From: Robert Berman [mailto:bermaneconomics@gmail.com]

Sent: Friday, November 11, 2011 11:16 AM

To: Phil Hopkinson

Cc: Corkran, Jerry L; Richard Parker; Freeman, Jeremiah (CONTR); rick.anderson@faypwc.com;

tballo@earthjustice.org; ScottB@LVMetals.com; john.caskey@nema.org; Cymbalsky, John;

adelaski@standardsASAP.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com;

rgreeson@federalpacific.com; bruce.r.hirsch@bge.com; jhodge@howard.com; mhyland@appanet.org;

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com;

Eric.Petersen@aksteel.com; Raymond.Polinski@ATImetals.com; artrosenfeld@gmail.com;

srosenstock@eei.org; rroy@nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgnmail.com;

kwinder@mleainc.com; mwaltner@nrdc.org; jerry.schoen@aksteel.com; Paul.Ryan@hitmet.com;

ahofmann@ publicpower.org; pkumar@publicpower.org; bsmith@federalpacific.com;

greg.coulter405@gmail.com; jmauer@standardsasap.org; Cohen, Daniel; Meyers, Aaron;

Jim.creevy@nema.org; jrossetti@mlgw.org; cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; Michael

Rivest; gjrosenquist@lbl.gov; Caitlin Johnson; Zhimei Luo; Marchetti, Emily (CONTR); charlied@uus.org;

DYoung@energy

‐ solution.com; James.Lass@cleco.com; maheshsampat@bellsouth.net; Matthew

Nardotti; Raba, Jim; Savitz, Maxine (EMAB); tpetrosino@carolina.rr.com;

chris.brown@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com;

frank.guilbault@cogentpowerinc.com; ned.efbrush@gmail.com; dbrender@cda.copper.org;

chad.kennedy@us.schneider

‐ electric.com; eduardorobles@eaton.com;

vijay.tendulkar@onyxpower.com; thomas.patzner@us.schneider

‐ electric.com;

carlosgsiqueiros@eaton.com; Robert Be rman; Trujillo, Antonio; Moore, Jack C

Subject: Re: Negotiated Rulemaking

‐ Distribution Transformers Teleconference

Even if it were that high (and Mr. Hopkinson is the only one I've seen who has put the number anywhere

near that), the efficiency objective is saving Watt

‐ hours (energy) not Watts (the capacity to save energy )

. One Watt saved for 8,760 hours per year for 30 years is 262.8 kWh (not counting leap years). Even at

Mr. Hutchinson's $20, that's just over 7¢ / kWh. If Mr. Hutchinson will examine his electric bill, as he has

reported, he will see that even as high as 7¢ it's a go od buy, and that assumes we put a ZERO value on

any environmental benefits (which is why DOE agreed to reconsider its 2007 MEPS in the first place.

Indeed, the cost of losses per Watt (roughly the A factors that OPS has been using) are no where near

the $20 clai med here. Moreover, as ABB and others have pointed out, the proper approach would have

been to minimize cost subject to efficiency, not A & B, which would have resulted in a lower, flatter

curve to the asymptote. ABB's actual market data

‐‐ physical transformers produced and delivered

‐‐

shows a competitiv e market for M3 transformers even at EL4 efficiency. You can make all the

hypothetical claims you want to, gentlemen, the market is the real world

.

Regards,

Robert A. Berman, Principal

Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703

‐ 281

‐ 0490

703

‐ 655

‐ 8398 (cell)

BermanEconomics@gmail.comOn Nov 10, 2011, at 6:53 PM, Phil Hopkinson wrote:

Well stated Jerry

That is also what my analysis and report said. If you restrict to M3 then the cost of EL1 rises to about

$20/watt.

Phil

Phil Hopkinson,P.E.

HVolt Inc.

704

‐ 846

‐ 3290

F: 704

‐ 845

‐ 2520

C: 704

‐ 236

‐ 3320

phopkinson @hvolt.com

On Nov 10, 2011, at 18:04, "Corkran, Jerry L" < Jerry.Corkran@CooperIndustries.com > wrote:

To Mr. Parker and the DOE working group,

The reason for the request for the incremental cost of the losses is that the current DOE efficiency levels

can be obtained if the design is optimized at about $4 per core watt and $1 per winding watt at full

load. At the DOE 50% kVA rating, this is the same as evaluating th e losses or optimizing the design at

about $4 per total watts loss.

The present DOE efficiency loss level results in transformer designs about like many utilities were

purchasing their transformers before 2007. The utilities were purchasing the efficien cy levels that were

justified based on the cost of losses. A few utilities were purchasing higher efficiency that the 2007

efficiency rules because of the calculated cost of energy being higher than the $4/$1 loss evaluation.

What came up in the discussion last week was even for loss level 1, the incr emental cost of losses was

about $17 per watt for the design checked, between the present DOE losses an efficiency level of DEL1.

The added cost of $17 per watt is so much higher than the typical cost of the energy for the utilities,

that it is very questiona ble that the DOE payback estimates are accurate. A 3% interest rate may be a

factor in the payback calculations.

