpose Pool Pump Shipments, by Equipment Class
[Thousands]
----------------------------------------------------------------------------------------------------------------
Equipment class 2011 2012 2013 2014 2015
----------------------------------------------------------------------------------------------------------------
Self-Priming Pool Filter Pump, 543.8 561.1 578.9 597.3 616.3
standard-size..................
Self-Priming Pool Filter Pump, 70.6 72.8 75.1 77.5 80.0
small-size.....................
Non-Self-Priming Pool Filter 329.0 339.5 350.2 361.4 372.9
Pump...........................
Waterfall Pump.................. 8.8 9.1 9.4 9.7 10.0
Pressure Cleaner Booster Pump... 121.6 123.3 125.0 126.8 128.6
Integral Cartridge Filter Pool 843.2 860.4 878.0 895.9 914.2
Pump...........................
Integral Sand Filter Pool Pump.. 130.3 133.0 135.7 138.4 141.3
----------------------------------------------------------------------------------------------------------------
5. Market and Industry Trends
DOE gathered data on DPPP market and industry trends. Several of
DOE's observations and conclusions are noted in the following sections.
a. Equipment Efficiency
DOE assembled a Pool Pump Performance Database that describes the
capacity, speed configuration, and estimated efficiency of the majority
of dedicated-purpose pool pumps that are available on the market.\42\
Using data from the database, Table IV-4 lists the ranges of efficiency
that are available for the different speed configurations of standard-
size self-priming pool filter pumps. In terms of total annual energy
consumption, standard-size self-priming pool filter pumps are the
largest equipment class covered by this rulemaking.\43\
---------------------------------------------------------------------------
\42\ See section IV.C.1.a for more information regarding the
Pool Pump Performance Database.
\43\ The self-priming pool filter pump equipment class is
defined in section IV.A.1 of this document.
Table IV-4--Ranges of Dedicated-Purpose Pool Pump Efficiency Available
for Standard-Size Self-Priming Pool Filter Pumps
------------------------------------------------------------------------
Speed configuration of self-priming Efficiency range available in
pool filter pump, standard-size (0.711 the pool pump performance
to 2.5 hydro hp) database WEF
------------------------------------------------------------------------
Single-Speed........................... 1.81 to 3.73 kgal/kWh.
Two-speed.............................. 3.41 to 5.45 kgal/kWh.
Variable-Speed......................... 5.81 to 10.25 kgal/kWh.
------------------------------------------------------------------------
The engineering analysis, found in section IV.C of this document,
provides a full discussion of DPPP efficiency data for all of the
equipment classes, from the lowest performing pump available on the
market to the highest performing pump that is technologically feasible.
b. Pump Sizing
Based on manufacturer interviews, DOE concluded that approximately
76 percent of the installed base of dedicated-purpose pool pumps are
single-speed and two-speed pumps that use single-phase induction
motors. These pumps come in a wide range of nominal horsepower ratings.
Single-phase induction motor pumps are typically available in a wide
variety of nominal horsepower ratings, such as 0.5 hp, 0.75 hp, 1 hp,
1.5 hp, 2 hp, 2.5 hp, and 3 hp, as well as other ratings above, below,
and in between. This variety gives a pump installation contractor the
ability to select a pump that is appropriately sized for the
application. The contractor can make this decision based on the volume
of water the pump needs to circulate (related to the pool volume) and
the head that the pump needs to overcome (related to the piping and
ancillary pool equipment such as heaters and chlorinators).
The remainder of the installed base of dedicated-purpose pool pumps
are variable-speed pool pumps that use electronically commutating
motors (ECMs) or other variable-speed motor technologies. These
variable-speed pumps are typically only available in a small number of
nominal horsepower ratings, such as 1.65 hp, 2.40 hp, 2.70 hp, and 3.45
hp. Due to the limited number of nominal horsepower ratings available,
it is common for variable-speed dedicated-purpose pool pumps to be
oversized for their application, when evaluated at maximum speed
capability. A variable-speed pump can be programmed by the installer or
end user to operate at an appropriate speed that is less than 100
percent.
6. Technology Options
This section describes the technology options that can be used to
reduce the energy consumption of DPPP equipment. The technology options
are divided into two categories: Options relevant to DPPP equipment
classes that are analyzed for performance standards (e.g., varieties of
pool filter pumps, pressure cleaner booster pumps, and waterfall pumps)
and options relevant to DPPP equipment classes that are analyzed for
prescriptive standards (e.g., integral cartridge filter pool pumps and
integral sand filter pool pumps).
In the May 2015 RFI, DOE requested comments on technology options
that could be considered to improve the energy efficiency of dedicated-
purpose pool pumps. 80 FR 26483 (May 8, 2015). APSP commented that
APSP-15 and California Title 20 capture many of the technology options
that are available to the industry. APSP asked DOE to reference these
programs. (APSP, No. 10 at p. 13) The following technologies are
described in the APSP and California standards:
APSP-15 and California Title 20 identify motor performance
as a technology option to reduce energy consumption, and both standards
prohibit the sale of pool pumps that incorporate particular motor
constructions. See ANSI/APSP/ICC-15a-2013, section 4.1.1.1; and 20CCR
section 1605.3 (g)(5)(A).
APSP-15 and California Title 20 identify two-speed, multi-
speed, and variable-speed pumps as a technology to reduce energy
consumption. See ANSI/
[[Page 5676]]
APSP/ICC-15a-2013, section 4.1.1.2; and 20CCR section 1605.3 (g)(5)(B).
APSP-15 requires a time switch or similar control
mechanism to control the pool pump's operation schedule. See ANSI/APSP/
ICC-15a-2013, section 5.3.3.
Based on the DPPP Working Group's review of the APSP and California
standards and independent research, DOE identified three technology
options that can be used to reduce the energy consumption of the DPPP
equipment classes for which performance standards were being analyzed
(i.e., self-priming pool filter pumps, non-self-priming pool filter
pumps, pressure cleaner booster pumps, and waterfall pumps).
Specifically, those performance standard technology options are:
Improved motor efficiency;
ability to operate at reduced speeds; and
improved hydraulic design.
DOE identified one technology option, a pool pump timer, which
could be used to reduce the energy consumption of the DPPP equipment
classes for which prescriptive standards were being analyzed (i.e.,
integral cartridge filter pool pumps and integral sand filter pool
pumps).
The DPPP Working Group reviewed both sets of technology options
(Docket No. EERE-2015-BT-STD-0008-0053, November 12 DPPP Working Group
Meeting, at pp. 51-78; Docket No. EERE-2015-BT-STD-0008-0094, March 21
DPPP Working Group Meeting, at pp. 37-38) and offered no objections to
DOE's approach. The DPPP Working Group ultimately evaluated standards
based on efficiency levels determined by these options.
Each technology option is addressed separately in the sections that
follow.
a. Improved Motor Efficiency
Different varieties (or constructions) of motors have different
achievable efficiencies. Two general motor constructions are present in
dedicated-purpose pool pump market: Single-phase induction motors and
electronically commutated motors (ECMs).\44\ Single-phase induction
motors may be further differentiated and include split phase,
capacitor-start induction-run (CSIR), capacitor-start capacitor-run
(CSCR), and permanent split capacitor (PSC) motors.
---------------------------------------------------------------------------
\44\ Three-phase induction motors also are found on certain
self-priming pool filter pumps; however this motor construction is
specifically excluded from the scope of this rulemaking for self-
priming pool filter pumps (as described in section III.C).
---------------------------------------------------------------------------
The majority of pool filter pumps available on the market come
equipped with single-phase induction motors. According to manufacturer
interviews, very few pool filter pumps on the market use split phase or
CSIR motors. This is partly due to the regulatory prohibition of these
motor constructions in California and other states. Most pool filter
pumps on the market use CSCR or PSC motors; both have similar
attainable efficiencies, although CSCR motors are typically able to
provide greater starting torque.
ECMs are typically used in variable-speed pool filter pump
applications. However, induction motors, coupled to a proper variable
speed drive, can also be used in variable-speed pool filter pump
applications. ECMs are inherently more efficient than single-phase
induction motors because their construction minimizes slip losses
between the rotor and stator components. Unlike single-phase induction
motors, ECMs require an electronic drive to function. This electronic
drive consumes electricity, and variations in drive losses and
mechanical designs lead to a range of ECM efficiencies.
As part of the engineering analysis (section IV.C), DOE assessed
the range of attainable motor efficiency for certain representative
motor capacities and constructions. As motor capacity increases, the
attainable efficiency of the motor at full load also increases. Higher
horsepower motors also operate close to their peak efficiency for a
wider range of loading conditions.\45\ Table IV-5 presents these
ranges, based on nameplate (or nominal) motor efficiencies listed in
the Pool Pump Performance Database. Motor efficiency data submitted by
pump and motor manufacturers to DOE confirms the ranges reported in
this table.
---------------------------------------------------------------------------
\45\ U.S. DOE Building Technologies Office. Energy Savings
Potential and Opportunities for High-Efficiency Electric Motors in
Residential and Commercial Equipment. December 2013. Prepared for
the DOE by Navigant Consulting. pp. 4. Available at http://energy.gov/sites/prod/files/2014/02/f8/Motor%20Energy%20Savings%20Potential%20Report%202013-12-4.pdf.
Table IV-5--Ranges of Nameplate Motor Efficiencies Reported for Three Capacities of Self-Priming Pool Filter
Pumps
----------------------------------------------------------------------------------------------------------------
Range of full speed motor nameplate
Hydraulic horsepower on efficiencies reported in the pool pump
curve C of a typical performance database, by motor construction *
Motor total horsepower (thp) * dedicated-purpose pool (%) *
pump with this motor -----------------------------------------------
CSCR [dagger] PSC [dagger] ECM [dagger]
----------------------------------------------------------------------------------------------------------------
0.75................................... 0.44 64-79 51-75 77
1.35................................... 0.95 65-81 61-78 78-86
3.45................................... 1.88 75-81 74-82 77-92
----------------------------------------------------------------------------------------------------------------
* The three pump capacities described in this table align with the representative unit capacities that are
defined in section IV.C.2 and used throughout the engineering analysis in section IV.C.
** Neither split phase nor CSIR motors are listed in this table because no self-priming pool filter pumps in the
Pool Pump Performance Database utilize these motor types.
[dagger] Members of the DPPP Working Group stated that there may be small errors in the motor nameplate
efficiency data reported for pumps in the CEC database that DOE incorporated into the Pool Pump Performance
Database. (Docket No. EERE-2015-BT-STD-0008-0056, December 7 DPPP Working Group Meeting, at pp. 38-40).
DPPP manufacturers do not typically manufacture motors inhouse.
Instead, they purchase complete or partial motors from motor
manufacturers and/or distributors. As such, improving the nameplate
motor efficiency of the pump is typically achieved by swapping a less
efficient purchased motor component for a more efficient one.
b. Ability To Operate at Reduced Speeds
Self-Priming and Non-Self-Priming Pool Filter Pumps
Self-priming and non-self-priming pool filter pumps at or above
49.4 gpm
[[Page 5677]]
max flow on curve C can achieve a higher (more favorable) WEF value if
they have the ability to operate at reduced speeds. As discussed
previously in section III.C, the WEF metric is a weighted average of
energy factors, measured at one or more test points. The DPPP test
procedure allows WEF values for two-, multi-, and variable-speed pumps
to be calculated as the weighted average of performance at both high
and reduced speeds, while WEF for single-speed pumps is calculated
based only on performance at high speed. Due to pump affinity laws,
most pumps will achieve higher energy factors at lower rotational
speeds, compared to higher rotational speeds. As such, the WEF
efficiency metric confers benefits on pool filter pumps that are able
to operate at reduced rotational speeds.
Specifically, pump affinity laws describe the relationship of pump
operating speed, flow rate, head, and hydraulic power. According to the
affinity laws, speed is proportional to flow such that a relative
change in speed will result in a commensurate change in flow, as
described in Equation 5. The affinity laws also establish that pump
total head is proportional to speed squared, as described in Equation
6, and pump hydraulic power is proportional to speed cubed, as
described in Equation 7.
[GRAPHIC] [TIFF OMITTED] TR18JA17.009
[GRAPHIC] [TIFF OMITTED] TR18JA17.010
[GRAPHIC] [TIFF OMITTED] TR18JA17.011
Where:
Q1 and Q2 = volumetric flow rate at two operating points
H1 and H2 = pump total head at two operating points
N1 and N2 = pump rotational speed at two operating points
P1 and P2 = pump hydraulic power at two operating points
This means that a pump operating at half speed will provide one
half of the pump's full-speed flow and one eighth of the pump's full-
speed power.\46\ However, pump affinity laws do not account for changes
in hydraulic and motor efficiency that may occur as a pump's rotational
speed is reduced. Typically, hydraulic efficiency and motor efficiency
will be reduced at lower operating speeds. Consequently, at reduced
speeds, power consumption is not reduced as drastically as hydraulic
output power. Even so, the efficiency losses at low-speed operation are
typically outweighed by the exponential reduction in hydraulic output
power at low-speed operation; this results in a higher (more
beneficial) energy factor at low speed operation.
---------------------------------------------------------------------------
\46\ A discussion of reduced-speed pump dynamics is available at
https://www.regulations.gov/document?D=EERE-2015-BT-STD-0008-0099.
---------------------------------------------------------------------------
Self-priming and non-self-priming pool filter pumps with a two-
speed motor configuration that produce less than 49.4 gpm maximum flow
on curve C cannot achieve higher WEF score through reduced speed
operation. This is because the test procedure final rule specifies two
load points for two-speed self-priming and non-self-priming pool filter
pumps--one at 100 percent of maximum speed and one 50 percent of
maximum speed. Further, the test procedure final rule specifies that
the lower of the two load points cannot be below 24.7 gpm, and that the
pump will be tested at the ``lowest speed capable of meeting the
specified flow and head values.'' Consequently, a two-speed pump that
delivers less than 49.4 gpm of flow at maximum speed on curve C would
deliver less than 24.7 gpm of flow at half of the maximum, which mean
the half-speed setting would not be considered in the calculation of
the pump's WEF.\47\ Such a two-speed pump would effectively be tested
as a single-speed pump.
---------------------------------------------------------------------------
\47\ The DOE DPPP test procedure final rule specifies that flow
be measured to the nearest tenth of a gpm.
---------------------------------------------------------------------------
Self-priming and non-self-priming pool filter pumps with a
variable- or multi-speed motor configuration that produce less than
49.4 gpm max flow on curve C could conceivably achieve a higher WEF
score through reduced speed operation. However, DOE did not apply the
``ability to operate at reduced speeds'' technology option to pumps
that provide less than 49.4 gpm at maximum speed on curve C. A flow of
49.4 gpm at maximum speed on curve C is equivalent to a hydraulic power
of 0.25 hhp; such a pump would typically require a motor shaft power of
approximately 0.60 horsepower. Comparatively, the smallest currently
available variable-speed pool pump motor is 1.65 thp. Due to the
mismatch in physical size and performance of such a wet end and motor
combination, DOE concludes that it is not technologically feasible to
pair a 1.65-thp motor with a pump wet end that provides only 49.4 gpm
at maximum speed on curve C. For this reason, DOE's analysis assumes
that that the design option described as ``ability to operate at
reduced speeds'' does not apply to self-
[[Page 5678]]
priming or non-self-priming pool filter pumps that are below 49.4 gpm
at maximum speed on curve C.
Pressure Cleaner Booster Pumps
In the field, pressure cleaner booster pumps are only operated at
one speed and therefore the test procedure final rule specifies only
one load point for testing pressure cleaner booster pumps. However, the
test procedure final rule specifies that pressure cleaner booster pumps
are tested at the lowest speed that can achieve 60 feet of head at the
10 gpm test condition. Consequently, a pressure cleaner booster pump
can see benefits from the ability to operate at reduced speeds as the
pump may vary its speed to achieve this load point.\48\ For instance, a
pressure cleaner booster pump equipped with a variable-speed motor may
produce more than 60 feet of head when operated at maximum speed at the
10 gpm test point. Such a pump could be tested at a reduced speed that
produces exactly 60 feet of head at 10 gpm, while consuming less power
than it would at maximum speed. In this case, testing at a reduced
speed would result in a higher (more beneficial) WEF value.
---------------------------------------------------------------------------
\48\ The DPPP Working Group requested that DOE examine variable-
speed pumps as a design option for pressure cleaner booster pumps.
(Docket No. EERE-2015-BT-STD-0008-0095, March 22 DPPP Working Group
Meeting, at pp. 197-203)
---------------------------------------------------------------------------
Waterfall Pumps
The test procedure final rule specifies that waterfall pumps are
only tested at 100 percent speed. Consequently, waterfall pumps cannot
achieve a higher (more beneficial) WEF value if they have the ability
to operate at reduced speeds. Consequently, DOE did not consider the
``ability to operate at reduced speeds'' as a technology option for the
waterfall pump equipment class.
c. Improved Hydraulic Design
The performance characteristics of a pump, such as flow, head, and
efficiency, are a direct result of the pump's hydraulic design. For
purposes of the DOE analysis, ``hydraulic design'' is a broad term DOE
used to describe the system design of the wetted components of a pump.
Although hydraulic design focuses on the specific hydraulic
characteristics of the impeller and the volute/casing, it also includes
design choices related to bearings, seals, and other ancillary
components.
Impeller and volute/casing geometries, clearances, and associated
components can be redesigned to a higher efficiency (at the same flow
and head) using a combination of historical best practices and modern
computer-aided design (CAD) and analysis methods. The wide availability
of modern CAD packages and techniques now enables pump designers to
more quickly reach designs with improved vane shapes, flow paths, and
cutwater designs, all of which work to improve the efficiency of the
pump as a whole.
Self-Priming Pool Filter Pumps
For self-priming pool filter pumps, DOE used empirical data from
the Pool Pump Performance Database to estimate the potential efficiency
gains available from improved hydraulic design. DOE used hydraulic
power, line input power, and nameplate motor efficiency to estimate the
hydraulic efficiency of these pumps and to observe the range of
hydraulic efficiencies available for self-priming pool filter pumps at
pump capacities less than 2.5 hhp. For any given capacity less than 2.5
hhp, DOE found that the best hydraulic efficiency of self-priming pool
filter pumps at maximum speed on curve C could be 116.2 percent of the
baseline hydraulic efficiency. Chapter 3 of the direct final rule TSD
contains more details regarding the hydraulic improvements estimated
for self-priming pool filter pumps.
Non-Self-Priming Pool Filter Pumps
For non-self-priming pool filter pumps, DOE attempted to follow a
similar methodology to self-priming pumps. While DOE's Pool Pump
Performance Database contains few records of non-self-priming pool
filter pumps, these records were sufficient to establish a baseline
hydraulic efficiency, which DOE identified as 51.5 percent. In the May
2015 DPPP RFI, DOE requested information regarding the magnitude of
efficiency improvements available from any potential technology
options. 80 FR 26483 (May 8, 2015). DOE did not receive public comment
regarding the range of hydraulic efficiency improvements that are
available to pool filter pumps. With limited data, DOE was not able to
use this database to empirically identify the maximum hydraulic
efficiency that is technologically feasible, nor estimate the range of
hydraulic efficiency improvements that are available to non-self-
priming pool filter pumps.
Instead, DOE referred to empirical data gathered during the 2016
general pumps \49\ rulemaking. During the general pumps rulemaking, DOE
estimated the maximum technologically feasible hydraulic efficiency for
end suction, close-coupled pumps as a function of flow and specific
speed.\50\ For this dedicated-purpose pool pumps direct final rule, DOE
evaluated a 0.52-hhp, end suction, close-coupled pump that is optimized
for curve-C flow and head using equations from the general pumps
rulemaking analysis, and found that such a pump can achieve a hydraulic
efficiency of up to 69.7 percent.\51\ This pump has a configuration
that is nearly identical to a non-self-priming pool filter pump, with
the exception that non-self-priming pool filter pumps are defined by
the presence (or requirement of) a basket strainer. As discussed in
section IV.A, the addition of a basket strainer and strainer housing
reduce a pump's hydraulic efficiency by a measurable amount. Based on
discussions with pump industry professionals, the impact may be in the
range of 1 to 3 points of hydraulic efficiency. Consequently, DOE
conservatively established a maximum hydraulic efficiency of 67 percent
for non-self-priming pool filter pumps. This represents an improvement
of 30 percent over the baseline hydraulic efficiency. At the April 18,
2016, Working Group meeting, DOE presented the DPPP Working Group with
values for motor efficiency and wire-to-water efficiency of
representative units at each efficiency level. This data enables the
calculation of hydraulic efficiency, since wire-to-water efficiency
equals the product of motor efficiency multiplied by hydraulic
efficiency. (Docket No. EERE-2015-BT-STD-0008-0078, April 18, 2016 DPPP
Working Group Meeting, at p. 20-30) At subsequent meetings, DOE
presented max tech wire-to-water efficiency results, based on the
aforementioned 67 percent hydraulic efficiency. DPPP Working Group
members offered no objections to DOE's hydraulic efficiency
assumptions. The DPPP Working Group ultimately evaluated standards
based on efficiency levels determined by these assumptions. (Docket No.
EERE-2015-BT-STD-
[[Page 5679]]
0008-0100, May 18 DPPP Working Group Meeting, at p. 140-149) Chapter 3
of the direct final rule TSD contains more details regarding the
hydraulic improvements estimated for non-self-priming pool filter
pumps.
---------------------------------------------------------------------------
\49\ The pumps energy conservation standard rulemaking docket
EERE-2011-BT-STD-0031 contains all notices, public comments, public
meeting transcripts, and supporting documents pertaining to this
rulemaking.
\50\ Specific speed is a dimensionless index describing the
geometry of a pump impeller and provides an indication of the pump's
pressure/flow ratio at the pump's best efficiency point. For more
details, see chapter 3 of the general pumps rulemaking final rule
TSD, at https://www.regulations.gov/document?D=EERE-2011-BT-STD-0031-0056.
\51\ See the discussion of efficiency levels for general pumps
equipment in the general pumps final rule TSD, available at
www.regulations.gov/document?D=EERE-2011-BT-STD-0031-0056. In
particular, DOE calculates the standard pump efficiency
[eta]STD of 69.7% for the max-tech level of the ESCC.3600
equipment class at a flow rate Q of 63 GPM, a constant C of 125.3,
and a specific speed, NS, of 2,760.
---------------------------------------------------------------------------
Pressure Cleaner Booster Pumps
DOE's contractor received motor specifications and test data for
pressure cleaner booster pumps from manufacturers, which DOE used to
calculate the total pump efficiency and the hydraulic efficiency for
several pumps at the pressure cleaner booster pump test point of 10 gpm
flow. DOE found that the best available hydraulic efficiency of
pressure cleaner booster pumps, at the test point of 10 gpm, could be
112.2 percent of the baseline hydraulic efficiency. Chapter 3 of the
direct final rule TSD contains more details regarding the hydraulic
improvements estimated for pressure cleaner booster pumps.
Waterfall Pumps
DOE's contractor used manufacturer-supplied motor specifications
and test data for waterfall pumps to calculate the total pump
efficiency and the pump hydraulic efficiency for several pumps at the
waterfall pump test point of 17 feet of head. DOE found that the best
available hydraulic efficiency of waterfall pumps at this test point
could be 111.5 percent of the baseline hydraulic efficiency. Chapter 3
of the direct final rule TSD contains more details regarding the
hydraulic improvements estimated for waterfall pumps.
d. Pool Pump Timer
Pool pump timers can reduce the energy consumed by dedicated-
purpose pool pumps by reducing the number of hours that the pump is
operated unnecessarily.
Many smaller-size pools do not require a dedicated-purpose pool
pump to operate 24 hours per day to achieve the desired turnover of
pool water. DOE initially surveyed recommendations for pool turnover
rates collected by the Consortium for Energy Efficiency.\52\ DOE stated
that California recommends one turnover every 12 to 14 hours. (EERE-
2015-BT-STD-0008-0059, October 20 DPPP Working Group Meeting, at p. 88)
Several members of the DPPP Working Group commented that the California
recommendation cited by DOE pertains to commercial pools, and that the
pool industry recommends one turnover per day for residential
applications. (EERE-2015-BT-STD-0008-0059, October 20 DPPP Working
Group Meeting, at p. 134-135; EERE-2015-BT-STD-0008-0053, November 12
DPPP Working Group Meeting, at p. 134) DOE only considered the pool
pump timer design option for the integral cartridge filter pump and
integral sand filter pump equipment classes. Pump models in these
equipment classes are marketed exclusively to residential end users.
Therefore, DOE assumed that the pool pump timer design option applies
only to pumps that must provide a minimum of one turnover per day. In
support of the DPPP Working Group, DOE reviewed the integral pump
products on the market and the pool volumes that they are recommended
to service. DOE concluded that, when paired with the appropriate size
pool, integral filter pumps should achieve one turnover in 8 hours or
less. If a pool pump timer turned off the pump after 10 hours, DOE
concluded that it would have allowed at least one full turnover to
occur (thus meeting the industry recommendation for daily turnovers and
maintaining end user utility), and it would prevent the pump for
running unnecessarily for the remainder of the day.
---------------------------------------------------------------------------
\52\ Consortium for Energy Efficiency. 2012. ``CEE High
Efficiency Residential Swimming Pool Initiative.'' Boston, MA.
https://library.cee1.org/sites/default/files/library/9986/cee_res_swimmingpoolinitiative_07dec2012_pdf_10557.pdf.
---------------------------------------------------------------------------
DOE initially suggested that a pool pump timer be defined as a pool
pump control that automatically turns a dedicated-purpose pool pump on
and off based on a pre-programmed user-selectable schedule. (Docket No.
EERE-2015-BT-STD-0008-0101, May 19 Working Group Meeting, at pp. 112)
In response, Bestway requested that the pool pump timer be defined
instead as a type of countdown timer, where the end user turns on the
pump, the pump runs for a set amount of time, and then the pump shuts
off automatically and remains off until the end user starts the pump
again. (Docket No. EERE-2015-BT-STD-0008-0101, May 19 Working Group
Meeting, at pp. 39-40) Bestway commented that this style of timer is
what currently exists in the market for integrated cartridge and
integrated sand filter pumps. (Docket No. EERE-2015-BT-STD-0008-0101,
May 19 Working Group Meeting, at pp. 124-125)
DOE also asked the DPPP Working Group whether end users should be
able to program the run time of the pool pump timer or whether the pool
pump timer should ship with a preprogrammed run-time that cannot be
adjusted by the end user. (Docket No. EERE-2015-BT-STD-0008-0101, May
19 Working Group Meeting, at pp. 113-115) The DPPP Working Group
clarified that integrated cartridge filter pumps and integrated sand
filter pumps are typically sold in a package with the pool that they
are meant to service, so the pump run-time necessary to achieve one
turnover may be determined prior to sale based upon the relative sizes
of the pump and the pool. (Docket No. EERE-2015-BT-STD-0008-0101, May
19 Working Group Meeting, at pp. 116-117) Therefore, the Working Group
agreed that there would be little benefit to allowing end users to
modify the pump run-time that the pool pump timer allows.
The DPPP Working Group also discussed whether end users might be
burdened by a pool pump timer that cannot automatically turn on a pump,
since end users would be required to initiate the pump operation on a
daily basis to maintain a sanitary pool. Bestway commented that the
burden, if any, on the end user to activate their pump on a daily basis
would be minimal. (Docket No. EERE-2015-BT-STD-0008-0101, May 19
Working Group Meeting, at pp. 116-119) A DPPP Working Group member
speculated that if an end user were to leave their home for a week, a
simple countdown timer would not be able to activate the pump on a
daily basis to maintain sanitary pool conditions while the end user is
away. Bestway commented that the pool pump timer definition Bestway
proposed does not prevent manufacturers from offering a pool pump timer
with automatic start and stop functionality. Bestway commented that,
with their proposed definition, manufacturers could offer more advanced
timers as a selling feature for their pumps. (Docket No. EERE-2015-BT-
STD-0008-0101, May 19 Working Group Meeting, at pp. 119-121)
The DPPP Working Group voted, and did not reach consensus on a pool
pump timer definition that included automatic on-off functionality and
user-selectable scheduling. (Docket No. EERE-2015-BT-STD-0008-0101, May
19 Working Group Meeting, at pp. 124) Instead, the DPPP Working Group
voted to recommend defining a pool pump timer to mean a pool pump
control that automatically turns off a dedicated-purpose pool pump
after a run-time of no longer than 10 hours. (EERE-2015-BT-STD-0008,
No. 82 Recommendation #4 at p. 2) DOE agrees with this reasoning and is
adopting the definition recommended by the DPPP Working Group in this
direct final rule.
B. Screening Analysis
DOE uses the following four screening criteria to determine which
technology options are suitable for further
[[Page 5680]]
consideration in an energy conservation standards rulemaking:
1. Technological feasibility. Technologies that are not
incorporated in commercial products or in working prototypes will not
be considered further.
2. Practicability to manufacture, install, and service. If it is
determined that mass production and reliable installation and servicing
of a technology in commercial products could not be achieved on the
scale necessary to serve the relevant market at the time of the
projected compliance date of the standard, then that technology will
not be considered further.
3. Impacts on product utility or product availability. If it is
determined that 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 be
considered further.
4. Adverse impacts on health or safety. If it is determined that a
technology would have significant adverse impacts on health or safety,
it will not be considered further.
See 10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b).
Technologies that pass through the screening analysis are referred
to as ``design options'' in the engineering analysis. The screening
analysis and engineering analysis are discussed in detail,
respectively, in chapters 4 and 5 of the direct final rule TSD.
1. Screened-Out Technologies
Of the identified technology options, DOE was not able to identify
any that would fail the screening criteria.
2. Remaining Technologies
After reviewing each technology, DOE concluded that all of the
identified technologies listed in section IV.A.6 met all four screening
criteria to be examined further as design options in DOE's analysis. In
summary, DOE continued its analysis for the following technology
options:
improved motor efficiency
ability to operate at reduced speeds
improved hydraulic design
pool pump timers
DOE determined that these technology options are technologically
feasible because they are being used or have been used in commercially
available products or working prototypes. DOE also found that these
technology options met the other screening criteria (i.e., practicable
to manufacture, install, and service; and do not result in adverse
impacts on consumer utility, equipment availability, health, or
safety). For additional details, see chapter 4 of the direct final rule
TSD.
C. Engineering Analysis
In the engineering analysis, DOE describes the relationship between
manufacturer production cost (MPC) and improved DPPP efficiency. This
relationship serves as the basis for cost-benefit calculations for
individual end users, manufacturers, and the Nation. The following
sections describe methods DOE used to conduct the engineering analysis.
1. Summary of Data Sources
For the engineering analysis, DOE used two principal data sources:
(1) The Pool Pump Performance Database; and (2) the manufacturer
production cost dataset. The following subsections provide a brief
description of each data source. Complete details are found in chapter
5 of the direct final rule TSD.
a. Pool Pump Performance Database
DOE assembled a database of pool pump performance data by
collecting current and archived records of pool pump performance from
public databases maintained by the CEC,\53\ APSP,\54\ and the ENERGY
STAR program.\55\ The Pool Pump Performance Database also includes
historic records from prior CEC database versions, which were provided
to DOE by stakeholders. These historic records include pumps that met
previous CEC efficiency standards but do not meet the current CEC
standards.
---------------------------------------------------------------------------
\53\ Appliance Efficiency Database: Public Search, California
Energy Commission. Available at https://cacertappliances.energy.ca.gov/Pages/ApplianceSearch.aspx.
\54\ Energy Efficiency Pool Pumps, APSP. Available at http://apsp.org/resources/energy-efficient-pool-pumps.aspx.
\55\ ENERGY STAR Certified Pool Pumps. Available at
www.energystar.gov/productfinder/product/certified-pool-pumps/results.
---------------------------------------------------------------------------
The CEC, APSP, and ENERGY STAR databases contain third-party test
data that manufacturers submit as a means of certifying their pump
equipment to the relevant entity's standards. The database records
contain pump performance information such as motor horsepower, flow and
head on pump performance curves, and pump speed configuration. DOE
added records to the database based on pump data published in
manufacturer specification sheets. These specification sheets typically
publish motor horsepower and performance curves but they do not
typically provide information regarding the pump's electrical
performance or efficiency.
DOE filtered the collected data to remove duplicate entries,
entries that only represented a replacement motor (but no pump), and
entries with incomplete data. To allow for easier analysis, DOE
combined and reformatted the databases into a user-friendly format. DOE
performed a regression analysis to estimate the part-load efficiencies
of variable-speed pumps at the test points specified in the test
procedure final rule. DOE then calculated the WEF value of each pump
record in the database, according to the calculation method described
in section III.C. Chapter 5 of the direct final rule TSD contains more
detail regarding the regression analysis and the calculation of WEF
values.
b. Manufacturer Production Cost Dataset
DOE collected MPC and performance data from manufacturers for pool
pumps and motors across a range of capacities and equipment classes.
Data collected for individual DPPP models included the nominal
horsepower and efficiency of the pump motor; the MPC of the motor and
the finished pump; and the efficiency, flow rate, head, and input power
of the pump at full load and partial loads.
DOE also collected retail price data for DPPPs and replacement
motors sold by the online retailers Leslie's Swimming Pool
Supplies,\56\ INYO Pools,\57\ and Pool Supply World.\58\ These retail
price data are publicly available on each retailer's Web site. DOE
estimated MPCs for various pump models using this retail price data and
several assumptions about supply chain markups (see section IV.D for a
discussion of markups). DOE primarily used this retail price data
analysis to supplement and validate the individual MPCs submitted by
manufacturers.
---------------------------------------------------------------------------
\56\ www.lesliespool.com/.
\57\ www.inyopools.com/.
\58\ www.poolsupplyworld.com/.
---------------------------------------------------------------------------
2. Representative Equipment
For the engineering analysis, DOE analyzed the MPC-efficiency
relationships for the equipment classes specified in section IV.A.1.
Generally, the manufacturing cost and the attainable efficiency of
dedicated-purpose pool pumps vary as a function of pump capacity (i.e.,
hydraulic horsepower). Because it is impractical to assess the MPC-
efficiency relationship
[[Page 5681]]
for all dedicated-purpose pool pump capacities available on the market,
DOE selected a set of representative units to analyze. These
representative units exemplify typical capacities in each equipment
class and are used to quantify the manufacturing costs and the energy
savings potential for each equipment class. In general, to determine
representative capacities for each equipment class, DOE analyzed the
distribution of available models and/or shipments and discussed its
finding with the DPPP Working Group. The following subsections discuss
each equipment class in further detail.
a. Self-Priming Pool Filter Pumps
The scope of this direct final rule includes self-priming pool
filter pumps with capacities less than 2.5 hhp at maximum speed on
curve C. As described in section IV.A.1.c of this document, the DPPP
Working Group recommended that this range be subdivided into two
equipment classes, with a breakpoint of 0.711 hhp. This breakpoint
divides the range of self-priming pool filter pumps into a standard-
size equipment class and a small-size equipment class. DOE used
shipment distributions provided by manufacturers, distributions of
models listed in the Pool Pump Performance Database, and feedback from
the DPPP Working Group to select representative capacities for these
equipment classes.
For the standard-size self-priming pool filter pumps, DOE selected
two representative units, with 1.88 hhp and 0.95 hhp. At the baseline
efficiency level (discussed further in section IV.C.3), a 1.88-hhp pump
and a 0.95-hhp pump require 3.0 hp and 1.6 hp shaft input power from
the motor, respectively. Typically, these pumps are equipped with
motors rated between 3.5-3.9 thp and 1.7-2.2 thp, respectively.
b. Non-Self-Priming Pool Filter Pumps
For the small-size self-priming pool filter pump equipment class,
DOE selected one representative unit with hydraulic horsepower of 0.44
hhp. DOE reviewed an initial selection of representative units with the
DPPP Working Group. (Docket No. EERE-2015-BT-STD-0008-0078, April 18
DPPP Working Group Meeting, at pp. 12-19) The DPPP Working Group
recommended a break point capacity of 0.711 hhp to separate the small-
and standard-size self-priming pool filter pump equipment classes (see
section IV.A.1.c for discussion of this break point). DOE revised the
capacities of the representative units after this break point was
introduced, to include a representative capacity of 0.44 hhp for the
small size self-priming pool filter pump equipment class.
The scope of this direct final rule also includes non-self-priming
pool filter pumps with capacities less than 2.5 hhp at maximum speed on
curve C. However, the majority of non-self-priming pool filter pump
models on the market deliver less than 1.0 hhp at maximum speed on
curve C. Accordingly, the representative capacities DOE used to analyze
the non-self-priming pool filter pump equipment class were different
from the representative capacities used to analyze the self-priming
pool filter pump equipment classes. Specifically, DOE selected two
representative capacities for non-self-priming pool filter pumps, 0.52
hhp and 0.09 hhp at maximum speed on curve C. The smaller unit (at 0.09
hhp) is representative of pumps that are typically sold with (or as
replacements for) seasonal pools. These pumps are typically distributed
in commerce on a skid with a sand filter, where the pump and the sand
filter are connected with removable hoses. The larger representative
unit (at 0.52 hhp) is representative of pumps that are typically sold
for applications where the pump is installed and operated below the
waterline of the pool that it services, such as in aboveground pool
applications. These pumps are typically distributed in commerce as
standalone pumps. DOE presented the larger representative capacity (at
0.52 hhp) and the smaller representative capacity (at 0.09 hhp) to the
DPPP Working Group. (Docket No. EERE-2015-BT-STD-0008-0078, April 18
DPPP Working Group Meeting, at pp. 27-29; and Docket No. EERE-2015-BT-
STD-0008-0091, June 22 DPPP Working Group Meeting, at pp. 115-118) The
DPPP Working Group did not offer any opposition to the selected
representative capacities and ultimately evaluated standards based on
the analysis of these representative capacities.
c. Pressure Cleaner Booster Pumps
The pressure cleaner booster pumps on the market are clustered in a
small range of capacities. For this equipment class, DOE selected a
capacity that is representative of the cluster of models on the market.
Specifically, DOE selected a representative capacity of 10 gpm of
flow and 112 feet of head, which equates to 0.28 hhp. Ten gpm aligns
with the testing load point specified in the test procedure final rule
for pressure cleaner booster pumps. The DPPP Working Group recommended
that pressure cleaner booster pumps be tested at the load point of 10
gpm and a head greater than 60 feet, to represent the typical pressure
cleaner booster pump operation.\59\ (Docket No. EERE-2015-BT-STD-0008,
No. 82 Recommendation #8 at pp. 4-5)
---------------------------------------------------------------------------
\59\ The DPPP Working Group initially recommended that pressure
cleaner booster pumps be tested at 90 feet of head and a volumetric
flow rate that corresponds to 90 feet of head. (Docket No. EERE-
2015-BT-STD-0008, No. 51 Recommendation #6 at pp. 5) However, the
DPPP Working Group discussed that the minimum pressure requirement
to drive a pressure cleaner is approximately 60 feet of head.
(Docket No. EERE-2015-BT-STD-0008-0095, March 22 Working Group
Meeting, at pp. 207-210) ASAP expressed a desire that the test
procedure allow better ratings for variable-speed pressure cleaner
pumps that are able to reduce speed to avoid supplying (and wasting)
excess pressure beyond what is required to drive the cleaner.
(Docket No. EERE-2015-BT-STD-0008-0101, May 19 Working Group
Meeting, at pp. 49) The DPPP Working Group subsequently revised its
recommendation to recommend that pressure cleaner booster pumps be
tested at a flow rate of 10 gpm and the minimum head the pump can
achieve that is greater than or equal to 60 feet. (Docket No. EERE-
2015-BT-STD-0008, No. 82 Recommendation #8 at pp. 4)
---------------------------------------------------------------------------
At 10 gpm, the pressure cleaner booster pump models from the three
largest manufacturers (representing the majority of the pressure
cleaner booster pump market) all achieve a similar head in a range from
100 feet to 127 feet of head. To represent the average performance of
the pressure cleaner booster pump models available on the market, DOE
selected a head value of 112 feet as the value the representative unit
would achieve at the test condition of 10 gpm.
d. Waterfall Pumps
The waterfall pumps on the market are clustered in a small range of
capacities. For this equipment class, DOE selected a capacity that is
representative of the cluster of models on the market. Specifically,
DOE selected a representative capacity of 93 gpm of flow and 17 feet of
head, which equates to 0.40 hhp. Seventeen feet of head aligns with the
testing load point specified in the test procedure final rule for
pressure cleaner booster pumps. The DPPP Working Group recommended the
testing load point of 17 feet of head (and flow corresponding to 17
feet of head on the pump curve) to represent the typical waterfall pump
operation. (Docket No. EERE-2015-BT-STD-0008, No. 51 Recommendation #6
at p. 5)
e. Integral Sand and Cartridge Filter Pool Pump
In this direct final rule, DOE is establishing a prescriptive
design standard, rather than a performance standard, for integral sand
and cartridge filter pool pumps. The DPPP Working
[[Page 5682]]
Group considered two alternatives for this analysis: (1) A prescriptive
standard that would require a timer for integrated cartridge and
integrated sand filter pumps, and (2) a performance standard that would
likely be achieved through the use of advanced motors. To help evaluate
these alternatives, DOE developed cost-efficiency relationships for
integrated cartridge and integrated sand filter pool pumps that
describe (1) the use of a timer on all pumps, and (2) the use of
advanced motors where possible. The DPPP Working Group reviewed these
cost-efficiency relationships. DPPP Working Group members commented
that a prescriptive standard requiring a timer may be economically
justified, but that a performance standard with advanced motors would
not be economically justified. A DPPP Working Group member commented
that a prescriptive standard requiring a timer may not be beneficial
because some end users may choose to disable or circumvent the timer
mechanism. DOE clarified that the analytical results will account for
such instances of misuse, since the rulemaking analysis of a
prescriptive standard takes into account that a certain percentage of
end users may not use the prescribed technology properly. (Docket No.
