[Federal Register Volume 84, Number 130 (Monday, July 8, 2019)]
[Notices]
[Pages 32437-32445]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-14462]
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DEPARTMENT OF ENERGY
[EERE-2019-BT-PET-0019]
Energy Efficiency Program for Industrial Equipment: Petition of
North Carolina Advanced Energy Corporation Efficiency Verification
Services for Classification as a Nationally Recognized Certification
Program for Electric Motors and Small Electric Motors
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of petition and request for public comments.
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SUMMARY: This notice announces receipt of a petition from North
Carolina Advanced Energy Corporation Efficiency Verification Services
seeking classification as a nationally recognized certification
program. The petition, which appears at the end of this notice,
includes documentation to help substantiate company's position that its
certification program for electric motors and small electric motors
satisfies the evaluation criteria for classification as a nationally
recognized certification program. This notice summarizes the
substantive aspects of these documents and requests public comments on
the merits of the petition.
DATES: DOE will accept comments, data, and information with respect to
the Advanced Energy Petition until August 7, 2019.
ADDRESSES: You may submit comments, identified by docket number ``EERE-
2019-BT-PET-0019,'' by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov. Follow the
instructions for submitting comments.
Email: [email protected] Include the
docket number and/or RIN in the subject line of the message.
Postal Mail: Appliance and Equipment Standards Program, U.S.
Department of Energy, Building Technologies Office, Mailstop EE-5B,
1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone:
(202) 287-1445. If possible, please submit all items on a compact disc
(``CD''), in which case it is not necessary to include printed copies.
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting written comments and additional information
on the rulemaking process, see section V of this document (Public
Participation).
Hand Delivery/Courier: Appliance and Equipment Standards Program,
U.S. Department of Energy, Building Technologies Office, 950 L'Enfant
Plaza SW, Suite 600, Washington, DC 20024. Telephone: (202) 287-1445.
If possible, please submit all items on a CD, in which case it is not
necessary to include printed copies.
Docket: For access to the docket to review the background documents
relevant to this matter, you may visit the U.S. Department of Energy,
950 L'Enfant Plaza SW, Washington, DC 20024; (202) 586-2945, between
9:00 a.m. and 4:00 p.m., Monday through Friday, except Federal
holidays. Please call Ms. Brenda Edwards at the above telephone number
for additional information.
FOR FURTHER INFORMATION CONTACT: Mr. Jeremy Dommu, U.S. Department of
Energy, Building Technologies Program, EE-5B, 1000 Independence Avenue
SW, Washington, DC 20585-0121. Telephone: (202) 586-9870. Email:
[email protected].
Mr. Michael Kido, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0103.
Telephone: (202) 586-8145. Email: [email protected].
For further information on how to submit a comment, review other
public comments and the docket, or to request a public meeting, contact
the Appliance and Equipment Standards Program staff at (202) 287-1445
or by email: [email protected].
SUPPLEMENTARY INFORMATION:
I. Background and Authority
Part C of Title III of the Energy Policy and Conservation Act
contains energy conservation requirements for, among other things,
electric motors and small electric motors, including test procedures,
energy efficiency standards, and compliance certification requirements.
42 U.S.C. 6311-6316.\1\ Section 345(c) of EPCA directs the Secretary of
Energy to require manufacturers of electric motors ``to certify through
an independent testing or certification program nationally recognized
in the United States, that [each electric motor subject to EPCA
efficiency standards] meets the applicable standard.'' 42 U.S.C.
6316(c). The United States Department of Energy (``DOE'' or, in
context, ``the Department'') codified this requirement at 10 CFR
431.17(a)(5). DOE also established certain compliance testing
requirements for manufacturers of small electric motors. 77 FR 26608
(May 4, 2012) Manufacturers of small electric motors have the option of
self-certifying the efficiency of their small electric motor using a
certification program nationally recognized in the U.S to certify the
efficiency of these motors. (10 CFR 431.445) DOE developed a regulatory
process for the recognition, and withdrawal of recognition, for
certification programs nationally recognized in the U.S. The criteria
and procedures for national recognition of an energy efficiency
certification program for electric motors are codified at 10 CFR
431.20--10 CFR 431.21 for electric motors and at 10 CFR 431.447--10 CFR
431.448 for small electric motors. Each step of the process and
evaluation criteria are discussed below.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
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For a certification program to be classified by DOE as being
nationally recognized in the United States for the testing and
certification of electric motors and small electric motors, the
organization operating the program must submit a petition to the
Department requesting such classification, in accordance with
aforementioned sections.
[[Page 32438]]
For the Department to grant such a petition, the petitioner's
certification program must:
(1) Have satisfactory standards and procedures for conducting and
administering a certification system, and for granting a certificate of
conformity;
(2) Be independent of electric motor and small electric motor
manufacturers (as applicable), importers, distributors, private
labelers or vendors;
(3) Be qualified to operate a certification system in a highly
competent manner; and
(4) Be expert in the following test procedures and methodologies:
(a) For electric motors it must be expert in the content and
application of the test procedures and methodologies in IEEE Std 112-
2004 Test Method B or CSA C390-10. It must have satisfactory criteria
and procedures for the selection and sampling of electric motors tested
for energy efficiency. (10 CFR 431.20(b)); and
(b) For small electric motors it must be expert in the content and
application of the test procedures and methodologies in IEEE Std 112-
2004 Test Methods A and B, IEEE Std 114-2010, CSA C390-10, and CSA
C747, or similar procedures and methodologies for determining the
energy efficiency of small electric motors. It must have satisfactory
criteria and procedures for the selection and sampling of electric
motors tested for energy efficiency. (10 CFR 431.447(b))
The petition requesting classification as a nationally recognized
certification program must contain a narrative statement explaining why
the organization meets the above criteria, be accompanied by
documentation that supports the narrative statement, and be signed by
an authorized representative. (10 CFR 431.20(c), and 10 CFR
431.447(c)).
