Antonio Bouza

02/12/2007 07:00 AM

To: Antonio Bouza/EE/DOE@DOE

cc: Brenda Edwards-Jones/EE/DOE@DOE

Subject: Distribution Transformers , Notice of Data Availability (NODA)

0 Federal Record Not a Federal Record

User Filed as : Not Categorized in ERMS

To all Distribution Transformer stakeholders:

The Department of Energy (DOE) is writing to inform you that a Notice of Data Availability (NODA) and

a request for comments was published on February 9, 2007 in the Federal Register. Please find a copy of

that Notice attached below.

DOE will be updating its website to add this NODA later this week:

http://www.eere.energy.gov/buildin,s/ appliance standards/cormzrercial/distribution transformers html

On August 4, 2006, DOE issued a Notice of Proposed Rulemaking (NOPR) for liquid-immersed and

medium-voltage , dry-type distribution transformers under the Energy Policy and Conservation Act

(EPCA). In response to this notice , stakeholders commented that DOE's standard may prevent or render

impractical the replacement of distribution transformers in certain space-constrained (e.g., vault)

installations. Some stakeholders suggested that DOE's analysis of the benefits and burdens of the proposed

standard should take into consideration the potential impacts of replacing transformers in space-constrained

vaults. In NOPR, DOE factored weight-dependent installation costs in the analysis, but did not specifically

address potential costs related to transformers installed in vaults. In the NODA attached below, DOE

requests comment on the inclusion of potential costs related to size constraints of transformers installed in

vaults. In addition, DOE is also requesting comment on a different approach on the selection of the

efficiency standards for liquid-immersed distribution transformers.

The deadline for submitting written comments on the NODA is March 12, 2007. Please see the NODA

section titled "ADDRESSES" for instructions on how to submit your comments.

We appreciate your thorough review of the NODA and look forward to your comments.

Sincerely,

Antonio Bouza

Building Technologies Program

U.S. Department of Energy

1000 Independence Avenue, SW

Washington DC 20585-0121

phone: 202.586.4563

antonio.bouza@ee.doe.gov

DT NODA 7fFH6186.pdf

 EE-RM/STD-00-550 COMMENT 159

Antonio Bouza To: Antonio Bouza/EE/DOE@DOE 

cc: Brenda Edwards-Jones/EE/DOE@DOE 02/12/2007 07:00 AM Subject: Distribution Transformers, Notice of Data Availability (NODA) 

o Federal Record • Not a Federal Record 

User Filed as: Not Categorized in ERMS 

To all Distribution Transformer stakeholders: 

The Department of Energy (DOE) is writing to inform you that a Notice of Data Availability (NODA) and 

a request for comments was published on February 9, 2007 in the Federal Register. Please find a copy of 

that Notice attached below. 

DOE will be updating its website to add this NODA later this week: 

http://www.eere.energy.gov/buildings/appliance standards/commercial/distribution transformers.html 

On August 4,2006, DOE issued a Notice of Proposed Rulemaking (NOPR) for liquid-immersed and 

medium-voltage, dry-type distribution transformers under the Energy Policy and Conservation Act 

(EPCA). In response to this notice, stakeholders commented that DOE's standard may prevent or render 

impractical the replacement of distribution transformers in certain space-constrained (e.g., vault) 

installations. Some stakeholders suggested that DOE's analysis of the benefits and burdens of the proposed 

standard should take into consideration the potential impacts of replacing transformers in space-constrained 

vaults. In NOPR, DOE factored weight-dependent installation costs in the analysis, but did not specifically 

address potential costs related to transformers installed in vaults. In the NODA attached below, DOE 

requests comment on the inclusion of potential costs related to size constraints of transformers installed in 

vaults. In addition, DOE is also requesting comment on a different approach on the selection of the 

efficiency standards for liquid-immersed distribution transformers. 

The deadline for submitting written comments on the NODA is March 12,2007. Please see the NODA 

section titled "ADDRESSES" for instructions on how to submit your comments. 

We appreciate your thorough review of the NODA and look forward to your comments. 

