ES -i 

### EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVIT IES

...................................... 1 ES.2 KEY RESULTS OF THE A NALYSIS

........................................................................... 3 ES.2.1 Determination of Scope ................................................................................................... 3 ES.2.2 Market and Technology Assessment

............................................................................... 5 ES.2.3 Screening Analysis

.......................................................................................................... 6 ES.2.4 Engineering Analysis ....................................................................................................... 6 ES.2.5 Markups Analysis .......................................................................................................... 12 ES.2.6 Energy Use Characterization

......................................................................................... 12 ES.2.7 Life

- Cycle Cost and Payback Period Analyses

............................................................. 13 ES.2.7.1 Life -Cycle Cost and Payback Period Analysis Results ............................... 15 ES.2.8 Shipments Analysis

........................................................................................................ 16 ES.2.9 National Impact Analysis

............................................................................................... 17 ES.2.9.1 National Energ y Savings Analysis

.............................................................. 18 ES.2.9.2 Net Present Value Analysis

......................................................................... 18 ES.2.10 P reliminary Manufacturer Impact Analysis

................................................................... 19 ES.2.11 Other Analyses

............................................................................................................... 19 ES.3 ISSUES ON WHICH THE U.S. DEPARTMENT OF ENERGY SEEKS PUBLIC COMMENT

................................................................................................................... 20 ES.3.1 Efficiency Requirements for Dual/Multiple

- Voltage Secondaries

................................ 20 ES.3.2 Dual/Multiple

- Voltage Transformers with Varying Basic Impulse Levels

................... 20 ES.3.3 Weighted

- Average Losses from Multiple Loading Points

............................................ 21 ES.3.4 Current DOE Test Procedure ......................................................................................... 21 ES.3.5 Symmetric Core Designs

............................................................................................... 21 ES.3.6 Core Deactivation Technology ...................................................................................... 21 ES.3.6.1 Nanotechnology Composites ....................................................................... 21 ES.3.7 Representative Units for Single

- Phase, Liquid

- Imme rsed Design Lines

...................... 22 ES.3.8 Representative Unit for Design Line 5

.......................................................................... 22 ES.3.9 Representative Unit for Design Line 13

........................................................................ 22 ES.3.10 Additional Representative Units

.................................................................................... 22 ES.3.11 Scaling Methodology ..................................................................................................... 22 ES.3.12 Design Option Combinations ........................................................................................ 22 ES.3.13 Materials Prices

.............................................................................................................. 23 ES.3.14 Factory Overhead Markup for Designs Using a Prefabricated Amorphous Core ......... 23 ES.3.15 Shipping Costs ............................................................................................................... 23 ES.3.16 Additional Costs for Amorphous Designs in Large, Dry- Type Design Lines

............... 23 ES.3.17 Trial S tandard Levels

..................................................................................................... 24 ES.3.18 Impact on Manufacturers ............................................................................................... 24 ES.3.19 Supply of Core Steels

.................................................................................................... 24 ES.3.20 Valuing Air -Borne Emission Reductions ...................................................................... 24 ES.3.21 Hourly Load Data .......................................................................................................... 25 ES.3.22 Installation Practices

...................................................................................................... 25 ES.3.23 Distributer Markups ....................................................................................................... 25ES

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### ES.3.24 Evaluation of Energy Efficiency in the Basecase

.......................................................... 25 ES.3.25 Replacement and Maintenance Practices

....................................................................... 25 ES.3.26 Sizing Practices

.............................................................................................................. 26 ES.3.27 Efficiency Trends

........................................................................................................... 26

LIST OF TABLES

Table ES.2.1 Equipment Classes for Distribution Transformers ..................................................... 5 Table ES.2.2 Engineering Design Lines and Representative Units for Analysis ........................... 7 Table ES.2.3 Summary of Baselines and Candidate Standard Levels for Distribution Transformer Representative Units

........................................................................... 9 Table ES.2.4 Summary of Incremental Manufacturer Selling Prices over the Baseline for Distribution Transformer Representative Units

..................................................... 10 Table ES.2.5 Markups for Distribution Transformers .................................................................. 12 Table ES.2.6 Summary of Life-Cycle Cost Savings (2010$) ....................................................... 15 Table ES.2.7 Summary of Payback Period Results (Years) ......................................................... 16 Table ES.2.8 Cumulative Shipments of Transformers by Candidate Standard Level (Billion kVA), 2015 - 2044 .................................................................................... 17 Table ES.2.9 Mapping of Design Line (DL) to Equipment Class (EC) ....................................... 18 Table ES.2.10 Summary of Cumulat ive National Energy Savings and Net Present Value Impact

.................................................................................................................... 19

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the Distribution Transformer Rulemaking Process

..................................................................................................................... 2 Figure ES.2.1 Cost-Efficiency Outputs of Engineering Analysis for Design Line 7 ................... 11ES

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### EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMIN ARY ANALYSIS ACTIVIT IES

Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE or Department) to establish energy conservation standards that are technologically feasible and economically justified, and that would achieve the maximum improvement in energy efficiency. This executive summary highlights the activities associated with this preliminary analysis that DOE conducted when considering amended energy conservation standards for distribution
transformers . The executive summary also describes key results from DOE’s preliminary analysis and delineates issues on which DOE seeks comm ent. These issues are highlighted in the public meeting presentation and are further discussed in chapter 2 of the preliminary technical support document (TSD).

Figure ES.1 .1 presents a summary of the analytical components of the standards- setting process and illustrates how key results are generated. The focal point of the figure is the center column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how the analyses fit into the process and relate to each other. Key inputs are the types of data and other information required by the analyses. DOE obtains some key information from public
d atabases and collects other inputs from interested parties or persons having special knowledge and expertise. Key outputs are analytical results that feed directly into the standards

- setting process. The issues on which DOE seeks comment from interested pa rties derive from the key results that are generated by the preliminary analyses. Arrows connecting analyses show the types of information that feed from one analysis to another.ES

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### Figure ES.1.1 Flow Diagram of Analyses for the Distribution Transformer Rulemaking ProcessES

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### ES.2 KEY RESULTS OF THE A NALYSIS

The following sections describe in detail the key analyses DOE performed.

