From: Christopher Bolduc To: Robert Berman Cc: Richard Parker; rick.anderson@faypwc.com ; tballo@earthjustice.org ; ScottB@lvmetals.com ; john.caskey@nema.org ; jerry.corkran@cooperindustries.com ; john.cymbalsky@ee.doe.gov; 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 ; srosenstock@eei.org ; rroy@nrdc.org ; robert.saint@nreca.coop ; chuck.simmons@pgnmail.com ; mark.e.stoering@xcelenergy.com ; Daniel.Cohen@hq.doe.gov; greg.coulter405@gmail.com ; Jim.Creevy@nema.org ; ahofmann@publicpower.org; pkumar@publicpower.org ; jmauer@standardsasap.org ; paul.ryan@hitmet.com ; bsmith@federalpacific.com ; kwinder@mleainc.com ; brian.coffey@navigant.com ; Jim.Raba@ee.doe.gov; mrivest@navigant.com ; GJRosenquist@lbl.gov ; Katie Coughlin Subject: Re: DOE MV Transformer rulemaking - Analysis is now online Date: Thursday, September 08, 2011 5:23:49 PM



## All, > With respect to the engineering and life-cycle costs distributed, many of > the designs included in a CSL appear to be redundant in the sense that they > result in the same efficiency albeit at a higher cost (see, for example, the > plots in the TSD).
Transformer design selection for the LCC simulation is based on more than transformer efficiency. The methodology is described in detail in chapter 8 of the preliminary TSD. In brief: during the LCC and PBP simulation of 10000 samples, designs are selected from the engineering database for the basecase and for each standard level based on one of two criteria. 1) designs are selected based on lowest purchase price, or 2) designs are selected based on lowest purchase price given a pair of A and B values. This is described in chapter 8, section 8.2.2.3 of the preliminary TSD. The fraction of simulation samples that use either method is referred to in the LCC analysis as the evaluation rate, which varies based on transformer type and size. The evaluation rate is described in more detail the preliminary TSD chapter 8, section 8.3.1.

> to what extent are these higher cost designs reflected in the tables showing the percent of transformers with net costs by CSL? Very little, or none. There is the possibility that some of higher costs designs could be selected as part of the 10,000 samples during a simulation, but as outliers they would have little impact on the results. > to what extent do these higher cost designs impact costs and PBP calculations?

See above. > would is be possible to see the analyses with redundant designs (as described above) deleted from the database?
No, the impact of these "redundant designs" is very small or close to zero. > With respect to the PBPs shown, are these calculated specifically as the

## PBP for the particular least-cost design for a CSL or as in the TSD? The PBPs shown are calculated as described in the preliminary TSD (chapter 8, section 8.6).
Sincerely, -- Chris

---- Chris Bolduc Energy Efficiency Standards Group Environmental Energy Technologies Division Lawrence Berkeley National Laboratory 647-832-4021