Sincerely, 

Antonio Bouza 

Building Technologies Program 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington DC 20585-0121 

phone: 202.586.4563 

antonio. bouza@ee.doe.gov 

DT NODA 72FR6186.pdf 
6186 Federal Register /Vol. 72, No. 27 /Friday, February 9, 2007 /Proposed Rules

The alternative assumptions for the

state or regional distribution of

condensing furnaces in the base case are

likely to have some effect on other facets

of DOE's analysis, but none of these

other effects are likely to be significant.

While this alternative analysis of the

possible impacts of regional standards

does not have any significant effects on

DOE's assessment of the benefits and

burdens associated with the trial

standards levels for national standards,

it could affect stakeholder assessments

of possible alternatives to a national

standard. For this reason, DOE

concluded that it should present the

alternative results for stakeholder

consideration and comment.

B. Installation Cost Differences

At the October 2006 public meeting,

ACEEE requested further clarification of

the new installation cost increases

applied in the NOPR analysis for oilfired furnaces rated between 82 percent

and 83 percent AFUE. (Public Meeting

Transcript, No. 107.6 at p. 121)

In the Advance Notice of Public

Rulemaking (ANOPR), DOE calculated

the installation costs for oil-fired

furnaces by assuming that upgraded

Category III venting systems would be

needed to prevent corrosion in 100

percent of the installations rated 84

percent AFUE and above (as explained

in section 6.5.5 in the ANOPR TSD).

DOE presented these installation costs

at the ANOPR public meeting and

received the following comments from

ACEEE and GAMA.

GAMA commented that Brookhaven

National Lab (BNL) had done an

extensive amount of work on oil venting

and that DOE should ask BNL for its

information as a data resource for oilfired furnace venting systems. (Public

Meeting Transcript, No. 59.8 at p. 112.)

ACEEE commented that there are oilfired boilers rated 86 percent AFUE and

oil furnaces rated 84 percent AFUE that

have significant market share. ACEEE

recommended that DOE reexamine the

application of Category III vents at

efficiency levels rated below 84 percent

AFUE, determine at which efficiency

level Category III vents are required 100

percent of the time, and apply some

type of phase-in of the venting systems,

rather than a single-step function as

DOE had done in the ANOPR analysis.

(Public Meeting Transcript, No. 59.8 at

p. 113.)

In response to the comments both

from GAMA and ACEEE, DOE further

examined oil-fired furnace venting

systems and consulted with BNL on

furnace installation requirements. BNL

indicated that some fraction of the

installations rated at 83 percent AFUE

may require Category III venting

systems. As a result of its consultations

with BNL, DOE revised its ventingmodel assumptions, which

characterized the rate of required

Category III venting systems, from using

a step function to a more linear, "phasein" function, which assigns a Category

III-requirement rate of 25 percent for oilfired furnaces rated at 83 percent AFUE,

and gradually increases the percentage

of installations using Category III

venting systems for oil-fired furnaces

rated above 83 percent AFUE. DOE's

approach is further detailed and

explained in section 6.5.6 of the NOPR

TSD for oil-fired furnaces. DOE used a

per-installation cost adder for Category

III venting systems that does not change

with the AFUE level of oil-fired

furnaces. It is the change in the assumed

frequency of installations requiring

Category III venting systems which

results in the cost differences. Table 2,

below, compares the DOE's ANOPR and

NOPR assumptions about the fraction of

the oil furnaces that require Category III

venting systems at certain efficiency

levels:

TABLE 2.-FRACTION OF THE OIL FURNACES REQUIRING CATEGORY III

VENTING SYSTEMS

Efficiency level ANOPR

(percent)

NOPR

(percent)

82% and below ..... 0 0

83% ....................... 0 25

84% ....................... 100 50

85% .. 100 75

86% and above .... 100 100

DOE welcomes comment on its

assumptions for use of Category III

venting systems for oil-fired furnaces.

Issued in Washington, DC, on February 2,

2007.

Alexander A. Karsner,

Assistant Secretary Energy Efficiency and

Renewable Energy.