EERE-2015-BT-STD-0008-0053, November 12 DPPP Working Group Meeting, at
pp. 45-78)
As such, in the test procedure final rule, DOE did not establish a
test method for these equipment classes. However, as a part of this
direct final rule, DOE still evaluated the incremental MPC-efficiency
relationship for the prescriptive standard. To do so, DOE established
representative models based on performance characteristics of these
pumps on system curve C.
DOE examined model availability in the integral sand and cartridge
filter pool pumps and selected one representative equipment capacity
(0.03 hhp at maximum speed on curve C) for integral sand filter pool
pumps, and two representative equipment capacities (0.02 hhp and 0.18
hhp at maximum speed on curve C) for integral cartridge filter pool
pumps. The DPPP Working Group reviewed the representative equipment
capacities for integral filter pumps and offered no objections. (Docket
No. EERE-2015-BT-STD-0008-0094, March 21 DPPP Working Group Meeting, at
pp. 54-58)
f. Summary of Representative Units
DOE's representative dedicated-purpose pool pump capacities are
summarized in Table IV-6.
Table IV-6--Characteristics of Representative Units, by Equipment Class
----------------------------------------------------------------------------------------------------------------
Performance at test point at 100% speed
DPPP equipment class Test point -----------------------------------------------
Power hhp Head feet Flow gpm
----------------------------------------------------------------------------------------------------------------
Self-priming pool filter pump, Curve C................. 1.88 76.8 96.8
standard-size.
Curve C................. 0.95 48.7 77.1
Self-priming pool filter pump, small- Curve C................. 0.44 29.2 59.7
size.
Non-self-priming pool filter pump..... Curve C................. 0.52 32.6 63.1
Curve C................. 0.09 10.1 35.1
Pressure cleaner booster pump......... 10 gpm flow............. 0.28 110.0 10.0
Waterfall pump........................ 17 ft. head............. 0.40 17.0 93.0
Integral sand filter pool pump........ n/a *................... 0.03 4.9 24.4
Integral cartridge filter pool pump... n/a *................... 0.18 16.1 44.3
n/a *................... 0.02 3.7 21.3
----------------------------------------------------------------------------------------------------------------
** DOE did not establish a test procedure for integral sand filter pool pumps or integral cartridge filter pool
pumps, because these equipment classes are not subject to performance standards. However, the performance
reported for integral pumps in this table is measured on curve C.
3. Baseline Configuration and Performance
The baseline configuration defines the lowest efficiency equipment
in each analyzed equipment class. DOE established baseline
configurations by reviewing the configurations and performance of pumps
listed in the Pool Pump Performance Database. DOE determined that, for
pool filter pumps (including all sub-varieties) and pressure cleaner
booster pumps, the baseline configuration has the following
characteristics:
single-speed
low-efficiency motor
low hydraulic efficiency
To determine an appropriate level of performance for each
representative pool filter pump unit at the baseline, DOE identified
pumps in the Pool Pump Performance Database that have similar hydraulic
capacity to the representative units, and that share the baseline
equipment characteristics. DOE adopted the estimated WEF values of
these identified pumps as the baseline performance level for each
representative unit. Pressure cleaner booster pumps and waterfall pumps
are not listed in the Pool Pump Performance Database. Manufacturers
provided test data for several models of pressure cleaner booster pumps
and waterfall pumps, and these test data enabled DOE to estimate the
performance of representative units at the baseline.
The baseline configuration for integral filter pumps for which
prescriptive standards were considered is characterized by median
performance and lack of a timer mechanism.
Table IV-7 summarizes the baseline configurations and performance
levels for the representative units used in this analysis. These
baseline configurations ultimately define the energy consumption and
associated costs for the lowest efficiency equipment analyzed in each
equipment class.
Table IV-7--Baseline Configurations and Performance for DPPP
Representative Units
------------------------------------------------------------------------
Baseline
DPPP representative unit Baseline performance
configuration WEF
------------------------------------------------------------------------
Self-priming pool filter pump, Single-speed, low 1.74
1.88 hhp. efficiency motor,
low hydraulic
efficiency.
Self-priming pool filter pump, 2.13
0.95 hhp.
[[Page 5683]]
Self-priming pool filter pump, 2.69
0.44 hhp.
Non-self-priming pool filter pump, 2.77
0.52 hhp.
Non-self-priming pool filter pump, 3.93
0.09 hhp.
Pressure cleaner booster pump..... 0.34
Waterfall pump.................... 7.46
Integral sand filter pool pump.... No timer............ n/a
Integral cartridge filter pool n/a
pump, 0.18 hhp.
Integral cartridge filter pool n/a
pump, 0.02 hhp.
------------------------------------------------------------------------
Chapter 5 of the direct final rule TSD describes the process that
DOE used to select the baseline configuration for each equipment class
and discusses the baseline in greater detail.
4. Efficiency Levels
For each equipment class, DOE established and analyzed a set of
efficiency levels above the baseline configuration to assess the
relationship between MPC and DPPP efficiency. These efficiency levels
are discrete tiers of energy efficiency that can be represented by the
WEF test metric.
a. Design Option Applicability and Ordering
For pool filter pump varieties, DOE considered incremental
improvements that could be applied to the baseline configuration; these
improvements are related to the three design options discussed in
section IV.A.6: (1) Improved motor efficiency, (2) ability to operate
at reduced speeds, and (3) improved hydraulic design.
Specifically, for the ``improved motor efficiency'' design option,
DOE considered three tiers or motor efficiency (low, medium, and high
efficiency) for both single-speed and two-speed pump motors. The
specific nameplate motor efficiency associated with these tiers varied
by pump variety and capacity. For the ``ability to operate at reduced
speeds'' design option, DOE considered three motor speed
configurations: Single-speed, two-speed, and variable-speed. Finally,
for the ``improved hydraulic design'' design option, DOE considered two
hydraulic efficiencies (low and high efficiency). The specific
hydraulic efficiencies associated with these tiers varied by pump
variety and capacity.
For pressure cleaner booster pumps, DOE evaluated the same design
options as pool filter pumps. However, DOE did not consider two-speed
motors because pressure cleaner booster pumps only operate at one speed
and cannot benefit from the ability to switch between two discrete
speeds. Alternatively, DOE did consider variable-speed motors for
pressure cleaner booster pumps, as the WEF metric accounts for energy
savings available from adjusting the pump speed to reach the minimum
required pressure, i.e., 60 feet.
For waterfall pumps, DOE evaluated the same improved motor
efficiency and improved hydraulic efficiency design options as pool
filter pumps, but did not evaluate the ability to operate at reduced
speeds. This is because DOE determined that waterfall pumps only
operate at one speed and therefore cannot benefit from the ability to
switch speeds.
To order the design options for each equipment class, DOE
considered all of the costs (both incremental MPCs and one-time product
conversion costs) that would be incurred with each design option. Based
on data from manufacturer interviews, as well as DPPP Working Group
discussions (Docket No. EERE-2015-BT-0008, March 21 DPPP Working Group
Meeting, at pp. 108-122), DOE concluded that a direct relationship
exists between motor MPC and pump WEF score, while a flat relationship
exists between motor-related conversion costs and WEF score, i.e.,
better performing motors cost more, but manufacturers face similar
conversion costs for all motor-related design options, regardless of
whether they are substituting on the basis of motor efficiency or on
the basis of motor speed configuration. DPPP Working Group members
clarified that the motor-related conversion costs associated with
upgrading a pump motor include the costs of sourcing and qualifying the
pump motor as a purchased component, but they do not include the costs
that motor manufacturers would incur (e.g., the costs of designing,
testing, and marketing a motor model). (Docket No. EERE-2015-BT-0008-
0094, March 21 DPPP Working Group Meeting, at pp. 113-114; Docket No.
EERE-2015-BT-0008-0100, May 18 DPPP Working Group Meeting, at pp. 89-
90) DPPP Working Group members also clarified that the conversion costs
associated with upgrading motors are not cumulative across multiple
efficiency levels, i.e., if a manufacturer pays a conversion cost to
upgrade from EL 0 to EL 2, they do not pay the conversion cost
associated with an interim upgrade to EL 1. (Docket No. EERE-2015-BT-
STD-0008-0100, May 18 DPPP Working Group Meeting, at pp. 102)
In discussions with the DPPP Working Group, DOE stated the
assumption that MPC does not increase as hydraulic efficiency
increases. Hayward commented that the addition of a diffuser would
change the efficiency and the MPC of a pump wet end, but DOE noted that
the analysis already accounts for this effect. The addition of a
diffuser would change a pump's ability to self-prime and thus, would
change the pump's equipment class, and DOE already determined the MPCs
and efficiencies of the different equipment classes on the basis of
these design differences. (Docket No. EERE-2015-BT-STD-0008-0094, March
21 DPPP Working Group Meeting, at pp. 117-118) Based on data from
manufacturer interviews and these Working Group discussions, DOE
concluded that hydraulic redesign has a negligible effect on MPC, but
results in significant conversion costs--much greater than those
incurred for motor-related improvement. The DPPP Working Group did not
object to these conclusions. Complete discussions of incremental MPC
and conversion costs are found in sections IV.C.5 and IV.J.2,
respectively.
Ultimately, DOE ordered its design options to first employ all
motor-related design options, based on ascending incremental MPC,
followed by improved hydraulic design to reach the maximum
technologically feasible efficiency level. This ordering was reviewed
by the DPPP Working Group (Docket No. EERE-2015-BT-STD-0008-0094, March
21 DPPP Working Group Meeting, at pp. 58-105), which
[[Page 5684]]
offered no objections, and ultimately evaluated standards based on
efficiency levels resulting from this ordering. Table IV-8 describes
the design options applied to each equipment class at each efficiency
level from the baseline up to the max-tech level.
Table IV-8--Design Options by Efficiency Level for Pump Varieties Subject to Performance Standards
----------------------------------------------------------------------------------------------------------------
DPPP variety
--------------------------------------------------------------------------
Pool filter pumps
Efficiency level -------------------------------------------------- Pressure cleaner
Self-priming/Non-self- booster pump
priming Waterfall pump *
----------------------------------------------------------------------------------------------------------------
0 (Baseline)......................... 1-speed motor, Low 1-speed motor, Low 1-speed motor, Low
efficiency motor, Low efficiency motor, Low efficiency motor, Low
hydraulic efficiency. hydraulic efficiency. hydraulic efficiency.
1.................................... 1-speed motor, Medium 1-speed motor, Medium 1-speed motor, Medium
efficiency motor, Low efficiency motor, Low efficiency motor, Low
hydraulic efficiency. hydraulic efficiency. hydraulic efficiency.
2.................................... 1-speed motor, High 1-speed motor, High 1-speed motor, High
efficiency motor, Low efficiency motor, Low efficiency motor, Low
hydraulic efficiency. hydraulic efficiency. hydraulic efficiency.
3.................................... 2-speed motor, Low 1-speed motor, High Variable-speed motor,
efficiency motor, Low efficiency motor, High Low hydraulic
hydraulic efficiency. hydraulic efficiency. efficiency.
4.................................... 2-speed motor, Medium ....................... Variable-speed motor,
efficiency motor, Low High hydraulic
hydraulic efficiency. efficiency.
5.................................... 2-speed motor, High
efficiency motor, Low
hydraulic efficiency.
6.................................... Variable-speed motor,
Low hydraulic
efficiency.
7 (max tech)......................... Variable-speed motor,
High hydraulic
efficiency.
----------------------------------------------------------------------------------------------------------------
* As described in section IV.A.6.b, DOE did not consider efficiency levels above EL2 for non-self-priming pool
filter pumps that produce less than 49.4 gpm maximum flow on curve C.
DOE analyzed one design option for the integral cartridge filter
pool pump and integral sand filter pool pump classes that are subject
to prescriptive standards. Table IV-9 presents the two efficiency
levels considered for those classes: The baseline (without a pool pump
timer), and EL1 (with a pool pump timer). Chapter 5 of the direct final
rule TSD contains more details on the development of efficiency levels.
Table IV-9--Design Options by Efficiency Level for DPPP Varieties
Subject to a Prescriptive Standards
------------------------------------------------------------------------
DPPP variety
---------------------------------------------
Efficiency level Integral cartridge Integral sand filter
filter pumps pumps
------------------------------------------------------------------------
0 (Baseline).............. Does not include pool Does not include pool
pump timer. pump timer.
1......................... Includes pool pump Includes pool pump
timer. timer.
------------------------------------------------------------------------
b. Summary of Available Motor Efficiencies
For the improved motor efficiency design option, DOE selected a
discrete motor efficiency (or efficiencies, for two-speed motors) for
each representative unit at each efficiency level. DOE presented
initial motor efficiency assumptions to the DPPP Working Group. These
initial figures showed full-speed nameplate motor efficiency ranging
from 55 percent to 81 percent for motors used in small self-priming
pool filter pumps and in 0.52-hhp non-self-priming pool filter pumps;
ranging from 75 percent to 92 percent for motors used in 1.88-hp self-
priming pool filter pumps; ranging from 55 percent to 77 percent for
motors used in pressure cleaner booster pumps; and ranging from 38
percent to 50 percent for motors used in waterfall pumps. (Docket No.
EERE-2015-BT-STD-0008-0094, March 21 DPPP Working Group Meeting, at pp.
58-65) DPPP Working Group members commented that certain manufacturers
offer a wider variety of two-speed motors than were represented in
DOE's initial assumptions. In particular, certain manufacturers offer
two-speed motors that are designed to have improved efficiency at low
speed. The DPPP Working Group requested DOE revise the motor efficiency
assumptions to include a new efficiency level representing a two-speed
motor with an improved low-speed motor efficiency. (Docket No. EERE-
2015-BT-STD-0008-0094, March 21 DPPP Working Group Meeting, at pp. 76-
77) DOE subsequently added an efficiency level (specifically, EL 4)
that incorporates a motor with high-speed efficiency of 68 percent and
low-speed efficiency of 48 percent.
DPPP Working Group members also commented that the efficiency range
DOE assumed for waterfall pumps was lower than what exists in the
market. DPPP Working Group members suggested that DOE examine typical
motor efficiencies for dedicated 1725-rpm motors. (Docket No. EERE-
2015-BT-STD-0008-0094, March 21 DPPP Working Group Meeting, at pp. 96-
99) DOE reviewed motor catalog data and subsequently revised its
waterfall motor efficiency assumptions upward. DOE revised the baseline
waterfall pump motor efficiency from 38 percent to 65 percent
efficient, and the max tech waterfall pump motor efficiency from 50
percent to 78 percent efficient.
Based on motor efficiency data in the CEC pool pump database, DOE
initially assumed that variable-speed ECM motors are available with
nameplate efficiency of 92 percent. Members of the DPPP Working Group
commented that 92 percent would be too high for a nameplate motor
efficiency, and suggested that the 92 percent figure did not account
for efficiency losses in the
[[Page 5685]]
motor's electronic drive. DPPP Working Group members requested that DOE
review its assumption for variable-speed nameplate motor efficiency and
revise it appropriately. (Docket No. EERE-2015-BT-STD-0008-0094, March
21 DPPP Working Group Meeting, at pp. 80-82) DOE subsequently revised
its assumption of typical variable-speed motor efficiency at high-speed
from 92 percent downward to 82 percent. The DPPP Working Group did not
object to this assumption.
DOE also initially assumed that smaller 48-frame motors typically
used in non-self-priming pumps would be able to achieve the same
nameplate motor efficiency as the larger 56-frame motors typically used
in self-priming pool filter pumps. DOE initially assumed that both 48-
frame and 56-frame single-speed motors would be available ranging from
55 percent efficiency to 77 percent efficiency. DPPP Working Group
members commented that, due to constraints of their smaller frame size,
48-frame motors could not always achieve the same efficiency as 56-
frame motors at the same capacity, and that 48-frame motors likely
could not achieve the 77 percent nameplate efficiency that DOE
initially assumed. (Docket No. EERE-2015-BT-STD-0008-0091, June 22 DPPP
Working Group Meeting, pp. 132-138 and pp. 189-191) DOE subsequently
revised its assumption regarding the nameplate efficiency from 77
percent to 72 percent for the larger (0.52-hhp) non-self-priming pool
filter pump representative unit, which used a 48-frame motor. The DPPP
Working Group did not object to this assumption.
Table IV-10 presents the revised motor efficiencies for each
combination of motor efficiency and motor configuration described in
Table IV-8. DOE selected these motor efficiencies based on data listed
in the Pool Pump Performance Database, publicly available catalog data,
and motor data that manufacturers submitted to DOE. Motor components
with the efficiencies listed in Table IV-10 are currently available on
the market at the appropriate frame sizes and capacities to drive the
representative unit pumps.
Table IV-10--Motor Nameplate Efficiencies for Representative Units With Different Motor Configurations *
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Motor efficiencies (and corresponding ELs) for representative units at high speed except as noted
-----------------------------------------------------------------------------------------------------------------------------------------------------------------
Motor description Self-priming pool filter pump Non-self-priming pool filter pump
-------------------------------------------------------------------------------------------------------------------- Pressure cleaner Water-fall pump (%)
0.44 hhp (%) 0.95 hhp (%) 1.88 hhp (%) 0.09 hhp (%) 0.52 hhp (%) booster pump (%)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
1-speed, low efficiency 55 (EL0).............. 55 (EL0)............. 75 (EL0)............. 55 (EL0)............. 55 (EL0)............. 55 (EL0)............. 65 (EL0)
(Baseline).
1-speed, mid efficiency....... 69 (EL1).............. 69 (EL1)............. 79 (EL1)............. 69 (EL1)............. 69 (EL1)............. 67 (EL1)............. 70 (EL1)
1-speed, high efficiency...... 76 (EL2).............. 77 (EL2)............. 84 (EL2)............. 72 (EL2)............. 72 (EL2)............. 72 (EL2)............. 78 (EL2-3)
2-speed, low efficiency....... 64 high, 38 low (EL3). 64 high, 38 low (EL3) 74 high, 49 low (EL3) n/a **............... 61 high, 38 low (EL3) n/a [Dagger]......... n/a [Dagger]
2-speed, mid efficiency....... 70 high, 46 low (EL4). 71 high, 46 low (EL4) 76 high, 55 low (EL4) n/a **............... 68 high, 48 low (EL4) n/a [Dagger]......... n/a [Dagger]
2-speed, high efficiency...... 73 high, 51 low (EL5). 73 high, 51 low (EL5) 83 high, 62 low (EL5) n/a **............... 72 high, 51 low (EL5) n/a [Dagger]......... n/a [Dagger]
Variable Speed................ 81 (EL6-7)............ 81 (EL6-7)........... 82 (EL6-7)........... n/a [dagger]......... 81 (EL6-7)........... 81 (EL3-4)........... n/a [Dagger]
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* The integral cartridge filter pool pump and integral sand filter pool pump equipment classes are not included in this table because DOE did not separately consider the motor costs for these
equipment classes.
** As discussed in section IV.A.6.b this analysis does not consider two-speed motor configurations for the extra-small non-self-priming pool filter pump representative unit. According to the
test procedure final rule, this representative unit would always be subject to the single-speed test procedure because the half-speed flow rate for a 0.09 hhp pump would be 17.8 gpm, which
is less than the test procedure minimum flow rate of 24.7 gpm.
[dagger] As discussed in section IV.A.6.b, this analysis does not consider variable-speed motor configurations for the extra-small non-self-priming pool filter pump representative unit.
[Dagger] Two-speed motors were not considered for waterfall pumps or pressure cleaner booster pumps, and variable-speed motors were not considered for waterfall pumps, because DOE assumes
these pump varieties are always operated at a single-speed.
c. Summary of Available Hydraulic Efficiencies
For the ``improved hydraulic design'' design option, DOE evaluated
two discrete hydraulic efficiencies (``low'' and ``high'') for each
representative unit. The low hydraulic efficiency represents the pump
hydraulic efficiency of a baseline unit that has not been optimized.
The high hydraulic efficiency represents the hydraulic efficiency of a
pump that has been hydraulically redesigned to improve hydraulic
efficiency, as described in section IV.A.6.c.
Table IV-11 presents the selected hydraulic efficiencies at each
efficiency level described in Table IV-8. DOE selected these hydraulic
efficiencies based on data listed in the Pool Pump Performance
Database, publicly available catalog data, and pump test data submitted
by manufacturers.\60\
---------------------------------------------------------------------------
\60\ For further information regarding the estimation of
hydraulic efficiencies, refer to chapter 5 of the direct final rule
TSD.
[[Page 5686]]
Table IV-11--Hydraulic Efficiencies for Representative Units
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Hydraulic efficiencies and corresponding efficiency levels for representative units at maximum speed
----------------------------------------------------------------------------------------------------------------------------------------------------------------
Hydraulic efficiency descriptor Self-priming pool filter pump Non-self-priming pool filter pump
(%) --------------------------------------------------------------------------------------------------------------------- Pressure cleaner Waterfall pump
0.44 hhp (%) 0.95 hhp (%) 1.88 hhp (%) 0.09 hhp (%) 0.52 hhp (%) booster pump (%)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Low Hydraulic Efficiency 45 (EL0-EL6)........... 59 (EL0-EL6)......... 62 (EL0-EL6)......... 23 (EL0-EL2)......... 51 (EL0-EL6)......... 24 (EL0-EL3)........ 61 (EL0-EL2)
(Applicable ELs).
High Hydraulic Efficiency 49 (EL7)............... 63 (EL7)............. 72 (EL7)............. n/a *................ 67 (EL7)............. 27 (EL4)............ 67 (EL3)
(Applicable ELs).
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* DOE did not have sufficient data to evaluate a 0.09-hhp non-self-priming pool filter pump with high hydraulic efficiency.
d. Representative Unit Performance at Each Efficiency Level
In the previous sections of this direct final rule, DOE described
efficiency levels and the available improvements in motor and hydraulic
efficiency for different equipment classes. This section describes how
DOE used that information to calculate the WEF value of each
representative unit at each efficiency level.
The DPPP equipment classes within the scope of this direct final
rule are varied in terms of the number of pump models that are offered
on the market and in terms of the amount of data available for those
models. Because of these variations, DOE calculated WEF values using
slightly different methodologies for each equipment class. The
following sections describe the methodologies that DOE used for each
equipment class.
Self-Priming Pool Filter Pumps
This subsection describes how DOE used the baseline and incremental
performance data presented in sections IV.C.3 through IV.C.4.c to
determine the WEF value for three representative self-priming pool
filter pump units (0.44 hhp, 0.95 hhp, and 1.88 hhp) from efficiency
levels one through max tech.
Efficiency levels one and two represent single-speed pumps. For EL1
and EL2, DOE held hydraulic efficiency constant and replaced the
baseline maximum speed motor efficiency with the EL1 and EL2 maximum
speed motor efficiencies (presented in Table IV-10). In doing so, DOE
was able to calculate the wire-to-water efficiency, input power, and
ultimately the WEF at maximum speed on curve C. Chapter 5 of the direct
final rule TSD provides full details regarding the calculations and
estimations presented in this section.
Efficiency levels three through five represent two-speed pumps. For
EL3, EL4, and EL5, DOE used the same method as described for EL1 and
EL2 to determine pump performance at maximum speed on curve C. However,
a dedicated-purpose pool pump operating at half-speed will exhibit
lower hydraulic efficiency and lower motor efficiency compared to its
full speed operation. To characterize the performance of pumps at half-
speed, DOE referred to the Pool Pump Performance Database, which
includes half-speed performance data for listings of two-speed self-
priming pool filter pumps. For all three representative units, DOE
identified pumps in the Pool Pump Performance Database that exemplify
EL3, with design characteristics of low motor efficiency, two-speed
motor, and low hydraulic efficiency. DOE used the half-speed motor
efficiency and input power for these EL3 units to estimate a
representative baseline half-speed hydraulic efficiency.\61\ Then DOE
calculated the total efficiency and the input power for EL4 and EL5 at
half speed by holding the half-speed hydraulic efficiency constant at
baseline and substituting the half-speed motor efficiencies assumed for
EL4 and EL5 (presented in Table IV-10). DOE calculated WEF for
representative units at EL4 and EL5 by combining the half-speed
performance with the max-speed performance, as specified in the test
procedure final rule.
---------------------------------------------------------------------------
\61\ For further information on this method of calculating the
half-speed hydraulic efficiency and WEF for two-speed pumps, refer
to chapter 5 of the direct final rule TSD.
---------------------------------------------------------------------------
Efficiency levels 6 and 7 describe variable-speed pumps. Similar to
previous ELs, DOE assumed that the baseline motor would be replaced
with the EL6 and EL7 motors presented in Table IV-10. Unlike two-speed
pumps, the high-speed test point for variable speed pumps is at 80
percent of maximum speed on curve C, and the low-speed test point is at
either 24.7 gpm flow or 31.1 gpm flow on curve C (depending on the pump
capacity). Although the Pool Pump Performance Database contains
performance data for many variable-speed pumps, data for these pumps is
not typically reported at these specific test points. Consequently, DOE
used the variable-speed performance data available for other speeds to
estimate performance for the representative units at the specific
variable-speed test points.
Based on examination of power-flow curves for many variable-speed
pumps and variable-speed motor performance data, DOE concluded that
total efficiency at 80 percent of maximum speed is approximately equal
to the pump's total efficiency at maximum speed. As such, the hydraulic
and motor efficiency of each variable-speed representative unit remains
constant, between 100 percent and 80 percent of maximum speed.\62\
---------------------------------------------------------------------------
\62\ See chapter 5 of the direct final rule TSD for more details
regarding the estimation of variable-speed pump performance at the
80-percent-speed and the low-speed test points.
---------------------------------------------------------------------------
However, examination of the same power-flow curves and variable-
speed motor performance data indicated that that pump's total
efficiency will be lower at the low-speed test point, as hydraulic and
motor efficiency tend to be significantly reduced at low speeds. DOE
constructed a regression of these power-flow data to quantify the
relationship between wire-to-water efficiency and speed reduction. This
relationship allowed DOE to estimate wire-to-water efficiency, and thus
input power, for each representative unit, based on each unit's wire-
to-water efficiency at maximum speed on curve C. The DPPP Working Group
reviewed this method of estimating low-speed performance and certain
members expressed explicit agreement with the results of this low-speed
estimation methodology. (Docket No. EERE-2015-BT-STD-0008-0094, March
21 DPPP Working Group Meeting, at pp. 26-35 and Docket No. EERE-2015-
BT-STD-0008-0095, March 22 DPPP Working Group Meeting, at pp. 4-5) None
of the DPPP Working Group members
[[Page 5687]]
expressed disagreement with this method of estimating low-speed
performance. The remainder of the DPPP Working Group offered no
objections, and ultimately evaluated standards based on this
methodology. Details regarding this regression and the estimation of
low-speed performance is included in chapter 5 of the direct final rule
TSD.
At EL6, DOE also estimated representative baseline low-speed and
high-speed hydraulic efficiency using data from the Pool Pump
Performance Database. To do so, DOE identified pumps in the Pool Pump
Performance Database that exemplify EL6, (those with variable-speed
motor and low hydraulic efficiency) and referenced the low-speed and
high-speed motor efficiencies and input power values that DOE estimated
for those units. DOE used these estimated values to calculate the
representative hydraulic efficiency of these pumps at low speed and at
high speed. Details regarding this estimation of hydraulic efficiency
are included in chapter 5 of the direct final rule TSD.
Then DOE calculated the total efficiency and the input power for
EL7 at low speed by holding the low-speed motor efficiency constant at
its EL6 level and substituting an improved hydraulic efficiency at
maximum speed on curve C, up to the values specified in Table IV-11.
DOE calculated the high-speed performance at EL7 in the same way, by
calculating total efficiency and input power holding the high-speed
motor efficiency constant and substituting an improved hydraulic
efficiency. Ultimately, DOE calculated WEF for representative units at
EL6 and EL7 by combining low-speed performance with the high-speed
performance, as specified in the test procedure final rule.
Non-Self-Priming Pool Filter Pumps
This subsection describes how DOE used the baseline and incremental
performance data presented in sections IV.C.3 through IV.C.4.c to
determine the WEF values for two representative non-self-priming pool
filter pump units (0.09 hhp and 0.52 hhp) from efficiency levels 1
through max tech. DOE analyzed the 0.09-hhp non-self-priming
representative unit separately from the 0.52-hhp non-self-priming
representative unit.\63\
---------------------------------------------------------------------------
\63\ The DPPP Working Group ultimately determined that separate
standard levels were not appropriate for standard-size non-self-
priming and extra-small non-self-priming pool filter pumps (Docket
No. EERE-2015-BT-STD-0008-0092, June 23 DPPP Working Group Meeting,
pp. 277-280), and the two representative capacities are regulated
together in one equipment class.
---------------------------------------------------------------------------
DOE did not analyze any efficiency levels above EL2 for the 0.09-
hhp non-self-priming pool filter pump representative unit. As discussed
in section IV.A.6.b, the design option described as ``ability to
operate at reduced speeds'' does not benefit pool filter pumps that are
below 49.4 gpm at maximum speed on curve C. The representative unit
characteristics in Table IV-6 show that the 0.09-hhp non-self-priming
representative unit achieves a flow rate of 35.1 gpm at maximum speed
on curve C. This flow rate is below the 49.4 gpm threshold, so DOE
analyzed only single-speed efficiency levels (EL0 through EL2) for the
0.09-hhp non-self-priming pool filter pump. DOE discussed this point
with the DPPP Working Group and the group did not offer any comments or
objections. (Docket No. EERE-2015-BT-STD-0008-0091, June 22 DPPP
Working Group Meeting, pp. 115-116)
To calculate the WEF of non-self-priming pool filter pumps at EL1
and EL2 at maximum speed on curve C, DOE used the same methods as those
described for self-priming pool filter pumps at EL1 and EL2.
To calculate the WEF of 0.52-hhp non-self-priming pool filter pumps
at EL3, EL4, and EL5, DOE used the same methods as those described for
self-priming pool filter pumps at EL3, EL4, and EL5.
Efficiency levels 6 and 7 describe variable-speed pumps. Similar to
previous ELs, DOE assumed that the baseline motor would be replaced
with the EL6 and EL7 motors presented in Table IV-10. As described in
the discussion of self-priming pool filter pumps, the high-speed test
point for variable-speed pumps is at 80 percent of maximum speed on
curve C, and the low-speed test point is at either 24.7 gpm flow or
31.1 gpm flow on curve C (depending on the pump capacity). However, the
Pool Pump Performance Database does not contain performance data for
any variable-speed non-self-priming pool filter pumps, and DOE is not
aware of any non-self-priming pool filter pumps on the market that
incorporate a variable-speed motor. To characterize EL6 and EL7, DOE
estimated the performance of a hypothetical variable-speed non-self-
priming pool filter pump. Based on examinations of power-flow curves
for self-priming and non-self-priming pool filter pumps, DOE concluded
that these two pump varieties experience similar degradation of motor
and hydraulic efficiency as pump flow is reduced. DOE estimated the
low-speed efficiencies of non-self-priming pumps using the same
relationship between wire-to-water efficiency and speed reduction that
was determined by regression of self-priming pool filter pump data. DOE
applied this relationship to the 0.52-hhp representative non-self-
priming unit to this representative unit at 80-percent speed and at low
speed.
DOE then calculated the total efficiency and the input power for
EL7 at low speed by holding the low-speed motor efficiency constant at
its EL6 level and substituting an improved hydraulic efficiency at
maximum speed on curve C, up to the values specified in Table IV-11.
Ultimately, DOE calculated WEF for representative units at EL6 and EL7
by combining low-speed performance with the high-speed performance, as
specified in the test procedure final rule.
Pressure Cleaner Booster Pumps
This subsection describes how DOE used the baseline and incremental
performance data presented in sections IV.C.3 through IV.C.4.c to
determine the WEF value for one representative pressure cleaner booster
pump (at 0.28 hhp at the test point of 10 gpm flow) from efficiency
levels 1 through max tech.
To calculate the WEF of pressure cleaner booster pumps at EL1 and
EL2 at the pressure cleaner booster pump test point of 10 gpm of flow,
DOE used the same methods as those described for self-priming pool
filter pumps at EL1 and EL2.
EL 3 represents a variable-speed pump. As described in section
IV.A.6.b, pressure cleaner booster pumps are tested at 100 percent
speed or (for variable-speed pumps) at the lowest speed that can
achieve 60 feet of head at the 10 gpm test condition.\64\ DOE assumed
that the representative unit's motor efficiency would improve from EL2
to EL3, as the shift from single speed to variable speed would likely
be achieved by switching from induction motor technology to the more
efficient ECM technology.\65\ For EL3, DOE held hydraulic efficiency
constant and replaced the EL2 motor efficiency with the EL3 maximum
speed motor efficiency (presented in Table IV-10).
[[Page 5688]]
DOE used pump affinity laws \66\ to calculate the input power that the
representative unit would consume at 60 feet of head at 10 gpm
flow.\67\ In doing so, DOE was able to calculate the wire-to-water
efficiency and ultimately WEF at the waterfall pump test point of 10
gpm flow.
---------------------------------------------------------------------------
\64\ The DPPP Working Group requested that DOE examine variable-
speed pumps as a design option for pressure cleaner booster pumps.
(Docket No. EERE-2015-BT-STD-0008-0095, March 22 DPPP Working Group
Meeting, at pp. 197-203)
\65\ As noted in section IV.A.6.a, ECMs are inherently more
efficient than induction motors because their construction minimizes
slip losses between the rotor and stator components.
\66\ The pump affinity laws relevant to this calculation are
stated in Equation 5, Equation 6, and Equation 7.
\67\ DOE calculated that, for the representative pressure
cleaner booster pump, this operating point represents 73 percent of
the pump's maximum speed. Based on examination of power-flow curves
for many variable-speed self-priming pool filter pumps and variable-
speed motor performance data, DOE concluded that this reduced-speed
operation would incur negligible motor efficiency and hydraulic
efficiency losses. Thus, DOE assumed that the representative
pressure cleaner booster pump operating at 73 percent speed would
exhibit the same motor efficiency and hydraulic efficiency as it
would when operating at 100 percent speed.
---------------------------------------------------------------------------
Efficiency level four represents a variable-speed pressure cleaner
booster pump with improved hydraulic design. DOE calculated the total
efficiency and the input power for EL4 by holding the motor efficiency
constant at its EL3 level and substituting an improved hydraulic
efficiency at maximum speed on curve C, up to the value specified in
Table IV-11. Chapter 5 of the direct final rule TSD provides full
details regarding the calculations and estimations presented in this
section.
Waterfall Pumps
This subsection describes how DOE used the baseline and incremental
performance data presented in sections IV.C.3 through IV.C.4.c to
determine the WEF value for one representative waterfall pump (at 0.40
hhp at the test point of 17 feet of head) from efficiency levels 1
through max tech.
To calculate the WEF of waterfall pumps at EL1 and EL2 at the
waterfall pump test point of 17 feet of head, DOE used the same methods
as those described for self-priming pool filter pumps at EL1 and EL2.
Efficiency level three represents a single-speed pump with improved
hydraulic design. DOE calculated the total efficiency and the input
power for EL3 by holding the motor efficiency constant at its EL2 level
and substituting an improved hydraulic efficiency at maximum speed on
curve C, up to the values specified in Table IV-11. Chapter 5 of the
direct final rule TSD provides full details regarding the calculations
and estimations presented in this section.
Summary of Representative Unit Performance at Each Efficiency Level
Table IV-12 presents the performance in terms of WEF calculated for
each of the representative units at each efficiency level.
Table IV-12 Performance of Representative Units at Each Efficiency Level
--------------------------------------------------------------------------------------------------------------------------------------------------------
Representative units
---------------------------------------------------------------------------------------------------------------
Self-priming Non-self-priming
Efficiency level ---------------------------------------------------------------------------------------------------------------
Water-fall Pressure
0.44 hhp (WEF) 0.95 hhp (WEF) 1.88 hhp (WEF) 0.09 hhp (WEF) 0.52 hhp (WEF) (WEF) cleaner (WEF)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0 (Baseline)............................ 2.69 2.13 1.74 3.93 2.77 7.46 0.34
1....................................... 3.37 2.67 2.03 4.93 3.47 7.95 0.42
2....................................... 3.72 2.98 2.16 5.14 3.62 8.95 0.45
3....................................... 4.68 3.98 3.45 * n/a 4.62 9.85 0.51
4....................................... 5.38 4.60 3.66 * n/a 5.47 ** n/a 0.56
5....................................... 5.77 4.88 4.18 * n/a 5.80 ** n/a ** n/a
6....................................... 8.78 6.89 5.21 * n/a 7.42 ** n/a ** n/a
7....................................... 11.71 8.59 6.97 * n/a 11.96 ** n/a ** n/a
(Max Tech)..............................
--------------------------------------------------------------------------------------------------------------------------------------------------------
* DOE evaluated 0.09-hhp non-self-priming pool pumps at single-speed efficiency levels only.
** The max-tech efficiency level is EL3 for waterfall pumps and EL4 for pressure cleaner booster pumps.
e. Efficiency Level Structure for All Pump Capacities
The previous section summarizes the performance of the
representative units at each efficiency level. However, the market for
self-priming and non-self-priming pool filter pumps is more diverse
than these representative units. The self-priming and non-self-priming
pool filter pump classes include pumps less than 2.5 hhp, and the range
of available pump efficiencies (as measured by WEF) decreases as pump
capacity increases. To reflect this variation, DOE developed efficiency
levels for these equipment classes in the form of equations to specify
the WEF performance of equipment across the range of hydraulic power.
For self-priming and non-self-priming pool filter pumps, DOE
constructed mathematical functions that fit the performance of the
representative units at each efficiency level. DOE observed that the
natural logarithm function provides curves with the best fit (i.e., the
least error) when comparing the calculated curve values to the
performance values that DOE estimated for representative units. DOE
constructed scatterplots (Figure IV.4 and Figure IV.5) to visualize the
performance of the self-priming and non-self-priming pool filter pumps
listed in the Pool Pump Performance Database, along with the
representative unit performance at each efficiency level and the
efficiency level curve equations.
DOE manually adjusted coefficients in the efficiency level curves
to shape the curves to meet the needs of the DPPP Working Group. For
instance, DOE adjusted the EL6 curve for self-priming pool filter pumps
so that all variable-speed self-priming pool filter pumps listed in the
Pool Pump Performance Database would meet a standard set at EL6. The
development of the finished efficiency level curve equations is
described further in chapter 5 of the direct final rule TSD. After DOE
adjusted the efficiency level curves, the DPPP Working Group reviewed
them (Docket No. EERE-2015-BT-STD-0008-0078, April 18 DPPP Working
Group Meeting, at pp. 17-18), offered no objections, and ultimately
evaluated standards based on these efficiency levels. DOE presented an
alternate curve for EL 6 that accounted for the statistical error
inherent in the estimation of WEF scores.\68\ (Docket No. EERE-2015-BT-
[[Page 5689]]
STD-0008-0100, May 18 DPPP Working Group Meeting, at pp. 118-120) The
DPPP Working Group ultimately reached consensus, with no dissenting
votes, to recommend the original EL 6 curve that does not include
corrections for statistical error. (Docket No. EERE-2015-BT-STD-0008-
0092, June 23 DPPP Working Group Meeting, at pp. 282-283) .
---------------------------------------------------------------------------
\68\ DOE did not have access to performance data for variable-
speed pool filter pumps at the load points prescribed in the test
procedure final rule. DOE estimated the performance of pool filter
pumps at these load points using statistical regression analysis, as
described in section IV.C.1.a. DOE estimated that the regression
analysis introduces statistical error of about 8 percent for the WEF
scores calculated for representative pool filter pump units.
[GRAPHIC] [TIFF OMITTED] TR18JA17.012
[[Page 5690]]
[GRAPHIC] [TIFF OMITTED] TR18JA17.013
As evidenced in Figure IV.4 and Figure IV.5, the DPPP Working Group
ultimately requested that each efficiency level curve become a flat
line at 40 gpm (which is equivalent to 0.13 hhp on curve C) so that for
each curve, all flow values below 40 gpm correspond to the WEF score
for the efficiency level at 40 gpm. (Docket No. EERE-2015-BT-STD-0008-
0092, June 23 DPPP Working Group Meeting, at pp. 277-280) The DPPP
Working Group made this request for both self-priming and non-self-
priming pool filter pumps.
The pressure cleaner booster pumps on the market are clustered in a
small range of capacities, with hydraulic power ranging from 0.26 hhp
to 0.32 hhp at the test point of 10 gpm flow. Due to the limit range of
available capacities, DOE did not use equations to describe the
efficiency levels for pressure cleaner booster pumps. Instead, DOE
selected fixed WEF values to represent the efficiency levels. The DPPP
Working Group reviewed this method and recommended that DOE set a
standard level for pressure cleaner booster pumps that is a single
value. (EERE-2015-BT-STD-0008, No. 82, Recommendation #1 at pp. 1-2)
Chapter 5 of the direct final rule TSD contains complete details
regarding the development of efficiency levels for pressure cleaner
booster pumps.
