To: Cyrus Nasseri, Project Manager, Test Procedures for Distribution Transformers,

U.S. Department of Energy

From: Michael Scholand, Navigant Consulting, Inc.

Date: January 10, 2005

Re: Conversation with Jerry Hodge at Howard Industries on the Alternative

Efficiency Determination Method (AEDM) Validation

Energy Conservation Test Procedures for Electric Distribution Transformers

Docket Number : EE- TP-98-550

This memo serves to document a conversation I had on January 10th with Jerry Hodge, Vice

President and General Manager of the Pole Type Transformer Division at Howard Industries,

Inc. in Laurel, Mississippi. At the direction of DOE, I contacted Mr. Hodge at Howard

Industries to gather additional information on a comment submitted by him regarding the number

of Basic Models that should be tested to validate an AEDM (Howard Industries, No. 55, p. 3).

The written comment reads:

"If efficiency is indeed to be mandated, we also suggest that in the AEDM approach,

instead of requiring only five models to be tested that you require 75 models to be tested.

We feel that only five models is a much too low of sampling size to adequately represent

all the different KVA/VOLTAGES/BIL requirements that have differing calculations to

verify adequacy of your programs. "

In our conversation, Mr. Hodge indicated that in his briefing with the Howard family (founders

of Howard Industries) about the Department of Energy Distribution Transformer Rulemakings, it

was felt that five basic models was too low a number to verify that the AEDM software would

accurately predict the efficiency of all liquid-immersed transformers. Mr. Hodge pointed out

that unlike electric motors, there is a considerable amount of variety in transformers. Indeed,

Howard Industries does not offer a "standard series of designs", instead, Mr. Hodge said,

everything they design and built is custom-manufactured for their clients. They produce only

what is the best fit for their customers, and that means considering their design constraints, their

economic evaluation formula and other needs of their clients.

Mr. Hodge believes that while there is some variety in the electric motors industry, there is a fair

degree of standardization, for example many motors are built around a few common voltages.

This situation is not true for the liquid-immersed transformer industry. All of Howard

Industries' clients get custom-built transformers which take into account their unique needs and

situations. With such a large number of design options and variety in the industry for liquidimmersed transformers, Mr. Hodge said that Howard Industries believes that 75 is a better

number of basic models to validate the AEDM. This recommended number of basic models was

selected because it seems more reasonable than five.

EE-TP-98-550 COMMENT 61

To: Cyrus Nasseri, Project Manager, Test Procedures for Distribution Transformers, 

U.S. Department of Energy 

From: Michael Scholand, Navigant Consulting, Inc. 

Date: January 10, 2005 

Re: Conversation with Jerry Hodge at Howard Industries on the Alternative 

Efficiency Determination Method (AEDM) Validation 

Energy Conservation Test Procedures for Electric Distribution Transformers 

Docket Number: EE-RMlTP-98-550 

This memo serves to document a conversation I had on January 10th with Jerry Hodge, Vice 

President and General Manager of the Pole Type Transformer Division at Howard Industries, 

Inc. in Laurel, Mississippi. At the direction of DOE, I contacted Mr. Hodge at Howard 

Industries to gather additional information on a comment submitted by him regarding the number 

of Basic Models that should be tested to validate an AEDM (Howard Industries, No. 55, p. 3). 

The written comment reads: 

"If efficiency is indeed to be mandated, we also suggest that in the AEDM approach, 

instead of requiring only jive models to be tested that you require 75 models to be tested. 

We feel that only jive models is a much too low of sampling size to adequately represent 

all the different KVAIVOLTAGESIBIL requirements that have differing calculations to 

verify adequacy of your programs. " 

In our conversation, Mr. Hodge indicated that in his briefing with the Howard family (founders 

of Howard Industries) about the Department of Energy Distribution Transformer Rulemakings, it 

was felt that five basic models was too Iowa number to verify that the AEDM software would 

accurately predict the efficiency of all liquid-immersed transformers. Mr. Hodge pointed out 

that unlike electric motors, there is a considerable amount of variety in transformers. Indeed, 

Howard Industries does not offer a "standard series of designs", instead, Mr. Hodge said, 

everything they design and built is custom-manufactured for their clients. They produce only 

what is the best fit for their customers, and that means considering their design constraints, their 

economic evaluation formula and other needs of their clients. 

Mr. Hodge believes that while there is some variety in the electric motors industry, there is a fair 

-degree of standardization, for example many motors are built around a few common voltages. 

This situation is not true for the liquid-immersed transformer industry. All of Howard 

Industries' clients get custom-built transformers which take into account their unique needs and 

situations. With such a large number of design options and variety in the industry for liquidimmersed transformers, Mr. Hodge said that Howard Industries believes that 75 is a better 

number of basic models to validate the AEDM. This recommended number of basic models was 

selected because it seems more reasonable than five.