[Federal Register Volume 87, Number 154 (Thursday, August 11, 2022)]
[Proposed Rules]
[Pages 49537-49554]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-17074]
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Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
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Federal Register / Vol. 87, No. 154 / Thursday, August 11, 2022 /
Proposed Rules
[[Page 49537]]
DEPARTMENT OF ENERGY
10 CFR Part 431
[EERE-2021-BT-STD-0018]
RIN 1904-AE54
Energy Conservation Program: Energy Conservation Standards for
Commercial and Industrial Pumps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notification of data availability (``NODA'').
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SUMMARY: On August 9, 2021, the U.S. Department of Energy (``DOE'')
published a request for information regarding energy conservation
standards for commercial and industrial pumps (``pumps''). In this
notice of data availability (``NODA''), DOE is publishing an overview
of potential technology/design options and associated estimated
national energy savings with preliminary industry net present value
estimates for certain pump equipment classes in order to provide
stakeholders with additional information and to assist DOE in
determining how to proceed with the rulemaking. The analysis presented
in this NODA is consistent with the scope that DOE proposed in a test
procedure notice of proposed rulemaking for commercial and industrial
pumps published on April 11, 2022. DOE requests comments, data, and
information regarding its analysis.
DATES: Written comments and information will be accepted on or before,
September 26, 2022.
ADDRESSES: Interested persons are encouraged to submit comments using
the Federal eRulemaking Portal at www.regulations.gov, under docket
number EERE-2021-BT-STD-0018. Follow the instructions for submitting
comments. Alternatively, interested persons may submit comments,
identified by docket number EERE-2021-BT-STE-0018, by any of the
following methods:
(1) Email: [email protected]. Include the docket number
EERE-2021-BT-STD-0018 in the subject line of the message.
(2) 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.
(3) Hand Delivery/Courier: Appliance and Equipment Standards
Program, U.S. Department of Energy, Building Technologies Office, 950
L'Enfant Plaza SW, 6th Floor, 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.
No telefacsimiles (``faxes'') will be accepted. For detailed
instructions on submitting comments and additional information on this
process, see section IV of this document.
To inform interested parties and to facilitate this rulemaking
process, DOE has prepared a technical support document (``TSD'') which
is available in the docket for this rulemaking.
Docket: The docket for this activity, which includes Federal
Register notices, comments, public meeting transcripts, 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, some documents listed in the index,
such as those containing information that is exempt from public
disclosure, may not be publicly available.
The docket web page can be found at www.regulations.gov/docket/EERE-2021-BT-STD-0018. The docket web page contains instructions on how
to access all documents, including public comments in the docket. See
section IV.A of this document for information on how to submit comments
through www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies, 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 20585-0121.
Telephone: (202) 586-8145. Email: [email protected].
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact the Appliance and Equipment Standards Program staff at (202)
287-1445 or by email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Authority
B. Deviation From Appendix A
II. Background
A. Current Standards
B. Current Process
III. Discussion
A. Scope
B. Technology Options
1. Hydraulic Redesign
2. Advanced Motors
3. Variable-Speed Drives
a. Potential Disruption to Pumps Market
b. Potential Issues With the Replacement Market
c. Potential Energy Use Impacts
d. Potential Cost Impacts
C. Analysis
1. Screening
a. Methodology
b. Hydraulic Redesign Approach
c. Motors and Controls Approach
2. National Energy Savings
a. Energy Use Analysis
b. Shipments Analysis
c. National Energy Savings
3. Manufacturer Impact Analysis
a. Small Business Impacts
IV. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
V. Approval of the Office of the Secretary
I. Introduction
A. Authority
The Energy Policy and Conservation Act, as amended (``EPCA''),\1\
authorizes DOE to regulate the energy efficiency of a number of
consumer products and certain industrial equipment. (42 U.S.C.
[[Page 49538]]
6291-6317) Title III, Part C \2\ of EPCA, added by Public Law 95-619,
Title IV, section 441(a), established the Energy Conservation Program
for Certain Industrial Equipment, which sets forth a variety of
provisions designed to improve energy efficiency. This covered
equipment includes pumps, the subject of this document. (42 U.S.C.
6311(1)(A))
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\1\ All references to EPCA in this document refer to the statute
as amended through the Energy Act of 2020, Public Law 116-260 (Dec.
27, 2020), which reflect the last statutory amendments that impact
parts A and A-1 of EPCA.
\2\ For editorial reasons, upon codification in the U.S. Code,
part C was redesignated part A-1.
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EPCA provides that, not later than 6 years after the issuance of
any final rule establishing or amending a standard, DOE must publish
either a notification of determination that standards for the product
do not need to be amended, or a notice of proposed rulemaking
(``NOPR'') including new proposed energy conservation standards
(proceeding to a final rule, as appropriate). (42 U.S.C. 6316(a); 42
U.S.C. 6295(m)(1)) Not later than three years after issuance of a final
determination not to amend standards, DOE must publish either a notice
of determination that standards for the product do not need to be
amended, or a NOPR including new proposed energy conservation standards
(proceeding to a final rule, as appropriate). (42 U.S.C. 6316(a); 42
U.S.C. 6295(m)(3)(B))
Under 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. 6316(a); 42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or
amended standard must result in a significant conservation of energy.
(42 U.S.C. 6316(a); 42 U.S.C. 6295(o)(3)(B))
DOE is publishing this NODA to collect data and information to
inform its decision consistent with its obligations under EPCA.
B. Deviation From Appendix A
In accordance with section 3(a) of 10 CFR part 430, subpart C,
appendix A (``appendix A''), which applies to commercial and industrial
pumps under 10 CFR 431.4, DOE notes that it is deviating from the
provision in appendix A regarding the length of comment periods for the
pre-NOPR stages for an energy conservation standards rulemaking.
Section 6(d)(2) of appendix A specifies that the length of the public
comment period for pre-NOPR rulemaking documents will not be less than
75 calendar days. For this NODA, DOE has opted instead to provide a 45-
day comment period. DOE requested comment in an early assessment
request for information published on August 9, 2021 (``August 2021
RFI'') on the analysis conducted in support of the previous energy
conservation standard rulemaking for pumps. 86 FR 43430, 43431. The
August 2021 RFI provided 30 days for submitting written comment, data,
and information. In response to comment received from stakeholders, DOE
extended the comment period for the August 2021 RFI another 30 days.
Given that the analysis will largely remain the same, and in light of
the 60-day comment associated with the August 2021 RFI, DOE has
determined that a 45-day comment period is sufficient to enable
interested parties to review the data and accompanying analysis and
develop meaningful comments in response to the NODA.
II. Background
A. Current Standards
In a final rule published on January 26, 2016 (``January 2016 Final
Rule''), DOE prescribed the current energy conservation standards for
pumps manufactured on and after January 27, 2020. 81 FR 4368. These
standards are set forth in DOE's regulations at 10 CFR 431.465 and are
reproduced in Table II.1. DOE set standards for equipment classes which
were divided based on pump category, nominal speed of rotation (rpm),
and load type (constant and variable). Equipment class labels are
structured as pump category acronym, rpm, constant-load (``CL'') or
variable-load (``VL''). CL and VL equipment classes were not analyzed
separately in the January 2016 Final Rule and therefore were not
assigned different standards.
Table II.1--Federal Energy Conservation Standards for Pumps
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Maximum
Equipment class PEI C-value
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ESCC.1800.CL...................................... 1 128.47
ESCC.3600.CL...................................... 1 130.42
ESCC.1800.VL...................................... 1 128.47
ESCC.3600.VL...................................... 1 130.42
ESFM.1800.CL...................................... 1 128.85
ESFM.3600.CL...................................... 1 130.99
ESFM.1800.VL...................................... 1 128.85
ESFM.3600.VL...................................... 1 130.99
IL.1800.CL........................................ 1 129.3
IL.3600.CL........................................ 1 133.84
IL.1800.VL........................................ 1 129.3
IL.3600.VL........................................ 1 133.84
RSV.1800.CL....................................... 1 129.63
RSV.3600.CL....................................... 1 133.2
RSV.1800.VL....................................... 1 129.63
RSV.3600.VL....................................... 1 133.2
ST.1800.CL........................................ 1 138.78
ST.3600.CL........................................ 1 134.85
ST.1800.VL........................................ 1 138.78
ST.3600.VL........................................ 1 134.85
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B. Current Process
In the August 2021 RFI, DOE sought data and information to evaluate
whether amended energy conservation standards for pumps would result in
a significant savings of energy; be technologically feasible; and be
economically justified. 86 FR 43430. Comments received to date as part
of the current process have helped DOE identify and resolve issues
related to the preliminary analyses. Chapter 1 of the TSD accompanying
this NODA summarizes and addresses the comments received.
III. Discussion
The goal of this NODA is to provide an overview of potential design
options and associated national energy savings (``NES'') and
preliminary industry net present value (``INPV'') estimates for the
various commercial and industrial pump equipment classes, as well as
associated qualitative information. Following comments received on this
NODA, DOE would determine how to proceed with the rulemaking.
The contents of this NODA are based on the scope proposed in a test
procedure notice of proposed rulemaking for pumps published on April
11, 2022 (``April 2022 TP NOPR''). 87 FR 21268, 21273. DOE acknowledges
that stakeholder comments in response to the April 2022 TP NOPR include
scope-related comments, which DOE will consider in determining the
scope of any final test procedure and any subsequent energy
conservation standards analyses.
This NODA includes an abbreviated set of analyses as compared to a
full preliminary analysis or notice of proposed rulemaking: market and
technology assessment; screening analysis; engineering analysis; energy
use analysis and shipments analysis to calculate national energy
savings; and a preliminary manufacturer impact analysis.
This NODA does not include a life cycle cost analysis (``LCC'') or
the national net present value portion of the national impact analysis
(``NIA''). In the January 2016 Final Rule, all LCC results based on
hydraulic redesign were positive since there was no increase in
manufacturer production cost (``MPC''), and the energy cost savings
significantly outweighed the increase in manufacturer selling price
(``MSP'') that DOE calculated by assuming manufacturers recouped
conversion costs. 81 FR 4368, 4406-4409. At this time, DOE does not
have data that would indicate the results would be different from those
presented in the January 2016 Final Rule, and as discussed in section
III.B.1 of this document, manufacturers were unable to recoup any
conversion costs resulting
[[Page 49539]]
from the current standard. However, if updated data were provided, DOE
could evaluate MPC increases for additional hydraulic redesign and
these values could be incorporated into a future LCC or NIA analysis,
along with MPC increases for other technology options as discussed in
section III.C.2.c. of this document.
The analyses in this NODA are primarily based on data from the
previous rulemaking, except for updated efficiency distributions,
conversion costs, estimated motors and controls performances and costs,
and performance data for pumps not currently subject to standards. In
addition, due to limited data, the analysis for pumps not currently
subject to standards is based largely on proxies from the current
scope. Overviews of the analyses can be found in section III.C of this
document, with detailed methodology available in the TSD accompanying
this NODA.
