U.S. DEPARTMENT OF ENERGY PUBLIC MEETING ON TEST PROCEDURES FOR DISTRIBUTION TRANSFORMERS

MONDAY, SEPTEMBER 27, 2004The meeting was held at 9:00 a.m. in Room 1E245 of the Forrestal Building, 1000 Independence Avenue, SW, Washington, D.C., Cyrus Nasseri of DOE's Building Technologies Program, presiding. PRESENT: DAVID BRENDER Copper Development Association DOUG BROOKMAN Public Solutions EDWIN BRUSH BB&F Associates CARL BUSH Pemco Corporation GLEN CAMPBELL Natural Resources Canada STUART CHAITKIN Lawrence Berkeley National Laboratory SCOTT CHOINSKI National Electrical Manufacturers Association MICHAEL FAULKENBERRY Georgia Power Company PAUL GOETHE Optimized Program Services, Inc. EDWARD GRAY National Electrical Manufacturers Association ROB GREESON Federal Pacific Transformer HARRY HAYES III Ameren Services GERALD HODGE Howard Industries, Inc. RICHARD LYKE AK Steel Corporation JIM McMAHON Lawrence Berkeley National Laboratory STANLEY MERRITT Merritt and Associates WALTER MOREHART Acme Electric Corporation OSKARS PETERSONS National Institute of Standards and Technology MICHAEL RIVEST Navigant Consulting, Inc. ROBERT SAINT National Rural Electric Cooperative Association JERRY SCHOEN AK Steel Corporation MIKE SCHOLAND Navigant Consulting, Inc. JOHN STOOPS Lawrence Berkeley National Laboratory KEN STRICKLETT National Institute of Standards and Technology JOHN TALBOTT NIST consultant ALAN TRAUT Kuhlman Electric Corporation

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com2 ROBERT VAN BUSKIRK LAURA VAN WIE DAVID WIEGAND ALAN WILKS Lawrence Berkeley National Laboratory Lawrence Berkeley National Laboratory Navigant Consulting, Inc. ERMCO Distribution Transformers

DOE REPRESENTATIVES PRESENT: CYRUS NASSERI BRYAN BERRINGER CHRIS EARLY THOMAS DePRIEST SAM JOHNSON RONALD LEWIS MICHAEL McCABE FRANCINE PINTO JIM RAGA JIM RANNELS

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com3 A-G-E-N-D-A Welcome . . . . . . . . . . . . . . . . . . . . . 4 Cyrus Nasseri Introduction and Agenda Review . . . . . . . . . 8 Doug Brockman Overview of the Proposed Rule . . . . . . . . . . 15 Cyrus Nasseri Comments and Issues from Participants . . . . . 21 Definition of a Distribution Transformer . . . . 24 Michael Scholand Definition of Basic Model . . . . . . . . . . . . 27 Michael Scholand Uniform Test Method for Measuring Energy Consumption . . . . . . . . . . . . . . . . . . . 47 Oskars Petersons Sampling Plans for Compliance and Enforcement Testing Oskars Petersons . . . . . . . . . . . . . . 64 Kenneth Stricklett . . . . . . . . . . . . . 69 Alternative Efficiency Determination Method (AEDM) Kenneth Stricklett . . . . . . . . . . . . . 79 Other Issues . . . . . . . . . . . . . . . . . . 84

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com4 1 P-R-O-C-E-E-D-I-N-G-S 2 9:04 a.m. 3 MR. NASSERI: Good morning and welcome 4 everyone to the public meeting for the Distribution 5 Transformer Test Procedure Supplemental Notice of 6 Proposed Rulemaking. I am Cyrus Nasseri, project 7 mana er for this rulemakin

g g. 8 I would like to recognize my colleagues 9 from DOE seated here at the table, Ron Lewis from 10 Building Technologies and Tom DePriest, present, and 11 I think Francine Pinto is going to be later here at 12 some kind of a doctor appointment. And they are from 13 Office of General Counsel. I would like also to 14 recognize some of the team which supported the 15 development of this rule who are also present today. 16 Oskars Petersons and Kenneth Stricklett from 17 National Institute of Standards and Technology, and 18 Michael Scholand from Navigant Consulting. 19 Our facilitator today is Doug Brookman, 20 on my left side, and I will be chairing this public 21 meeting. On behalf of the Department of Energy, I 22 would like to thank you all for taking the time to 23 participate in this public meeting. 24 As published in the Federal Register on 25 July 29 of this year, this public meeting is a forum NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (9n91 9Rd_ddT4 1A1AQWIAI(,TIVMI n c OnnnR_z7na ,en,n,, noolrnrncc rnm5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for interested parties to comment on proposed test

procedures for distribution transformers. DOE would like to receive your comments on the proposed rule for this product. This morning, we will follow the agenda you received in your packets. And hopefully you all picked up the packet at the front desk. Ideally we would keep precisely to time. However, Doug and I will try and be flexible to ensure we have ample time for everyone who wants to comment. Please note that today's meeting is on the record. In other words, a transcript will be prepared, so I ask that you clearly state your name -- and maybe if for the first time you're introducing yourself, your affiliation -- every time you start to speak. The transcripts for this public meeting will be entered into the docket for this rulemaking, and the department will take all the comments you make today into consideration. Furthermore, the written comments period, as you probably remember from the notice that we published, is November 8, a month and a half from now. You will find in your participant packet a one-pager titled "How to Comment." This is essentially an extraction from the Federal Register notice to make it easier for you to submit your feedback. The department welcomes all comments on

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final rule. As is provided in the Federal Register notice, and also appearing in the How to Comment one-pager, all the material related to this rulemaking is posted on our website. And I'm not going to read that,.it's a very long website, unless you want me to do that later on. The slides that you see today will also be posted on our website very shortly, I would say in the next two or three days. So please feel free to forward the link to any of your colleagues who could not participate with us today. As you are already seeing, there's also a hard copy of all the slides appearing in your packets. In approximately two weeks, or sometime sooner, a complete copy of the transcript will be available for inspection at the Building Technologies Program Resource Room, located in Room 1J -- as in Jack -- 018. Anyone wishing to purchase a copy of the transcript may make arrangements with the court reporter sitting on my right.

To provide the department with as much pertinent information, and as many views as can be reasonably obtained, and to enable interested persons to express their views, this public meeting 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 will be conducted in accordance with the following

procedures. We will begin with introductions, and then proceed to short introductory presentations from people who have asked to speak and provided us with submitted comments. I want to stress our request that your initial comments be limited to general issues, and,the summary of your views, and be no longer than five minutes. This is the policy, but today since we have more time, we might give you a little more time for that. Following those presentations, we will discuss the issues on the agenda, and any other issues you wish to discuss. And you will have an opportunity to provide more detailed comments on the specific issues. Please limit your questions on the opening presentations to general points so that we can provide everyone the opportunity to present their summary of concerns. During the remainder of the proceedings, questions on the specific issues are welcome. I encourage everyone present to participate as much as possible so that we may get the fullest spectrum of opinions on issues raised. The public meeting is scheduled to recess today at 5:00 p.m.

All comments, today's transcript, and data submissions, will be available for public

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 review at the Building -- again, I mentioned that

before -- Technologies Program Resource Office in Room 1J018. The room is open between 9:00 and 4:00 p.m. Monday through Friday except federal holidays. For more information, please contact Ms. Brenda Edwards-Jones, and her telephone number is 202-586- 9127, and that is basically listed under our rule also, the telephone number. Again, we appreciate the time and effort you have taken in preparing for this public meeting, and we are pleased to receive your comments and opinions. Our purpose today is to have dialogue on the issues so that all who are interested can share and add insight to this rulemaking. At this point, I would like to turn the floor to our facilitator Doug, and he will complete the introduction of participants, review the agenda, and start the presentations. Thank you very much.

FACILITATOR BROOKMAN: Thank you. Good morning everybody. I'd like to give everybody a chance to introduce him- or herself. That's a tradition that we've had. May I start with you? If you'd say your name and organizational affiliation. If everybody would take your table tents and turn them towards me so that I can read them, then I'll

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 be able to recognize many of you by name. Please,

Glen. MR. CAMPBELL: I'm Glen Campbell, Natural Resources Canada.

MR. GRAY: Ed Gray, National Electrical Manufacturers Association.

MR. LYKE: I'm Richard Lyke, AK Steel Corporation.MR. MOREHART: Gene Morehart, Acme Electric. MR. TRAUT: Alan Traut with Kuhlman Electric Corporation.

MR. HAYES: Harry Hayes, Ameren Services. MR. BRENDER: David Brender, Copper Development. MR. WILKS: Alan Wilks, ERMCO.

MR. FAULKENBERRY: Mike Faulkenberry, Georgia Power Company, Southern Company.

MR. HODGE: Gerald Hodge from Howard Industries. MR. LEWIS: Ron Lewis from the Building Technologies program here at DOE.

MR. NASSERI: Cyrus Nasseri again, from Building Technologies. 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 10 MR. DEPRIEST: Tom DePriest, DOE Office of General Counsel.

FACILITATOR BROOKMAN: Now just continue. You first, please.

MR. STRICKLETT: I'm Ken Stricklett from the National Institute of Standards and Technology.

MR. PETERSONS: Oskars Petersons, National Institute of Standards and Technology.

MR. SCHOLAND: Michael Scholand from Navigant Consulting.

MR. WIEGAND: Dave Wiegand. I'm under contract to Navigant Consulting.

MR. GOETHE: Paul Goethe from Optimized Program Services.

MR. STOOPS: John Stoops, Lawrence Berkeley National Lab.

MR. MCMAHON: Jim McMahon, Lawrence Berkeley National Lab.

MR. MCCABE: Michael McCabe, Department of Energy. MR. CHOINSKI: Scott Choinski, from the National Electrical Manufacturers Association.

MR. BUSH: Carl Bush, Pemco Corporation. MR. TALBOTT: John Talbott, consulting 25 II for NIST.

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1 MR. RIVEST: Mike Rivest, Navigant i l 2 ng.