ES.2.1 Determination of Scope

Amendments to the Energy Policy and Conservation Act of 1975 (EPCA) direct DOE to
determine whether to amend energy conservation standards for distribution transformers . (42 U.S.C. 6295(o )( 2 )( A )) DOE published a final rule in October 2007 that prescribed energy conservation standards for liquid

- immersed and medium-voltage dry- type (MVDT) distribution
transformers. 72 FR 58190 (Oct. 12, 2007); see 10 CFR 431.196(b)- (c). During the course of that rulemaking, the Energy Policy Act of 2005 (EPACT) , Pub. L. 109-58, set standards for lowvoltage dry -type distribution (LVDT) transformers. (EPACT 2005, Section 135(c); codified at 42 U.S.C. 6295(y)) Therefore , DOE had removed these transformers from the scope of the
rule making. 72 FR 58191

After the publication of the final rule, certain parties filed petitions challenging the final rule. They alleged that, in developing its energy conservation standards for distribution transformers, DOE did not comply with certain applicable provisions of EPCA and the National Environmental Policy Act of 1969 (NEPA), 42 U.S.C. 4321 et seq . On July 10, 2009, DOE and the petitioners subsequently entered into a settlement agreement to resolve the appeals. The settlement agreement outlined an expedited timeline for DOE to determine whether to amend the energy conservation standards for liquid-immersed and medium-voltage dry-type distribution
transformers. Under the terms of the settlement agreement, DOE must publish , no later than October 1, 2011, either a determination that the standards for these distribution transformers do not need to be amended or a notice of proposed rulemaking ( NOPR ) that includes any new proposed standards and that meets all applicable requirements of EPCA and NEPA. If DOE finds that amended standards are warranted, DOE must publish a final rule containing such amended
standards no later than October 1, 2012. This document is DOE ’s first step in satisfy ing the requirements of the settlement agreement.

DOE is initiating this rulemaking at the preliminary analysis stage rather than the
framework document stage. In considering new or amended standards for a given product or type of equipment, DOE’s current practice generally is to publish a framework document as the first step in the rulemaking process, and to subsequently issue a TSD that contains the
De partment’s preliminary analyses as to potential standards. The framework document generally advises interested parties of the analytical methods, data sources, and key assumptions DOEES

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### plans to use in considering the adoption of standards for the product or equipment type. Typically, the document does not contain any analysis of the data. However, b ecause the previous rulemaking to develop standards for distribution transformers was completed relatively recently, DOE has a set of methodologies, data sources and assumptions that have been vetted recently and revised according to public comments that DOE can use to perform the analyses needed for this rulemaking. Therefore, DOE is not issuing a framework document for this rulemaking. DOE will conduct the analyses referenced by the petitioners ’ complaint and required by EPCA and NEPA according to standard practices for energy conservation standard rulemakings. Hence , DOE is initiating this rulemaking at the preliminary analysis stage and has prepared a prel iminary TSD on which it is requesting comment.

At present, DOE plans to examine in this rulemaking amended standards for LVDT distribution transformers, as well as revised standards for liquid -immersed and MVDT
transformers. DOE is not required to consi der LVDT distribution transformers as part of the settlement agreement. As such, DOE may subsequently opt to conduct a separate rulemaking for
LVDT transformers with a different timeline. However, the preliminary analysis considers low

voltage dry

- type d istribution transformers along with liquid

- immersed and MVDT distribution
transformers.

The definition of a distribution transformer was presented in EPACT, and then further refined by DOE when it was codified into Title 10 of the Code of Federal Regulations, Part 431 (10 CFR Part 431) on April 27, 2006. 71 FR 24972.

As set forth in 10 CFR 431.192, Distribution transformer (1) Has an input voltage of 34.5 kV or less; means a transformer that -

(2) Has an output voltage of 600 V or less; (3) Is ra ted for operation at a frequency of 60 Hz; and (4) Has a capacity of 10 kVA [kilo

- volt ampere] to 2500 kVA for liquid

- immersed units and 15 kVA to 2500 kVA for dry-type units; but (5) The term “distribution transformer” does not include a transformer that is an– (i) Autotransformer; (ii) Drive (isolation) transformer; (iii) Grounding transformer; (iv) Machine-tool (c ontrol) t ransformer; (v) Nonventilated t ransformer;ES

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### (vi) Rectifier t ransformer; (vii) Regulating t ransformer; (viii) Sealed t ransformer; (ix) Special -i mpedance t ransformer; (x) Testing t ransformer; (xi) Transformer with t ap range of 20 percent or more; (xii) Uninterruptible p ower supply t ransformer; or (xiii) Welding t ransformer.

ES.2.2 Market and Technology Assessment

A market and technology assessment characterizes the relevant equipment markets and technology options, including prototype designs. See chapter 3 of t he preliminary TSD for
details.

DOE generally divides covered equipment into equipment classes by the type of energy
used

, capacity

, or other performance

- related features that affect customer utility or efficiency. Different energy conservation standards may apply to different equipment classes. (42 U.S.C. 6295(q)) Table ES.2 .1 describes all of the equipment classes DOE is considering in this rulemaking.

Table ES.2.1 Equipment Classes for Distribution Transformers
Equi pment

C lass es Insulation Voltage Phase Basic Impulse
Level ( BIL ) Rating kVA Range

1 Liquid

- Immersed Medium Single

- 10

- 833 kVA

2 Liquid

- Immersed Medium Three - 15

- 2500 kVA

3 Dry

- Type Low Single

- 15

- 333 kVA

4 Dry

- Type Low Three

- 15

- 1000 kVA

5 Dry

- Type Medium Single 20

- 45kV BIL 15

- 833 kVA

6 Dry

- Type Medium Three 20

- 45kV BIL 15

- 2500 kVA

7 Dry

- Type Medium Single 46

- 95kV BIL 15

- 833 kVA

8 Dry

- Type Medium Three 46

- 95kV BIL 15

- 2500 kVA

9 Dry

- Type Medium Single ≥ 96kV BIL 75

- 833 kVA

10 Dry

- Type Medium Three ≥ 96kV BIL 225

- 2500 kVAES

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### DOE addresses (1) manufacturer market share and characteristics, (2) existing regulatory
and non- regulatory initiatives for improving equipment efficiency, and (3) trends in equipment
characteristics and retail markets. This informatio n provides data and resource material throughout the analysis.

DOE reviews literature and interview s manufacturers to develop an overall understanding of the distribution transformer industry . Industry publications including trade journals and literature from manufacturers, government agencies, and trade organizations provide the bulk of the information, which includes: (1) manufacturers and their market share , (2) shipments by equipment type , (3) equipm ent information , and (4) industry trends.

DOE typically uses information about existing and past technology options and prototype designs to determine which technologies and combinations of technologies manufacturers use to attain higher performance lev els. In consultation with interested parties, DOE develops a list of technologies to be considered. The technologies initially identified include all those DOE believes are technologically feasible.

