“During the scope discussions for the Commercial/Industrial Pumps Working Group, they decided circulator pumps would be better served to have separate regulations,” explained Laura G. Petrillo-Groh, senior engineering manager, regulatory affairs, Air-Conditioning, Heating, and Refrigeration Institute (AHRI). “All the right people were not in the room during that rulemaking, and the test procedure needed to be refined a bit for the products.”

“Circulator pumps were carved out as kind of a subset of pumps,” said Chuck White, vice president of code and technical services, Plumbing-Heating-Cooling Contractors National Association (PHCC). “Circulators have never been a regulated product, and the industrial pump manufacturers and others in the industry wanted to have some time to evaluate what the possibilities are and the current conditions and then decide how to move forward. Now, it’s 2016, and the industry has come forth and said, we think we can work on crafting a program and try to establish some baseline standards and work on improving the energy efficiency of these products. So, kind of in a nutshell, this is an attempt to improve the efficiency of these products that have never been regulated before.”

Several industry manufacturers, two trade associations, representatives from the DOE, DOE consultants, energy advocates, environmental advocates, and consulting scientists make up the roster of working group participants, said Mark Chaffee, vice president of governmental relations and sustainability, Taco Comfort Solutions. “The move to a formal ASRAC puts us on an accelerated pace and brings together greater resources in order to get a rule in place,” he added.

CIRCLING BACK

The DOE addressed commercial and industrial pumps first because of the significant energy savings potential, and now that those standards are complete, the regulatory body is approaching the smaller pumps used most often on the residential side, explained Brent Ross, director of core/hydronics products at Armstrong Fluid Technology.

“It was debatable whether they wanted to address a smaller energy-savings potential, such as circulators,” Ross said. “Obviously, the potential in a 30-W [circulator] is the same as a 30-W lightbulb. So, there’s a lot less energy consumed, especially when compared to pumps that go 100-200 hp. But, the DOE chose to address [circulators].”

The industry organization representing manufacturers, the Hydraulic Institute Inc. (HI), was an active participant in the Commercial/Industrial Pumps Working Group and is again participating in the circulators working group, said Peter Gaydon, director of technical affairs for HI.

“There’s been a lot of work done over the last two years, informally, leading up to this between pump manufacturers and energy advocates,” Gaydon said. “We’ve gone into this formal rulemaking with lots of ideas and thoughts and a general understanding of different viewpoints. I’d say that’s kind of a unique part of this rulemaking, and it’s helped the process so far.”

While it’s impossible to know what the standards will look like this early into the rulemaking process, energy-efficiency advocates are pushing to eliminate standard, permanent split-capacitor (PSC)-motor-driven circulators, Taco’s Chaffee said. “This is chiefly the trickle-down effect of what began in Europe years ago, prompted by much higher energy costs. The change to ECM [electronically commutated motor] technology [in Europe] is sweeping and complete, including a series of rulemakings to eliminate less efficient circulators from the market. As happens so often, we are following in their tracks. This is driving [Taco’s] research-and-development spending on new, greatly more-efficient technologies, while pumps like Taco’s seminal 007 Series circulator workhorse will most likely be eliminated by the DOE’s rulemaking.”

TIMELINE

So far, the working group is still early into the process of developing a consensus standard, Gaydon said. “We’ve only gone through the introductory meeting where we go over the ground rules, and now we’re into the scope discussion leading into performance and evaluating data.”

“At the beginning stage, you have to define your terms — especially in this case, where they have never been regulated before,” White said. “The circulator market is pretty broad, and there are a lot of different products in there. To come up with a generic one-line description for those products is kind of difficult.”

The working group will most likely divide circulators into three or four subsets, White said. “They would likely be your wet-rotor, close-coupled-inline, three-piece, and small vertical-inline pumps. That last one is kind of a blend; those types of pumps might run into commercial and industrial sizing bracket or could be more of a circulator, and they’re probably the hardest to define. It’s a work in progress, so there’s nothing that is official yet.”

The working group has until the end of September to submit its recommendation, also called a “term sheet,” to ASRAC. “This will serve as the foundation for the development of a DOE NOPR [notice of proposed rulemaking],” Chaffee said. “After the publication of the NOPR, the DOE will accept comments and then integrate those comments into a final rule, which should be published later in 2017.”

There is also a chance the DOE may decide to issue a direct final rule (DFR) for the energy conservation standard instead of releasing a NOPR, Gaydon said. The test procedure for the circulators will still be published as a NOPR, which will be available for comment from stakeholders, but, before then, there is a lot of work that needs to be done, he added.