Consu t 3 MR. MERRITT: Stanley Merritt, Merritt & 4 Associates, under contract to Berkeley Lab. 5 MR. CHAITKIN: Stuart Chaitkin, Berkeley

b 6 La . 7 MR. BERRINGER: Bryan Berringer,

t t f E 8 Depar men o nergy. 9 MR. BRUSH: Ned Brush, consultant to the i i 10 at on.

Copper Development Assoc 11 MR. SCHOEN: Jerry Schoen, AK Steel. 12 MR. SAINT: Bob Saint, National Rural 13 Electric Cooperative Association. 14 MR. VAN BUSKIRK: Robert van Buskirk, 15 Lawrence Berkeley National Lab. 16 MR. EARLY: Chris Early, Department of

E 17 nergy. 18 MS. VAN WIE MCGRORY: Laura Van Wie 19 McGrory, Lawrence Berkeley National Lab. 20 MR. RABA: Jim Raba, Department of

E 21 nergy. 22 MR. RANNELS : Jim Rannels, Building 23 Technologies program. 24 MR. JOHNSON: Sam Johnson, Building 25 Technologies program. 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FACILITATOR BROOKMAN: Thank you. I

hope everybody has received a packet. If you haven't signed in when you walked into the door, please do so. A list of the attendees of this workshop will be sent out after today via email, so everybody should check in. The first item in your packet is the agenda. You can see it up here on the

screen. We are now doing the introductions and the agenda review. We're going to move from here to a brief overview of the proposed rule by Cyrus.

Following that brief overview, we want to provide a comment period for anybody in the room that wishes to speak. I would ask that you not read from your written submitted statement, that you summarize and keep it as brief as possible. That'll make it easier for all of us to stay focused on the key issues. And any additional or supplemental issues I'll be noting as we go along here.

We'll take a break mid-morning, around about 10:15 or 10:30, depending on how the steam in the room is at the time. Following that we'll have a definition of distribution transformers, brief presentation followed by the opportunity -- well, the format, the general format which Cyrus described, a segment of presentation followed by 

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opportunity for question and comment. And that will be the format for the entire day. Before lunch we'll be talking about the definition of the basic model. We'll take lunch midday. Following lunch, we'll talk about the uniform test method for measuring energy consumption. Following that, sampling plans for compliance and enforcement testing. We'll take a break mid-afternoon, 3:00 or so. And after that, alternative efficiency determination method. And finally, around about 4:00 this afternoon, or if we get there earlier, any other issues that pertain to this supplemental notice. And that's the plan for today.

Questions, comments, at the outset? In particular, is there anything that people came here to discuss that isn't in this agenda somewhere? I see nobody has anything additional.

Okay. Let me ask your consideration. Over the span of the years, as we have done a lot of these appliance energy efficiency standards workshops, norms have emerged, and you see them posted on the wall over there to my left. I'm going to simply ask you speak one at a time. Please say your name for the record. You're going to have to

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 stick the microphone right square in your face and

that way we'll get a good recording for the transcript. I'm going to ask that you listen as an ally. One thing I've observed over the years is that the listening has gotten better and the dialogue has gotten a whole lot better in this room.

Please keep the focus here. If you need to take a cell phone call -- please turn off your cell phone ringers -- if you need to take a cal we'll understand you going out of the room. If you need to engage the person next to you in a sidebar conversation, we'll understand if it's going to be more than 10 or 15 seconds that you will take that out of the room as well. We're trying to keep it as focused here as possible. Please be concise, share the airtime. There are a lot of people that have a lot to say on this subject, and we're going to provide everyone the opportunity to do that.

I'm going to be cuing people to speak. I'll be cuing you by name to the extent I can. I'll be pointing otherwise. And I do wish, however, to not shut off the follow-on comments. Please make it possible for this to work gracefully. That is, especially if you're following on, try to be as brief as possible. If I drop you out of the queue, 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 don't let me get away with it. Start waving your

arms or something like that, okay? So that's the general information before we start. And as we get towards the break, we'll talk about other kinds of issues. Anything else, any other questions before we begin? So Cyrus, are you ready?

MR. NASSERI: Yes. Good morning again. The next presentation would be the overview of today's public meeting for this test procedure. Thank you. And I'm going to present this part of the presentation.

The purpose of this public meeting, as I state in the four bullets, is to present the department's proposed test procedure that you have seen in July 29 of this year. Seek comments from participants on proposed methodology and requirements. Discuss and respond to specific issues or questions related to the proposal. And finally, discuss the next steps.

Steps in the Distribution Transfer Test Procedure Rulemaking. As you see here, the determination analysis was mandated by Congress in 1992, that DOE has to make a determination for this product. And you see the detail of that analysis 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was published in a notice on October 22, 1997.

Almost seven years ago. And some of you probably know what our determination was. Shortly, I should mention the determination was that efficiency rule or establish a minimum efficiency for this product is feasible, and DOE should proceed for the next step. The next steps for this, after this determination, was to develop a test procedure. So we had a workshop in February 10, 1998, to discuss the test procedure where the stakeholders were interested parties. And obviously the NEMA TP-2 and some of the ANSI, or IEEE, sorry, IEEE procedures were discussed. So we basically reviewed the comments that were made during that workshop, and did our analysis further. And in November of that year, we published a Notice of Proposed Rule. You have probably seen that, and the review of that is mentioned in the SNOPR that we published on the 29th of July. When we published the SNOPR, there was a series of comments on the Notice of Proposed Rule. In the meantime, we find out that there are some areas that we have to reopen the comments and see what the views of the experts and the stakeholders 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on those issues are. So we did. We reopened the

notice on June 23 of 1999, and we have received many comments on the issues that we mentioned in that reopen notice. And gather all those comments, and then we developed the Supplemental Notice of Proposed Rulemaking, which we published on the 29th, and the subject of today's public meeting.

Well, from here, obviously we're going to hear your comments. And as I mentioned earlier in my opening remarks, the comment period's deadline is November 8, 2004, a month and a half from now. And after we go through your comments or anybody else who's interested to make comments, we will start developing a final rule, and we will make all efforts possible to have that done by September 2005. The Test Procedure Overview. We determined that the test procedure in five major areas. In each of these proposed areas, they're either new or different from what was previously published. And I would like to make all my effort in a few words to tell you what the differences are and which ones are new. In the definition of the distribution transformer, in the previous NOPR we published, we were very much qualitative, 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com18 1 generalized definition. And we decided that we have 2 to give more quantitative numbers for these 3 definitions for the transformers, primary, 4 secondary, what. And we did that. And that's a 5 major difference on new definition. 6 And definition of basic models. In 7 basic models, the way we defined previously in NOPR, 8 simply we said basic models are the one that have 9 the same kVA, they are the same insulation 10 requirements, either submerged, liquid submerged, or 11 dry type transformers. Having the same range of 12 voltages, and having the same phase, either single13 phase or three. Later on when we reviewed that, we 14 found out that is a little problematic. And the 15 reason for that was that with that basic model 16 definition, there was a way of interpreting it that 17 a series of transformers, the same as -- defined as 18 the same basic model might have different 19 performance, which affects efficiency. So because 20 of that, we basically in this notice that we 21 published, we take all the provisions that 22 previously we state in the basic model definition, 23 with additional requirements. And that requirement 24 is that there should not be any differentiating in 25 performance, electrical, or functional of that basic 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 transformer which affects efficiency. These two

areas will be presented by Michael Scholand of Navigant Consulting later on, as we proceed. The third area is Uniform Test Method for Measuring Energy Consumption. This area will be presented by Oskars Petersons.

What we have proposed in the past was basically incorporated by reference standards, such as NEMA TP-2, and IEEE standards, the four standards. The series of comments we received during the original NOPR reopening notice, and some of the review of our technical team on TP-2 and IEEE, we decided that we would like to have one test procedure that will stand by itself, DOE test procedure. But I have to mention at this point that we basically referenced and incorporated almost every requirements in NEMA TP-2 and IEEE standards.

The fourth area that we're going to talk today is sampling for compliance and enforcement testing. The sampling would be presented by Oskars Petersons again. And as you recall, originally we basically took the sampling plan that we basically have in the Code of Federal Regulation Part 430, which was established for consumer products. And we find that later on with a number of comments, that 

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5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for this product, which is unique, and not being

similar to household products, we have to basically have something different. What we have done, if some of you are familiar with the motor rule that we published a few years back. And that is in the Code of Federal Regulation part 431. This, what we are proposing today, is very much similar to that rule for the motor sampling. Again, that is going to be presented by Oskars.

The enforcement part of this presentation is going to be presented by Kenneth Stricklett. And this is something new. We have not proposed this previously. And you will see and discuss it when he is presenting that area.

And finally, the last area is the Alternative Efficiency Determination Method, that many of you might be familiar with. And also if you're in a motor, manufacturing motors, we had that method in the motor rule. And this is something new in this rulemaking.

Next steps. Obviously today we are here to hear your oral comments. We are going to be on the record. Transcripts are available for DOE's review later on. And also, your written comments which I already mentioned, the deadline would be 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 November 8. So we take all the transcripts, your

written comments, any other comments from the stakeholders, and start developing the final rule for this product. Obviously the timing for final rule depends on the nature of the comments the stakeholder's going to make. But, we are going to make our efforts, and we probably -- there's a commitment to do that. That we are going to publish the final rule before the start of the -- before the publication of NOPR for efficiency standards, which would be the nature of the subject for tomorrow's public meeting.

And at this time, I would like to turn back the floor to Doug to go through the next steps of the agenda. Thank you.

FACILITATOR BROOKMAN: Thank you. This is the opportunity for people that wish to make summary comments, and list other issues to take up more specifically as the day goes on . So I'll turn the lights up. And some of you presented summary comments , written comments in advance. I know the department appreciates that greatly. So then let's start with those summary comments now. Who would like to start? Please, Ed.



### MR. GRAY: I am Ed Gray of the National

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Electrical Manufacturers Association. Our formal

written statement was submitted to DOE on September 13, 2004. My comments today serve to briefly highlight our issues as per DOE's request. We may have additional written comments to submit by the November 8 deadline.