For waterfall pumps, DOE performed the economic analyses on the
waterfall pump representative units from baseline to max tech and
presented the results to the DPPP Working Group. DOE's analytical
results showed that EL 1 and EL 2 would have negative LCC savings. Many
DPPP Working Group members commented that the energy savings for the
waterfall class would be small and thus not economically justifiable to
pursue standards for waterfall pumps. (Docket No. EERE-2015-BT-STD-
0008-0101, May 19 DPPP Working Group Meeting, at pp. 35-36 and pp. 45-
46) Consequently, DOE did not establish detailed potential standard
levels for waterfall pumps beyond the aforementioned representative
units.
Table IV-13 presents the equations used to calculate the WEF at
each efficiency level as a function of hydraulic horsepower for self-
priming and non-self-priming pool filter pumps. Table IV-14 presents
the fixed WEF values at each efficiency level for pressure cleaner
booster pumps.
Table IV-13--Efficiency Level WEF Equations for Self-Priming and Non-Self-Priming Pool Filter Pumps
----------------------------------------------------------------------------------------------------------------
Equipment class
-----------------------------------------------------------------------------
Self-priming pool filter pumps, small Non-self-priming pool filter pumps **
Efficiency level and standard classes (WEF) * (WEF) *
-----------------------------------------------------------------------------
<=0.13 hhp >0.13 hhp <=0.13 hhp >0.13 hhp
----------------------------------------------------------------------------------------------------------------
0 (Baseline)...................... 3.51 -0.69 x ln(hhp) + 3.71 -0.69 x ln(hhp) +
2.10. 2.30.
1................................. 4.84 -1.10 x ln(hhp) + 4.60 -0.85 x ln(hhp) +
2.60. 2.87.
[[Page 5691]]
2................................. 5.55 -1.30 x ln(hhp) + 4.92 -0.90 x ln(hhp) +
2.90. 3.08.
3................................. 5.89 -1.00 x ln(hhp) + 5.89 -1.00 x ln(hhp) +
3.85. 3.85.
4................................. 7.05 -1.30 x ln(hhp) + 7.05 -1.30 x ln(hhp) +
4.40. 4.40.
5................................. 7.60 -1.30 xln(hhp) + 4.95 7.60 -1.30 x ln(hhp) +
4.95.
6................................. 11.28 -2.30 x ln(hhp) + 9.36 -1.60 x ln(hhp) +
6.59. 6.10.
7................................. 13.40 -2.45 x ln(hhp) + 13.86 -1.60 x ln(hhp) +
(Max Tech)........................ 8.40. 10.60.
----------------------------------------------------------------------------------------------------------------
* hhp represents the hydraulic horsepower of the pump, measured at maximum speed on system curve C and reported
in units of horsepower.
** As described in section IV.A.6.b, DOE did not consider efficiency levels above EL2 for non-self-priming pool
filter pumps that produce less than 49.4 gpm maximum flow on curve C.
Table IV-14--Efficiency Level WEF Values for Pressure Cleaner Booster
Pumps
------------------------------------------------------------------------
Equipment class
-------------------
Efficiency level Pressure cleaner
booster pumps, at
10 gpm flow (WEF)
------------------------------------------------------------------------
0 (Baseline)........................................ 0.34
1................................................... 0.42
2................................................... 0.45
3................................................... 0.51
4................................................... 0.56
------------------------------------------------------------------------
5. Manufacturer Production Costs
This section present the MPCs at each efficiency level, for each
equipment class, and discusses the analytical methods used to develop
these MPCs. This section contains six subsections. The first subsection
describes the principal drivers of manufacturing costs. The second and
third subsections focus on the motor costs and non-motor costs for pool
filter pumps and pressure cleaner booster pumps. The fourth subsection
focuses specifically on the costs of integral sand filter and integral
cartridge filter pumps. The final two subsections present cost-
efficiency tables and MPC breakdowns for all DPPP equipment classes.
a. Principal Drivers of DPPP Manufacturing Costs
For most models of pool filter pumps and pressure cleaner booster
pumps, the motor is the most expensive component of the pump. As
discussed previously, for these equipment classes, all efficiency
levels except max tech are defined by a motor substitution. In a motor
substitution, the pump motor of a representative baseline (low
efficiency, single-speed) unit is exchanged with a motor that will
provide improved performance (e.g., improved efficiency or ability to
operate at reduced speed).
DOE researched the design and engineering constraints associated
with motor substitution, examining manufacturer interview responses and
holding discussions with the DPPP working group. In particular, Hayward
commented that manufacturers would incur costs, such as costs
associated with testing, packaging, and labeling, when substituting the
motor component of a pump. (Docket No. EERE-2015-BT-STD-0008-0079,
April 19 DPPP Working Group Meeting, at pp. 105-106) Zodiac commented
that manufacturers would incur costs for motor substitutions associated
with qualification testing, reliability testing, and updating catalogs
and marketing materials. (Docket No. EERE-2015-BT-STD-0008-0100, May 18
DPPP Working Group Meeting, at pp. 78) DOE included the cost items
described by Hayward and Zodiac in the product conversion costs
(discussed in section IV.J.2.c) in the MIA and did not account for them
in the MPC figures estimated for dedicated-purpose pool pumps. DOE
concluded that for the representative equipment capacities being
considered, a given DPPP wet end could be paired with a range of motors
of various efficiencies and speed configurations without significant
changes to the per-unit costs associated with manufacturing the wet
end. In other words, a motor swap results in negligible incremental MPC
to the non-motor components of the dedicated-purpose pool pump. Thus,
DOE concluded that the incremental MPC of the motor swap design options
(improved motor efficiency and ability to operate at reduced speeds)
may be considered equivalent to the incremental MPC of the motor
component being swapped.
Consequently, DOE broke the equipment MPCs for pool filter pumps
and pressure cleaner booster pumps into two categories--motor costs and
non-motor costs--and estimated the MPC of each separately. However, DOE
did not break out the motor costs of the integral cartridge and
integral sand filter pool pump classes because no motor design options
were considered for these equipment classes.
b. Pool Filter Pump and Pressure Cleaner Booster Pump Motor Costs
DOE quantified pump motor MPCs at each efficiency level, for each
representative unit. These MPCs represent the cost incurred by DPPP
manufacturers to either purchase the motors or assemble them in house.
DOE estimated motor costs using two data sources: (1) Estimates
provided by manufacturers, and (2) publicly available motor catalogs.
DOE presented initial motor cost estimates to the DPPP Working Group
and received feedback from the group. (Docket No. EERE-2015-BT-0008-
0094, March 21 DPPP Working Group Meeting, at pp. 108-122) Hayward
commented that the motor MPCs that DOE initially presented for
variable-speed pump motors were extremely low, and Hayward asked DOE to
ensure that these MPC figures include the cost of all three components
(the motor, the motor drive, and the user interface) that are required
to replace a single-speed or two-speed motor. (Docket No. EERE-2015-BT-
0008-0100, May 18 DPPP Working Group Meeting, at pp. 130-131) DOE's
contractor subsequently received new motor cost data and revised the
MPC assumptions for variable-speed motors based on those numbers.
The revised motor component costs presented in Table IV-15
represent aggregate cost estimates for the dedicated-purpose pool pump
industry,
[[Page 5692]]
and do not represent the costs incurred by any one pump manufacturer.
The costs in Table IV-15 include all of the costs incurred to deliver
finished motor components that are ready for assembly into a pump.\69\
For variable-speed motors, the listed costs include the cost of
controls (which include a motor driver and a user interface), as
variable-speed motors require this equipment to operate. (Docket No.
EERE-2015-BT-STD-0008-0079, April 19 DPPP Working Group Meeting, at pp.
207-208)
---------------------------------------------------------------------------
\69\ For manufacturers that purchase third-party motors, these
costs include shipping and delivery costs, as well as the overhead
associated with ordering and inventory. For manufacturers that
assemble motors in house, these costs include the components, labor,
and depreciation associated with motor assembly.
---------------------------------------------------------------------------
As discussed in section IV.A.5.b, variable-speed motors are not
currently available in capacities smaller than 1.65 thp. Initially, DOE
assumed that motor manufacturers would begin to offer variable-speed
motors smaller than 1.65-thp, and DOE estimated the costs of these
smaller motors by extrapolating the costs of larger variable-speed
motors that are currently available. (Docket No. EERE-2015-BT-STD-0008-
0078, April 18 DPPP Working Group Meeting, at pp. 31-32) The DPPP
Working Group recommended that DOE consider only motors that that are
currently available on the market. (EERE-2015-BT-STD-0008-0079, April
19 DPPP Working Group Meeting, at pp. 109-112) Specifically, the DPPP
Working Group did not find it reasonable to assume that motor suppliers
would develop smaller variable-speed motor that are not are already
available on the market. (Docket No. EERE-2015-BT-STD-0008-0079, April
19 DPPP Working Group Meeting, at pp. 109) Thus, DOE modeled a 1.65-thp
variable-speed motor that would be the motor of choice for smaller
representative units at efficiency levels that are defined by variable-
speed motors.
DPPP Working Group members commented that smaller DPPP models may
require additional design changes to accommodate a 1.65-thp variable-
speed motor. DOE requested comments on the product conversion costs
that would be required to adapt smaller DPPP models to use 1.65-thp
variable-speed motors. (Docket No. EERE-2015-BT-STD-0008-0079, April 19
DPPP Working Group Meeting, at pp. 108-113) DOE incorporated
manufacturer feedback into the product conversion cost assumptions,
which are discussed in section IV.J.2.c.
DOE presented the revised motor costs in Table IV-15 to the DPPP
Working Group and the DPPP Working Group did not offer any comments in
opposition. (Docket No. EERE-2015-BT-STD-0008-0100, May 18 DPPP Working
Group Meeting, at pp. 115-116; Docket No. EERE-2015-BT-0008-0101, May
19 DPPP Working Group Meeting, at pp. 6-10)
Table IV-15--MPC of DPPP Motor Components *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Representative units
---------------------------------------------------------------------------------------------------------------
Self-priming pool filter pump Non-self-priming pool filter Pressure
Motor description ------------------------------------------------ pump cleaner Water-fall
-------------------------------- booster pump pump ($)
0.44 hhp ($) 0.95 hhp ($) 1.88 hhp ($) 0.09 hhp ($) 0.52 hhp ($) ($)
--------------------------------------------------------------------------------------------------------------------------------------------------------
(Baseline) 1-speed low efficiency....... 55 66 142 24 46 53 58
1-speed, mid efficiency................. 68 85 177 30 50 63 69
1-speed, high efficiency................ 87 101 198 36 64 83 88
2-speed, low efficiency................. 90 102 226 ** n/a 68 [dagger][dagge [dagger][dagge
r] n/a r] n/a
2-speed, mid efficiency................. 100 119 239 ** n/a 82 [dagger][dagge [dagger][dagge
r] n/a r] n/a
2-speed, high efficiency................ 111 137 253 ** n/a 96 [dagger][dagge [dagger][dagge
r] n/a r] n/a
Variable Speed.......................... 273 273 367 [dagger] n/a 273 273 [dagger][dagge
r] n/a
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The integral cartridge filter pool pump and integral sand filter pool pump equipment classes are not included in this table because DOE did not
separately consider the motor costs for these equipment classes.
** As discussed in section IV.A.6.b this analysis does not consider two-speed motor configurations for the 0.09-hhp non-self-priming pool filter pump
representative unit. According to the test procedure final rule, this representative unit would always be subject to the single-speed test procedure
because the half-speed flow rate for a 0.09-hhp pump would be 17.8 gpm, which is less than the test procedure minimum flow rate of 24.7 gpm.
[dagger] As discussed in section IV.A.6.b, this analysis does not consider variable-speed motor configurations for the 0.09-hhp non-self-priming pool
filter pump representative unit.
[dagger][dagger] Two-speed motors were not considered for waterfall pumps or pressure cleaner booster pumps, and variable-speed motors were not
considered for waterfall pumps, because DOE assumes these pump varieties are always operated at a single-speed.
c. Pool Filter Pump and Pressure Cleaner Booster Pump Non-Motor Costs
The non-motor costs of manufacturing pool filter pumps and pressure
cleaner booster pumps include the costs associated with manufacturing
the wet end of the pump and the costs associated with assembling and
packaging the pump. To determine the MPC of non-motor components, DOE
developed a comprehensive spreadsheet model itemizing all component
parts and their associated costs. The spreadsheet model took inputs
from virtual teardowns as well as data obtained through manufacturer
interviews and independent research. For the virtual teardowns, DOE
referenced catalogs of replacement pump parts and analyzed the
materials and the manufacturing processes used to produce the various
pump components. With this information, DOE calculated the amount a
DPPP manufacturer would pay to produce each representative unit.
Chapter 5 of the direct final rule TSD includes further detail on the
inputs and methods used to determine MPC, including material, labor,
and overhead breakdowns.
Table IV-16 presents the non-motor MPCs associated with producing
representative units in the pool filter pump and pressure cleaner
booster pump equipment classes. DOE presented these costs to the DPPP
Working Group (Docket No. EERE-2015-BT-STD-0008-0094, March 21 DPPP
Working Group Meeting, at pp. 117-118) and received no objections.
[[Page 5693]]
Table IV-16--Non-Motor MPC for Pool Filter Pump and Pressure Cleaner Booster Pump Classes *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Representative units
------------------------------------------------------------------------------------------------------
Self-priming pool filter pump Non-self-priming pool filter
--------------------------------------------------- pump Pressure
---------------------------------- cleaner booster
0.44 hhp 0.95 hhp 1.88 hhp 0.09 hhp 0.52 hhp pump
----------------------------------------------------------------------------------------------------------------------------------------
Non-Motor Costs.................. $47 $47 $50 $23 $24 $35 $42
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The integral cartridge filter pool pump and integral sand filter pool pump equipment classes are not included in this table because DOE did not
separately consider the motor costs for these equipment classes.
DOE investigated the incremental MPC associated with manufacturing
a pool filter pump with high hydraulic efficiency compared to a pool
filter pump with low hydraulic efficiency. To do this, DOE identified
several pairs of pool filter pumps that had identical capacities and
motor efficiencies, but one pump had higher total efficiency than the
other at maximum speed on curve C. DOE used a manufacturing cost model
to individually model the MPCs of the higher efficiency wet end and the
lower efficiency wet end. DOE determined that the MPC of producing a
higher efficiency wet end would be approximately equal to the MPC of
producing a low efficiency wet end. Thus, DOE concluded that there
would be no incremental MPC associated with improving the hydraulic
efficiency of a pool filter pump.\70\ DOE presented this conclusion to
the DPPP Working Group, which raised no objections. (Docket No. EERE-
2015-BT-STD-0008-0094, March 21 DPPP Working Group Meeting, at pp. 117-
118)
---------------------------------------------------------------------------
\70\ DOE notes that manufacturers would still likely incur costs
for component design, prototyping, tooling, and testing. These costs
are not included in the per-unit MPC figures described in this
section. Instead, these one-time conversion costs are discussed in
the manufacturer impact analysis discussed in section IV.J of this
direct final rule.
---------------------------------------------------------------------------
d. Cost Analysis of Integral Filter Pool Pump Equipment Classes
DOE did not break out the motor component costs for integral filter
pool pump equipment classes estimating MPCs for that class. DOE first
estimated the MPC of the three representative units associated with
these classes at the baseline efficiency level. DOE then estimated the
incremental cost of the sole design option (pool pump timer) considered
for these classes.
Baseline MPCs of Integral Filter Pump Classes
DOE used several data sources to estimate the MPC of integral
filter pumps at the baseline efficiency level:
DOE received MPC estimates from manufacturers, including
estimates of the MPC of integral filter pumps at the baseline level.
DOE retrieved retail price data for integral filter pumps
that are commercially available on the market. These retail prices
represent the MPC of producing a unit plus the various markups and
taxes that are applied along the distribution chain.\71\ DOE aggregated
retail price data for representative integral filter pump units and
divided by a set of assumed markups to estimate the MPCs of
representative units.
---------------------------------------------------------------------------
\71\ Markups are discussed in section IV.D of this notice and
markup assumptions are presented in chapter 6 of the direct final
rule TSD.
---------------------------------------------------------------------------
DOE conducted a reverse-engineering teardown as a bottom-
up approach to estimate the MPC of a representative unit. DOE purchased
and disassembled an integral filter pump and created a manufacturing
cost model to estimate the manufacturing costs associated with
producing the pump at the same volumes as integral pump manufacturers.
DOE aggregated the cost data from these sources. Table IV-17
presents the estimated MPC for the three representative units of
integral filter pool pumps. DOE presented the MPCs in Table IV-17 to
the DPPP Working Group and the DPPP Working Group did not offer any
opposition or additional comments. (Docket No. EERE-2015-BT-STD-0008-
0094, March 21 DPPP Working Group Meeting, at pp. 132-133).
Table IV-17--MPCs for Integral Filter Pump Equipment Classes
----------------------------------------------------------------------------------------------------------------
Representative equipment
--------------------------------------------------
Integral sand Integral cartridge filter pool
filter pool pump
pump ---------------------------------
-----------------
0.03 hhp 0.02 hhp 0.18 hhp
----------------------------------------------------------------------------------------------------------------
Baseline MPC................................................. $57 $17 $92
----------------------------------------------------------------------------------------------------------------
Incremental Cost of Pool Pump Timer Design Option
The only design option considered for the integral cartridge filter
pool pump and integral sand filter pool pump equipment classes is the
addition of a pool pump timer. The DPPP Working Group recommended that
the prescriptive standard for including a timer with integral filter
pumps should be fulfilled by a timer that is either integral to the
pump or that is a separate component shipped with the pump. (Docket No.
EERE-2015-BT-STD-0008-0082, Recommendation #2 at p. 2) Based on
manufacturer interviews, DOE concluded that the incremental cost of
adding a pool pump timer would be approximately the same for all three
representative units associated with the integral filter pump equipment
classes.
DOE separately evaluated the costs of integrating a timer into an
existing integral filter pump and the costs of including a timer with
an existing pump. To estimate the cost of integrating a timer into an
existing pump, DOE used MPC estimates provided by pump manufacturers.
[[Page 5694]]
These data included manufacturer estimates of the incremental MPC of
integrating a timer into existing integral pump products. To estimate
the cost of including a timer with an existing pump, DOE conducted a
retail price analysis of timers that are available off the shelf. DOE
retrieved retail prices for off-the-shelf timers that would meet the
criteria required for servicing an outdoor integral filter pump (e.g.,
timer is waterproof, timer is electrically grounded, and is rated to an
amperage greater than what the pump requires). DOE then derated the
retail price to estimate the price of timers purchased in bulk.
DOE aggregated the cost data from these sources, and estimated that
the industry average incremental cost of adding a pool pump timer to an
integral filter pump is $6.67 per unit. DOE presented this incremental
cost to the DPPP Working Group and the DPPP Working Group did not
oppose it or offer additional comments. (Docket No. EERE-2015-BT-STD-
0008-0094, March 21 DPPP Working Group Meeting, at pp. 132).
e. Cost-Efficiency Results
This subsection presents the cost-efficiency tables that result
from the combination of motor and wet end costs at each efficiency
level. Table IV-18 through Table IV-22 present results for each
representative unit.
Table IV-18--MPCs for Self-Priming Pool Filter Pump Representative Units
----------------------------------------------------------------------------------------------------------------
Representative unit capacity on system curve C
-----------------------------------------------
Efficiency level 0.44 hhp (MPC 0.95 hhp (MPC 1.88 hhp (MPC
$) $) $)
----------------------------------------------------------------------------------------------------------------
0 (Baseline).................................................... 102 113 192
1............................................................... 115 132 227
2............................................................... 134 148 248
3............................................................... 137 149 276
4............................................................... 147 166 290
5............................................................... 158 184 303
6............................................................... 320 320 417
7 (Max Tech).................................................... 320 320 417
----------------------------------------------------------------------------------------------------------------
Table IV-19--MPCs for Non-Self-Priming Pool Filter Pump Representative
Units
------------------------------------------------------------------------
Representative unit capacity
on system curve C
Efficiency level -------------------------------
0.09 hhp (MPC 0.52 hhp (MPC
$) $)
------------------------------------------------------------------------
0 (Baseline)............................ 47 69
1....................................... 53 74
2....................................... 59 87
3....................................... * n/a 91
4....................................... * n/a 105
5....................................... * n/a 119
6....................................... * n/a 297
7 (Max Tech)............................ * n/a 297
------------------------------------------------------------------------
* DOE did not analyze any efficiency levels above EL2 for the 0.09-hhp
non-self-priming pool filter pump representative unit, as discussed in
section IV.C.4.d.
Table IV-20--MPCs for Pressure Cleaner Booster Pump Representative Units
------------------------------------------------------------------------
Representative unit
capacity
Efficiency level ----------------------------
0.28 hhp at 10 gpm of flow
(MPC $)
------------------------------------------------------------------------
0 (Baseline)............................... 88
1.......................................... 99
2.......................................... 118
3.......................................... 308
4 (Max Tech)............................... 308
------------------------------------------------------------------------
Table IV-21--MPCs for Waterfall Pump Representative Units
------------------------------------------------------------------------
Representative unit
capacity
Efficiency level ----------------------------
0.40 hhp at 17 feet of head
(MPC $)
------------------------------------------------------------------------
0 (Baseline)............................... 100
1.......................................... 110
2.......................................... 130
3 (Max Tech)............................... 130
------------------------------------------------------------------------
[[Page 5695]]
Table IV-22--MPCs for Integral Filter Pump Representative Units
----------------------------------------------------------------------------------------------------------------
Representative unit capacity on system curve C
-----------------------------------------------
Integral sand Integral cartridge filter pool
filter pool pump
Efficiency level pump -------------------------------
----------------
0.03 hhp (MPC 0.02 hh (MPC 0.18 hhp (MPC
$) $) $)
----------------------------------------------------------------------------------------------------------------
0 (Baseline).................................................... 57 17 92
1 (With Timer).................................................. 64 23 99
----------------------------------------------------------------------------------------------------------------
f. MPC Cost Components
The MIA requires MPCs to be disaggregated the MPCs into material,
labor, depreciation, and overhead costs. DOE estimated MPC breakdowns
using the manufacturing cost model tool described in section IV.C.5.c,
and the estimated MPC breakdowns during interviews with manufacturers.
The MPC cost components are reported in the manufacturer impact
analysis described in chapter 9 of the direct final rule TSD.
6. Other Analytical Outputs
As discussed previously in section III.C, the DOE test procedure
specifies test points for the pool filter pump, waterfall pump, and
pressure cleaner booster pump equipment classes covered by this direct
final rule. For instance, the test points for self-priming and non-
self-priming pool filter pumps are at specified pump speeds on system
curve C, and the test point for pressure cleaner booster pumps is at 10
gpm of flow. In the field, the conditions in which these pumps operate
will not exactly match the test points. For instance, some pumps may
service pools with plumbing that approximates system curve A instead of
curve C, and some variable-speed pumps will be programmed to operate at
speeds that are higher or lower than the test point speeds specified in
the DOE test procedure. These variations in installation conditions are
modeled in the energy use analysis, which is discussed in section IV.D.
To facilitate the energy use analysis, DOE estimated the power
consumption of representative units across a variety of potential
installation conditions.
For self-priming and non-self-priming pool filter pumps, DOE
estimated the flow and energy factor of representative units operating
on system curves A, B, and C. DOE developed these estimates using
actual pump performance data on curves A, B, and C from the Pool Pump
Performance Database, combined with the motor substitution methodology
described in section IV.C.4.c. For efficiency levels with single-speed
motor configurations, DOE estimated flow and EF at 100-percent speed.
For efficiency levels with two-speed motor configurations, DOE
estimated flow and EF at 100 percent speed and at 50 percent speed. For
efficiency levels with variable-speed motor configurations, DOE
estimated flow and EF at 80 percent speed and at a low-speed test point
of either 24.7 gpm or 31.1 gpm, depending on the pump capacity. For
these variable-speed units, DOE also developed equations to estimate EF
as a function of flow for variable-speed representative units operating
at reduced speeds near the low-speed test point. DOE developed these
equations using the pump affinity laws and the regressions of pump
total efficiency versus pump speed described in section IV.C.4.c.
Chapter 5 of the direct final rule TSD provides further details on
these analytical outputs.
DOE also developed equations to estimate the power consumption as a
function of flow for waterfall pumps and pressure cleaner booster pumps
operating near the respective test points for those equipment classes.
DOE developed these equations by aggregating pump test data that was
submitted to DOE by manufacturers. The resulting equations estimate
head and power consumption as a function of flow for waterfall pumps
and pressure cleaner booster pumps at all efficiency levels. The
distribution of field installations and their operating parameters are
discussed further in the energy use analysis in section IV.E. Chapter 5
of the direct final rule TSD presents more details regarding these
analytical outputs.
7. Manufacturer Selling Price
To account for manufacturers' non-production costs and profit
margin, DOE applied a non-production cost multiplier (the manufacturer
markup) to the MPC. The resulting manufacturer selling price (MSP) is
the price at which the manufacturer distributes a unit into commerce.
DOE developed an average manufacturer markup by examining the
annual Securities and Exchange Commission (SEC) 10-K reports filed by
publicly traded manufacturers primarily engaged in pool pump
manufacturing and whose combined product range includes pool pumps. DOE
adjusted these estimates based on feedback received during confidential
manufacturer interviews. DOE estimated a manufacturer markup of 1.46
for self-priming and waterfall pool pumps, 1.35 for non-self-priming
and pressure cleaner booster pool pumps, and 1.27 for integral
cartridge filter and integral sand filter pool pumps.
D. Markups Analysis
The markups analysis develops appropriate markups in the
distribution chain and sales taxes to convert the MSP estimates derived
in the engineering analysis to consumer prices, which are then used in
the LCC and PBP analyses. At each step in the distribution channel,
companies mark up the price of the equipment to cover business costs
and profit margin.
1. Dedicated-Purpose Pool Pump Markups
For this dedicated-purpose pool pump direct final rule, DOE
identified two markets in which dedicated-purpose pool pumps pass from
the manufacturer to residential and commercial consumers: (1)
Replacement of a pool pump for an existing swimming pool; (2)
installation of a pool pump in a new swimming pool.
Based on manufacturer interviews, the distribution channels for
dedicated-purpose pool pumps were characterized as noted in Table IV-
23.
[[Page 5696]]
Table IV-23--Fraction of Dedicated-Purpose Pool Pump Distribution by
Channel
------------------------------------------------------------------------
Fraction of
Distribution channel dedicated-purpose
pool pumps (%)
------------------------------------------------------------------------
Replacement for an Existing Pool
------------------------------------------------------------------------
Manufacturer [rarr] Wholesaler [rarr] Pool Service 75
Contractor [rarr] Consumer.........................
Manufacturer [rarr] Pool Product Retailer [rarr] 20
Consumer...........................................
------------------------------------------------------------------------
New Installation for a New Pool
------------------------------------------------------------------------
Manufacturer [rarr] Pool Builder [rarr] Consumer.... 5
------------------------------------------------------------------------
For all market participants except for manufacturers, DOE developed
baseline and incremental markups. Baseline markups are applied to the
price of equipment with baseline efficiency, while incremental markups
are applied to the difference in price between baseline and higher
efficiency models (the incremental cost increase). The incremental
markup is typically less than the baseline markup, and is designed to
maintain similar per-unit operating profit before and after new or
amended standards.\72\
---------------------------------------------------------------------------
\72\ Because the projected price of standards-compliant
equipment is typically higher than the price of baseline equipment,
using the same markup for the incremental cost and the baseline cost
would tend to result in higher per-unit operating profit. While such
an outcome is possible, DOE maintains that in markets that are
reasonably competitive it is unlikely that standards would lead to a
sustainable increase in profitability in the long run.
---------------------------------------------------------------------------
To estimate baseline and incremental markups, DOE relied on several
sources, including: (1) For pool wholesalers, SEC form 10-K from Pool
Corp; \73\ (2) for pool product retailers, SEC form 10-K from several
major home improvement centers \74\ and U.S. Census Bureau 2012 Annual
Retail Trade Report,\75\ and (3) for pool contractors and pool
builders, U.S. Census Bureau 2012 Economic Census data \76\ on the
building construction industry.
---------------------------------------------------------------------------
\73\ U.S. Securities and Exchange Commission. SEC 10-K Reports
for Pool Corp (2010-2015). Available at www.sec.gov/ (Last accessed
May 26, 2016.).
\74\ U.S. Securities and Exchange Commission. SEC 10-K Reports
for Home Depot, Lowe's, Wal-Mart and Costco. Available at
www.sec.gov/ (Last accessed May 26, 2016.).
\75\ U.S. Census Bureau, 2012 Annual Retail Trade Report,
available at www.census.gov/retail/index.html (last accessed Dec. 3,
2015).
\76\ U.S. Census Bureau, 2012 Economic Census Data, available at
www.census.gov/econ/ (last accessed Dec. 3, 2015).
---------------------------------------------------------------------------
2. Replacement Motor Markups
As discussed in section IV.F, in some cases, only the motor
component in the pool pump is replaced instead of the entire pool pump.
DOE treated motor replacement as a repair of the pump. In this case,
the replacement motor typically goes through different distribution
channels than pool pumps. Based on inputs from motor manufacturers
inputs, DOE considered three distribution channels to characterize how
motors are distributed in the motor replacement market. Table IV-24
shows these distribution channels.
Table IV-24--Fraction of Dedicated-Purpose Pool Pump Replacement Motor
Distribution by Channel
------------------------------------------------------------------------
Fraction of pool
Distribution channel pumps (%)
------------------------------------------------------------------------
Via Motor Manufacturer
------------------------------------------------------------------------
(1) Motor Manufacturer [rarr] Wholesaler [rarr] 25
Contractor [rarr] Consumer.........................
(2) Motor Manufacturer [rarr] Wholesaler [rarr] 25
Retailer [rarr] Consumer via Internet or direct
sale at local stores...............................
------------------------------------------------------------------------
Via Pool Pump Manufacturer
------------------------------------------------------------------------
(3) Pump Manufacturer [rarr]Pump Product Retailer 50
[rarr] Consumer....................................
------------------------------------------------------------------------
Due to limited available information, DOE assumed that the motor
wholesaler markup in the second motor replacement channel via Internet
and direct local store sales is the same as in the first motor
replacement channel via contractor. To estimate baseline and
incremental markups for each of the market participants (except for
manufacturers) mentioned in Table IV-24, DOE relied on several sources,
including: (1) For motor wholesalers, U.S. Census Bureau 2012 Annual
Wholesale Trade Report; \77\ (2) for electrical contractors, RSMeans
electrical cost data; \78\ and (3) for motor retailers, U.S. Census
Bureau 2012 Annual Retail Trade Report.\79\
---------------------------------------------------------------------------
\77\ U.S. Census Bureau, 2012 Annual Wholesale Trade Report,
available at www.census.gov/wholesale/index.html (last accessed Dec.
3, 2015).
\78\ RSMeans. Electrical Cost Data 2015. 2014. RSMeans: Norwell,
MA.
\79\ U.S. Census Bureau, 2012 Annual Retail Trade Report,
available at www.census.gov/retail/index.html (last accessed April
28, 2016).
---------------------------------------------------------------------------
In addition to the markups, DOE obtained state and local taxes from
data provided by the Sales Tax Clearinghouse.\80\ These data represent
weighted average taxes that include county and city rates. DOE derived
shipment-weighted average tax values for each region considered in the
analysis.
---------------------------------------------------------------------------
\80\ Sales Tax Clearinghouse Inc., State Sales Tax Rates Along
with Combined Average City and County Rates (2016), available at
http://thestc.com/STrates.stm (last accessed April 18, 2016).
---------------------------------------------------------------------------
Chapter 6 of the direct final rule TSD provides details on DOE's
development of markups for pool pumps.
[[Page 5697]]
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of pool pumps at different efficiencies in
representative U.S. applications, and to assess the energy savings
potential of increased dedicated-purpose pool pump efficiency. The
energy use analysis estimates the range of energy use of dedicated-
purpose pool pumps in the field (i.e., as they are actually used by
consumers). The energy use analysis provides the basis for other
analyses DOE performed, particularly assessments of the energy savings
and the savings in consumer operating costs that could result from
adoption of standards.
1. Dedicated-Purpose Pool Pump Consumer Samples
DOE created individual consumer samples for five dedicated-purpose
pool pump markets: (1) Single-family homes with a swimming pool; (2)
indoor swimming pools in commercial applications; (3) single-family
community swimming pools; (4) multi-family community swimming pools;
and (5) outdoor swimming pools in commercial applications. DOE used the
samples to determine dedicated-purpose pool pump annual energy
consumption as well as for conducting the LCC and PBP analyses.
DOE used the Energy Information Administration's (EIA) 2009
Residential Energy Consumption Survey (RECS 2009) to establish a sample
of single-family homes that have a swimming pool.\81\ For dedicated-
purpose pool pumps used in indoor swimming pools in commercial
applications, DOE developed a sample using the 2012 Commercial Building
Energy Consumption Survey (CBECS 2012).\82\ RECS and CBECS include
information such as the household or building owner demographics and
the location of the household or building.
---------------------------------------------------------------------------
\81\ U.S. Department of Energy--Energy Information
Administration. 2009 RECS Survey Data. (Last accessed July 27,
2016.) www.eia.gov/consumption/residential/data/2009/.
\82\ U.S. Department of Energy--Energy Information
Administration. 2012 CBECS Survey Data. (Last accessed: July 27,
2016.) www.eia.gov/consumption/commercial/data/2012/index.cfm?view=microdata.
---------------------------------------------------------------------------
Neither RECS nor CBECS provide data on community pools or outdoor
swimming pools in commercial applications, so DOE created samples based
on other available data. To develop samples for dedicated-purpose pool
pumps in single or multi-family communities, DOE used a combination of
RECS 2009, U.S. Census 2009 American Home Survey Data (2009 AHS),\83\
and 2015 PK Data report.\84\ To develop a sample for pool pumps in
outdoor commercial swimming pools, DOE used a combination of CBECS 2012
and 2015 PK Data report.
---------------------------------------------------------------------------
\83\ U.S. Census Bureau. 2009 AHS survey data (Last accessed:
July 27, 2016.) www.census.gov/programs-surveys/ahs/data/2009/ahs-2009-public-use-file-puf-/2009-ahs-national-puf-microdata.html.
\84\ PK Data. 2015 Swimming Pool and Pool Heater Customized
Report for LBNL. (Last accessed: April 30, 2016.) www.pkdata.com/current-reports.html.
---------------------------------------------------------------------------
Table IV-25 shows the estimated shares of the five dedicated-
purpose pool pump markets in the existing stock based on the afore-
mentioned sources. The vast majority of dedicated-purpose pool pumps
are used for residential single-family swimming pools.
Table IV-25--Fraction of Dedicated-Purpose Pool Pumps by DPPP Market
------------------------------------------------------------------------
Fraction of
Pool type ID Description pool pumps (%)
------------------------------------------------------------------------
1.............................. Residential Single 95.1
Family Swimming Pools.
2.............................. Community Pools (Single 0.8
Family).
3.............................. Community Pools (Multi 0.4
Family).
4.............................. Commercial Indoor Pools 0.3
5.............................. Commercial Outdoor 3.4
Swimming Pools.
------------------------------------------------------------------------
Dedicated-purpose pool pumps can be installed with either above-
ground or in-ground swimming pools. DOE established separate sets of
consumer samples for in-ground pools and above-ground pools by
adjusting the original sample weights based on the number of installed
in-ground and above-ground pools in 2014 per state provided by APSP.
(EERE-2015-BT-STD-0008-0010, No. 31 at pp. 14-15) The consumer samples
for self-priming, auxiliary (waterfall) and pressure cleaner booster
pumps are drawn from the in-ground pool samples; the consumer samples
for non-self-priming and integral pumps are obtained from the above-
ground pool samples.
See chapter 7 of the direct final rule TSD for more details about
the creation of the consumer samples and the regional breakdowns.
2. Energy Use Estimation
DOE calculated the annual unit energy consumption (UEC) of pool
pumps at the considered efficiency levels by multiplying the average
daily UEC by the annual days of operation. For single-speed pool pumps,
the daily UEC is simply the pool pump power multiplied by the daily
operating hours. For two-speed and variable-speed pool pumps, the daily
UEC is the sum of low-speed mode power multiplied by the low-speed
daily operating hours and the high-speed mode power multiplied by the
corresponding daily operating hours.
a. Power Inputs
Self-Priming and Non-Self-Priming Pumps
For self-priming and non-self-priming pool pumps, the power inputs
are obtained by using flow (Q, in gallon/minute) divided by energy
factor (in gallon/Wh). In the case of single-speed pumps, Q and EF are
provided in the engineering analysis for each representative unit at
each system curve (A, B or C).\85\ In the case of two-speed pumps, Q
and EF are provided for both low-speed and high-speed modes for each
representative unit at each system curve. For variable-speed pumps, Q
and EF are provided only for the high-speed mode, which, according to
the DOE test procedure, corresponds to 80 percent of maximum speed; for
the low-speed mode, Q is specific to each consumer
[[Page 5698]]
and EF is provided as a function of Q. For each consumer in the sample,
DOE specified the system curve used (A, B or C) by drawing from a
probability distribution suggested by the DPPP Working Group. The
suggested distribution was based on field testing and experience
indicating that many pools are closer to curve C, but additional
amenities such as a sand filter or a heater would bring a pump's
performance to curve A. (EERE-2015-BT-STD-0008-0094, pp. 144-147) In
the recommended distribution, 35 percent of the pool pumps follow curve
A, 10 percent of the pool pumps follow curve B, and the remaining 55
percent follow curve C.
---------------------------------------------------------------------------
\85\ The requirements of a pool (or any water system), can be
expressed in terms of a system curve. When a pump is tested on a
system curve (such as curve C), any one of the measurements
hydraulic power, P (hp), volumetric flow, Q (gpm) and total dynamic
head, H (feet of water) can be used to calculate the other two
measurements. See section IV.A.1 for further details.
---------------------------------------------------------------------------
For variable-speed pumps, to define the consumer-specific low-speed
flow, DOE used the pool size divided by the desired time per turnover,
which was assumed by the DPPP Working Group to be 12 hours for
residential applications, and 6 or 10 hours for commercial applications
(EERE-2015-BT-STD-0008-0094 pp. 143-144). DOE developed a distribution
for pool size based on information given in several
references.86 87 88 The minimum of the pool size
distribution for standard-size self-priming pool pumps and integral
pool pumps was then decreased by the DPPP Working Group based on the
existing small pools on the market, and the mode of the pool size
distribution for standard-size non-self-priming pool pumps was
increased based on the DPPP Working Group's decision. (EERE-2015-BT-
STD-0008-0094 pp. 163-171) The pool size distributions for integral
pumps were later adjusted by the DPPP Working Group based on the
suggested pool sizes for the integral pumps on the market. (EERE-2015-
BT-STD-0008-0078 pp. 75-77) A minimum threshold of flow Q is considered
according to the capacity of the pumps. The variable-speed EF can
therefore be calculated, as it was provided in the engineering analysis
as a function of Q for each representative unit on each system curve.
---------------------------------------------------------------------------
\86\ CEE Residential Swimming Pool Initiative. (Last Accessed:
July 28, 2016) http://library.cee1.org/sites/default/files/library/9986/cee_res_swimmingpoolinitiative_07dec2012_pdf_10557.pdf.
\87\ California Energy Commission Pool Heater CASE. (Last
Accessed: July 28, 2016) www.energy.ca.gov/appliances/2013rulemaking/documents/proposals/12-AAER-2F_Residential_Pool_Pumps_and_Replacement_Motors/California_IOUs_Response_to_the_Invitation_for_Standards_Proposals_for_Pool_Heaters_2013-07-29_TN-71754.pdf.
\88\ Evaluation of potential best management practices--Pools,
Spas, and Fountains 2010. (Last Accessed: July 28, 2016) http://cuwcc.org/LinkClick.aspx?fileticket=3p3DgiY6ObY%3D.
---------------------------------------------------------------------------
Pressure Cleaner Booster Pumps and Waterfall Pumps
The test procedure final rule established a test point at 10 gpm of
flow for pressure cleaner booster pumps and a test point at 17 feet of
head for waterfall pumps. DOE developed a distribution for each of
these equipment classes, in coordination with the DPPP Working Group,
from which a flow or head value, respectively is drawn for each sampled
consumer. (Pressure cleaner booster pumps: EERE-2015-BT-STD-0008-0092
pp. 310; waterfall pumps: EERE-2015-BT-STD-0008-0094 pp. 149-150) For
waterfall pumps, DOE used the pump curve H = f(Q) provided in the
engineering analysis for each representative unit to determine the flow
Q associated with the selected head, from which the corresponding power
can be calculated based on the power curve P = f(Q), also provided by
the engineering analysis. For single-speed pressure cleaner booster
pumps, DOE calculated the power directly from the power curve P = f(Q)
from the engineering analysis. For variable-speed pressure cleaner
booster pumps, DOE estimated power consumption at reduced speed for
consumers with sampled Q above 10 gpm.
Integral Pumps
For integral pumps, the power value was provided for each
representative unit. DOE did not apply a distribution to this value
given that integral pumps are designed to be used for specific pools,
and therefore the power is not expected to vary widely.
b. Operating Hours
The following sub-sections describe DOE's methodology for
calculating daily operating hours for each pump variety. For self-
priming and non-self-priming pool filter pumps in residential
applications, operating hours are calculated uniquely for each consumer
based on pool size, number of turnovers per day (itself based on
ambient conditions), and the pump flow rate. In commercial
applications, DOE assumes these pumps operate 24 hours per day. For
integral pumps, those without a timer operate 12 hours a day, while
those with a timer have operating hours determined the same way as for
pool filter pumps. For pressure cleaner booster pumps and waterfall
pumps, operating hours are drawn from a distribution. Table IV-26
summarizes the results of these calculations.