A. Scope
In this NODA, DOE conducted analyses for pump categories currently
subject to DOE standards, in addition to some pump categories that are
not currently subject to standards, but were included in the April 2022
TP NOPR. 87 FR 21268. Pump categories currently subject to standards
include end suction frame mounted (``ESFM'') pumps, end suction close-
coupled (``ESCC'') pumps, in-line (``IL'') pumps, radially split,
multi-stage, vertical, in-line diffuser casing (``RSV'') pumps, and
submersible turbine (``ST'') pumps. Pump categories not currently
subject to standards that were included in the April 2022 TP NOPR
include between bearing (``BB'') pumps, vertical turbine (``VT'')
pumps, small vertical in-line (``SVIL'') pumps, radially split
horizontal (``RSH'') pumps, pumps with a nominal speed of rotation of
1,200 rpm, and ST pumps with bowl diameters greater than 6 inches.
During the pumps negotiations in 2014,\3\ DOE collected data on BB, VT,
and SVIL pumps. DOE combined these data with data from a recent round
of manufacturer interviews for this NODA analysis. DOE did not have
sufficient data to evaluate RSH pumps and ST pumps with bowl diameters
greater than 6 inches in this NODA. In addition, as there are so few
models of ST.1800 pumps, DOE only evaluated ST.3600 pumps as part of
this NODA, consistent with the January 2016 Final Rule.
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\3\ A commercial and industrial pumps working group (``CIP
working group'') was established in 2013 under the Appliance
Standards and Rulemaking Advisory Committee (``ASRAC'') in
accordance with the Federal Advisory Committee Act and the
Negotiated Rulemaking Act. (5 U.S.C. App.; 5 U.S.C. 561-570). See 78
FR 44036. The purpose of the CIP working group was to discuss and,
if possible, reach consensus on proposed standards for pump energy
efficiency. On June 19, 2014, the CIP working group reached
consensus on proposed energy conservation standards for specific
rotodynamic, clean water pumps used in a variety of commercial,
industrial, agricultural, and municipal applications. The CIP
working group assembled their recommendations into a Term Sheet (See
Docket EERE-2013-BT-NOC-0039-0092, www.regulations.gov/document/EERE-2013-BT-NOC-0039-0092).
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Table III.1 compares shipments and average horsepower (``HP'') for
pumps not currently, and currently, subject to standards based on
available data. Based on stakeholder feedback through public comments
and manufacturer interviews, DOE has tentatively determined that the
pumps not currently subject to standards are, on average, rated at a
higher HP than the pumps currently subject to DOE standards--and as a
result, total shipments for these pumps within the scope limitations of
200 HP and 459 feet of head tend to be smaller than for the pump
categories that DOE currently regulates. As noted, DOE will address
stakeholder comments received on the April 2022 TP NOPR related to
those pumps that are not currently subject to standards, including the
application of the current scope limitations, in subsequent test
procedure rulemaking documents.
Table III.1--Shipments and Average HP by Equipment Class for Pumps Not Currently, and Not Currently, Subject to
Standards and Pumps Not Currently Subject to Standards
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2021 Shipments
Equipment category estimates Average HP
(units)
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Currently subject to standards:
ESCC...................................................................... a 206,215 a 9
ESFM...................................................................... a 52,894 a 20
IL........................................................................ a 60,566 a 10
ST........................................................................ a 128,893 a 7
RSV....................................................................... a 60,019 b 14
Not currently subject to standards
BB........................................................................ a 6,379 c 21
VT........................................................................ a 7,179 c 7
SVIL...................................................................... c 10,212 c 0.5
RSH....................................................................... N/A N/A
1200 rpm (ESCC, ESFM, and IL categories).................................. c 7,874 c 13
ST and VT > 6inch......................................................... N/A N/A
---------------------------------
Total................................................................. 540,231 10
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\a\ Year 2012 shipments based on an HI survey (www.regulations.gov/document/EERE-2013-BT-NOC-0039-0068),
projected forward to year 2021 based on the shipments methodology (discussed in section III.C.3.b of this
document).
\b\ DOE's Compliance Certification Database, see www.regulations.doe.gov/certification-data/CCMS-4-Pumps_-_General_Pumps.html#q=Product_Group_s%3A%22Pumps%20-%20General%20Pumps%22 accessed on March 20, 2022.
\c\ Based on both manufacturer data collection conducted for this analysis and for the January 2016 Final Rule
while applying equipment class similarity (discussed in section III.C.3.a of this document) and the shipments
methodology (discussed in section III.C.3.b of this document).
Issue 1: DOE seeks individual model level data or industry
aggregated data to update its shipment and average horsepower estimate
for pump categories that are currently subject to standards and those
pump categories that are currently not subject to standards.
As discussed previously, DOE intends to use this NODA as a step
toward determining how to proceed with a rulemaking for pumps. DOE
[[Page 49540]]
acknowledges that if pump classes that are not currently within scope
of the test procedure were included in the scope of the test procedure
final rule, but were not included in the scope of the energy
conservation standard, these classes would not have assigned C-
values.\4\ In this case, the pump energy rating (``PER'') for a
minimally compliant pump (``PERSTD'') could not be
calculated, making it impossible to determine a pump energy index
(``PEI'') rating for these classes. To address this issue, DOE could
consider issuing a supplemental NOPR for the test procedure to
establish C-values for the categories currently subject to standards at
a baseline level that would enable calculation of PEI for these
categories and facilitate rebate or other efficiency programs for pumps
not currently subject to standards.
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\4\ C-value is the translational component of a three-
dimensional polynomial equation that describes the attainable
hydraulic efficiency of pumps as a function of flow at best
efficiency point (``BEP''), specific speed, and C-value. The C-value
is used to define an efficiency level that a pump can readily attain
across the entire regulated scope of flow and specific speed for
that particular pump.
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Issue 2: DOE requests comments on potential benefits or drawbacks
of proposing a change to the test procedure to allow calculation of PEI
for pumps not subject to energy conservation standards.
B. Technology Options
For this NODA analysis, DOE evaluated hydraulic redesign, advanced
motors, and variable-speed drives (``VSDs'') as potential technologies
for reducing pump energy consumption. These technologies are discussed
in the following sections.
1. Hydraulic Redesign
DOE evaluated five efficiency levels (``EL'') in the January 2016
Final Rule; each EL was developed according to efficiency percentiles
(10th, 25th, 40th, 55th, and 70th percentile) and each percentile for
each equipment class was assigned a C-value. 81 FR 4368, 4386.
Ultimately, the pumps energy conservation standard was established at
C-values corresponding to EL 2 for all equipment classes except for RSV
pumps and ST pumps with a specific speed of 1,800 rpm. 81 FR 4368, 4369
and 4386 (see Table IV.2 of the January 2016 Final Rule detailing the
adopted efficiency levels). Standards for these pump equipment classes
were established at baseline, or EL 0.\5\ Id.
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\5\ DOE notes that the baseline for RSV pumps was equivalent to
the EU's 40th percentile standard, as all RSV pumps had already been
designed to meet that standard.
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During interviews, manufacturers stated that additional hydraulic
redesign might be possible to reach EL 3 as presented in the January
2016 Final Rule; however, they pointed out that any such redesign would
be as or more expensive than the previous redesign and energy savings
would likely be minimal. In order to meet the standards set in the
January 2016 Final Rule, many manufacturers redesigned their pumps to
be as efficient as possible given pump family and certain technology
limitations; most manufacturers did not redesign their pumps to just
meet the standard. Therefore, for redesigned pumps that did not reach
EL 4 or EL 5 as presented in the January 2016 Final Rule, manufacturers
expressed concern that reaching these levels with a hydraulic redesign
would be extremely difficult and costly. In particular, manufacturers
commented that:
MPC would begin to increase at EL 4 and EL 5 as presented
in the January 2016 Final Rule due to finer part tolerances and manual
surface finishing;
Utility could be compromised. Some manufacturers stated
that they had observed a warranty claim increase for redesigned pumps.
Additionally, several manufacturers commented that they had to flatten
the pump curve in order to achieve higher efficiency levels. A flatter
pump curve can limit controllability and cause operational problems in
some applications.\6\
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\6\ Karrasik, Messina, Cooper, and Heald. ``Pump Handbook,'' 4th
Edition, pp. 2.55-2.57.
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In some cases, manufacturers were or would be unable to
maintain flange positions on some models during redesign. This means
that a new pump cannot easily replace an older pump without changing
piping into and out of the pump, which in turn may result in loss of
business for that manufacturer or increase installation costs for end
users in replacement situations.
Manufacturers may choose not to redesign to EL 4 and EL 5,
resulting in gaps in a product family, and the possibility that a
consumer would then purchase a pump that was less efficient for their
application than they would have purchased without such a standard.
Manufacturers reported that they did not recoup the
conversion costs incurred due to the redesigns required by the current
DOE standards due to market pressures. Manufacturers expect the same
outcome if DOE were to set more stringent standards.
DOE acknowledges that there are many pumps already on the market
that meet EL 4 and EL 5 as presented in the January 2016 Final Rule.
There are several reasons why this may be possible, even with
manufacturers stating that meeting these ELs are not feasible for all
pumps:
Choices to limit the impacts listed previously (increased
MPC and labor/staffing needs, loss of utility for certain applications,
potential loss of replacement business due to changed flange
positions);
Choosing to stay within the constraints of a product
family in order to take advantage of shared common parts, as opposed to
a substantially more expensive redesign of an entire product family or
a redesign that would make a model(s) different from the rest of the
family;
Variability in designer skill and experience with
computational fluid dynamics;
Irregularities in the three-dimensional surface that sets
the standard level as a function of flow and specific speed. To
harmonize with the European Union (``EU''), the surface used to
determine DOE energy conservation standards is based on EU data and not
data specific to the U.S. market. (See January 2016 Final Rule TSD
Appendix 3B p. 5, EERE-2011-BT-STD-0031-0056) This means that there may
be some points of flow or specific speed where EL 4 or EL 5, as
presented in the January 2016 Final Rule, may be easier to achieve than
at other points.
Issue 3: DOE requests comment on the percentage of basic models
that would be impacted by the following factors if manufacturers were
to redesign their pumps to EL 4 and EL 5 (as presented in the January
2016 Final Rule): (1) need to flatten the pump curve beyond potentially
acceptable levels for the existing market for a given model or any
reported issues with controllability; (2) increased warranty claims;
and (3) increased MPCs for pumps redesigned to higher efficiencies.
Additionally, DOE requests comment on which EL (as presented in the
January 2016 Final Rule) and for which pump classes (or hp ranges)
these issues would first appear.
Issue 4: DOE also seeks comment on the availability of designers
skilled enough to design a pump that can reach EL 4 and EL 5 and be
readily manufactured.
Issue 5: Additionally, DOE requests comment on any other issues
that may prevent manufacturers from redesigning pumps to reach higher
efficiency levels, including other utility issues.
Issue 6: DOE requests comment on the fraction of installations in
which consumers would have to make piping changes as a result of a
change in flange position (as opposed to purchasing another model with
the desired flange
[[Page 49541]]
positions), and the cost of such piping changes.