First of all I'd like to state that we favor high efficiency products at NEMA. Secondly, we don't like the approach that was taken this time to come up with a standalone test procedure. What we would like to see happen is the stakeholders agree at this proceeding and the other one as to what testing efficiency standards and labeling are needed. And then we can revise the industry consensus standards appropriately. And then DOE's rule could be a very simple thing, just refer to the industry standards.

In lieu of the sampling plan proposed in the SNOPR, manufacturers must be given the option of testing all transformers of a basic model or some basic models. This and the other comments I'm making are provided in a little more detail in our written comments. NEMA agrees with the proposed 15 kVA lower limit for dry-type transformers. We do not agree with the extension of dry-type energy 

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2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 23

efficiency standards to ratings below 15 kVA. NEMA shares DOE's concern that buyers could possibly use what DOE calls harmonic distribution transformers exclusions to avoid purchase of transformers meeting efficiency standards. Consequently, NEMA proposes elimination of these exclusions. NEMA believes that strong enforcement of efficiency standards once standards are adopted are a vital part of energy conservation. NEMA believes that the basic model definition is too vague and needs clarification. And again, in our written comments we provide an example of where we think that clarification is needed. FACILITATOR BROOKMAN: Thank you. Say again what needs clarification?

MR. GRAY: The basic model definition. FACILITATOR BROOKMA.N: Thank you. Who's next? And I appreciate you being focused and offering your comments in summary form. Who would like to proceed next? No additional comments at this time? There will be plenty of opportunity for people to comment following the beginning of the presentation. So if no one additional wishes to say anything now then we'll proceed.



### Okay. Then let's go to the next

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 presentation, which is Mike Scholand. MR. SCHOLAND: That's a very hidden light switch back there. The man behind the curtain, pay no attention. My name is Michael Scholand. I work at Navigant Consulting here in Washington, D.C. We are supporting the Department of Energy in the distribution transformer rulemaking process, both the test procedure and the efficiency standard which we'll be talking about tomorrow.

This morning I want to start by discussing the definition of a distribution transformer. The discussion of this definition can be found in Section 2 (b) of the preamble of the Federal Register notice, and the definition itself appears in Subpart B of Section 432.10 of the proposed rule, just to give you some crossreferences for that. For the definition overview, the purpose of the definition is to identify the transformers to which the department's test procedure would apply. The definition is the Supplemental Notice to Proposed Rule, or the SNOPR, provides generalized numerical criteria and specific exclusions, as you' ve seen . The definition has been redrafted to be consistent with the scope of the IEEE definition of a distribution transformer and 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 with NEMA TP-1 and TP-2, which both have a scope

definition for coverage. But I'll talk about that more in the next slide.

The previous proposed definition had emphasized application description. I have a little quote here from the previous, the 1998 Notice of Proposed Rulemaking for the test procedure. It reads that, "a distribution transformer transfers electrical energy from a primary distribution circuit to a secondary distribution circuit, or within a secondary distribution circuit, or to a customer service circuit. The problem with that as discussed in the NOPR is the definition is imprecise and could be subject to misinterpretation. So the department developed a more quantitative-based approach which we feel is more accurate.

In terms of the comparison between the department's definition and TP-1 and TP-2, the kVA range for both liquid-immersed and dry-type transformers is the same. The primary and secondary voltage ranges are the same. The DOE exclusions list is largely the same as the exclusions in NEMA TP-1 and 2. However, two differences to point out: harmonic transformers are treated differently in the department's proposed definition, and secondly the 

### NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 department does not exclude retrofit transformers.

We'll be discussing both of these issues in more detail later in this presentation.

Let me go and present the department's definition. The definition being proposed reads, "Distribution transformer means a transformer with a primary voltage of equal to or less than 35 kV, a secondary voltage equal to or less than 600 V, a frequency of 55 to 65 hZ, and a capacity of 10 kVA to 2500 kVA for liquid-immersed units, and 15 kVA to 2500 kVA for dry-type units, and does not include the following types of transformers." And then it lists 15 exclusions. And each of these exclusions are defined in the notice itself, as you've probably

seen. Now let's look at five specific areas where the department invites comments on the definition. That is the exclusion of the 5 and 10kVA dry-type, the exclusion of sealed and nonventilated units, the definition of a specialimpedance transformer basically by establishing normal impedance tables, the K-factor threshold of K-13 for exemption, and finally retrofit transformers. Now I'm going to look at each of these five issues and then at the end of each of the 

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slides for these five issues we're going to stop and have a discussion about it if there's any comments.

Okay, so let's start with the 5 an 10 kVA exclusion. The department's prior proposed definition included these kVA ratings as distribution transformers. However, stakeholders commented that 5 and 10 kVA are not typically found in distribution applications. The department therefore is proposing now to exclude these ratings, but we do invite further comment on this decision. Doug? I don't know if you need to facilitate. Do people have additional comments they'd like to make at this time on 5 and 10 kVA being excluded from adefinition of a distribution transformer for drytype units? FACILITATOR BROOKMAN: No additional comments? Okay.

MR. SCHOLAND: Great, okay. Go to thenext slide. The exclusion of sealed and nonventilated units. Comments that were received in the 1999 reopening notice for this test procedure indicated that unique features for these products may impose a hardship for some manufacturers in testing them. Sealed and unventilated units constitute a very small market share, and the

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 department believes that excluding them would not

result in the loss of significant energy savings. These transformers are listed as exclusions in NEMA TP-1 and TP-2. Therefore, the department is for these reasons also excluding them from its definition today. We invite comment and discussion on this proposal to adopt this exclusion. Are there any comments? Easy crowd today.

Alright, I'll go to the next slide. Okay, there is -- for defining a special impedance transformer, there is no precise IEEE definition for special impedance. Second point, that the department's proposed definition is based on defining what constitutes a normal impedance. These are the normal impedance tables which I alluded to earlier. We are inviting comment on the tables of normal impedance. Let me just read the definition here. Special impedance transformer means any transformer built to operate at the impedance outside of the normal impedance range for that transformer's kVA rating. The normal impedance range for each kVA rating is shown in Tables 2.1 and 2.2. So if you turn the page in your handouts, you'll see the two tables defining special impedance. These are tables -- the first slide is 

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transformers by kVA rating, and then the next slide shows the normal impedance ranges for dry-type units. Now, I was going to stop here and have a discussion. We can have a discussion now about it if you'd like, or you can also submit comments, of course, by November 8. Give you more time to study the tables and decide if you think these ranges are reasonable ranges for normal impedance for each of these kVAs. Yes, Jerry?

MR. HODGE: Gerald Hodge from Howard Industries. How did you go about determining the upper limit for those impedance limits? What basis do you have for determining for that?

MR. SCHOLAND: Okay, thanks Jerry. The question, just so everyone can hear, is how did we determine the upper limit of the normal impedance ranges for these kVA units. We actually used both Paul Goethe and Dave Wiegand, the gentlemen seated behind you, to put together these tables for the definition, because there was no definition. So this is just based on their experience with the industry. So we're very keen on having manufacturers and customers comment on whether they 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 think these are reasonable ranges. FACILITATOR BROOKMAN: And let me note that when the department asks specifically for your comment, they would like to hear whether you like it or don't like it both.

(Laughter) FACILITATOR BROOKMAN: You know what I'm saying? They're seeking specific comment.

MR. SCHOLAND: And if you don't like it, what you would suggest instead. Thank you. Other questions or comments at this time? Okay. We'll be looking forward to some written comments on these. Thank you. The next slide referring to the exclusion of K-factor transformers of K-13 and greater. NEMA TP-1 excludes harmonic transformers and transformers designed for high harmonics. The department's definition broke that down into two groups: harmonic mitigating and harmonic tolerating, or K-factor transformers, and proposed definitions of both exclusions. Part of the reason for this is what happened, what was observed in Minnesota, where a state standard was adopted, and basically customers all started purchasing K-4 transformers to basically circumvent the standard. Therefore, the 

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exclusion for K-factor transformers, basically to avoid that problem. So K-4 and K-9 or any other K rating below K-13 would be considered distribution.

So the definition appears at the top of this slide, that a K-factor transformer means a transformer with a K-factor of 13 or greater that is designed to tolerate the additional eddy current losses resulting from harmonics drawn by non-linear loads, usually when the ratio of non-linear loads to the linear load is greater than 50 percent. So I wanted to stop at this point and have a discussion on K-factor transformers, noting that Ed Gray made in his opening remarks a comment that NEMA believes there's no need for this breakdown, and that all harmonic transformers could be excluded. Sorry, we don't need an exemption for harmonic transformers.

FACILITATOR BROOKMAN: Ed, do you want to say a little more about that, explain your position a little more fully?

MR. GRAY: Well, we made a pretty brief comment, not as brief as I made a minute ago, but a pretty brief comment in our September 13 comments. I mean, I have no personal knowledge of people trying to get around standards by using these 

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transformers, but if that is going on, NEMA doesn't want that to continue. We want high quality products in the marketplace. So that's why we made the comment we did.

FACILITATOR BROOKMAN: Thank you. MR. SCHOLAND: Okay, thanks. FACILITATOR BROOKMAN: Additional comments on this subject? And particularly from manufacturers or other members of this community. Yes, please. Walter.