Table IV-26--Weighted Average Daily Operating Hours by Pump Variety
------------------------------------------------------------------------
Weighted average daily
operating hours *
Pump variety -------------------------------
Residential Commercial
------------------------------------------------------------------------
Standard-Size Self-Priming Pool Filter 10 24
Pump...................................
Small-Size Self-Priming Pool Filter Pump 7.7 ..............
Standard-Size Non-Self-Priming Pool 6.2 ..............
Filter Pump............................
Extra-Small Non-Self-Priming Pool Filter 3.3 ..............
Pump...................................
Waterfall Pump.......................... 2.0 12.0
Pressure Cleaner Booster Pump........... 2.5 2.5
Integral Cartridge Filter Pool Pump..... 5.0 ..............
Integral Sand Filter Pool Pump.......... 4.8 ..............
------------------------------------------------------------------------
* Only during the pool operating season.
Self-Priming and Non-Self-Priming Pool Filter Pumps
For self-priming and non-self-priming pool filter pumps in
residential applications, the single-speed pump daily run time is the
product of the assigned pool size and the number of turnovers per day
divided by pump flow rate. For two-speed and variable-speed pumps, DOE
calculated run time at both high speed and low speed. For high speed,
DOE assumed a maximum of 2 hours a day based on the ENERGY
[[Page 5699]]
STAR calculator.\89\ For low speed, DOE calculated the runtime in the
same manner as for single-speed pumps and then subtracted two hours
(for assumed high-speed operation).\90\ In the two-speed analysis, DOE
followed the recommendation of the DPPP Working Group based on the
observations that some of the timer controls for two-speed pumps are
not wired correctly, or some of the consumers never operate at low-
speed. (EERE-2015-BT-STD-0008-0079 pp. 199-203) DOE assumed that 5
percent of the consumers either would not purchase or would not
correctly operate the timer control to switch from high-speed mode (the
default mode) to low-speed mode. For these consumers, high-speed
runtime was calculated in the same manner as for single-speed pumps,
and low-speed runtime was assumed to be zero.
---------------------------------------------------------------------------
\89\ ENERGY STAR Pool Pump Calculator. (Last Accessed: July,
2016) www.energystar.gov/sites/default/files/asset/document/Pool%20Pump%20Calculator.xlsx.
\90\ In cases where the calculation (product of pool volume
times turns per day, divided by flow) results in less than 2 hours,
the high speed run time is reduced to that value, and low speed run
time is assumed to be zero.
---------------------------------------------------------------------------
For each equipment class, DOE developed distributions for the
number of turnovers per day (i.e., the number of times a pool's
contents can be filtered through its filtration equipment in a 24-hour
period). The number of turnovers per day is drawn from a probability
distribution linked to the ambient condition of the sampled consumer
(hot humid, warm or cold) and sanitary requirements, especially for the
commercial pool samples. This distribution was adjusted and approved by
the DPPP Working Group based on the observation that some consumers do
not follow the Centers for Disease Control and Prevention (CDC)
recommendation \91\ and operate fewer turnovers than recommended.
(EERE-2015-BT-STD-0008-0094 pp. 175-186)
---------------------------------------------------------------------------
\91\ CDC suggests 4 turnovers per day for public aquatic
facilities. (Last accessed: September 21, 2016) http://www.cdc.gov/healthywater/pdf/swimming/pools/mahc/Complete-First-Edition-MAHC-Code.pdf.
---------------------------------------------------------------------------
For commercial applications, DOE assumed that single-speed pumps
operate 24 hours a day. (EERE-2015-BT-STD-0008-0094 p. 151) For the
two-speed and variable-speed pumps, based on the ENERGY STAR
calculator, the high speed was assumed to operate 2 hours per day,
while the low speed was assumed to operate the remaining 22 hours per
day. (EERE-2015-BT-STD-0008-0094 pp. 172-185)
Pressure Cleaner Booster Pumps and Waterfall Pumps
For pressure cleaner booster pumps and waterfall pumps, DOE drew
the operating hours from operating hours distributions suggested and
approved by the DPPP Working Group. (EERE-2015-BT-STD-0008-0094 pp.
159-162)
Integral Pumps
For integral pumps, the DPPP Working Group suggested that 80
percent of the consumers use these pumps without a timer. (EERE-2015-
BT-STD-0008-0094 p. 157) DOE assumed that integral pumps without a
timer operate 12 hours per day, based on the recommendation of the DPPP
Working Group (EERE-2015-BT-STD-0008-0094 pp. 155-157). For those that
have a timer, DOE calculated the operating hours the same way as for
residential single-speed self-priming pool filter pumps.
c. Annual Days of Operation
DOE calculated the annual unit energy consumption (UEC) by
multiplying the daily operating hours by the annual days of operation,
which depends on the number of months of pool operation. For each
consumer sample, DOE assigned different annual days of operation
depending on the region in which the dedicated-purpose pool pump is
installed. Table IV-27 provides the assumptions of pool pump operating
season based on geographical locations. This assignment was based on
DOE's Energy Saver Web site assumptions \92\ and PK Data \93\ that
include average pool season length (i.e., operating months) by state,
along with discussion of the geographic distribution of pool operating
days by the DPPP Working Group, which suggested that although some of
the regions had warm weather, the pool pumps should still be operating
all year long. (EERE-2015-BT-STD-0008-0094 pp. 191-193)
---------------------------------------------------------------------------
\92\ DOE Energy Saver. (Last Accessed: April 26, 2016) http://energy.gov/energysaver/articles/heat-pump-swimming-pool-heaters.
\93\ PK Data. 2015 Swimming Pool and Pool Heater Customized
Report for LBNL. (Last accessed: April 16, 2016) www.pkdata.com/current-reports.html.
Table IV-27--Pool Pump Operating Season Assumption by Geographical
Location
------------------------------------------------------------------------
Average months Pool use
Location (States or census divisions) of pool use months
------------------------------------------------------------------------
CT,ME,NH,RI,VT.......................... 4 5/1-8/31
MA...................................... 4 5/1-8/31
NY...................................... 4 5/1-8/31
NJ...................................... 4 5/1-8/31
PA...................................... 4 5/1-8/31
IL...................................... 4 5/1-8/31
IN,OH................................... 4 5/1-8/31
MI...................................... 4 5/1-8/31
WI...................................... 4 6/1-9/30
IA,MN,ND,SD............................. 4 6/1-9/30
KS,NE................................... 4 6/1-9/30
MO...................................... 4 6/1-9/30
VA...................................... 7 4/1-10/31
DE,DC,MD................................ 5 5/1-9/30
GA...................................... 7 4/1-10/31
NC,SC................................... 7 4/1-10/31
FL...................................... 12 1/1-12/31
AL,KY,MS................................ 12 1/1-12/31
TN...................................... 12 1/1-12/31
AR,LA,OK................................ 12 1/1-12/31
TX...................................... 12 1/1-12/31
CO...................................... 4 5/1-8/31
ID,MT,UT,WY............................. 4 5/1-8/31
[[Page 5700]]
AZ...................................... 12 1/1-12/31
NV,NM................................... 12 1/1-12/31
CA...................................... 12 1/1-12/31
OR,WA................................... 3 6/1-8/31
AK...................................... 5 5/1-9/30
HI...................................... 12 1/1-12/31
WV...................................... 5 5/1-9/30
New England............................. 4 5/1-8/31
Middle Atlantic......................... 5 5/1-9/30
East North Central...................... 5 5/1-9/30
West North Central...................... 4 6/1-9/30
South Atlantic.......................... 12 1/1-12/31
East South Central...................... 12 1/1-12/31
West South Central...................... 12 1/1-12/31
Mountain................................ 4 5/1-8/31
Pacific................................. 12 1/1-12/31
------------------------------------------------------------------------
Chapter 7 of the direct final rule TSD provides details on DOE's
energy use analysis for pool pumps.
F. Life-Cycle Cost and Payback Period Analyses
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual consumers of potential energy conservation standards for
dedicated-purpose pool pumps. The effect of new or amended energy
conservation standards on individual consumers usually involves a
reduction in operating cost and an increase in purchase cost. DOE used
the following two metrics to measure consumer impacts:
The LCC (life-cycle cost) is the total consumer expense of
equipment over the life of that equipment, consisting of total
installed cost (MSP, distribution chain markups, sales tax, and
installation costs) plus operating costs (expenses for energy use,
maintenance, and repair). To compute the operating costs, DOE discounts
future operating costs to the time of purchase and sums them over the
lifetime of the equipment.
The PBP is the estimated amount of time it takes consumers
to recover the increased purchase cost (including installation) of
more-efficient equipment through lower operating costs. DOE calculates
the PBP by dividing the change in purchase cost at higher efficiency
levels by the change in annual operating cost for the year that amended
or new standards are assumed to take effect.
For any given efficiency level, DOE measures the change in LCC
relative to the LCC in the no-standards case, which reflects the
estimated efficiency distribution of pool pumps in the absence of
energy conservation standards. In contrast, the PBP for a given
efficiency level is measured relative to the baseline equipment.
For each considered efficiency level in each equipment class, DOE
calculated the LCC and PBP for a nationally representative set of
consumers. As stated previously, DOE developed consumer samples from
the 2009 RECS and 2012 CBECS. For each consumer in the sample, DOE
determined the energy consumption for the pool pump and the appropriate
energy price. By developing a representative sample of consumers, the
analysis captured the variability in energy consumption and energy
prices associated with the use of pool pumps.
Inputs to the calculation of total installed cost include the cost
of the equipment--which includes MPCs, manufacturer markups, retailer
and distributor markups, and sales taxes--and installation costs.
Inputs to the calculation of operating expenses include annual energy
consumption, energy prices and price projections, repair and
maintenance costs, equipment lifetimes, and discount rates. DOE created
distributions of values for equipment lifetime, discount rates, and
sales taxes, with probabilities attached to each value, to account for
their uncertainty and variability.
The computer model DOE uses to calculate the LCC and PBP, which
incorporates Crystal Ball\TM\ (a commercially-available software
program), relies on a Monte Carlo simulation to incorporate uncertainty
and variability into the analysis. The Monte Carlo simulations randomly
sample input values from the probability distributions and pool pump
consumer samples. The model calculated the LCC and PBP for equipment at
each efficiency level for 10,000 units per simulation run.
DOE calculated the LCC and PBP for all consumers of pool pumps as
if each were to purchase a new product in the expected year of required
compliance with new energy efficiency standards. As discussed in
section III.B, the standards would apply to pool pumps manufactured 54
months years after the date on which new standards are published. At
the time of the analysis for this rule, DOE estimated publication of
this direct final rule in the second half of 2016. Therefore, for
purposes of its analysis, DOE used 2021 as the year of compliance with
any new standards for pool pumps.
Table IV-28 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations. The subsections that follow
provide further discussion. Details of the spreadsheet model, and of
all the inputs to the LCC and PBP analyses, are contained in chapter 8
of the direct final rule TSD and its appendices.
Table IV-28--Summary of Inputs and Methods for the LCC and PBP Analysis *
----------------------------------------------------------------------------------------------------------------
Inputs Source/method
----------------------------------------------------------------------------------------------------------------
Equipment Cost............................................... Derived by multiplying MPCs by manufacturer and
retailer markups and sales tax, as appropriate.
Used historical data to derive a price scaling
index to project equipment costs.
[[Page 5701]]
Installation Costs........................................... Baseline installation cost determined with data
from manufacturer interviews.
Annual Energy Use............................................ The daily energy consumption multiplied by the
number of operating days per year.
Variability: Based on regional data and 2009 RECS
and 2012 CBECS.
Energy Prices................................................ Electricity: Based on EIA's Form 861 data for
2014.
Variability: Regional energy prices determined
for 30 regions for pool pumps in individual
single-family homes and 9 census divisions for
pool pumps in community and commercial pool
pumps.
Marginal prices used for electricity.
Energy Price Trends.......................................... Based on AEO2016 No-CPP case price projections.
Repair and Maintenance Costs................................. Consider only motor replacement as repair cost,
which includes labor cost from RS Means and
motor cost provided with MPC.
Equipment Lifetime........................................... For residential applications, on average 7 years
for self-priming and waterfall pumps, 5 years
for non-self-priming and pressure cleaner
booster pumps, and 4 years for integral pumps.
For commercial applications, the residential
equipment lifetime is adjusted according to the
ratio of commercial to residential daily
operating hours.
Variability: Based on Weibull distribution.
Discount Rates............................................... Residential: Approach involves identifying all
possible debt or asset classes that might be
used to purchase the considered appliances, or
might be affected indirectly. Primary data
source was the Federal Reserve Board's Survey of
Consumer Finances.
Commercial: Calculated as the weighted average
cost of capital for entities purchasing pool
pumps. Primary data source was Damodaran Online.
Compliance Date.............................................. 2021.
----------------------------------------------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided in the sections following the table or in
chapter 8 of the direct final rule TSD.
1. Equipment Cost
To calculate consumer equipment costs, DOE multiplied the MPCs
developed in the engineering analysis by the markups described above
(along with sales taxes). DOE used different markups for baseline
products and higher efficiency products, because DOE applies an
incremental markup to the increase in MSP associated with higher
efficiency products.
To project an equipment price trend for the direct final rule, DOE
derived an inflation-adjusted index of the Producer Price Index (PPI)
for pumps and pumping equipment over the period 1984-2015.\94\ These
data show a general price index increase from 1987 through 2009. Since
2009, there has been no clear trend in the price index. Given the
relatively slow global economic activity in 2009 through 2015, the
extent to which the future trend can be predicted based on the last two
decades is uncertain and the observed data do not provide a firm basis
for projecting future cost trends for pump equipment. Therefore, for
single-speed and two-speed pumps, DOE used a constant price assumption
as the default trend to project future pump prices in 2021. For
variable-speed pool pumps, however, DOE assumed that the controls
portion of the electrically commutated motor would be affected by price
learning. DOE used PPI data on ``Semiconductors and related device
manufacturing'' between 1967 and 2015 to estimate the historic price
trend of electronic components in the control.\95\ The regression
performed as an exponential trend line fit results in an R-square of
0.98, with an annual price decline rate of 6 percent.
---------------------------------------------------------------------------
\94\ Series ID PCU333911333911; www.bls.gov/ppi/ ppi/.
\95\ Semiconductors and related device manufacturing PPI series
ID: PCU334413334413; www.bls.gov/ppi/.
---------------------------------------------------------------------------
2. Installation Cost
Installation cost includes labor, overhead, and any miscellaneous
materials and parts needed to install the product. DOE estimates all
the installation costs associated with fitting a dedicated-purpose pool
pump in a new housing unit (new owners), or as a replacement for an
existing pool pump. To simplify the calculation, DOE only accounted for
the difference of installation cost by efficiency levels. For two-speed
pumps, DOE included the cost of a timer control and its installation
where applicable, as recommended by the DPPP Working Group (EERE-2015-
BT-STD-0008-0079 pp. 199-203). DOE used information obtained in the
manufacturer interviews to calculate the supplemental installation
labor costs for two-speed and variable-speed pumps.
See chapter 8 of the direct final rule TSD for more details on
installation costs.
3. Annual Energy Consumption
For each sampled installation, DOE determined the energy
consumption for a dedicated-purpose pool pump at different efficiency
levels using the approach described in section IV.E of this direct
final rule.
4. Energy Prices
DOE used residential electricity prices for dedicated-purpose pool
pumps in residential applications, and commercial electricity prices
for dedicated-purpose pool pumps in commercial applications.
DOE derived average annual residential marginal electricity prices
for 30 geographic regions and commercial marginal electricity prices
for 9 census divisions using 2015 data from the EIA.\96\
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\96\ U.S. Department of Energy-Energy Information
Administration, Form EIA-826 Database Monthly Electric Utility Sales
and Revenue Data (2015) available at www.eia.doe.gov/cneaf/electricity/page/eia826.html.
---------------------------------------------------------------------------
To estimate electricity prices in future years, DOE multiplied the
average regional prices by annual energy price factors derived from the
forecasts of annual average residential and commercial electricity
price changes by region that are consistent with cases described on p.
E-8 in AEO 2016.\97\ AEO
[[Page 5702]]
2016 has an end year of 2040. To estimate price trends after 2040, DOE
used the average annual rate of change in prices from 2030 to 2040.
---------------------------------------------------------------------------
\97\ EIA. Annual Energy Outlook 2016 with Projections to 2040.
Washington, DC. Available at www.eia.gov/forecasts/aeo/. The
standards finalized in this rulemaking will take effect a few years
prior to the 2022 commencement of the Clean Power Plan compliance
requirements. As DOE has not modeled the effect of CPP during the 30
year analysis period of this rulemaking, there is some uncertainty
as to the magnitude and overall effect of the energy efficiency
standards. These energy efficiency standards are expected to put
downward pressure on energy prices relative to the projections in
the AEO 2016 case that incorporates the CPP. Consequently, DOE used
the electricity price projections found in the AEO 2016 No-CPP case
as these electricity price projections are expected to be lower,
yielding more conservative estimates for consumer savings due to the
energy efficiency standards.
---------------------------------------------------------------------------
5. Repair and Maintenance Costs
Repair costs are associated with repairing or replacing equipment
components that have failed in an appliance; maintenance costs are
associated with maintaining the operation of the equipment. Typically,
small incremental increases in equipment efficiency produce no, or only
minor, changes in repair and maintenance costs compared to baseline
efficiency equipment. DOE assumed that for maintenance costs, there is
no change with efficiency level, and therefore DOE did not include
those costs in the model.
The primary repair cost for dedicated-purpose pool pumps is motor
replacement, and cost of a motor does vary by efficiency level. DOE
estimated that such replacement occurs at the halfway point in a pump's
lifetime, but only for those dedicated-purpose pool pumps whose
lifetime exceeds the average lifetime for the relevant equipment class.
The cost of the motor was determined in the engineering analysis and
the markups analysis. DOE used 2015 RS Means, a well-known and
respected construction cost estimation source, to estimate labor costs
for pump motor replacement.\98\ DOE accounted for the difference in
labor hours depending on the dedicated-purpose pool pump horsepower, as
well as regional differences in labor hourly costs.
---------------------------------------------------------------------------
\98\ RS Means Company, Inc., RS Means Electrical Cost Data 2015
(2015).
---------------------------------------------------------------------------
Further detail regarding the repair costs developed for dedicated-
purpose pool pumps can be found in chapter 8 of the direct final rule
TSD.
6. Equipment Lifetime
DOE used dedicated-purpose pool pump lifetime estimates from
manufacturer input and the DPPP Working Group's discussion (EERE-2015-
BT-STD-0008-0094 pp. 209-223). The data allowed DOE to develop a
survival function, which provides a distribution of lifetime ranging
from a minimum of 2 or 3 years based on warranty covered period, to a
maximum of 15 years, with a mean value of 7 years for self-priming and
waterfall pumps, 5 years for non-self-priming and pressure cleaner
booster pumps, and 4 years for integral pumps. These values are
applicable to pumps in residential applications. For commercial
applications, DOE scaled the lifetime to acknowledge the higher
operating hours compared to residential applications, resulting in a
reduced average lifetime.
7. Discount Rates
In calculating the LCC, DOE applies discount rates appropriate to
consumers to estimate the present value of future operating costs. The
discount rate used in the LCC analysis represents the rate from an
individual consumer's perspective. DOE estimated a distribution of
residential discount rates for dedicated-purpose pool pumps based on
the opportunity cost of funds related to appliance energy cost savings
and maintenance costs.
To establish residential discount rates for the LCC analysis, DOE
identified all relevant household debt or asset classes in order to
approximate a consumer's opportunity cost of funds related to appliance
energy cost savings. It estimated the average percentage shares of the
various types of debt and equity by household income group using data
from the Federal Reserve Board's Survey of Consumer Finances \99\ (SCF)
for 1995, 1998, 2001, 2004, 2007, 2010 and 2013. Using the SCF and
other sources, DOE developed a distribution of rates for each type of
debt and asset by income group to represent the rates that may apply in
the year in which amended standards would take effect. DOE assigned
each sample household a specific discount rate drawn from one of the
distributions. The average rate across all types of household debt and
equity and income groups, weighted by the shares of each type, is 4.6
percent.
---------------------------------------------------------------------------
\99\ Board of Governors of the Federal Reserve System. Survey of
Consumer Finances. 1995, 1998, 2001, 2004, 2007, 2010, and 2013.
(Last accessed December 15, 2015.) (www.federalreserve.gov/econresdata/scf/scfindex.htm).
---------------------------------------------------------------------------
DOE applies weighted average discount rates calculated from
consumer debt and asset data, rather than marginal or implicit discount
rates.\100\ The LCC does not analyze the equipment purchase decision,
so the implicit discount rate is not relevant in this model. The LCC
estimates net present value over the lifetime of the equipment, so the
appropriate discount rate will reflect the general opportunity cost of
household funds, taking this time scale into account. Given the long
time horizon modeled in the LCC, the application of a marginal interest
rate associated with an initial source of funds is inaccurate.
Regardless of the method of purchase, consumers are expected to
continue to rebalance their debt and asset holdings over the LCC
analysis period, based on the restrictions consumers face in their debt
payment requirements and the relative size of the interest rates
available on debts and assets. DOE estimates the aggregate impact of
this rebalancing using the historical distribution of debts and assets.
---------------------------------------------------------------------------
\100\ The implicit discount rate is inferred from a consumer
purchase decision between two otherwise identical goods with
different first cost and operating cost. It is the interest rate
that equates the increment of first cost to the difference in net
present value of lifetime operating cost, incorporating the
influence of several factors: Transaction costs; risk premiums and
response to uncertainty; time preferences; interest rates at which a
consumer is able to borrow or lend.
---------------------------------------------------------------------------
To establish commercial discount rates for the small fraction of
applications where businesses purchase and use dedicated-purpose pool
pumps, DOE estimated the weighted-average cost of capital using data
from Damodaran Online.\101\ The weighted-average cost of capital is
commonly used to estimate the present value of cash flows to be derived
from a typical company project or investment. Most companies use both
debt and equity capital to fund investments, so their cost of capital
is the weighted average of the cost to the firm of equity and debt
financing. DOE estimated the cost of equity using the capital asset
pricing model, which assumes that the cost of equity for a particular
company is proportional to the systematic risk faced by that company.
---------------------------------------------------------------------------
\101\ Damodaran Online, Data Page: Costs of Capital by Industry
Sector (2016). (Last accessed April, 2016) http://
pages.stern.nyu.edu/~adamodar/.
---------------------------------------------------------------------------
See chapter 8 of the direct final rule TSD for further details on
the development of consumer discount rates.
8. Energy Efficiency Distribution in the No-Standards Case
To accurately estimate the share of consumers that would be
affected by a potential energy conservation standard at a particular
efficiency level, DOE's LCC analysis considered the projected
distribution (market shares) of equipment efficiencies under the no-
standards case.
The estimated efficiency market shares for dedicated-purpose pool
pumps for 2015 were based on manufacturer interviews. To project
efficiencies to the compliance year, 2021, DOE shifted 1 percent per
year of the market share in the single-speed efficiency levels to the
variable-speed efficiency levels. (See section IV.H.1 for more detail.)
For the equipment classes that don't have variable-speed efficiency
levels (i.e., waterfall pumps and integral
[[Page 5703]]
pumps), efficiency was held constant at 2015 levels based on the
Working Group discussion. (EERE-2015-BT-STD-0008-0078 pp. 138-141)
Table IV-29 shows the efficiency distribution for the self-priming
pool filter pump equipment class as an example. See chapter 8 of the
direct final rule TSD for further information on the derivation of the
efficiency distributions, as well as the distributions for the
remaining equipment classes.
Table IV-29--Efficiency Distribution in the No-Standards Case for Self-
Priming Pool Filter Pumps in 2021
------------------------------------------------------------------------
National
Efficiency level Description market share
(%)
------------------------------------------------------------------------
0 (Baseline).............. Low efficiency single-speed 39
motor; Low hydro efficiency.
1......................... Medium efficiency single- 15
speed motor; Low hydro
efficiency.
2......................... High efficiency single-speed 10
motor; Low hydro efficiency.
3......................... Low efficiency two-speed 2
motor; Low hydro efficiency.
4......................... Medium efficiency two-speed 2
motor; Low hydro efficiency.
5......................... High efficiency two-speed 2
motor; Low hydro efficiency.
6......................... Variable-speed motor; Low 11
hydro efficiency (High
speed is 80% of max).
7......................... Variable-speed motor; High 19
hydro efficiency (High
speed is 80% of max).
------------------------------------------------------------------------
9. Payback Period Analysis
The payback period is the amount of time it takes the consumer to
recover the additional installed cost of more-efficient equipment,
compared to baseline equipment, through energy cost savings. Payback
periods are expressed in years. Payback periods that exceed the life of
the equipment mean that the increased total installed cost is not
recovered in reduced operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the equipment and the change in the
first-year annual operating expenditures relative to the baseline. The
PBP calculation uses the same inputs as the LCC analysis, except that
discount rates are not needed.
As noted above, EPCA, as amended, 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 first year's energy savings resulting from
the standard, as calculated under the applicable test procedure. (42
U.S.C. 6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determined the value of the first year's energy savings by calculating
the energy savings in accordance with the applicable DOE test
procedure, and multiplying those savings by the average energy price
forecast for the year in which compliance with the new standards would
be required.
G. Shipments Analysis
DOE uses projections of annual equipment shipments to calculate the
national impacts of potential or new amended energy conservation
standards on energy use, emissions, NPV, and future manufacturer cash
flows. The shipments model takes an accounting approach, tracking
market shares of each equipment class and the vintage of units in the
stock. Stock accounting uses equipment shipments as inputs to estimate
the age distribution of in-service product stocks for all years. The
age distribution of in-service product stocks is a key input to
calculations of both the NES and NPV, because operating costs for any
year depend on the age distribution of the stock.
For the direct final rule, because there was no readily available
data on dedicated-purpose pool pump shipments, DOE estimated shipments
in 2015 using data collected from manufacturer interviews. Shipments
were projected from 2015 throughout the end of the analysis period
(2050) initially using growth rates obtained from manufacturer
interviews, the Veris Consulting report, and several macroeconomic
indicators. These rates were then reviewed by the DPPP Working Group,
which recommended minor modifications to the growth rates \102\ (EERE-
2015-BT-STD-0008-0078, pp. 106-120). The modified growth rates were
also applied in reverse to determine historical shipments. DOE was then
able to apply retirement functions derived from dedicated-purpose pool
pump lifetime estimates to each vintage in historical shipments to
calculate the existing stock. Shipments were divided into two market
segments: Replacements and new pool construction. The market segment
associated with dedicated-purpose pool pump replacements was calculated
such that the stock is maintained, using historical shipments, lifetime
curves, and repair-replace decision making. The market segment for new
pool construction pool pump installations is thus the difference
between total shipments and replacement shipments.
---------------------------------------------------------------------------
\102\ The initial growth rates for Non-Self-Priming Pool Filter
Pumps and Integral Cartridge Filter Pumps were -2.77% and -2.0%,
respectively. These were adjusted due to Working Group
recommendations to 3.08% (so that Non-Self-Priming Pool Filter Pumps
matched the rate of Self-Priming Pool Filter Pumps) and 2.0% (so
that Integral Cartridge Filter Pumps matched the rate of Integral
Sand Filter Pumps).
---------------------------------------------------------------------------
Because the standards-case projections take into account the
increase in purchase price and the decrease in operating costs
associated with higher efficiency equipment, projected shipments for a
standards case typically deviate from those for the no- standards case.
Because purchase price tends to have a larger impact than operating
cost on equipment purchase decisions, standards-case projections
typically show a decrease in shipments relative to the no-standards
case. For dedicated-purpose pool pumps, DOE modeled this impact in two
ways. In the replacement segment, DOE implemented a repair-replace
model in which under the standards case where the pool pump is more
expensive, 60 percent of the time the pump is repaired (i.e., motor
replacement) rather than replaced, compared to only around 40 percent
in the base case. (EERE-2015-BT-STD-0008-0100 pp. 173-175) In the new
construction segment, DOE implemented a relative price elasticity.
However, DOE determined that where the cost of the pool far exceeds the
incremental cost of a more-efficient pump (i.e., inground pool
installations or, where timers are considered, larger inflatable/rigid
steel-framed installations), shipments would not be affected by an
increase in purchase price of the dedicated-purpose pool pump.
Therefore, a relative price elasticity, which accounts for the total
[[Page 5704]]
installed cost of the pool including the pump, is only applied to non-
self-priming pool filter pumps, smaller integral cartridge filter pool
pumps, and smaller integral sand filter pool pumps, and is based on
DPPP Working Group recommendations and data obtained from manufacturer
interviews. The elasticity \103\ implemented was 0.2. (EERE-2015-BT-
STD-0008-0079 pp. 67-72, 138-139) See chapter 9 of the direct final
rule TSD for more detail on the shipments model.
---------------------------------------------------------------------------
\103\ Elasticity of -0.2 was only applied to approximately 40%
of the integral cartridge filter and integral sand filter pump
shipments, thus yielding an effective elasticity of -0.08 for these
two categories rather than -0.2. This percentage represents the
smallest and least expensive segment of this market, where an
increase in pump price due to standards is significant relevant to
the pool price.
---------------------------------------------------------------------------
H. National Impact Analysis
The NIA assesses the national energy savings (NES) and the national
net present value from a national perspective of total consumer costs
and savings that would be expected to result from new or amended
standards at specific efficiency levels.\104\ DOE calculates the NES
and NPV for the potential standard levels considered based on
projections of annual equipment shipments, along with the annual energy
consumption and total installed cost data from the energy use and LCC
analyses. For the present analysis, DOE projected the energy savings,
operating cost savings, equipment costs, and NPV of consumer benefits
over the lifetime of pool pumps sold from 2021 through 2050.
---------------------------------------------------------------------------
\104\ The NIA accounts for impacts in the 50 States and U.S.
territories.
---------------------------------------------------------------------------
DOE evaluated the impacts of new standards by comparing a case
without such standards with standards-case projections. The no-
standards case characterizes energy use and consumer costs for each
equipment class in the absence of new energy conservation standards.
For this projection, DOE considers trends in efficiency and various
forces that are likely to affect the mix of efficiencies over time. DOE
compares the no-standards case with projections characterizing the
market for each equipment class if DOE adopted new standards at
specific energy efficiency levels (i.e., the TSLs or standards cases)
for that class. For the standards cases, DOE considers how a given
standard would likely affect the market shares of equipment with
efficiencies greater than the standard.
DOE uses a spreadsheet model to calculate the energy savings and
the national consumer costs and savings from each TSL. Interested
parties can review DOE's analyses by changing various input quantities
within the spreadsheet. The NIA spreadsheet model uses typical values
(as opposed to probability distributions) as inputs.
Table IV-30 summarizes the inputs and methods DOE used for the NIA
analysis for the direct final rule. Discussion of these inputs and
methods follows the table. See chapter 10 of the direct final rule TSD
for further details.
Table IV-30--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments............................ Annual shipments from shipments
model.
Compliance Date of Standard.......... 2021.
Efficiency Trends.................... No-standards case: Future trend
shifts 1% per year from single-
speed efficiency levels to
variable-speed efficiency
levels.
Standards cases: Roll-up in the
compliance year. 1% shift also
used.
Annual Energy Consumption per Unit... Annual weighted-average values
are a function of energy use at
each efficiency level.
Total Installed Cost per Unit........ Annual weighted-average values
are a function of cost at each
efficiency level.
Incorporates projection of future
equipment prices based on
historical data.
Annual Energy Cost per Unit.......... Annual weighted-average values as
a function of the annual energy
consumption per unit and energy
prices.
Repair and Maintenance Cost per Unit. Annual values increase with
higher efficiency levels.
Energy Prices........................ AEO2016 no-CPP case price
forecasts (to 2040) and
extrapolation through 2050.
Energy Site-to-Primary and FFC A time-series conversion factor
Conversion. based on AEO2016.
Discount Rate........................ Three and seven percent.
Present Year......................... 2016.
------------------------------------------------------------------------
1. Equipment Efficiency Trends
A key component of the NIA is the trend in energy efficiency
projected for the no-standards case and each of the standards cases.
Chapter 8 of the direct final rule TSD describes how DOE developed an
energy efficiency distribution for the no-standards case for each of
the considered equipment classes for the first year of anticipated
compliance with an amended or new standard. To project the trend in
efficiency absent standards for pool pumps over the entire shipments
projection period, DOE shifted 1 percent per year of the market share
in the single-speed efficiency levels to the variable-speed efficiency
levels. For the equipment classes that do not have variable-speed
efficiency levels, efficiency was held constant at 2015 levels. The
DPPP Working Group agreed with DOE's assumptions. (EERE-2015-BT-STD-
0008-0078 pp. 138-141).
For the standards cases, DOE used a ``roll-up'' scenario to
establish the shipment-weighted efficiency for the first year of
compliance assumed for standards (2021). In this scenario, the market
shares of equipment in the no-standards case that do not meet the
standard under consideration would roll up'' to meet the new standard
level, and the market share of equipment above the standard would
remain unchanged. In the standards cases, the efficiency after the
compliance year increases at a rate similar to that of the no-standards
case.
2. National Energy Savings
The national energy savings analysis involves a comparison of
national energy consumption of the considered equipment between each
potential standards case (TSL) and the case with no energy conservation
standards. DOE calculated the national energy consumption by
multiplying the number of units (stock) of each equipment (by vintage
or age) by the unit energy consumption (also by vintage). DOE
calculated annual NES based on the difference in national energy
consumption for the no-standards case and for each higher efficiency
standard case. DOE estimated energy consumption and savings based on
site energy and converted the
[[Page 5705]]
electricity consumption and savings to primary energy (i.e., the energy
consumed by power plants to generate site electricity) using annual
conversion factors derived from AEO2016. Cumulative energy savings are
the sum of the NES for each year over the timeframe of the analysis.
In 2011, in response to the recommendations of a committee on
Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards appointed by the National Academy of Sciences, DOE
announced its intention to use full-fuel-cycle (FFC) measures of energy
use and greenhouse gas and other emissions in the national impact
analyses and emissions analyses included in future energy conservation
standards rulemakings.76 FR 51281 (August 18, 2011). After evaluating
the approaches discussed in the August 18, 2011 document, DOE published
a statement of amended policy in which DOE explained its determination
that EIA's National Energy Modeling System (NEMS) is the most
appropriate tool for its FFC analysis and its intention to use NEMS for
that purpose. 77 FR 49701 (August 17, 2012). NEMS is a public domain,
multi-sector, partial equilibrium model of the U.S. energy sector \105\
that EIA uses to prepare its Annual Energy Outlook. The FFC factors
incorporate losses in production and delivery in the case of natural
gas (including fugitive emissions) and additional energy used to
produce and deliver the various fuels used by power plants. The
approach used for deriving FFC measures of energy use and emissions is
described in appendix 10B of the direct final rule TSD.
---------------------------------------------------------------------------
\105\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview, DOE/EIA-0581 (2009) (Oct. 2009)
(Available at www.eia.gov/forecasts/aeo/nems/overview/pdf/0581(2009).pdf).
---------------------------------------------------------------------------
3. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by consumers are: (1) Total annual installed cost; (2)
total annual operating costs (energy costs and repair and maintenance
costs); and (3) a discount factor to calculate the present value of
costs and savings. DOE calculates net savings each year as the
difference between the no-standards case and each standards case in
terms of total savings in operating costs versus total increases in
installed costs. DOE calculates operating cost savings over the
lifetime of each unit shipped during the projection period.
As previously noted in section IV.F.1, for single-speed and two-
speed pumps, DOE used a constant price assumption as the default price
trend to project future pump prices for single-speed and two-speed
pumps. For variable-speed pool pumps, however, DOE followed a
suggestion from the Working Group and assumed that the controls portion
of the electrically commutated motor would be affected by price
learning,\106\ and used an annual price decline rate of 6 percent. To
evaluate the effect of uncertainty regarding the price trend estimates,
DOE investigated the impact of different product price forecasts on the
consumer NPV for the considered TSLs for dedicated-purpose pool pumps.
In addition to the default price trend, DOE considered two product
price sensitivity cases: (1) A low price trend based on an exponential
fit to the integral horsepower motors and generators PPI from 1991 to
2000 for equipment classes with integral sized motors (self-priming 1
hp and self-priming 3 hp), and an exponential fit to fractional
horsepower motors PPI from 1967 to 2015 for equipment classes with
fractional sized motors (small-size self-priming pool filter pumps,
standard-size non-self-priming pool filter pumps, extra-small non-self-
priming pool filter pumps, waterfall pumps, pressure cleaner booster
pumps, integral sand filter pool pumps, and integral cartridge filter
pool pumps); and (2) a high price trend based on an exponential fit to
the integral horsepower motors and generators PPI from 1969 to 2015 for
the equipment classes with integral sized motors, and an exponential
fit to the fractional horsepower motors PPI from 2001 to 2015 for the
equipment classes with fractional sized motors.\107\ The derivation of
these price trends and the results of these sensitivity cases are
described in appendix 10C of the direct final rule TSD.
---------------------------------------------------------------------------
\106\ A member of the Working Group suggested adding price
learning to the controls portion of variable-speed efficiency
levels, similar to what was done in the Ceiling Fans Rulemaking
(EERE-2015-BT-STD-0008-0079, pp. 95-96, and also EERE-2015-BT-STD-
0008-0100, pp. 159-161).
\107\ U.S. Census. Producer Price Index data. Available at
www.bls.gov/ppi/
---------------------------------------------------------------------------
The operating cost savings are the sum of the differences in energy
cost savings, maintenance, and repair costs, which are calculated using
the estimated energy savings in each year and the projected price of
the appropriate form of energy. To estimate energy prices in future
years, DOE multiplied the average regional prices by annual energy
price factors derived from the forecasts of annual average residential
and commercial electricity price changes by region that are consistent
with cases described on p. E-8 in AEO 2016,\108\ which has an end year
of 2040. To estimate price trends after 2040, DOE used the average
annual rate of change in prices from 2030 to 2040. As part of the NIA,
DOE also analyzed scenarios that used lower and higher energy price
trends. NIA results based on these cases are presented in appendix 10C
of the DPPP direct final rule TSD.
---------------------------------------------------------------------------
\108\ The standards finalized in this rulemaking will take
effect a few years prior to the 2022 commencement of the Clean Power
Plan compliance requirements. As DOE has not modeled the effect of
CPP during the 30 year analysis period of this rulemaking, there is
some uncertainty as to the magnitude and overall effect of the
energy efficiency standards. These energy efficiency standards are
expected to put downward pressure on energy prices relative to the
projections in the AEO 2016 case that incorporates the CPP.
Consequently, DOE used the electricity price projections found in
the AEO 2016 No-CPP case as these electricity price projections are
expected to be lower, yielding more conservative estimates for
consumer savings due to the energy efficiency standards.
---------------------------------------------------------------------------
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPR, DOE estimated the NPV of consumer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (OMB) to Federal agencies on the development of regulatory
analysis.\109\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
---------------------------------------------------------------------------
\109\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis (September 17, 2003), section E. (Available
at www.whitehouse.gov/omb/memoranda/m03-21.html).
---------------------------------------------------------------------------
I. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended energy
conservation standards on consumers, DOE evaluates the impact on
identifiable subgroups of consumers that may be disproportionately
affected by a new or amended national standard. The purpose of a
subgroup analysis is to determine the extent of any such
disproportional impacts. DOE evaluates impacts on particular subgroups
of consumers by analyzing the LCC impacts and PBP for those particular
consumers from alternative standard
[[Page 5706]]
levels. For this direct final rule, DOE analyzed the impacts of the
considered standard levels on senior-only households.\110\ The analysis
used a subset of the RECS 2009 sample is comprised of households that
meet the criteria for the subgroup. DOE used the LCC and PBP
spreadsheet model to estimate the impacts of the considered efficiency
levels on the subgroup. Chapter 11 in the direct final rule TSD
describes the consumer subgroup analysis.
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\110\ DOE did not evaluate low-income consumer subgroup impacts
because the sample size of the subgroup is too small for meaningful
analysis.
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J. Manufacturer Impact Analysis
1. Overview
DOE conducted an MIA for dedicated-purpose pool pumps to estimate
the financial impact of standards on manufacturers of dedicated-purpose
pool pumps. The MIA has both quantitative and qualitative aspects. The
quantitative part of the MIA relies on the GRIM, an industry cash-flow
model customized for the dedicated-purpose pool pumps covered in this
rulemaking. The key GRIM inputs are data on the industry cost
structure, MPCs, shipments, assumptions about manufacturer markups, and
conversion costs. The key MIA output is INPV. DOE used the GRIM to
calculate cash flows using standard accounting principles and to
compare changes in INPV between the no-standards case and various TSLs
(the standards cases). The difference in INPV between the no-standards
case and the standards cases represents the financial impact of energy
conservation standards on dedicated-purpose pool pump manufacturers.
Different sets of assumptions (scenarios) produce different INPV
results. The qualitative part of the MIA addresses factors such as
manufacturing capacity; characteristics of, and impacts on, any
particular subgroup of manufacturers, including small manufacturers;
and impacts on competition.
