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CONSULTATION REGULATION IMPACT STATEMENT
THREE PHASE CAGE INDUCTION MOTOR
E3 seeks feedback from stakeholders regarding the questions below. Please ensure that you explain your answer.
• Summary questions
1. Do you support the proposal to increase the MEPS and /or expand the scope of MEPS for three phase electric motors and why?
Yes. Helps improve the efficiency of the final product sold and brings Aus/NZ in line with Europe,
America and other leading regions/countries.
2. What is your preferred option(s) and why?
Option 2. Motor manufacturers already have product to suit option 1 requirements, and the addition of option 2 in 2029 provides ample time for a IE4 solution if they don’t have one already.
• Cost benefit and modelling assumptions
3. Do you agree with the assumptions and parameters used in the cost benefit modelling
(listed in Appendix 1: Cost benefit approach and parameters)? If not, can you please provide information on what you consider the assumptions/parameters should be.
Yes
4. Do you agree with the assumptions on the proportion of motors sold as bare motors compared to those embedded or packaged with machines?
Yes
5. What do you think will be the impact on competition in the market and three phase electric motor availability if the proposed new MEPS levels are adopted, namely:
▪ IE4 MEPS (75kW <= x <= 200kW, poles 2, 4, and 6)
▪ IE3 MEPS (0.75kW <= x <= 375kW)
▪ IE2 MEPS for small three phase electric motors (0.12kW <= x < 0.75kW)
Most motor manufactures operate in international markets where these requirements are already in place, or they produce motors to these greater efficiency levels already. Therefore, availability should not be an issue provided there is amble time for the proposed change over.
6. The CBA is based on the supply of bare three phase electric motors. Do you think that the supply of three phase electric motors contained within other equipment, such as pumps, fans and compressors, differ significantly in their size, efficiency and other characteristics from the market for bare motors?
No.
7. Do you have any comments on how the market for IE3 motors is changing, compared with the market for IE2 motors, and what factors are driving this change?
Consultants are more aware of IE3 and often specify this efficiency level on projects as a result of other regions adopting this as the minimum requirement.
8. Figure 12 shows in Australia the overall stock of three phase motors is increasing until
2012 and then declining until 2030 with a slight increase over the next decade. This is largely due to the rapid increase in the period 2000 to 2012 of motors under 4kW. Do you have any insight into why this is the case?
The reduction in three phase motors from 2012 could potentially be attributed to the popularity of EC (electronically commutated) motor/impeller solutions which are widely used in the ventilation industry across the 0.73-4kW range.
• Minor technical changes
9. Do you support lowering the voltage threshold to 1,000 V?
Yes
10. Are you supportive of adopting EU duty cycles under regulation?
Yes
11. What are your opinions on regulating the following types of motors: motors with integral variable speed drive; motors incorporating integral brakes; and motors specifically designed for the traction of electric vehicles?
Most motors from reputable suppliers with integral variable speed drives will already exceed the proposed options.
12. Do you support allowing IEC 60034-2-1 (Edition 3):2024 (Method 2-1-1B) as a test
Standard for compliance purposes? This is in addition to IEC 60034-2-1 Ed 2.0 (2014) (Method 2-
1-1B), IEEE 112:2004 and IEEE 112:2017 which are allowed in the current GEMS determination.
Yes, as for the purposes of the energy efficiency test they are equivalent
13. Should three phase electric motors designed to be used with VSDs be regulated separately to non-VFD motors, and what should MEPS level be (IE2, IE3, etc.)?
No and MEPS levels should remain the same as proposed
• Minimum Energy Performance Standards and scope
14. Do you support regulating small three phase electric motors (0.12kW <= x < 0.75kW) at
IE2 levels?
Yes
15. Do you support regulating medium (0.75kW <= x < 185kW) and large three phase electric motors (185kW <= x 375kW) at IE3 levels?
Yes
16. Do you support adopting IE4 efficiency levels for the three-phase electric motor in 2, 4, and 6 poles configuration in the range 75kW <= x <= 200kW levels?
Yes
• Implementation
17. How much lead time would you consider is necessary to comply with an increasing of
MEPS to IE3 levels for the current scope 0.75kW to 185kW? Note the proposed timeframe is
2027.
Propose to have stock held prior to transition date grandfathered otherwise, the proposed time frame is suitable
18. How much lead time would you consider is necessary to comply with introducing MEPS at IE2 levels for small three phase electric motors 0.12 kW (inclusive) to 0.75kW? Note the proposed timeframe is 2027.
Propose to have stock held prior to transition date grandfathered otherwise, the proposed time frame is suitable
19. How much lead time would you consider is necessary to comply with introducing MEPS at IE4 levels for three phase electric motor in 2, 4, and 6 poles configuration in the range 75kW
<= x <= 200kW levels? Note the proposed timeframe is 2029.
Propose to have stock held prior to transition date grandfathered otherwise, the proposed time frame is suitable
• Registration
20. Do you support the proposal to change the family of model’s definition for three phase electric motors? Do you have any feedback on the proposed definition e.g. should it include: shaft diameters and length requirements?
Yes, in theory it enables more three phase electric motors to be registered under a single family
21. Do you support a new requirement to provide an image of a motor’s nameplate at point of registration and why?
Yes, provides easier point of reference when checking against registrations.
• Labelling
22. Do you support the introduction of product information requirements in line with EU eco-design 2019/1781 requirements Annex 1 point 2?
Yes, as most of our members are already currently sourcing product from the EU, it will mean more information is readily available without having to request it.
23. Do you support the introduction of the requirement to display the current registration number of the three-phase electric motor when offered for supply? Note this includes when a machine that contains a three-phase electric motor is offered for supply.
Yes, for motors offered for supply.
No when they are included in a machine. Suppliers of machines may use motors from many manufacturers with many variants. This would mean displaying all the potential registrations for every machine during the offer stage, and then the actual registration at the supply stage.
24. Do you think the existing nameplate requirements on three phase electric motor should be expanded to require a nameplate to be placed on a machine with the motor information, where the motor is not visible externally?
No, most machine manufacturers will provide an external label of their own which caries the motor information, but admittedly not the registration details.
• Compliance
25. Is regulation of three phase electric motors and some products they are embedded into
(e.g. air conditioners and chillers) an issue? If so, can you please explain in detail the issue you see.
Issues may be seen for these products as they already have Energy efficiency requirements, and this could be seen as double regulation.
26. Do you have any suggestions on how compliance of three phase electric motors
(including those embedded in or packaged with machinery) could be improved?
More policing of suspected non-compliance within the industry
