DOE Pump Efficiency Rulemaking
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:
DOE Issues Notice of Proposed Rulemaking Regarding Energy Conservation Standards for Pumps
The U.S. Department of Energy yesterday released its anticipated Notice of Proposed Rulemaking (NOPR) for Energy Conservation Standards for Pumps. This 257 page document is now available for public review and comment. HI intends to respond on behalf of its members, both in writing and at the April 29th Public Hearing.
DOE also announced its plans to hold a public hearing on the NOPR on April 29, 2015 in Washington, DC which will be supported by webinar access as well. As noted by DOE, to participate in the public meeting via webinar, please click here to register. All notices, public comments, public meeting transcripts, and supporting documents associated with this rulemaking are included in Docket No. EERE-2013-BT-TP-0055. DOE’s website gives guidance on how to comment on the rulemaking. The public comment period closes 75 days after publication in the Federal Register. To register for the public hearing click here.
HI intends, as it has done in the past, to organize pump industry input with and through HI members and to submit a summary of consolidated and consensus-based comments to the U.S. DOE. This DOE Rulemaking section of the HI website provides background and a history of HI’s efforts to represent its members throughout the DOE rulemaking process [see below]. To find more information on the DOE rulemaking, including milestones, statutory authority, rulemaking documents, and any other related rulemakings from the DOE, you can also click here.
A copy of the 257 page Notice of Proposed Rulemaking Regarding Energy Conservation Standards for Pumps can be found here.
HI members who have been actively involved in this issue including the HI members on the ASRAC Pump Working Group, along with all HI members who are interested in being involved, are invited to participate in the review of the proposed rulemaking. Any HI member who is interested in actively participating in this review should contact Matt Zolnick, HI Standards Engineer at mzolnick@Pumps.org.
Any interested company can obtain a copy of the referenced HI 40.6 Efficiency Testing for Rotodynamic Pumps standard at www.Pumps.org/HI40-6.
DOE Issues Notice of Proposed Rulemaking (NOPR) for the Test Procedure for Commercial and Industrial Pumps
The U.S. Department of Energy today released the Notice of Proposed Rulemaking (NOPR) for the Test Procedures for Commercial and Industrial Pumps. This 270-page document is now available for public review and comment.
DOE also announced its plans to hold a public hearing on the NOPR on April 29, 2015 in Washington, DC which will be supported by webinar access as well. As noted by DOE, to participate in the public meeting via webinar, please click here to register. All notices, public comments, public meeting transcripts, and supporting documents associated with this rulemaking are included in Docket No. EERE-2013-BT-TP-0055. DOE's website gives guidance on how to comment on the rulemaking. The public comments period closes 75 days after publication in the Federal Register.
A copy of the 270-page NOPR for the Test Procedures for Commercial and Industrial Pumps can be found here.
HI members that have been actively involved in the creation of HI 40.6 Efficiency Testing for Rotodynamic Pumps, cited and referenced in the NOPR, along with members of the ASRAC Pump Working Group and other HI members involved in Pump Efficiency Rating (PER) metric analysis will work to review the NOPR and be prepared to submit comments to DOE during the hearing on April 29, 2015. Any HI member who is interested in actively participating in this review should contact Matt Zolnick, HI Standards Engineer at mzolnick@Pumps.org.
Any interested company can obtain a copy of the referenced HI 40.6 standard at www.Pumps.org/40-6.
Over 250 members of the Hydraulic Institute met in St. Petersburg, Florida during HI's 98th Annual meeting, anticipating release of the U.S. Department of Energy rulemaking on industrial and commercial pumps. However, at the time of the meeting, the NOPR was not yet released by the DOE. It is the understanding of the Hydraulic Institute that the draft NOPR was submitted on November 3, 2014 to the White House OMB, Office of Information and Regulatory Affairs (OIRA) for internal departmental review.
The session devoted to review of the NOPR was then changed to provide for a briefing from a senior staff member of NEMA who reviewed their experiences in dealing with this stage of DOE regulatory review, from the perspective of the motor industry, which is new to the pump industry. The insights gained were helpful to HI members in better understanding the regulatory and enforcement process within DOE and will help them prepare for the release of the anticipated NOPR.
HI Member Briefing during HI Fall Meeting in St. Louis: HI members were briefed at the recent Fall meeting in St. Louis, MO on the DOE rulemaking progress. Participating in the briefing were the following HI delegates to the ASRAC Pump Working Group: Greg Case, Senior VP of Research & New Product Development, TACO, Inc., Greg Towsley, LEED AP BD+C, Director, Regulatory & Technical Affairs, Grundfos USA, Mark Handzel, V.P. Regulatory Affairs, Xylem Inc. - Applied Water Systems, and Bob Barbour, VP of New Business Development, TACO, Inc. The next key milestone, anticipated at the end of 2014 or early 2015, is the Notice of Proposed Rulemaking (NOPR). HI members are urged to remain alert to the short comment period once the NOPR is published. The presentation may be found below to help keep HI members and other pump OEMs informed on the DOE rulemaking.
DOE Pump Efficiency Rulemaking Update Presentation - Fall 2014 Meeting (PDF)
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
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
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.
Special Information regarding the May 28th and 29th ASRAC Working Group Meeting in Washington DC: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.
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.
March 26-27 ASRAC Pumps Working Group Meeting Presentation "Calculations and Standard Setting"
March 4-5 ASRAC Pumps Working Group Meeting Presentation "Scope"
March 4-5: 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 Register notice of open teleconference/webinar regarding the Appliance Standards and Rulemaking Federal Advisory Committee’s (ASRAC) Commercial and Industrial Pumps Working Group.