DOE conducted the MIA for this rulemaking in three phases. In the
first phase, DOE prepared an industry characterization based on the
market and technology assessment and publicly available information. In
the second phase, DOE estimated industry cash flows in the GRIM using
industry financial parameters derived in the first phase and the
shipments derived in the shipment analysis. In the third phase, DOE
conducted interviews with dedicated-purpose pool pumps manufacturers
that account for the large majority of domestic DPPP sales covered by
this rulemaking. During these interviews, DOE discussed engineering,
manufacturing, procurement, and financial topics specific to each
company, and obtained each manufacturer's view of the dedicated-purpose
pool pump industry as a whole. The interviews provided information that
DOE used to evaluate the impacts of amended standards on manufacturers'
cash flows, manufacturing capacities, and direct domestic manufacturing
employment levels. See section V.B.2.b of this direct final rule for
the discussion on the estimated changes in the number of domestic
employees involved in manufacturing dedicated-purpose pool pumps
covered by energy conservation standards.
During the third phase, DOE used the results of the industry
characterization analysis in the first phase and feedback from
manufacturer interviews to group manufacturers that exhibit similar
production and cost structure characteristics. DOE identified one
manufacturer subgroup for a separate impact analysis: Small businesses.
DOE determined that dedicated-purpose pool pump manufacturing falls
under the North American Industry Classification System (NAICS) code
333911, pump and pumping equipment manufacturing. The U.S. Small
Business Administration (SBA) defines a small business as having less
than 750 total employees for manufacturing under this NAICS code. This
threshold includes all employees in a business' parent company and any
other subsidiaries. Based on this classification, DOE identified five
domestic dedicated-purpose pool pump businesses that manufacture
dedicated-purpose pool pumps in the United States and qualify as small
businesses per the SBA threshold. DOE analyzed the impact on the small
business subgroup in the complete MIA in the Regulatory Flexibility
analysis, required by the Regulatory Flexibility Act, 5 U.S.C. 601, et.
seq., presented in section VII.B of this final rule.
2. Government Regulatory Impact Model and Key Inputs
DOE uses the GRIM to quantify the changes in cash flow due to new
standards that result in a higher or lower industry value. The GRIM
uses an annual discounted cash-flow analysis that incorporates MPCs,
manufacturer markups, shipments, and industry financial information as
inputs. The GRIM models the changes in MPCs, the distribution of
shipments, manufacturing investments, and manufacturer margins that
could change as a result from new energy conservation standards. The
GRIM spreadsheet uses the inputs to arrive at a series of annual cash
flows, beginning in 2016 (the reference year of the analysis) and
continuing to 2050 (the terminal year of the analysis). DOE calculated
INPVs by summing the stream of annual discounted cash flows during this
period. DOE used a real discount rate of 11.8 percent for all
dedicated-purpose pool pump equipment classes. This discount rate is
derived from industry financials and modified based on feedback
received during manufacturer interviews.
The GRIM calculates cash flows using standard accounting principles
and compares changes in INPV between the no-standards case and each
standards case. The difference in INPV between the no-standards case
and the standards cases represents the financial impact of new energy
conservation standards on manufacturers. As discussed previously, DOE
developed critical GRIM inputs using a number of sources, including
publicly available data, results of the engineering analysis, results
of the shipments analysis, and information gathered from industry
stakeholders during the course of manufacturer interviews and
subsequent working group meetings. The GRIM results are presented in
section V.B.2. Additional details about the GRIM, the discount rate,
and other financial parameters can be found in chapter 12 of the direct
final rule TSD.
a. Manufacturer Production Costs
Manufacturing more efficient equipment is typically more expensive
than manufacturing baseline equipment due to the use of more complex
components, which are typically more costly than baseline components.
The changes in the MPCs of covered equipment can affect the revenues,
gross margins, and cash flow of the industry.
In the MIA, DOE used the MPCs calculated in the engineering
analysis, as described in section IV.C.5 and further detailed in
chapter 5 of the direct final rule TSD. DOE made several revisions to
the MPCs based on feedback and data that was received during the
working group meetings. The MIA used these MPCs as inputs to the MIA
for the direct final rule.
b. Shipments Forecasts
The GRIM estimates manufacturer revenues based on (1) total unit
shipment forecasts and the distribution of those shipments by
efficiency level, (2) MPCs, and (3) manufacturer markups. Changes in
sales volumes and efficiency mix over time can significantly affect
manufacturer
[[Page 5707]]
finances. For this analysis, the GRIM uses the annual shipment
forecasts derived from the shipments analysis from 2016 to 2050. See
section IV.G of this direct final rule for additional details.
c. Product and Capital Conversion Costs
Energy conservation standards could cause manufacturers to incur
conversion costs to bring their production facilities and equipment
designs into compliance. DOE evaluated the level of conversion-related
expenditures that would be needed to comply with each considered
efficiency level in each equipment class. For the MIA, DOE classified
these conversion costs into two major groups: (1) Product conversion
costs; and (2) capital conversion costs. Product conversion costs are
investments in research and development, testing, marketing, and other
non-capitalized costs necessary to make product designs to comply with
new energy conservation standards. Capital conversion costs are
investments in property, plant, and equipment necessary to adapt or
change existing production facilities such that new compliant product
designs can be fabricated and assembled.
In general, DOE assumes all conversion-related investments occur
between the year of publication of the direct final rule and the year
by which manufacturers must comply with the new standards. DOE used
inputs from manufacturer interviews and feedback from the working group
meetings to evaluate the level of conversion costs manufacturers would
likely incur to comply with new energy conservation standards. The
majority of design options analyzed represent the implementation of
more efficient motors, either single-speed, two-speed, or variable-
speed. For standard-size self-priming, small-size self-priming,
standard-size non-self-priming, waterfall, and pressure cleaner booster
pool pumps, the max-tech efficiency level represents a hydraulic wet-
end redesign. For extra-small non-self-priming pool filter pumps max-
tech represents the implementation of a more efficient single-speed
motor, and for integral cartridge-filter pool pumps and integral sand
filter pool pumps DOE analyzed the incorporation of a timer as a design
option.
Product conversion costs represent the majority of conversion costs
for efficiency levels that represent a motor redesign and are estimated
on a per model basis. DOE estimated product conversion costs of
$140,000, $160,000, and $500,000 per model to implement a single-speed,
two-speed, or variable-speed motor in a dedicated-purpose pool pump,
respectively. DOE estimated the incorporation of a variable-speed motor
to cost an additional $100,000 for standard-size non-self-priming pool
filter pumps, because there are currently no non-self-priming pool
filter pumps on the market with variable-speed motors. The additional
product conversion costs represent housing redesign costs to
accommodate variable-speed motors.
In addition to motor redesign costs and testing and certification
costs, DOE estimated the per-model cost for new tooling and machinery
that would be needed as a result of new standards. DOE approximated
capital conversion costs of $100,000 per wet-end when incorporating
single-speed, two-speed, or variable-speed motors in dedicated-purpose
pool pumps. These estimates are based on comments from manufacturers
made during working group meetings that a motor change could alter the
dimensions of a dedicated-purpose pool pump and require investments in
packaging machines and other equipment. The working group offered no
objections to this estimate. (Docket No. EERE-2015-BT-STD-0008-0079,
April 19 DPPP Working Group Meeting, at p. 105)
Max-tech represents a hydraulic wet-end redesign for all equipment
classes except for extra-small non-self-priming pool filter pumps,
integral cartridge filter pumps, and integral sand filter pumps. DOE
estimated product conversion costs for a hydraulic redesign at $500,000
per wet-end, in addition to the previously discussed $500,000 per model
to incorporate a variable-speed motor. The hydraulic redesign costs
represent research and development costs associated with optimizing the
impeller and the volute for efficiency. For capital conversion costs,
at max-tech, DOE estimated $1.5 million per wet-end for self-priming
and waterfall pumps, $750,000 per wet-end for non-self-priming pool
filter pumps, and $375,000 per wet-end for pressure cleaner booster
pumps. These estimates vary based on the type of tooling and machinery
that is used to manufacture pumps in different equipment classes.
Max-tech for extra-small non-self-priming pool filter pumps
represents the incorporation of a more efficient single-speed motor.
DOE used the conversion cost estimates previously described to
implement a single-speed motor.
After gathering per-model and per-wet-end conversion cost
estimates, DOE analyzed self-priming pool filter pump equipment
offerings to estimate the number of dedicated-purpose pool pumps that
would be redesigned at each efficiency level. DOE used catalogs from
the three largest dedicated-purpose pool pump manufacturers that have
approximately 75 percent of all self-priming pool filter pump models in
the market based on DOE's product database. DOE first listed all self-
priming pool filter pumps of the three manufacturers and estimated
their efficiency based on descriptions found in catalogs. All analyzed
manufacturer catalogs list the number of speeds (i.e., single-speed,
two-speed, multi-speed, or variable-speed) and the catalogs provided an
estimate of their efficiency (i.e., single-speed standard efficiency
compared to single-speed energy efficient).
After DOE estimated the efficiency of each dedicated-purpose pool
pump, DOE grouped pumps together for each manufacturer based on their
performance characteristics, including: The pump wet-ends, port size,
voltage, total horsepower, and pump performance curve (i.e., head vs.
flow curve). This allowed DOE to make a mapping with pump
characteristics on one axis and pump efficiency level on the other
axis. DOE used this mapping to estimate the number of dedicated-purpose
pool pumps that would be redesigned if a standard were set at each
efficiency level. DOE assumed that:
Pumps with the same performance characteristics, but a
different efficiency, can replace each other.
There can be no gaps in equipment offerings. At least one
pump has to meet the efficiency at each performance characteristic.
A redesigned single- or two-speed pump can only replace
one other pump.
A variable-speed pump can replace multiple single and two-
speed pumps with the same wet-end, port size, voltage, and similar
total horsepower.
These assumptions were discussed during the working group meetings
and allowed DOE to estimate the number of self-priming pool filter
pumps needed to be redesigned at each efficiency level for each
manufacturer. (Docket No. EERE-2015-BT-STD-0008-0100, May 18 DPPP
Working Group Meeting, at p. 23-24) To estimate the total number of
industry redesigns DOE divided the number of redesigns per efficiency
level by the percent of models that belongs to the three largest
manufacturers.
DOE did not have reliable performance data for non-self-priming,
waterfall, and pressure cleaner booster pumps. Therefore, DOE used the
shipments distribution to estimate the number of pumps that do not meet
each efficiency level. In the absence of data, DOE assumed
manufacturers would redesign 25 percent of non-compliant
[[Page 5708]]
non-self-priming models. DOE presented this number to the working
group, which included manufacturers of such equipment. However the
working group offered no suggestions on how to change the number.
Therefore DOE continued using the assumption that manufacturers would
redesign 25 percent of non-compliant non-self-priming models. (Docket
No. EERE-2015-BT-STD-0008-0079, April 19 DPPP Working Group Meeting, at
p. 64) Further, DOE assumed that all non-compliant pressure cleaner
booster and waterfall models would be redesigned due to the limited
number of models in the market.
The design option analyzed for integral cartridge filter and
integral sand filter pool pumps represents the incorporation of a
timer. Based on confidential interviews with manufacturers that
represent the majority of the market, DOE estimates that the R&D
required to design a pump with a timer requires a full month of work
for three engineers, and involves testing and certification costs. DOE
estimated that the per model product conversion costs associated with
adding a timer are $50,000 for integral cartridge filter pumps and
$60,000 for integral sand filter pumps. DOE used specification sheets
to determine the number of integral cartridge filter pumps and integral
sand filter pumps that do not have a timer and multiplied this by the
per model product conversion cost to calculate industry product
conversion costs.
In addition, manufacturers that own tooling and machinery may incur
capital conversion costs to replace molding machines and tooling. DOE
estimated that the capital conversion costs associated with these
activities would be $220,000 per manufacturer. DOE multiplied this by
the number of manufacturers that own tooling and machinery, to
calculate industry capital conversion costs. DOE presented these
conversion cost estimates to the DPPP working group.
In responses, Hayward stated that the product conversion costs [for
integral pumps] are probably nominally low. (Docket No. EERE-2015-BT-
STD-0008-0079, April 19 DPPP Working Group Meeting, at p. 130) However,
Hayward is not a manufacturer of integral cartridge filter and integral
sand filter pool pumps and did not provide specific recommendations to
alter the estimates. In addition the numbers presented during the
working group reflect input from manufacturers that represent the
majority of the market. Therefore, DOE used the product conversion
costs estimates presented during the working group.
Testing and Certification Costs
DOE also estimated the magnitude of the aggregate industry
compliance testing costs needed to conform to new energy conservation
standards. Although compliance testing costs are a subset of product
conversion costs, DOE estimated these costs separately. DOE pursued
this approach because no energy conservation standards currently exist
for dedicated-purpose pool pumps; as such, all basic models will be
required to be tested and certified to comply with new energy
conservation standards regardless of the level of such a standard. As a
result, the industry-wide magnitude of these compliance testing costs
will be constant, regardless of the selected standard level.
DOE notes that new energy conservation standards will require every
model offered for sale to be tested according to the sampling plan
proposed in the test procedure final rule. This sampling plan specifies
that a minimum of two units must be tested to certify a basic model as
compliant. DOE estimated the industry-wide magnitude of compliance
testing by multiplying the estimated number of models currently in each
equipment class by the cost to test each model. DOE used product
specification sheets and information from manufacturer interviews to
estimate the total number of models in each equipment class. DOE
estimated testing and certification costs based on input from third-
party test labs and manufacturers to be $11,000 per model, which
applies to all self-priming, all non-self-priming, pressure cleaner
booster and waterfall pumps.
d. Markup Scenarios
As discussed in section IV.C.5, the MPCs for dedicated-purpose pool
pumps are the manufacturers' production costs for those units. These
costs include materials, labor, depreciation, and overhead, which are
collectively referred to as the cost of goods sold. The MSP is the
price received by DPPP manufacturers from the first sale, typically to
a wholesaler or a retailer, regardless of the downstream distribution
channel through which the dedicated-purpose pool pumps are ultimately
sold. The MSP is not the same as the cost the end user pays for the
dedicated-purpose pool pump, because there are typically multiple sales
along the distribution chain and various markups applied to each sale.
The MSP equals the MPC multiplied by the manufacturer markup. The
manufacturer markup covers all the dedicated-purpose pool pump
manufacturer's non-production costs (i.e., selling, general, and
administrative expenses; research and development; interest) as well as
profit. Total industry revenue for DPPP manufacturers equals the MSPs
at each efficiency level multiplied by the number of shipments at that
efficiency level.
Modifying these manufacturer markups in the standards cases yields
a different set of impacts on DPPP manufacturers than in the no-
standards case. For the MIA, DOE modeled three standards case markup
scenarios for dedicated-purpose pool pumps to represent the uncertainty
regarding the potential impacts on prices and profitability for DPPP
manufacturers following the implementation of standards. The three
scenarios are: (1) A preservation of gross margin markup scenario, or
flat markup; (2) a preservation of operating profit markup scenario;
and (3) a two-tiered markup scenario. Each scenario leads to different
manufacturer markup values, which, when applied to the inputted MPCs,
result in varying revenue and cash-flow impacts on DPPP manufacturers.
Under the preservation of gross margin percentage scenario, DOE
applied a single uniform ``gross margin percentage'' markup across all
efficiency levels, which assumes that manufacturers would be able to
maintain the same amount of profit as a percentage of revenues at all
efficiency levels within an equipment class. DOE used manufacturer
interviews, and publicly available financial information for
manufacturers to estimate the preservation of gross margin markup for
each equipment class. DOE estimated a manufacturer markup of 1.46 for
all self-priming and waterfall pumps, 1.35 for all non-self-priming and
pressure cleaner booster pumps, and 1.27 for integral cartridge filter
and integral sand filter pool pumps. DOE presented these manufacturer
markups to the working group and did not receive any objection. (Docket
No. EERE-2015-BT-STD-0008-0079, April 19 DPPP Working Group Meeting, at
p. 92-99)
The preservation of operating profit markup scenario assumes that
manufacturers are not able to yield additional operating profit from
higher production costs and the investments that are required to comply
with new DPPP energy conservation standards. Instead this scenario
assumes that manufacturers are only able to maintain the no-standards
case total operating profit in absolute dollars in the standards cases,
despite higher product costs and investment.
[[Page 5709]]
DOE implemented the two-tiered markup scenario because multiple
manufacturers stated in interviews that they offer tiers of product
lines that are differentiated, in part, by efficiency level.
Specifically, manufacturers stated that they earn lower markups on
self-priming pool filter pumps that have variable-speed functionality,
compared to self-priming pool filter pumps with single or two-speed
functionality. As higher standards push more consumers to purchase
variable-speed motors, manufacturers lose sales of higher margin
single- and two-speed motor dedicated-purpose pool pumps. Therefore,
average manufacturer markups decrease.
A comparison of industry financial impacts under the three markup
scenarios is presented in section V.B.2.a of this direct final rule.
K. Emissions Analysis
The emissions analysis consists of two components. The first
component estimates the effect of potential energy conservation
standards on power sector and site (where applicable) combustion
emissions of CO2, NOX, SO2, and Hg.
The second component estimates the impacts of potential standards on
emissions of two additional greenhouse gases, CH4 and
N2O, as well as the reductions to emissions of all species
due to ``upstream'' activities in the fuel production chain. These
upstream activities comprise extraction, processing, and transporting
fuels to the site of combustion. The associated emissions are referred
to as upstream emissions.
The analysis of power sector emissions uses marginal emissions
factors that were derived from data in AEO2016, as described in section
IV.M. The methodology is described in chapter 13 and chapter 15 of the
DPPP direct final rule TSD.
Combustion emissions of CH4 and N2O are
estimated using emissions intensity factors published by the EPA:
Greenhouse Gases HG Emissions Factors Hub.\111\ The FFC upstream
emissions are estimated based on the methodology described in chapter
15 of the DPPP direct final rule TSD. The upstream emissions include
both emissions from fuel combustion during extraction, processing, and
transportation of fuel, and ``fugitive'' emissions (direct leakage to
the atmosphere) of CH4 and CO2.
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\111\ Available at www.epa.gov/climateleadership/center-corporate-climate-leadership-ghg-emission-factors-hub.
---------------------------------------------------------------------------
The emissions intensity factors are expressed in terms of physical
units per megawatt-hour (MWh) or million Btu (MMBtu) of site energy
savings. Total emissions reductions are estimated using the energy
savings calculated in the national impact analysis.
For CH4 and N2O, DOE calculated emissions
reduction in tons and also in terms of units of CO2-
equivalent (CO2eq). Emissions of CH4 and
N2O are often converted to CO2eq by multiplying
each ton of gas by the gas' global warming potential (GWP) over a 100-
year time horizon. Based on the Fifth Assessment Report of the
Intergovernmental Panel on Climate Change,\112\ DOE used GWP values of
28 for CH4 and 265 for N2O.
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\112\ IPCC (2013). Climate Change 2013: The Physical Science
Basis. Contribution of Working Group I to the Fifth Assessment
Report of the Intergovernmental Panel on Climate Change Stocker,
T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A.
Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.). Cambridge University
Press, Cambridge, United Kingdom and New York, NY, USA. Chapter 8.
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The AEO incorporates the projected impacts of existing air quality
regulations on emissions. AEO2016 generally represents current
legislation and environmental regulations, including recent government
actions, for which implementing regulations were available as of the
end of February 2016. DOE's estimation of impacts accounts for the
presence of the emissions control programs discussed in the following
paragraphs.
SO2 emissions from affected electric generating units
(EGUs) are subject to nationwide and regional emissions cap-and-trade
programs. Title IV of the Clean Air Act sets an annual emissions cap on
SO2 for affected EGUs in the 48 contiguous States and the
District of Columbia (DC). (42 U.S.C. 7651 et seq.) SO2
emissions from 28 eastern States and DC were also limited under the
Clean Air Interstate Rule (CAIR). 70 FR 25162 (May 12, 2005). CAIR
created an allowance-based trading program that operates along with the
Title IV program. In 2008, CAIR was remanded to EPA by the U.S. Court
of Appeals for the District of Columbia Circuit, but it remained in
effect.\113\ In 2011, EPA issued a replacement for CAIR, the Cross-
State Air Pollution Rule (CSAPR). 76 FR 48208 (Aug. 8, 2011). On August
21, 2012, the D.C. Circuit issued a decision to vacate CSAPR,\114\ and
the court ordered EPA to continue administering CAIR. On April 29,
2014, the U.S. Supreme Court reversed the judgment of the D.C. Circuit
and remanded the case for further proceedings consistent with the
Supreme Court's opinion.\115\ On October 23, 2014, the D.C. Circuit
lifted the stay of CSAPR.\116\ Pursuant to this action, CSAPR went into
effect (and CAIR ceased to be in effect) as of January 1, 2015.\117\
AEO2016 incorporates implementation of CSAPR.
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\113\ See North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008),
modified on rehearing, 550 F.3d 1176 (D.C. Cir. 2008).
\114\ See EME Homer City Generation, LP v. EPA, 696 F.3d 7.
\115\ See EPA v. EME Homer City Generation, 134 S. Ct. 1584,
1610 (U.S. 2014). The Supreme Court held in part that EPA's
methodology for quantifying emissions that must be eliminated in
certain States due to their impacts in other downwind States was
based on a permissible, workable, and equitable interpretation of
the Clean Air Act provision that provides statutory authority for
CSAPR.
\116\ See EME Homer City Generation, L.P. v. EPA, Order (D.C.
Cir. filed October 23, 2014) (No. 11-1302).
\117\ On July 28, 2015, the D.C. Circuit issued its opinion
regarding the remaining issues raised with respect to CSAPR that
were remanded by the Supreme Court. The D.C. Circuit largely upheld
CSAPR, but remanded to EPA without vacatur certain States' emission
budgets for reconsideration. EME Homer City Generation, LP v. EPA,
795 F.3d 118 (D.C. Cir. 2015).
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The attainment of emissions caps is typically flexible among EGUs
and is enforced through the use of emissions allowances and tradable
permits. Under existing EPA regulations, any excess SO2
emissions allowances resulting from the lower electricity demand caused
by the adoption of an efficiency standard could be used to permit
offsetting increases in SO2 emissions by any regulated EGU.
In past years, DOE recognized that there was uncertainty about the
effects of efficiency standards on SO2 emissions covered by
the existing cap-and-trade system, but it concluded that negligible
reductions in power sector SO2 emissions would occur as a
result of standards.
Beginning in 2016, however, SO2 emissions will fall as a
result of the Mercury and Air Toxics Standards (MATS) for power plants.
77 FR 9304 (Feb. 16, 2012). In the MATS final rule, EPA established a
standard for hydrogen chloride as a surrogate for acid gas hazardous
air pollutants (HAP), and also established a standard for
SO2 (a non-HAP acid gas) as an alternative equivalent
surrogate standard for acid gas HAP. The same controls are used to
reduce HAP and non-HAP acid gas; thus, SO2 emissions will be
reduced as a result of the control technologies installed on coal-fired
power plants to comply with the MATS requirements for acid gas. AEO2016
assumes that, in order to continue operating, coal plants must have
either flue gas desulfurization or dry sorbent injection systems
installed by 2016. Both technologies, which are used to reduce acid gas
emissions, also reduce SO2 emissions. Under the MATS,
emissions will be far below the cap established by
[[Page 5710]]
CSAPR, so it is unlikely that excess SO2 emissions
allowances resulting from the lower electricity demand would be needed
or used to permit offsetting increases in SO2 emissions by
any regulated EGU.\118\ Therefore, DOE believes that energy
conservation standards that decrease electricity generation will
generally reduce SO2 emissions in 2016 and beyond.
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\118\ DOE notes that on June 29, 2015, the U.S. Supreme Court
ruled that the EPA erred when the agency concluded that cost did not
need to be considered in the finding that regulation of hazardous
air pollutants from coal- and oil-fired electric utility steam
generating units (EGUs) is appropriate and necessary under section
112 of the Clean Air Act (CAA). Michigan v. EPA, 135 S. Ct. 2699
(2015). The Supreme Court did not vacate the MATS rule, and DOE has
tentatively determined that the Court's decision on the MATS rule
does not change the assumptions regarding the impact of energy
conservation standards on SO2 emissions. Further, the
Court's decision does not change the impact of the energy
conservation standards on mercury emissions. The EPA, in response to
the U.S. Supreme Court's direction, has now considered cost in
evaluating whether it is appropriate and necessary to regulate coal-
and oil-fired EGUs under the CAA. EPA concluded in its final
supplemental finding that a consideration of cost does not alter the
EPA's previous determination that regulation of hazardous air
pollutants, including mercury, from coal- and oil-fired EGUs, is
appropriate and necessary. 79 FR 24420 (April 25, 2016). The MATS
rule remains in effect, but litigation is pending in the D.C.
Circuit Court of Appeals over EPA's final supplemental finding MATS
rule.
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CSAPR established a cap on NOX emissions in 28 eastern
States and the District of Columbia. Energy conservation standards are
expected to have little effect on NOX emissions in those
States covered by CSAPR because excess NOX emissions
allowances resulting from the lower electricity demand could be used to
permit offsetting increases in NOX emissions from other
facilities. However, standards would be expected to reduce
NOX emissions in the States not affected by the caps, so DOE
estimated NOX emissions reductions from the standards
considered in this direct final rule for these States.
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would likely reduce Hg emissions. DOE estimated mercury
emissions reduction using emissions factors based on AEO2016, which
incorporates the MATS.
The AEO2016 Reference case (and some other cases) assumes
implementation of the Clean Power Plan (CPP), which is the EPA program
to regulate CO2 emissions at existing fossil-fired electric
power plants.\119\ DOE used the AEO2016 No-CPP case as a basis for
developing emissions factors for the electric power sector to be
consistent with its use of the No-CPP case in the NIA.\120\
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\119\ U.S. Environmental Protection Agency, ``Carbon Pollution
Emission Guidelines for Existing Stationary Sources: Electric
Utility Generating Units'' (Washington, DC: October 23, 2015).
https://www.federalregister.gov/articles/2015/10/23/2015-22842/carbon-pollution-emission-guidelines-for-existing-stationary-sources-electric-utility-generating.
\120\ As DOE has not modeled the effect of CPP during the 30
year analysis period of this rulemaking, there is some uncertainty
as to the magnitude and overall effect of the energy efficiency
standards. With respect to estimated CO2 and
NOX emissions reductions and their associated monetized
benefits, if implemented the CPP would result in an overall decrease
in CO2 emissions from electric generating units (EGUs),
and would thus likely reduce some of the estimated CO2
reductions associated with this rulemaking.
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L. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of this rule, DOE considered the
estimated monetary benefits from the reduced emissions of
CO2, CH4, N2O and NOX that
are expected to result from each of the TSLs considered. In order to
make this calculation analogous to the calculation of the NPV of
consumer benefit, DOE considered the reduced emissions expected to
result over the lifetime of products shipped in the projection period
for each TSL. This section summarizes the basis for the values used for
monetizing the emissions benefits and presents the values considered in
this direct final rule.
1. Social Cost of Carbon
The SC-CO2 is an estimate of the monetized damages
associated with an incremental increase in carbon emissions in a given
year. It is intended to include (but is not limited to) climate-change-
related changes in net agricultural productivity, human health,
property damages from increased flood risk, and the value of ecosystem
services. Estimates of the SC-CO2 are provided in dollars
per metric ton of CO2. A domestic SC-CO2 value is
meant to reflect the value of damages in the United States resulting
from a unit change in CO2 emissions, while a global SC-
CO2 value is meant to reflect the value of damages
worldwide.
Under section 1(b)(6) of Executive Order 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993), agencies must, to
the extent permitted by law, ``assess both the costs and the benefits
of the intended regulation and, recognizing that some costs and
benefits are difficult to quantify, propose or adopt a regulation only
upon a reasoned determination that the benefits of the intended
regulation justify its costs.'' The purpose of the SC-CO2
estimates presented here is to allow agencies to incorporate the
monetized social benefits of reducing CO2 emissions into
cost-benefit analyses of regulatory actions. The estimates are
presented with an acknowledgement of the many uncertainties involved
and with a clear understanding that they should be updated over time to
reflect increasing knowledge of the science and economics of climate
impacts.
As part of the interagency process that developed these SC-
CO2 estimates, technical experts from numerous agencies met
on a regular basis to consider public comments, explore the technical
literature in relevant fields, and discuss key model inputs and
assumptions. The main objective of this process was to develop a range
of SC-CO2 values using a defensible set of input assumptions
grounded in the existing scientific and economic literatures. In this
way, key uncertainties and model differences transparently and
consistently inform the range of SC-CO2 estimates used in
the rulemaking process.
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the incremental economic impacts of
CO2 emissions, the analyst faces a number of challenges. A
report from the National Research Council \121\ points out that any
assessment will suffer from uncertainty, speculation, and lack of
information about (1) future emissions of GHGs, (2) the effects of past
and future emissions on the climate system, (3) the impact of changes
in climate on the physical and biological environment, and (4) the
translation of these environmental impacts into economic damages. As a
result, any effort to quantify and monetize the harms associated with
climate change will raise questions of science, economics, and ethics
and should be viewed as provisional.
---------------------------------------------------------------------------
\121\ National Research Council. Hidden Costs of Energy:
Unpriced Consequences of Energy Production and Use. 2009. National
Academies Press: Washington, DC.
---------------------------------------------------------------------------
Despite the limits of both quantification and monetization, SC-
CO2 estimates can be useful in estimating the social
benefits of reducing CO2 emissions. Although any numerical
estimate of the benefits of reducing carbon dioxide emissions is
subject to some uncertainty, that does not relieve DOE of its
obligation to attempt to factor those benefits into its cost-benefit
analysis. Moreover, the interagency working group (IWG) SC-
CO2 estimates are well supported by the existing scientific
and economic
[[Page 5711]]
literature. As a result, DOE has relied on the IWG SC-CO2
estimates in quantifying the social benefits of reducing CO2
emissions. DOE estimates the benefits from reduced (or costs from
increased) emissions in any future year by multiplying the change in
emissions in that year by the SC-CO2 values appropriate for
that year. The NPV of the benefits can then be calculated by
multiplying each of these future benefits by an appropriate discount
factor and summing across all affected years.
It is important to emphasize that the current SC-CO2
values reflect the IWG's best assessment, based on current data, of the
societal effect of CO2 emissions. The IWG is committed to
updating these estimates as the science and economic understanding of
climate change and its impacts on society improves over time. In the
meantime, the interagency group will continue to explore the issues
raised by this analysis and consider public comments as part of the
ongoing interagency process.
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing carbon dioxide emissions. To ensure consistency in how
benefits are evaluated across Federal agencies, the Administration
sought to develop a transparent and defensible method, specifically
designed for the rulemaking process, to quantify avoided climate change
damages from reduced CO2 emissions. The interagency group
did not undertake any original analysis. Instead, it combined SC-
CO2 estimates from the existing literature to use as interim
values until a more comprehensive analysis could be conducted. The
outcome of the preliminary assessment by the interagency group was a
set of five interim values that represented the first sustained
interagency effort within the U.S. government to develop an SC-
CO2 estimate for use in regulatory analysis. The results of
this preliminary effort were presented in several proposed and final
rules issued by DOE and other agencies.
b. Current Approach
After the release of the interim values, the IWG reconvened on a
regular basis to generate improved SC-CO2 estimates.
Specially, the IWG considered public comments and further explored the
technical literature in relevant fields. It relied on three integrated
assessment models commonly used to estimate the SC-CO2: The
FUND, DICE, and PAGE models. These models are frequently cited in the
peer-reviewed literature and were used in the last assessment of the
Intergovernmental Panel on Climate Change (IPCC). Each model was given
equal weight in the SC-CO2 values that were developed.
Each model takes a slightly different approach to model how changes
in emissions result in changes in economic damages. A key objective of
the interagency process was to enable a consistent exploration of the
three models, while respecting the different approaches to quantifying
damages taken by the key modelers in the field. An extensive review of
the literature was conducted to select three sets of input parameters
for these models: Climate sensitivity, socio-economic and emissions
trajectories, and discount rates. A probability distribution for
climate sensitivity was specified as an input into all three models. In
addition, the IWG used a range of scenarios for the socio-economic
parameters and a range of values for the discount rate. All other model
features were left unchanged, relying on the model developers' best
estimates and judgments.
In 2010, the IWG selected four sets of SC-CO2 values for
use in regulatory analyses. Three sets of values are based on the
average SC-CO2 from the three integrated assessment models,
at discount rates of 2.5, 3, and 5 percent. The fourth set, which
represents the 95th percentile SC-CO2 estimate across all
three models at a 3-percent discount rate, was included to represent
higher-than-expected impacts from climate change further out in the
tails of the SC-CO2 distribution. The values grow in real
terms over time. Additionally, the IWG determined that a range of
values from 7 percent to 23 percent should be used to adjust the global
SC-CO2 to calculate domestic effects,\122\ although
preference is given to consideration of the global benefits of reducing
CO2 emissions. Table IV-31 presents the values in the 2010
IWG report.\123\
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\122\ It is recognized that this calculation for domestic values
is approximate, provisional, and highly speculative. There is no a
priori reason why domestic benefits should be a constant fraction of
net global damages over time.
\123\ United States Government-Interagency Working Group on
Social Cost of Carbon. Social Cost of Carbon for Regulatory Impact
Analysis Under Executive Order 12866. February 2010. https://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
Table IV-31--Annual SCC Values From 2010 IWG Report
[2007$ per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate and statistic
---------------------------------------------------------------
5% 3% 2.5% 3%
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 4.7 21.4 35.1 64.9
2015............................................ 5.7 23.8 38.4 72.8
2020............................................ 6.8 26.3 41.7 80.7
2025............................................ 8.2 29.6 45.9 90.4
2030............................................ 9.7 32.8 50.0 100.0
2035............................................ 11.2 36.0 54.2 109.7
2040............................................ 12.7 39.2 58.4 119.3
2045............................................ 14.2 42.1 61.7 127.8
2050............................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
In 2013 the IWG released an update (which was revised in July 2015)
that contained SC-CO2 values that were generated using the
most recent versions of the three integrated assessment models that
have been published in the peer-reviewed literature.\124\ DOE used
[[Page 5712]]
these values for this direct final rule. Table IV-32 shows the four
sets of SC-CO2 estimates from the 2013 interagency update
(revised July 2015) in 5-year increments from 2010 through 2050. The
full set of annual SC-CO2 estimates from 2010 through 2050
is reported in appendix 14A of the direct final rule TSD. The central
value that emerges is the average SC-CO2 across models at
the 3-percent discount rate. However, for purposes of capturing the
uncertainties involved in regulatory impact analysis, the IWG
emphasizes the importance of including all four sets of SC-
CO2 values.
---------------------------------------------------------------------------
\124\ United States Government-Interagency Working Group on
Social Cost of Carbon. Technical Support Document: Technical Update
of the Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. May 2013. Revised July 2015. https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf. In 2015, the IWG asked the National Academies of
Science, Engineering and Medicine (NAS) to review the latest
research on modeling the economic aspects of climate change to
inform future revisions of the SC-CO2. The NAS Committee on the
Social Cost of Carbon issued an interim report in January 2016 that
recommended against a near-term update of the SC-CO2 estimates, but
included recommendations for enhancing the presentation and
discussion of uncertainty around the current estimates. A new
Technical Support Document, released by the IWG in August 2016,
responds to these recommendations (https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc_tsd_final_clean_8_26_16.pdf). The NAS
Committee's final report, expected in early 2017, will provide
longer term recommendations for a more comprehensive update.
Table IV-32--Annual SC-CO2 Values From 2013 IWG Update (Revised July 2015)
[2007$ per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate and statistic
---------------------------------------------------------------
5% 3% 2.5% 3%
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 10 31 50 86
2015............................................ 11 36 56 105
2020............................................ 12 42 62 123
2025............................................ 14 46 68 138
2030............................................ 16 50 73 152
2035............................................ 18 55 78 168
2040............................................ 21 60 84 183
2045............................................ 23 64 89 197
2050............................................ 26 69 95 212
----------------------------------------------------------------------------------------------------------------
It is important to recognize that a number of key uncertainties
remain, and that current SC-CO2 estimates should be treated
as provisional and revisable because they will evolve with improved
scientific and economic understanding. The interagency group also
recognizes that the existing models are imperfect and incomplete. The
National Research Council report mentioned previously points out that
there is tension between the goal of producing quantified estimates of
the economic damages from an incremental ton of carbon and the limits
of existing efforts to model these effects. There are a number of
analytical challenges that are being addressed by the research
community, including research programs housed in many of the Federal
agencies participating in the interagency process to estimate the SC-
CO2. The interagency group intends to periodically review
and reconsider those estimates to reflect increasing knowledge of the
science and economics of climate impacts, as well as improvements in
modeling.\125\
---------------------------------------------------------------------------
\125\ In November 2013, OMB announced a new opportunity for
public comment on the interagency technical support document
underlying the revised SCC estimates. 78 FR 70586. In July 2015 OMB
published a detailed summary and formal response to the many
comments that were received: This is available at https://www.whitehouse.gov/blog/2015/07/02/estimating-benefits-carbon-dioxide-emissions-reductions. It also stated its intention to seek
independent expert advice on opportunities to improve the estimates,
including many of the approaches suggested by commenters.
---------------------------------------------------------------------------
DOE converted the values from the 2013 interagency report (revised
July 2015) to 2015$ using the implicit price deflator for gross
domestic product (GDP) from the Bureau of Economic Analysis. For each
of the four sets of SC-CO2 cases, the values for emissions
in 2020 are $13.5, $47.4, $69.9, and $139 per metric ton avoided
(values expressed in 2015$). DOE derived values after 2050 based on the
trend in 2010-2050 in each of the four cases in the interagency update.
DOE multiplied the CO2 emissions reduction estimated for
each year by the SC-CO2 value for that year in each of the
four cases. To calculate a present value of the stream of monetary
values, DOE discounted the values in each of the four cases using the
specific discount rate that had been used to obtain the SC-
CO2 values in each case.
2. Social Cost of Methane and Nitrous Oxide
While carbon dioxide is the most prevalent greenhouse gas emitted
into the atmosphere, other GHGs are also important contributors. These
include methane and nitrous oxide. Global warming potential values
(GWPs) are often used to convert emissions of non-CO2 GHGs
to CO2-equivalents to facilitate comparison of policies and
inventories involving different GHGs. While GWPs allow for some useful
comparisons across gases on a physical basis, using the social cost of
carbon to value the damages associated with changes in CO2-
equivalent emissions is not optimal. This is because non-CO2
GHGs differ not just in their potential to absorb infrared radiation
over a given time frame, but also in the temporal pathway of their
impact on radiative forcing, which is relevant for estimating their
social cost but not reflected in the GWP. Physical impacts other than
temperature change also vary across gases in ways that are not captured
by GWP.
In light of these limitations and the paucity of peer-reviewed
estimates of the social cost of non-CO2 gases in the
literature, the 2010 SCC Technical Support Document did not include an
estimate of the social cost of non-CO2 GHGs and did not
endorse the use of GWP to approximate the value of non-CO2
emission changes in regulatory analysis. Instead, the IWG noted that
more work was needed to link non-CO2 GHG emission changes to
economic impacts.
Since that time, new estimates of the social cost of non-
CO2 GHG emissions have been developed in the scientific
literature, and a recent study by Marten et al. (2015) provided the
first set of published estimates for the social cost of CH4
and N2O emissions that are consistent with the methodology
and
[[Page 5713]]
modeling assumptions underlying the IWG SC-CO2
estimates.\126\ Specifically, Marten et al. used the same set of three
integrated assessment models, five socioeconomic and emissions
scenarios, equilibrium climate sensitivity distribution, three constant
discount rates, and the aggregation approach used by the IWG to develop
the SC-CO2 estimates. An addendum to the IWG's Technical
Support Document on Social Cost of Carbon for Regulatory Impact
Analysis under Executive Order 12866 summarizes the Marten et al.
methodology and presents the SC-CH4 and SC-N2O
estimates from that study as a way for agencies to incorporate the
social benefits of reducing CH4 and N2O emissions
into benefit-cost analyses of regulatory actions that have small, or
``marginal,'' impacts on cumulative global emissions.\127\
---------------------------------------------------------------------------
\126\ Marten, A.L., Kopits, E.A., Griffiths, C.W., Newbold,
S.C., and A. Wolverton. 2015. Incremental CH4 and
N2O Mitigation Benefits Consistent with the U.S.
Government's SC-CO2 Estimates. Climate Policy. 15(2): 272-298
(published online, 2014).
\127\ United States Government-Interagency Working Group on
Social Cost of Greenhouse Gases. Addendum to Technical Support
Document on Social Cost of Carbon for Regulatory Impact Analysis
under Executive Order 12866: Application of the Methodology to
Estimate the Social Cost of Methane and the Social Cost of Nitrous
Oxide. August 2016. https://www.whitehouse.gov/sites/default/files/omb/inforeg/august_2016_sc_ch4_sc_n2o_addendum_final_8_26_16.pdf.
---------------------------------------------------------------------------
The methodology and estimates described in the addendum have
undergone multiple stages of peer review and their use in regulatory
analysis has been subject to public comment. The estimates are
presented with an acknowledgement of the limitations and uncertainties
involved and with a clear understanding that they should be updated
over time to reflect increasing knowledge of the science and economics
of climate impacts, just as the IWG has committed to do for the SC-
CO2. The OMB has determined that the use of the Marten et
al. estimates in regulatory analysis is consistent with the
requirements of OMB's Information Quality Guidelines Bulletin for Peer
Review and OMB Circular A-4.
