The regulatory environment around pumps changed significantly in 2011 when the US Department of Energy (DOE) initiated the process of regulating the efficiency of pumps for the first time. The Hydraulic Institute led the effort to organize the pump industry and facilitated the data gathering and standards development required for the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) negotiated energy conservation standard and test procedure for Commercial and Industrial Pumps. Regulation of pump efficiency and the scope thereof will continue in the future and the Hydraulic Institute will continue to lead and organize the pump industry. This page will serve as a resource for interested parties to catch up on and stay up to date with regulatory initiatives related pumps and pumping systems.
For more information regarding HI's activity with the DOE please contact Michael Michaud, Executive Director at mmichaud@Pumps.org or (973) 267-9700 x100.
Members of the Pump Working group include:
DOE will host a public meeting and webinar in at
DOE's Forrestal Building, 1000 Independence Ave S.W. Washington,
To attend the public
meetings please email email@example.com
and visit the following links for more information:
Register for the webinar here.
The Hydraulic Institute (HI) lead the effort to organize the pump industry and facilitated the data gathering and standards development required for the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) negotiated energy conservation standard and test procedure for Commercial and Industrial Pumps (CIP). The proposed CIP rule will eliminate the least efficient 25% of CIPs and includes performance metrics for constant speed equipment with no controls and for variable speed equipment with controls, acknowledging the benefits of the system approach to reducing energy. As a result of the CIP ASRAC negotiations certain pump types were excluded from the proposed rule. One of the excluded pump types is circulator pumps, which are relatively small centrifugal pumps designed for hydronic systems where only pipe friction head must be overcome. The ASRAC negotiation recommended that the HI circulator committee and the energy advocates enter an informal negotiation process to develop a framework that could be presented to the DOE for a separate rulemaking suitable for circulator pumps. Currently the HI circulator committee and advocates are working on defining the following recommendations:
Circulator pump manufacturers and other interested parties should be involved with this informal negotiation which will lead to a separate rule focused on circulator pumps. Please contact Peter Gaydon with any questions and to get involved with the Hydraulic Institute.
On April 29, 2015, HI delegates met with DOE representatives. See the following for more information:
Energy.Gov/ Office of Energy Efficiency and Renewable Energy/ Building Technologies Office announced on April 2nd, that the Department of Energy had published Federal Register notice of proposed rulemakings and public meetings regarding energy conservation standards (80 FR 17826 April 2, 2015) and test procedures (80 FR 17586 April 1, 2015) for commercial and industrial pumps. The notice which was sent out by the DOE provided the following:
If you are interested in participating in the April 29th meeting in Washington, D.C., please contact Naomi Crisall at Hydraulic Institute by email: firstname.lastname@example.org or by telephone: 973-967-9700 x120.
Consensus Reached, But Subject to Approval: The U.S. DOE pump rulemaking negotiations through ASRAC Pump Working Group reached a consensus agreement on June 19, 2014, wrapping up the latest three-day negotiating session. Consensus is defined in a Term Sheet, documenting all of the negotiated positions which includes a summary of the votes for each position that the DOE documented as part of the rulemaking. The next step in the process is for DOE staff to present the Terms Sheet to the next ASRAC meeting, which may be held later in July. With regard to next steps, and according to a U.S. DOE representative, “ASRAC will vote on whether to the approve the negotiated or positions or they could seek additional clarity from the working group. From there, it goes to DOE for inclusion in a 2014 June DOE Term Sheet notice of proposed rulemaking. Even though the positions were negotiated, DOE still has to go through its typical notice-and-comment rulemaking, which typically includes a proposal, comment period, and final rule. DOE fully intends to honor any negotiated positions that are approved by ASRAC, but it needs to meet its statutory obligations for following the correct process when implementing them.”The Hydraulic Institute, and its members on the ASRAC Pump Working Group, will continue to monitor progress as the Terms Sheet moves to ASRAC for approval and then into the statutory process later in 2014. HI Members Updated at June Technical Meeting: A panel session of five (5) HI members who have served on the ASRAC Pump Working Group briefed nearly 130 members of the Hydraulic Institute during the recent HI Technical Meeting held in Charlotte, NC. A copy of the Powerpoint presentation is available that provides insights into the negotiated positions, term sheets and next steps in the DOE pump rulemaking process. An EU update was also provided by Frank Ennenbach, Sulzer Pumps, on the evolving state of pump efficiency regulations in Europe. Members present had an