From: Christopher Bolduc

To: Robert Berman

Cc: Richard Parker; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com;

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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