2. Advanced Motors
Advanced motors were not considered as a technology option in
support of the January 2016 Final Rule. However, based on feedback from
stakeholders, DOE is including advanced motors as a technology option
in this NODA analysis. In this NODA, advanced motors refer to any motor
paired with a pump that has a greater efficiency than the default motor
referenced in the pumps test procedure. If DOE were to set an energy
conservation standard that is stringent enough to require more
efficient motors, some pumps may need to be paired with a motor in
order to be sold in the U.S.\7\ DOE has identified several potential
issues with this technology option, which are listed below:
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\7\ DOE acknowledges that pump manufacturers may be able to
hydraulically redesign a bare pump to reach the same PEI level as a
minimally compliant bare pump sold with a more efficient motor. In
this case, the issues discussed in section III.B.1 might apply. DOE
would consider an appropriate ordering of any design options for the
engineering analysis after conducting a screening analysis, which it
has not done for this NODA. (See discussion in section III.C.1. of
this document).
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Replacement pumps. If all pumps must be paired with motor
for distribution into commerce, it is not clear how the replacement
market for bare pumps would work.
Potential market disruption. The majority of sales for
most manufacturers are from bare pumps; distributors may then pair the
pump with a motor (and possibly controls). Requiring that pumps be sold
with a motor (by the pump's original equipment manufacturer) would
likely have a negative impact on pump distributors and result in
substantial disruption to the pumps market.
Potential consequences. Larger stock in the field of
older, more inefficient pumps. Requiring pumps to be paired with a
motor for distribution in commerce is expected to increase the cost of
the pump. Some end users may opt to repair rather than replace older,
inefficient pumps. Additionally, if a motor fails before the pump
fails, end users may choose a less efficient motor as a replacement.
Overlapping regulation. The vast majority of motors paired
with pumps subject to this rulemaking are already covered equipment (as
electric motors) within the DOE appliance standards program. (subpart B
to 10 CFR part 431) \8\ DOE is currently undertaking an energy
conservation rulemaking to consider amended standards for electric
motors (see Docket No. EERE-2020-BT-STD-0007). This prevents DOE from
determining how much energy savings would result from a pumps design
option related to motor efficiency without potentially double-counting
energy savings also accounted for in the electric motors rulemaking.
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\8\ Some motors paired with pumps subject to this and other pump
rulemakings (e.g., dedicated purpose pool pumps, circulator pumps)
are covered by the DOE appliance standards program as small electric
motors (subpart X to 10 CFR part 431). Small electric motors that
are components of another piece of covered equipment do not have to
comply with standards prescribed for this equipment. (See 10 CFR
431.466(a). See also 42 U.S.C. 6317(b)(3)). As such, the problem of
overlapping regulation may not apply to covered products and
equipment that are only paired with small electric motors (as
defined in 10 CFR 431.462).
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These issues (excluding overlapping regulation) are discussed in
more detail in section III.B.3 of this document in the context of VSDs,
but apply similarly to motors.
Issue 7: DOE requests comment on how a standard that requires an
advanced motor to be paired with a bare pump would impact: (1) the bare
pump replacement market; (2) the distributor market and business model;
(3) the repair of pumps rather than their replacement and (4) the
replacement of failed motors with less efficient motors. DOE also
requests feedback on any potential consistency concerns with a standard
that requires an advanced motor to be paired with a bare pump and
current or future energy conservation standards for electric motors.
3. Variable-Speed Drives
Variable-speed drives were considered as a technology option in the
January 2016 Final Rule. (See Chapter 3 of the January 2016 Final Rule
TSD, EERE-2011-BT-STD-0031-0056, pp. 3-29 to 3-35) VSDs were screened
out of the January 2016 Final Rule analysis because DOE determined the
technology may not significantly improve efficiency for all pumps
within each equipment class. (See Chapter 4 of the January 2016 Final
Rule TSD, EERE-2011-BT-STD-0031-0056, pp. 4-5) In fact, DOE determined
that energy use would increase for many applications. Id.
As discussed in chapter 1 of the TSD accompanying this NODA, DOE
received comments from stakeholders recommending that VSDs be
considered as a technology option in the current pumps analysis. (CA
IOUs, No. 10 at p. 12; ASAP and NRDC, No. 7 at p. 2; NEEA, No. 11 at p.
6) These stakeholders referenced a recent study by NEEA that reported
significant savings for both constant-load and variable-load pump
applications.\9\ If DOE were to set an energy conservation standard
that is stringent enough to require VSDs, all pumps would have to be
paired with a motor and VSD in order to be sold in the U.S.
---------------------------------------------------------------------------
\9\ Northwest Energy Efficiency Alliance, ``Extended Motor
Products Savings Validation Research on Clear Water Pumps and
Circulators,'' August 29, 2029. See www.neea.org/img/documents/XMP-Savings-Validation-Research-on-Clean-Water-Pumps-and-Circulators.pdf.
---------------------------------------------------------------------------
During interviews, manufacturers shared multiple concerns about
requiring pumps to be sold with a VSD. However, many manufacturers also
acknowledged that it would be ideal for DOE to incentivize applications
to use controls with their pumps and suggested that a rebate program
would be the best way to do this since it would limit all of the
potential unintended consequences discussed. On April 27, 2022, DOE
published a Notice of Availability and Solicitation of Public Comment
on the Draft Implementation Guidance Pertaining to the Extended Product
System Rebate Program and Energy Efficient Transformer Rebate Program.
87 FR 25006. This draft implementation guidance includes a rebate
program for pumps designed to incentivize adding controls to existing
facilities (by specifying a maximum qualifying variable-load PEI
(``PEIVL'')), with maximum rebate payments to a given entity
of up to $25,000 per calendar year. For more information, refer to the
guidance web page: www.energy.gov/eere/buildings/draft-implementation-guidance-pertaining-extended-product-system-rebate-program-and.
a. Potential Disruption to Pumps Market
The primary concern shared by most manufacturers was how disruptive
a requirement to sell pumps with controls would be for the overall
pumps market. Manufacturers stated that end users typically have
specific controller requirements, meaning they have one controller
brand for their facility, primarily to simplify maintenance and
operation. Because pump manufacturers typically stock one to two
controller brands, distributors often buy the pump or pump and motor
from the pump manufacturer but buy the controls from the controls
manufacturer. Additionally, if pumps were required to be sold with
motors and VSDs, pump manufacturers would have to greatly increase
their floor space, inventory, and unique model numbers in order to
satisfy end users who would currently work through a distributor. In
this case, there could be significantly large impacts to
[[Page 49542]]
distributors, who would provide less added value.
Manufacturers also commented that there are supply chain
constraints. Specifically, pump manufacturers were skeptical about the
ability of VSD manufacturers to be able to meet the increased demand
that an energy conservation standard requiring VSDs would cause.
Manufacturers also stated that the VSD technology for higher horsepower
motors is not as mature as that for lower horsepower motors, and that,
in some cases, they already had trouble obtaining VSDs of acceptable
quality for higher horsepower motors.
Issue 8: DOE seeks comment on the frequency with which pump
consumers specify only a single controller brand, as well as on the
number of controller brands typically stocked by a pump manufacturer.
Issue 9: DOE seeks comment on how a VSD requirement for pumps would
impact distributors.
Issue 10: DOE requests comment on whether there would be sufficient
quantity and quality of VSDs available if there were a VSD requirement
for pumps.
b. Potential Issues With the Replacement Market
The EU is evaluating its current standard for pumps and issued a
call of evidence on January 21, 2022, that included a recommendation
for evaluating an extended product approach for pumps.\10\ In its
comments, EuroPump \11\ supported the extended product approach as a
means to capture savings that were not captured by the current EU
regulation. However, while efficiency organizations provided general
support for the extended product approach, they also stated that VSDs
should only be required as needed to minimize material waste, while
commenting that around 50 percent of pump systems benefit from a
VSD.\12\ During interviews, manufacturers also voiced concerns about
how a replacement parts market would work if pumps were required to be
sold with motors and controls. If a bare pump is sold as a replacement
part, that practice would eliminate the waste associated with replacing
an entire pump system. However, selling a bare pump as a replacement
part without controls opens a loophole where end users could purchase
the bare pump and operate it without controls. This is also an issue
for advanced motors, although to a lesser degree since only the motor
and bare pump would have to be replaced, not the controller.
---------------------------------------------------------------------------
\10\ The document discusses the possibility of covering the
``extended product'' referring to the pump, motor, and VSD as one
unit. See www.ec.europa.eu/info/law/better-regulation/have-your-say/
initiatives/12831-Ecodesign-requirements-for-water-pumps-review-_en.
\11\ Europump is the European Association of Pump Manufacturer
Associations. See Comments at www.ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/12831-Ecodesign-requirements-
for-water-pumps-review-/F2822271_en.
\12\ See comments from ECOS, coolproducts, and the European
Environmental Bureau, available at www.ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/12831-Ecodesign-requirements-
for-water-pumps-review-/F2878588_en.
---------------------------------------------------------------------------
Issue 11: DOE seeks comment on possible methods to retain a
replacement market for bare pumps while preventing a loophole where
bare pumps could be purchased for current and new installations.
c. Potential Energy Use Impacts
Through interviews conducted with manufacturers, DOE has also
identified several ways that VSDs may impact pump energy use (if pumps
must be sold with advanced motors or VSDs) that are not accounted for
in this NODA's energy use analysis but would need to be to justify new
or amended standards that DOE may decide to adopt.
First, if a motor sold with a pump fails, the customer could
replace the failed motor with a less efficient motor since current DOE
standards for electric motors do not require advanced technology and/or
controls. This issue is the reason why stakeholders requested that DOE
conduct a rulemaking using its direct final rule authority to establish
standards for dedicated-purpose pool pump (``DPPP'') motors. In their
view, because the adopted DPPP standards require DPPPs (at least in
certain cases) to be sold with a VSD. Establishing DPPP motor standards
would ensure that the expected savings from the DPPP standards would
occur. 83 FR 45851, 45853 (September 11, 2018). In the case of DPPPs,
there are motors specific to DPPPs, such that adopting a motor standard
specific to DPPPs would be feasible. In the case of pumps, the motors
used with this equipment are used in multiple applications, so DOE
cannot adopt motor standards, as it did for DPPPs, that are specific to
pumps. This issue also applies to the advanced motors design option
discussed previously.
Second, requiring all pumps to be sold with controls could cause an
increase in repairs of inefficient pumps because replacement pumps
would have the added cost of a VSD. This would delay the purchase of a
new pump with motor and controls. This issue also applies to the
advanced motors design option discussed previously, although to a
lesser extent since a motor is less expensive than a motor-plus-VSD
combination.
Third, pumps designed for integrated controls may have a lower
efficiency if installed in properly-sized constant-load applications
since there are additional electrical inefficiencies when a controller
is added to a motor. If a system operates at a constant load with an
appropriately-sized pump, these additional losses become greater than
the benefits of a VSD.