II. Discussion
Pursuant to sections 431.20, 431.21, 431.447 and 431.448, on
February 11, 2019, North Carolina Advanced Energy Corporation
Efficiency Verification Services (``Advanced Energy'') submitted to DOE
a Petition for Recognition related to the group's motor efficiency
verification services. That petition, titled, ``Energy Efficiency
Evaluation of Electric Motors and Small Electric Motors to US
Department of Energy Regulations as stipulated in 10 CFR part 431,
subpart B and Subpart X'' (``Petition'' or ``Advanced Energy
Petition''), was accompanied by a cover letter from Advanced Energy to
the Department containing four separate sections including individual
narrative statements--(1) Standards and Procedures, (2) Independent
Status, (3) Qualification of Advanced Energy to Operate a Certification
System, and (4) Expertise in Electric Motor Test Procedures. The
petition included supporting documentation on these subjects. The
Department is required to publish in the Federal Register such
petitions for public notice and solicitation of comments, data and
information as to whether the Petition should be granted. 10 CFR
431.21(b) and 10 CFR 431.448(b). A copy of Advanced Energy's petition
and accompanying cover letter have been placed in the docket.
The Department hereby solicits comments, data and information on
whether it should grant the Advanced Energy Petition. 10 CFR 431.21(b)
and 10 CFR 431.448(b). Any person submitting written comments to DOE
with respect to the Advanced Energy Petition must also, at the same
time, send a copy of such comments to Advanced Energy. As provided
under Sec. Sec. 431.21(c) and 431.448(c), Advanced Energy may submit
to the Department a written response to any such comments. After
receiving any such comments and responses, the Department will issue an
interim and then a final determination on the Advanced Energy Petition,
in accordance with Sec. 431.21(d) and (e), and Sec. 431.448(d) and
(e) of 10 CFR part 431.
In particular, the Department is interested in obtaining comments,
data, and information respecting the following evaluation criteria:
(1) Whether Advanced Energy has satisfactory standards and
procedures for conducting and administering a certification system,
including periodic follow up activities to assure that basic models of
electric motors and small electric motors continue to conform to the
efficiency levels for which they were certified, and for granting a
certificate of conformity. DOE is also interested in obtaining comments
as to how rigorously Advanced Energy operates its certification system
under the guidelines contained in ISO/IEC Guide 65, General
requirements for bodies operating product certification systems.
(2) Whether Advanced Energy is independent of electric motor and
small electric motor manufacturers, importers, distributors, private
labelers or vendors. To meet this requirement, it cannot be affiliated
with, have financial ties with, be controlled by, or be under common
control with any such entity.
(3) Whether Advanced Energy is expert in the content and
application of the test procedures and methodologies for both electric
motors and small electric motors. Specifically, for electric motors,
that Advanced Energy is expert in the content and application of the
test procedures and methodologies IEEE Std 112-2004 Test Method B or
CSA C390-10. (See 10 CFR 431.20(c)(4)). And, for small electric motors,
that Advanced Energy is expert in the content and application of the
test procedures and methodologies IEEE Std 112-2004, Test Methods A and
B, IEEE Std 114-2010, CSA C390-10, and CSA C747 and with similar
procedures and methodologies. (See 10 CFR 431.447(c)(4)).
(4) DOE is also interested in receiving comments on whether
Advanced Energy's criteria and procedures are satisfactory for the
selection and sampling of electric motors and small electric motors
tested for energy efficiency.
Signed in Washington, DC, on June 28, 2019.
Alexander N. Fitzsimmons,
Acting Deputy Assistant Secretary for Energy Efficiency, Energy
Efficiency and Renewable Energy.
Petition for Recognition
Energy Efficiency Evaluation of Electric Motors to United States
Department of Energy
Requirements as Documented in 10 CFR part 431--Subpart B and Subpart X
State of NORTH CAROLINA
SS: County of WAKE
Before me, the undersigned notary public, this day, personally,
appeared Brian Coble to me known, who being duly sworn according to
law, deposes the following:
/s/ Brian Coble Subscribed and sworn to before me this 12 day of
February 2019.
/s/ Terri Bowling, Notary Public
Petition for Recognition
Advanced Energy Motor Efficiency Verification Services
[GRAPHIC] [TIFF OMITTED] TN08JY19.002
Energy Efficiency Evaluation of Electric Motors and Small Electric
Motors to US Department of Energy Regulations as stipulated in 10 CFR
431--Subpart B and Subpart X
State:-----------------------------------------------------------------
County:----------------------------------------------------------------
Before me the undersigned notary public, this day personally appeared
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[[Page 32439]]
___who being duly sworn according to law, deposes the following:
On behalf of Advanced Energy
__________ (Signature of Affiant)
Brian Coble, Senior Vice President
Advanced Energy
Subscribed and sworn to before me this ____ day of ______ 20_
My Commission Expires:-------------------------------------------------
Contents
1. Program Criteria Narrative
2. Standards and procedures for conducting and administering a
certification system, and for granting a certificate of conformity
(CONFIDENTIAL)
2.1 Scope of Covered Products
2.2 Summary of Elements of the Certification Program
2.3 Detailed Description of Key Elements of Certification
Program
2.3.1 Application (APP)
2.3.2 Initial Product Evaluation (EVAL)
2.3.3 Test Facility Evaluation (TFE)
2.3.4 Sample Selection (SAMP)
2.3.5 Motor Build Inspection Analysis and Construction
Evaluation (MBIA)