MR. MOREHART: Walter Morehart, Acme Electric. I believe that the K-factor, and I was part of the NEMA task force committee on writing the TP-l. One of the reasons for leaving out K rated transformers was that there is no way, practical way, to test the losses with those harmonics. However, there is the problem that people are using, and I have run into it Ed, K-4 transformers to get around the requirement of the efficiency. So it is necessary now to go back and revisit our position, and that's the reason why NEMA will be taking out the K-factor transformer. But we will have to specify, and this is not figured out, but we will have to specify how we are going to determine what the efficiency of that unit is. But it's almost 

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2 going to be impractical to do it by testing.

don't know how you're going to generate the I

3 different harmonics to get the unit tested. So it 4 can be done by calculation, and that's the method

' 5 that we ll have to come up. 6 FACILITATOR BROOKMAN: And Walter, do

you have a perspective on the approach the DOE is 8 suggesting here? 9 MR. MOREHART: I don't feel that K-13 10 will stop the practice. You take a small dry-type 11 transformer, and you multiply the straight losses by 12 13, you're not going to increase it much. So it'll 13 be more practical for a manufacturer to come in and 14 offer a K-13 transformer in place of a high 15 efficiency transformer. 16 FACILITATOR BROOKMAN: So do you have 17 any suggestions for the department about how they 18 proceed with this? 19 MR. MOREHART: Well, the NEMA suggestion 20 has been, or will be, that we're going to look at 21 changing that exclusion, eliminate it. The K rated 22 transformer should be part of TP-1. However, in 23 addition to that, we will have to add a section in 24 there how we're going to determine that efficiency. 25 Because it is not a testable efficiency, that I know

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### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of. MR. SCHOLAND: Thanks. FACILITATOR BROOKMAN: Thank you for that comment. Do we have any additional comments following onto Walter's? Yes, please, Rob.

MR. GREESON: Rob Greeson, Federal Pacific Transformer. Just adding to that comment, I work a great deal with quoting transformers from day to day. And I see a very large number of energy efficient transformers required to comply with TP-1. However, they have no qualms about adding additional K-factor requirements on that as well. And we have repeatedly pointed out that they are excluded in the NEMA TP-1 standard K-factor transformers. However, that does not seem to be something that they care to hear. They just, well, it has to be both. So given the fact of the problem of measuring the losses, and it's not really covered in the standard. Typically what we have to do is make a statement that the transformer is compliant only as a -- under linear loads, or K = 1. And that's the way we've addressed that. Now, I provide that just to really share that that's something we run into, but we quote every day transformers that are K-factor and TP-1. 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 We have to make that further definition to state

that it's TP-1 compliant only if you treat it like it's K-l. And that's kind of what we've -- and I'm not saying that's a good thing or a bad thing, but that's about the only choice that we have at this point. MR. SCHOLAND: A very useful comment, thank you. Other comments on K-factor? Okay.

Now my fifth issue, the fifth slide here, the department does not have an exclusion for a retrofit transformer. In both the test procedure NOPR and the reopening notice, the department sought specific input from stakeholders on how to handle retrofit transformers. Comments received indicated that retrofit transformers may be larger than existing ones that could impose expensive installation costs such as breaker and switch gear replacement, adjusting terminal locations, and/or enlarging the transformer room or access doors to where the transformer is installed.

Additional clarification or specific information pertaining to the definition of a retrofit transformer was not provided in response to the reopening notice. So there is no exclusion in today's proposal for a retrofit transformer. And 

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of retrofit transformers. We have some comments now, some discussion on retrofit transformers.

FACILITATOR BROOKMAN: I'm wondering why no comments showed up the first time around on retrofit transformers. Ed Gray.

MR. GRAY: In our discussions, we saw it as a problem, but we had not as yet come up with some proposed solutions, so it's not in our comments. FACILITATOR BROOKMAN : I see . Are you getting towards creating a proposed solution? Do you not have a recommendation yet for the department? MR. GRAY: That's correct.

FACILITATOR BROOKMAN: Okay. Yes, please, Gerald Hodge.

MR. HODGE: Gerald Hodge from Howard Industries. We too are called upon at times to provide a retrofit transformer that the customer has certain requirements in order to be able to put this new unit in in place of some 1942 model. And I think we've got to find some way to be able to do that. I'm not sure what the answer is yet myself, but I can understand his needs, and the cost issues 

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1 involved. It makes a lot of sense to provide some h d 2 at.

way to o t 3 MR. SCHOLAND: Well, Jerry, we look 4 forward to some written comments in that regard from 5 you. Thank you. 6 FACILITATOR BROOKMAN: Additional 7 comments on this slide and the preceding slides? 8 And any other issues related to this cluster. 9 Definitions, generally. 10 MR. SCHOLAND: I guess you've all had a 11 chance to look at the 15 exemption definitions. 12 They're derived from the IEEE, primarily. Some of 13 them, such as special impedance, were crafted in14 house. If there's any of the 15 that you want to 15 discuss specifically I do have a slide on each of 16 them. So that was the idea at this point was to 17 discuss any other issues or questions that you might 18 have on a definition of distribution transformer. 19 (No response) 20 Okay, great. Well, that's the 21 definition. Thank you. 22 FACILITATOR BROOKMAN: So we're ahead of 23 schedule, and we're going to proceed to definition 24 of the basic model, and Mike Scholand's going to 25 keep presenting. He's going to press on with the 

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MR. GRAY: Well, in our written comments we indicated specifically the area that we thought was a problem. I'm sure it was intended to be helpful, but there was a phrase at the end of the definition that said, "and do not have many differentiating electrical, physical, or functional features that affect energy consumption." And we were concerned that that particular phrase could add to additional basic models at some later date, you know, just kind of confuse the testing and all that was actually needed. So we would like a pretty tight definition of what that means.

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presentation, the definition of a basic model. The comments that Ed was giving did not relate to a definition of a distribution transformer.

MR. GRAY: That's right. MR. SCHOLAND: Okay. Right. FACILITATOR BROOKMAN: So then let's proceed, then, with these slides, and take additional comments.

MR. SCHOLAND: Not very many slides in this presentation. The purpose of a basic model is to reduce the testing burden by enabling manufacturers to group products having essentially identical characteristics with respect to energy consumption into the same basic model. Basic model is the finest level of disaggregation at which manufacturers rate the efficiency of a distribution transformer. And manufacturers will rate the efficiency of each basic model either by testing a representative sample or by applying a substantiated AEDM. That's the Alternative Efficiency Determination Method, which Cyrus alluded to earlier, and that will be the final presentation today, on the AEDM.

So, the next slide. Changes from the previous definition of a.basic model from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE. ISLAND AVE., N.W. (202) 234-4433 WASHINGTGN, D.C. 20005-3701 www.nealrgross.com40 1 reopening notice. It's essentially the same basic 2 model as proposed in the NOPR, with a requirement 3 that Ed Gray just read, that the basic model should, 4 quote, "not have any differentiating electrical, 5 physical, or functional features that affect energy 6 consumption." These are some other changes which 7 are a little more subtle . We omit the provision 8 that transformers within a basic model must operate 9 within the same voltage range as this is encompassed 10 in the new requirement that I read above in the 11 previous bullet. And it also revises the provision 12 from, quote, "have a comparable nominal output power 13 kVA rating" to "have the same standard kVA rating." 14 We just felt that the language was a little clearer 15 that way. 16 The standard kVA ratings are defined as 17 those appearing in the IEEE standards C57.12.00 and 18 C57.12.01. And stakeholders had sought in the past 19 that basic model be essentially all designs having 20 the same nominal kVA rating. However, this is 21 inconsistent with the nature of groupings the basic 22 model is meant to permit in the context of 23 Department of Energy test procedures. 24 So let me go to the next slide. The 25 basic model definition reads, "Basic model means a 

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group of distribution transformers manufactured by a single manufacturer that have the same insulation type (i.e., liquid-immersed or dry-type), have the same number of phases (i.e., single or three), have the same standard kVA rating, and do not have any differentiating electrical, physical, or functional features that affect energy consumption." And then the standard kVA ratings are defined in the table that you see.

Now, with respect to a kVA rating, there are many design option combinations of core steels, windings, dimensions, number of turns, and so on, that can be changed. And as these variants in the design will affect energy consumption, it would appear that within one kVA rating you could have several different basic models.

So I'd like to stop at this point and have a discussion on the definition of a basic model. Ed, does this provide any clarification in terms of that sentence?

MR. GRAY: Well, we made another written comment that was -- there is a table in there that has basic models, and there's some footnotes on the table, and our written comments sort of get to that. It's sort of like if the table is the basic models, 

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and the only basic models, if you want to look at it that way, then maybe that's alright . But we were concerned that this phrase at the end could be construed to generate additional basic models later, additional burden on the manufacturers.

FACILITATOR BROOKMAN: Would you suggest what to do with that phrase? How to modify it for the department's benefit?

MR. GRAY: I can take that back to the members and we can provide something in the written comments. FACILITATOR BROOKMAN: Thank you, that would be helpful.

MR. SCHOLAND: John Talbott. Do you want to grab a microphone, John?

MR. TALBOTT: John Talbott, consultant with NIST. And I think this issue gets to some of the old definitional problems we used to have. And it concerns product classes and basic models. Sometimes it's easy to say they're the same thing, but a product class is these various distinctions of which a manufacturer could make all of them. And then within a product class, a given manufacturer could make more than one version of that product class. And that's what we're trying to define as 

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basic model. And that's where -- you don't get that difference. Maybe with distribution transformers there may not be any other differentiating things within a product class. So there is only one basic model for that product class.

But if you have something that's physically different that affects energy efficiency, then that would constitute a different basic model. So you would have, for example, a high efficiency version of a 10 kVA single-phase transformer. And you would have a standard efficiency version of a 10 kVA transformer. And those would be different represented values for those basic models. So hopefully that helps. It's product class and basic models. To some people they're the same thing.

FACILITATOR BROOKMAN: Thanks John. Any comment following that explanation?

MR. GRAY: It seems to me -- FACILITATOR BROOKMAN: Ed Gray speaking. MR. GRAY: It seems to me if you have an energy efficiency standard for that basic model that's what the standard is. I mean, if you wanted to produce a transformer more efficient than that you certainly may. But that the standard has a certain baseline efficiency level that has to be 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 satisfied. MR. SCHOLAND: That's correct, Ed, and

the basic model could be your design that's compliant with the standard. And then you may have different basic models that are more efficient than the standard. And even at the same efficiency you've got a combination of core and coil losses. And if you do a different tradeoff to arrive at the same efficiency at a given loading point, those would also be different basic models.

MR. GRAY: I think what I'm saying here, and this is kind of reacting to the comment, is I don't understand why that's a different basic model. It seems to me if you have a certain basic model, if the customer wants a higher efficiency transformer with that same rating, then the manufacturer will provide that. But I don't see what that has to do with creating another standard, another basic model.