Issue 12: DOE seeks comment on the frequency with which customers
would replace an inverter-only motor and control with an induction
motor upon the end of the lifetime of the motor originally purchased
with the pump.
Issue 13: DOE seeks comment on how bare pump repair frequency may
change if customers delay purchasing a more expensive pump with motor
and controls. For example, in its DPPP motors analysis, DOE assumed
that in the standards case, a greater percentage of consumers would
repair their pump as compared to the no-new-standards case.
Issue 14: DOE seeks comment on the percentage of pump models that
would be redesigned for controls if they were required to be sold with
them, and of those, what percentage would have worse efficiency in
constant-load applications than the current pump model, and by how much
the efficiency or energy use would be impacted.
d. Potential Cost Impacts
During interviews, manufacturers identified potential cost impacts
that have not been accounted for in this analysis but would need to be
in any analysis to justify new or amended standards. Specifically,
there could be significant installation difficulties or costs for some
applications in which electrical upgrades or filters may be required.
In addition, there could be a need for re-piping since, in this
scenario, pump manufacturers may not offer the same bare pumps. Re-
piping is discussed previously in relation to hydraulic redesign.
Finally, there could be downtime for facilities while they re-pipe or
perform electrical upgrades.
Issue 15: DOE seeks comment on the frequency with which customers
who would be required to buy a pump with a VSD would need to add
filters or perform electrical upgrades, and the estimated cost of such
equipment and installation.
Issue 16: DOE seeks comment on the frequency with which customers
might need to re-pipe to accommodate a pump with motor and controls
rather than a drop-in replacement pump, and the estimated cost of re-
piping.
[[Page 49543]]
Issue 17: DOE seeks quantitative data on the overall installation
costs of pumps with VSDs compared to bare pumps, as well as any
differences in lifetime or repair and maintenance costs for pumps sold
with VSDs as compared to bare pumps.
C. Analysis
The following sections provide a brief overview of the results from
the analyses DOE conducted for this NODA. Full details of the
methodology can be found in chapters 2 through 6 of the TSD
accompanying this NODA. Summaries of comments received from the August
2021 RFI responses related to analytical methodologies are included in
chapter 1 of the TSD accompanying this NODA.
1. Screening
DOE uses the following five screening criteria to determine which
technology options are suitable for further 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 a significant adverse impact on
the utility of the product for 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.
(5) Unique-pathway proprietary technologies. If a design option
utilizes proprietary technology that represents a unique pathway to
achieving a given efficiency level, that technology will not be
considered further due to the potential for monopolistic concerns.
10 CFR part 430, subpart C, appendix A, sections 6(b)(3) and 7(b).
If DOE determines that a technology, or a combination of
technologies, fails to meet one or more of the listed five criteria, it
will be excluded from further consideration in the engineering
analysis.
DOE did not conduct a screening analysis for this NODA and instead
is presenting analyses for the three technologies discussed in section
III.B of this document (i.e., hydraulic redesign, advanced motors, and
VSDs) in order to receive stakeholder feedback. In a future analysis to
support this rulemaking, based on many of the issues listed in section
III.B of this document, DOE may screen out some or all of the listed
technologies based on one or more of the screening criteria.
Issue 18: DOE requests comment on if or how the five screening
criteria may limit application of hydraulic redesign, advanced motors,
or VSDs as design options in the current rulemaking analysis.
2. Engineering
The purpose of the engineering analysis is to determine the
incremental manufacturing cost associated with producing products at
higher efficiency levels. The primary considerations in the engineering
analysis are the selection of efficiency levels to analyze (i.e., the
``efficiency analysis'') and the determination of product cost at each
efficiency level (i.e., the ``cost analysis'').
DOE conducts the efficiency analysis using either an efficiency-
level approach, a design-option approach, or a combination of both.
Under the efficiency-level approach, the efficiency levels to be
considered in the analysis are determined based on the market
distribution of existing products (in other words, observing the range
of efficiency and efficiency level ``clusters'' that already exist on
the market). This approach typically starts with compiling a
comprehensive list of products available on the market, such as from
DOE's product certification database. Next, the list of models is
ranked by efficiency level from lowest to highest, and DOE typically
creates a scatter plot to visualize the distribution of efficiency
levels. From these rankings and visual plots, efficiency levels can be
identified by examining clusters of models around common efficiency
levels. The maximum efficiency level currently available on the market
can also be identified.
Under the design option approach, the efficiency levels to be
considered in the analysis are determined through detailed engineering
calculations and/or computer simulations of the efficiency improvements
from implementing specific design options that have been identified in
the technology assessment. In an iterative fashion, design options can
also be identified during product teardowns as described. The design
option approach is typically used when a comprehensive database of
certified models is unavailable (for example, if a product is not yet
regulated)--making the efficiency-level approach unusable.
In certain rulemakings, the efficiency-level approach (based on
actual products on the market) will be extended using the design option
approach to interpolate between levels to define ``gap fill'' levels
(to bridge large gaps between other identified efficiency levels) and/
or to extrapolate to the ``max tech'' level (the level that DOE
determines is the maximum achievable efficiency level), particularly in
cases where the ``max tech'' level exceeds the maximum efficiency level
currently available on the market.
The cost analysis portion of the engineering analysis is conducted
using one or a combination of cost approaches. The selection of the
cost approach depends on a variety of factors such as the availability
and reliability of information on product features and pricing, the
physical characteristics of the regulated product, and the
practicability of purchasing the product on the market. DOE generally
uses the following cost approaches:
Physical teardown: Under this approach, DOE physically
dismantles a commercially available product, component-by-component, to
develop a detailed bill of materials (``BOM'') for the product.
Catalog teardown: In lieu of physically deconstructing a
product, DOE identifies each component using parts diagrams (available
from manufacturer websites or appliance repair websites, for example)
to develop the BOM for the product.
Price surveys: If neither a physical nor catalog teardown
is feasible (for example, for tightly-integrated products that are
infeasible to disassemble and for which parts diagrams are
unavailable), DOE conducts retail price surveys by scanning retailer
websites and other marketing materials. This approach must be coupled
with assumptions regarding distributor markups and retailer markups in
order to estimate the actual manufacturing cost of the product.
The engineering analysis conducted for this NODA used an efficiency
level approach consistent with that used in the January 2016 Final Rule
analysis
[[Page 49544]]
along with a new design option approach. The cost analysis relied on
physical and catalog tear downs and confidential information provided
by manufacturers.
a. Methodology
DOE conducted two engineering analyses for this NODA. The first
analysis is consistent with that performed to support the January 2016
Final Rule in which only hydraulic redesign was considered as a design
option. 81 FR 4368, 4384. This approach developed conversion costs that
DOE expected industry to incur when redesigning non-compliant pumps to
meet a potential new standard. Discussions with manufacturers indicated
that MPC would not increase as efficiency increases.
The second analysis examined the possibility of motors and controls
as technologies to improve pump efficiency. This analysis developed MPC
versus efficiency (i.e., PEI) curves. DOE assumed the motors and
controls approach would not result in conversion costs for
manufacturers. DOE separated these analyses into a ``branched''
approach that assumes that no hydraulic redesign would occur relative
to the current baseline if a motors or controls standard were adopted,
and no pumps would shift towards only being sold with motors or
controls in a hydraulic redesign scenario. This assumption allowed DOE
to separate conversion costs from increases in MPC. DOE performed both
of these analyses for pumps larger than 1 horsepower and for SVILs.
Details of these analyses are discussed in sections III.C.2.b and
III.C.2.c of this document.
Assumptions
Since DOE had limited data for pumps that are not currently subject
to standards, the Department used similar pump categories that are
currently subject to standards as a proxy to estimate costs and
performance metrics for pumps that are not currently subject to
standards. Table III.2 summarizes the pump categories used as proxies
for the pump categories where DOE had insufficient data to conduct an
analysis. The specific instances where DOE used these proxies are
discussed in more detail in Chapter 2 of this TSD accompanying this
NODA.
Table III.2--Pump Category Similarities Used Throughout Analysis
------------------------------------------------------------------------
Pump category with insufficient data Pump category used as proxy
------------------------------------------------------------------------
Between Bearing........................ End-Suction.
Small Vertical In-Line................. In-Line.
Radially Split Horizontal.............. Radially Split Vertical.
Vertical Turbine....................... Submersible Turbine.
End Suction 1200 rpm................... End-Suction 1800 rpm and 3600
rpm.
In-Line 1200 rpm....................... In-Line 1800 rpm and 3600 rpm.
------------------------------------------------------------------------
Additionally, to make use of older performance data, DOE assumed
that for pumps that are not currently subject to standards, performance
data obtained during the 2014 pumps negotiations would provide an
accurate summary of the performance of these pump models on the market
today.
Issue 19: If DOE's assumptions are not appropriate, DOE requests
updated shipments and performance data for BB, SVIL, RSH, and VT pumps.
DOE also requests updated shipments and performance data for pumps sold
at a specific speed of 1,200 rpm and for ST pumps with a bowl diameter
greater than 6 inches.
Constant-Load and Variable-Load Pumps
In the analysis for the January 2016 Final Rule, DOE conducted one
analysis to encompass both CL and VL equipment classes. 81 FR 4368,
4382. Constant-load pumps are sold without controls and variable-load
pumps are sold with controls. 10 CFR 431.466. Since only one analysis
was performed for both constant- and variable-load pump classes, the
standards for these classes are the same. Setting the PEI metric in
this way was intended to incentivize manufacturers to sell pumps with
controls as an alternative to hydraulic redesign. As discussed in
chapter 1 of the TSD accompanying this NODA, some stakeholders
requested that DOE establish a separate set of C-values for VL pumps so
that standards for VL pumps could be raised to require that any bare
pumps sold with controls would also meet the PEICL for bare
pump efficiency before adding controls. During manufacturer interviews,
some manufacturers observed that some companies were selling pumps with
controls that do not meet the bare pump standard; however, DOE notes
the current standard is silent as to how a pump distributed into
commerce can meet the energy conservation standard.
DOE is concerned that increasing the standard for VL classes may
increase their cost relative to CL classes. This may result in
equipment class switching, where consumers who would have purchased a
pump with a motor and control may purchase a bare pump or a bare pump
with only a motor in order to reduce their first costs. However, DOE
also acknowledges that sales of pumps with motors and controls do not
seem to have been driven by the option for manufacturers to sell only
into the VL class and instead is limited by market demand.
Issue 20: DOE seeks comment on the likelihood of equipment class
switching or other unintended consequences if DOE were to set a higher
standard for VL equipment classes.
For this NODA, DOE's analysis is consistent with its approach
supporting the January 2016 Final Rule. However, DOE did evaluate VSDs
as a potential technology for reducing energy consumption in this NODA.
This analysis could be applied differently to CL and VL classes in
future rulemaking analyses.
SVILs
As discussed in the April 2022 TP NOPR, stakeholders universally
supported addressing SVILs as part of the commercial and industrial
pump rulemaking. 87 FR 21268, 21275. This support aligns with
recommendations from the Circulators Working group.\13\ (Docket No.