ES.2.3 Screening Analysis

DOE develops an initial list of options for enhancing efficiency from the technologies that the technology assessment identified as feasible. In consultation with interested parties, DOE reviews the list to assess whether the technologies are practicable t o manufacture, install, and service; would adversely affect equipment utility or availability; or would have adverse impacts on health and safety. In the subsequent engineering analysis, DOE further examines the technology options that it did not remove fr om consideration in the screening analysis. See chapter 4 of the preliminary TSD for details.

ES.2.4 Engineering Analysis

The engineering analysis develops cost

- efficiency relationships that show a manufacturer’s cost of achieving increased efficiency. DOE uses manufacturer markups to
determine the manufacturer production cost (MPC) and then to convert the MPC to manufacturer selling price (MSP) for each unit. See chapter 5 of the preliminary TSD for details.

The engineering analysis analyzed 13 key design lines that cover the range of equipment
classes within the distribution transformer market. Within each design line, DOE selected aES

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### representative unit to analyze in the engineering analysis. Table ES.2 .2 outlines the design lines and representative units selected for each equipment class.

Table ES.2.2 Engineering Design Lines and Representative Units for Analysis

E C* DL * Type of Distribution Transformer kVA Range Representative Unit for this Engineering Design Line

1 1 Liquid

- immersed, single

- phase, rectangular tank 10



### – 167 50 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 240/120V secondary, rectangular tank

2 Liquid

- immersed, single

- phase, round tank 10



### – 167 25 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 120/240V secondary, round tank

3 Liquid

- immersed, single

- phase 250



### – 833 500 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 277V secondary

2 4 Liquid

- immersed, three

- phase 15



### – 500 150 kVA, 65 **°** C, three

- phase, 60Hz, 12470Y/7200V primary, 208Y/120V secondary

5 Liquid

- immersed, three

- phase 750



### – 2500 1500 kVA, 65 **°** C, three

- phase, 60Hz, 24940GrdY/14400V primary, 480Y/277V secondary

3 6 Dry

- type, low

- voltage, single

phase 15



### – 333 25 kVA, 150 **°** C, single

- phase, 60Hz, 480V primary, 120/240V secondary, 10kV BIL

4 7 Dry

- type, low

- voltage, three

phase 15



### – 150 75 kVA, 150 **°** C, three

- phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL

8 Dry

- type, low

- voltage, three

phase 225



### – 1000 300 kVA, 150 **°** C, three

- phase, 60Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL

6 9 Dry

- type, medium

- voltage, three

- phase, 20

- 45kV BIL 15



### – 500 300 kVA, 150 **°** C, three

- phase, 60Hz, 4160V Delta primary, 480Y/277V secondary, 45kV BIL

10 Dry

- type, medium

- voltage, three

- phase, 20

- 45kV BIL 750



### – 2500 1500 kVA, 150 **°** C, three

- phase, 60Hz, 4160V primary, 480Y/277V secondary, 45kV BIL

8 11 Dry

- type, medium

- voltage, three

- phase, 46

- 95kV BIL 15



### – 500 300 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL

12 Dry

- type, medium

- voltage, three

- phase, 46

- 95kV BIL 750



### – 2500 1500 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL

10 13 Dry

- type, medium

- voltage, three

- phase, 96

- 150kV BIL 225



### – 2500 2000 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 125kV BIL
* E C = Equipment Class. DL = Design Line.



### For each representative unit , DOE identified several design option combinations to characterize the range of possible efficiencies. For each design, DOE calculated the MSP and efficiency to generate cost

- efficiency curves for each representative unit. To calculate MSP,
DOE used a commerci ally available software program to generate a bill of materials containing information on the transformer core, conductors, enclosure, and other components. DOE then applied additional cost estimates for labor and other manufacturer markups that are speci fic to the distribution transformer industry to arrive at the final MSP. DOE then extrapolated the results of its analysis from the unit studied to the other equipment with different kVA ratings within that same engineering design line. The technique DOE used to extrapolate the findings on the representative unit to the other kVA ratings within a design line is referred to as “the 0.75ES

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### scaling rule.” This rule states that, for similarly designed transformers, costs of construction and
losses scale to the ratio of kVA ratings raised to the 0.75 power. See chapter 5 of the preliminary
TSD for details.

Table ES.2 .3 presents the efficiency identified for each baseline and candidate standard level (CSL) in the engineering analysis

. The baseline CSL is the minimum efficiency rating evaluated in DOE’s analysis, determined by the current minimum efficiency standards. Table
ES.2 .4 presents the incremental MSP for each of the least -costly design options at each CSL.ES

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### Table ES.2.3 Summary of Baselines and Candidate Standard Levels for Distribution Transformer Representative UnitsDesignLine Representative Unit Base

line CSL1 CSL2 CSL3 CSL 4 CSL 5 CSL 6 CSL 7 Eff. [%] Eff. [%] Eff. [%] Eff. [%] Eff. [%] Eff. [%] Eff. [%] Eff. [%]

1 50 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 240/120V secondary, rectangular tank 99.08 99.17 99.27 99.36 99.46 99.55 99.60 N/A

2 25 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 120/240V secondary, round tank 98.91 99.02 99.13 99.24 99.35 99.46 N/A N/A

3 500 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 277V secondary 99.42 99.48 99.54 99.57 99.61 99.67 99.73 99.76

4 150 kVA, 65 **°** C, three

- phase, 60Hz, 12470Y/7200V primary, 208Y/120V secondary 99.08 99.17 99.27 99.36 99.46 99.55 99.60 N/A

5 1500 kVA, 65 **°** C, three

- phase, 60Hz, 24940GrdY/14400V primary, 480Y/277V secondary 99.42 99.48 99.54 99.57 99.61 99.67 99.73 N/A

6 25 kVA, 150 **°** C, single

- phase, 60Hz, 480V primary, 120/240V secondary, 10kV BIL 98.00 98.23 98.47 98.60 98.70 98.93 99.17 99.40

7 75 kVA, 150 **°** C, three

- phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL 98.00 98.23 98.47 98.60 98.70 98.93 99.17 99.40

8 300 kVA, 150 **°** C, three

- phase, 60Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL 98.60 98.80 99.02 99.19 99.41 99.59 N/A N/A

9 300 kVA, 150 **°** C, three

- phase, 60Hz, 4160V Delta primary, 480Y/277V secondary, 45kV BIL 98.82 98.97 99.12 99.28 99.43 99.58 N/A N/A

10 1500 kVA, 150 **°** C, three

- phase, 60Hz, 4160V primary, 480Y/277V secondary, 45kV BIL 99.22 99.31 99.40 99.50 99.59 99.68 N/A N/A

11 300 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL 98.67 98.84 99.00 99.17 99.33 99.50 N/A N/A