January 2014: DOE Issues Notice of Open Webinar for the ASRAC Commercial and Industrial Pumps Working Group
Notice of Proposed Rule (NOPR)
DOE Preliminary Analysis
2013 - 2014
Monthly Meetings: 2014
DOE Notice of Open Meeting of ASRAC Pumps Working Group
May 2, 2013
December 18-19, 2013
HI Provides Formal Response to DOE Framework Document
ASRAC Pumps Working Group Meeting in DC
February 20, 2013
November 12, 2013
DOE Framework Hearing in Washington, DC
- Purpose & Agenda
January 25, 2013
October 24, 2013
DOE Framework Document
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
February 26, 2013
DOE Convenes First ASRAC Meeting: Discusses Pumps
- Updated Agenda
DOE Framework Hearing in Washington, DC
March 30, 2012: HI Request to Meet with DOE
June 13, 2011: DOE Request for Information
July 11, 2011: HI Response Letter 1
September 16, 2011: HI Response Letter 2
September 16, 2011: HI Response Letter 3
A number of HI committees were formed over the past two years to work on different aspects of the DOE rulemaking. Experts from HI member companies have collaborated, beginning with the HI Pump Efficiency Expert Team (PEET), to advance work that will be fundamental to both the DOE rulemaking and end-user understanding of optimizing pumping systems. Most of the committees regularly teleconference but will meet in person during the HI Annual meeting in Phoenix, AZ in early February 2014. Following is a brief summary of the work of the different HI committees that are working on topics that are related to the DOE rulemaking:
Government Affairs Committee (NEW): The HI Board of Directors, in February 2014, approved establishing a new government affairs committee whose purpose is to develop a strategy to engage the pump industry in public policy, legislative and regulatory oversight issues, ensuring that pump and supplier OEMs are properly represented on such matters that have a direct, positive, impact on the business interests of member companies. HI members that have interest in participating should contact HI Executive Director: Robert K. Asdal, rasdal@Pumps.org. (Purpose/Scope)
HI Pump Test Standard: HI 40.6: While HI pump test standards, particularly ANSI/HI 14.6, are well known among pump end users, EC firms, pump OEMs and distributors, the DOE would have to reference its own specific pump test procedure as the foundation of its rulemaking. HI offered to write that standard for the DOE and invited DOE experts as part of the standards-writing team. Unlike the 14.6 standard, the standard that DOE will adopt will be based on only one test tolerance known as 2B. Documentation created by the HI committee was submitted to the DOE for introduction into their Test Procedure Rulemaking process. A formal public hearing is scheduled for the summer of 2014, according to the latest schedule published by the DOE. (Purpose/Scope)
Minimum Efficiency Index (MEI) Standard: The purpose of the MEI is to develop a methodology for reducing the energy consumption of pumping systems. The MEI concept takes into account the factors of pump type, size (flow rate @ BEP), head, and specific speed to predict the efficiency cut-off level. The MEI provides a decimal index value (<1) indicating an efficiency class. (Purpose/Scope)
Pump Test Lab Approval Program: This committee is developing a pump test laboratory audit and inspection program to approve a pump test laboratory’s ability to test the performance of certain products to applicable HI and other performance test standard(s) as well as to adhere to the requirements of an international test lab accreditation standard (ISO 17025). The scope of the committee’ work encompasses all pump test laboratories testing pumps and extended products. (Purpose/Scope)
Extended Product Standard: The Extended Product Committee is working on a publication to identify and verify optimized energy usage of extended products, defined as the pump-motor-drive assembly and control. Working collaboratively with its European counterpart, Europump, HI intends to create a standard for the pump/motor assembly and motor control from the perspective of a sub-systems approach (European Extended Product Approach). Focusing on optimizing energy efficiency use of the extended product, the standard will likely recommend metrics and minimum standards. Such a standard will help support HI and the pump industry’s advocacy for optimizing pumping systems extended products to achieve higher energy savings, rather than by addressing pump-end efficiency alone. Improving the efficiency of extended products can significantly benefit end-user economics and the environment. The HI Extended Product document will address rotodynamic pump systems extended products that only cover designs for clean water, and most likely, will be consistent with the anticipated DOE rulemaking. (Purpose/Scope)
Efficiency Prediction Guideline: The
HI Pump Efficiency Prediction Committee has begun to gather new pump
performance data to update this important guideline that relates pump
efficiency to pump type, specific speed, and pump size. Considerations such as surface roughness,
internal clearances, mechanical losses, pumpage, impeller design and diameter
trim, and thrust balancing techniques are just a few of the factors that are
included in this guideline. (Purpose/Scope)
Pump Systems Energy Optimization Standard: This committee is creating a standard for the evaluation of energy usage in pump systems that provide the user or system designer with a collection of tools and metrics for the development of energy efficient pump systems. This standard is intended to facilitate the optimization of pumping systems to achieve higher energy savings rather than address pump efficiency alone. The scope of the standard is intended to be used as a tool in the design and retrofitting of pump systems to optimize energy efficiency and reduce life cycle costs. (Purpose/Scope)
Extended Product & Pump Labeling Initiatives: HI recently joined a collaborative effort on Extended Product Labeling, organized by the American Council for an Energy Efficient Economy (ACEEE), to work with electric power utilities, energy efficiency advocates and other trade allies to develop new concepts for pump and extended product labeling to recognize higher efficiency products or extended products. Other trade organizations involved include the Air Movement and Control Association (AMCA), the Compressed Air and Gas Institute (CAGI), the Fluid Sealing Association (FSA) and the National Electrical Manufacturers Association (NEMA). Other members of the consortium including leading energy efficiency advocates and electric power utilities who have interest in supporting rebate and incentive programs to transform markets toward more energy efficient products. (Purpose/Scope)
For more information regarding HI's activity with the DOE please contact Robert K. Asdal, Executive Director at rasdal@Pumps.org or (973) 267-9700 x113