The SC-CH4 and SC-N2O estimates are presented
in Table IV-33. Following the same approach as with the SC-
CO2, values for 2010, 2020, 2030, 2040, and 2050 are
calculated by combining all outputs from all scenarios and models for a
given discount rate. Values for the years in between are calculated
using linear interpolation. The full set of annual SC-CH4
and SC-N2O estimates between 2010 and 2050 is reported in
appendix 14-A of the direct final rule TSD. DOE derived values after
2050 based on the trend in 2010-2050 in each of the four cases in the
IWG addendum.
Table IV-33--Annual SC-CH4 and SC-N2O Estimates From 2016 IWG Addendum
[2007$ per metric ton]
--------------------------------------------------------------------------------------------------------------------------------------------------------
SC-CH4 SC-N2O
-------------------------------------------------------------------------------------------------------------
Discount rate and statistic Discount rate and statistic
-------------------------------------------------------------------------------------------------------------
Year 5% 3% 2.5% 3% 5% 3% 2.5% 3%
-------------------------------------------------------------------------------------------------------------
95th 95th
Average Average Average percentile Average Average Average percentile
--------------------------------------------------------------------------------------------------------------------------------------------------------
2010...................................... 370 870 1,200 2,400 3,400 12,000 18,000 31,000
2015...................................... 450 1,000 1,400 2,800 4,000 13,000 20,000 35,000
2020...................................... 540 1,200 1,600 3,200 4,700 15,000 22,000 39,000
2025...................................... 650 1,400 1,800 3,700 5,500 17,000 24,000 44,000
2030...................................... 760 1,600 2,000 4,200 6,300 19,000 27,000 49,000
2035...................................... 900 1,800 2,300 4,900 7,400 21,000 29,000 55,000
2040...................................... 1,000 2,000 2,600 5,500 8,400 23,000 32,000 60,000
2045...................................... 1,200 2,300 2,800 6,100 9,500 25,000 34,000 66,000
2050...................................... 1,300 2,500 3,100 6,700 11,000 27,000 37,000 72,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
DOE multiplied the CH4 and N2O emissions
reduction estimated for each year by the SC-CH4 and SC-
N2O estimates for that year in each of the four cases. To
calculate a present value of the stream of monetary values, DOE
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SC-CH4 and
SC-N2O estimates in each case.
3. Social Cost of Other Air Pollutants
As noted previously, DOE estimated how the considered energy
conservation standards would decrease power sector NOX
emissions in those 22 States not affected by CSAPR. Unlike greenhouse
gas emissions, the social cost of other air pollution emissions depends
upon the location of those emissions (and conversely, the social
benefit of emissions reductions depends on the location of those
reductions), making monetization more complicated.
DOE estimated the monetized value of NOX emissions
reductions from electricity generation using benefit per ton estimates
from the Regulatory Impact Analysis for the Clean Power Plan Final
Rule, published in August 2015 by EPA's Office of Air Quality Planning
and Standards.\128\ The report includes high and low values for
NOX (as PM2.5) for 2020, 2025, and 2030 using
discount rates of 3 percent and 7 percent; these values are presented
in appendix 14B of the direct final rule TSD. DOE primarily relied on
the low estimates to be conservative.\129\ DOE developed values
specific to the sector for dedicated-purpose pool pumps using a method
described in appendix 14B of the direct final rule TSD. For this
analysis DOE used linear interpolation to define values for the years
between 2020 and 2025 and between 2025 and 2030; for years beyond 2030
the value is held constant.
---------------------------------------------------------------------------
\128\ Available at www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis. See Tables 4A-3, 4A-4, and
4A-5 in the report. The U.S. Supreme Court has stayed the rule
implementing the Clean Power Plan until the current litigation
against it concludes. Chamber of Commerce, et al. v. EPA, et al.,
Order in Pending Case, 577 U.S. ___ (2016). However, the benefit-
per-ton estimates established in the Regulatory Impact Analysis for
the Clean Power Plan are based on scientific studies that remain
valid irrespective of the legal status of the Clean Power Plan.
\129\ For the monetized NOX benefits associated with
PM2.5, the related benefits are primarily based on an
estimate of premature mortality derived from the ACS study (Krewski
et al. 2009), which is the lower of the two EPA central tendencies.
Using the lower value is more conservative when making the policy
decision concerning whether a particular standard level is
economically justified. If the benefit-per-ton estimates were based
on the Six Cities study (Lepuele et al. 2012), the values would be
nearly two-and-a-half times larger. (See chapter 14 of the direct
final rule TSD for citations for the studies mentioned above.)
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[[Page 5714]]
DOE multiplied the emissions reduction (in tons) in each year by
the associated $/ton values, and then discounted each series using
discount rates of 3 percent and 7 percent as appropriate.
DOE is evaluating appropriate monetization of reduction in other
emissions in energy conservation standards rulemakings. DOE has not
included monetization of those emissions in the current analysis.
M. Utility Impact Analysis
The utility impact analysis estimates several effects on the
electric power generation industry that would result from the adoption
of new or amended energy conservation standards. The utility impact
analysis estimates the changes in installed electrical capacity and
generation that would result for each TSL. The analysis is based on
published output from the NEMS associated with AEO2016. NEMS produces
the AEO Reference case, as well as a number of side cases that estimate
the economy-wide impacts of changes to energy supply and demand. For
the current analysis, impacts are quantified by comparing the levels of
electricity sector generation, installed capacity, fuel consumption and
emissions consistent with the projections described on page E-8 of AEO
2016 and various side cases. Details of the methodology are provided in
the appendices to chapters 13 and 15 of the direct final rule TSD.
The output of this analysis is a set of time-dependent coefficients
that capture the change in electricity generation, primary fuel
consumption, installed capacity, and power sector emissions due to a
unit reduction in demand for a given end use. These coefficients are
multiplied by the stream of electricity savings calculated in the NIA
to provide estimates of selected utility impacts of potential new or
amended energy conservation standards.
N. Employment Impact Analysis
DOE considers employment impacts in the domestic economy as one
factor in selecting a proposed standard. Employment impacts from new
conservation standards include both direct and indirect impacts. Direct
employment impacts are any changes in the number of employees of
manufacturers of the products subject to standards, their suppliers,
and related service firms. The MIA addresses those impacts. Indirect
employment impacts are changes in national employment that occur due to
the shift in expenditures and capital investment caused by the purchase
and operation of more-efficient appliances. Indirect employment impacts
from standards consist of the net jobs created or eliminated in the
national economy, other than in the manufacturing sector being
regulated, caused by: (1) Reduced spending by consumers on energy, (2)
reduced spending on new energy supply by the utility industry, (3)
increased consumer spending on the products to which the new standards
apply and other goods and services, and (4) the effects of those three
factors throughout the economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (BLS).\130\ BLS regularly publishes its estimates of
the number of jobs per million dollars of economic activity in
different sectors of the economy, as well as the jobs created elsewhere
in the economy by this same economic activity. Data from BLS indicate
that expenditures in the utility sector generally create fewer jobs
(both directly and indirectly) than expenditures in other sectors of
the economy.\131\ There are many reasons for these differences,
including wage differences and the fact that the utility sector is more
capital-intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive sector (i.e., the utility sector) to more labor-
intensive sectors (e.g., the retail and service sectors). Thus, the BLS
data suggest that net national employment may increase due to shifts in
economic activity resulting from energy conservation standards.
---------------------------------------------------------------------------
\130\ Data on industry employment, hours, labor compensation,
value of production, and the implicit price deflator for output for
these industries are available upon request by calling the Division
of Industry Productivity Studies (202-691-5618) or by sending a
request by email to [email protected].
\131\ See Bureau of Economic Analysis, Regional Multipliers: A
User Handbook for the Regional Input-Output Modeling System (RIMS
II), U.S. Department of Commerce (1992).
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this direct final rule using an input/output model
of the U.S. economy called Impact of Sector Energy Technologies version
4 (ImSET).\132\ ImSET is a special-purpose version of the ``U.S.
Benchmark National Input-Output'' (I-O) model, which was designed to
estimate the national employment and income effects of energy-saving
technologies. The ImSET software includes a computer-based I-O model
having structural coefficients that characterize economic flows among
187 sectors most relevant to industrial, commercial, and residential
building energy use.
---------------------------------------------------------------------------
\132\ J. Livingston, O.V., S.R. Bender, M.J. Scott, and R.W.
Schultz (2015). ImSET 4.0: Impact of Sector Energy Technologies
Model Description and User's Guide. Pacific Northwest National
Laboratory. PNNL-24563.
---------------------------------------------------------------------------
DOE notes that ImSET is not a general equilibrium forecasting
model, and understands the uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Because ImSET does not incorporate price changes, the
employment effects predicted by ImSET may over-estimate actual job
impacts over the long run for this rule. Therefore, DOE used ImSET only
to generate results for near-term timeframes (2028), where these
uncertainties are reduced. For more details on the employment impact
analysis, see chapter 16 of the direct final rule TSD.
V. Analytical Results and Conclusions
The following section addresses the results from DOE's analyses
with respect to the considered energy conservation standards for
dedicated-purpose pool pumps. It addresses the TSLs examined by DOE,
the projected impacts of each of these levels if adopted as energy
conservation standards for dedicated-purpose pool pumps, and the
standards levels that DOE is adopting in this direct final rule.
Additional details regarding DOE's analyses are contained in the direct
final rule TSD supporting this document.
A. Trial Standard Levels
DOE analyzed the benefits and burdens of five TSLs for dedicated-
purpose pool pumps. These TSLs were developed by combining specific
efficiency levels for each of the equipment classes analyzed by DOE.
DOE presents the results for the TSLs in this direct final rule. The
results for all efficiency levels that DOE analyzed are in the direct
final rule TSD.
Table V-1 presents the TSLs and the corresponding efficiency levels
that DOE identified for potential amended energy conservation standards
for dedicated-purpose pool pumps. TSL 5 represents the maximum
technologically feasible energy efficiency for all equipment classes.
TSL 4 represents the combination of highest
[[Page 5715]]
efficiency levels without hydraulic improvements (variable speed for
relevant equipment classes). TSL 3 represents the standard levels
recommended by the DPPP Working Group. (EERE-2015-BT-STD-0008, No. 82
Recommendation #1 at p. 1-2) TSL 2 represents the efficiency levels
with the highest NPV based on dual speed for relevant equipment
classes, and in other classes the same efficiency level as in TSL 1.
TSL 1 represents the efficiency levels with the highest NPV based on
single-speed technology and no hydraulic improvements.
Table V-1--Trial Standard Levels for Dedicated-Purpose Pool Pumps
----------------------------------------------------------------------------------------------------------------
Trial standard level
Equipment class ----------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Efficiency level
----------------------------------------------------------------
Standard-Size Self-Priming Pool Filter Pump.... 2 5 6 6 7
Small-Size Self-Priming Pool Filter Pump....... 2 5 2 6 7
Standard-Size Non-Self-Priming Pool Filter Pump 1 4 1 6 7
Extra-Small Non-Self-Priming Pool filter Pump.. 1 1 1 2 2
Waterfall Pump................................. 1 1 0 2 3
Pressure Cleaner Booster Pump.................. 1 1 1 3 4
Integral Cartridge Filter Pool Pump............ 0 0 1 0 0
Integral Sand Filter Pool Pump................. 0 0 1 0 0
----------------------------------------------------------------------------------------------------------------
DOE only considers an efficiency level above the baseline for
integral cartridge filter and integral sand filter pumps in TSL3, the
recommended TSL, because DOE is only able to adopt prescriptive
standards and performance standards for the same equipment through use
of a direct final rule based on consensus recommendations. (42 U.S.C.
6295(p)(4)(A) and 6316(a))
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on consumers of pool pumps by
looking at the effects potential standards at each TSL would have on
the LCC and PBP. DOE also examined the impacts of potential standards
on selected consumer subgroups. These analyses are discussed below.
a. Life-Cycle Cost and Payback Period
In general, higher efficiency equipment affects consumers in two
ways: (1) Purchase price increases and (2) annual operating costs
decrease. Inputs used for calculating the LCC and PBP include total
installed costs (i.e., equipment price plus installation costs), and
operating costs (i.e., annual energy use, energy prices, energy price
trends, repair costs, and maintenance costs). The LCC calculation also
uses equipment lifetime and a discount rate. Chapter 8 of the direct
final rule TSD provides detailed information on the LCC and PBP
analyses.
Table V-2 through Table V-17 show the LCC and PBP results for the
TSLs considered for each equipment class. In the first of each pair of
tables, the simple payback is measured relative to the baseline
equipment. In the second of each pair of tables, the impacts are
measured relative to the efficiency distribution in the no-standards
case in the compliance year (see Section IV.F.8 of this document).
Because some consumers purchase equipment with higher efficiency in the
no-standards case, the average savings are less than the difference
between the average LCC of the baseline equipment and the average LCC
at each TSL. The savings refer only to consumers who are affected by a
standard at a given TSL. Those who already purchase equipment with
efficiency at or above a given TSL are not affected. Consumers for whom
the LCC increases at a given TSL experience a net cost.
Table V-2--Average LCC and PBP Results for Standard-Size Self-Priming Pool Filter Pump
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple payback Average
TSL level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
--...................................... Baseline 481 774 4,565 5,046 n/a 6.7
1....................................... 2 576 605 3,640 4,216 0.6 6.7
2....................................... 5 823 315 2,082 2,906 0.7 6.7
3,4..................................... 6 853 223 1,644 2,497 0.7 6.8
5....................................... 7 853 181 1,402 2,255 0.6 6.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
[[Page 5716]]
Table V-3--Average LCC Savings Relative to the No-Standards Case for Standard-Size Self-Priming Pool Filter Pump
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1......................................................... 2 669 1
2......................................................... 5 1,779 5
3,4....................................................... 6 2,140 10
5......................................................... 7 2,085 8
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-4--Average LCC and PBP Results for Small-Size Self-Priming Pool Filter Pump
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple payback Average
TSL level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
--...................................... Baseline 320 282 1,743 2,063 n/a 6.8
1,3..................................... 2 386 200 1,294 1,679 0.8 6.8
2....................................... 5 588 146 1,004 1,593 2.0 6.8
4....................................... 6 720 94 826 1,546 2.1 6.8
5....................................... 7 720 77 723 1,443 1.9 6.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V-5--Average LCC Savings Relative to the No-Standards Case for Small-Size Self-Priming Pool Filter Pump
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,3....................................................... 2 295 4
2......................................................... 5 322 27
4......................................................... 6 360 29
5......................................................... 7 414 26
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-6--Average LCC and PBP Results for Standard-Size Non-Self-Priming Pool Filter Pump
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple payback Average
TSL level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
--...................................... Baseline 199 225 1,055 1,254 n/a 4.7
1,3..................................... 1 208 177 858 1,066 0.2 4.7
2....................................... 4 411 131 684 1,095 2.3 4.7
4....................................... 6 576 64 541 1,117 2.3 4.8
5....................................... 7 576 45 458 1,034 2.1 4.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
[[Page 5717]]
Table V-7--Average LCC Savings Relative to the No-Standards Case for Standard-Size Non-Self-Priming Pool Filter
Pump
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,3....................................................... 1 191 0
2......................................................... 4 35 58
4......................................................... 6 10 51
5......................................................... 7 93 47
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-8--Average LCC and PBP Results for Extra-Small Non-Self-Priming Pool Filter Pump
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple Average
TSL level First year's Lifetime payback lifetime
Installed cost operating cost operating cost LCC (years) (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
--...................................... Baseline 135 57 305 440 n/a 4.7
1,2,3................................... 1 146 45 259 405 0.9 4.7
4,5..................................... 2 158 43 255 413 1.6 4.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V-9--Average LCC Savings Relative to the No-Standards Case for Extra-Small Non-Self-Priming Pool Filter
Pump
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,2,3..................................................... 1 36 4
4,5....................................................... 2 10 39
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-10--Average LCC and PBP Results for Waterfall Pumps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple Average
TSL level First year's Lifetime payback lifetime
Installed cost operating cost operating cost LCC (years) (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
--...................................... Baseline 313 73 500 813 n/a 6.6
1,2..................................... 1 335 67 481 816 4.5 6.6
3....................................... 0 313 73 500 813 n/a 6.6
4....................................... 2 375 60 459 834 5.4 6.6
5....................................... 3 375 54 429 803 3.7 6.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V-11--Average LCC Savings Relative to the No-Standards Case for Waterfall Pumps
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,2....................................................... 1 -3 50
[[Page 5718]]
3......................................................... 0 n/a n/a
4......................................................... 2 -20 70
5......................................................... 3 13 55
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-12--Average LCC and PBP Results for Pressure Cleaner Booster Pumps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple Average
TSL level First year's Lifetime payback lifetime
Installed cost operating cost operating cost LCC (years) (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
--...................................... Baseline 255 173 858 1,113 n/a 4.8
1,2,3................................... 1 276 140 726 1,001 0.6 4.8
4....................................... 3 631 110 758 1,390 6.0 4.8
5....................................... 4 631 99 711 1,343 5.1 4.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V-13--Average LCC Savings Relative to the No-Standards Case for Pressure Cleaner Booster Pumps
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,2,3..................................................... 1 111 0
4......................................................... 3 -372 69
5......................................................... 4 -313 68
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-14--Average LCC and PBP Results for Integral Cartridge Filter Pool Pump
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple payback Average
TSL level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,4,5................................. 0 98 65 234 332 n/a 3.8
3....................................... 1 110 26 93 203 0.4 3.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V-15--Average LCC Savings Relative to the No-Standards Case for Integral Cartridge Filter Pool Pump
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,2,4,5................................................... 0 n/a n/a
[[Page 5719]]
3......................................................... 1 128 3
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table V-16--Average LCC and PBP Results for Integral Sand Filter Pool Pump
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2015$)
Efficiency ---------------------------------------------------------------- Simple payback Average
TSL level First year's Lifetime (years) lifetime
Installed cost operating cost operating cost LCC (years)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,2,4,5................................. 0 154 39 133 287 n/a 3.8
3....................................... 1 166 14 48 214 0.5 3.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use equipment at that efficiency level. The PBP is measured relative to the
baseline equipment.
Table V-17--Average LCC Savings Relative to the No-Standards Case for Integral Sand Filter Pool Pump
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
-----------------------------------
Percent of
TSL Efficiency level Average LCC consumers that
savings * experience net
(2015$) cost (%)
----------------------------------------------------------------------------------------------------------------
1,2,4,5................................................... 0 n/a n/a
3......................................................... 1 73 3
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
b. Consumer Subgroup Analysis
In the consumer subgroup analysis, DOE estimated the impact of the
considered TSLs on senior-only households. Table V-18 through Table V-
25 compare the average LCC savings and PBP at each efficiency level for
the consumer subgroups, along with the average LCC savings for the
entire consumer sample. In most cases, the average LCC savings and PBP
for senior-only households at the considered efficiency levels are not
substantially different from the average for all households. Chapter 11
of the direct final rule TSD presents the complete LCC and PBP results
for the subgroup analysis.
Table V-18--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Standard-Size Self-
Priming Pool Filter Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1............................................... 741 651 0.6 0.6
2............................................... 1,902 1,664 0.7 0.8
3,4............................................. 2,344 2,054 0.7 0.7
5............................................... 2,282 2,004 0.6 0.7
----------------------------------------------------------------------------------------------------------------
[[Page 5720]]
Table V-19--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Small-Size Self-
Priming Pool Filter Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,3............................................. 336 295 0.7 0.8
2............................................... 377 322 1.8 2.0
4............................................... 446 360 1.9 2.1
5............................................... 501 414 1.8 1.9
----------------------------------------------------------------------------------------------------------------
Table V-20--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Standard-Size Non-
Self-Priming Pool Filter Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,3............................................. 217 191 0.2 0.2
2............................................... 62 35 1.9 2.3
4............................................... 86 10 2.0 2.3
5............................................... 182 93 1.8 2.1
----------------------------------------------------------------------------------------------------------------
Table V-21--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Extra-Small Non-Self-
Priming Pool Filter Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,2,3........................................... 42 36 0.8 0.9
4,5............................................. 15 10 1.4 1.6
----------------------------------------------------------------------------------------------------------------
Table V-22--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Waterfall Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,2............................................. 0 -4 4.1 4.7
3............................................... n/a n/a n/a n/a
4............................................... -14 -22 4.9 5.6
5............................................... 21 9 3.4 3.8
----------------------------------------------------------------------------------------------------------------
Table V-23--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Pressure Cleaner
Booster Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,2,3........................................... 134 112 0.5 0.6
4............................................... -353 -372 5.2 6.0
5............................................... -287 -312 4.4 5.1
----------------------------------------------------------------------------------------------------------------
[[Page 5721]]
Table V-24--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Integral Cartridge
Filter Pool Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,2,4,5......................................... n/a n/a n/a n/a
3............................................... 161 128 0.3 0.4
----------------------------------------------------------------------------------------------------------------
Table V-25--Comparison of LCC Savings and PBP for Consumer Subgroup and All Households for Integral Sand Filter
Pool Pump
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2015$) -------------------------------
TSL --------------------------------
Senior-only Senior-only All households
households All households households
----------------------------------------------------------------------------------------------------------------
1,2,4,5......................................... n/a n/a n/a n/a
3............................................... 92 73 0.4 0.5
----------------------------------------------------------------------------------------------------------------
c. Rebuttable Presumption Payback
As discussed in section III.G.3, EPCA establishes a rebuttable
presumption that an energy conservation standard is economically
justified if the increased purchase cost for a product that meets the
standard is less than three times the value of the first-year energy
savings resulting from the standard. In calculating a rebuttable
presumption payback period for each of the considered TSLs, DOE used
discrete values, and as required by EPCA, based the energy use
calculation from the DOE test procedures for dedicated-purpose pool
pumps. In contrast, the PBPs presented in section V.B.1.a were
calculated using distributions that reflect the range of energy use in
the field.
Table V-26 presents the rebuttable-presumption payback periods for
the considered TSLs for dedicated-purpose pool pumps. While DOE
examined the rebuttable-presumption criterion, it considered whether
the standard levels considered for this rule are economically justified
through a more detailed analysis of the economic impacts of those
levels, pursuant to 42 U.S.C. 6295(o)(2)(B)(i) and 6316(a), that
considers the full range of impacts to the consumer, manufacturer,
Nation, and environment. The results of that analysis serve as the
basis for DOE to definitively evaluate the economic justification for a
potential standard level, thereby supporting or rebutting the results
of any preliminary determination of economic justification.
Table V-26--Rebuttable-Presumption Payback Periods
----------------------------------------------------------------------------------------------------------------
TSL
Equipment class -------------------------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
(Years)
-------------------------------------------------------------------------------
Self-Priming, Standard Size..... 0.5 0.8 0.8 0.8 0.8
Self-Priming, Small Size........ 0.9 2.1 0.9 2.4 2.1
Non-Self-Priming, Standard Size. 0.2 2.4 0.2 2.8 2.5
Non-Self-Priming, Extra-Small... 1.0 1.0 1.0 1.8 1.8
Waterfall....................... 3.9 3.9 n/a 4.7 3.2
Pressure Cleaner Booster........ 0.6 0.6 0.6 7.8 6.5
Integral Cartridge.............. n/a n/a 0.3 n/a n/a
Integral Sand................... n/a n/a 0.5 n/a n/a
----------------------------------------------------------------------------------------------------------------
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of new energy
conservation standards on manufacturers of dedicated-purpose pool
pumps. The next section describes the expected impacts on manufacturers
at each considered TSL. Chapter 12 of the direct final rule TSD
explains the analysis in further detail.
a. Industry Cash-Flow Analysis Results
In this section, DOE provides results from the GRIM, which examines
changes to the industry that would result from the analyzed standards.
Table V-27 through Table V-29 illustrate the estimated financial
impacts (represented by changes in INPV) of analyzed energy
conservation standards on manufacturers of dedicated-purpose pool
pumps, as well as the conversion costs that DOE estimates DPPP
manufacturers would incur at each TSL.
As discussed in section IV.J.2.d, DOE modeled three different
manufacturer markup scenarios to evaluate a range of cash flow impacts
on the DPPP industry: (1) The preservation of gross margin markup
scenario, (2) the preservation of operating profit markup scenario, and
(3) a two-tiered markup scenario. To assess the upper (less severe)
bound on the range of potential impacts on DPPP manufacturers, DOE
[[Page 5722]]
modeled a preservation of gross margin markup scenario. This scenario
assumes that in the standards cases, manufacturers would be able to
pass along the higher production costs required for more efficient
products to their consumers. Specifically, the industry would be able
to maintain its no-standards case gross margin (as a percentage of
revenue) for each equipment class despite the higher production costs
in the standards cases.
To assess the lower (more severe) bound on the range of potential
impacts on DPPP manufacturers, DOE modeled two additional manufacturer
markup scenarios; a preservation of operating profit markup scenario
and a two-tiered markup scenario. In the preservation of operating
profit markup scenario manufacturers are not able to yield additional
operating profit from higher production costs and the investments that
are required to comply with new DPPP energy conservation standards, but
instead are only able to maintain the same per-unit operating profit in
the standards cases that was earned in the no-standards case. This
scenario represents a potential lower bound on the range of impacts on
manufacturers because manufacturers are only able to maintain the
operating profit, in dollars, that they would have earned in the no-
standards case despite higher production costs and investments.
Manufacturers must, therefore, reduce margins as a result of this
manufacturer markup scenario, which reduces profitability.
DOE also modeled a two-tiered markup scenario as a potential lower
(more severe) bound on the range of potential impacts on DPPP
manufacturers. In this manufacturer markup scenario, manufacturers have
two tiers of markups that are differentiated, in part, by efficiency
level. Several manufacturers suggested that new standards would lead to
a reduction in overall markups and could reduce their overall
profitability. During manufacturer interviews, manufacturers stated
that they have lower margins on self-priming pool filter pumps that use
a variable-speed motor. DOE used this information to estimate
manufacturer markups for self-priming pool filter pumps under a two-
tiered pricing strategy in the no-standards case. In the standards
cases, DOE modeled the situation in which standards result in more
variable-speed self-priming pool filter pumps being purchased by
consumers. Since these products are modeled to have a lower
manufacturer markup than the single- and two-speed self-priming pool
filter pumps, the overall manufacturer markup declines and results in a
lower overall manufacturer markup and reduction in profitability.
Each of the modeled scenarios results in a unique set of cash-flows
and corresponding industry values at each TSL. In the following
discussion, the INPV results refer to the difference in industry value
between the no-standards case and each standards case resulting from
the sum of discounted cash-flows from 2016 (the reference year) through
2050 (the end of the analysis period). To provide perspective on the
short-run cash-flow impact, DOE includes in the discussion of results a
comparison of free cash flow between the no-standards case and the
standards case at each TSL in the year before new standards take
effect.
Table V-27 through Table V-29 show the MIA results for each TSL
using the manufacturer markup scenarios previously described.
Table V-27--Manufacturer Impact Analysis for Dedicated-Purpose Pool Pumps Under the Preservation of Gross Margin Markup Scenario *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-standards ------------------------------------------------------
case 1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV......................................................... 2015($ MM) 212.8 209.0 197.8 219.8 195.9 110.5
Change in INPV............................................... 2015($ MM) ................ (3.7) (15.0) 7.0 (16.9) (102.3)
Change in INPV............................................... % ................ (1.8) (7.1) 3.3 (7.9) (48.1)
Product Conversion Costs..................................... 2015($ MM) ................ 11.7 29.8 30.8 61.7 116.3
Capital Conversion Costs..................................... 2015($ MM) ................ 3.5 6.0 4.8 6.7 83.3
Total Investment Required.................................... 2015($ MM) ................ 15.2 35.8 35.6 68.4 199.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
* INPV results do not trend monotonically due to the efficiency level composition. The efficiency levels for each TSL are depicted in Table V-1 in
section V.A.
Table V-28--Manufacturer Impact Analysis for Dedicated-Purpose Pool Pumps Under the Preservation of Operating Profit Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-standards ------------------------------------------------------
case 1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV......................................................... 2015($ MM) 212.8 201.0 178.8 166.5 126.2 36.8
Change in INPV............................................... 2015($ MM) ................ (11.7) (34.0) (46.3) (86.6) (176.0)
Change in INPV............................................... % ................ (5.5) (16.0) (21.8) (40.7) (82.7)
Product Conversion Costs..................................... 2015($ MM) ................ 11.7 29.8 30.8 61.7 116.3
Capital Conversion Costs..................................... 2015($ MM) ................ 3.5 6.0 4.8 6.7 83.3
Total Investment Required.................................... 2015($ MM) ................ 15.2 35.8 35.6 68.4 199.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-29--Manufacturer Impact Analysis for Dedicated-Purpose Pool Pumps Under the Two-Tiered Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-standards ------------------------------------------------------
case 1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV......................................................... 2015($ MM) 212.8 210.9 200.2 182.6 144.9 59.3
[[Page 5723]]
Change in INPV............................................... 2015($ MM) ................ (1.9) (12.6) (30.2) (67.8) (153.5)
Change in INPV............................................... % ................ (0.9) (5.9) (14.2) (31.9) (72.1)
Product Conversion Costs..................................... 2015($ MM) ................ 11.7 29.8 30.8 61.7 116.3
Capital Conversion Costs..................................... 2015($ MM) ................ 3.5 6.0 4.8 6.7 83.3
Total Investment Required.................................... 2015($ MM) ................ 15.2 35.8 35.6 68.4 199.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
At TSL 1, DOE estimates impacts on INPV range from -$11.7 million
to -$1.9 million, or a change in INPV of -5.5 percent to -0.9 percent.
At TSL 1, industry free cash-flow is expected to decrease by $5.3
million to $13.2 million, compared to the no-standards case value of
$18.5 million in 2020, the year leading up to the standards.
DOE estimates that 46 percent of all self-priming shipments, 67
percent of extra-small non-self-priming shipments, 71 percent of
standard-size non-self-priming shipments, 87 percent of pressure
cleaner booster shipments, 30 percent of waterfall shipments, 100
percent of integral cartridge filter shipments, and 100 percent of
integral sand filter DPPP shipments would already meet or exceed the
efficiency levels required at TSL 1 in the standards year. To bring
non-compliant equipment into compliance, DOE expects DPPP manufacturers
to incur $11.7 million in product conversion costs for redesign and
testing. In addition, DOE estimates manufacturers will incur $3.5
million in capital conversion costs at TSL 1.
At TSL 1, the shipment-weighted average MPC for all dedicated-
purpose pool pumps increases by 6.1 percent relative to the no-
standards case shipment-weighted average MPC for all dedicated-purpose
pool pumps in 2021, the year of compliance for new DPPP energy
conservation standards. In the preservation of gross margin markup
scenario, manufacturers are able to fully pass on this cost increase to
consumers. The increase in shipment-weighted average MPC for all
dedicated-purpose pool pumps is outweighed by the $15.2 million in
conversion costs, causing a slightly negative change in INPV at TSL 1
under the preservation of gross margin markup scenario.
Under the preservation of operating profit markup scenario,
manufacturers earn the same operating profit as would be earned in the
no-standards case, but manufacturers do not earn additional profit from
their investments. The average manufacturer markup for both the
preservation of operating profit and two-tiered markup scenarios is
calculated by averaging the DPPP industry manufacturer markup, for all
DPPP equipment classes in aggregate, from the year of compliance (2021)
until the terminal year (2050). In this preservation of operating
profit markup scenario, the 6.1 percent increase in the shipment-
weighted average MPC for all dedicated-purpose pool pumps results in a
slight reduction in average manufacturer markup, from 1.413 in the no-
standards case to 1.409 at TSL 1. The slight reduction in average
manufacturer markup and $15.2 million in conversion costs causes a
negative change in INPV at TSL 1 under the preservation of operating
profit markup scenario.
Under the two-tiered markup scenario, where manufacturers earn
lower markups for more efficient products, the average manufacturer
markup increases from 1.409 in the no-standards case to 1.412 at TSL 1.
The increase in the average manufacturer markup and the increase in the
shipment-weighted average MPC for all dedicated-purpose pool pumps are
outweighed by the $15.2 million in conversion costs, causing a slightly
negative change in INPV at TSL 1 under the two-tiered markup scenario.
At TSL 2, DOE estimates impacts on INPV range from -$34.0 million
to -$12.6 million, or a change in INPV of -16.0 percent to -5.9
percent. At TSL 2, industry free cash-flow is expected to decrease by
$11.9 million to $6.6 million, compared to the no-standards case value
of $18.5 million in 2020, the year leading up to the standards.
DOE estimates that 32 percent of all self-priming shipments, 67
percent of extra-small non-self-priming shipments, 7 percent of
standard-size non-self-priming shipments, 87 percent of pressure
cleaner booster shipments, 30 percent of waterfall shipments, 100
percent of integral cartridge filter shipments, and 100 percent of
integral sand filter pool pump shipments would already meet or exceed
the efficiency levels required at TSL 2 in the standards year. To bring
non-compliant equipment into compliance, DOE expects dedicated-purpose
pool pump manufacturers to incur $29.8 million in product conversion
costs for redesign and testing. In addition, DOE estimates
manufacturers will incur $6.0 million in capital conversion costs
associated with TSL 2, to make investments in tooling and machinery
required to incorporate the design options analyzed at TSL 2.
At TSL 2, the shipment-weighted average MPC for all dedicated-
purpose pool pumps decreases by 3.4 percent relative to the no-
standards case shipment-weighted average MPC for all dedicated-purpose
pool pumps in 2021. At TSL 2, consumers will repair existing self-
priming and non-self-priming pool pumps instead of replacing the entire
pump, which reduces shipments in the standards year by 0.5 million
compared to the no-standards case shipments. In the preservation of
gross margin markup scenario, the decrease in the shipment-weighted
average MPC for all dedicated-purpose pool pumps, the reduction in
shipments, and the $35.8 million in conversion costs, causes a negative
change in INPV at TSL 2 under the preservation of gross margin markup
scenario.
Under the preservation of operating profit markup scenario, the 3.4
percent decrease in the shipment-weighted average MPC for all
dedicated-purpose pool pumps results in a reduction in average
manufacturer markup, from 1.413 in the no-standards case to 1.399 at
TSL 2. The reduction in average manufacturer markup, the reduction in
shipments, and the $35.8 million in conversion costs causes a negative
change in INPV at TSL 2 under the preservation of operating profit
markup scenario.
Under the two-tiered markup scenario, where manufacturers earn
lower markups for more efficient products, the average manufacturer
markup slightly increases from 1.409 in the no-standards case to 1.412
at TSL 2. The increase in the average manufacturer markup is outweighed
by the reduction in shipments, and the $35.8 million in conversion
costs, causing a negative change in INPV at
[[Page 5724]]
TSL 2 under the two-tiered markup scenario.
At TSL 3, DOE estimates impacts on INPV range from -$46.3 million
to $7.0 million, or a change in INPV of -21.8 percent to 3.3 percent.
At TSL 3, industry free cash flow is expected to decrease by $11.9
million to $6.6 million, compared to the no-standards case value of
$18.5 million in 2020, the year leading up to the standards.
DOE estimates that 46 percent of small-size self-priming shipments,
30 percent of standard-size self-priming shipments, 67 percent of
extra-small non-self-priming shipments, 71 percent of standard-size
non-self-priming shipments, 87 percent of pressure cleaner booster
shipments, 100 percent of waterfall shipments, 20 percent of integral
cartridge filter shipments, and 20 percent of integral sand filter pool
pump shipments would already meet or exceed the efficiency levels
required at TSL 3 in the standards year. To bring non-compliant
equipment into compliance, DOE expects DPPP manufacturers to incur
$30.8 million in product conversion costs for redesign and testing. In
addition, DOE estimates manufacturers will incur $4.8 million in
capital conversion costs to make changes to machinery and tooling.
At TSL 3, the shipment-weighted average MPC for all dedicated-
purpose pool pumps increases by 10.5 percent relative to the no-
standards case shipment-weighted average MPC for all dedicated-purpose
pool pumps in 2021. At TSL 3 consumers repair existing self-priming
pool filter pumps instead of replacing the entire pump, which reduces
shipments in the standards year by 0.3 million compared to the no-
standards case shipments. In the preservation of gross margin markup
scenario, the increase in the shipment-weighted average MPC for all
dedicated-purpose pool pumps outweighs the reduction in shipments in
the standards year, and the $35.6 million in conversion costs, which
causes a slightly positive change in INPV at TSL 3 under the
preservation of gross margin markup scenario.
Under the preservation of operating profit markup scenario, the
10.5 percent increase in the shipment-weighted average MPC for all
dedicated-purpose pool pumps results in a reduction in average
manufacturer markup, from 1.413 in the no-standards case to 1.380 at
TSL 3. The reduction in average manufacturer markup, the reduction in
shipments, and $35.6 million in conversion costs causes a negative
change in INPV at TSL 3 under the preservation of operating profit
markup scenario.
Under the two-tiered markup scenario, where manufacturers earn
lower markups for more efficient products, the average manufacturer
markup decreases from 1.409 in the no-standards case to 1.389 at TSL 3.
The decrease in the average manufacturer markup, the reduction in
shipments, and the $35.6 million in conversion costs cause a negative
change in INPV at TSL 3 under the two-tiered markup scenario.
At TSL 4, DOE estimates impacts on INPV range from -$86.6 million
to -$16.9 million, or a change in INPV of -40.7 percent to -7.9
percent. At TSL 4, industry free cash-flow is expected to decrease by
$23.1 million to -$4.6 million, compared to the no-standards case value
of $18.5 million in 2020, the year leading up to the standards.
DOE estimates that 30 percent of all self-priming shipments, 33
percent of extra-small non-self-priming shipments, 6 percent of
standard-size non-self-priming shipments, 6 percent of pressure cleaner
booster shipments, 10 percent of waterfall shipments, 100 percent of
integral cartridge filter shipments and 100 percent of integral sand
filter pool pump shipments would already meet or exceed the efficiency
levels required at TSL 4 in the standards year. To bring non-compliant
equipment into compliance, DOE expects DPPP manufacturers to incur
$61.7 million in product conversion costs for redesign and testing. In
addition, DOE estimates manufacturers will incur $6.7 million in
capital conversion costs associated with TSL 4 to make changes to
machinery and tooling.
At TSL 4, the shipment-weighted average MPC for all dedicated-
purpose pool pumps increases by 39.4 percent relative to the no-
standards case shipment-weighted average MPC for all dedicated-purpose
pool pumps in 2021. At TSL 4, consumers repair existing self-priming,
non-self-priming, and pressure cleaner booster pumps instead of
replacing the entire pump, which reduces total shipments in the
standards year by 0.6 million units compared to the no-standards case
shipments. In the preservation of gross margin markup scenario, the
increase in the shipment-weighted average MPC for all dedicated-purpose
pool pumps is outweighed by the reduction in shipments and the $68.4
million in conversion costs, which causes a negative change in INPV at
TSL 4 under the preservation of gross margin markup scenario.
Under the preservation of operating profit markup scenario, the
39.4 percent increase in the shipment-weighted average MPC for all
dedicated-purpose pool pumps results in a reduction in average
manufacturer markup, from 1.413 in the no-standards case to 1.367 at
TSL 4. The reduction in average manufacturer markup, the reduction in
shipments, and $68.4 million in conversion costs causes a significantly
negative change in INPV at TSL 4 under the preservation of operating
profit markup scenario.
Under the two-tiered markup scenario, where manufacturers earn
lower markups for more efficient products, the average manufacturer
markup decreases from 1.409 in the no-standards case to 1.376 at TSL 4.
The decrease in the average manufacturer markup, the reduction in
shipments, and the $68.4 million in conversion costs cause a
significantly negative change in INPV at TSL 4 under the two-tiered
markup scenario.
At TSL 5, DOE estimates impacts on INPV range from -$176.0 million
to -$102.3 million, or a change in INPV of -82.7 percent to -48.1
percent. At TSL 5, industry free cash flow is expected to decrease by
$79.3 million to -$60.9 million, compared to the no-standards case
value of $18.5 million in 2020, the year leading up to the standards.
DOE estimates that 19 percent of all self-priming shipments, 33
percent of extra-small non-self-priming shipments, 3 percent of
standard-size non-self-priming shipments, 3 percent of pressure cleaner
booster shipments, 0 percent of waterfall shipments, 100 percent of
integral cartridge filter shipments and 100 percent of integral sand
filter pool pump shipments would already meet the efficiency levels
required at TSL 5 in the standards year. To bring non-compliant
equipment into compliance, DOE expects dedicated-purpose pool pump
manufacturers to incur $116.3 million in product conversion costs for
redesign and testing. In addition, DOE estimates manufacturers will
incur $83.3 million in capital conversion costs associated with TSL 5
to make changes to machinery and tooling.
At TSL 5, the shipment-weighted average MPC for all dedicated-
purpose pool pumps increases by 39.4 percent relative to the no-
standards case shipment-weighted average MPC for all dedicated-purpose
pool pumps in 2021. At TSL 5, consumers repair existing self-priming,
non-self-priming, and pressure cleaner booster pumps instead of
replacing the entire pump, which reduces total shipments in the
standards year by 0.6 million units compared to the no-standards case
shipments. In the preservation of gross margin markup scenario, the
increase in the shipment-weighted average MPC for all dedicated-
[[Page 5725]]
purpose pool pumps is outweighed by the reduction in shipments and the
$199.5 million in conversion costs, which causes a significantly
negative change in INPV at TSL 5 under the preservation of gross margin
markup scenario.