12 1500 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL 99.12 99.21 99.30 99.39 99.48 99.57 99.66 N/A

13 2000 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 125kV BIL 99.15 99.25 99.35 99.46 99.56 99.66 N/A N/AES

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### Table ES.2.4 Summary of Incremental Manufacturer Selling Prices over the Baseline for Distribution Transformer Representative UnitsDesignLine Representative Unit Base

line CSL1 CSL2 CSL3 CSL 4 CSL 5 CSL 6 CSL 7

$ $ $ $ $ $ $ $

1 50 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 240/120V secondary, rectangular tank - 234 501 578 854 1,406 2,109 N/A

2 25 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 120/240V secondary, round tank - 235 416 605 751 1,312 N/A N/A

3 500 kVA, 65 **°** C, single

- phase, 60Hz, 14400V primary, 277V secondary - 675 2,386 2,246 3,005 4,544 7,140 11,922

4 150 kVA, 65 **°** C, three

- phase, 60Hz, 12470Y/7200V primary, 208Y/120V secondary - 364 331 764 1,313 2,730 4,286 N/A

5 1500 kVA, 65 **°** C, three

- phase, 60Hz, 24940GrdY/14400V primary, 480Y/277V secondary - 1,663 5,509 6,040 6,694 10,613 43,740 N/A

6 25 kVA, 150 **°** C, single

- phase, 60Hz, 480V primary, 120/240V secondary, 10kV BIL - (2) 146 264 303 452 591 1,219

7 75 kVA, 150 **°** C, three

- phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL - 18 117 288 565 1,171 1,234 2,703

8 300 kVA, 150 **°** C, three

- phase, 60Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL - 520 1,037 2,734 3,730 7,334 N/A N/A

9 300 kVA, 150 **°** C, three

- phase, 60Hz, 4160V Delta primary, 480Y/277V secondary, 45kV BIL - 828 2,780 4,189 5,443 9,715 N/A N/A

10 1500 kVA, 150 **°** C, three

- phase, 60Hz, 4160V primary, 480Y/277V secondary, 45kV BIL - 5,561 9,469 12,907 14,341 31,275 N/A N/A

11 300 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL - 460 2,079 3,861 5,617 10,715 N/A N/A

12 1500 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL - 2,567 5,170 11,072 12,556 19,192 33,255 N/A

13 2000 kVA, 150 **°** C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 125kV BIL - 3,929 10,513 18,017 24,196 44,046 N/A N/A



### DOE uses a software model to generate thousands of potential design options for each representative unit analyzed in the engineering analysis. DOE considers five to eight different design option combinations for each representative unit, and generates over 500 unique designs for each combination of design options. The output of the engineering analysis is th is set ofES

- 11 

### thousands of unique designs for each representative unit. Figure ES.2 .1 illustrates the cost

efficiency relationship of these designs for design line 7, a 75 kVA, three- phase, LVDT distribution transformer. DOE generates a similar set of designs for each of the 13 representative
units identified in Table ES.2 .4

.

Figure ES.2.1 Cost

- Efficiency Outputs of Engineering Analysis for Design Line 7

DOE considered an advanced technology scenario that examines the cost- efficiency relationship of symmetric core designs. Symmetric core designs use a continuously wound core with 120 degree radial symmetry, resulting in a triangularly shaped core when viewed from above. This type of design has several benefits over traditional core designs, including reduced weight, volume, no-load losses, noise, vibration, stray magnetic fields, inrush current, and power
in the third harmonic. DOE simulated symmetric co re designs for each three -phase design line by adjusting the traditional core designs. After the adjustments, symmetric core designs were typically less costly and more efficient tha n traditional core designs. DOE examined an additional CSL for each of these design lines to analyze the maximum possible efficiency, which is not attainable for traditional core designs. $1,500 $2,500 $3,500 $4,500 $5,500 $6,500 $7,500

97.80% 98.00% 98.20% 98.40% 98.60% 98.80% 99.00% 99.20% 99.40% 99.60%Manufacturer Selling Price ($)

Efficiency at 35% Load, Temperature Corrected M12AlAl_bl_3leg
M12CuAl_bl_3leg
M6AlAl_bl_3leg
M6AlAl_fm_3leg
M4CuAl_fm_3leg
M3AlAl_fm_3leg
H0CuCu_fm_3leg
SA1CuCu_5leg

CSLs CSL 0 CSL 1

CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 CSL 7ES

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### DOE also considered core deactivation technology, which uses a system of smaller transformers to replace a single, larger transformer. These smaller transformers can then be powered on and off in response to shifts in loading demand, which results in energy savings at
lower load factors whe n some of the component transformers can be deactivated. Core deactivation technology presents energy sa vings potential at lower load factors, but may not demonstrate an efficiency benefit at the current test procedure load factor. In the preliminary analysis, DOE seeks comment on a potential revision to the test procedure that will examine a weighted

- av erage loading for core deactivation technology.

ES.2.5 Markups Analysis

The markups analysis (see chapter 6 of the preliminary TSD ) develops appropriate markups in the distribution chain to convert the estimates of manufacturer cost derived in the engineering an alysis to installed transformer prices. Transformers are specialty items, often

custom- built with unlisted prices. The engineering analysis ( see chapter 5 of the preliminary
TSD ) provided the manufacturer selling prices , including shipping costs, for each of the transformer designs analyzed by the LCC. DOE derived a set of prices for each transformer design produced by the engineering analysis by applying markups to the manufacturer selling price

. These markups represent all the costs associated wit h bringing a manufactured transformer into service as an installed piece of electrical equipment at a customer’s site.

For both liquid-immersed and dry-type transformers, DOE estimated national averages
for sales tax, an installation labor and equipment markup, and weight-dependent installation

costs. Table ES.2 .5 summarizes the markup rates.

Table ES.2.5 Markups for Distribution Transformers

Marku ps Markup Rate Liquid

- I mmersed Dry

- T ype Distributor 1.07 1.15 Installation/Contractor Materials 1.10 1.10 Installation/Contractor Labor/Equip . (LE) 1.43 1.52 Sales Tax Markup 1.05 1.05

ES.2.6 Energy Use Characterization

The energy use characterization, which assesses the potential energy savings resulting from new or amended efficiency standards, provides the basis for developing energy savingsES

- 13 

### used in the life-cycle cost (LCC) and subsequent analyses. The energy use and end

- use load characterization analysis (see Chapter 7 of the preliminary TSD) produced energy use estimates
and end- use load shapes a 

### for distribution transformers. The energy use estimates enable DOE to evaluate the energy savings from the operation of distribution transformer equipment at various efficiency levels, while the end -use load characterization allowed evaluation of the impact on monthly and peak demand for electricity from the operation of transformers.