FACILITATOR BROOKMAN: John? John Talbott. MR. 'TALBOTT: John Talbott. The difference is that you have a high efficiency version of the same product class. That's the concept. You may want to represent the efficiency of a higher efficiency version of a given product

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class. And that would constitute a different basic model. You're distinguishing your high efficiency line within a product class. Now we expect that's going to happen. And it may be manufacturers would have three different versions of a given product class, and there would be three different basic models. And we're at the test procedure phase, so we're talking about just representing your efficiency, not meeting the standard. The standard is down the line. This'll come up later in the sampling provisions as well.

MR. GRAY: Well, we currently have a similar circumstance in a lot of products. You know, we may have an efficiency standard for some product, and we may have an Energy Star product, or something like that that's voluntary that has a higher efficiency. But I still don't see what that has to do with coming up with another basic model which conceivably could have different testing, different efficiency standards, and labeling. I don't understand why we need that.

MR. TALBOTT: Well, it's so -- FACILITATOR BROOKMAN: John Talbott. MR. TALBOTT: You would have confidence 

### in the Energy Star level representation. It has to NEAL R. GROSS COUF r REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 rIASHINGTON, D.C. 20005-3701 www.nealrgross.com46 1 meet the statistical quality as meeting a minimum 2 efficiency standard. 3 FACILITATOR BROOKMAN: Ed Gray. 4 MR. GRAY: That's a voluntary program, 5 and that's handled in the context of that program. 6 That's not handled in the context of an energy 7 efficiency baseline standards program. I guess 8 that's the point I'm making. And we can address 9 that further in our written comments later now that 10 I understand the thinking behind it. 11 FACILITATOR BROOKMAN: Thank you. 12 Additional comments on this? Mike Rivest. 13 MR. RIVEST: I'd like to say something. 14 FACILITATOR BROOKMAN: Mike Rivest. 15 MR. RIVEST: This draws more on my 16 experience on other consumer products, but a basic 17 model is basically locking in the configuration, a 18 physical design that can then be tested and 19 extrapolated to every similar design without having 20 to retest. So it's not about the minimum efficiency 21 standard. It's not -- you see? It's about 22 extrapolation to a larger population. If you have a 23 transformer which is made of different core steels, 24 different copper, you know, different configurations 25 core, you cannot just test the one which is built a 

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certain way and then extrapolate or label something built completely differently with the same efficiency. Neither of them attest to meeting the minimum standard. So it's not a new standard level to meet, or something like that, which I thought there was some confusion there.

FACILITATOR BROOKMAN: Okay. Comments? MR. SCHOLAND: Okay. That's actually the whole presentation. Trying to keep it brief so there's time for discussion. So if people have any other remarks to make on the definition of a basic model? We look forward to other comments in writing. FACILITATOR BROOKMAN: Okay. It's now 10 minutes after 10:00. I'm going to suggest we keep plugging along. We didn't start till 9:15 almost, so let's press on with the next presentation, which is Oskars Petersons. The Uniform Test Method for Measuring Energy Consumption. MR. PETERSONS: My name is Oskars Petersons. I'm with the National Institute of Standards and Technology. Used to be employee at one time there. Right now I'm consultant or contractor.

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 48 I'm going to outline Uniform Test Method for Measuring Energy Consumption of Distribution Transformers. This topic is covered in the proposed rule 10 CFR Part 432, Subpart B, Appendix A. It's towards the end of the document.

General characteristics of the proposed test method. Content is based largely on the four IEEE standards in C57 series 12.90, 12.91, and then 12.00, 12.01, and also on NEMA standard TP-2. Organization of the document is similar to that of the NEMA standard TP-2. In some items, more detail is added, and language modified, because a proposed DOE test procedure is mandatory and not a voluntary guideline. Any comments at this point on general considerations? Okay.

Key elements of the test method are listed in this slide. They are similar to those in TP-2. I shall comment on each of them as I present the next five slides. Well, first, key element. Test system accuracy requirements. The table is identical to that in TP-2, and 12.90 and 12.91. So no change there.

The next one is resistance measurement element. Includes measurement of winding temperature, direct current resistance measurement, 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com49 transformer windings, including instrumentation 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and conversion of the measured resistance to the

value at the reference temperature. The DC resistance measurement is required only for one unit of a basic model, since this measurement is considered as design type measurement in IEEE standards. Any comment on resistance measurement?

The next key element is loss measurement element. Includes description of test sites for measurement of electric power loss, measurement of no-load loss, and application of corrections to the measured data. That is if these corrections are significant and therefore required. The measurement of load loss and application of corrections. And finally, adjustment of load loss data to reference temperature. Any comments on loss measurement?

Then determination of efficiency. It includes adjustment of the load loss to the value at which the efficiency is rated. And this is at 35percent of the rated full load for low voltage drytype transformers, and 50 percent of the rated full load for all liquid-immersed transformers, and medium voltage dry-type transformers. The losses are calculated, and then the efficiency is calculated. The total losses are calculated, and 

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then the efficiency. Any discussion comments here?

Now, the final element is test equipment calibration and certification element. It is similar, almost identical, to that in NEMA 2, and describes all steps involved in use, maintenance, and calibration, and record-keeping of test equipment. Comments? No.

Now, finally, an opportunity for you to discuss other issues related to the test method.

FACILITATOR BROOKMAN: Ed Gray. MR. GRAY: Yes, this is Ed Gray. This is our comment that we made in writing, which is we had the motor standard which is out there, we have experience with, doesn't use this approach. It refers to industry consensus standards, the IEEE standards, the NEMA standards, IEC standards. And the people skilled in the art know what's in those standards. So what's being done here with this approach is laying a standard out there. I'm not commenting on how good, bad, or indifferent the standard is, but something that people are going to have to learn all over. You know, it takes many, many years for somebody to be skilled in these standards. There are representatives from the stakeholders that thoroughly understand what's in 

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TP-2 and the IEEE standards, and now it's like we're saying, well, you know, we sort of took bits and pieces from those, and our best judgment, DOE's best judgment on where things could be improved, and now the participants in the industry are going to have to learn all this all over again. And these standards always have lots and lots of nuances that requires a lot of experience for people to fully understand. So I think this is going to create a lot of difficulty in the industry. And it seems to me that referring to the standards -- changing the industry standards where they need to be changed, we don't have a problem with that if the stakeholders decide that those changes are needed. But rather to toss the baby out with the bathwater we don't think is a very good idea.

FACILITATOR BROOKMAN: Can you be specific about what you would propose the department do? MR. GRAY: Well, what we would like to see is to, as the motor standard does, refer to the industry consensus standards that are out there. The people that are in the business of designing, manufacturing, testing these components know their business, their day-to-day jobs. And so if you 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 would like changes in TP-2, if everybody thinks

that's a good idea around this table, all stakeholders involved, then we would be willing to consider doing that. And then the final rule could just refer to the industry consensus standards, NEMA's, IEEE's, whatever, as opposed to something of whole new cloth.

FACILITATOR BROOKMAN: Thank you. Additional comments from other persons? Manufacturers, interested parties? Cyrus.

MR. NASSERI: Well, the department policy always has been, not for this product, for other products, to reference industry standards, consensus standards. But in the rule that we published, we stated very clearly the comments we have about TP-2. And we basically in the preamble part we stated all those. The lack of clarification being the mandatory language compared to voluntary language. And as you recall originally we did reference either the method of TP-2 or IEEE. And because of the nature of comments and the view of the nature of the test procedure, the decision was that we will have a test procedure as we said. We incorporate almost every requirement of the TP-2 and IEEE in our test procedures. 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53 But one thing that again I mentioned is our sensitivity about timing. And that we have to have a test procedure in place before the publication of a NOPR for the standard rulemaking, as you know it is a parallel line you're doing. And if NEMA is going to make comments and you would like to hear that, that they would like to revise, whatever the committee is handling TP-2, in accordance with what DOE's proposal is, assuming that they accept what we say in our proposal, the only issue of sensitivity that we have is that the timing. When are you going to revise the 1998 TP-2? And do we, I said, very sensitive about the timing, do we have time to go ahead and reference that. And then if that happens, do we need to reopen the NOPR again because of the certain things we are going to change and is not basically discussed in this meeting which sometimes can happen? And again, we are very much sensitive about the time for this rule. FACILITATOR BROOKMAN: Ed Gray.

MR. GRAY: The thing about referring to existing standards is people understand what they mean. And we can change places here and there, in TP-2 or wherever, to satisfy stakeholder needs. But 

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if we go to what's proposed here, we have to have a whole lot of people throughout the industry really thoroughly understand what you're proposing in lieu of TP-2 and the IEEE standards before we can even comment on what you've done. I mean, this is going to be a very difficult, detailed, time-consuming process that perhaps isn't needed.

My understanding, and we haven't discussed that here, is that a key DOE concern about TP-2 is the CAFE-like nature of it. In other words, the way TP-2 is worded is you have a 6-month rolling testing of your output of a given manufacturer, and the rolling average has to satisfy the overall efficiency standard. We could argue about whether that's good, bad, or indifferent, but my understanding is that that's a concern. We discussed this in the NEMA membership, and we are willing to have every basic model satisfy the standard, and not this rolling average of production of all the transformers. So that's, again, why we're pretty concerned about getting the basic model definition, some reasonable number, because we're saying that every one of those has to meet the standard.

(202) 234-4433 FACILITATOR BROOKMAN: Yes, Cyrus. 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Please. MR. NASSERI: Well, the CAFE standard

obviously is a sensitive issue because in other appliances that we have we cannot apply that to the efficiency and compliance, basically, for thedeficiency. But what our concern is is that the TP2 being very much a general test procedure --'for example, in TP-2 refers to keystone bridge, and doesn't say, you know, well, talking about experts, they might know. But what we get to sample, we kind of throw a figure for keystone bridge, what it is, and be very detailed, since our standard's mandatory for the manufacturers or the interested parties to follow. We were not able to really have a standard which is not in detail. And our feeling is TP-2 is not as detailed as we need for a DOE test procedure.

