Appliance Standards Awareness Project American Council for an Energy-Efficient Economy

Dommu: This letter constitutes the comments of the Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), National Consumer Law Center (NCLC) on behalf of its low-income clients, and the Natural Resources Defense Council (NRDC) on the notice of proposed rulemaking (NOPR) for expanded scope electric motor (ESEM) standards. [...] At TSL 2, the average life- cycle cost (LCC) savings range from $26 to $160, with simple payback periods (PBPs) of 0.7 to 2.0 years across each of the representative units (RUs) analyzed.3 Overall, the shipment-weighted average LCC savings are $102 with an average PBP of 1.2 years.4 The per-unit operating cost savings for ESEM purchasers are also quite significant in comparison to the typical ESEM. [...] As part of the NOPR analysis, DOE performed testing and teardowns of 17 ESEM models and consulted with industry stakeholders to inform the engineering and cost analysis.6 Importantly, DOE also constrained motor frame size (i.e., diameter) at higher efficiency levels to that of a baseline motor for each RU; this assumption reflects the likelihood that motor manufacturers will avoid increasing frame. [...] Additionally, the same technology options used to improve motor efficiency broadly (thinner electrical steel laminations, increased slot fill, etc.) may be implemented to improve AO ESEM efficiency; the lack of an internal fan may even improve the efficiency of an AO ESEM in comparison to a non-AO ESEM. [...] The proposed standards for both AO and non-AO ESEMs would apply to motors regardless of whether they are sold alone or embedded into covered equipment.7 While energy efficiency improvements for ESEM-containing products subject to standards (i.e., covered equipment) may require more efficient motors, the presence of ESEMs in covered equipment does not preclude the possibility of cost-effective effi.