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 andsituations. 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. To: Cyrus Nasseri, Project Manager, Test Procedures for DistributionTransformers, U.S. Department ofEnergy 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 TestProcedures for Electric Distribution Transformers Docket Number: EE-RMlTP-98-550

This memo serves to document a conversation I had onJanuary 10th with Jerry Hodge, Vice President and General Manager ofthe Pole Type Transformer Division at Howard Industries, Inc. inLaurel, Mississippi. At the direction ofDOE, I contacted Mr. Hodge at Howard Industries to gather additional information on a comment submittedby himregarding the number ofBasic 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 theAEDMapproach, instead of requiring only jive models to be tested thatyou require 75 models to be tested. Wefeel that only jive models is a much too low of sampling size to adequately represent all the different KVAIVOLTAGESIBIL requirements thathave differing calculations to verify adequacy of yourprograms. "

In our conversation, Mr. Hodge indicated that inhis briefing with the Howard family (founders ofHoward Industries) about the Department ofEnergy Distribution TransformerRulemakings, it
was felt that five basic models was too Iowanumberto verify that the AEDM software would accuratelypredict the efficiency ofall liquid-immersed transformers. Mr. Hodge pointed out that unlike electric motors, there is a considerable amount ofvariety intransformers. Indeed, Howard Industries does not offer a "standard series ofdesigns", instead, Mr. Hodge said, everything they design and built is custom-manufactured for their clients. Theyproduce only what is the best fit for their customers, and that means considering their design constraints, their economic evaluation formula and otherneeds oftheir clients.

Mr. Hodge believes that while there is some variety inthe electric motors industry, there is a fair -degree ofstandardization, for example many motors are built around a few common voltages. This situation is not true for the liquid-immersed transformer industry. All ofHoward Industries' clients get custom-built transformers which take into account their unique needs and situations. With such a large number ofdesign options and variety in the industry for liquidimmersed transformers, Mr. Hodge said that Howard Industries believes that 75 is a better number ofbasic models to validate the AEDM. This recommended number ofbasic models was selectedbecause it seems more reasonable than five.