Editor's note: The following is a response to the article "Get Ready for New Federal Pump Efficiency Rules" found in the October 2016 issue of Pumps & Systems. The article is located online at this link. Peter Gaydon, Director of Technical Affairs at the Hydraulic Institute, writes: While reviewing the October 2016 edition of Pumps & Systems magazine, I came across the article “Get Ready for New Federal Pump Efficiency Rules.” I believe there are several points discussed in this article that should be clarified so that the published federal pump energy conservations standards and ongoing rulemakings and their requirements are fully understood by end users and manufacturers. The U.S. Department of Energy (DOE) has published a Federal Register final rule prescribing new energy conservation standards 81 FR 4368 (Jan. 26, 2016) and test procedures 81 FR 4086 (Jan. 25, 2016) for certain general pumps. Compliance by the manufacturer must be on or before Jan. 27, 2020. The article “Get Ready for New Federal Pump Efficiency Rules” referenced an ongoing negotiated rulemaking for circulator pumps, docket EERE-2016-BT-STD-0004, but then discussed requirements of the rules for certain general pumps (81 FR 4368 & 81 FR 4086). In addition to the ongoing circulator pump negotiation, dedicated purpose pool pumps (DPPP), docket EERE-2015-BT-STD-0008, are in a rulemaking process. A Notice of Proposed Rulemaking (NOPR) pertaining to the DPPP test procedure 81 FR 64580 was published on Sept. 20, 2016. The article indicated that the general pumps rule and ongoing rulemakings cover or will cover the efficiency of existing pumps, the systems they are installed in, and that end users will need to audit the efficiency of their pumps and systems. This is not the case, however, as the DOE rules are prescriptive to products as distributed in commerce. The rules do not extend to the overlying system that contains the pump. It is incumbent upon the manufacturer of the pump to ensure compliance with the standard—not the end user or system owner. What’s more, the rules do not include a requirement to audit the efficiency of preexisting pumps or the systems in which they are installed. The rules for general pumps (81 FR 4368 & 81 FR 4086) define five equipment classes of clean water pumps that are within scope and sets standard levels for these pumps. In the rules, DOE defines a pump to be inclusive of a “bare pump” (pump wet end only) and, when applicable, a “driver” (typically a motor) and “controls” (typically a variable frequency drive). The standard level power consumption prescribed is based on the minimally compliant efficiency of the bare pump, but the test procedure rule (81 FR 4086) outlines methods to account for the driver losses in the prescribed standard level power consumption. According to the product definition, a pump can be rated and certified with a driver and control when distributed in commerce with a driver or control. The point to understand is that DOE’s product definition for a pump can be inclusive to what industry terms the “extended product” (driver and control). At times, I have heard the extended product referred to as the “pump system,” which is misleading terminology because, as defined, a pump is rated and certified according to its pump/motor/drive configuration, not by the overall system in which it is installed. In summary, the burden of compliance is on the manufacturer of the pump and not the end user. The end user should be aware of the rules pertaining to pumps and use this understanding to make educated purchasing decisions. And while not required by the DOE rule, system audits are a recommended practice in order to identify less efficient pumps, ready for replacement.
12/15/2016