EERE-2016-BT-STD-0004, No. 58, Recommendation #1B at pp. 1-2) However,
during interviews, manufacturers provided conflicting suggestions for
how DOE should conduct its SVIL analysis. One group of manufacturers
suggested evaluating hydraulic redesign only for SVILs,
[[Page 49545]]
similar to the approach taken in the January 2016 Final Rule for IL
pumps. In this case, any new SVIL standards would be consistent with IL
pump standards. A subset of manufacturers viewed this approach as
appropriate since many SVILs are a 4-pole version of a 2-pole IL pump.
Another group of manufacturers suggested that potential SVIL standards
should be equivalent to any future standards for circulator pumps.
Manufacturers expect that the circulators analysis will be based on
motor and controls design options, consistent with recommendations by
the Circulators Working Group to set a standard at EL 2 that would
essentially require a single-speed electronically commutated motor.
(Docket No. EERE-2016-BT-STD-0004, No. 98 Recommendation #1 at p. 1 and
No. 97 at p. 2). In this case, SVILs would be a potentially less
efficient and less costly substitute for circulators. Additionally, DOE
received conflicting feedback on whether circulators and SVILs would
compete with, or act as substitutes for, each other. Some manufacturers
stated that an SVIL would never be substituted for a circulator, while
others said that it was possible.
---------------------------------------------------------------------------
\13\ On February 3, 2016, DOE published its intention to
establish a working group under the Appliance Standards and
Rulemaking Federal Advisory Committee (``ASRAC'') to negotiate a
test procedure and energy conservation standards for circulator
pumps. 81 FR 5658. Throughout this document this working group shall
be referred to as ``the Circulator Pumps Working Group.''
---------------------------------------------------------------------------
Issue 21: DOE requests comment on specific applications for which
SVILs could be used instead of circulators and how an SVIL would need
to be modified for use in these applications.
Issue 22: DOE requests comment on the portion of the SVIL market
whose bare pumps are already subject to DOE's IL pump standards.
Specifically, what portion of SVIL bare pumps are a different pole
version of IL pumps, and what portion of SVIL pumps are a separate
product family?
Issue 23: DOE requests comment on the potential benefits and
drawbacks of setting standards for SVILs that align with circulator
pumps versus setting standards for SVILs that align with IL pumps.
b. Hydraulic Redesign Approach
In this NODA, DOE evaluated hydraulic redesign using the same
approach that it used in the January 2016 Final Rule. 81 FR 4368. In
the January 2016 Final Rule, DOE assumed that hydraulic redesign would
be the only design option used by manufacturers to meet the energy
conservation standard.\14\ 81 FR 4368, 4416. Conversations with
manufacturers indicated that this assumption was appropriate in order
for most pump families to meet the current energy conservation
standard. The conversion costs presented in the January 2016 Final Rule
assumed that every pump not meeting the energy conservation standard
would either be redesigned to just meet the prescribed standard or
removed from the market. However, during interviews, many manufacturers
stated that they redesigned their pumps to be as efficient as possible
with the technology and resources available at the time. DOE analyzed
its Compliance Certification Database (``CCD'') to confirm this
assertion. Table III.3 summarizes the estimated distribution, by
equipment class, over the ELs 2, 3, 4, and 5, as defined in the January
2016 Final Rule. Table III.4 shows the current distribution efficiency
distribution from the CCD, by pump equipment class, over ELs 0, 1, 2
and 3.
---------------------------------------------------------------------------
\14\ Other technologies hydraulic redesign may encompass are
clearances, seals, and other volumetric losses.
Table III.3--Projected Efficiency Distributions by Equipment Class as Presented in the January 2016 Final Rule
----------------------------------------------------------------------------------------------------------------
2016 EL 2016 EL 2016 EL 2016 EL Total
Product class 2 (%) 3 (%) 4 (%) 5 (%) (%)
----------------------------------------------------------------------------------------------------------------
ESCC, 1800......................................................... 52 11 13 24 100
ESCC, 3600......................................................... 27 3 4 67 100
ESFM, 1800......................................................... 39 24 10 27 100
ESFM, 3600......................................................... 44 16 11 29 100
IL, 1800........................................................... 41 11 11 38 100
IL, 3600........................................................... 41 5 12 43 100
ST, 3600........................................................... 46 6 6 43 100
----------------------------------------------------------------------------------------------------------------
Table III.4--CCMS Efficiency Distributions by Equipment Class Using Manufacturer Data from the January 2016
Final Rule Power Bin Distributions
----------------------------------------------------------------------------------------------------------------
NODA EL NODA EL NODA EL NODA EL Total
Product class 0 (%) 1 (%) 2 (%) 3 (%) (%)
----------------------------------------------------------------------------------------------------------------
ESCC, 1800......................................................... 42 6 7 45 100
ESCC, 3600......................................................... 20 3 3 74 100
ESFM, 1800......................................................... 32 17 8 43 100
ESFM, 3600......................................................... 29 8 10 53 100
IL, 1800........................................................... 33 8 8 52 100
IL, 3600........................................................... 36 1 10 52 100
ST, 3600........................................................... 47 5 4 44 100
----------------------------------------------------------------------------------------------------------------
The hydraulic redesign approach was conducted in the same manner as
the January 2016 Final Rule's analysis. 81 FR 4368, 4387. (See also
Chapter 5 of the January 2016 Final Rule TSD, EERE-2011-BT-STD-0031-
0056, pp. 5-30 to 5-42)
For currently regulated pumps, DOE set the baseline efficiency at
the standard. In the January 2016 Final Rule, the pumps energy
conservation standard was set at EL 2 for all equipment classes except
for RSV pumps and ST pumps with a specific speed of 1,800 rpm. 81 FR
4368, 4369
[[Page 49546]]
and 4386. Standards for RSV pumps and ST pumps with a specific speed of
1,000 rpm were set at baseline, or EL 0. Id. DOE did not redefine
efficiency levels for those pumps whose standard was set at EL 2 for
this NODA; instead, DOE shifted ELs 2 through 5 so that EL 2 became EL
0 (or baseline) in this NODA analysis. The new nomenclature is
summarized in Table III.5 and is used in the rest of this NODA and in
the TSD accompanying this NODA. EL 1, EL 2, and EL 3 have the same C-
values as EL 3, EL 4, and EL 5, respectively, as presented in the
January 2016 Final Rule.
Table III.5--Efficiency Level Nomenclature Changes for Pumps Currently
Subject to Standards
------------------------------------------------------------------------
January 2016 Final Rule efficiency
level Current NODA efficiency level
------------------------------------------------------------------------
EL 0...................................
EL 1...................................
EL 2................................... EL 0 (Baseline).
EL 3................................... EL 1.
EL 4................................... EL 2.
EL 5................................... EL 3.
------------------------------------------------------------------------
For pumps that were not analyzed in the January 2016 Final Rule,
DOE defined new efficiency levels based on C-values from pump
performance data. DOE had model level performance data available for
some BB, VT, and SVIL pumps. DOE did not have data available for pumps
with nominal speeds of rotation at 1,200 rpm, RSH pumps, or ST pumps
with bowl diameters greater than 6 inches. For this reason, DOE did not
develop C-values for these pump categories in this analysis.
DOE developed preliminary C-values for BB and VT pumps using the
same procedure used in the January 2016 Final Rule. (See Chapter 5 of
the January 2016 Final Rule TSD, EERE-2011-BT-STD-0031-0056, pp. 5-15
to 5-16) Each efficiency level corresponded to a percentile of pump
performance. The C-value calculated for the efficiency level was the C-
value for the minimally compliant pump at the prescribed performance
percentile.
DOE set the baseline for pumps not currently subject to standards
at the 5th percentile of pump performance, just as was done for pumps
in the January 2016 Final Rule. (See Chapter 5 of the January 2016
Final Rule TSD, EERE-2011-BT-STD-0031-0056, pp. 5-16 to 5-19) The
reasons for using the 5th instead of the 0th percentile are discussed
in Chapter 5, section 5.8.6 of the January 2016 Final Rule TSD. (EERE-
2011-BT-STD-0031-0056)
Conversion costs are based on those used in the January 2016 Final
Rule, manufacturer interviews, data from the DOE CCD, and data
collected during the 2014 pump negotiations.\15\ 81 FR 4368, 4388. A
more detailed description of the development of these costs is included
in chapter 2 of the TSD accompanying this NODA. As stated previously,
DOE assumed that hydraulic redesign did not increase the MPC of pumps
but may consider MPC increases in future analyses. The estimated total
conversion costs and estimated per model conversion costs for pumps
currently subject to standards are summarized in Table III.6 and Table
III.7, respectively. Estimated total conversion costs and estimated per
model conversion costs for pumps not currently subject to standards are
summarized in Table III.8 and Table III.9, respectively. Based on
conversations with manufacturers, the per model costs are higher than
those estimated in the January 2016 Final Rule. The conversion costs
are used as inputs to the manufacturer impact analysis, presented in
section III.C.4 of this document. As previously discussed, DOE
accounted for conversion costs in the LCC in the January 2016 Final
Rule but DOE has not conducted an LCC for this NODA.
---------------------------------------------------------------------------
\15\ The data collected in the 2014 pump negotiations is
described in detail in the 2016 final rule TSD (see Chapter 5 for
the January 2016 Final Rule TSD, EERE-2011-BT-STD-0031-0056, pp. 5-6
to 5-8).
---------------------------------------------------------------------------
Due to a lack of performance data for the pumps that were not
analyzed in the January 2016 Final Rule, DOE was unable to conduct the
national energy savings analysis using the C-values developed for this
NODA and relied instead on the proxy equipment classes that were
analyzed in the January 2016 Final Rule discussed in section III.C.3 of
this document. As a result, the national energy savings associated with
each EL analyzed may not directly correspond to the manufacturer
impacts associated with each EL. DOE would address this inconsistency
in any future analyses.
