AEDM Subsequent Verification

By Jonathan Susser | December 3, 2019

For over 20 years, Advanced Energy has provided motor testing and motor efficiency compliance services to motor manufacturers to help them achieve compliance with the Energy Policy and Conservation Act of 1975 (EPCA). The EPCA, as amended, established a federal program consisting of test procedures, labeling and energy efficiency standards for consumer products, including commercial and industrial electric motors.

In 1999, U.S. Department of Energy (DOE) federal regulation 10 CFR Part 431 was enacted, specifying that motor manufacturers must obtain a Compliance Certification number to be able to sell motors in the United States. At a minimum, test reports are required for five motor models using five samples of each model. The data gathered from these models is used to extrapolate the efficiency ratings of other models. Manufacturers can then use an Alternative Efficiency Determination Method (AEDM) to predict the efficiency levels across all models.

After earning initial compliance, the DOE requires that motor manufacturers verify that their AEDMs remain accurate. The DOE defines three options for “subsequent verification of an AEDM.” Specifically, the regulation states that “Each manufacturer shall periodically select basic models representative of those to which it has applied an AEDM and for each basic model selected shall either:

  1. Subject a sample of units to testing in accordance with 431.23 and 431.24 (2) by an accredited laboratory that meets the requirements of 431.25.
  2. Have a certification body recognized under 431.27 certify its nominal full load efficiency, or
  3. Have an independent state registered professional engineer, who is qualified to perform an evaluation of electric motor efficiency in a highly competent manner and who is not an employee of the manufacturer, review the manufacturer’s representations and certify that the results of the AEDM accurately represent the total power loss and nominal full load efficiency of the basic model.”

In 2014, a new final rule applied the existing standards to a wider scope of electric motors.

Federal regulation 10 CFR Part 431 states that each motor manufacturer that has used an AEDM shall have records showing the method or methods used to be made available for inspection by the DOE. At any time, the DOE can ask a manufacturer to produce records that prove its AEDM is current and valid under the law, and a failure to have these records could result in a violation.

The DOE recognizes that AEDMs are fluid models that are continually adjusted to improve motor efficiency prediction. Because AEDMs are fluid and because motor manufacturers strive to improve product efficiency, the DOE requires continual maintenance. In addition, anytime a motor manufacturer makes significant design or production changes, the AEDM needs to reflect those changes, so it is important to verify that your AEDM subsequent verifications include any of the more recently covered motors if applicable.

To provide complete compliance services and to make sure all of our clients are prepared for a potential DOE inspection, we offer two programs to help maintain sufficient records. The first is for clients who have achieved or are working toward National Voluntary Laboratory Accreditation Program (NVLAP) compliance. This program involves testing a few basic models per year per AEDM in a chosen NVLAP lab, with reports sent to Advanced Energy for verification to the AEDM. Advanced Energy defines the motor test plan, reviews all test reports and creates the documentation necessary to maintain the “subsequent verification of an AEDM.”

Our second AEDM maintenance program is for customers who do not have a NVLAP lab or are not planning to obtain this accreditation (though we do offer programs to motor manufacturers interested in obtaining NVLAP accreditation for their own labs.) Under this program, we perform all of the items listed above along with testing from our own NVLAP lab (Lab Code: 200081-0). We help each customer select a few basic models per AEDM, test them and prepare the necessary documentation for record-keeping. We analyze the database of your motor models on file with the DOE each year and make sure we vary testing to include as many basic models (over time) as possible.

We strive to help customers achieve efficiency compliance and stay in compliance to legally distribute motors in commerce in the United States. Reach out to us if you have any questions, and view our full AEDM maintenance program letter here.