2.3.6 Initial Certification Testing (ICT)
2.3.7 On-Going Production Testing (OGT)
2.3.8 Follow-Up Visits and Testing (FUV)
2.3.9 Non-Conformance (NCF)
2.3.10 File Review (REVIEW)
2.3.11 Certification Decision (CERT)
3. Qualifications of Advanced Energy to Certify Motors and its
Expertise in Test Procedures
3.1 Introduction
3.2 Summary of Advanced Energy Qualifications
3.3 Advanced Energy's Experience with Certification Matters
4. Independent Status of Advanced Energy
5. APPENDICES
5.1 Accreditation Certificate from ANSI
5.2 Accreditation Certificate from NVLAP
5.3 Accreditation Certificate from NOM?
5.4 Form 103
1. Program Criteria Narrative
This document is a petition for the recognition, by US Department
of Energy (DOE), of North Carolina Advanced Energy Corporation
(Advanced Energy) Efficiency Verification Services as a nationally
recognized certification program for certifying electric motors to the
DOE standards currently in effect in the United States.
North Carolina Advanced Energy Corporation (Advanced Energy) has
been operating as an independent electric motor efficiency testing
facility since 1989. In 1992 Advanced Energy began working with the
U.S. Department of Energy (DOE) and many other public stakeholders in
the Notice of Proposed Rule (NOPR) making process for motor efficiency.
Our test facility provides motor efficiency testing to various
entities, including subcontractors of DOE, motor manufacturers, motor
distributors, motor service centers, motor end users, motor inventors
and others. Advanced Energy has tested thousands of motors for
efficiency.
Below is our summarized responses to each of the four DOE
evaluation criteria. Detailed response can be found in subsequent
sections of the document.
(1) It must have satisfactory standards and procedures for
conducting and administering a certification system, including periodic
follow up activities to assure that basic models of electric motor
continue to conform to the efficiency levels for which they were
certified, and for granting a certificate of conformity.
Advanced Energy's test lab has been ISO 17025 certified since 1997.
ISO 17025 ensures our lab strictly follows standards and adheres to
procedures to ensure quality. Our lab has been audited annually by the
National Institute of Standards and Technology since 1997. In addition
our lab is audited for motor efficiency testing by Asociacion Nacional
de Normalizacion y Certification (ANCE). We have other programs and
clients in our lab often requiring a review of our records. As a result
we are expert in how motor labs should be audited for motor efficiency
testing.
Advanced Energy's test lab recently added ISO 17065 for electric
motor efficiency certification by the American National Standards
Institute (ANSI). ISO 17065 ensures Advanced Energy's has satisfactory
standards and procedures for conducting and administering a
certification system. Our processes for motor efficiency certification,
including periodic follow up activities to assure basic models conform
to prescribed efficiency levels, are clearly defined in our required
ANSI scheme. As our ANSI scheme represent our services for motor
efficiency certification we provide the full scheme in a section marked
``confidential''. As a result of our ISO 17065 certification we have
established and registered a mark with the US Patents and Trademark
Office (mark is noted on the cover page) and we are capable of issuing
a certificate of conformity for electric motor efficiency.
Advanced Energy has well established standards and procedures in
place for administering Certification programs. The company currently
operates several Certification programs relating to multiple products,
such as residential affordable homes, HVAC Contractor systems, Solar
Installations and Electric Motor Repair. These are described under item
(3) below.
(2) It must be independent of electric motor manufacturers,
importers, distributors, private labelers or vendors. It cannot be
affiliated with, have financial ties with, be controlled by, or be
under common control with any such entity.
Advanced Energy is 501 (c) 3 corporation chartered in North
Carolina by the North Carolina Utilities Commission in 1980, to fulfil
the mission for which it was established. Our Board of Directors
comprises public members appointed by the sitting Governor and our
electric utility members in North Carolina. Advanced Energy is a
nonprofit energy services and engineering firm working with electric
utilities, government agencies, public and private organizations to
provide research, testing, training, consulting and program design
services in the residential, commercial and industrial sectors markets.
Our vision is to ensure energy is clean, affordable, reliable,
efficient, and safe for all people.
While Advanced Energy regularly tests electric motors and small
electric motors for all of the client categories noted at the beginning
of this narrative, Advanced Energy does not have any affiliation,
financial or otherwise with any of its clients. Advanced Energy is
solely controlled by its Management and Board of Directors.
(3) It must be qualified to operate a certification system in a
highly competent manner.
Advanced Energy has offered accreditation services to the motor
repair industry since 2000. Our Proven Efficiency Verification program
requires site audits of the motor service center and annual testing to
prove motor repair processes are not degrading efficiency. We are also
one of four Electrical Apparatus Service Association auditors for the
EASA Accreditation program for electric motor repair.
Advanced Energy has operated a HVAC contractor Certification
program launched in 2012. Our certification services for HVAC
contractors was developed in response to and as a requirement of the
Environmental Protection Agency (EPA)'s Energy Star New Homes Program--
HQUITO. Our program serves to not only help HVAC contractors become
Certified in the ENERGY STAR program, but also supports their growth
and success with technical assistance and best-in-class training and
resources.
SystemVision\TM\ is an Advanced Energy Certification Program for
affordable homes whereby homes that are built to Advanced Energy's
specifications are guaranteed a specific heating and cooling energy
consumption at a specified comfort
[[Page 32440]]
level. SystemVision\TM\ Certified homes that have their heating and
cooling expenditure above the pre-set threshold are reimbursed by the
program. Advanced Energy provides the training and technical support
that helps affordable housing market players in the design,
construction and certification of energy-efficient affordable homes.