Table III.6--Estimated Total Conversion Costs for Currently Regulated Pumps
----------------------------------------------------------------------------------------------------------------
Class EL 1 EL 2 EL 3
----------------------------------------------------------------------------------------------------------------
ESCC............................................................ $28,771,000 $97,667,000 $177,414,000
ESFM............................................................ 65,068,000 204,491,000 390,974,000
IL.............................................................. 38,456,000 78,965,000 148,440,000
ST.............................................................. 42,046,000 106,922,000 169,737,000
----------------------------------------------------------------------------------------------------------------
Table III.7--Estimated per Model Conversion Costs for Currently Regulated Pumps
----------------------------------------------------------------------------------------------------------------
Class EL 1 EL 2 EL 3
----------------------------------------------------------------------------------------------------------------
ESCC............................................................ $167,000 $235,000 $301,000
ESFM............................................................ 167,000 235,000 301,000
IL.............................................................. 201,000 283,000 363,000
ST.............................................................. 203,000 288,000 374,000
----------------------------------------------------------------------------------------------------------------
[[Page 49547]]
Table III.8--Estimated Total Industry Conversion Costs for Not Currently Regulated Pumps
----------------------------------------------------------------------------------------------------------------
Pump category EL 1 EL 2 EL 3 EL 4 EL 5
----------------------------------------------------------------------------------------------------------------
BB.............................. $3,356,000 $14,057,000 $26,832,000 $47,273,000 $85,095,000
VT.............................. 252,000 988,000 1,774,000 3,122,000 5,625,000
ES.1200......................... 4,253,000 12,291,000 21,547,000 38,884,000 60,316,000
IL.1200......................... 767,000 2,782,000 4,126,000 7,284,000 11,279,000
SVIL............................ 1,055,000 4,419,000 8,461,000 14,941,000 26,917,000
----------------------------------------------------------------------------------------------------------------
Table III.9--Estimated per Model Conversion Costs for Not Currently Regulated Pumps
----------------------------------------------------------------------------------------------------------------
Pump category EL 1 EL 2 EL 3 EL 4 EL 5
----------------------------------------------------------------------------------------------------------------
BB.............................. $156,000 $245,000 $275,000 $388,000 $498,000
VT.............................. 105,000 165,000 185,000 260,000 335,000
ES.1200 \16\.................... 105,000 165,000 185,000 260,000 335,000
IL.1200......................... 107,000 149,000 167.000 260,000 301,000
SVIL............................ 101,000 159,000 179,000 253,000 325,000
----------------------------------------------------------------------------------------------------------------
Issue 24: DOE requests shipment and performance data for (1) pumps
with a nominal speed of rotation at 1,200 rpm; (2) RSH pumps; and (3)
ST pumps with bowl diameters greater than 6 inches.
---------------------------------------------------------------------------
\16\ ES.1200 and IL.1200 refer to end suction and in-line pumps
with nominal speeds of 1,200 rpm.
---------------------------------------------------------------------------
Issue 25: DOE requests comment on its conversion cost approach for
evaluating hydraulic redesign.
c. Motors and Controls Approach
The January 2016 Final Rule engineering analysis evaluated one
representative configuration per equipment class. For this NODA
analysis, DOE instead selected 3 representative units per equipment
class to assess motor and control technologies and their effect on the
efficiency of a pump as measured by the DOE test procedure. These
representative units are described by head flow pairings. The three
representative units were selected to cover the most common head and
flow areas in a given equipment class based on unit shipments, which
were determined from unit performance and shipment data DOE collected
during the 2014 pumps negotiations. The process of selecting
representative units is described in more detail in chapter 2 of the
TSD accompanying this NODA.
As discussed in section III.C.2.a of this document, DOE assumed no
hydraulic redesign would be conducted if motors and controls were used
to meet a potential new energy conservation standard. Therefore, DOE
assumed that the baseline for each representative unit is a minimally
compliant pump according to the current pump standard and the current
DOE electric motor standards summarized in Table 5 of 10 CFR 431.25,
effective as of June 1, 2016. For pumps currently subject to standards,
PEI is equal to 1. For pumps not currently subject to standards, DOE
used the preliminary EL 0 C-value for all PEI calculations, which means
that pumps not currently subject to standards were assumed to have a
PEI of 1.
DOE defined the efficiency levels for the motors and controls
approach based on the technologies applied to the representative unit.
DOE analyzed single-speed induction motors, improved single-speed
induction motors, and VSDs for pumps larger than 1 hp. Therefore, each
representative unit had three efficiency levels: baseline (EL 0) with a
bare pump paired to a minimally compliant single-speed induction motor,
EL 1 with the same bare pump paired to a more efficient single-speed
induction motor, and EL 2 with the same configuration as EL 1 paired
with a VSD. These efficiency levels are consistent with the efficiency
levels used for SVIL pumps except DOE included electronically
commutated motors (``ECM'') as a technology for SVILs. DOE has
tentatively determined that ECMs are not produced at hp ratings large
enough for commercial industrial pumps. DOE maintained similar
efficiency levels across SVILs and larger pumps to ensure consistency
in any potential standards. The efficiency levels for all pumps are
summarized in Table III.10.
Table III.10--Motor and Controls Approach Efficiency Level Summary
----------------------------------------------------------------------------------------------------------------
Pump category EL 1 EL 2 EL 3 EL 4
----------------------------------------------------------------------------------------------------------------
Pumps Larger Than 1 HP......... Single-speed Improved single- VSD ..................
induction motor. speed induction
motor.
SVILs.......................... Single-speed Improved single- ECM................ VSD
induction motor. speed induction
motor.
----------------------------------------------------------------------------------------------------------------
The motor and controls approach evaluated MPCs with data from the
prior standards rulemaking, electric motor teardowns, and VSD
teardowns. The analysis evaluated efficiency with pump performance
data, motor efficiency data, and default VSD performance from the DOE
pumps test procedure.
Results from this analysis are not used in any of the downstream
analyses in this NODA but could be considered in future analyses if the
technology options pass the screening criteria. Additional analysis
details and results are included in chapter 2 of the TSD accompanying
this NODA.
Issue 26: DOE requests comment on its approach for evaluating pump
efficiency and costs with the addition of advanced motors and/or VSDs
for pumps larger than 1 hp.
Issue 27: DOE requests comment on its approach for evaluating pump
efficiency and costs with the addition of
[[Page 49548]]
advanced motors and/or VSDs for SVILs.
For future analyses, DOE may choose to convert MPCs to MSPs using
manufacturer markups. DOE has tentatively determined that the markups
used in the 2016 analysis and summarized in Table III.11 remain
accurate. DOE has used similar assumptions between classes, as
discussed in section III.C.2.a of this document, to estimate markups
for pump classes not currently subject to standards.
Table III.11--Industry-Average Markups by Pump Category
--------------------------------------------------------------------------------------------------------------------------------------------------------
Equipment class group
Efficiency level ------------------------------------------------------------------------------------------
ESCC ESFM IL ST BB VT SVIL
--------------------------------------------------------------------------------------------------------------------------------------------------------
EL 0......................................................... 1.387 1.380 1.472 1.372 1.330 1.350 1.425
EL 1......................................................... 1.387 1.387 1.472 1.397 1.368 1.369 1.462
EL 2......................................................... 1.387 1.387 1.472 1.397 1.380 1.372 1.472
EL 3......................................................... 1.387 1.387 1.472 1.397 1.387 1.397 1.472
--------------------------------------------------------------------------------------------------------------------------------------------------------
EL 4......................................................... N/A 1.387 1.397 1.472
EL 5......................................................... 1.387 1.397 1.472
--------------------------------------------------------------------------------------------------------------------------------------------------------
Issue 28: DOE requests comment on the accuracy of the manufacturer
markups presented in Table III.11.
2. National Energy Savings
DOE estimated national energy savings for hydraulic redesign only.
DOE is not assessing national energy savings for the advanced motor
technology option given the concurrent electric motor rulemaking noted
in section III.B.2 of this document. DOE acknowledges that the
potential national energy savings resulting from a VSD technology
option could be substantially higher than for any hydraulic redesign
efficiency level if such a technology option could be successfully
implemented. However, DOE did not estimate national energy savings for
this technology option given the significant hurdles discussed in
section III.B.3 of this document, as well as current lack of
information on how to factor some of these issues into the analysis
(specifically, the potential inability of the supply chain to meet
required demand as discussed in section III.B.3.a of this document, as
well as the potential energy use impacts discussed in section III.B.3.c
of this document.).
In order to estimate national energy savings from hydraulic
redesign, DOE first conducted an energy use analysis and a shipments
analysis, which are described in the following sections.
a. Energy Use Analysis
To conduct the energy use analysis for the current scope of pumps,
DOE relied primarily on the methodology, efficiency levels, and energy
use inputs from the January 2016 Final Rule (assuming EL 2 from the
January 2016 Final Rule is now EL 0, and EL 5 is now EL 3, as discussed
previously). Consumer inputs to the energy use analysis are based on
operational demands that are independent of the pump's efficiency,
while equipment inputs to the analysis are based on the efficiency of
the pump. Consumer inputs include the consumer duty point (defined by
the flow and head), annual load profile, and annual operating hours.
For this NODA, DOE updated the energy use analysis based on efficiency
distributions from the CCD and integration of a load profile from the
January 2016 Final Rule VSD consumer subgroup analysis with revised
load profile weighting. Further details can be found in chapter 3 of
the TSD accompanying this NODA.
For pumps not currently subject to standards, DOE relied on proxy
pump classes within the current scope of pumps, with the range and
frequency of horsepower bins constrained based on data collected in
manufacturer interviews. See Table III.12 of this document. The sample
weights (sector, application, and power bin correlations) were also
developed based on the proxy classes. For these pumps, DOE evaluated
five (5) levels of hydraulic redesign (ELs 0-5), consistent with those
analyzed for the proxy pump categories in the January 2016 Final Rule.
Table III.12--Equipment Class Substitutes for Pumps Not Currently
Subject to Standards
------------------------------------------------------------------------
Equipment class not
currently subject to Substitute equipment Additional
standards class constraint
------------------------------------------------------------------------
ESCC, 1200.................. ESCC, 1800. ....................
ESFM, 1200.................. ESFM, 1800. ....................
IL, 1200.................... IL, 1800. ....................
BB \a\...................... ESCC, 1800.......... Above power bin 4
(>10.53 HP).
SVIL........................ IL, 1800 and IL, Lowest power bin
3600. only (1-1.79 HP).
VT.......................... VT-S, 3600. ....................
------------------------------------------------------------------------
\a\ Where the design speed is not specified, the equipment category
represents aggregated design speeds at 1200, 1800, and 3600 rpm.
In addition, as discussed in chapter 1 of the TSD accompanying this
NODA, NEEA suggested that DOE re-evaluate the load profiles used in its
analysis. DOE undertook two sensitivities by conducting the energy use
analysis using: (1) DOE's load profiles with BEP offset from NEEA and
(2) NEEA load profiles with no BEP offset. This sensitivity is
discussed in appendix 3A of the TSD accompanying this NODA.
Issue 29: DOE seeks model level performance data for all pumps not
currently subject to standards as well as RSV pumps.
b. Shipments Analysis
In the shipments analysis for the January 2016 Final Rule, DOE
developed shipment projections for pumps and, in turn, calculated
equipment stock from 2020 through 2049, using the 2012 shipment
estimates
[[Page 49549]]
from the Hydraulics Institute (Docket EERE-2013-BT-NOC-0039-0068). To
project pump shipments, DOE relied primarily on Annual Energy Outlook
2014 forecasts.
For this NODA, DOE based the shipments analysis on the methodology
used for the January 2016 Final Rule. DOE updated the AEO trends on
which the shipment growth was based to reflect the most recent AEO--and
for pumps not currently subject to standards, DOE used initial year
shipments data from 2012, as discussed in section II.A. of this
document. DOE projected shipments for the period 2028-2057. For more
details on the shipments methodology, refer to chapter 4 of the TSD
accompanying this NODA.