[FR Doc. E7-2167 Filed 2-8-07; 8:45 am]

BILLING CODE 6450-01-P

DEPARTMENT OF ENERGY

Office of Energy Efficiency and

Renewable Energy

10 CFR Part 431

[Docket Number: EE-RM/STD-00-550]

RIN 1904-AB08

Energy Conservation Program for

Commercial Equipment : Distribution

Transformers Energy Conservation

Standards

AGENCY : Office of Energy Efficiency and

Renewable Energy, Department of

Energy.

ACTION : Notice of data availability and

request for comments.

SUMMARY : The Department of Energy

(DOE) issued a notice of proposed

rulemaking (NOPR) for liquid-immersed

and medium-voltage, dry-type

distribution transformers under the

Energy Policy and Conservation Act

(EPCA). In response to this notice,

stakeholders commented that DOE's

standard may prevent or render

impractical the replacement of

distribution transformers in certain

space-constrained (e.g., vault)

installations. Some stakeholders

suggested that DOE's analysis of the

benefits and burdens of the proposed

standard should take into consideration

the potential impacts of replacing

transformers in space-constrained

vaults. In the Notice of Proposed

Rulemaking (NOPR), DOE factored

weight-dependent installation costs in

the analysis, but did not specifically

address potential costs related to

transformers installed in vaults. In

today's notice, DOE requests comment

on inclusion of potential costs related to

size constraints of transformers installed

in vaults. DOE also is considering an

additional option for the final efficiency

levels for liquid-immersed distribution

transformers and by this notice invites

public comment on this additional

option.

DATES : DOE will accept written

comments, data, and information in

response to this notice, but no later than

March 12, 2007. See section VI, "Public

Participation," of this notice for details.

ADDRESSES : Any comments submitted

must identify the Notice of Data

Availability for Distribution

Transformers Energy Conservation

Standards, and provide the docket

number EE-RM/STD-00-550 and/or

Regulatory Information Number (RIN)

1904-ABO8. Comments may be

submitted using any of the following

methods:

 EE-RM/STD-00-550 COMMENT 159

#159 

6186 Federal Register/Vol. 72, No. 27/Friday, February 9, 2007/Proposed Rules 

The alternative assumptions for the 

state or regional distribution of 

condensing furnaces in the base case are 

likely to have some effect on other facets 

of DOE's analysis, but none of these 

other effects are likely to be significant. 

While this alternative analysis of the 

possible impacts of regional standards 

does not have any significant effects on 

DOE's assessment ofthe benefits and 

burdens associated with the trial 

standards levels for national standards 

it could affect stakeholder assessments' 

of possible alternatives to a national 

standard. For this reason, DOE 

concluded that it should present the 

alternative results for stakeholder 

consideration and comment. 

B. Installation Cost Differences 

At the October 2006 public meeting, 

ACEEE requested further clarification of 

the new installation cost increases 

applied in the NOPR analysis for oilfired furnaces rated between 82 percent 

and 83 percent AFUE. (Public Meeting 

Transcript, No. 107.6 at p. 121) 

In the Advance Notice of Public 

Rulemaking (ANOPR), DOE calculated 

the installation costs for oil-fired 

furnaces by assuming that upgraded 

Category III venting systems would be 

needed to prevent corrosion in 100 

percent of the installations rated 84 

percent AFUE and above (as explained 

in section 6.5.5 in the ANOPR TSD). 

DOE presented these installation costs 

at the ANOPR public meeting and 

received the following comments from 

ACEEE and GAMA. 

GAMA commented that Brookhaven 

National Lab (BNL) had done an 

extensive amount of work on oil venting 

and that DOE should ask BNL for its 

information as a data resource for oilfired furnace venting systems. (Public 

Meeting Transcript, No. 59.8 at p. 112.) 

ACEEE commented that there are oilfired boilers rated 86 percent AFUE and 

oil furnaces rated 84 percent AFUE that 

have significant market share. ACEEE 

recommended that DOE reexamine the 

application of Category III vents at 

efficiency levels rated below 84 percent 

AFUE, determine at which efficiency 

level Category III vents are required 100 

percent of the time, and apply some 

type of phase-in of the venting systems, 

rather than a single-step function as 

DOE had done in the ANOPR analysis. 

(Public Meeting Transcript, No. 59.8 at 

p.113.) 