The SystemVision\TM\ homes are reputed to contribute to improved
health, safety, durability, comfort and energy efficiency in the state
of North Carolina.
(4) It must be expert in the content and application of the test
procedures and methodologies in IEEE Std. 112-2004 Test Method B or CSA
C390-10, (incorporated by reference, see Sec. 431.15). It must have
satisfactory criteria and procedures for the selection and sampling of
electric motors tested for energy efficiency
Advanced Energy Motor Engineers actively participate in motor and
drive test standard development with IEEE, CSA, and IEC. We not only
conduct these tests daily, our staff contributes to the development of
these standards and others recognized in 10 CFR 431.15 including IEEE
114, IEEE 112 Method A, IEC 60034-2-1, IEC 61800-9-2 and many others.
Our many years of experience operating our ISO 17025 test lab,
participating on standard setting committees, and participation in
DOE's NOPR process make us experts in the content and application of
all prescribed test procedures and methodologies incorporated in 10 CFR
part 431.15.
Advanced Energy utilizes a simple random number generator process
for test sample selection when advising clients requiring random model
selection. In addition we test drives for the Air Condition Heating and
Refrigeration Institute's (AHRI) variable frequency drive certification
program, partnering with Underwriters Laboratories (UL), where samples
are selected at sites randomly and shipped to our lab for testing.
2. Standards and procedures for conducting and administering a
certification system, and for granting a certificate of conformity
(CONFIDENTIAL)
2.1 Scope of Covered Products
DOE's Energy Efficiency Regulations cover certain electric motors
and small motors.
Electric motors manufactured and distributed in commerce, as defined by
42 U.S.C. 6311(7), must meet the energy conservation standards
specified in the Code of Federal Regulations at 10 CFR 431.25 through
431.26
Small electric motors manufactured and distributed in commerce, as
defined by 42 U.S.C. 6291(16), must meet the energy conservation
standards specified in the Code of Federal Regulations at 10 CFR
431.446 through 431.448
Detailed provisions are available in the following references:
Electric Motors: https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=6&action=viewlive
Small Motors: https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=7
Electronic Code of Federal Regulations: https://www.ecfr.gov/cgi-bin/retrieveECFR?n=pt10.3.431
2.2 Summary of Elements of the Certification Program
The following is a brief overview of the major elements of Advanced
Energy's (AE) Motor Energy Efficiency Certification Service used for
qualifying manufacturers' motors. Detailed descriptions of the items
below are provided in section 2.3.
Application
Customer requests motor energy efficiency certification service
through an application. The application is evaluated. A Motor
Efficiency Verification Services Agreement shall be executed by both
sides.
Initial Product Evaluation
At this stage the Applicant's product is evaluated. The AE staff
requests pertinent information to that will be required in order to
properly evaluate the product for compliance. The AE personnel will
request all data that will help to properly evaluate the product
including information about the manufacturer's production and test
facilities used to manufacture and characterize the product.
Test Facility Evaluation
A client utilizing AE's certification services for motor efficiency
may or may not utilize AEs lab for testing. For the purposes of
ensuring that test facilities meet the highest standard required to
ensure confidence in test result, all test facilities will be evaluated
by Advanced Energy for conformance to ISO/IEC 17025 Standard (see
details in Section 3 (TFE)).
Sample Selection
Manufacturer would provide to AE, a list of all covered motors that
it manufacturers. Representative samples from the manufacturer's
production line or stock are selected by AE's engineering staff for
testing subsequent to evaluation and certification (see below).
Motor Build and Construction Evaluation
While sample testing provides a good indication of performance of
samples at a point in time, Advanced Energy is capable of
comprehensively evaluating the physical product to assess the
manufacturer's design and construction philosophy in general and to a
lesser extent, consistency between the electromagnetic design and test
results. The manufacturer's motor design and construction will be
evaluated to identify the critical design decisions and construction
features that would affect its energy efficiency performance.
Initial Certification Testing
The samples selected per DOE sampling guidelines will be tested in
an approved facility according to DOE test procedures and the results
are evaluated in order to determine compliance.
On-Going Production Testing
After the initial certification, ongoing production testing will be
required for continued compliance verification. Manufacturers will test
samples of their products as part of their ongoing production
procedures to determine continued compliance with the energy efficiency
requirements. The results of the ongoing tests will be reviewed by AE.
Follow-Up Visits and Testing
AE staff would reserve the right to conduct follow up visits to
manufacturer's facilities for random inspections to check compliance of
production issues or test lab's ability to perform accurate testing of
products.
Non-Conformance
For non-conforming test results found during testing at the
manufacturer's own or other qualified test facilities, or any other
forms of non-conformance Advanced Energy will apply its procedures to
resolve the non-conformity of the applicant.
File Review
A Reviewer shall be appointed to review the work of the Evaluator.
This is a critical step that precedes the Certification decision. In
line with the ISO/IEC 17065 Guidelines, the Evaluator shall not serve
as the Reviewer.
Certification Decision
Certification decision shall follow Evaluation and Review. After
[[Page 32441]]
determination that the motors meet the applicable standards, through
the key activities of the preceding steps, the applicant is formally
notified that the energy efficiency of their motors is duly verified
and in compliance and is issued a Certificate of Conformity by AE.
Follow Up Service (FUS) Agreement
Advanced Energy and the manufacturer or Applicant will enter into a
follow-up services agreement in conformity to ISO/IEC 17065.