opportunity to ask questions and learn, first hand, of details of the negotiations and final Term Sheet that was agreed upon during the negotiations. Pump Test Procedure to Support DOE Rulemaking: On May 15, 2014 the Hydraulic Institute submitted HI 40.6, “Methods for Rotodynamic Pump Efficiency Testing Standard” to the U.S. DOE for eventual adoption as part of the pump rulemaking process. This standard, a year in the making, has been supported by a team of pump experts within the Hydraulic Institute and was reviewed and approved by HI Standards Voting Representatives (SVRs) leading up to its release to DOE. This standard will be available for sale, in its current “draft” form, beginning no later than July 31st, 2014 on the HI website. Details will be announced to members and to non-members once the standard is ready for publication and sale. According the a U.S. DOE representative, “The rulemaking process for the test procedure is typically conducted one step ahead of the accompanying standards rule, meaning that a formal proposal is published in advance of proposed standards. The ASRAC pump working group has been operating under a schedule that would permit publication of proposed standards before the end of this year, which means a test procedure proposal would be published probably by this fall. DOE would collect comments from the public on that proposal and, provided no amendments to the proposal are needed based on any comments received, DOE would publish the adopted test method in a final rule.”HI will continue to track this issue closely, and will develop a process for reviewing any proposed changes to the current draft version of the standard leading to its eventual final publication later in 2014 or early 2015. Pump Systems Performance Metric (PSPM) Task Force: The Hydraulic Institute's Extended Product Committee has formed the Pump Systems Performance Metric (PSPM) Task Force to support the ASRAC pump working group members in their negotiations with the DOE. This task force has provided immediate technical advice and counsel to the ASRAC PWG members regarding pump system performance metrics, and has focused its attention on reviewing the DOE's PEI Calculator, which will be used by HI Members and the pump industry at large to help determine compliance with pending DOE regulations. This task force has held weekly WebEx meetings and continues to review updates to the PEI Calculator as new versions are released. The task force members have been working closely with Pacific Northwest Laboratory's Research Engineer, Sarah Widder, to ensure the technical accuracy of the PEI Calculator and to offer suggestions for its future use. This task force will also provide content for the Extended Product guideline on how to use the calculator and to describe how it functions. PSPM Task Force meetings are currently held as needed, but no longer on a recurring basis.
At the May 28th and 29th ASRAC Pump Working Group meeting DOE consultants presented extensive material on subjects critical to the next steps and negotiations associated with the evolving pump efficiency rules. These subjects, which involve significant financial analysis, are detailed in the slides that are linked below. The five PowerPoint slide decks in PDF format include:
During the June 10th-11th HI-NAM Manufacturing Summit, in Washington DC, a delegation of HI members will meet with members of the House Energy and Commerce Committee and the Senate Energy and Natural Resources Committee to discuss the DOE rulemaking on pumps. This four-page position paper was developed to help inform members of Congress and the pump industry about the DOE rulemaking...and to address key issues. Download a Copy of The HI Position Paper on the DOE rulemaking to share with members of your staff.
Since January 2011, when the first notice appeared in the Federal Register, the Hydraulic Institute (HI) and its members have been closely tracking the U.S. Department of Energy’s (DOE) plans to regulate efficiency of industrial and commercial pumps. HI has also been advocating for addressing the efficiency of the package of the pump, motor, driver and controls which has been defined by Europump and HI as an “Extended Product.” Energy savings with optimizing “Extended Products” far exceeds what can be obtained by eliminating the least efficient pump products in the market. A summary of HI's positions appear in the January, February, and March issues of Pumps and Systems magazine. For more information, click here. This section of the HI website is designed to share the history of DOE’s regulatory efforts associated with the commercial and industrial pump rulemaking, and provide HI’s testimony, positions and educational materials that have been provided since the beginning of the rulemaking. HI members will continue to benefit from direct engagement in the process, and regular updates during the course of HI meetings. Finally, important standards and guideline writing work is underway within HI’s technical committees associated with the DOE pump efficiency rulemaking. To learn more about HI's extensive initiatives regarding the DOE Pump Efficiency Rulemaking process, click here. For more information regarding HI's Test Lab Approval program, click here. Additional participation is welcome from HI members. If your company is eligible for membership, we invite your inquiry to Mary Silver, Director, Membership and Technology at msilver@Pumps.org or (973) 267-9700 x117.
