The U.S. pump manufacturing industry has enjoyed a long history unfettered by federal regulations. As the DOE develops new regulations for pump efficiency, that will change. Mandatory pump rules are expected to take effect in 2016 and will begin to be enforced in 2019. Taking the lead in representing the pump industry, HI has communicated with the DOE since learning about the new rulemaking and, in December, met with its members to officially approve a new negotiated rulemaking process under the rules of the Appliance Standards Rulemaking Advisory Committee.
As DOE pump efficiency regulations are formulated, pump manufacturers should pay close attention to the direction in which the rules are headed and even begin defining actions that will ensure future compliance of their affected products. While the levels of pump efficiency defined by new regulations are uncertain, they will most likely involve design improvements. If the DOE models its regulations after the European Union (EU) standards, pumps not inherently efficient in their peer group across all companies that manufacture the same types of equipment will either be removed from the market or must be redesigned to meet higher efficiency levels.
While the outcome of these pump efficiency regulations is still uncertain, the DOE made it clear that Congress authorized them to set minimum efficiency standards for commercial and industrial pumps in 1977.
As the DOE regulatory process matures, it follows two paths—a traditional and negotiated approach (see Table 1)—that merit the attention of pump original equipment manufacturers (OEMs) and its future impact on their market.
HI Responds to the DOE
Since the DOE first announced its pump rulemaking plans three years ago in the Federal Register, HI members and staff have advocated for sensible regulations. Recognizing that regulations were inevitable, the group has been realistic in mitigating the impact on the pump industry, while supporting DOE energy savings and efficiency improvement goals.
Within days of learning about the potential pump efficiency regulations, a delegation of HI members and staff met with the DOE to better understand the regulatory process and, as best as possible, begin to help shape its outcome. HI members also met with the American Council for an Energy Efficient Economy (ACEEE), the National Association of Manufacturers (NAM) and staff on the House and Senate Energy committees. These meetings helped the pump industry better understand the DOE rulemaking process and become formally engaged with regulators, energy efficiency advocates and DOE consultants.
In 2011, HI responded to a formal DOE request for information with three lengthy letters that outlined its views on regulations, leadership role with technical standards and guidelines, and the benefits of end-user education that provides knowledge on proper pump selection, pump/system interactions and how pumps can be operated at or near their best efficiency points.
The Need for DOE Education—an Ongoing Opportunity
Through its interactions with DOE regulators, consultants and members of energy efficiency non-government organizations (EENGOs), HI realized that this audience was mostly unfamiliar with pump and pumping system operations.
HI staff and members organized several briefings for all involved individuals to provide a better understanding of the complexities of pump operations, pump hydraulic design, and pump and system interaction. HI also offered day-long training on the HI and Pump Systems Matter course, “Pump Systems Matter: Energy Efficiency and Bottom-Line Savings.”
In addition, HI met with energy efficiency non-government organizations and DOE consultants in Washington, D.C.; Dallas, Texas; Denver, Colo.; and Parsippany, N.J., to explore common ground and reach an agreement on regulatory approaches to energy savings regarding pumps and pumping systems. HI advocates a product scope similar to that adopted under EU pump regulations, along with a method of recognizing the pump system optimization potential to achieve the greatest energy savings.
An independent agreement with EENGOs, which might have led to a DOE sanctioned rule, remained elusive during 2013. The possibility of rulemaking based on direct negotiations with other stakeholders, under DOE established rules, was then explored as the traditional rulemaking process advanced.
The DOE’s framework document was released in January 2013, and HI members presented testimony during a day-long public hearing in Washington, D.C., at the end of February. A week later, HI delegates and staff attended the first meeting of the DOE’s Appliance Standards Rulemaking Advisory Committee (ASRAC).