2.3 Detailed Description of Key Elements of Certification Program
2.3.1 Application (APP)
The customer applies for motor energy efficiency verification and
certification service. The application is made available to download
online at the Advanced Energy website. Upon receipt of the application,
AE will assign a qualified staff member to be responsible for handling
the project. A Motor Efficiency Verification Services Agreement (also
known as ``Advanced Energy Motor Efficiency Certification Services--
Terms of Service'') shall be sent to the customer and shall be executed
by both sides. A project initiation checklist (Form 101) shall be
invoked after the execution of the necessary agreements. The assigned
staff member will also serve as the Evaluator and proceed with the
initial product evaluation steps and other subsequent steps as laid out
below. At the time of appointment of an Evaluator, a File Reviewer will
be designated. The Evaluator and File Reviewer shall NOT be the same
person.
2.3.2 Initial Product Evaluation (EVAL)
As part of the Initial Product Evaluation, the following
information is obtained by the Evaluator prior to and/or during the
initial visit (if required) to the manufacturer's or applicant's
facilities for the purposes of the test facility evaluation step
(discussed below):
(a) Description of the products being submitted by basic
specification such as type, brand name, model designations or model
number, frame, poles or speed, rated voltage, phase, efficiency and any
other pertinent information specific to the products.
(b) Design data and Alternative Efficiency Determination data and
description of AEDM methods.
(c) Test data and information on energy consumption, and product
test methods applied, test conditions, test reports, declaration and
proof that the tests for the products being submitted were conducted in
accordance with the applicable DOE test standards and information on
the test facilities used to obtain the test data.
(d) Description of test facility, list of major equipment and test
facility layout such as power supply, autotransformer, loading device,
ambient control; list of instrumentation and calibration records and
practices, measurement accuracy of instruments used in making
measurements; with particular emphasis on torque, speed, electrical
power, temperature instrumentation, and Accreditation if applicable.
(e) Information on the product design and construction, including
the critical product features which would affect product energy
efficiency performance. Information on quality control practices and
parameters which must be controlled by the manufacturer in order to
maintain a consistent product performance.
2.3.3 Test Facility Evaluation (TFE)
Advanced Energy Motor Efficiency Certification Service may use AE's
lab, manufacturers' lab or other test facilities approved by AE for
conducting testing (lab selection process is done using Form 103 Flow
Chart).
The use of a manufacturer's test facility or other facility to
conduct testing upon which Advanced Energy Motor Efficiency
Certification service can be based, is contingent upon an evaluation
conducted by Advanced Energy of the test facilities, equipment and
competence of personnel conducting the testing and overall competency
and capability of the facility to test motors to applicable DOE test
procedures while complying with requirements of ISO/IEC 17025. The test
facility used for conducting the tests shall be either ISO/IEC 17025
accredited or shall be evaluated for conformance to ISO/IEC 17025
standard by Advanced Energy using NIST Handbook 150 checklist and NIST
Handbook 150-10 Checklist. The Evaluator shall follow Advanced Energy's
Form 103 flow chart for determining the test facility where testing can
be conducted for Certification purposes.
Advanced Energy's evaluation of test facility (or Facility
Evaluation) may include at least two of the following:
Lab document and management system review
Site visit for lab audit and witness testing
Inter-lab test comparison
Annual re-verification
The initial lab document review of test facility may include but
not limited to, review of documents pertaining to equipment
(specifications), calibration records, test lab layout, wiring and
specifications, equipment accuracy and tolerances, past test reports,
operating manuals, and quality system.
If a site visit is required as part of the Facility evaluation, it
will involve Advanced Energy visiting the Client's lab to witness
physical resources of the facility, general lab practices, the lab
setup and equipment, calibration practices and calibration records,
operational practices, setup and testing of motors (used to further
evaluate the equipment), documentation and control of data, processing
of test data, calculations and general assessment of engineering
competence of lab staff. It is expected during this trip that data from
benchmark motors tested in the Client's lab in the presence of Advanced
Energy will be subjected to calculation of efficiency by both the lab
and simultaneously and independently by AE. The results of this
calculation comparison on same set of motors will highlight areas, if
any, that needs attention in the Client's lab. During this visit the
detailed evaluation of the calibration procedures and techniques are
performed that are critical to obtaining the required accuracy of +\-
0.2%. Advanced Energy staff will use personal observation and face to
face communication during the visit to ensure that the Client's lab is
suited to perform efficiency testing accurately.
If inter-lab testing is required as part of the Facility
evaluation, AE will require the Client to supply three motors for
comparison (benchmark) testing to be shipped to Advanced Energy's lab
for testing. These same motors will be shipped back to the Client's
facility for subsequent testing and the inter-lab results will be
compared. Advanced Energy will specify the three motors based on the
equipment list (dynamometers sizes and ranges) such that all equipment
is evaluated equally. Benchmarking test results between Advanced
Energy's NVLAP accredited lab and Client's lab will provide a strong
indication of the relative accuracy of the Client's lab and can be used
as a guide for lab evaluation.
If an annual reverification is included as part of the Client
Facility evaluation it will take the form of one or more of the
following: subsequent site visit, lab document review, inter-lab test
comparison, as previously described.
2.3.4 Sample Selection (SAMP)
Manufacturer would provide a list of all covered motors that it
manufacturers to AE. Representative samples from the manufacturer's
production line or stock are selected by AE's engineering staff for
[[Page 32442]]
testing, subsequent to evaluation and certification. The main objective
in sampling is to ensure that the motors meet the applicable energy
efficiency standard with high confidence while reducing testing burden.
The sampling plan that is adopted by AE shall follow the requirements
of 10 CFR part 431 and statutory revisions applicable at the time of
application.
