has utterly no internal losses. But such losses are unavoidable in any machine because of internal friction, heat transfer and aerodynamic losses (breathing and windage losses). For reciprocating (piston type) air compressors the present level of power consumption breaks down into 15.3 hp/100 cfm as the power required for compression, and 3.7 hp/100 cfm as the power lost internally in the operation of the machine. If further improvements in efficiency were possible, industry would surely invest the development funds necessary to achieve such higher efficiencies. But, the fact is, that the piston-type compressor has pretty well reached the ultimate possible in its efficiency; neither large development expenditures, nor legislation, will help to improve its present efficiency.

(2) Legislation is unnecessary because the marketplace is already energy aware, selecting the most efficient pumps and compressors available. These market forces unquestionably will continue to exert an increasing influence favoring the most energy efficient pumps and compressors as the cost of energy rises.

Industrial pumps and compressors are purchased by the customer to perform a specific duty. Pumps and compressors are quite similar in nature; both are intended to deliver a given quantity of fluid at a given pressure. The only essential difference between them is that pumps are used to deliver a liquid (incompressible fluid), whereas compressors operate on gases (compressible fluid).

Once an industrial customer defines his requirements in terms of flow rate and output pressure, he will generally choose the product characterized by the lowest operating cost. Styling, convenience, or prestige value, which frequently lead to energy wasteful choices in consumer products, have no bearing and do not influence the choice of industrial machinery.

If other things, such as the first cost (price), the expected life, and maintenance and repair costs, are equal between two products, then the operating cost is directly related to the energy consumed. For a given amount of work delivered, the machine (pump or compressor) which consumes the smallest amount of energy during its operation will also have the greatest efficiency. It follows that the most efficient machine, which also minimizes the amount of energy consumed to discharge a given task, will be selectively favored by the marketplace. The value of energy savings can be readily illustrated. Assuming that power costs an industrial user 21⁄2 cents per kilowatt-hour, then for each horsepower saved this translates into a value of $160 a year. For a 10-year life customarily assumed for industrial installations, the equivalent value of 1 horsepower saved is $1,600, neglecting interest. The value that the marketplace places on such horsepower saved at current energy prices, regardless of whether the equipment in question is a pump or a compressor, is around $1,000 per horsepower. If one now considers a 10,000 horsepower pump which is 2 percent more efficient than a competitive unit-with all other items, such as a first cost, maintenance, repair, and life being the same-then this pump with an overall efficiency improvement of 2 percent over its operating range could command a premium of $200,000 in its sale price.

(3) Legislation may be counterproductive because the specific selection of pumps and compressors is influenced by a vast array of factors which can dictate the use of a lower peak efficiency machine to minimize total energy consumption. These factors include the

pressure levels required to be delivered. the corrosive or erosive nature of the fluid being pumped, the required service life, safety, reliability, and the conditions of use-intermittent, fluctuating, or steady load applications.

Mandating uniform standards for this multitude of applications does not appear feasible, and might be counterproductive (by way of forcing less fuel efficient products to be used inadvertently for certain applications).

Pictured in exhibit 1, attached to the testimony, are the efficiency curves of two pumps, pump A and pump B, having substantially the same flow-gallons per minute pumped-and head-pressure. If the service is one where the pump operates most of the time at or near its maximum rated speed-full flow-then clearly pump A is the better choice, simply because it operates most of the time at its maximum efficiency, that is, at full load. If, on the other hand, the service conditions fluctuate between no flow and full flow, pump B will be the better choice because it has better overall efficiency when averaged out over the entire operating speed range. But note that its maximum efficiency is lower than pump A.

The economics of marketplace will select the right choice for each application. Thus, if peak efficiency is mandated for a given size, in many applications, specifically using pump B, energy would be wasted. Contrariwise, if overall efficiency is mandated, in other applications, energy would be wasted.

In summary, we sincerely do not believe that the picture unfolded above can be significantly influenced, changed, or improved by legislation, no matter how praiseworthy the objectives of such legislation may be. We, therefore, respectfully counsel that any consideration of legislation toward mandating the energy efficiency of pumps or compressors for industrial use be dropped as being unnecessary at best, and potentially harmful at worst.

Mr. Chairman, that is the conclusion of my testimony. [The exhibit referred to follows:]

Mr. DINGELL. Thank you, Doctor.
Our next witness is Mr. Hanson.

STATEMENT OF JOHN NILS HANSON, PRESIDENT AND GENERAL MANAGER, ELECTRIC MOTOR DIVISION, GOULD, INC.

Mr. HANSON. Mr. Chairman, I am John Nils Hanson, president and general manager of the Electric Motor Division of Gould, Inc. Gould, Inc., Electric Motor Division, a St. Louis-based manufacturer of high efficiency electric motors, welcomes the opportunity to provide comments on H.R. 8985, a bill to establish labeling rules and efficiency standards for industrial equipment. Due to the time constraints, my oral statement responds generally to the questions you have posed, while our written statement provides more specific and detailed response.

Gould, Inc., is a multiple division corporation with primary interests in the electrical products business and total sales exceeding $1.6 billion. The company ranks well within the top half of the Fortune 500 largest industrial firms. Gould's research and development expenditures, which will exceed $67 million in 1977, emphasize product development keyed to the needs of the marketplace. The electrical motor division has spent a considerable amount of money and effort in the development of improved efficiency products and in January 1976 introduced a line of high efficiency electric motors.

