Comment response to the published Framework Document

Fire pumps should be exempt from the proposed change in efficiency requirements. - Fire pumps provide fire water for large buildings and places of assembly. As such, they are critical to both life-safety and property protection. - These pumps are in standby mode most of the time. They normally run only during their periodic test intervals. - Higher efficiency pumps necessarily have steeper pressure versus volume (flow) curves (characteristics). This is very problematic for fire pumps. - Re-design and re-approval costs are very high. - This is a small industry. - Current designs already maximize the efficiency versus performance paradigm. - Forcing a re-design could likely result in reduced competition in this marketplace. - Fire fighters rely heavily on these pumps. Forcing a change in their characteristics would affect both fire sprinkler system design as well as how, or if, they can be safely used by fire fighters. A file has been uploaded with further details on the above.