The energy used by distribution transfor mers is characterized by two types of losses. The
first are no -load losses, which are also known as core losses. No-load losses are roughly constant and exist whenever the transformer is energized (i.e., connected to live power lines). The second
are load losses, which are also known as resistance or I 2 

### R losses. Load losses are proportional to the square of the instantaneous load being served by the transformer. Because the application of distribution transformers varies significantly by type of transformer (liquid -immersed or drytype) and ownership (electric utilities own approximately 95 percent of liquid- immersed transformers, while commercial/industrial entities use mainly dry

- type), DOE performed two separate end

- use load analyses to evaluate distribut ion transformer efficiency. The analysis for liquid -immersed transformers assumes that these are owned by utilities, and uses hourly load andprice data to estimate the energy, peak demand and cost impacts of improved efficiency. For drytype transformers, the analysis assumes that these are owned by commercial and industrial customers, so the energy and cost savings estimates are based on monthly building- level demand and energy consumption data and marginal electricity prices. In both cases, the energy an d cost savings are estimated for individual transformers, and aggregated to the national level using weights derived from either utility or commercial/industrial building data.

Chapter 7 provides greater detail on the methods, data, and assumptions used for the Energy Use and End- Use Load Characterization analyses.

ES.2.7 Life -Cycle Cost and Payback Period Analyses

Stipulating new or amended energy conservation standards for equipment results in changes in consumer operating expenses ( usually a decrease ) and changes in consumer price ( usually an increase ). DOE analyzed the net effect of amended standards on consumers by evaluating the LCC using the cost- efficiency relationship derived in the engineering analysis, as well as the energy costs derived from the en ergy use characterization. Inputs to the LCC

a End

- use load shape is an expression used to describe the quantity of electricity used by a distri bution transformer, measured over a period of time, usually one year.ES

- 14 

### calculation included the installed cost to the consumer (purchase price plus installation cost), operating costs (primarily energy expenses), the expected lifetime of the equipment, and a
discount rate.

Because the installed cost of equipment typically increases while operating cost typically decreases in response to new or amended standards, there is a point when the equipment has higher- than

- baseline efficiency wh ile the net operating -cost benefit (in d ollars) since the time of purchase is equal to the incremental first cost of purchasing the higher efficiency equipment . The length of time required for equipment to reach this cost-equivalence point is known as the payback period (PBP).

DOE conducted th e LCC and PBP analyses using values that reflect utilization of the equipment in the field. DOE identified several input values for estimating the LCC, including
retail equipment prices, energy prices, equipment lifetimes, and discount rates.

For dry- ty pe distribution transformers, DOE used utility tariff data to develop monthly marginal electricity prices for each transformer in the LCC sample. The marginal prices are calculated by taking account of the difference between the transformer’s losses in the base

- case and for a candidate standard level, in combination with the associated change in energy use. The price used is based on commercial and industrial tariffs. DOE then applied the calculated monthly prices to the estimated electricity use by the tra nsformer in each corresponding month. For liquid- immersed distribu tion transformers, DOE used hourly system lambda data , as a proxy for system price data, from the Federal Energy Regulatory Commission ( FERC ) (for regions without wholesale markets) and day- ahead market clearing price data (for regions with wholesale markets) to determine average hourly prices of electricity. To estimate the future trends in energy prices, DOE used projections from the U.S. Energy Information Administration’ s ( EIA’s ) Annual Energy Outlook 2010 ( AEO 20 10 ). b



### Because the basis for the lifetime estimates in the literature for distribution transformers is uncertain, and in view of the Oak Ridge National Laboratory (ORNL) Determination Analysis of Energy Conservation Standards for Distribution Transformers

, ORNL -6847 that estimated a national average lifetime for utility owned transformers at 31.95 years, DOE assumed that the average life of distribution transformers is 32 years. This lifetime assumption includes a constant

b AEO 2010 presents long

- term projections of energy supply, demand, and prices through 2035, based on results from EIA’s National Energy Modeling System (NEMS).ES

- 15 

### fail ure rate of 0.5 percent/year due to lightning and other random failures unrelated to transformer age, and an additional corrosive failure rate of 0.5 percent/year starting at year 15. DOE adjusted the retirement distribution to maintain an average life of 32 years.

Using the projected distribution of equipment efficiencies for each design line , DOE assigned a specific equipment efficiency to each sample transformer. If a transformer was assigned a n equipment efficiency that is greater than or equal to th e efficiency of the standard level under consideration, the LCC calculation would show that this transformer is not impacted by that standard level.

ES.2.7.1 Life -Cycle Cost and Payback Period Analysis Results

Table ES.2 .6 show summary LCC Savings results and Table ES.2 .7 show summary PBP
results analyses for all design lines at each cons idered candidate standard level (CSL)

.

Table ES.2.6 Summary of Life-Cycle Cost Savings (2010$)
Design

Line Rated Capacity

( kVA ) Candidate Standard Level

1 2 3 4 5 6 7

1 50 221.1 1,138.9 1,271.8 1,347.7 944.8 172.7 N/A
2 25 83.9 507.8 490.2 362.9 -130.4 N/A N/A
3 500 935.8 5,705.0 7,179.7 7,662.4 8,067.0 6,559.5 4,087.1
4 150 2,309.6 2,592.4 2,974.4 3,203.3 2,776.7 1,309.4 N/A
5 1500 7,827.9 19,260.0 19,625.1 20,091.7 18,797.7 -10,105.4 N/A
6 25 86.4 100.9 56.8 136.4 157.1 29.4 -820.3
7 75 243.5 532.7 625.8 657.9 816.8 913.5 -782.8 8 300 1,375.9 2,625.6 2,395.9 3,760.7 226.7 N/A N/A
9 300 1,382.7 1,455.0 2,312.5 2,556.8 -1,572.0 N/A N/A
10 1500 2,417.0 7,604.3 12,276.5 12,988.2 -7,203.8 N/A N/A
11 300 562.9 1,942.5 1,317.5 197.1 -7,054.2 N/A N/A
12 1500 -167.6 2,643.9 7,473.9 9,063.2 4,961.7 -18,429.1 N/A
13 2000 3,050.3 4,076.1 10,600.3 11,919.2 -9,580.7 N/A N/AES