From Advanced Energy's experience, most manufacturers use an
Alternative Efficiency Determination Method (AEDM) for larger
populations of covered product. If the manufacturer uses an AEDM,
information of the AEDM would be submitted and evaluated at the initial
product evaluation stage (EVAL). AEDM information shall again be
reviewed during sample selection. Following 10 CFR 431, there shall be
5 samples of no fewer than 5 motors (25 motors) tested and the
efficiency results compared with the AEDM predicted values according to
the regulations.
The factors to consider, including two of the basic models among
the five basic models, being with the highest unit volumes of
production in the prior year, and basic models being of different
horsepower and frame numbers without duplication, and all other sample
criteria shall be followed strictly.
2.3.5 Motor Build Inspection Analysis and Construction Evaluation
(MBIA)
The manufacturer's motor design and construction is evaluated to
identify the critical design decisions and construction features that
would affect its energy efficiency performance. Advanced Energy has
significant experience in this area. During MBIAs, AE obtains sample
motors from the customer and tears them down and measures and analyzes
critical motor dimensions, such as active stack length, air gap,
lamination thickness, and bearings specifications. The analysis results
in a detailed report with photographs and data tables. The MBIA is non-
destructive and motors are reassembled to their original as received
condition. In addition to the evaluation of motor design and build, the
manufacturer's factory quality assurance procedures in certain areas
that affect the key performance indicators for energy efficiency will
be reviewed. The manufacturer's in-process testing during production
runs will also be reviewed.
2.3.6 Initial Certification Testing (ICT)
The samples selected shall be tested according to 10 CFR part 431
and the test results shall be processed in order to determine
compliance.
Prior to ICT, Advanced Energy would have already evaluated and
qualified a test facility that would be used to obtain the test data.
The qualification would ensure that the lab is capable of performing
testing according to DOE's test procedures. The test facility shall
maintain the most up-to-date data processing sheets to perform tests
according to the relevant standards such as IEEE 112, IEEE 114, CSA
C390, and CSA C747.
Advanced Energy reserve the right to request raw data for any
selected basic model(s) and process same, using data processing sheet
of its own laboratory in order to check the work of the test facility.
The test data and full load efficiency of the sample set shall be
processed in accordance with 10 CFR 431. Non-conformance of test
results for the ICT would be addressed in accordance with 10 CFR431 and
in line with Advanced Energy guidelines.
2.3.7 On-Going Production Testing (OGT)
On-going production testing will be required for continued
compliance verification. These will be carried out in the same
facilities as the ICT or in an approved facility. Manufacturers will
test samples of their products as part of their ongoing production
procedures to determine continued compliance with the energy efficiency
requirements.
The on-going production testing shall include an AEDM subsequent
verification. Statistically valid samples of the manufacturer's
production shall be selected for the subsequent verification of the
AEDM, in line with 10 CFR 431.
The process for review of results of the ongoing tests by AE will
be in similar fashion as the review of the ICT test results.
2.3.8 Follow-Up Visits and Testing (FUV)
Advanced Energy considers it an important goal that manufacturers
using its Certification Services do not relent in their efforts to
ensure that their products meet compliance requirements on an on-going
basis. In order to meet this goal, Advanced Energy would reserve the
right to conduct follow-up visits for inspections to check compliance
of production issues or test facility's ability to perform accurate
testing of products.
One visit may be conducted to a manufacturer's facility each year
to observe that the manufacturers' production and control practices are
consistent with Advanced Energy's expectations and. During this visit,
samples of the product shall also be selected by the Advanced Energy
staff representative and tested by the manufacturer for verification.
Data processing shall follow similar practices as ICT and the test
results are compared to the AEDM generated values. The manufacturer may
use the reported data to meet the requirements of the AEDM subsequent
verification.
2.3.9 Non-Conformance (NCF)
For non-conforming test results found during testing at an approved
test facility, or any other forms of non-conformance, including any
violation or not meeting the conditions of certification, Advanced
Energy shall inform the client of the nonconformities. Advanced Energy
shall provide information regarding additional evaluation tasks that
are needed to verify that all nonconformities have been corrected. If
the client agrees to completion of the additional evaluation tasks, the
process of EVAL shall be repeated to complete the additional evaluation
tasks. The results of all evaluation activities shall be documented for
the purposes of the file REVIEW step.
All such non-conformities will be addressed on a case by case
basis. Options available include but not limited to:
(a) Remove the non-conforming products from consideration
(b) perform comprehensive analysis to determine the cause of non-
conformance, determine remedies, evaluate effectiveness of remedies,
subject to re-evaluation.
2.3.10 File Review (REVIEW)
This is a critical step that precedes the Certification decision
and it is meant to ensure that all the important preceding steps and
requirements are met during the Evaluation of the products for
Certification. An Advanced Energy staff member shall be appointed as a
Reviewer to review the work of the Evaluator and to determine if the
necessary provisions of ISO/IEC 17065 are followed. In line with the
procedures, the Evaluator shall not serve as the Reviewer.
The outcome of the REVIEW is a recommendation. The recommendation
may identify a non-conformity that had been a result of oversight at
the EVAL stage or may have occurred during the period between the EVAL
and REVIEW. Recommendation may also be for a Certification decision.
All recommendations based on the REVIEW shall be documented. It is
acceptable for the review and the certification decision
[[Page 32443]]
to be completed concurrently by the same AE Staff Member.
2.3.11 Certification Decision (CERT)
The project for certifying motors, following the application to
Advanced Energy, Evaluation, Assessment and Qualification of test
facility, testing to DOE Standards, Review and Processing of Data, File
Review and Recommendation for Approval concludes with the issuance of a
Certificate of Conformity by Advanced Energy and subsequent issuance of
a Compliance Certificate number by the US Department of Energy. The
designated AE staff member responsible for the Certification decision
will also be responsible for ensuring that Follow-up surveillance
activities are in place.