FACILITATOR BROOKMAN: Ed Gray. MR. GRAY: Well, we have the same situation, and maybe I don't want to say this, but we have the same situation in all the other productswe have standards on. You know, we have industryaccepted ways of testing lamps, lamp ballasts, electric motors, you name it. Everything that has a standard has a generally understood industry consensus way of doing the test. And the DOE rule 

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standard, and that gives it the force of law. This is no different than ASHRAE standards in states around the country. They don't have any standing as a law or a regulation till some agency like yourself declares that they are. And at that point, if TP-2 gets references, then people would have to comply with that as of some date. So all we're saying is why should this be different than all the other standards that are out there, all the other testing methods. I don't think we have to get down to EE101 in this kind of a standard.

FACILITATOR BROOKMAN: Ron Lewis. MR. LEWIS: So your major concern is the methodology approach of establishing a DOE versus the TP-2 or the existing standards generally. And you anticipate having further comments as far as any issues within there where you take exception to. The two different tracks, one is the methodology, and the second would be the specifics? Is that?

MR. GRAY: Yes, we'll do that. I don't know how much between now and November we'll be able to go through the details. I mean, there may very well be some disagreement technically, possibly with something you've chosen to put in there. I'm in no 

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position to know that or not know that at this time.

MR. LEWIS: Thanks. FACILITATOR BROOKMAN: Well, Ed, one thing that I thought I heard the department referring to was the timetable involved here, and the potential for revising TP-2. Can you respond to that? Would it be possible for NEMA to respond to the DOE's intended timeline to revise TP-2?

MR. GRAY: Well, first of all we'd have to of course get all the stakeholders involved, and there's a lot of people in this room. You know, there's utilities in here, manufacturers that aren't NEMA members, and so forth. We would have to have some consensus on what revisions would be needed. It turns out that TP-2 for better or worse is not in the American National Standards Institute process, and the utilities have had problems with that in the past. The good news is the ANSI standards process has lots of stakeholder involvement. The bad news it can take a long time. So we could, I would think, revise TP-2, if we could agree on the changes, pretty rapidly from a process standpoint.

You might -- just for people's information, the energy bill that's been stalled in Congress has TP-l, 2, and 3 in there for low voltage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com58 1

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 dry-type transformers. And there was an

implementation date of the first of next year in there. So I think if we could understand what the game plan is very quickly then we could react to that. But if it's simply a matter of changing each, you know, the idea of the rolling average of efficiency versus each individual model that wouldn't be very hard to change. However, the nature of these standards is, and I think a lot of the people in this room understand this, is there is a certain level of skill involved in the people that write the standards, that use the standards, and so forth. And we don't have to dot every `i' and cross every `t' for them to know what they're doing in their day-to-day jobs. And that's kind of what's different about this particular DOE proposal.

FACILITATOR BROOKMAN: Ron Lewis. MR. LEWIS: Ed, if we had people that were available to point out, answer questions onwhere you've got questions of things that are in TP2 or IEEE, and what's embedded here just on what we did of what's in there to assist, would that be of help to you as you're going through it looking for where are those differences?



### MR. GRAY: Yes, that would certainly be

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com59 1 helpful. I think, however, we're starting kind of 2 in different places. I'm starting from sort of like 3 the motors rule. In order to apply the motors rule 4 you have to be expert in NEMA standards, IEC 5 standards, IEEE standards. And the assumption is 6 that people are. And you know, that's the law of 7 the land now for that particular type of product. 8 And so -- and that was a lot easier to get ourselves 9 through, I think, than this approach of starting 10 from completely new cloth. 11 FACILITATOR BROOKMAN: I think we have 12 an additional comment. Your name, please, for the 13 record? 14 MR. WIEGAND: Dave Wiegand, contract 15 employee of Navigant. Just in comparing the IEEE 16 standards, IEEE C57.12.90 and 12.91 with the DOE 17 test procedure, there is really awfully close 18 concurrence between the two. But DOE tries to bring 19 the loading down to 50 percent load for liquid20 filled transformers, and also some of the dry-type 21 transformers, and a 35 percent load for most of the 22 dry-type transformers. Okay. There is one 23 difference in all of this that sticks out in my 24 memory, and that is the reference temperature for 25 liquid-filled transformers in the test procedure, 

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the temperature is 55 degrees Celsius as a reference temperature. In NEMA, which reflects the IEEE standards, there is the same 50 percent load spoken about, but the reference temperature is given as 85 degrees Celsius. That is the only difference that I'm aware of. Now, having looked at NEMA TP-2, and I brought a copy of it along, I have it back at my hotel room for closer reference if called upon, it leaves a few of the details floating, incomplete, whereas the test procedure picks up those floating details and carries them through to completion. So I would just like to -

FACILITATOR BROOKMAN: Thank you for that comment. Ed, do you wish to respond now? Oskars Petersons has an additional comment.

MR. PETERSONS: I'd just like to add that with respect to technical content, there is essentially no difference between the proposed DOE test procedure and various items in IEEE and TP-2. We did start out with TP-2 to be referenced in whole. Well, we went, started the review process. It was rejected because of too abbreviated language in it, as was said, left things uncertain.



### Suggestion was, well, why did you not go

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to IEEE standard? There was another problem which

was earlier addressed that in that case we would have to take various paragraphs out of four standards and reference to those. That was considered unsatisfactory also. So basically in proposed document, the technical content is nearly identical to existing standards.

MR. GRAY: Well, I mean, it would be good if you could --

FACILITATOR BROOKMAN: Ed Gray is speaking. MR. GRAY: -- provide us that list of where the "nearly's" are so we understand what's different. FACILITATOR BROOKMAN: Okay? Good, that's helpful. I'm certain the department and its contractors can provide that. Ron Lewis?

MR. LEWIS: Ed, I think that as you were approaching it and trying to discuss it with the committee that works on the TP-1 and TP-2 standards, et cetera, that you are bound to have questions. I think having a contact point for you where you can ask things, rather than trying to come up with all the answers in advance, just saying here's a list. 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 into things we can't do during the comment period,

we have certain limitations, but trying to help you to understand where it is and how it compares to things. Simply clarifying from an educational standpoint, we can give you a lot of assistance there as you're trying to do it, rather than just give you a static list and say this is just what we see right now. Because there may be other questions. So I don't want it to stop at just here's a conveyance, here's a contact.

MR. GRAY: Thank you. MR. LEWIS: That, by the way, is not just for NEMA. This is a general reference. And we're not looking for addressing just anybody. You were bringing up specifically the NEMA's TP-2 standard, so I'm addressing that. But it's not to be to the exclusion of non-NEMA stakeholders.

FACILITATOR BROOKMAN: I think I hear you making a general invitation from anybody here or beyond here that wants to seek additional information to contact you and be prepared to make your comments prior to the comment deadline.

MR. LEWIS: Yes. We want everybody to clearly understand what's embedded, what's the content, what are the technical things that are in 

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the test procedure. And we actually held a webcast trying to help people to understand the tools that are in the ANOPR that we're going to talk about tomorrow and other rulemakings in the test procedure, trying to make sure that everybody's comfortable with what's there and there is a dialogue. And we tried to off-load some of these things so we could have more discussion and have more input and not have just a one-way taking turns talking kind of thing, but working together to try to gravitate to something that makes sense and that's fully understood.

FACILITATOR BROOKMAN: Final comments on this set of slides? Okay, I see none. We have scheduled on the agenda two more presentation/discussion periods, followed by an open comment period following those two. It's now 10:35. Do you want to take a break now? Let's take a break now. It's 10:35. We will resume at 10:50. And it seems right now we're on course to finish early today for those of you that are wanting to know how this may proceed. So we will resume at 10:50 and thanks for a good start on the day.

(Whereupon, the foregoing matter went off the record at 10:36 a.m. and went back on the NEAL R. GROSS COURT REPORTERSAID TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com64

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 record at 10:53 a.m.) FACILITATOR BROOKMAN: Our next presentation and comment/question period following the presentation segments is on sampling plans for compliance and enforcement testing, and we'll be hearing again from Oskars Petersons, and also Ken Stricklett. MR. PETERSONS: Well, in this presentation Ken Stricklett and I are going to outline sampling plans for compliance and enforcement testing. I will start with the compliance plan and then Ken will continue with the enforcement plan.

Well, the purpose of compliance testing is to establish on a one-time basis the efficiency of the basic model. Selection of units. For each basic model, a sample of five or more units is selected. If fewer than five units are available, all units are tested, but a basic model is used for substantiation of AEDM, Alternative Efficiency Determination Method, the sample size must be at least five units.

The next step is use of the operating equation. The average efficiency of the sample is calculated, and the results are compared in the 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com65 first equation. For compliance, the average 2 efficiency of the sample must be equal to or larger 3 than the right-hand side of the equation, which does 4 contain the represented efficiency. Compliance can 5 be expressed also in terms of power loss according 6 to the second equation, which gives a simpler 7 presentation. 8 MR. SCHOLAND: Oskars? 9 MR. PETERSONS: Yes. 10 MR. SCHOLAND: Do you want to comment on 11 the edit we made, rated efficiency versus 12 represented efficiency in the first equation? 13 MR. PETERSONS: Right. Well, here RE is 14 -- okay. Yes, in first equation, RE is defined on 15 slide here as represented efficiency. 16 Unfortunately, when handouts were made, there was an 17 error where instead of represented efficiency, rated 18 efficiency is used. Once we have the standard out, 19 they sort of become synonymous, but at this stage it 20 is represented efficiency. 21 FACILITATOR BROOKMAN: So what's in the 22 slide there, for that first equation on Slide 4, 23 should read RE = represented efficiency, not rated

i ffi 24 ency.

c e 25 MR. PETERSONS: Well, for expression in

(202) 234-4433 

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represented power loss. Now some comments on operating equation of the sampling plan. The magnitude and functionality of the expanded uncertainty term, and that is this 0.05 divided by square root of N, that effects results verydirectly. The plan is related to the statistical ztest. The statistical basis and operating characteristics are discussed in considerable detail in NIST Technical Note of which the copies are available at the desk. Well, at the entrance table.

