National Electrical Manufacturers Association 2101 L Street, N.W., Suite 300 Washington, DC 20037 (202) 457-8400

Telex 904077 NEMA WSH



### December 16, 1994

Mr. Michael J. McCabe 

### Director, Office of Codes & Standards Room 5E-066 Department of Energy 1000 Independence Avenue, S.W. Washington, D.C. 20585

Re: Department of Energy and Oak Ridge National Laboratory Study for Determination of Whether Energy Efficiency Standards Should be Established for Distribution Transformers.

Dear Mr. McCabe:

Section 346 of the Energy Policy and Conservation Act, as amended by section 124 of the Energy Policy Act of 1992, requires that the Department of Energy make an initial determination of whether or not energy efficiency standards (and accompanying test procedures) should be prescribed for distribution transformers. Before commencing any regulatory proceedings to establish standards or test procedures for any class of distribution transformers, DOE must first determine that standards would be technologically feasible and economically justified, and would result in significant energy savings. To assist DOE in making this determination, the Oak Ridge National Laboratory has been contracted to undertake a study of distribution transformers.

A number of individual members of the NEMA Transformer Products Section have had discussions with DOE and Oak Ridge staff concerning the pending study of distribution transformers. Among the topics discussed has been the significance of two distinct markets for distribution transformers: the utility and the commercial/industrial markets. The NEMA Transformer Products Section wishes to underscore the importance of studying these two distinct markets for purposes of defining product classes and of making determinations about technological feasibility, economic justification, and energy savings. The utility market is characterized by purchasers with long-term horizons and disciplined procurement and acquisition processes. In addition, public utility purchasers are subject to regulatory oversight. The commercial/industrial market is characterized bypurchasers of diverse size and needs who, by and large, lack the same disciplined

procurement and acquisition processes employed by utility purchasers.

The NEMA Transformer Products Section intends to offer additional input to the Department of Energy and the Oak Ridge National Laboratory regarding the pending study of distribution transformers. It is quite likely that properly established energy efficiency standards, that over time raise the level of distribution transformer efficiency for both markets, will result in significant energy savings as well as a reduction in greenhouse gas emissions. We also believe that today's transformer manufacturers utilize established testing procedures that more than meet any criteria required to substantiate efficiency requirements that would be stipulated in an efficiency standard. We are preparing for submission in the near future a study that addresses energy efficiency levels for classes of distribution transformers. We look forward to presentation of this NEMA study and to the opportunity to discuss it with you and your staff at your earliest convenience.



### In the meantime, if you or Oak Ridge National Laboratory staff have any questions regarding distribution transformers, please do not hesitate to contact Mr. John Gauthier of the NEMA staff (202-457-8442) or the undersigned at 202-457- 8448.

Very truly yours,

Kyle Pitsor Manager , Energy & Trade NEMA Government Affairs

cc: Terry Logee