- 16 

### Table ES.2.7 Summary of Payback Period Results (Years)
Design

Line Rated Capacity

( kVA ) Candidate Standard Level

1 2 3 4 5 6 7

1 50 26.8 8.4 10.4 12.5 22.6 31.2 N/A
2 25 26.5 13.7 16.7 20.6 30.4 N/A N/A
3 500 18.3 12.2 8.1 9.1 11.1 17.3 22.7
4 150 5.8 4.8 9.4 11.8 23.7 33.5 N/A
5 1500 16.5 6.5 7.5 8.3 17.8 39.9 N/A
6 25 12.5 19.2 19.7 15.0 15.6 18.8 33.0
7 75 0.3 7.8 9.8 11.2 12.3 12.7 24.0
8 300 6.9 6.9 11.9 10.7 18.6 N/A N/A
9 300 13.6 13.6 13.0 14.1 21.7 N/A N/A
10 1500 18.5 13.3 10.4 11.1 22.5 N/A N/A
11 300 17.5 13.2 15.3 18.5 34.4 N/A N/A
12 1500 23.1 15.6 13.8 13.0 16.0 27.6 N/A
13 2000 14.4 17.4 13.7 13.8 21.8 N/A N/A



### Chapter 8 of the preliminary TSD provides more details on the methods, data, and assumptions used for the LCC and PBP analyses

ES.2.8 Shipments Analysis

Shipment forecasts are needed to calculate the national impacts of new or amended standards on energy use, net present value ( NPV ) of consumer costs and savings, and future
manufacturer cash flows for each representative equipment clas s under consideration . DOE obtained forecasts of shipments for the base case and each potential standards case as inputs to the National Energy Savings (NES) model that is used to estimate th e total national energy savings as a function of shipments. For the distribution transformer rulemaking, DOE developed an accounting framework to prepare shipment scenarios for the base case and each of the CSLs

. The model keeps track of the aging and replacement of transformer capacity given a projection
of future transformer sales based on electricity sales obtained from EIA’s Annual Electric Power Industry Database, 2008

. The framework uses annual transformer sales and the age distribution
of the in- service stock to calculate equipment costs for the NPV and ener gy use for the NES, respectively. New transformer capacity demand is created by growth in electrical demand. Transformer shipments, a retirement function, and the initial number of transformers in service influence how transformers in service and supply of transformer capacity change over time.

Table ES.2 .8 shows the total shipments for all candidate standard levels for liquid-ES

- 17 

### immersed and dry- type distribution transformers over the analysis period from 2015 to 2044.

Table ES. 2.8 Cumulative Shipments of Transformers by Candidate Standard Level (Billion kVA) , 2015 - 2044 Candidate Standard Level Base

case 1 2 3 4 5 6 7
Liquid- Immersed 1.96 1.96 1.95 1.95 1.94 1.93 1.93 1.93
Low

- Voltage Dry

- Type 0.63 0.63 0.63 0.62 0.62 0.62 0.62 0.62
Medium- Voltage Dry

- Type 0.23 0.23 0.23 0.23 0.22 0.22 0.22 0.22



### Chapter 9 of the preliminary TSD provides more details on the methods, data, and assumptions used for the Shipments analyses.

ES.2.9 National Impact Analysis

The national impact analysis (NIA) estimates the following national impacts from possible candidate standard levels: (1) NES, (2) monetary value of the energy savings due to new or amended standards, (3) increased total installed costs of the considered equipment due to new or amended standards, and (4) NPV of energy savings (difference between value of energy savings and increased total installed costs). DOE prepared a spreadsheet model to forecast energy savings and national consumer economic costs and savings resulting from new standards.

The NES and NPV calculations use the LCC calculations as the source of most input data. The LCC calculations are performed by design line, whereas an y eventual standards would be promulgated by equipment class. As a first step, therefore, the NES calculation aggregates the LCC design line data to calculate data relevant to equipment classes. Design

- line

- to -equipmentclass aggregation is the process by which the Department took the results from the economic analysis of engineering design lines and combined them to provide estimates of economic impact by equipment class. To represent the variety of designs in some equipment classes, the Department analyz ed up to three different design lines per equipment class. Specifically, equipment class 1 (single -phase, medium- voltage, liquid

- immersed transformers) is represented by three design lines and equipment class 2 (three-phase, medium-voltage, liquid- immersed transformers) is represented by two design lines. For single- phase equipment classes 5, 7, and 9, there are no directly corresponding dry- type single -phase design lines (DLs), the Department used the appropriate three-phase design lines of similar BIL ra ting, and divided by 3. Table
ES.2 .9 presents the mapping of design line to equipment class.ES

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### Table ES.2.9 Mapping of Design Line (DL) to Equipment Class (EC)

Equipment Class BIL* (kV) Capacity (kVA) Mapping
EC 1, Liquid-Immersed, MV,** Single- Phase Any 10-833 DL 1 + DL 2 + DL 3 EC 2, Liquid- Immersed, MV, Three

- Phase Any 15-2500 DL 4 + DL 5 EC 3, Dry- Type, LV,† Single

- Phase ≤ 10 15-333 DL 6 EC 4, Dry- Type, LV, Three

- Phase ≤ 10 15-1000 DL 7 + D L8 EC 5, Dry-Type, MV, Single- Phase 20-45 15-833 (DL 9 ÷ 3) +(DL 10 ÷ 3) EC 6, Dry- Type, MV, Three

- Phase 20-45 15-2500 DL 9 + DL 10 EC 7, Dry-Type, MV, Single- Phase 46-95 15-833 (DL 11 ÷ 3) +(DL 12 ÷ 3) EC 8, Dry- Type, MV, Three

- Phase 46-95 15-2500 DL 11 + DL 12 EC 9, Dry-Type, MV, Single- Phase ≥ 95 75-833 DL 13 ÷ 3 EC 10, Dry- Type, MV, Three

- Phase ≥ 95 225-2500 DL 13
* BIL = Basic Impulse I nsulation Lev els ** MV = Medium Voltage † LV = Low Voltage



### ES.2.9.1 National Energy Savings Analysis

DOE calculated annual NES as the difference between national energy consumption in the base case (without new energy conservation standards) and under each CSL. DOE estimated energy consumption and savings based on site energy, and converted the site energy values to primary (source) energy using factors that account for losses in transmission and distribution and in electricity gene ration. Cumulative energy savings are the sum of the annual NES, which DOE determined over the analysis period from 2015 to 2044.

Table ES.2 .10 shows summary results of both the NES and NPV for liquid- immersed and dry- type transformers.

ES.2.9.2 Net Present Value Analysis

DOE calculated net monetary savings each year as the difference between total savings in operating costs and increases in total equipment costs in the base case and amended standards cases. DOE calculated savings over the life of the equipment purchased in the forecast period. The NPV is the difference between the present value of operating cost savings and the present value of increased total installed costs. DOE used discount rates of 7 percent and 3 percent to discount future costs and savings to the present.