The DOE rulemaking is currently following two paths. The first is the “traditional” rulemaking, which is based on a significant amount of data gathering, published positions of DOE (such as the “Request for Information,” “Framework,” and “Notice of Proposed Rulemaking” documents) and public meetings allowing comments on their findings, recommendations or positions. The second path, which began on December 18-19, 2013 is a “negotiated rulemaking,” whereby a group of DOE appointed individuals meet on a regular monthly basis in Washington, DC in public meetings to work to reach a consensus on a rulemaking under rules established by the DOE’s Appliance Standards Rulemaking Advisory Committee (ASRAC). A group of HI members has been appointed to the ASRAC Working Group on Pumps, and a schedule of meetings is planned through July 2014 to reach a consensus agreement.
ASRAC Pumps Working Group Roster Schedule of ASRAC Meetings How to Participate in ASRAC Meetings
March 26-27, 2014: ASRAC Pumps Working Group Meeting Presentation "Scope"March 27-28, 2014: ASRAC Pumps Working Group Meeting Presentation "Calculations and Standard Setting"March 4-5, 2014: ASRAC Pumps Working Group Meeting Presentation "Scope"March 4-5, 2014: The U.S. DOE legal staff was asked to comment on the issue of preemption of pumps with regard to state regulations. This document provides a position statement from the DOE in this regard. Read the Preemptive Document Here.
The Department of Energy (DOE) has issued a pre-publication Federal Registernotice of open teleconference/webinar regarding the Appliance Standards and Rulemaking Federal Advisory Committee’s (ASRAC) Commercial and Industrial Pumps Working Group.
January 30-31, 2014:
January 14, 2014: DOE Notice of Open Meeting of ASRAC Pumps Working Group
January 2014: DOE Issues Notice of Open Webinar for the ASRAC Commercial and Industrial Pumps Working Group
The Hydraulic Institute Board of Directors, in a special meeting on February 28, voted overwhelmingly in favor of preserving the current language in the Energy Policy and Conservation Act of 1975, whereby pumps are encompassed by Section 6311(1)(A) of EPCA and state regulation of pumps is preempted by the Federal Statute. The HI Board is opposed to any changes in the current preemption status for pumps.
WebEx Breifing on NAM Summit & HI Government Affairs Committee:
In case you missed the March 5th briefing for HI members, above is the link to help you understand the role of HI's new Government Affairs Committee and reasons that HI members should attend the NAM Manufacturing Summit in Washington, DC on June 10th-11th, 2014.
HI's Government Affairs Initiatives:
Understand the multi-faceted approach that HI is taking to support pump OEMs and other HI members in improving their ability to comply with forthcoming DOE pump efficiency regulations. HI is also taking a pro-active lead in developing new test procedures for DOE's rigorous efficiency rating requirements for pumps, developing a new pump test lab approval program and working on Extended Product and Minimum Efficiency Index (MEI) issues.
Briefing on DOE Rulemaking:
On March 20th HI members received an update on the most recent ASRAC Pump Working Group meeting, held March 4th - 5th in Washington, DC. The Hydraulic Institute continues its efforts to keep members informed on progress with the negotiations to establish a pump efficiency rulemaking. Powerpoint slides and other information can be found here, dealing with: Metrics, Scope, and Preemption issues dicussed at the latest meeting. The next ASRAC meeting will be held March 26th - 27th in Washington, DC, which is open to the public by attending in person or via web conference.
For more information please visit: http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201310&RIN=1904-AC54.
December 18-19, 2013: ASRAC Pumps Working Group Meeting in DC
November 12, 2013: DOE Notice of First ASRAC Commerical and Industrial PumpsWorking Group Meeting
October 24, 2013: DOE Presents at HI Fall Meeting
July 16, 2013: DOE Notice of Intent to Establish ASRAC Negotiated Rulemaking Working Group
May 17, 2013: HI Requests to Pursue Negotiated Rulemaking
May 2, 2013: HI Provides Formal Response to DOE Framework Document
February 26, 2013: DOE Convenes First ASRAC Meeting: Discusses Pumps
February 20, 2013: DOE Framework Hearing in Washington, DC
January 25, 2013: DOE Framework Document