Now, opportunity for stakeholders to make comments, suggestions. Yes, sir.

MR. WILKS: Alan Wilks, ERMCO. What if a manufacturer chooses to test all the units 100 percent? Then the AEDM would not apply? Is that correct? FACILITATOR BROOKMAN: I was going to say, please repeat the question to make sure I heard you correctly, Alan.

MR. WILKS: Okay. If a manufacturer chooses to test 100 percent of the units, whether it's five or less, or five or more, the sampling plan as described, the AEDM plan would not -- you wouldn't have to use that, right? 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PETERSONS: That is correct. FACILITATOR BROOKMAN: Ron Lewis. MR. LEWIS: I believe that the AEDM was put in place so you wouldn't have to do 100 percent testing, and that if you are doing 100 percent testing that the alternate route was put in place to try to make life easier. If you're already doing 100 percent of the testing, you're taking the more rigorous route. So it would not be appropriate then. Is that correct, Oskars?

MR. PETERSONS: Correct. But AEDM is really a substitute for testing so that you don't have to test eventually all the basic models.

FACILITATOR BROOKMAN: And we'll get into more detail on that in the next set of presentations. Are there comments at this stage on these details and definitions regarding the equation, and I guess definition of the sampling plan? MR. GRAY: Ed Gray again. I'd just like to clarify that the proposed rule does indeed say what Slide 3 says, because I didn't read it that way? If fewer than five units are available, a reasonable time to test all units. That is what the proposed rule in fact says? 

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1 MR. PETERSONS: Yes. 2 MR. GRAY: Okay. Because I thought 3 there was some way of plugging different sample 4 sizes in the equation where N could be five or less. 5 MR. NASSERI: No, it -- 6 MR. GRAY: Okay, thank you. 7 MR. PETERSONS: The equation addresses 8 sample size from one to entire populations. 9 FACILITATOR BROOKMAN: Those last 10 comments were from Cyrus, and then back to Oskars. 11 Ed, did you have any additional comment or question 12 at this point? 13 MR. GRAY: I thought what you just said 14 was inconsistent with what this says. You said 15 sample size from one to whatever, but the sample 16 size can't be that small a sample size. You have to i i i h 17 test everything if s, r g t? t 18 FACILITATOR BROOKMAN: Oskars first. 19 MR. PETERSONS: No, you don't have to 20 test everything if you -- if for other reasons you 21 need to test everything you can do it. But you 22 don't have to test everything. You can limit to 23 sample size of five, even if you have more than five 24 units manufactured. But if you want to use entire 25 population on demonstrating compliance, you can do 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it. FACILITATOR BROOKMAN: Ron Lewis. MR. LEWIS: The AEDM is the last thing on the program today. So we're going to go through that more thoroughly. And if you have any questions after that part of the presentation, make sure to jot those down and let's go through that thoroughly.

FACILITATOR BROOKMAN: Okay. MR. PETERSONS: Thank you. MR. STRICKLETT: I'm Ken Stricklett, and I'm from the National Institute of Standards and Technology. And I'd like to take a few minutes to outline the major provisions for enforcement testing proposed for distribution transformers. My comments are intended only to be a brief introduction for the day's discussion. A full description of the enforcement testing procedures proposed for distribution transformers can be found in the Supplemental Notice of Proposed Rulemaking. It's included in two sections in that proposal. There's the general provisions are included in Section 432.13, and then there's also the sampling plan for enforcement testing, which is the Appendix B to Subpart B. So those are the two significant areas you want to look at in the proposed rule. 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 70 There's analysis Oskars mentioned of the operating characteristics of both the compliance demonstration sampling plan and the enforcement testing sampling plan is in our tech note. There's, again, copies at the back of the room which you're more than welcome to have a copy. And if you have any questions please by all means contact either Oskars or I and we can discuss that.

This proposal for enforcement testing is new. It had not been included in the earlier rulemakings. And so I wanted to go into a little bit of detail and maybe some background on it. So it's very similar to what's in place for consumer products and for electric motors. We basically took what was in place for those two product classes and modified it to what we thought was appropriate and reasonable for distribution transformers. The key provisions of the enforcement test procedures include the test notice. They're also in the general description section. There's guidelines for the selection and preparation of units. There's the, as I mentioned earlier, the sampling plan for enforcement testing. And I want to emphasize that there's also the option for the manufacturer to do further testing which I'll explain a little bit 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE: ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 further in the next slides. The test notice is a formal notification of the details that are required during an enforcement testing procedure. So that would clarify what transformer is to be tested, how the units are to be selected, how many units are to be selected, and the place in time that testing would be started and when it's scheduled. Now, so that's the sort of notification to the manufacturer from the Department of Energy that a testing is under way. Before that notice is ever issued, the department takes steps to clarify any discrepancies in the product. The department will examine the underlying test data and will also offer the manufacturer an opportunity to meet with the department to reconcile any discrepancies. And then there's further provisions. If an AEDM, that is if an Alternate Efficiency Determination Method is used, then the department may ask the manufacturer to -- they may ask that specific calculations be conducted, or witness any re-verification of any of the calculations, or ask that specific models, specific transformers might be tested. So there's a little bit of -- in that case there's a little additional flexibility. 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The sampling plan is based on methods

that are very well established. The sampling plan involves a test on the mean of a sample, and ultimately it's based on what's known in statistics as a t-test type protocol. The general provisions for the sampling plan include that the test would be conducted using the DOE test procedure, which Oskars had discussed earlier, and that up to 20 units could be selected for testing, and that five units should be tested initially. The sampling plan is built around a 97.5 percent confidence limit, and that would imply or that by design the risk of a false outcome, a false determination of non-compliance is not greater than 2.5 percent. And there's also, which I'll mention on the next slide, a test for the sample size, to validate that a sufficient number of units have been tested. And that's based on a five percent tolerance on the losses. And there are some other modifications of the enforcement testing plan to accommodate the specific needs of transformers, and that is allowances for testing small samples.

Now this slide is a flow chart for the sampling plan. And it's fairly involved, and I don't want to go through all the steps. I'd be glad to discuss it with you afterwards if you have any 

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questions, but I want to go through a few of the key steps. And I thought that this chart might be useful in reviewing the proposal and in preparing your comments for written comments. So it's indicated that the sampling plan begins with a set of initial tests. And here, M1 is the number of units that are available for testing, which could be up to 20. So that's one of the initial starting conditions. And N1 is the number of initial tests. That one of the accommodations that's made in the sampling plan is that if fewer than five units are available, then a single unit may be tested more than once. And so that's why N1 and M1 have been separated in this sampling plan.

Based on that initial sample, the initial sample efficiency, sample standard deviation, the standard error, the sample size discount, and finally the lower confidence limit are calculated. And then the next step on the chart is to compare the sample mean with the lower -- I'm sorry, the lower control limit. And then there are sort of two outcomes. If the mean efficiency is less than the lower control limit, the product is non-compliant. If it is greater than or equal to the lower control limit, then the next step is to

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evaluate and ask the question if the sample size is adequate for it to support the conclusion. And if the calculation of the sample size demonstrates that it is adequate, then the product is compliant and testing is complete. If that evaluation of the sample size indicates that enough units have not been tested, then this sampling plan may require that additional units be tested. And in either

case , if the product is found to be non-compliant, these two blocks at the bottom, then the manufacturer has the option of doing additional tests, up to 20 is I believe what's specified.

So this completes the overview of the major provisions. And then so I'd like to open the floor for any comments or discussion.

FACILITATOR BROOKMAN: Ed Gray. MR. GRAY: This is Ed Gray again. My question isn't on the method so much, but what starts the clock here. I mean, you know, the other products I have experience with, there may be a manufacturer that tests a competitor's product and doesn't think they comply with the standards or something, or maybe a state energy office doesn't think something's compliant. So how do you get into this loop to begin with? 

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FACILITATOR BROOKMAN: Cyrus Nasseri. MR. NASSERI: Well Ed, this enforcement has any meaning if we establish minimum efficiency standards. FACILITATOR BROOKMAN: Sorry, get the mic closer to you, please.

MR. NASSERI: So obviously we do not have the standard established for this product, minimum efficiency standards for these products. And this is assuming that we have -- this is way ahead of our game a little bit here. The enforcement comes into the picture when whatever the case is, we had cases that competitors or manufacturers claim that certain product is not meeting the minimum efficiency established by the department. And then we have to go through the enforcement process. Am I answering your question, or your question was something else?

FACILITATOR BROOKMAN: Ed Gray. MR. GRAY: So I guess what you're saying is that if we have comments on enforcement, we should make that comment on the energy efficiency process? Is that what you're saying? 

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. NASSERI: What I'm saying, your

comments should be in the process for enforcement that we proposed for the first time. Assuming the fact that we have a minimum efficiency standard established for these products, which would be the nature of tomorrow's meeting and the other rule that we're doing in parallel line, whatever that minimum is. At that time, when we establish that minimum efficiency standards, then enforcement is basically something that we would, and the department would apply. But at this point we decided that we propose this, and if you had any comments, assuming that we had a minimum efficiency standard established.

One thing I would like to mention Doug, because you mentioned about this NIST technical document. FACILITATOR BROOKMAN: Yes.

MR. NASSERI : We put that on the website at the time that we put the proposed rule.

FACILITATOR BROOKMAN: Okay. MR. NASSERI: So this is not the first time they see it, by the way.

FACILITATOR BROOKMAN: Okay, good. Thanks for mentioning that. Michael McCabe.

MR. MCCABE: Michael McCabe. A couple

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that you asked. Ed, please comment on the procedures as part of this docket, the enforcement procedures. The two rulemakings, the appliance standards, ANOPR distribution transformers for the public meeting is being held tomorrow, and the test procedure rulemaking are very related. But the regulations with respect to certification and enforcement are part of this proceeding, not the standards proceeding. Enforcement actions, as the regulations that we've laid out in the SNOPR, deal with both representation and standards. In answer to your initial question when would we get into that, it would be in response to information coming to the department. That information, as you had indicated, can come from a variety of sources.