Issue 30: DOE seeks comment on the total shipments of pump
categories not currently subject to standards as well as RSV pumps.
c. National Energy Savings
To calculate national energy savings over the lifetime of equipment
shipped from 2028-2057, DOE relied on the energy use inputs and
shipments analysis discussed previously and added data reflecting the
penetration of VSDs in the no-new-standards case and standards cases
starting at 18.5% in 2021, with an additional 0.67% penetration per
year. See chapter 5 of the TSD accompanying this NODA for more details
on DOE's derivation of these numbers. Although DOE did not analyze RSVs
directly in the energy use and shipments analysis in this NODA or the
2016 Final Rule, due to lack of available data, DOE added scaler
factors in the national energy savings analysis to account for
potential energy savings from these pumps. These factors were based on
a consideration of the distribution of power bins and efficiencies
obtained from DOE's CCMS data. Refer to chapter 5 of the TSD
accompanying this NODA for more detail. Table III.13 shows the full
fuel cycle results.
DOE notes that this NES analysis relies on a technology option that
DOE has not yet determined would be technologically feasible or would
pass the screening analysis as a result of the issues discussed in
section III.B of this document. In addition, as discussed in the
previous sections, for pumps not currently subject to standards, the
analysis relies on efficiency levels and data inputs from the 2016
rulemaking and proxy equipment classes. For RSVs, the analysis relies
on scalers based on proxy class assumptions, and only includes two
efficiency levels, baseline and max-tech. For both pumps not currently,
and currently, subject to standards, the NES analysis does not account
for the potential loss of utility, as discussed in section III.B.1 of
this document, which could reduce savings. In addition, DOE does not
have robust information on a nationally representative sample of load
profiles for pumps across the United States. DOE acknowledges that
while load profile selection could significantly impact energy savings
estimates for variable-speed drives if analyzed, it does not
significantly impact results for ELs based on hydraulic redesign. This
can be seen in the sensitivity conducted based on NEEA load profiles,
which results on average in increased NES of only 1 to 2 percent for
TSLs 1 and 2. The full results for the sensitivity are shown in
appendix 5A of the TSD accompanying this NODA.
For all of these listed reasons, the savings in Table III.13 should
be viewed as an order-of-magnitude estimate for savings across
different equipment categories rather than an indication of a specific
outcome should a full analysis be conducted. As noted previously, DOE
has not conducted an LCC or national net present value analysis for
this NODA; such analyses would be assessed, if needed, along with the
manufacturer impact analysis (discussed in section III.C.4 of this
document) when determining whether new or amended standards would be
economically justified at the considered levels, should any considered
technology options pass the screening analysis.
Table III.13--Estimates of Cumulative Full-Fuel-Cycle National Energy Savings (Quads) by TSL
[30 years of shipments]
----------------------------------------------------------------------------------------------------------------
Trial standard level *
Equipment class --------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Quads **
----------------------------------------------------------------------------------------------------------------
Currently Subject to Standards:
ESCC, 1800..................................................... 0.03 0.07 0.12 0.12 0.12
ESCC, 3600..................................................... 0.04 0.11 0.21 0.21 0.21
ESFM, 1800..................................................... 0.08 0.22 0.34 0.34 0.34
ESFM, 3600..................................................... 0.01 0.03 0.05 0.05 0.05
IL, 800........................................................ 0.04 0.08 0.13 0.13 0.13
IL, 3600....................................................... 0.01 0.01 0.02 0.02 0.02
RSV............................................................ 0.21 0.21 0.21 0.21 0.21
ST, 3600....................................................... 0.08 0.17 0.23 0.23 0.23
--------------------------------------------
Sub-Total.................................................. 0.50 0.89 1.31 1.31 1.31
Not Currently Subject to Standards:
BB............................................................. 0.00 0.01 0.02 0.03 0.04
ESCC, 1200..................................................... 0.00 0.01 0.01 0.02 0.02
ESFM, 1200..................................................... 0.00 0.00 0.00 0.01 0.01
IL, 1200....................................................... 0.00 0.00 0.00 0.00 0.01
SVIL........................................................... 0.00 0.00 0.00 0.00 0.00
VT............................................................. 0.00 0.00 0.01 0.01 0.01
--------------------------------------------
Sub-Total.................................................. 0.01 0.03 0.04 0.07 0.10
--------------------------------------------
[[Page 49550]]
Total.................................................. 0.51 0.92 1.35 1.38 1.40
----------------------------------------------------------------------------------------------------------------
* Trial Standard Levels (``TSLs'') refer to standards case scenarios. In this analysis, each TSL corresponds to
the same EL for each equipment category (i.e., TSL 1 includes EL 1 for each pump category), with a few
exceptions. For pumps currently subject to standards, DOE only examined 3 ELs; as such the results for TSL 4
and TSL 5 for those pumps are equivalent to those for TSL3. In addition, for the RSV class, which has models
only at EL 0 and EL 3, TSL 1 and TSL 2 correspond to EL 3. Results for each TSL account for the base case
efficiency distribution shown in Table III.4. DOE assumes that all pumps below a given EL ``roll-up'' to that
EL, and all pumps at ELs above the given EL remain unchanged.
** The results are rounded to two decimals. All values showing 0.00 are non-zero values, with savings at the
thousandths place or less.
Issue 31: DOE requests comment on the applicability of load
profiles found in the NEEA data to the full sample of pumps in this
analysis.
3. Manufacturer Impact Analysis
DOE has conducted an initial analysis on the potential impacts to
manufacturers resulting from the analysis discussed in this NODA. In
developing its analysis of the industry, DOE began with the financial
parameters used in the January 2016 Final Rule. These financial
parameters were, prior to the January 2016 Final Rule and during
interviews preceding this rulemaking, vetted by multiple manufacturers
and are the most robust equipment-specific estimates that are publicly
available. DOE noted that tax rate estimates from before 2018 are not
relevant for modeling future cash-flows due to the Tax Cuts and Jobs
Act of 2017,\17\ which was signed into law in December 2017 and changed
the maximum Federal corporate tax rate from 35 percent to 21 percent.
Table III.14 reflects these initial financial parameters.
---------------------------------------------------------------------------
\17\ See www.congress.gov/115/bills/hr1/BILLS-115hr1enr.pdf.
Table III.14--Initial Financial Metrics
------------------------------------------------------------------------
Financial metric Initial estimate
------------------------------------------------------------------------
Tax Rate (% of Taxable Income) \18\............ 21.0
Working Capital (% of Revenue)................. 18.6
SG&A (% of Revenue)............................ 21.6
R&D (% of Revenues)............................ 1.6
Depreciation (% of Revenues)................... 2.6
Capital Expenditures (% of Revenues)........... 2.4
Net Property, Plant, and Equipment (% of 15.0
Revenues).....................................
------------------------------------------------------------------------
During interviews, manufacturers generally commented that their
markups were similar to what was presented by the interviewers (see
Table III.11), taking into account different product lines and
distribution channels. However, manufacturers did state that markups
did not change substantially across efficiency levels and that they
were largely unable to recoup investments made to comply with the
existing energy conservation standards. Accordingly, DOE proceeded with
the previously adopted standard level estimated markup across all ELs--
which is EL 0 in Table III.11. For pumps not currently subject to
standards, DOE assumed that BB pumps and ESFM pumps, ST and VT pumps,
and IL and SVIL pumps have respectively similar markups. DOE did not
include RSV pumps due to a lack of available data.
---------------------------------------------------------------------------
\18\ The tax rate used in the 2016 Final Rule was 32 percent.
---------------------------------------------------------------------------
Initial financial parameters, estimates of product markups and
conversion costs (discussed in III.C.2 of this document), shipment
estimates (discussed in III.C.3.b of this document), and the MPC
estimates--adjusted for inflation from the January 2016 Final Rule--
form the primary inputs for the Government Regulatory Impact Model
(``GRIM'') that DOE uses to assess impacts of industry and industry
subgroup cashflows. As in the January 2016 Final Rule, the MPC
estimates remain the same across efficiency levels. In the tables that
follow, DOE compares the GRIM results for each evaluated EL against the
results for the no-new-standards case, in which energy conservation
standards are not established or amended. In this preliminary GRIM,
consistent with the NES, DOE only considers efficiency levels that can
be accomplished by hydraulic redesign--corresponding to EL 1 to EL 3
for currently in-scope pumps and EL 1 to EL 5 for pumps that are not
currently subject to standards. Results examine a single markup
scenario where manufacturers are assumed to preserve the same gross
margin percentage in the standards cases as in the no-new-standards
case. Table III.18 presents the results for the entire scope considered
in this NODA, whereas Table III.19 and Table III.20 present results for
pumps not currently, and currently, subject to standards, respectively.
These results are similar to the flat markup scenario results presented
in the January 2016 Final Rule, which are included in Table III.21.
Further details on the manufacturer impact analysis are included in
chapter 6 of the TSD accompanying this NODA.
[[Page 49551]]
Table III.18--Preliminary Manufacturer Impact Analysis for Pumps Not Currently, and Currently, Subject to Standards--Preservation of Gross Margin
Percentage Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-new- ----------------------------------------------------------------
standards case 1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV..................................... 2020$ MM.................... 237.5 144.92 (44.1) (283.1) (910.8) (961.9)
Change in INPV........................... 2020$ MM.................... .............. (92.6) (281.6) (520.6) (1,148.2) (1,199.3)
%........................... .............. (39.0) (118.6) (219.2) (483.5) (505.1)
Product Conversion Costs................. 2020$ MM.................... .............. 126.9 360.3 654.23 687.3 740.2
Capital Conversion Costs................. 2020$ MM.................... .............. 57.7 164.0 297.6 315.4 342.8
--------------------------------------------------------------------------------------------------------------
Total Investment Required................ 2020$ MM.................... .............. 184.6 524.2 951.8 1,002.7 1,083.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parenthesis indicate negative numbers.
Table III.19--Preliminary Manufacturer Impact Analysis for Pumps Currently Subject to Standards--Preservation of
Gross Margin Percentage Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-new- --------------------------------------
standards case 1 2 3
----------------------------------------------------------------------------------------------------------------
INPV.............................. 2021$ MM............. 211.2 123.4 (51.5) (274.1)
Change in INPV.................... 2021$ MM............. .............. (87.8) (262.7) (485.3)
%.................... .............. (41.6) (124.1) (229.8)
Product Conversion Costs.......... 2021$ MM............. .............. 120.3 336.9 611.7
Capital Conversion Costs.......... 2021$ MM............. .............. 54.1 151.3 274.8
-----------------------------------------------------------------------------
Total Investment Required......... 2021$ MM............. .............. 174.4 488.2 886.5
----------------------------------------------------------------------------------------------------------------
* Values in parenthesis indicate negative numbers.