Table ES.2 .10 shows summary results of both the NES and NPV for liquid- immersed and dry- type transformers.ES

- 19 

### Table ES.2.10 Summary of Cumulative National Energy Savings and Net Present Value Impact

Analysis Discount Rate (%) Candidate Standard Level
1 2 3 4 5 6 7 Liquid

- Immersed Cumulative Source Savings 2044 (Quads) 0.62 1.38 1.69 1.93 2.27 2.50 2.50

Net Present Value (B 2010$) 3 5.21 13.84 15.08 14.98 8.67 -3.67 -3.74
7 0.44 2.37 1.75 0.70 -4.12 -11.65 -11.69 Dry

- Type Cumulative Source Savings 2044 (Quads) 0.27 0.64 1.01 1.32 1.83 2.09 2.38

Net Present Value (B 2010$) 3 2.14 4.85 6.51 7.99 8.43 8.08 2.75
7 0.55 1.12 1.17 1.30 0.44 -0.34 -3.86



### Chapter 10 of the preliminary TSD provides more details on the methods, data, and assumptions used for the NIA analyses.

ES.2.10 Preliminary Manufacturer Impact Analysis

A preliminary manufacturer impact analysis (MIA) assesses the potential impacts of new or amended energy conservation standards on manufacturers, such as effects on expenditures for capital conversion, marketing costs, shipments, and research and developme nt costs. Potential impacts might lead to changes in manufacturing practices for distribution transformers . DOE identified potential impacts through interviews with manufacturers and other interested parties.

As a result of preliminary interviews, DOE identified three key issues relevant to
distribution transformers : core steel availability , equipment conversion costs , and intellectual property. Chapter 12 of the preliminary TSD provides additional detail on the preliminary manufacturer impact analysis.

ES.2.11 Other Analyses

The remaining chapters of the preliminary TSD address the analyses to be performed for
the NOPR:

**•** The LCC analysis for subgroups evaluates the effects of amended energy conservation standards on various national subgroups (chapter 11).ES

- 20 

### • The utility impact analysis examines impacts of amended energy conservation standards on the generation capacity of electric utilities (chapter 13).

**•** The employment impact analysis examines the effects of amended energy conservation standards on national emplo yment (chapter 14).

**•** The environmental assessment examines the effects of amended energy conservation
standards on various airborne emissions (chapter .15)

**•** The regulatory impact analysis examines the national impacts of non -regulatory
alternatives to mandat ory energy conservation standards (chapter 16)

.

ES.3 ISSUES ON WHICH THE U.S. DEPARTMENT OF ENERGY SEEKS PUBLIC
COMMENT

DOE is interested in receiving comments on all aspects of this preliminary analysis. DOE especially invites comments or data to improve DOE’s analysis, including information that will respond to the following questions and concerns that were raised during DOE’s preliminary
interview s with manufacturers and in the preparation of the preliminary TSD.

ES.3.1 Efficiency Requirements for Dual/Multiple

- Vo ltage Secondaries

DOE understands that dual -voltage and multiple- voltage distribution transformers with reconfigurable secondaries typically exhibit small difference s in efficiency between series and parallel connections. Additionally, the less

- efficient (parallel) connection is rarely used in service of the distribution transformer. DOE seeks comment on its proposal to change the testing requirement to permit compliance testing in any secondary configuration. Additionally, DOE
seeks comment on whether the proposed revision should apply to all covered distribution
transformers or a subset of transformers. DOE welcomes the submission of any data that would support a conclusion.

ES.3.2 Dual/Multiple -Voltage Transformers with Varying Basic Impulse Levels

DOE welcomes comment on its proposal to require compliance at the lowest basic impulse level (BIL) that a dual/multiple -voltage distribution transformer is rated for operation.ES

- 21 

### ES.3.3 Weighted -Average Losses from Multiple Loading Points

Certain technology options, such as core deactivation technology, enable energy savings at lower loading points when compared to traditional transformer design options. DOE seeks

comment on its proposal to designate a weighted-average loss calculation using various loadings to capture the energy savings potential of technologies that do not follow the standard “loading vs. losses” relationship evident in traditional transformer designs. DOE welcomes comment on the appropriate weightings to use for the different load factors.

ES.3.4 Current DO E Test Procedure DOE welcomes comment on all aspects of the current test procedure for distribution transformers.

ES.3.5 Symmetric Core Designs

DOE seeks comment on symmetric core designs, their practicability to manufacture and
install , and whether or not they offer potential for efficiency improvement. In particular, DOE seeks comment on any application types for which using a symmetric core design may be
infeasible. DOE requests comment on the adjustments it used to estimate symmetric core cost

efficiency rel ationships, and welcomes any performance data generated from simulation or testing that demonstrate the performance of symmetric core designs.

ES.3.6 Core Deactivation Technology

DOE seeks comment on core deactivation technology. DOE requests input on any
consid erations necessary for analyzing core deactivation systems composed of different component transformers, or core deactivation systems for medium- voltage distribution
transformers . DOE also seeks comment on the types of applications that might benefit from the technology, and any other considerations related to the incorporation of the technology in the current test procedure. Finally, DOE seeks input on any intellectual property concerns related to employing core deactivation technology.

ES.3.6.1 Nanotechnology Composites

DOE knows of no current commercial efforts or prototype designs that employ nanotechnology composites in distribution transformers, but welcomes comment on such technology and its implications for the future of the industry.ES

- 22 

### ES.3.7 Representative Units for Single

- Phase , Liquid

- Immersed Design Lines

DOE welcomes comment on the representative units selected for the single -phase, liquidimmersed units in design line 1 through design line 3. Specifically, DOE seeks comment on its decision to use a 14400V primary voltage for design line 1 through design line 3.

ES.3.8 Representative Unit for Design Line 5

DOE welcomes comment on the representative unit selected for design line 5, a 1500 kVA, three-phase, liquid- immersed transformer. Specifically, DOE asks f or comment on the appropriate primary voltage for analyzing this selected representative unit.

ES.3.9 Representative Unit for Design Line 13

DOE seeks comment on the representative unit selected for design line 13, a 2000 kVA,
three -phase, medium-voltage dry- typ e transformer . DOE specifically would like comments on the most appropriate primary voltage for analyzing this representative unit.

ES.3.10 Additional Representative Units

DOE welcomes comment on additional representative units or design lines that should be

con sidered in its analysis. DOE welcomes comment on all aspect s of its selected representative units and design lines.