It is also, as far as the process is laid out, it's that the information, once it comes to the department, it is reviewed by the department. Dialogue occurs between the department and a variety of parties. That variety would include, for example, the party that is submitting the information to understand that information. If we believe that there are questions that warrant follow-up, we would then initiate a dialogue with 

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the manufacturer. It is only after the questions -- we have questions that cannot be addressed resolved that we would go into an enforcement testing. The enforcement testing burden would be a burden on the department. This product, however, is very different than, say, than the residential products where you have basic models. Some may be just one unit that is produced a year, or every five years. Others might be thousands of units produced a year. And so the enforcement provisions, the testing, we recognize it needs to have some flexibility to meet the needs of the product. And we're interested in your comments on how these procedures can be applied if there is an enforcement issue for transformers.

Have I answered? MR. GRAY: That's very helpful, thank you. FACILITATOR BROOKMAN: Additional questions or comments following this segment of the presentation? So I think we're about ready to move now to Alternative Efficiency Determination Method if no one has anything additional at this point. Okay then, Ken Stricklett again.



### MR. STRICKLETT: This Alternative

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Efficiency Determination Method, or an AEDM, is also new for distribution transfers. And again, I'd like to just briefly outline the major provisions in the proposed rule, and just sort of frame the discussion today. Full description of AEDMs can be found in Section 432.12 of the proposed rule.

The key points regarding the AEDMs is listed on the slide. So I'd like to just go through this. It's a new topic. I'll go through this material fairly quickly, and then that will allow adequate time for comments and discussion. It looks like we're way ahead of schedule, so we have plenty of time to discuss this topic.

There are two ways that you can determine the efficiency of a product. One is, as Oskars gave in his presentation, is through testing a sample of units. And the second option is that you can calculate the energy efficiency through the use of an AEDM. Now the use of an AEDM has been proposed for distribution transformers to reduce the testing burden. And an AEDM can be used to predict the energy efficiency. Basic models that are rated through that are rated through the application of an AEDM need not be tested.



### AEDMs have been successfully used to

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reduce the testing burden for HVAC equipment and for electric motors. And the department is suggesting that this strategy may also be useful for distribution transformers.

The proposed rule gives several characteristics of an AEDM to clarify what it intends to qualify as an AEDM. And I've sort of paraphrased some of the language from the proposed rule in these three bullets. An AEDM is a computational method such as a software design tool. It's derived from a mathematical model that represents the electrical characteristics of the basic model. And an AEDM is based on engineering and statistical analysis, computer simulation or modeling, or other analytical evaluation of performance data.

There are limitations to the application of an AEDM that are provided in the proposed rule. First of all, the accuracy of an AEDM must be substantiated. It must go through this phase of substantiation before it can be used. A particular AEDM can only be used to rate basic models in one of the following groups of distribution transfers. And those are liquid-immersed transfers, low voltage 

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used to rate basic models that have been tested.

The criteria for substantiation of an AEDM include the following, that five or more basic models must be tested using the DOE test procedure, that five units of the transformer of the basic model must be tested for each basic model, and that the predicted or calculated loss should be within +/-5 percent of measured value for each basic model tested, and then finally that the average of the predicted losses must be within +/-3 percent of the average losses.

There's also guidance given for the selection of basic models during the substantiation. And those include that two of the basic models must be among the five basic models with the highest unit volumes of production in the prior year. No two basic models should have the same combination of kVA and voltage ratings. And at least one basic modelshould be single-phase and one should be threephase. There are some additional requirements that are stipulated if an AEDM is to be used. And those include that there be periodic verification, and that there be a maintenance of records to sort NEPAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com1

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of a traceability path on the AEDM. The department, as mentioned during the enforcement discussion, the department may also request that specific simulations be conducted, and that the analysis of previous simulations be provided, and/or that sample testing may be conducted on select basic models.

This completes the overview of the provisions for the use of the AEDM proposed in the test procedure. And at this time I'd like to open the floor for comments and discussion. There are some particular issues that the department is very interested in receiving comments on. And those are the limitations on the applications of an AEDM, the criteria proposed for the substantiation of an AEDM, the accuracy and reliability of using AEDMs in general, and on the criteria for the selection of basic models during the substantiation of an AEDM.

FACILITATOR BROOKMAN: So, questions and comments, and particularly the department has, as you said, those four bulleted items on 9 on your sheet. Any comments on those? And others as well. Yes, please, Gerald Hodge.

MR. HODGE: Yes, Gerald Hodge from Howard Industries. Going back to Number 8, where it talks about the periodic verification of an AEDM. 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Are we talking about a specific period of time, or

is that up to the manufacturer, or that just seems somewhat vague in my opinion.

MR. STRICKLETT: There is no specific time given in the proposal. And if -- Francine did you have a -- Prior to the meeting we had some discussions. That was one of the issues that you thought might be a -- So I think if you have specific suggestions that you feel would be appropriate, then the department would be very interested in receiving those.

MR. HODGE: Okay, will do. FACILITATOR BROOKMAN: Michael, did you wish to comment? No? Okay. Additional comments, especially as they relate to limitations on applicability, criteria for substantiation, accuracy and reliability, and selection of basic models. Department welcomes your comments on those items. Okay. So I guess then that finishes that slide segment. This is a slide that says how to submit comments. And in your packet there was a single page that had all this information in a very clear and well laid out format. I would call your attention to that as the way to submit your

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 comments, and the deadlines are there, and

everything else. So now we wanted to preserve an opportunity for anybody that had any additional questions or comments they wish to make, or make any summary comments at this time, because we're nearing the end of this workshop, it seems . Ed Gray?

MR. GRAY: This is just a minor detail, I guess. We looked at the NEMA standards during the break, and we have the same temperature , 55 degrees C, as I guess IEEE has in their standard. There was some comment that was different I remember earlier.

FACILITATOR BROOKMAN: So thank you. Anybody else with any additional or summary comments at this time? I don't see any. So then Cyrus Nasseri. MR. NASSERI: I just wanted to emphasize the fact that the timing is important for us to go to the final rule for this test procedure. Also in the test procedure, as we said , the provisions of TP-2 and IEEE are all there. Nothing new. And then we state very clearly what our comments on the TP-2 are, the present TP-2, the 1998 version. And I think at one time we discussed the fact that Ed said that he would like to have some future discussion. My feeling is that we already stated all of the 

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changes in the SNOPR, that differences or the things that we feel, the department feels should be basically corrected or according to ours, and then we welcome any comments on what our determination has been. FACILITATOR BROOKMAN: Okay, thank you. That clarification I think is useful. Ron Lewis.

MR. LEWIS: We have tried to change the public meeting and the process here slightly to take pressure off time. We off-loaded a bunch of the presentation of the highly technical stuff, the tools, the presentations of what's on the website, what are we using as background as we're analyzing all the data. And rather than have everybody sit here through the whole day and present all the data to you, we chose to try to give the emphasis to time for you to have your questions and give your comments and interact, rather than it being a monologue. We did a webcast in advance to go over the tools, and go through the higher technical content, hoping that the pressure wouldn't be on the day for us to get through the extensive presentations. I'm not sure how to interpret here. We're getting through so quickly, there's been a minimum of dialogue.

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 86 Our intent -- I hope that you see that. By having the webcast out early, by publishing things early, by having more time for dialogue, we're trying to make proper provision. Because this is the point in the process for you to really get us on the right track. If there are things that you have concerns about and we've missed something, it's important. We're not here to be defensive or argue perspectives. It's important that your perspective and your viewpoint be heard. And we wanted to give an emphasis to that, and that's why we've changed the format here, to off-load some of the technical information. So I personally would be interested in your comments on that part of the process as well. We want to have the user-friendly, and trying not to have a just taking turns talking, but have a true dialogue, and have you engaged in the process so that we fully understand your concerns and you fully understand what we've done. So I hope this is going in the right direction, and again I'd be quite interested in your input on that.

As Ed and I had spoken of earlier, Cyrus mentions that there is quite a bit of information in the Federal Register notice of things where we saw areas that we were not comfortable with. But if 

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exhaustive sheet of all the areas that are different, I'm really concerned about making sure we understand your perspective and what's behind the concerns as well. So I don't want it to be just a static process of here it is, take it or leave it. We want to make sure that thoroughly we've explained what we have, and that we're available to help you understand. Again, during the comment period we're limited. We don't want to in any way be trying to persuade you of our perspective, or trying to lead you in any way. We're just trying to gather the information, make sure you understand what the analysis is that we've done, and then we want to understand just as clearly what your concerns andinput is on the topic. So we're trying to be userfriendly, and hopefully this process is going to get us to something at the end that's very much developed together, where DOE has its charge and its mission, and you have your interests, and that we've assessed everything when we're going forward. So again, your input on the general process would be helpful as well.

FACILITATOR BROOKMAN: Thank you. So I

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believe we've covered all the items that are listed on the agenda. And we've heard from the department their invitation to both seek them out and provide additional comments. So then perhaps I guess we're at the point where I personally am going to sign off and say thank you, and see if the department has any closing remarks as well.

MR. NASSERI: Well, closing remarks. We really appreciate taking your time and coming. And we look forward for your comments. I was expecting to see more comments about the proposed, and we are hoping that by the end of the comment period, which is November 8, that you provide us with as much comments that would help us to come up with a final rule, which would be something that you're comfortable with, the manufacturers are comfortable with, and we achieve the fact that it is a good method for rating the product. Thank you very much.

FACILITATOR BROOKMAN: Thank you. (Whereupon, the foregoing matter went off the record at 11:34 a.m.)

(9(191 7 t-44'i'i 

### NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS '*23 RHODE ISLAND AVE., N.W. WASHW(.T(lN n c, 9Ml5_17M AAiW naalrnrr rnm89 CERTIFICATE

This is to certify that the foregoing transcript in the matter of: Public Meeting

Before: U.S. Department of Energy

Date: September 27, 2004

Place: Washington, DC

represents the full and complete proceedings of the aforementioned matter, as reported and reduced to typewriting.