We strongly advocate the concept of improved energy efficiency for all industrial products where the economics of the present and future support it. We consider Gould the leader in developing and offering energy efficient product lines including energy efficient electric motors which were introduced in January 1976. The high efficiency motor line consists of three-phase motors in the horsepower range of 1 to 25 horsepower, providing reductions in energy losses of 19 to 29 percent compared to "standard" three-phase electric motors. These motors carry a price premium of approximately 25 percent due to the increased material required to obtain the efficiency improvements. At the same time their energy efficiencies are sufficiently greater than industry averages to assure a sound economical payback for many applications where the motors have proper utilization and electric energy costs exceed a few cents per kilowatt-hour.

Gould's experience in developing and supplying energy efficient motors convinces us that the imposition of mandatory efficiency standards for electric motors is impractical, creates excessive administrative costs, financially burdens manufacturers and users alike, and in fact. is unworkable. The following fundamental and vital facts must be considered regarding the imposition of mandatory motor performance standards:

1. Mandatory efficiency standards for all electric motors would be all but impossible to administer. There are well over 2,000 basic motors and literally thousands of applications to consider in developing, implementing, and administering a standard. The costs alone-of standard setting, certification, enforcement, recordkeeping, and Government personnel requirements-will be prohibitive.

Furthermore, the technical considerations necessary for efficiency standards to result in energy savings require that the specific end use application of each and every motor be considered and understood. The actual operating load of a motor more often than not differs from the rated horsepower output of the motor. A motor operating at 50 percent rated load can exhibit a decrease in energy efficiency in the order of 10 percent and an increase in load current of 25 percent over a properly applied motor. With standards based in part on horsepower rating the results would be standards that in effect cause energy inefficiency. Setting mandatory efficiency standards for classes of motors ignores the basic fact that similar horsepower category motors do not have identical characteristics. Indeed, motors of the same horsepower category have diverse performance features that must be considered; for example, different starting torques, different operating torques, and different duty cycles.

2. Establishing across-the-board mandatory efficiency standards. for all electric motors would freeze efficiencies at the set values and over the years would, in fact, result in wasted energy as marketplace motivation to improve motor efficiencies would be nonexistent. More immediately, if H. R. 8985 is enacted into law in its current form, the electric motor industry would be faced with a chaotic situation. A 5-year period would ensue before promulgation of final mandatory efficiency standards. During that period, the Administrator of the FEA would determine which motors and manufacturers would ultimately be subject to the mandatory standards. Until this determination is made and the standards are established, the product lines, long-range planning, and capital allocation of the entire motor industry would be stagnated.

3. Mandatory standards would place severe financial handicaps on-or even force out of business-the small motor manufacturers who would be required to make major capital investments for design changes and retooling. While some form of relief or exemption could be granted to these manufacturers, market forces will require them, in any event, to produce motors with efficiencies meeting the mandatory standards. In many cases, these small manufacturers deal in markets where energy efficient products are inappropriate.

4. In many applications, the use of electric motors meeting a mandated high efficiency standard will result in increased not decreased energy consumption. Indeed, in certain applications high efficiency motors do not operate long enough to recover in energy savings even the amount of energy used to produce the additional materials required to make these motors more efficent.

Adequate labeling of electric motors is a positive step which we feel will lead to the increased utilization of energy efficient motors in the marketplace. Labeling motors with energy efficiency ratings will provide motor users with additional information to make purchasing decisions based on energy efficiency. With the accelerated use of energy efficient motors, significantly increased energy savings can be realized.

While supporting the concept of labeling of electric motors in section 344 of the bill, we strongly urge that careful consideration be given to the method used to label electric motors. It is possible to identify the

motor efficiency on the motor nameplate or by other acceptable identifying means. However, it is important to recognize that the value of efficiency only applies at the nameplate or rating horsepower. At other loads imposed on the motor these values change. In addition, the definitions and meanings of these markings must be developed to recognize the normal manufacturing variations in the production of electric motors. The National Electrical Manufacturers Association has recently developed a nameplate marking standard for the integral horsepower motors to improve the identifying of motor efficiency on the nameplate. While this system promises to lead to significant savings, it has not been in use long enough to measure its results in the marketplace in terms of selection and application of electric motors.

In addition, the National Electrical Manufacturers Association is developing an engineering document entitled "Statistical Methods for Motor Efficiency Data." This document will provide means and recommendations for a statistical analysis of motor performance, in order to provide uniformity in the method of statistical determination of motor efficiency and thereby improve the comparability of data available to the user.

Gould supports the concept of adequate test procedures-section 343 of the bill-for determining the energy performance of electric motors. Based on our experience, however, we believe that appropriate test procedures already exist and these procedures are adequately defined by present Institute of Electrical and Electronic Engineers test codes 112-A and 114, respectively, for polyphase motors and single phase motors. These test codes were developed by an IEEE body representing a broad spectrum of technical personnel from industry, users, academia, and government.

To develop application test procedures based on application and duty cycle of electric motors, as currently set forth in section 343 of this bill, is not practical due to the wide variation of the application of motors. A typical duty cycle does not represent the energy utilization of the motor on any specific application. The energy utilization of the motor can best be determined by the user, based on the motor efficiency determined in accordance with the above test codes, the specific load, duty cycle, and power costs. For the specific applications, Gould, Inc. has developed application and energy payback guides to assist the user in making an energy conservation analysis. Copies of these guides are included in the written testimony.

Gould strongly opposes mandatory electric motor efficiency standards since such standards are impractical, costly, and unworkable. We do favor testing and labeling procedures which require the provision of meaningful information so that the user of electric motors can make proper decisions regarding energy efficiency. The test procedures defined in section 343 and labeling requirements in section 344 are confusing, and do not provide the motor user with adequate or appropriate information.

Therefore, we recommend that electric motors be excluded from the purview of sections 341, 343, 344, and 345 of H.R. 8985. We further recommend that electric motors be included to fall within section 342 of the bill. This will permit the logical and systematic development of workable test procedures and labeling requirements