ES.3.11 Scaling Methodology

DOE uses “the 0.75 scaling rule” to scale results from analyzed representative units to
other units with kVA ratings w ithin the same engineering design line. During preliminary manufacturer interviews, DOE heard that the application of this scaling rule during the previous rulemaking for distribution transformers made it difficult to manufacture compliant transformers
fo r certain kVA ranges. DOE welcomes comment on the scaling approach used and whether an improved scaling methodology exists. DOE also welcomes comment on the extent of the impact that the previous scaled standard levels have had on the low kVA units for M VDT or for any other market segments.

ES.3.12 Design Option Combinations

DOE seeks comment on the design option combinations selected for analyzing each design line. DOE would like comments on any additional design option combinations that yieldES

- 23 

### efficiency ratings greater than the domain refined steels used in DOE’s analysis. DOE considered ZDMH for liquid-immersed designs and H-0 DR for dry- type designs.

ES.3.13 Material s Prices

During its previous rulemaking on distribution transformers, DOE collected five years of
h istorical material s prices and used five- year average prices in its analysis. During preliminary interviews, manufacturers indicated that current (2010) materials prices would better predict the future price of materials than a five -year average price. As such, DOE used 2010 materials prices for its analysis, and conducted high-price and low-price sensitivities using 2008 and 2006
material s prices, respectively. DOE requests comment on its tentative decision to consider the current (2010) material s prices as the reference case material s price rather than a five

- year average price.

ES.3.14 Factory Overhead Markup for Designs Using a Prefabricated Amorphous Core

DOE welcom es comment on its tentative decision to use the same factory overhead markup for designs using a prefabricated amorphous core as for designs for which the manufacturer produces the core. DOE used a factory overhead markup of 12.5 percent on all
direct mat erial production costs for all designs.

ES.3.15 Shipping Costs

DOE welcomes comment on its tentative decision to include shipping costs in the engineering analysis as a component of the manufacturer’s selling price. Specifically, DOE seeks comment on whether profit markups are applied to the shipping cost, and if shipping costs are typically four to eight percent of total revenue for the sale of all sizes and types of
distribution transformers.

ES.3.16 Additional Costs for Amorphous Designs in Large, Dry- Type Design Line s
DOE accounted for additional labor and hardware costs in its amorphous designs used in dry-type design lines of 1500 kVA or greater. The additional labor costs account for the extra handling necessary for working with large, amorphous cores. The additional hardware costs account for bracing necessary in such large designs to contain the coil and prevent short circuit problems that may arise. DOE seeks comment on the additional costs DOE considered for amorphous designs in design lines 10, 12, and 13. Additionally, DOE seeks comment onES

- 24 

### whether these additional costs should be considered for liquid- immersed design lines that are 1500 kVA or greater, or whether the costs are specific to dry- type designs.

ES.3.17 Trial Standard Levels

For the NOPR, DOE will develop trial standard levels (TSLs) based on the selected CSLs
for distribution transformers. DOE is considering several criteria in developing the TSLs, including, but not limited to, minimum LCC, maximum NPV, and maximum technologically

feasible efficiency. These TSLs may include combinations of CSLs and the interaction between proposed equipment classes. From the list of TSLs developed, DOE will select one as its proposed standard for the NOPR. DOE invites comment on the criteria it should use as the basis
for selection of TSLs.

ES.3.18 Impact on Manufacturers

DOE requests comment on its identification of key issues and requests data and information from interested parties that can assist in evaluating the potential impact of amended
standards on manufacturers.

ES.3.19 Supply of Core Steels

DOE welcomes comment on the supply of core steels used in its designs. In particular, DOE seeks comment on the global supply of grain

- oriented silicon steel, such as M3 and M2, and amorphous core steels compared to the projected consumption based on CSLs

.

ES.3.20 Valuing Air

- Borne Emission Reductions

DOE will conduct an environmental assessment as part of the next phase of the standards rulemaking, the NOPR. The primary environmental effects of energy conservation standards for
ballasts are the reduction of power plant emissions resulting from reduced consumption of electricity. DOE will assess these environmental effects by using the National Energy Modeling System -Building Technologies ( NEMS

- BT ) to provide key inputs to its analysis. The portion of the environmental assessment that will be produced by NEMS-BT considers carbon dioxide (CO 2 

### ), sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ), and mercury (Hg). DOE also plans on monetizing the e mission reductions due to amended standards consistent with methods used in recent DOE standards rulemakings pertaining to commercial clothes washers and other consumer products and commercial equipment. For example, in the case of CO 2 

### , the most recent
int eragency estimates of the potential global benefits resulting from reduced CO 2 

### emissions inES

- 25 

### 2010 were $4.7, $21.4, $35.1, and $64.9 per metric ton in 2007 dollars. DOE invites comments on the proposed approaches for monetizing the emission savings realized as a result of amended energy conservation standards.

ES.3.21 Hourly Load Data

DOE seeks comment on any additional sources of distribution transformer load data that
could be used to validate the e nergy u se and end-u se load c haracterization analysis.

ES.3.22 Installatio n Practices

DOE does not currently have any quantitative information on how the number of transformers installed in a building scales with either the building floor space or the building annual peak load. Thus, to account for the effect of multiple transformers on a single building,
DOE has used a simple approach, in which the building sample weight is multiplied by the number of floors in the building. DOE seeks comment on whether this approach can be improved.

ES.3.23 Distributer Markups

DOE estimated the distr ibuter markups factors for liquid-immersed and dry- type transformers at 1.07 and 1.15, respectively. These factors are based on stakeholder comment from the previous distribution transformers final rule . DOE welcomes comments on these markup factors.

ES.3.24 Evalu ation of Energy Efficiency in the Basecase

DOE welcomes comment on the base

- case evaluation rates it has tentatively selected. Specifically, f or LVDT transformers, DOE assumed 10 percent evaluators. For MVDT transformers, DOE assumed 50 percent evaluators for small- capacity transformers —design line (DL) 9 and DL 11—and 80 percent for large- capacity transformers —DLs 10, 12, and 13. DOE
would particularly like comments on the most appropriate base- case evaluati on rate for MVDT
transformers.

ES.3.25 Replacement and Maintenance Practices

DOE seeks comment on recent changes in utility distribution transformer replacement and maintenance practices. In particular, DOE would like comments on any additional sources ofES

- 26 

### utility replacement rates or maintenance and repair costs that should be considered in the analysis.

ES.3.26 Sizing Practices

DOE seeks comment on recent changes in distribution transformer sizing practices. In particular, DOE would like comments on any additional sourc es of data regarding trends in
market share across equipment classes for either liquid -immersed or dry- type transformers that should be considered in the analysis.

ES.3.27 Efficiency Trends

The Department seeks further comment on its decision to use frozen effici encies for the analysis period. Specifically, DOE would like comments on additional sources of data on trends in efficiency improvement.