2.3.12 Follow-Up Service (FUS) Agreement
Advanced Energy and the Applicant will enter into a follow-up
services agreement. The FUS agreement defines the conditions for
maintaining certification such as access to manufacturing sites,
records, follow-up inspections, product re-testing and AEDM Subsequent
Verification.
3. Qualifications of Advanced Energy To Certify Motors and Its
Expertise in Test Procedures
3.1 Introduction
In 1997, Advanced Energy's motor testing lab became the first motor
lab in the world to be accredited for motor efficiency testing by the
National Institute of Standards and Technology (NIST), under the
National Voluntary Laboratory Accreditation Program (NVLAP Code:
200081-0). It remains the only independent motor lab in North America
to hold this accreditation which makes it uniquely qualified to help
evaluate and validate motors, drives and related products.
Energy efficiency testing is what Advanced Energy is known for
globally. Through the testing services of Advanced Energy, several
motor manufacturers around the globe have been certified to U.S.
Department of Energy (DOE) requirements for motor efficiency through
self-certification. Our testing capabilities apply to a wide variety of
international standards and our knowledge and reputation for accuracy
has helped Advanced Energy to gain the trust of motor manufacturers and
users worldwide, and has enabled us to help manufacturers and users to
validate performance claims and to achieve compliance with US DOE
regulations and government regulations in other jurisdictions.
Specifically, with regard to electric motors (and drives), Advanced
Energy's past activities include:
Testing to US Department of Energy (USDOE) requirements
Testing to Natural Resources of Canada (NRCan) requirements
Testing to IEEE Standards and other International standards
Testing to International Electro technical Commission (IEC)
requirements
Testing to NOM (Mexico) Standards and requirements
Testing to AHRI standards
Engineering Services to Develop Electric Motor Labs around the
world
Certification of motor energy efficiency and performance for
global R&D Companies, inventers and product developers
Engineering Services for Motor Designers and Application
Customers
Performance of Motor Build and Inspection Analysis (MBIA)
Development of Technical Standards for Motor Testing
Applied Research on Motor Design, Application and Testing
Research in collaboration with utilities on the effect of
electric power quality and smart grid on electric motors
Reliability testing of Motors for OEM Equipment
The bulk of Advanced Energy motors related work is carried out in
its state-of-the-art motor test laboratory. The laboratory has
maintained an ISO/IEC 17025 accreditation since 1997 through NIST/
NVLAP. The lab has also maintained a NOM designation through ANCE, the
first laboratory outside Mexico to gain such designation. From 2010 to
2014 the laboratory participated in UL's data acceptance program and
has worked closely with UL to test motors intended for certification
for UL clients. The laboratory has also in the past assisted CSA to
certify motors for its clients, following a witness by CSA staff.
Advanced Energy's Motor Efficiency Verification Services program is
an ISO/IEC Guide 17065 compliant program that is subjected to ANSI
accreditation as evidenced by the issuance of accreditation by this
august body (see Appendix).
The certification of motors under AE's Motor Energy Efficiency
Certification Service is based upon the satisfactory evaluation and
testing to the requirements of the applicable US DOE standards in
effect in an approved test facility, which is either the AE test
facility, the client's facilities or other facility approved by
Advanced Energy.
3.2 Summary of Advanced Energy Qualifications
(a) Advanced Energy's credentials in the motor efficiency field is
unmatched. The company has been testing motors since 1989 and has
operated an independent test lab since that time. The lab has helped
motor manufacturers, OEMs, utilities and industrial customers since
1989. A Motors and Drives group's history and summary of milestones of
the can be found at: https://www.advancedenergy.org/portal/mad/images/pdf_documents/Motor_History_Timeline_2014.pdf.
(b) Advanced Energy has maintained an ISO/IEC 17025 based
accreditation with NVLAP/NIST for the past 20 years. AE is familiar
with running and operating a quality system. Advanced Energy has
achieved ISO/IEC 17065 product certification accreditation with ANSI
and plans to maintain this accreditation on an ongoing basis. With the
company's strong knowledge of motors, motor testing and DOE rules on
which the Certification is based, Advanced Energy is capable of
operating a program for certifying electric motors and small electric
motors in a highly competent manner.
(c) Advanced Energy has been involved in DOE rulemaking process
since 1992 and has extensive knowledge of the regulations. The company
has actively participated in DOE public meetings for the rule making
process and has contributed white papers and comments to guide the
process since 1992. Several comments provided by Advanced Energy for
the small motors and electric motors rule making are often referenced
in the Code of Federal Regulations publications.
(d) Advanced Energy's motor test lab is globally recognized for its
accuracy in applying the IEEE 112, CSA C390, IEEE 114 and CSA C747
standard that are required for certifying motors. Advanced Energy's lab
has served as a benchmark laboratory for other laboratories to evaluate
their own performance. In this regard, Advanced Energy's test results
was used as the standard to judge other labs' performance. Advanced
Energy has also provided engineering services to several other labs
around the world to enable them achieve ISO/IEC 17025 accreditation
from NVLAP.
(e) Advanced Energy has contributed expertise in developing the
applicable test standards required for the motor tests and is well
familiar with these standards. Advanced Energy staff have been involved
in various capacities to
[[Page 32444]]
develop the IEEE and CSA motor efficiency test standards.