** EL 3, arrived at in TSL 3, represents max-tech for pumps currently subject to standards.
Table III.20-- Preliminary Manufacturer Impact Analysis for Pumps Not Currently Subject to Standards--Preservation of Gross Margin Percentage Markup
Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units No-new- ----------------------------------------------------------------
standards case 1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV..................................... 2021$ MM.................... 26.28 21.35 7.4 (9.0) (37.4) (88.5)
Change in INPV........................... 2021$ MM.................... .............. (4.9) (18.9) (35.3) (63.7) (114.8)
%........................... .............. (18.8) (71.8) (134.1) (242.3) (436.9)
Product Conversion Costs................. 2021$ MM.................... .............. 6.5 23.4 42.5 75.6 128.5
Capital Conversion Costs................. 2021$ MM.................... .............. 3.7 12.6 22.8 40.6 68.0
--------------------------------------------------------------------------------------------------------------
Total Investment Required................ 2021$ MM.................... .............. 10.2 36.0 65.3 116.2 196.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parenthesis indicate negative numbers.
Table III.21--2016 Final Rule Manufacturer Impact Analysis--Flat Markup Scenario
[Equivalent to preservation of gross margin scenario]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level (old rulemaking)
Units No-new- ----------------------------------------------------------------
standards case 1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV..................................... 2014$ MM.................... 120.0 110.3 80.5 20.9 (86.1) (229.0)
Change in INPV........................... 2014$ MM.................... .............. (9.7) (39.5) (99.1) (206.1) (349.0)
%........................... .............. (8.1) (32.9) (82.6) (171.8) (290.9)
Product Conversion Costs................. 2014$ MM.................... .............. 16.6 56.9 123.1 234.0 380.8
Capital Conversion Costs................. 2014$ MM.................... .............. 6.2 24.3 54.0 103.9 169.8
--------------------------------------------------------------------------------------------------------------
Total Investment Required................ 2014$ MM.................... .............. 22.8 81.2 177.2 337.9 550.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Values in parenthesis indicate negative numbers.
** TSL 2 represents the adopted standard level.
Issue 32: DOE requests comment on the financial parameters used,
the product markups used, whether DOE's assumption that markups do not
or will not (in the case of standards being applied) change across
efficiency levels, the conversion costs used, what--if any--additional
markup scenarios should be considered, and the estimated industry
impacts presented in this analysis.
[[Page 49552]]
a. Small Business Impacts
Throughout the rulemaking process, DOE will examine the impacts of
potential energy conservation standards on small business manufacturers
and how those impacts may be different or disproportionate to the
industry as a whole. Further details on the small business industry
subgroup analysis are included in chapter 6 of the TSD accompanying
this NODA.
Issue 33: DOE requests comment on whether and how small businesses
may be disproportionately affected by amended energy conservation
standards.
IV. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding this NODA
before or after the public meeting, but no later than the date provided
in the DATES section at the beginning of this document. Interested
parties may submit comments, data, and other information using any of
the methods described in the ADDRESSES section at the beginning of this
document.
Submitting comments via www.regulations.gov. The
www.regulations.gov web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
Confidential Business Information (``CBI'')). Comments submitted
through www.regulations.gov cannot be claimed as CBI. Comments received
through the website will waive any CBI claims for the information
submitted. For information on submitting CBI, see the Confidential
Business Information section.
DOE processes submissions made through www.regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that www.regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or postal
mail. Comments and documents submitted via email, hand delivery/
courier, or postal mail also will be posted to www.regulations.gov. If
you do not want your personal contact information to be publicly
viewable, do not include it in your comment or any accompanying
documents. Instead, provide your contact information in a cover letter.
Include your first and last names, email address, telephone number, and
optional mailing address. The cover letter will not be publicly
viewable as long as it does not include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via postal mail
or hand delivery/courier, please provide all items on a CD, if
feasible, in which case it is not necessary to submit printed copies.
No telefacsimiles (``faxes'') will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email two well-marked copies: one copy of the document marked
``confidential'' including all the information believed to be
confidential, and one copy of the document marked ``non-confidential''
with the information believed to be confidential deleted. DOE will make
its own determination about the confidential status of the information
and treat it according to its determination.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
B. Issues on Which DOE Seeks Comment
Issue 1: DOE seeks individual model level data or industry
aggregated data to update its shipment and average horsepower estimate
for pump categories that are currently subject to standards and those
pump categories that are currently not subject to standards.
Issue 2: DOE requests comments on potential benefits or drawbacks
of proposing a change to the test procedure to allow calculation of PEI
for pumps not subject to energy conservation standards.
Issue 3: DOE requests comment on the percentage of basic models
that would be impacted by the following factors if manufacturers were
to redesign their pumps to EL 4 and EL 5 (as presented in the January
2016 Final Rule): (1) need to flatten the pump curve beyond potentially
acceptable levels for the existing market for a given model or any
reported issues with controllability; (2) increased warranty claims;
and (3) increased MPCs for pumps redesigned to higher efficiencies.
Additionally, DOE requests comment on which EL (as presented in the
January 2016 Final Rule) and for which pump classes (or hp ranges)
these issues would first appear.
Issue 4: DOE also seeks comment on the availability of designers
skilled enough to design a pump that can reach EL 4 and EL 5 and be
readily manufactured.
Issue 5: Additionally, DOE requests comment on any other issues
that may prevent manufacturers from redesigning pumps to reach higher
efficiency levels, including other utility issues.
Issue 6: DOE requests comment on the fraction of installations in
which consumers would have to make piping changes as a result of a
change in flange position (as opposed to purchasing another model with
the desired flange
[[Page 49553]]
positions), and the cost of such piping changes.
Issue 7: DOE requests comment on how a standard that requires an
advanced motor to be paired with a bare pump would impact: (1) the bare
pump replacement market; (2) the distributor market and business model;
(3) the repair of pumps rather than their replacement and (4) the
replacement of failed motors with less efficient motors. DOE also
requests feedback on any potential consistency concerns with a standard
that requires an advanced motor to be paired with a bare pump and
current or future energy conservation standards for electric motors.
Issue 8: DOE seeks comment on the frequency with which pump
consumers specify only a single controller brand, as well as on the
number of controller brands typically stocked by a pump manufacturer.
Issue 9: DOE seeks comment on how a VSD requirement for pumps would
impact distributors.
Issue 10: DOE requests comment on whether there would be sufficient
quantity and quality of VSDs available if there were a VSD requirement
for pumps.
Issue 11: DOE seeks comment on possible methods to retain a
replacement market for bare pumps while preventing a loophole where
bare pumps could be purchased for current and new installations.
Issue 12: DOE seeks comment on the frequency with which customers
would replace an inverter-only motor and control with an induction
motor upon the end of the lifetime of the motor originally purchased
with the pump.
Issue 13: DOE seeks comment on how bare pump repair frequency may
change if customers delay purchasing a more expensive pump with motor
and controls. For example, in its DPPP motors analysis, DOE assumed
that in the standards case, a greater percentage of consumers would
repair their pump as compared to the no-new-standards case.
Issue 14: DOE seeks comment on the percentage of pump models that
would be redesigned for controls if they were required to be sold with
them, and of those, what percentage would have worse efficiency in
constant-load applications than the current pump model, and by how much
the efficiency or energy use would be impacted.
Issue 15: DOE seeks comment on the frequency with which customers
who would be required to buy a pump with a VSD would need to add
filters or perform electrical upgrades, and the estimated cost of such
equipment and installation.
Issue 16: DOE seeks comment on the frequency with which customers
might need to re-pipe to accommodate a pump with motor and controls
rather than a drop-in replacement pump, and the estimated cost of re-
piping.
Issue 17: DOE seeks quantitative data on the overall installation
costs of pumps with VSDs compared to bare pumps, as well as any
differences in lifetime or repair and maintenance costs for pumps sold
with VSDs as compared to bare pumps.
Issue 18: DOE requests comment on if or how the five screening
criteria may limit application of hydraulic redesign, advanced motors,
or VSDs as design options in the current rulemaking analysis.
2. Engineering
Issue 19: If DOE's assumptions are not appropriate, DOE requests
updated shipments and performance data for BB, SVIL, RSH, and VT pumps.
DOE also requests updated shipments and performance data for pumps sold
at a specific speed of 1,200 rpm and for ST pumps with a bowl diameter
greater than 6 inches.
Issue 20: DOE seeks comment on the likelihood of equipment class
switching or other unintended consequences if DOE were to set a higher
standard for VL equipment classes.
Issue 21: DOE requests comment on specific applications for which
SVILs could be used instead of circulators and how an SVIL would need
to be modified for use in these applications.
Issue 22: DOE requests comment on the portion of the SVIL market
whose bare pumps are already subject to DOE's IL pump standards.
Specifically, what portion of SVIL bare pumps are a different pole
version of IL pumps, and what portion of SVIL pumps are a separate
product family?
Issue 23: DOE requests comment on the potential benefits and
drawbacks of setting standards for SVILs that align with circulator
pumps versus setting standards for SVILs that align with IL pumps.
Issue 24: DOE requests shipment and performance data for (1) pumps
with a nominal speed of rotation at 1,200 rpm; (2) RSH pumps; and (3)
ST pumps with bowl diameters greater than 6 inches.
Issue 25: DOE requests comment on its conversion cost approach for
evaluating hydraulic redesign.
Issue 26: DOE requests comment on its approach for evaluating pump
efficiency and costs with the addition of advanced motors and/or VSDs
for pumps larger than 1 hp.
Issue 27: DOE requests comment on its approach for evaluating pump
efficiency and costs with the addition of advanced motors and/or VSDs
for SVILs.
Issue 28: DOE requests comment on the accuracy of the manufacturer
markups presented in Table III.11.
Issue 29: DOE seeks model level performance data for all pumps not
currently subject to standards as well as RSV pumps.
Issue 30: DOE seeks comment on the total shipments of pump
categories not currently subject to standards as well as RSV pumps.
Issue 31: DOE requests comment on the applicability of load
profiles found in the NEEA data to the full sample of pumps in this
analysis.
Issue 32: DOE requests comment on the financial parameters used,
the product markups used, whether DOE's assumption that markups do not
or will not (in the case of standards being applied) change across
efficiency levels, the conversion costs used, what--if any--additional
markup scenarios should be considered, and the estimated industry
impacts presented in this analysis.
Issue 33: DOE requests comment on whether and how small businesses
may be disproportionately affected by amended energy conservation
standards.
V. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this
notification of data availability.
Signing Authority
This document of the Department of Energy was signed on August 3,
2022, by Kelly J. Speakes-Backman, Principal Deputy Assistant Secretary
for Energy Efficiency and Renewable Energy, pursuant to delegated
authority from the Secretary of Energy. That document with the original
signature and date is maintained by DOE. For administrative purposes
only, and in compliance with requirements of the Office of the Federal
Register, the undersigned DOE Federal Register Liaison Officer has been
authorized to sign and submit the document in electronic format for
publication, as an official document of the Department of Energy. This
administrative process in no way alters the legal effect of this
document upon publication in the Federal Register.
[[Page 49554]]
Signed in Washington, DC, on August 4, 2022.
Treena V. Garrett,
Federal Register Liaison Officer, U.S. Department of Energy.
[FR Doc. 2022-17074 Filed 8-10-22; 8:45 am]
BILLING CODE 6450-01-P