e WWEMA ter Moser Esp sf pc July 8, 2022 Office of Water US. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460 Via Email: BABA-OW@epa.gov RE: Request and Justification for EPA National Public Interest Waiver for Blowers To Whom It May Concern: Blowers are a necessary part of wastewater treatment. The energy consumed by blowers is typically 50- 60% of the energy used in 2 municipal plant, and as much as 4% of a municipality's power usage. Over the past decade, the blower industry has gone through an evolution towards increased energy efficiency, with the manufacturing of the key components coming from overseas. In order to meet the Biden Administration's goals for increased energy and water efficiency itis critical that U.S. utilities and municipalities continue to have access to these more efficient technologies as they “Build Back Better” using the new infrastructure funding in the Bipartisan Infrastructure Law. In order to accomplish these goals, a National Public Interest Waiver is needed for the blower industry. The justification for a National Public Interest Waiver is outlined below. History of Treatment and Blowers Since the invention of the Roots Blower in Connersville, Indiana in 1859, and the Multistage Centrifugal Blower in 1905 in France, the technology had not advanced in the U.S. beyond the initial design for more than 100 years. The Roots Blower and Multistage Centrifugal Blower are the foundation of the two main categories of blower designs we have today: Positive Displacement and Centrifugal. Technological advancement in manufacturing led to additional core technologies with Claw, Bi Lobe, Tri Lobe, Twisted Lobe, and Screw making up the primary subcategories of Positive Displacement Blowers. Single Stage Integrally Geared, Multistage, Air Bearing Turbo, and Magnetic Bearing Turbo are the main classifications of Centrifugal Blowers. In water and wastewater, the types of treatment and how the blower is utilized is a critical part of the plant design. Finding the right blower for the right application remains one of the most requested and attended session topics by professionals. Proper technology selection is determined by the needs of the processes based on system variables and optimizing energy consumption. With the international expansion of blower technologies, especially the more energy-efficient technologies such as high speed turbo and screw blowers, all of the major blower companies have invested in expanding manufacturing to satisfy the world market for these newer technologies. Mergers and acquisitions have clouded the distinction between domestic and foreign manufacturers as the race to fill product portfolios has accelerated. Still, the U.S. wastewater market has benefitted tremendously from the use of these new technologies. Both high speed turbo blowers and screw blowers have brought dramatic energy savings to municipalities of all sizes across the country. 540 FORT EVANS ROAD, SUITE 304 © LEESBURG, VA 20176-3379 703.444.1777 © WWW.WWEMA.ORG © INFO@WWEMA.ORGComplex Manufacturing . ‘As with many technologies in the water and wastewater sector, the manufacturing processes are highly sophisticated and complex, employing both local workers and computer-aided design technology and other manufacturing advances. Siting, permitting, building, staffing, and accrediting these facilities is time, labor, and cost intensive. These are not facilities that can be created overnight or without significant capital investment. The links below provide examples of the precision manufacturing processes required for high efficiency blowers: ‘Aerzen: https://www. youtube.com watch?v-0¥anqn-0VOQ Atlas Copco: https://www. youtube.com/watch?v=fMOP HyNFw8 https: //www. youtube.com/watch?v=_HyaxvzbtZ8 All of the represented manufacturers use computer-aided design and manufacturing automation (including robots), and lean manufacturing practices to develop products with consistent quality. Additionally, these factories carry ISO 9001 and 14001 certifications as well as authorizations from bodies such as CSA, UL, ASME, and others to ensure their products can be sold in North American markets. State-of-the-art machining centers and test bays are all intended to ensure the clients receive the highest quality machines that satisfy their performance needs. The market also consists of packagers who source blowers, motors, and other materials from a variety of suppliers. Even these companies will struggle to comply with the new Build America, Buy America (BABA) guidelines as they will depend on their suppliers to meet these requirements. Foundry Capacity Because of the precision required for blower manufacturing, different types of casting processes are needed depending on the component and material. Not all foundries are the same. Specialized component production is required for stainless steel, cast iron, and aluminum. Some products are cast, others are forged. Depending on component size, a foundry that produces larger castings is unlikely to produce smaller parts. Similarly, smaller part foundries don’t have the capability for producing larger parts. Finding domestic foundry capacity with the capability to produce components of the same quality as the existing manufacturing plants, will prove to be a daunting task. Currently there are no blower manufacturers sourcing their castings in the U.S., even the manufacturers with U.S. corporate headquarters. This applies to standard positive displacement blowers, screw blowers, and all types of centrifugal blowers. Specialty Components High speed turbo blowers, whether they are airfoil bearing or magnetic bearing, all run on permanent magnet synchronous motors (PMSM). The permanent magnets are made of samarium cobalt, an alloy known for its tolerance to heat and resistance to demagnetization. China is the top worldwide source of samarium for commercial use. Cobalt is mined as an alloy, and the process to produce samarium cobalt is specialized and potentially dangerous. ‘Screw type blowers are driven by PMSM, SynRM, and premium efficiency NEMA motors. PMSM & ‘SynRM motors must be driven by technologically-advanced variable frequency drives (VEDs), of which ‘none are produced in the U.S. market that satisfy BABA requirements. Many of the traditional blower 2types such as rotary lobe and multistage centrifugals are driven by NEMA design or IEC motors, which as noted earlier are not readily produced in the U.S. market to meet BABA requirements. Furthermore, these older technologies operate at much lower efficiencies costing municipalities more to operate Investment Decision Bringing advanced production to the U.S. could be done, but itis going to take a lot more investment of e and capital. The U.S. affiliates of all blower companies are currently struggling to find qualified employees, whether it’s office workers, qualified production workers, or service technicians. Expanding manufacturing will magnify the challenges in finding qualified personnel. The time and cost of land, buildings, permits, manufacturing quality certifications such as ISO 14001, and finding local supply chains will take at least 5 years, not 12 months. The investment required by most blower manufacturers (especially those who provide high efficiency blowers) to build manufacturing facilities in the U.S. isan overall business decision, based on how much revenue comes from the domestic water and wastewater market. Its not “reshoring” since they were never domestic, except for the original Roots blower, which is now cast in India. Moving to domestic suppliers and forgoing the manufacturers’ existing high volume supply chains, will create cost disadvantages, raising the price of their products and increasing the costs to municipalities. itis our contention that blowers of all types be considered for a National Public interest Waiver. The bulk of blower manufacturers are already U.S. trading partners. Their U.S. affiliate companies employ ‘American workers. A National Public Interest Waiver will give blower manufacturers the time to assess the availability of foundry capacity, specialty components, and supply chains of remaining components to provide municipalities access to high efficiency blowers. We will work with EPA on our collective progress and determine the next course of action, ‘Thank you for the opportunity to submit information on the need for a National Public Interest Waiver for blowers. WWEMA looks forward to working with EPA to implement BABA in the most practical way possible and continue to ensure that U.S. municipalities and their customers have access to the best available technology as they invest in future infrastructure improvements. Sincerely, Vamasocs 4 \ei boy Vanessa M. Leiby Executive Director Water and Wastewater Equipment Manufacturers Association Ce: Andrew Sawyers, EPA Michael Deane, EPA Tim Connor, EPA Kiri Anderer, EPA