(f) Advanced Energy staff members frequently serve as subject
matter expertise on motors in several national and international
forums. Staff members make presentations and conduct several trainings
yearly on motor basics and applications to industry and utility
customers. Staff members also write and present technical papers in
scientific settings and in industry and trade publications of the
electric motor industry.
(g) Advanced Energy is independent and does not have or maintain
any relationship, direct or indirect, with any electric motor
manufacturer, importer, distributor, or any other related entity that
might pose a conflict of interest in any way shape or form. The Company
similarly does not have any relationship with the US Department of
Energy that might hinder its ability to serve as an independently
recognized national certification program for operating a certification
system for certifying the efficiency and compliance of electric motors
and small electric motors with the applicable energy efficiency
standards.
(h) Advanced Energy has developed extensive measures to ensure
impartiality, through various checks at every stage of a given project.
3.3 Advanced Energy's Experience With Certification Matters
(1) Advanced Energy has significant experience with certification
matters. Since 2000, Advanced Energy currently operates its own Quality
Assurance Program for Motor Repair Centers. This national program,
known as Proven Efficiency Verification program, conducts audits of
motor repair centers, including before and after testing and issues
Motor Repair Centers that have met the requirements a Certificate that
is renewed every year. Launched in 1999, the PEV program precedes a
similar program started in 2014 by the Electrical Apparatus Serves
Association, the trade association for Motor Repair Centers. Advanced
Energy was consequently selected as one of the approved Auditors for
the EASA program.
(2) Advanced Energy runs a certification program in the residential
housing market called SystemVision\TM\. SystemVision\TM\ is an Advanced
Energy Certification Program for affordable homes whereby homes that
are built to Advanced Energy's specifications are guaranteed a specific
heating and cooling energy consumption at a specified comfort level.
SystemVision\TM\ Certified homes that have their heating and cooling
expenditure above the threshold are reimbursed by the program. Advanced
Energy provides the training and technical support that helps
affordable housing market players in the design, construction and
certification of energy-efficient affordable homes. The
SystemVision\TM\ homes are reputed to contribute to improved health,
safety, durability, comfort and energy efficiency in the state of North
Carolina. For the last 17 years the Certification Program has been
guaranteeing the heating and cooling bills as well as homeowner comfort
for the residential new construction, affordable housing market in the
State. For more information visit: https://www.advancedenergy.org/portal/systemvision/.
(3) Advanced Energy has operated a HVAC contractor Certification
program, launched in 2012. Advanced Energy's certification services for
HVAC contractors was developed in response to and as a requirement of
the Environmental Protection Agency (EPA)'s Energy Star New Homes
Program--HQUITO. Our program serves to not only help HVAC contractors
become certified in the ENERGY STAR program, but to also support their
growth and success with technical assistance and best-in-class training
and resources. More information at: https://www.advancedenergy.org/portal/hvac/.
(4) Advanced Energy is the only organization in North Carolina
selected by the utilities to certify solar installations for
commissioning onto the grid. This activity comprises going on site to
inspect installations to ensure that they meet the Duke Energy design
codes as well as related UL and IEEE standards.
4. Independent Status of Advanced Energy
Advanced Energy is an independent organization, chartered by the
North Carolina Utilities Commission to fulfill the mission for which it
was setup. Advanced Energy is a nonprofit energy services and
engineering firm working with electric utilities, government agencies,
public and private organizations to provide research, testing,
training, consulting and program design services in the residential,
commercial and industrial sectors markets.
Advanced Energy's delivery team is organized into the following
business divisions--Building Science, Energy Efficiency Services,
Transportation Services, Solar, and Motors and Drives. The company does
business in those key markets.
As noted above in section 1 (Program Criteria Narrative) Advanced
Energy does have clients including electric motor manufacturers,
importers, distributors, private labelers, vendors, trade associations
and others that utilize our lab for testing and pay us for those
services. In all cases we perform testing to prescribed standards and
offer test results. We do not offer advice or consultation in motor
design or motor efficiency improvement. There are consultants in the
motor industry that do that and many of them utilize our lab as new
electric motor products are developed. In these cases Advanced Energy's
accuracy and repeatability in motor testing is valued and used by
others to improve products. Other clients use our test data to improve
their products at times but they do that solely on their own with
nothing further than test data offered from Advanced Energy. For motor
efficiency certification clients either pass or fail the test and it is
solely up to them to determine next steps.
We also tear motors down documenting findings providing reports of
all observations and a comment on the overall quality of construction.
We have done this for costing purposes too with DOE subcontractors
seeking to define the cost of materials required to achieve prescribed
efficiency levels in the DOE rules. Providing test data and observation
reports to our clients for compensation may appear to some to
constitute a conflict. We assert all other approved DOE third parties
certification programs for motor efficiency offer similar test services
to their clients and that by doing so we are all expert in
certification processes as required by the DOE program criteria.
We assert that Advanced Energy does not have affiliation, financial
or otherwise with any motor manufacturer or any of the client
categories mentioned above. Neither is the company controlled by any
other entity than its Management and Board of Directors, appointed by
the sitting Governor of North Carolina.
Further we assert Advanced Energy has no conflict of interest with
any of its clients with respect to operating a nationally recognized
motor certification program.
5. Appendices 2
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\2\ Attachments and data submitted by Advanced Energy with its
petition for rulemaking are available in the docket at http://www.regulations.gov.
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5.1 Accreditation Certificate From ANSI
(attached)
[[Page 32445]]
5.2 Accreditation Certificate From NVLAP
(attached)
5.3 Accreditation Certificate From NOM?
(attached)
5.4 Form 103
(attached)
5.5 MBIA
(attached)
[FR Doc. 2019-14462 Filed 7-5-19; 8:45 am]
BILLING CODE 6450-01-P