Under the preservation of operating profit markup scenario, the
39.4 percent increase in the shipment-weighted average MPC for all
dedicated-purpose pool pumps results in a reduction in average
manufacturer markup, from 1.413 in the no-standards case to 1.363 at
TSL 5. The reduction in average manufacturer markup, the reduction in
shipments, and $199.5 million in conversion costs causes a
significantly negative change in INPV at TSL 5 under the preservation
of operating profit markup scenario.
Under the two-tiered markup scenario, where manufacturers earn
lower markups for more efficient products, the average manufacturer
markup decreases from 1.409 in the no-standards case to 1.375 at TSL 5.
The decrease in the average manufacturer markup, the reduction in
shipments, and the $199.5 million in conversion costs cause a negative
change in INPV at TSL 5 under the two-tiered markup scenario.
b. Impacts on Direct Employment
To quantitatively assess the impacts of new energy conservation
standards on direct employment, DOE used the GRIM to estimate the
domestic labor expenditures and number of employees in the no-standards
case and at each TSL from 2016 through 2050. DOE used statistical data
from the U.S. Census Bureau's 2014 Annual Survey of Manufacturers (ASM)
and the results of the engineering analysis to calculate industry-wide
labor expenditures and domestic employment levels. Labor expenditures
related to equipment manufacturing depend on the labor intensity of the
equipment, the sales volume, and an assumption that wages remain fixed
in real terms over time. The total labor expenditures in each year are
calculated by multiplying the MPCs by the labor percentage of MPCs.
The total labor expenditures in the GRIM were then converted to
domestic production employment levels by dividing production labor
expenditures by the annual payment per production worker (production
worker hours multiplied by the labor rate found in the ASM). The
estimates of production workers in this section cover workers,
including line supervisors, who are directly involved in fabricating
and assembling equipment within the original equipment manufacturer
facility. Workers performing services that are closely associated with
production operations, such as materials handling tasks using
forklifts, are also included as production labor. DOE's production
worker estimates only account for workers who manufacture the specific
equipment covered by this rulemaking.
DOE calculated the total direct employment associated with the
covered equipment by multiplying the number of production workers by
the ratio of ``number of employees'' to ``production workers average
per year'' calculated using the employment data in the 2014 ASM. Using
the GRIM, DOE estimates there would be 101 domestic production workers
for original equipment manufacturers in 2021 in the absence of new
energy conservation standards. Using ASM data, DOE estimated 175 full-
time employees work directly on the covered equipment. Table V-30 shows
the range of the impacts of energy conservation standards on U.S.
production on dedicated-purpose pool pumps. Additional detail on the
analysis of direct employment can be found in chapter 12 of the direct
final rule TSD.
Table V-30--Total Number of Domestic Dedicated-Purpose Pool Pump Workers in 2021
----------------------------------------------------------------------------------------------------------------
Trial standard level
No-standards ------------------------------------------------------
case 1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Domestic Production Workers in 2021 101 101 80 94 78 78
(without changes in production
locations)............................
Total Number of Domestic Employees in 175 175 139 163 135 135
2021..................................
Potential Changes in Domestic ................ (10)-0 (25)-(21) (51)-(7) (51)-(23) (51)-(23)
Production Workers in 2021............
----------------------------------------------------------------------------------------------------------------
The employment impacts shown in Table V-30 represent the potential
employment changes that could result following the compliance date for
dedicated-purpose pool pumps. The upper end of the results in the table
(less severe) estimates the decline in employment due to the decrease
in the number of DPPPs sold in 2021, as more customers repair their
dedicated-purpose pool pumps instead of replacing them as they would in
the no-standards case. This case assumes that manufacturers would
continue to produce the same scope of covered equipment within the
United States. The lower end of the range (more severe) represents the
maximum potential decrease to employment due to production moving to
lower labor-cost countries, in addition to the decrease in the number
of DPPPs sold in 2021.
DOE estimated the lower end of the range based on manufacturer
interviews. Manufacturers could move production abroad depending on the
requirements of a standard for self-priming pool filter pumps. Based on
the complexity of the motor technology used in dedicated-purpose pool
pumps, either single-speed, two-speed, or variable-speed, DOE estimated
that the number of domestic production workers could be reduced by 10
percent if standards were set at TSL 1 (represented by a single-speed
motor for self-priming pool filter pumps), 25 percent if standards were
set at TSL 2 (represented by a two-speed motor for self-priming pool
filter pumps), and 50 percent if standards were set at TSL 3, TSL 4, or
TSL 5 (represented by a variable-speed motor for self-priming pool
filter pumps).
The direct employment impacts shown are independent of the
employment impacts from the broader U.S. economy, which are documented
in the employment impact analysis found in chapter 16 of the direct
final rule TSD.
c. Impacts on Manufacturing Capacity
DOE did not identify any significant capacity constraints for the
design options being evaluated for this rulemaking. 46 percent of
small-size self-priming, 30 percent of standard-size self-priming, 67
percent of extra-small non-self-priming, 71 percent of standard-size
non-self-priming, 87 percent of pressure cleaner booster, 100 percent
of waterfall, 20 percent of integral cartridge filter, and 20 percent
of integral sand filter pool pump shipments already meet or exceed the
adopted standard levels. In addition, the design options being
evaluated are
[[Page 5726]]
widely available as products that are on the market today.
DOE believes there is a sufficient supply of variable-speed motors
to be used in all standard-size self-priming pool filter pumps in 2021.
Variable speed motors are used a wide variety of equipment, and
dedicated-purpose pool pumps only represent a small fraction all the
equipment that use variable speed motors. As such existing production
lines can cope with the change in equipment offerings, and DOE does not
expect the industry to experience capacity constraints due to the
increase in demand of variable speed motors or for any other reason
directly resulting from new energy conservation standards.
d. Impacts on Subgroups of Manufacturers
As discussed in section IV.J.1, using average cost assumptions to
develop an industry cash-flow estimate may not be adequate for
assessing differential impacts among manufacturer subgroups. Small
manufacturers, niche manufacturers, and manufacturers exhibiting a cost
structure substantially different from the industry average could be
affected disproportionately. DOE used the results of the industry
characterization to group manufacturers exhibiting similar
characteristics. Consequently, DOE identified small business
manufacturers as a subgroup for a separate impact analysis.
For the small business subgroup analysis, DOE applied the small
business size standards published by the SBA to determine whether a
company is considered a small business. The size standards are codified
at 13 CFR part 121. To be categorized as a small business under NAICS
code 333911, ``Pump and Pumping Equipment Manufacturing,'' a DPPP
manufacturer and its affiliates may employ a maximum of 750 employees.
The 750-employee threshold includes all employees in a business' parent
company and any other subsidiaries. Based on this classification, DOE
identified five manufacturers that qualify as domestic small
businesses. The small business subgroup analysis is discussed in
section VII.B of this document and in chapter 12 of the direct final
rule TSD.
e. Cumulative Regulatory Burden
One aspect of assessing manufacturer burden involves considering
the cumulative impact of multiple DOE standards and the product-
specific regulatory actions of other Federal agencies that affect the
manufacturers of a covered product or equipment. While any one
regulation may not impose a significant burden on manufacturers, the
combined effects of several existing or impending regulations may have
serious consequences for some manufacturers, groups of manufacturers,
or an entire industry. Assessing the impact of a single regulation may
overlook this cumulative regulatory burden. In addition to energy
conservation standards, other regulations can significantly affect
manufacturers' financial operations. Multiple regulations affecting the
same manufacturer can strain profits and lead companies to abandon
product lines or markets with lower expected future returns than
competing equipment. For these reasons, DOE conducts an analysis of
cumulative regulatory burden as part of its rulemakings pertaining to
appliance efficiency.
Some DPPP manufacturers also make other products or equipment that
could be subject to energy conservation standards set by DOE. DOE looks
at these regulations that could affect DPPP manufacturers that will
take effect approximately 3 years before or after the estimated 2021
compliance date or during the compliance period of the new energy
conservation standards for DPPPs.
The compliance dates and expected industry conversion costs of
relevant energy conservation standards are indicated in Table V-31.
Also, included in the table are Federal regulations that have
compliance dates beyond the three years before or after the DPPP
compliance date.
Table V-31--Compliance Dates and Expected Conversion Expenses of Federal Energy Conservation Standards Affecting Dedicated-Purpose Pool Pump
Manufacturers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of Industry
Number of manufacturers Approximate Industry conversion conversion
Federal energy conservation standard manufacturers * from today's standards year costs (Millions $) costs/ revenue
rule ** ***
--------------------------------------------------------------------------------------------------------------------------------------------------------
Small, Large, and Very Large Commercial Package Air 13 1 2018 520.8 (2014$) 4.9%.
Conditioning and Heating Equipment 81 FR 2420 (January 15,
2016).....................................................
Commercial Packaged Boilers 81 FR 15836 (March 24, 2016) 45 1 2019 27.5 (2014$) 2.3%.
[dagger]..................................................
Commercial Water Heaters 81 FR 34440 (May 31, 2016) 25 1 2019 29.8 (2014$) 3.0%.
[dagger]..................................................
Commercial Warm Air Furnaces 81 FR 2420 (January 15, 2016). 13 1 2019 7.5 to 22.2 (2014$) 1.7%-5.2%.
Furnace Fans 79 FR 3813 (July 3, 2014)..................... 38 1 2019 40.6 (2013$) 1.6%.
Commercial Compressors 81 FR 40197 (June 21, 2016) [dagger] 40 1 2019 99.0-125.1 (2014$) 3.1%-3.9%.
Commercial and Industrial Pumps 80 FR 17826 (January 26, 86 5 2020 81.2 (2014$) 5.6%.
2016).....................................................
Residential Boilers 81 FR 2320 (January 15, 2016).......... 36 2 2021 2.5 (2014$) <1%.
Residential Furnace 80 FR 13120 (March 12, 2015) [dagger].. 14 1 2021 55.0 (2013$) <1%.
Direct Heating Equipment and Residential Water Heaters 75 39 1 2015 17.5 (2009$) 4.9%.
FR 20112 (April 16, 2010) [dagger][dagger]................
Residential Central Air Conditioners and Heat Pumps 76 FR 39 4 2015 44.0 (2009$) 0.1%.
37408 (June 27, 2011) [dagger][dagger]....................
[[Page 5727]]
External Power Supplies 79 FR 7846 (February 10, 2014) 243 1 2016 43.4 (2012$) 2.3%.
[dagger][dagger]..........................................
Walk-in Cooler and Walk-in Freezer Components 79 FR 32049 63 1 2017 33.6 (2012$) 2.7%.
(June 3, 2014) [dagger][dagger]...........................
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This column presents the total number of manufacturers identified in the energy conservation standard rule contributing to cumulative regulatory
burden.
** This column presents the number of manufacturers producing dedicated-purpose pool pumps that are also listed as manufacturers in the energy
conservation standard contributing to cumulative regulatory burden.
*** This column presents conversion costs as a percentage of cumulative revenue for the industry during the conversion period. The conversion period is
the timeframe over which manufacturers must make conversion cost investments and lasts from the announcement year of the final rule to the standards
year of the final rule. This period typically ranges from 3 to 5 years, depending on the energy conservation standard.
[dagger] The final rule for this energy conservation standard has not been published. The compliance date and analysis of conversion costs have not been
finalized at this time. If a value is provided for total industry conversion expense, this value represents an estimate from the NOPR or SNOPR.
[dagger][dagger] Consistent with Chapter 12 of the TSD, DOE has assessed whether this rule will have significant impacts on manufacturers that are also
subject to significant impacts from other EPCA rules with compliance dates within three years of this rule's compliance date. However, DOE recognizes
that a manufacturer incurs costs during some period before a compliance date as it prepares to comply, such as by revising product designs and
manufacturing processes, testing products, and preparing certifications. As such, to illustrate a broader set of rules that may also create additional
burden on manufacturers, DOE has included another rule with compliance dates that fall within six years of the compliance date of this rule by
expanding the timeframe of potential cumulative regulatory burden. Note that the inclusion of any given rule in this Table does not indicate that DOE
considers the rule to contribute significantly to cumulative impact. DOE has chosen to broaden its list of rules in order to provide additional
information about its rulemaking activities. DOE will continue to evaluate its approach to assessing cumulative regulatory burden for use in future
rulemakings to ensure that it is effectively capturing the overlapping impacts of its regulations. DOE plans to seek public comment on the approaches
it has used here (i.e., both the 3 and 6 year timeframes from the compliance date) in order to better understand at what point in the compliance cycle
manufacturers most experience the effects of cumulative and overlapping burden from the regulation of multiple products.
In addition to the Federal energy conservation standards listed in
Table V-31, there are appliance standards in progress that do not yet
have a proposed rule or final rule. The compliance date, manufacturer
lists, and analysis of conversion costs are not available at this time.
These appliance standards include pool heaters 80 FR 15922 (March 17,
2015), circulator pumps 80 FR 51483, (August 25, 2015), central air
conditioners, and commercial and industrial fans and blowers.
During the working group negotiations manufacturers did not
indicate that cumulative regulatory burden was a concern. In the DPPP
Working Group meeting on April 19, 2016, DOE presented initial
cumulative regulatory burden findings and provided interested parties
the opportunity to comment. Interested parties did not identify any
additional federal regulations. (Docket No. EERE-2015-BT-STD-0008-0079,
April 19 DPPP Working Group Meeting, at p. 136) DOE identified one
manufacturer that was affected by more federal regulations than other
DPPP manufacturers.
DOE discusses these and other requirements and includes the full
details of the cumulative regulatory burden analysis in chapter 12 of
the direct final rule TSD. DOE will continue to evaluate its approach
to assessing cumulative regulatory burden for use in future rulemakings
to ensure that it is effectively capturing the overlapping impacts of
its regulations. DOE plans to seek public comment on the approaches it
has used here (i.e., both the 3 and 6 year timeframes from the
compliance date) in order to better understand at what point in the
compliance cycle manufacturers most experience the effects of
cumulative and overlapping burden from the regulation of multiple
product classes.
3. National Impact Analysis
This section presents DOE's estimates of the national energy
savings and the NPV of consumer benefits that would result from each of
the TSLs considered as potential amended standards.
a. Significance of Energy Savings
To estimate the energy savings attributable to potential standards
for dedicated-purpose pool pumps, DOE compared their energy consumption
under the no-standards case to their anticipated energy consumption
under each TSL. The savings are measured over the entire lifetime of
equipment purchased in the 30-year period that begins in the year of
anticipated compliance with amended standards (2021-2050). Table V-32
presents DOE's projections of the national energy savings for each TSL
considered for pool pumps. The savings were calculated using the
approach described in section IV.H.2 of this document.
Table V-32--Cumulative National Energy Savings for Pool Pumps; 30 Years of Shipments
[2021-2050]
----------------------------------------------------------------------------------------------------------------
Trial standard level
------------------------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Quads
------------------------------------------------------------------------------
Primary energy................... 0.75 2.9 3.6 3.9 4.4
FFC energy....................... 0.79 3.0 3.8 4.1 4.6
----------------------------------------------------------------------------------------------------------------
[[Page 5728]]
OMB Circular A-4 \133\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis using nine, rather than 30, years
of product shipments. The choice of a 9-year period is a proxy for the
timeline in EPCA for the review of certain energy conservation
standards and potential revision of and compliance with such revised
standards.\134\ The review timeframe established in EPCA is generally
not synchronized with the product lifetime, product manufacturing
cycles, or other factors specific to dedicated-purpose pool pumps.
Thus, such results are presented for informational purposes only and
are not indicative of any change in DOE's analytical methodology. The
NES sensitivity analysis results based on a 9-year analytical period
are presented in Table V-33. The impacts are counted over the lifetime
of pool pumps purchased in 2021-2029.
---------------------------------------------------------------------------
\133\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. www.whitehouse.gov/omb/circulars_a004_a-4/.
\134\ Section 325(m) of EPCA requires DOE to review its
standards at least once every 6 years, and requires, for certain
equipment, a 3-year period after any new standard is promulgated
before compliance is required, except that in no case may any new
standards be required within 6 years of the compliance date of the
previous standards. While adding a 6-year review to the 3-year
compliance period adds up to 9 years, DOE notes that it may
undertake reviews at any time within the 6 year period and that the
3-year compliance date may yield to the 6-year backstop. A 9-year
analysis period may not be appropriate given the variability that
occurs in the timing of standards reviews and the fact that for some
equipment, the compliance period is 5 years rather than 3 years.
Table V-33--Cumulative National Energy Savings for Pool Pumps; 9 Years of Shipments
[2021-2029]
----------------------------------------------------------------------------------------------------------------
Trial standard level
-------------------------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Quads
----------------------------------------------------------------------------------------------------------------
Primary energy.................. 0.24 0.76 0.95 1.0 1.1
FFC energy...................... 0.25 0.80 1.0 1.0 1.2
----------------------------------------------------------------------------------------------------------------
b. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
consumers that would result from the TSLs considered for pool pumps. In
accordance with OMB's guidelines on regulatory analysis,\135\ DOE
calculated NPV using both a 7-percent and a 3-percent real discount
rate. Table V-34 shows the consumer NPV results with impacts counted
over the lifetime of equipment purchased in 2021-2050.
---------------------------------------------------------------------------
\135\ U.S. Office of Management and Budget. Circular A-4:
Regulatory Analysis. September 17, 2003. www.whitehouse.gov/omb/circulars_a004_a-4/.
Table V-34--Cumulative Net Present Value of Consumer Benefits for Pool Pumps; 30 Years of Shipments
[2021-2050]
----------------------------------------------------------------------------------------------------------------
Trial standard level (billion 2015$)
Discount rate -------------------------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
3 percent....................... 5.1 17 24 21 25
7 percent....................... 2.5 8.1 11 10 12
----------------------------------------------------------------------------------------------------------------
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V-35. The impacts are counted over the
lifetime of equipment purchased in 2021-2029. As mentioned previously,
such results are presented for informational purposes only and are not
indicative of any change in DOE's analytical methodology or decision
criteria.
Table V-35--Cumulative Net Present Value of Consumer Benefits for Pool Pumps; 9 Years of Shipments
[2021-2029]
----------------------------------------------------------------------------------------------------------------
Trial standard level (billion 2015$)
Discount rate -------------------------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
3 percent....................... 2.1 6.4 8.5 7.7 8.8
7 percent....................... 1.3 4.2 5.6 5.0 5.7
----------------------------------------------------------------------------------------------------------------
The above results reflect the use of a default price trend to
estimate the change in price for dedicated-purpose pool pumps over the
analysis period (see section IV.F.1 of this document). DOE also
conducted a sensitivity analysis that considered one scenario with a
low price trend and one scenario with a high price trend. The results
of
[[Page 5729]]
these alternative cases are presented in appendix 10C of the direct
final rule TSD. In the high price case, the NPV of consumer benefits is
lower than in the default case. In the low price case, the NPV of
consumer benefits is higher than in the default case.
c. Indirect Impacts on Employment
DOE expects that energy conservation standards for dedicated-
purpose pool pumps would reduce energy expenditures for consumers of
those equipment, with the resulting net savings being redirected to
other forms of economic activity. These expected shifts in spending and
economic activity could affect the demand for labor. As described in
section IV.N of this document, DOE used an input/output model of the
U.S. economy to estimate indirect employment impacts of the TSLs that
DOE considered. There are uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Therefore, DOE generated results for near-term timeframes
(2021-2026), where these uncertainties are reduced.
The results suggest that the adopted standards would be likely to
have a negligible impact on the net demand for labor in the economy.
The net change in jobs is so small that it would be imperceptible in
national labor statistics and might be offset by other, unanticipated
effects on employment. Chapter 16 of the direct final rule TSD presents
detailed results regarding anticipated indirect employment impacts.
4. Impact on Utility or Performance of Equipment
As discussed in section IV.B.2 of this direct final rule, DOE has
concluded that the standards adopted in this direct final rule would
not lessen the utility or performance of the pool pumps under
consideration in this rulemaking. Manufacturers of these equipment
currently offer units that meet or exceed the adopted standards.
5. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from a proposed standard. (42 U.S.C.
6313(a)(6)(B)(ii)(V)) Specifically, it instructs DOE to consider the
impact of any lessening of competition, as determined in writing by the
Attorney General, that is likely to result from the imposition of the
standard. DOE is simultaneously publishing a NOPR containing proposed
energy conservation standards identical to those set forth in this
direct final rule and has transmitted a copy of the rule and the
accompanying TSD to the Attorney General, requesting that the DOJ
provide its determination on this issue. DOE will consider DOJ's
comments on the direct final rule in determining whether to proceed
with finalizing its standards. DOE will also publish and respond to the
DOJ's comments in the Federal Register in a separate document.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the Nation's energy security, strengthens the economy, and reduces the
environmental impacts (costs) of energy production. Reduced electricity
demand due to energy conservation standards is also likely to reduce
the cost of maintaining the reliability of the electricity system,
particularly during peak-load periods. As a measure of this reduced
demand, chapter 15 in the direct final rule TSD presents the estimated
reduction in generating capacity, relative to the no-new-standards
case, for the TSLs that DOE considered in this rulemaking.
Energy conservation resulting from potential energy conservation
standards for dedicated-purpose pool pumps is expected to yield
environmental benefits in the form of reduced emissions of certain air
pollutants and greenhouse gases. Table V-36 provides DOE's estimate of
cumulative emissions reductions expected to result from the TSLs
considered in this rulemaking. The emissions were calculated using the
multipliers discussed in section IV.K. DOE reports annual emissions
reductions for each TSL in chapter 13 of the direct final rule TSD.
Table V-36--Cumulative Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
Trial standard level
-------------------------------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....... 40 152 192 205 233
SO2 (thousand tons)............. 30 115 145 155 176
NOX (thousand tons)............. 22 82 103 110 125
Hg (tons)....................... 0.10 0.39 0.50 0.53 0.60
CH4 (thousand tons)............. 4.2 16 20 22 25
N2O (thousand tons)............. 0.61 2.3 2.9 3.1 3.5
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....... 2.2 8.3 11 11 13
SO2 (thousand tons)............. 0.26 0.99 1.2 1.3 1.5
NOX (thousand tons)............. 32 122 154 165 188
Hg (tons)....................... 0.00 0.00 0.00 0.00 0.00
CH4 (thousand tons)............. 196 749 948 1,013 1,155
N2O (thousand tons)............. 0.01 0.06 0.07 0.07 0.08
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....... 42 160 202 216 246
SO2 (thousand tons)............. 31 116 147 156 178
NOX (thousand tons)............. 53 203 257 275 313
Hg (tons)....................... 0.10 0.39 0.50 0.53 0.60
CH4 (thousand tons)............. 200 765 968 1,035 1,179
[[Page 5730]]
N2O (thousand tons)............. 0.62 2.3 3.0 3.2 3.6
----------------------------------------------------------------------------------------------------------------
As part of the analysis for this rule, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2
that DOE estimated for each of the considered TSLs for dedicated-
purpose pool pumps. As discussed in section IV.L of this document, DOE
used the most recent values for the SC-CO2 developed by the
interagency working group. The four sets of SC-CO2 values
correspond to the average values from distributions that use a 5-
percent discount rate, a 3-percent discount rate, and a 2.5-percent
discount rate, and the 95th-percentile values from a distribution that
uses a 3-percent discount rate. The actual SC-CO2 values
used for emissions in each year are presented in appendix 14A of the
direct final rule TSD.
Table V-37 presents the global value of the CO2
emissions reduction at each TSL. DOE calculated domestic values as a
range from 7 percent to 23 percent of the global values; these results
are presented in chapter 14 of the direct final rule TSD. Table V-38
presents the annualized values for CO2 emissions reduction
at each TSL.
Table V-37--Estimates of Present Value of CO2 Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
SCC case
-------------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Billion 2015$
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
1........................................... 327 1,442 2,269 4,388
2........................................... 1,207 5,385 8,496 16,402
3........................................... 1,524 6,804 10,734 20,724
4........................................... 1,624 7,256 11,450 22,104
5........................................... 1,841 8,242 13,011 25,113
----------------------------------------------------------------------------------------------------------------
Table V-38--Annualized Value of CO2 Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
SCC case
-------------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Million 2015$
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
1........................................... 26 83 120 252
2........................................... 95 309 448 942
3........................................... 121 391 566 1,190
4........................................... 128 417 604 1,269
5........................................... 146 473 686 1,442
----------------------------------------------------------------------------------------------------------------
As discussed in section IV.L.2, DOE estimated monetary benefits
likely to result from the reduced emissions of methane and
N2O that DOE estimated for each of the considered TSLs for
dedicated-purpose pool pumps. DOE used the recent values for the SC-
CH4 and SC-N2O developed by the interagency
working group. Table V-39 presents the value of the CH4
emissions reduction at each TSL, and Table V-40 presents the value of
the N2O emissions reduction at each TSL. The annualized
values for CH4 and N2O emissions reductions at
each TSL are presented in Table V-40 and Table V-42, respectively.
[[Page 5731]]
Table V-39--Present Value of Methane Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
SC-CH4 case
-------------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Billion 2015$
-------------------------------------------------------------------
1........................................... 69 206 289 549
2........................................... 256 782 1,100 2,082
3........................................... 324 989 1,392 2,632
4........................................... 346 1,057 1,487 2,812
5........................................... 393 1,203 1,694 3,202
----------------------------------------------------------------------------------------------------------------
Table V-40--Annualized Value of Methane Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
SC-CH4 case
-------------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Million 2015$
-------------------------------------------------------------------
1........................................... 5.4 12 15 32
2........................................... 20 45 58 120
3........................................... 26 57 73 151
4........................................... 27 61 78 161
5........................................... 31 69 89 184
----------------------------------------------------------------------------------------------------------------
Table V-41--Present Value of Nitrous Oxide Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
SC-N2O case
-------------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Billion 2015$
-------------------------------------------------------------------
1........................................... 1.8 7.2 11 19
2........................................... 6.5 27 42 72
3........................................... 8.3 34 54 91
4........................................... 8.8 36 57 97
5........................................... 10 41 65 110
----------------------------------------------------------------------------------------------------------------
Table V-42--Annualized Value of Nitrous Oxide Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
SC-N2O case
-------------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Million 2015$
-------------------------------------------------------------------
1........................................... 0.14 0.41 0.60 1.1
2........................................... 0.52 1.6 2.2 4.1
3........................................... 0.65 2.0 2.8 5.2
4........................................... 0.70 2.1 3.0 5.6
5........................................... 0.79 2.4 3.4 6.3
----------------------------------------------------------------------------------------------------------------
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in
the future global climate and the potential resulting damages to the
world economy continues to evolve rapidly. Thus, any value placed on
reduced GHG emissions in this rulemaking is subject to change. DOE,
together with other Federal agencies, will continue to review various
methodologies for estimating the monetary value of reductions in
CO2 and other GHG emissions. This ongoing review will
consider the comments on this subject that are part of the public
record for this and other rulemakings, as well as other methodological
assumptions and issues. Consistent with DOE's legal obligations, and
taking into account the uncertainty involved with this particular
issue, DOE has included in this rule the most recent values resulting
from the interagency review
[[Page 5732]]
process. DOE notes, however, that the adopted standards would be
economically justified, as defined under EPCA, even without inclusion
of monetized benefits of reduced GHG emissions.
DOE also estimated the monetary value of the economic benefits
associated with NOX emissions reductions anticipated to
result from the considered TSLs for dedicated-purpose pool pumps. The
dollar-per-ton values that DOE used are discussed in section IV.L of
this document. Table V-43 presents the present value for NOX
emissions reduction for each TSL calculated using 7-percent and 3-
percent discount rates. This table presents results that use the low
benefit-per-ton values, which reflect DOE's primary estimate. Results
that reflect the range of NOX benefit-per-ton values are
presented in Table V-45.
Table V-43--Estimates of Present Value of NOX Emissions Reduction for Pool Pumps Shipped in 2021-2050
----------------------------------------------------------------------------------------------------------------
TSL 3% Discount rate 7% Discount rate
----------------------------------------------------------------------------------------------------------------
Billion 2015$
-------------------------------------------------
1............................................................. 103 47
2............................................................. 378 167
3............................................................. 477 210
4............................................................. 508 222
5............................................................. 575 250
----------------------------------------------------------------------------------------------------------------
Note: Results are based on the low benefit-per-ton values.
7. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) and
6316(a)) No other factors were considered in this analysis.
8. Summary of National Economic Impacts
Table V-44 presents the NPV values that result from adding the
estimates of the potential economic benefits resulting from reduced GHG
and NOX emissions to the NPV of consumer savings calculated
for each TSL considered in this rulemaking>
Table V-44--Consumer NPV Combined With Present Value of Benefits From Emissions Reductions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer NPV and low NOX values at 3% discount rate added with:
---------------------------------------------------------------------------------------------------
TSL GHG 5% discount rate, GHG 3% discount rate, GHG 2.5% discount rate, GHG 3% discount rate,
average case average case average case 95th percentile case
--------------------------------------------------------------------------------------------------------------------------------------------------------
Billion 2015$
---------------------------------------------------------------------------------------------------
1................................................... 5.6 6.8 7.7 10
2................................................... 19 23 27 36
3................................................... 26 32 36 48
4................................................... 24 30 35 47
5................................................... 28 35 41 54
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer NPV and low NOX values at 7% discount rate added with:
---------------------------------------------------------------------------------------------------
TSL GHG 5% GHG 3% GHG 2.5% GHG 3%
discount rate, discount rate, discount rate, discount rate,
average case average case average case 95th percentile case
--------------------------------------------------------------------------------------------------------------------------------------------------------
Billion 2015$
---------------------------------------------------------------------------------------------------
1................................................... 2.9 4.2 5.1 7.5
2................................................... 9.7 14 18 27
3................................................... 13 19 24 35
4................................................... 12 19 23 35
5................................................... 14 22 27 41
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The GHG benefits include the estimated benefits for reductions in CO2, CH4, and N2O emissions using the four sets of SC-CO2, SC-CH4, and SC-N2O
values developed by the interagency working group. See section IV.L.
The national operating cost savings are domestic U.S. monetary
savings that occur as a result of purchasing the covered equipment, and
are measured for the lifetime of equipment shipped in 2021-2050. The
benefits associated with reduced GHG emissions achieved as a result of
the adopted standards are also calculated based on the lifetime of
dedicated-purpose pool pumps shipped in 2021-2050. However, the
CO2 reduction is a benefit that accrues globally because
CO2 emissions have a very long residence time in the
atmosphere, the SC-CO2 values for future emissions reflect
climate-related impacts that continue through 2300.
C. Conclusion
When considering new energy conservation standards, the standards
[[Page 5733]]
that DOE adopts for any type (or class) of covered equipment must be
designed to achieve the maximum improvement in energy efficiency that
the Secretary determines is technologically feasible and economically
justified. (42 U.S.C. 6295(o)(2)(A) and 6316(a)) In determining whether
a standard is economically justified, the Secretary must determine
whether the benefits of the standard exceed its burdens by, to the
greatest extent practicable, considering the seven statutory factors
discussed previously. (42 U.S.C. 6295(o)(2)(B)(i) and 6316(a)) The new
standard must also result in significant conservation of energy. (42
U.S.C. 6295(o)(3)(B) and 6316(a))
For this direct final rule, DOE considered the impacts of potential
standards for pool pumps at each TSL, beginning with the maximum
technologically feasible level, to determine whether that level was
economically justified. Where the max-tech level was not justified, DOE
then considered the next most efficient level and undertook the same
evaluation until it reached the highest efficiency level that is both
technologically feasible and economically justified, as defined under
EPCA, and saves a significant amount of energy.
To aid the reader, as DOE discusses the benefits and/or burdens of
each TSL, tables in this section present a summary of the results of
DOE's quantitative analysis for each TSL. In addition to the
quantitative results presented in the tables, DOE also considers other
burdens and benefits that affect economic justification. These include
the impacts on identifiable subgroups of consumers who may be
disproportionately affected by a national standard and impacts on
employment.
1. Benefits and Burdens of TSLs Considered for Dedicated-Purpose Pool
Pumps
Table V-45 and Table V-46 summarize the quantitative impacts
estimated for each TSL for pool pumps. The national impacts are
measured over the lifetime of dedicated-purpose pool pumps purchased in
the 30-year period that begins in the anticipated year of compliance
with new standards (2021-2050). The energy savings, emissions
reductions, and value of emissions reductions refer to full-fuel-cycle
results. The efficiency levels contained in each TSL are described in
section V.A of this direct final rule.
Table V-45--Summary of Analytical Results for Pool Pumps TSLs: National Impacts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative FFC National Energy Savings (quads)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.79................... 3.0.................... 3.8................... 4.1................... 4.6.
--------------------------------------------------------------------------------------------------------------------------------------------------------
NPV of Consumer Costs and Benefits (billion 2015$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% discount rate.............. 5.1.................... 17..................... 24.................... 21.................... 25.
7% discount rate.............. 2.5.................... 8.1.................... 11.................... 10.................... 12.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative FFC Emissions Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)..... 42..................... 160.................... 202................... 216................... 246.
SO2 (thousand tons)........... 31..................... 116.................... 147................... 156................... 178.
NOX (thousand tons)........... 53..................... 203.................... 257................... 275................... 313.
Hg (tons)..................... 0.10................... 0.39................... 0.50.................. 0.53.................. 0.60.
CH4 (thousand tons)........... 200.................... 765.................... 968................... 1,035................. 1,179.
N2O (thousand tons)........... 0.62................... 2.3.................... 3.0................... 3.2................... 3.6.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Value of Emissions Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (billion 2015$) *......... 0.327 to 4.388......... 1.207 to 16.402........ 1.524 to 20.724....... 1.624 to 22.104....... 1.841 to 25.113.
CH4 (billion 2015$)........... 0.069 to 0.549......... 0.256 to 2.082......... 0.324 to 2.632........ 0.346 to 2.812........ 0.393 to 3.202.
N2O (billion 2015$)........... 0.002 to 0.019......... 0.007 to 0.072......... 0.008 to 0.091........ 0.009 to 0.097........ 0.010 to 0.110.
NOX--3% discount rate (billion 0.103 to 0.231......... 0.378 to 0.851......... 0.477 to 1.075........ 0.508 to 1.144........ 0.575 to 1.297.
2015$).
NOX--7% discount rate (billion 0.047 to 0.106......... 0.167 to 0.377......... 0.210 to 0.475........ 0.222 to 0.503........ 0.25 to 0.566.
2015$).
--------------------------------------------------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values.
* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
Table V-46--Summary of Analytical Results for Pool Pumps TSLs: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 * TSL 2 * TSL 3 * TSL 4 * TSL 5 *
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (million 2015$) (No- 201.0-210.9 178.8-200.2 166.5-219.8 126.2-195.9 36.8-110.5
standards case INPV = $212.8)..
Industry NPV (% change)......... (5.5)-(0.9) (16.0)-(5.9) (21.8)-3.3 (40.7)-(7.9) (82.7)-(48.1)
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2015$)
----------------------------------------------------------------------------------------------------------------
Standard-Size Self-Priming Pool 669 1,779 2,140 2,140 2,085
Filter Pump....................
Small-Size Self-Priming Pool 295 322 295 360 414
Filter Pump....................
Standard-Size Non-Self-Priming 191 35 191 10 93
Pool Filter Pump...............
Extra-Small Non-Self-Priming 36 36 36 10 10
Pool Filter Pump...............
Waterfall Pump.................. (3) (3) n/a (20) 13
Pressure Cleaner Booster Pump... 111 111 111 (372) (313)
Integral Cartridge Filter Pump.. n/a n/a 128 n/a n/a
[[Page 5734]]
Integral Sand Filter Pump....... n/a n/a 73 n/a n/a
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
Standard-Size Self-Priming Pool 0.6 0.7 0.7 0.7 0.6
Filter Pump....................
Small-Size Self-Priming Pool 0.8 2.0 0.8 2.1 1.9
Filter Pump....................
Standard-Size Non-Self-Priming 0.2 2.3 0.2 2.3 2.1
Pool Filter Pump...............
Extra-Small Non-Self-Priming 0.9 0.9 0.9 1.6 1.6
Pool Filter Pump...............
Waterfall Pumps................. 4.5 4.5 n/a 5.4 3.7
Pressure Cleaner Booster Pumps.. 0.6 0.6 0.6 6.0 5.1
Integral Cartridge Filter Pump.. n/a n/a 0.4 n/a n/a
Integral Sand Filter Pump....... n/a n/a 0.5 n/a n/a
----------------------------------------------------------------------------------------------------------------
Percent of Consumers That Experience a Net Cost (%)
----------------------------------------------------------------------------------------------------------------
Standard-Size Self-Priming Pool 1 5 10 10 8
Filter Pump....................
Small-Size Self-Priming Pool 4 27 4 29 26
Filter Pump....................
Standard-Size Non-Self-Priming 0 58 0 51 47
Pool Filter Pump...............
Extra-Small Non-Self-Priming 4 4 4 39 39
Pool Filter Pump...............
Waterfall Pumps................. 50 50 n/a 70 55
Pressure Cleaner Booster Pumps.. 0 0 0 69 68
Integral Cartridge Filter Pump.. n/a n/a 3 n/a n/a
Integral Sand Filter Pump....... n/a n/a 3 n/a n/a
----------------------------------------------------------------------------------------------------------------
* Parentheses indicate negative (-) values.
DOE first considered TSL 5, which represents the max-tech
efficiency levels. TSL 5 would save an estimated 4.6 quads of energy,
an amount DOE considers significant. Under TSL 5, the NPV of consumer
benefit would be $12 billion using a discount rate of 7 percent, and
$25 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 5 are 246 Mt of
CO2; 178 thousand tons of SO2; 313 thousand tons
of NOX; 0.60 tons of Hg; 1,179 thousand tons of
CH4; and 3.6 thousand tons of N2O. The estimated
monetary value of the GHG emissions reduction at TSL 5 ranges from $1.8
billion to $25 billion for CO2, from $393 million to 3,202
million for CH4, and from $10 million to $110 million for
N2O. The estimated monetary value of the NOX
emissions reduction at TSL 5 is $250 million using a 7-percent discount
rate and $575 million using a 3-percent discount rate.
At TSL 5, the average LCC impact is a savings that ranges from $10
for extra-small non-self-priming pumps, to $2,085 for standard-size
self-priming pump, except for pressure cleaner booster pumps, which
have a savings of negative $313. The simple payback period ranges from
0.6 years for standard-size self-priming pumps to 5.1 years for
pressure cleaner booster pumps. The fraction of consumers experiencing
a net LCC cost ranges from eight percent for standard-size self-priming
pumps to 68 percent for pressure cleaner booster pumps.
At TSL 5, the projected change in INPV ranges from a decrease of
$176.0 million to a decrease of $102.3 million, which correspond to
decreases of 82.7 percent and 48.1 percent, respectively. DOE estimates
that industry must invest $199.5 million to comply with standards set
at TSL 5. Manufacturers would need to redesign a significant portion of
the equipment they offer, including hydraulic redesigns to convert the
vast majority of their standard-size self-priming pool filter pumps.
The Secretary concludes that at TSL 5 for dedicated-purpose pool
pumps, the benefits of energy savings, positive NPV of consumer
benefits, emission reductions, and the estimated monetary value of the
emissions reductions would be outweighed by the economic burden on some
consumers, and the significant impacts on manufacturers, including the
large conversion costs and profit margin impacts that could result in a
large reduction in INPV. Consequently, the Secretary has concluded that
TSL 5 is not economically justified.
DOE then considered TSL 4, which represents efficiency levels based
on variable speed technology for most equipment classes. TSL 4 would
save an estimated 4.1 quads of energy, an amount DOE considers
significant. Under TSL 4, the NPV of consumer benefit would be $10
billion using a discount rate of 7 percent, and $21 billion using a
discount rate of 3 percent.
The cumulative emissions reductions at TSL 4 are 216 Mt of
CO2, 156 thousand tons of SO2, 275 thousand tons
of NOX, 0.53 tons of Hg, 1,035 thousand tons of
CH4, and 3.2 thousand tons of N2O. The estimated
monetary value of the GHG emissions reduction at TSL 4 ranges from $1.6
billion to $22 billion for CO2, from $346 million to $2,812
million for CH4, and from $8.8 million to $97 million for
N2O. The estimated monetary value of the NOX
emissions reduction at TSL 4 is $222 million using a 7-percent discount
rate and $508 million using a 3-percent discount rate.
At TSL 4, the average LCC impact is a savings that ranges from $10
for extra-small non-self-priming pumps, to $2,140 for standard-size
self-priming pumps, except for pressure cleaner booster pumps, which
have a savings of negative $372, and waterfall pumps, which have a
savings of negative $20. The simple payback period ranges from 0.7
years for standard-size self-priming pumps to 6.0 years for pressure
cleaner booster pumps. The fraction of consumers experiencing a net LCC
cost ranges from 10 percent for standard-size self-priming pumps to 70
percent for waterfall pumps.
At TSL 4, the projected change in INPV ranges from a decrease of
$86.6 million to a decrease of $16.9 million, which correspond to
decreases of 40.7 percent and 7.9 percent, respectively. DOE estimates
that industry must invest $68.4 million to comply with standards set at
TSL 4.
The Secretary concludes that at TSL 4 for dedicated-purpose pool
pumps,
[[Page 5735]]
the benefits of energy savings, positive NPV of consumer benefits,
emission reductions, and the estimated monetary value of the emissions
reductions, would be outweighed by the economic burden on some
consumers, and the significant impacts on manufacturers, including the
large conversion costs and profit margin impacts that could result in a
large reduction in INPV. Consequently, the Secretary has concluded that
TSL 4 is not economically justified.