Jerry Corkran

From: Richard Parker [ mailto:richardparkerdc@gmail.com ]

Sent: Thursday, November 10, 2011 3:23 PM

To: Robert Berman

Cc: Freeman, Jeremiah (CONTR); rick.anderson@faypwc.com ; tballo@earthjustice.org ;

ScottB@LVMetals.com ; john.caskey@nema.org ; Corkran, Jerry L; Cymbalsky, John;adelaski@standardsASAP.org ; Teckman@nwcouncil.org ; gbf1@pge.com ; carlos.gaytan@ge.com ;

rgreeson@federalpacific.com ; bruce.r.hirsch@bge.com ; jhodge@howard.com ; mhyland@appanet.org ;

dave.millure@metglas.com ; snadel@aceee.org ; wes.patterson@us.abb.com ;

Eric.Petersen@aksteel.com ; Raymond.Polinski@ATImetals.com ; artrosenfeld@gmail.com ;

srosenstock@eei.org ; rroy@nrdc.org ; robert.saint@nreca.coop ; chuck.simmons@pgnmail.com ;

kwinder@mleainc.com ; mwaltner@nrdc.org ; jerry.schoen@aksteel.com ; Paul.Ryan@hitmet.com ;

ahofmann@publicpower.org ; pkumar@publicpower.org ; bsmith@federalpacific.com ;

greg.coulter405@gmail.com ; jmauer@standardsasap.org ; Cohen, Daniel; Meyers, Aaron;

Jim.creevy@nema.org ; jrossetti@mlgw.org ; cabolduc@lbl.gov ; kcoughlin@lbl.gov ;

brian.coffey@navigant.com ; mrivest@navigant.com ; gjrosenquist@lbl.gov ;

caitlin.johnson@navigant.com ; zhimei.luo@navigant.com ; Marchetti, Emily (CONTR); charlied@uus.org ;

DYoung@energy

‐ solution.com ; James.Lass@cleco.com ; maheshsampat@bellsouth.net ;

phopkinson@hvolt.com ; matthew.nardotti@navigant.com ; Raba, Jim; Savitz, Maxine (EMAB);

tpetrosino@carolina.rr.com ; chris.brown@cogentpowerinc.com ; ted.johnstone@cogentpowerinc.com ;

frank.guilbault@cogentpowerinc.com ; ned.efbrush@gmail.com ; dbrender@cda.copper.org ;

chad.kennedy@us.schneider

‐ electric.com ; eduardorobles@eaton.com ;

vijay.tendulkar@onyxpower.com ; thomas.patzner@us.schneider

‐ electric.com ;

carlosgsiqueiros@eaton.com

Subject: Re: Negotiated Rulemaking

‐ Distribution Transformers Teleconference

Robert,

I understand the DOE staff are working on the incremental Watts calculations and will get that out to

group as soon as it's ready.

best wishes,

Richard

On Thu, Nov 10, 2011 at 11:52 AM, Robert Berman < bermaneconomics@gmail.com > wrote:

Thank you Richard. That clarification is helpful.

In the liquid

‐ filled meeting we were told that we would receive an analysis of incremental Watts saved

by DL for all ELs, as well as the incremental cost. When will that analysis be available? For many of us,

that analysis is the basis for additional, perhaps e xtensive analyses, so it should come with enough lead

time before any additional meetings or teleconferences to that we can give it the required

consideration. It would be most helpful if the incremental cost were provided separately for transformer

and installation, with any pole component of the ins tallation identified.

For the MV Dry and LV Dry meetings, it would be most helpful if you would also circulate an agenda with

objectives, hopefully this week, so that we are able to prepare for those meetings.

Regards,

Robert A. Berman, Principal

Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703

‐ 281

‐ 0490703

‐ 655

‐ 8398 (cell)

BermanEconomics@gmail.com

On Nov 10, 2011, at 11:14 AM, Richard Parker wrote:

Dear Colleagues:

The telcon on the 17th is currently planned for medium

‐ voltage dry

‐ type and the telcon on the 21st is

reserved for low

‐ voltage. There will be revised analysis circulated in advance of both calls per our

discussion yesterday. Eac h call has substantial chunks of time allocated, though I hope we won't need

all that time.

It may be prudent to schedule a liquid

‐ filled call at some point as well, but I propose that we hold off on

that for day or so, until we can clarify wh en revised analysis for liquid

‐ filled will be ready.

Thanks for your very constructive participation in the meetings over the last two days.

Richard Parker

On Thu, Nov 10, 2011 at 10:05 AM, Freeman, Jeremiah (CONTR) < Jeremiah.Freeman@ee.doe.gov >

wrote:

When: Thursday, November 17, 2011 1:00 PM

‐ 5:00 PM (GMT

‐ 05:00) Eastern Time (US & Canada).

Where: Webinar and Phone

Note: The GMT offset above does not reflect daylight saving time adjustments.

*~*~*~*~*~*~*~*~*~*

Dear Colleagues,

This event is to save the time slot on your calendar based on our discussion at ye sterday's meeting.

Later today further information will be sent regarding the registration information for our November 17

and November 21 webinars. After registering you will get the link for the webinar and a toll free

number.

Please call with questions or concerns.

Very Respectfully,

Jeremiah Freeman

202

‐ 431

‐ 424 3 (cell)

202

‐ 586

‐ 1867 (office)