“The biggest workload is going to be the surveying of performance data,” Gaydon said. “There’s a big effort from the manufacturers to actually gather those data, and there’s a lot of burden associated with that — getting the data and submitting them to the consultant teams for evaluation. There’s a lot of behind-the-scenes work. That’s probably the biggest hurdle to getting this done — having the data on paper so we can all look at it fairly.”

An overarching goal of the working group is to try to align the standards with those already in place in Europe, where the market for hydronic heating products is well-established.

“I think we want standards to be consistent nationally and internationally so manufacturers don’t have multiple standards to comply with,” Gaydon said. “However, my understanding of the markets in Europe compared to the U.S., as far as system design goes and especially for residential housing, is different. There are more types of circulators inclusive of CP1, CP2, and CP3 types sold in North America, where in Europe, the CP1 type is primarily used.”

Despite the difficult task at hand, industry participants in the working group are confident the negotiated rulemaking process will be completed fairly and on schedule.
“This whole process is relatively new to me; however, I must say, I was impressed that the [commercial/industrial pump working group] operated on schedule,” Ross said. “They said they were going to complete it by a certain date, and [they did]. So, I have every belief that it has been run effectively and efficiently and will be complete in September.”

REGULATORY BURDEN

As with most new energy conservation standards, there will be a cost to comply that could affect the entire supply chain. And while it’s difficult to estimate what that cost will be, Gaydon noted there’s certainly a burden associated with the standards.

“Just testing the equipment, for anyone who’s not already tied into the commercial/industrial rulemaking, is going to be a burden — getting their test labs and personnel up to speed with current practices to make sure they can comply,” Gaydon continued. “We imagine it will reference HI 40.6-2014: ‘Standard for Methods for Rotodynamic Pump Efficiency Testing,’ and the same power conditioning and other testing requirements in the pumps rule. As far as the cost to comply, I don’t know if we can comment too much because we’re not a manufacturer of the product, and we don’t know where it’s going to go. But, certainly, depending on where the line is drawn, there could be a significant cost to comply for not only the manufacturers but for consumers, as well.”

Any time the government decides to enact regulations that eliminate a class of products, it’s certainly disruptive, Chaffee said, though he admitted the DOE’s goals were admirable.

“There’s no question the implications of this legislation; when it takes effect, it will impact a lot of lives — even, and some may say especially, installers of this technology,” he said. “Taco is very strongly positioned to help with this, too, through the company’s broad training programs, expertise, and customer outreach, both personally and online.”

Chaffee also pointed out that 47 new regulations have been passed in the last two years, all of which impact the HVAC industry. “Some have pertained to items like large compressor units, and others were directed at walk-in coolers. Then, of course, the commercial pump rule, among a wide range of other facets of our industry. It just so happens that attention has now shifted to small pumps and circulators.”

While larger companies are often able to absorb the cost to comply with new regulations, smaller companies may struggle, Ross added. “[Armstrong has] no problem investing appropriately, but small companies? Yes, it could hurt them. Larger companies? No, not as long as there’s a guaranteed market.”

While manufacturers are gearing up to comply with the new standard, whatever it may be, industry associations are advocating for their respective members’ best interests.

“We have interest in [the rule] from the perspective of water heater, boiler, and geothermal products, where the pumps are integrated into the equipment,” Petrillo-Groh said. “So, for us, making sure the efficiency increases while maintaining the same size and utility for the product is very important. That’s something we’ve been keeping an eye out for.”

“PHCC is interested in helping improve the efficiency of these products and offering any installed advice,” White said. “While we are not manufacturers, a lot of questions may arise based on application installations. And while the DOE doesn’t regulate applications, the application of the pumps may have some bearing on what is or isn’t a circulator, or what is or isn’t a good idea. PHCC is really looking to help improve the efficiency levels of these products and offer any input and wisdom we might have.”

Raising awareness of the standards throughout the entire supply chain is one of HI’s goals, Gaydon said. 

“I just think it’s something that needs to be monitored, and general awareness to what’s going on needs to be brought to users of the equipment as well as installers and any manufacturers that don’t know about it. But, most manufacturers are certainly aware, if not all. So, I think it’s important to raise awareness so nobody gets left behind. The end users and installers of the product need to understand how the regulations might affect them, and they must comment if it’s going to adversely affect them. The DOE has a responsibility to make sure this is a sensible rule, but they need input from everybody.”

While working group participants agreed there are certainly challenges to overcome in this negotiated rulemaking, they also expressed confidence that the group will accomplish its goal.

“I think definitely everyone’s direction is in the right place, but there are some challenges that have to be overcome,” Ross said. “But, at the end of it, yes, we’ll overcome the challenges and issues and establish a reasonable and fair recommendation.”

To view the rulemaking webpage, visit http://bit.ly/CircWorkingGroup.

Publication date: 6/27/2016

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