DOE then considered TSL 3, the recommended TSL, which would save an
estimated 3.8 quads of energy, an amount DOE considers significant.
Under TSL 3, the NPV of consumer benefit would be $11 billion using a
discount rate of 7 percent, and $24 billion using a discount rate of 3
percent.
The cumulative emissions reductions at TSL 3 are 202 Mt of
CO2; 147 thousand tons of SO2; 257 thousand tons
of NOX, 0.50 tons of Hg, 968 thousand tons of
CH4; and 3.0 thousand tons of N2O. The estimated
monetary value of the GHG emissions reduction at TSL 3 ranges from $1.5
billion to $21 billion for CO2, from $324 million to $2,632
million for CH4, and from $8.3 million to $91 million for
N2O. The estimated monetary value of the NOX
emissions reduction at TSL 3 is $210 million using a 7-percent discount
rate and $477 million using a 3-percent discount rate.
At TSL 3, the average LCC impact is a savings that ranges from $36
for extra-small non-self-priming pool filter pumps to $2,140 for
standard-size self-priming pumps. The simple payback period ranges from
0.2 years for standard-size non-self-priming pool filter pumps to 0.8
years for extra-small non-self-priming pool filter pumps. The fraction
of consumers experiencing a net LCC cost ranges from zero percent for
standard-size non-self-priming pumps and pressure cleaner booster pumps
to 10 percent for standard-size self-priming pumps.
At TSL 3, the projected change in INPV ranges from a decrease of
$46.3 million to an increase of $7.0 million, which represents a
decrease of 21.8 percent to an increase of 3.3 percent, respectively.
DOE estimates that industry must invest $35.6 million to comply with
standards set at TSL 3.
After considering the analysis and weighing the benefits and
burdens, the Secretary has concluded that, at TSL 3 for dedicated-
purpose pool pumps, the benefits of energy savings, positive NPV of
consumer benefits, emission reductions, the estimated monetary value of
the emissions reductions, and positive average LCC savings, would
outweigh the potential negative impacts on manufacturers. Accordingly,
the Secretary has concluded that TSL 3 would offer the maximum
improvement in efficiency that is technologically feasible and
economically justified, as defined under EPCA, and would result in the
significant conservation of energy.
Therefore, based on the above considerations, as well as those
discussed in section III.A, DOE adopts the energy conservation
standards for pool pumps at TSL 3. The new performance-based energy
conservation standards for pool pumps, which are expressed as kgal/kWh,
are shown in Table V-47. The new prescriptive energy conservation
standards for pool pumps are shown in Table V-48.
Table V-47--Adopted Performance-Based Energy Conservation Standards for Dedicated-Purpose Pool Pumps
----------------------------------------------------------------------------------------------------------------
Equipment class
--------------------------------------------------------------------------------------- Minimum allowable WEF
Dedicated-purpose pool pump score [kgal/kwh]
variety hhp applicability * Motor phase
----------------------------------------------------------------------------------------------------------------
Self-priming pool filter pumps... 0.711 hp <=hhp <2.5 hp........... Single.......... -2.30 * ln (hhp) + 6.59.
Self-priming pool filter pumps... hhp <0.711 hp.................... Single.......... 5.55, for hhp <=0.13 hp
1.30 * ln (hhp) + 2.90,
for hhp >0.13 hp.
Non-self-priming pool filter hhp <2.5 hp...................... Any............. 4.60, for hhp <=0.13 hp
pumps **. 0.85 * ln (hhp) + 2.87,
for hhp >0.13 hp.
Pressure cleaner booster pumps... Any.............................. Any............. 0.42.
----------------------------------------------------------------------------------------------------------------
* All instances of hhp refer to rated hydraulic horsepower as determined in accordance with the DOE test
procedure at 10 CFR 431.464 and applicable sampling plans.
** Because DOE selected the same efficiency level for both extra-small and standard-size non-self-priming pool
filter pumps, the two equipment classes were ultimately merged into one.
Table V-48--Adopted Prescriptive Energy Conservation Standards for Dedicated-Purpose Pool Pumps
----------------------------------------------------------------------------------------------------------------
Equipment class
---------------------------------------------------------------------------------------
Dedicated-purpose pool pump Prescriptive standard
variety hhp applicability * Motor phase
----------------------------------------------------------------------------------------------------------------
Integral sand filter pool pump... Any.............................. Any............. Must be distributed in
commerce with a pool
pump timer that is
either integral to the
pump or a separate
component that is
shipped with the pump.
Integral cartridge filter pool Any.............................. Any............. Must be distributed in
pump. commerce with a pool
pump timer that is
either integral to the
pump or a separate
component that is
shipped with the pump.
----------------------------------------------------------------------------------------------------------------
2. Annualized Benefits and Costs of the Adopted Standards
The benefits and costs of the adopted standards can also be
expressed in terms of annualized values. The annualized net benefit is
(1) the annualized national economic value (expressed in 2015$) of the
benefits from operating equipment that meet the adopted standards
(consisting primarily of operating cost savings from using less
energy), minus increases in product purchase costs, and (2) the
annualized monetary value of the benefits of GHG and NOX
emission reductions.
Table V-49 shows the annualized values for dedicated-purpose pool
pumps under TSL 3, expressed in
[[Page 5736]]
2015$. The results under the primary estimate are as follows.
Using a 7-percent discount rate for benefits and costs other than
GHG reduction (for which DOE used average social costs with a 3-percent
discount rate),\136\ the estimated cost of the standards in this rule
is $138 million per year in increased equipment costs, while the
estimated annual benefits are $1.3 billion in reduced equipment
operating costs, $449 million in GHG reductions, and $22 million in
reduced NOX emissions. In this case, the net benefit amounts
to $1.7 billion per year.
---------------------------------------------------------------------------
\136\ DOE used average social costs with a 3-percent discount
rate these values are considered as the ``central'' estimates by the
interagency group.
---------------------------------------------------------------------------
Using a 3-percent discount rate for all benefits and costs, the
estimated cost of the adopted standards for dedicated-purpose pool
pumps is $149 million per year in increased equipment costs, while the
estimated annual benefits are $1.5 billion in reduced operating costs,
$449 million in CO2 reductions, and $27 million in reduced
NOX emissions. In this case, the net benefit amounts to $1.8
billion per year.
Table V-49--Annualized Benefits and Costs of Adopted Standards (TSL 3) for Dedicated-Purpose Pool Pumps
--------------------------------------------------------------------------------------------------------------------------------------------------------
High-net- benefits
Discount rate (%) Primary estimate Low-net- benefits estimate estimate
--------------------------------------------------------------------------------------------------------------------------------------------------------
Million 2015$/year
---------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings... 7............................... 1,340..................... 1,221..................... 1,467
3............................... 1,516..................... 1,367..................... 1,678
GHG Reduction (using avg. social 5............................... 147....................... 129....................... 164
costs at 5% discount rate) **.
GHG Reduction (using avg. social 3............................... 449....................... 392....................... 504
costs at 3% discount rate) **.
GHG Reduction (using avg. social 2.5............................. 642....................... 560....................... 721.
costs at 2.5% discount rate) **.
GHG Reduction (using 95th 3............................... 1,346..................... 1,175..................... 1,510.
percentile social costs at 3%
discount rate) **.
NOX Reduction [dagger]............ 7%.............................. 22........................ 20........................ 55.
3%.............................. 27........................ 24........................ 70.
Total Benefits [Dagger]........... 7% plus GHG range............... 1,509 to 2,708............ 1,369 to 2,416............ 1,686 to 3,032.
7%.............................. 1,811..................... 1,633..................... 2,026.
3% plus GHG range............... 1,690 to 2,890............ 1,520 to 2,566............ 1,912 to 3,258.
3%.............................. 1,993..................... 1,783..................... 2,252.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Incremental Equipment 7%.............................. 138....................... 124....................... 151.
Costs.
3%.............................. 149....................... 133....................... 164.
Manufacturer Conversion Costs 7%.............................. 3......................... 3......................... 3.
[dagger][dagger].
3%.............................. 2......................... 2......................... 2.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total [Dagger].................... 7% plus GHG range............... 1,371 to 2,570............ 1,245 to 2,292............ 1,535 to 2,881.
7%.............................. 1,673..................... 1,509..................... 1,875.
3% plus GHG range............... 1,542 to 2,741............ 1,387 to 2,433............ 1,748 to 3,094.
3%.............................. 1,844..................... 1,651..................... 2,088.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with pool pumps shipped in 2021-2050. These results include benefits to consumers
which accrue after 2050 from the pool pumps purchased from 2021-2050. The incremental equipment costs include incremental equipment cost as well as
installation costs. The costs account for the incremental variable and fixed costs incurred by manufacturers due to the adopted standards, some of
which may be incurred in preparation for the rule. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices
and real GDP from the AEO2016 No-CPP case, a Low Economic Growth case, and a High Economic Growth case, respectively. In addition, incremental product
costs reflect the default price trend in the Primary Estimate, a high price trend in the Low Benefits Estimate, and a low price trend in the High
Benefits Estimate. The methods used to derive projected price trends are explained in section IV.F.1. Note that the Benefits and Costs may not sum to
the Net Benefits due to rounding.
** The interagency group selected four sets of SC-CO2 SC-CH4, and SC-N2O values for use in regulatory analyses. Three sets of values are based on the
average social costs from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth set, which
represents the 95th percentile of the social cost distributions calculated using a 3-percent discount rate, is included to represent higher-than-
expected impacts from climate change further out in the tails of the social cost distributions. The social cost values are emission year specific. The
GHG reduction benefits are global benefits due to actions that occur nationally. See section IV.L for more details.
[dagger] DOE estimated the monetized value of NOX emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule, published in August 2015 by EPA's Office of Air Quality Planning and Standards.
(Available at www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis.) See section IV.L.3 for further discussion. For the
Primary Estimate and Low Net Benefits Estimate, DOE used national benefit-per-ton estimates for NOX emitted from the Electric Generating Unit sector
based on an estimate of premature mortality derived from the ACS study (Krewski et al. 2009). For the High Net Benefits Estimate, the benefit-per-ton
estimates were based on the Six Cities study (Lepuele et al. 2011); these are nearly two-and-a-half times larger than those from the ACS study.
[[Page 5737]]
[Dagger] Total Benefits for both the 3-percent and 7-percent cases are presented using the average social costs with 3-percent discount rate. In the
rows labeled ``7% plus GHG range'' and ``3% plus GHG range,'' the operating cost and NOX benefits are calculated using the labeled discount rate, and
those values are added to the full range of social cost values.
[dagger][dagger] Manufacturers are estimated to incur $35.6 million in conversion costs between 2017 and 2020.
VI. Other Prescriptive Requirements
As part of the DPPP Working Group's extended charter, the DPPP
Working Group considered requirements for pumps distributed in commerce
with freeze protections controls. (Docket No. EERE-2013-BT-NOC-0005,
No. 71 at pp. 20-52) Freeze protection controls, as defined in the test
procedure final rule, are controls that, at certain ambient
temperature, turn on the dedicated-purpose pool pump to circulate water
for a period of time to prevent the pool and water in plumbing from
freezing. As the control schemes for freeze protection vary widely
between manufacturers, the resultant energy consumption associated with
such control can also vary depending on control settings and climate.
To ensure freeze protection controls on dedicated-purpose pool pumps
only operate when necessary and do not result in unnecessary energy
use, the DPPP Working Group discussed two different approaches for
regulating freeze protection controls: (1) Regulation by incorporating
freeze protection into the WEF metric, and (2) regulation with a
prescriptive standard. Several DPPP Working Group members commented
that regulation by prescriptive standard would be the simplest
approach, since it would not involve revision of the WEF metric that
the DPPP Working Group previously recommended. The DPPP Working Group
reached consensus that freeze protection should be regulated by
prescriptive standard. (Docket No. EERE-2015-BT-STD-0008-0079, April 19
DPPP Working Group Meeting, at pp. 148)
The CA IOUs suggested that the prescriptive standard prescribe the
default settings for trigger temperature, run time, and operation speed
that would be pre-programmed into freeze-protection-enabled dedicated-
purpose pool pumps at the time of shipment. The CA IOUs commented that
models with default settings of 42 degrees Fahrenheit, 12 hours of run
time, and high-speed operation result in unnecessary energy use. The CA
IOUs proposed that freeze-protection-enabled pumps either ship with
freeze protection disabled or ship with default settings with maximums
of 39 degrees Fahrenheit, 30 minutes of run time, and a half-speed
operation. Hayward and Pentair commented that the suggested default
settings were too restrictive and may cause end users to experience
frozen piping. Pentair proposed default freeze protection settings with
a trigger temperature of 40 degrees Fahrenheit and a run time of one
hour. The DPPP Working Group agreed to these amended settings. (Docket
No. EERE-2015-BT-STD-0008-0101, May 19 DPPP Working Group Meeting, at
pp. 93-104)
Ultimately, the DPPP Working Group recommended establishing
prescriptive requirements for dedicated-purpose pool pumps that are
distributed in commerce with freeze protection controls. Specifically,
the DPPP Working Group made the following recommendation, which it
purports to maintain end-user utility while also reducing energy
consumption:
All dedicated-purpose pool pumps distributed in commerce with
freeze protection controls must be shipped either with freeze
protection disabled, or with the following default, user-adjustable
settings: (1) The default dry-bulb air temperature setting is no
greater than 40 [deg]F; and (2) the default run time setting shall be
no greater than 1 hour (before the temperature is rechecked); and (3)
the default motor speed shall not be more than half of the maximum
available speed. Id. (Docket No. EERE-2015-BT-STD-0008, No. 82,
Recommendation #6A at p. 4). DOE agrees with the DPPP Working Group's
reasoning, and given the considerations discussed in section III.A, DOE
adopts the recommended prescriptive standard for dedicated-purpose pool
pumps distributed in commerce with freeze protection controls.
VII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that the adopted standards for dedicated-purpose pool
pumps are intended to address are as follows:
(1) Insufficient information and the high costs of gathering and
analyzing relevant information leads some consumers to miss
opportunities to make cost-effective investments in energy efficiency.
In some cases the benefits of more efficient equipment are not
realized due to misaligned incentives between purchasers and users. An
example of such a case is when the equipment purchase decision is made
by a building contractor or building owner who does not pay the energy
costs.
There are external benefits resulting from improved energy
efficiency of products and equipment that are not captured by the users
of such equipment. These benefits include externalities related to
public health, environmental protection and national energy security
that are not reflected in energy prices, such as reduced emissions of
air pollutants and greenhouse gases that impact human health and global
warming. DOE attempts to qualify some of the external benefits through
use of social cost of carbon values.
The Administrator of the Office of Information and Regulatory
Affairs (OIRA) in the OMB has determined that the regulatory action in
this direct final rule is a significant regulatory action under section
(3)(f) of Executive Order 12866. Accordingly, pursuant to section
6(a)(3)(B) of the Order, DOE has provided to OIRA: (i) The text of the
draft regulatory action, together with a reasonably detailed
description of the need for the regulatory action and an explanation of
how the regulatory action will meet that need; and (ii) an assessment
of the potential costs and benefits of the regulatory action, including
an explanation of the manner in which the regulatory action is
consistent with a statutory mandate. DOE has included these documents
in the rulemaking record.
In addition, the Administrator of OIRA has determined that the
regulatory action is an ``economically'' significant regulatory action
under section (3)(f)(1) of Executive Order 12866. Accordingly, pursuant
to section 6(a)(3)(C) of the Order, DOE has provided to OIRA an
assessment, including the underlying analysis, of benefits and costs
anticipated from the regulatory action, together with, to the extent
feasible, a quantification of those costs; and an assessment, including
the underlying analysis, of costs and benefits of potentially effective
and reasonably feasible alternatives to the planned regulation, and an
explanation why the planned regulatory action is preferable
[[Page 5738]]
to the identified potential alternatives. These assessments can be
found in the direct final rule TSD.
DOE also has reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011. 76 FR 3281, Jan. 21, 2011. E.O.
13563 is supplemental to and explicitly reaffirms the principles,
structures, and definitions governing regulatory review established in
E.O. 12866. To the extent permitted by law, agencies are required by
E.O. 13563 to (1) propose or adopt a regulation only upon a reasoned
determination that its benefits justify its costs (recognizing that
some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that E.O. 13563 requires agencies to use the
best available techniques to quantify anticipated present and future
benefits and costs as accurately as possible. In its guidance, OIRA has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. In response to this guidance, DOE will
conduct a retrospective review of the seven EPCA statutory factors that
DOE evaluated to determine that the energy conservation standards in
this direct final rule were economically justified. (42 U.S.C.
6295(o)(2)(B)(i)(I)(VII)) and 6316(a)). For example, DOE's review will
seek to verify the projected manufacturer impacts following compliance
with the rule by comparing the estimated product conversion costs and
industry net present value to the actual costs. Other parts of the
review will cover the estimated impacts on consumers by assessing the
accuracy of the assumed pool pump operating hours in order to update,
as necessary, the estimated consumer energy savings, lifecycle savings,
and payback period estimates associated with this direct final rule.
DOE's review will investigate any potential utility or consumer welfare
impacts that may not have been quantified in the engineering cost
analysis. DOE's research will cover publicly available information, but
will also consist of a survey of manufacturers and pool owners to
assess the agency's assumptions. DOE will conduct this retrospective
review of this direct final rulemaking prior to issuing any future
revised energy efficiency standards for this product category.
For the reasons stated in the preamble, this direct final rule is
consistent with these principles, including the requirement that, to
the extent permitted by law, benefits justify costs.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) and a
final regulatory flexibility analysis (FRFA) for any rule that by law
must be proposed for public comment, unless the agency certifies that
the rule, if promulgated, will not have a significant economic impact
on a substantial number of small entities. As required by Executive
Order 13272, ``Proper Consideration of Small Entities in Agency
Rulemaking,'' 67 FR 53461 (Aug. 16, 2002), DOE published procedures and
policies on February 19, 2003, to ensure that the potential impacts of
its rules on small entities are properly considered during the
rulemaking process. 68 FR 7990. DOE has made its procedures and
policies available on the Office of the General Counsel's Web site
(http://energy.gov/gc/office-general-counsel). DOE has prepared the
following IRFA for the equipment that are the subject of this
rulemaking.
1. Description of Reasons Why Action Is Being Considered
Currently, no Federal energy conservation standards exist for
dedicated-purpose pool pumps. DOE excluded this category of pumps from
its recent consensus-based energy conservation standard final rule for
general pumps. 81 FR 4368 (January 26, 2016). That final rule, which
was the product of a pumps working group that had been created through
the ASRAC, examined a variety of pump categories. While dedicated-
purpose pool pumps were one of the pump categories that were considered
during the working group's discussions, the working group ultimately
recommended that DOE initiate a separate rulemaking for dedicated-
purpose pool pumps. (Docket No. EERE-2013-BT-NOC-0039, No. 0092 at p.
2)
2. Objectives of, and Legal Basis for, the Rule
Title III, Part C \137\ of the Energy Policy and Conservation Act
of 1975 (EPCA), (42 U.S.C. 6311-6317, as codified) established the
Energy Conservation Program for Certain Industrial Equipment, a program
covering certain industrial equipment.\138\ ``Pumps'' are listed as a
type of covered industrial equipment. (42 U.S.C. 6311(1)(A))
---------------------------------------------------------------------------
\137\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
\138\ All references to EPCA refer to the statute as amended
through the Energy Efficiency Improvement Act of 2015, Public Law
114-11 (April 30, 2015).
---------------------------------------------------------------------------
While pumps are listed as a type of covered equipment, EPCA does
not define the term ``pump.'' To address this, in January 2016, DOE
published a test procedure final rule (January 2016 general pumps test
procedure final rule) that established a definition for the term
``pump.'' 81 FR 4086, 4147 (January 25, 2016). Dedicated-purpose pool
pumps meet the definition of ``pump'' and are therefore a category of
pump.
3. Description and Estimate of the Number of Small Entities Affected
a. Methodology for Estimating the Number of Small Entities
For manufacturers of dedicated-purpose pool pumps, the Small
Business Administration (SBA) has set a size threshold, which defines
those entities classified as ``small businesses'' for the purposes of
the statute. DOE used the SBA's small business size standards to
determine whether any small entities would be subject to the
requirements of this rule. The size standards are codified at 13 CFR
part 121. The standards are listed by North American Industry
Classification System (NAICS) code and industry description and are
available at: www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf.
DPPP manufacturing is classified under NAICS 333911, pump and
pumping equipment manufacturing. The SBA sets a threshold of 750
employees or fewer for an entity to be considered a small business for
this category.
DOE reviewed the potential standard levels considered in this
direct final rule under the provisions of the Regulatory
[[Page 5739]]
Flexibility Act and the procedures and policies published on February
19, 2003. During its market survey, DOE used publicly available
information, such as databases from the CEC, APSP, and ENERY STAR;
individual company Web sites; and market research tools (e.g., Hoover's
reports) to create a list of companies that manufacture dedicated-
purpose pool pumps covered by this direct final rule. During
manufacturer interviews, DOE also asked stakeholders and industry
representatives if they were aware of any additional small
manufacturers. DOE then reviewed the list of companies manufacturing
equipment covered by this direct final rule, used publicly available
data sources (e.g., Hoovers,\139\ Cortera,\140\ LinkedIn,\141\ etc.),
and direct contact with various companies to determine if they met the
SBA's definition of a small business manufacturer. DOE screened out
companies that do not offer equipment affected by this direct final
rule, do not meet the definition of a ``small business,'' are foreign
owned and operated, or do not manufacture dedicated-purpose pool pumps
in the United States.
---------------------------------------------------------------------------
\139\ www.hoovers.com.
\140\ www.cortera.com.
\141\ www.linkedin.com.
---------------------------------------------------------------------------
DOE identified 21 manufacturers of dedicated-purpose pool pumps
products affected by this rulemaking. Of these, DOE identified five as
domestic small businesses.
b. Manufacturer Participation
DOE contacted the five identified small businesses and invited them
to take part in a manufacturer impact analysis interview. Of the small
businesses contacted, DOE was able to discuss potential standards with
one. DOE also obtained information about small businesses and potential
impacts on small businesses while interviewing large manufacturers.
c. Dedicated-Purpose Pool Pump Industry Structure and Nature of
Competition
Self-priming pool filter pumps account for approximately 65 percent
of manufacturer revenues in the dedicated-purpose pool pump industry.
Three manufacturers have approximately 75 percent of all self-priming
pool filter pump models in the market, which accounts for approximately
90 percent of shipments. None of these three major manufacturers are
small businesses. Besides the three major manufacturers, DOE identified
twelve other manufacturers that make self-priming pool filter pumps,
including all five small businesses.
The same three manufacturers that control the majority of the self-
priming pool filter pump market also control the majority of the
standard-size non-self-priming pool filter pump, pressure cleaner
booster pump, and waterfall pump market. Manufacturer revenues for
these equipment classes are substantially smaller than revenues for the
self-priming pool filter pump equipment classes. One small business
only makes standard-size self-priming pool filter pumps; three small
businesses make small-size self-priming, standard-size self-priming
pool filter pumps, and standard-size non-self-priming pool filter
pumps; and one small business makes small-size self-priming, standard-
size self-priming, standard-size non-self-priming, and pressure cleaner
booster pumps.
The large majority of integral cartridge filter pool pumps,
integral sand filter pool pumps, and extra-small non-self-priming pool
filter pumps market is controlled by manufacturers that focus on
seasonal pools, such inflatable or collapsible frame pools. These
manufacturers typically design dedicated-purpose pool pumps and have
them manufactured overseas. DOE did not identify any small businesses
that manufacture integral cartridge-filter pool pumps and integral sand
filter pool pumps, since this equipment is imported from China.
4. Description of Compliance Requirements
As previously stated, DOE identified five small DPPP manufacturers.
The small manufacturers make small-size self-priming, standard-size
self-priming, standard-size non-self-priming, and pressure cleaner
booster pumps. Accordingly, this analysis of small business impacts
focuses exclusively on these equipment classes.
To evaluate impacts facing manufacturers of dedicated-purpose pool
pumps, DOE estimated both the capital conversion costs (i.e.,
investments in property, plant, and equipment) and product conversion
costs (i.e., expenditures on R&D, testing, marketing, and other non-
depreciable expense) manufacturers would incur to bring their
manufacturing facilities and product designs into compliance with
adopted standards. As outlined in section IV.C and in chapter 5 of the
direct final rule TSD, the design options analyzed to comply with the
adopted energy conservation standards include changing the motor to
either variable-speed for standard-size self-priming pool filter pumps,
or a more efficient single-speed motor for small-size self-priming,
non-self-priming, and pressure cleaner booster pumps. DOE estimated
per-model and per-wet-end redesign costs to determine product and
capital conversion costs.
DOE used manufacturer specification sheets and product catalogs to
estimate the number of models that each small business needs to
redesign to comply with the adopted standards. DOE then multiplied this
number by the per model redesign costs. This methodology is outlined in
more detail in section IV.J.2.c.
The largest burden small businesses face is to bring standard-size
self-priming pool filter pumps into compliance with the adopted
standard. All five small businesses manufacture standard-size self-
priming pool filter pumps and all of them make at least one compliant
variable-speed pool filter pump. These small manufacturers could decide
to ramp up the production of their already-compliant models and
discontinue their non-compliant equipment. However, this could cause
gaps in equipment offerings for manufacturers. Therefore, it is likely
that manufacturers will redesign some non-compliant pumps to fill
potential gaps in their equipment offerings. As described in section
IV.J.2.c, DOE assumed that one variable-speed pool filter pump can
replace multiple single- and two-speed pool filter pumps. Using this
assumption DOE estimated that small businesses will incur $5.3 million
in conversion costs to bring non-compliant standard-size self-priming
pool filter pumps into compliance.
Four small businesses make small-size self-priming pool filter
pumps. The adopted efficiency level for this equipment class analyzes
the incorporation of a more efficient single-speed motor. All four
manufacturers make multiple single-speed models and some might need to
be redesigned to maintain a complete product offering. DOE expected
that two small businesses will not incur any conversion costs, and the
other two small businesses will incur a combined total of $0.6 million
in conversion costs to bring non-compliant small-size self-priming pool
filter pumps into compliance.
DOE identified four small businesses that make standard-size non-
self-priming pool filter pumps. The adopted efficiency level for this
equipment class can be achieved through the incorporation of a more
efficient single-speed motor. Two manufacturers offer all non-self-
priming pool filter pumps in both single- and two-speed configurations.
DOE estimated that these manufacturers will not incur any
[[Page 5740]]
conversion costs, because they could discontinue non-compliant single-
speed dedicated-purpose pool pumps and still continue to have the same
product offering with their two-speed dedicated-purpose pool pumps. The
two other manufacturers have a greater number of single-speed than two-
speed non-self-priming pool filter pumps and DOE expected these
manufacturers will redesign some dedicated-purpose pool pumps to
maintain a complete product offering. In total, small manufacturers of
non-self-priming pool filter pumps are estimated to redesign two
standard-size non-self-priming pool filter pumps and incur $0.7 million
in conversion costs to bring non-compliant equipment into compliance.
Only one pressure cleaner booster pump model is offered in the
market by small businesses. DOE did not have performance data for this
pump; however, based on the no-standards case shipments distribution,
87 percent of pressure cleaner booster shipments already meet or exceed
the adopted standard. Therefore, DOE expected that this model does not
have to be redesigned under the adopted standard.
DOE estimates that the five small business will incur a total of
$6.6 million in conversion costs to bring non-complaint standard-size
self-priming, small-size self-priming, standard-size non-self-priming,
and pressure cleaner booster pool pumps into compliance. Using publicly
available data, DOE estimates the average annual revenue of the five
small manufacturers to be $53.6 million.\142\ DOE expects small
manufacturers will be able to spread their conversion costs over the
four-and-a-half year and a half year compliance period between the
expected publication of a final rule (2016) and the expected compliance
year (2021). Given these assumptions, DOE estimates that conversion
costs are 0.55 percent of total small business four-and-a-half year
revenue. While the standards creates additional business risk for these
small businesses, DOE's calculations show that the conversion costs
associated with this increase in efficiency are moderate.
---------------------------------------------------------------------------
\142\ This estimate is based on estimates from Hoovers
(www.hoovers.com), Last accessed July 27, 2016.
---------------------------------------------------------------------------
5. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the rule being considered today.
6. Significant Alternatives Considered and Steps Taken To Minimize
Significant Economic Impacts on Small Entities
The discussion in the previous section analyzes impacts on small
businesses that would result from adoption of this direct final rule,
represented by TSL 3. In reviewing alternatives to the adopted rule,
DOE examined energy conservation standards set at lower efficiency
levels. While TSL 1 and TSL 2 would reduce the impacts on small
business manufacturers, it would come at the expense of a reduction in
energy savings and NPV benefits to consumers. TSL 1 achieves 79 percent
lower energy savings and 77 percent less NPV benefits discounted at 7
percent to consumers compared to the energy savings and NPV benefits at
TSL 3. TSL 2 achieves 21 percent lower energy savings and 26 percent
less NPV benefits discounted at 7 percent to consumers compared to the
energy savings and NPV benefits at TSL 3.
Establishing standards at TSL 3 balances the benefits of the energy
savings and benefits to consumers at TSL 3 with the potential more
significant burdens placed on DPPP manufacturers, including small
business manufacturers. Accordingly, DOE is choosing not to adopt one
of the other TSLs considered in the analysis, or the other policy
alternatives examined as part of the regulatory impact analysis,
included in chapter 17 of the direct final rule TSD.
Additional compliance flexibilities may be available through other
means. EPCA provides that a manufacturer whose annual gross revenue
from all of its operations does not exceed $8 million may apply for an
exemption from all or part of the energy conservation standards for a
period not longer than 24 months after the effective date of a final
rule establishing the standards. Additionally, Section 504 of the
Department of Energy Organization Act, 42 U.S.C. 7194, provides
authority for the Secretary to adjust a rule issued under EPCA in order
to prevent ``special hardship, inequity, or unfair distribution of
burdens'' that may be imposed on that manufacturer as a result of such
rule. Manufacturers should refer to 10 CFR part 430, subpart E, and 10
CFR part 1003 for additional details.
C. Review Under the Paperwork Reduction Act
Manufacturers of dedicated-purpose pool pumps must certify to DOE
that their products comply with any applicable energy conservation
standards. In certifying compliance, manufacturers must test their
products according to the DOE test procedures for dedicated-purpose
pool pumps, including any amendments adopted for those test procedures.
DOE has established regulations for the certification and recordkeeping
requirements for all covered consumer products and commercial
equipment, including pumps. 76 FR 12422 (March 7, 2011); 80 FR 5099
(Jan. 30, 2015). The collection-of-information requirement for the
certification and recordkeeping is subject to review and approval by
OMB under the Paperwork Reduction Act (PRA). This requirement has been
approved by OMB under OMB control number 1910-1400. Public reporting
burden for the certification is estimated to average 30 hours per
response, including the time for reviewing instructions, searching
existing data sources, gathering and maintaining the data needed, and
completing and reviewing the collection of information.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that this direct final rule fits within the category
of actions included in Categorical Exclusion (CX) B5.1 and otherwise
meets the requirements for application of a CX. (See 10 CFR part 1021,
app. B, B5.1(b); 1021.410(b) and App. B, B(1)-(5).) The rule fits
within this category of actions because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, and for which none of the exceptions identified
in CX B5.1(b) apply. Therefore, DOE has made a CX determination for
this rulemaking, and DOE does not need to prepare an Environmental
Assessment or Environmental Impact Statement for this rule. DOE's CX
determination for this rule is available at http://energy.gov/nepa/categorical-exclusion-cx-determinations-cx.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on Federal agencies formulating and
implementing policies or regulations that preempt
[[Page 5741]]
State law or that have Federalism implications. The Executive Order
requires agencies to examine the constitutional and statutory authority
supporting any action that would limit the policymaking discretion of
the States and to carefully assess the necessity for such actions. The
Executive Order also requires agencies to have an accountable process
to ensure meaningful and timely input by State and local officials in
the development of regulatory policies that have Federalism
implications. On March 14, 2000, DOE published a statement of policy
describing the intergovernmental consultation process it will follow in
the development of such regulations. 65 FR 13735.
DOE understands that publication of this direct final rule will
preempt certain California Energy Commission regulations governing
energy efficiency requirements for pool pumps. In accordance with
Executive Order 13132, DOE has examined this rule and has determined
that it would not have a substantial direct effect on any States,
including California, on the relationship between the national
government and the States, or on the distribution of power and
responsibilities among the various levels of government. EPCA governs
and prescribes Federal preemption of State regulations as to energy
conservation for the products, including DPPP, that are the subject of
this direct final rule. Additionally, DOE solicited and received
comments from the California Energy Commission, which are reflected in
this rulemaking. Finally, States, including California, can petition
DOE for exemption from such preemption to the extent, and based on
criteria, set forth in EPCA. (42 U.S.C. 6297) Therefore, no further
action is required by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on Federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity, (2) write regulations to minimize litigation, (3)
provide a clear legal standard for affected conduct rather than a
general standard, and (4) promote simplification and burden reduction.
61 FR 4729 (Feb. 7, 1996). Regarding the review required by section
3(a), section 3(b) of Executive Order 12988 specifically requires that
Executive agencies make every reasonable effort to ensure that the
regulation (1) clearly specifies the preemptive effect, if any, (2)
clearly specifies any effect on existing Federal law or regulation, (3)
provides a clear legal standard for affected conduct while promoting
simplification and burden reduction, (4) specifies the retroactive
effect, if any, (5) adequately defines key terms, and (6) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in section 3(a) and section 3(b) to
determine whether they are met or it is unreasonable to meet one or
more of them. DOE has completed the required review and determined
that, to the extent permitted by law, this direct final rule meets the
relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. (2 U.S.C. 1531) For a regulatory action likely to
result in a rule that may cause the expenditure by State, local, and
Tribal governments, in the aggregate, or by the private sector of $100
million or more in any one year (adjusted annually for inflation),
section 202 of UMRA requires a Federal agency to publish a written
statement that estimates the resulting costs, benefits, and other
effects on the national economy. (2 U.S.C. 1532(a), (b)) The UMRA also
requires a Federal agency to develop an effective process to permit
timely input by elected officers of State, local, and Tribal
governments on a ``significant intergovernmental mandate,'' and
requires an agency plan for giving notice and opportunity for timely
input to potentially affected small governments before establishing any
requirements that might significantly or uniquely affect them. On March
18, 1997, DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. DOE's policy
statement is also available at http://energy.gov/sites/prod/files/gcprod/documents/umra_97.pdf.
DOE has concluded that this direct final rule may require
expenditures of $100 million or more in any one year by the private
sector. Such expenditures may include (1) investment in research and
development and in capital expenditures by pool pump manufacturers in
the years between the direct final rule and the compliance date for the
new standards and (2) incremental additional expenditures by consumers
to purchase higher-efficiency pool pumps, starting at the compliance
date for the applicable standard.
Section 202 of UMRA authorizes a Federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the direct final rule. (2 U.S.C. 1532(c)) The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of this document and the TSD for this
direct final rule respond to those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. (2 U.S.C. 1535(a)) DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the rule unless DOE publishes an
explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C. 6295(m)
and 6316(a), this direct final rule establishes energy conservation
standards for pumps that are designed to achieve the maximum
improvement in energy efficiency that DOE has determined to be both
technologically feasible and economically justified, as required by
6295(o)(2)(A), 6295(o)(3)(B) and 6316(a)). A full discussion of the
alternatives considered by DOE is presented in chapter [17] of the TSD
for this direct final rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
Pursuant to Executive Order 12630, ``Governmental Actions and
Interference with Constitutionally Protected Property Rights,'' 53 FR
8859 (March 18, 1988), DOE has determined that this rule
[[Page 5742]]
would not result in any takings that might require compensation under
the Fifth Amendment to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for Federal agencies to
review most disseminations of information to the public under
information quality guidelines established by each agency pursuant to
general guidelines issued by OMB. OMB's guidelines were published at 67
FR 8452 (Feb. 22, 2002), and DOE's guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed this direct final rule under the
OMB and DOE guidelines and has concluded that it is consistent with
applicable policies in those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OIRA
at OMB, a Statement of Energy Effects for any significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgates or is expected to lead to promulgation of a
direct final rule, and that (1) is a significant regulatory action
under Executive Order 12866, or any successor order; and (2) is likely
to have a significant adverse effect on the supply, distribution, or
use of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any significant energy action, the
agency must give a detailed statement of any adverse effects on energy
supply, distribution, or use should the proposal be implemented, and of
reasonable alternatives to the action and their expected benefits on
energy supply, distribution, and use.
DOE has concluded that this regulatory action, which sets forth
energy conservation standards for pool pumps, is not a significant
energy action because the standards are not likely to have a
significant adverse effect on the supply, distribution, or use of
energy, nor has it been designated as such by the Administrator at
OIRA. Accordingly, DOE has not prepared a Statement of Energy Effects
on this direct final rule.
L. Information Quality
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as ``scientific information
the agency reasonably can determine will have, or does have, a clear
and substantial impact on important public policies or private sector
decisions.'' Id at FR 2667.
In response to OMB's Bulletin, DOE conducted formal peer reviews of
the energy conservation standards development process and the analyses
that are typically used and prepared a report describing that peer
review.\143\ Generation of this report involved a rigorous, formal, and
documented evaluation using objective criteria and qualified and
independent reviewers to make a judgment as to the technical/
scientific/business merit, the actual or anticipated results, and the
productivity and management effectiveness of programs and/or projects.
DOE has determined that the peer-reviewed analytical process continues
to reflect current practice, and the Department followed that process
for developing energy conservation standards in the case of the present
rulemaking.
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\143\ The 2007 ``Energy Conservation Standards Rulemaking Peer
Review Report'' is available at the following Web site: http://energy.gov/eere/buildings/downloads/energy-conservation-standards-rulemaking-peer-review-report-0.
---------------------------------------------------------------------------
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of this rule prior to its effective date. The report will
state that it has been determined that the rule is a ``major rule'' as
defined by 5 U.S.C. 804(2).
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this direct
final rule.
List of Subjects in 10 CFR Part 431
Administrative practice and procedure, Confidential business
information, Energy conservation, Imports, Intergovernmental relations,
Small businesses.
Issued in Washington, DC, on December 23, 2016.
David J. Friedman,
Acting Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons set forth in the preamble, DOE amends part 431 of
chapter II, subchapter D, of title 10 of the Code of Federal
Regulations, as set forth below:
PART 431--ENERGY EFFICIENCY PROGRAM FOR CERTAIN COMMERCIAL AND
INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 431 continues to read as follows:
Authority: 42 U.S.C. 6291-6317; 28 U.S.C. 2461 note.
0
2. Section 431.462 is amended by adding the definition for ``pool pump
timer'' in alphabetical order to read as follows:
Sec. 431.462 Definitions.
* * * * *
Pool pump timer means a pool pump control that automatically turns
off a dedicated-purpose pool pump after a run-time of no longer than 10
hours.
* * * * *
0
3. Section 431.465 is amended by adding paragraphs (e), (f), (g) and
(h) to read as follows:
Sec. 431.465 Pumps energy conservation standards and their compliance
dates.
* * * * *
(e) For the purposes of paragraph (f) of this section, ``WEF''
means the weighted energy factor and ``hhp'' means the rated hydraulic
horsepower, as determined in accordance with the test procedure in
Sec. 431.464(b) and applicable sampling plans in Sec. 429.59 of this
chapter.
(f) Each dedicated-purpose pool pump that is not a submersible pump
and is manufactured starting on July 19, 2021 must have a WEF rating
that is not less than the value calculated from the following table:
[[Page 5743]]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Equipment class Minimum allowable WEF score Minimum allowable WEF score
------------------------------------------------------------------------------------------- [kgal/kWh] [kgal/kWh]
-------------------------------------------------------------
Dedicated-purpose pool pump variety hhp Applicability Motor phase
--------------------------------------------------------------------------------------------------------------------------------------------------------
Self-priming pool filter pumps........ 0.711 hp <=hhp <2.5 hp............................ Single....................... WEF = -2.30 * ln (hhp) +
6.59.
Self-priming pool filter pumps........ hhp <0.711 hp..................................... Single....................... WEF = 5.55, for hhp <=0.13 hp
-1.30 * ln (hhp) + 2.90, for
hhp >0.13 hp.
Non-self-priming pool filter pumps.... hhp <2.5 hp....................................... Any.......................... WEF = 4.60, for hhp <=0.13 hp
-0.85 * ln (hhp) + 2.87, for
hhp >0.13 hp.
Pressure cleaner booster pumps........ Any............................................... Any.......................... WEF = 0.42.
--------------------------------------------------------------------------------------------------------------------------------------------------------
(g) Each integral cartridge filter pool pump and integral sand
filter pool pump that is manufactured starting on July 19, 2021 must be
distributed in commerce with a pool pump timer that is either integral
to the pump or a separate component that is shipped with the pump.
(h) For all dedicated-purpose pool pumps distributed in commerce
with freeze protection controls, the pump must be shipped with freeze
protection disabled or with the following default, user-adjustable
settings:
(1) The default dry-bulb air temperature setting is no greater than
40 [deg]F;
(2) The default run time setting shall be no greater than 1 hour
(before the temperature is rechecked); and
(3) The default motor speed shall not be more than \1/2\ of the
maximum available speed.
[FR Doc. 2016-31666 Filed 1-17-17; 8:45 am]
BILLING CODE 6450-01-P