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 by

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purchasers 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

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