In response to the comments both 

from GAMA and ACEEE, DOE further 

examined oil-fired furnace venting 

systems and consulted with BNL on 

furnace installation requirements. BNL 

indicated that some fraction of the 

installations rated at 83 percent AFUE 

may require Category III venting 

systems. As a result of its consultations 

with BNL, DOE revised its ventingmodel assumptions, which 

characterized the rate of required 

Category III venting systems, from using 

a step function to a more linear, "phasein" function, which assigns a Category 

III-requirement rate of 25 percent for oilfired furnaces rated at 83 percent AFUE, 

and gradually increases the percentage 

of installations using Category III 

venting systems for oil-fired furnaces 

rated above 83 percent AFUE. DOE's 

approach is further detailed and 

explained in section 6.5.6 ofthe NOPR 

TSD for oil-fired furnaces. DOE used a 

per-installation cost adder for Category 

III venting systems that does not change 

with the AFUE level of oil-fired 

furnaces. It is the change in the assumed 

frequency of installations requiring 

Category III venting systems which 

results in the cost differences. Table 2, 

below, compares the DOE's ANOPR and 

NOPR assumptions about the fraction of 

the oil furnaces that require Category III 

venting systems at certain efficiency 

levels: 

TABLE 2.-FRACTION OF THE OIL FURNACES REQUIRING CATEGORY III 

VENTING SYSTEMS 

Efficiency level ANOPR NOPR 

(percent) (percent) 

82% and below ..... 0 

83% ....................... 0 

84% ....................... 100 

85% ....................... 100 

86% and above .... 100 

DOE welcomes comment on its 

assumptions for use of Category III 

venting systems for oil-fired furnaces. 

0 

25 

50 

75 

100 

Issued in Washington, DC, on February 2, 

2007. 

Alexander A. Karsner, 

Assistant Secretary Energy Efficiency and 

Renewable Energy. 

[FR Doc. E7-2167 Filed 2-8-07; 8:45 am] 

BILLING CODE 64504l1-P 

DEPARTMENT OF ENERGY 

Office of Energy Efficiency and 

Renewable Energy 

10 CFR Part 431 

[Docket Number: EE-RM/STD-OO-550] 

RIN 1904-AB08 

Energy Conservation Program for 

Commercial Equipment: Distribution 

Transformers Energy Conservation 

Standards 

AGENCY: Office of Energy Efficiency and 

Renewable Energy, Department of 

Energy. 

ACTION: Notice of data availability and 

request for comments. 

SUMMARY: The Department of Energy 

(DOE) issued a notice of proposed 

rulemaking (NOPR) for liquid-immersed 

and medium-voltage, dry-type 

distribution transformers under the 

Energy Policy and Conservation Act 

(EPCA). In response to this notice, 

stakeholders commented that DOE's 

standard may prevent or render 

impractical the replacement of 

distribution transformers in certain 

space-constrained (e.g., vault) 

installations. Some stakeholders 

suggested that DOE's analysis of the 

benefits and burdens of the proposed 

standard should take into consideration 

the potential impacts of replacing 

transformers in space-constrained 

vaults. In the Notice of Proposed 

Rulemaking (NOPR), DOE factored 

weight-dependent installation costs in 

the analysis, but did not specifically 

address potential costs related to 

transformers installed in vaults. In 

today's notice, DOE requests comment 

on inclusion of potential costs related to 

size constraints of transformers installed 

in vaults. DOE also is considering an 

additional option for the final efficiency 

levels for liquid-immersed distribution 

transformers and by this notice invites 

public comment on this additional 

option. 

DATES: DOE will accept written 

comments, data, and information in 

response to this notice, but no later than 

March 12, 2007. See section VI, "Public 

Participation," of this notice for details. 

ADDRESSES: Any comments submitted 

must identify the Notice of Data 

Availability for Distribution 

Transformers Energy Conservation 

Standards, and provide the docket 

number EE-RM/STD-00-550 and/or 

Regulatory Information Number (RIN) 

1904-AB08. Comments may be 

submitted using any of the following 

methods: 
Federal Register /Vol. 72, No. 27 /Friday, February 9, 2007 /Proposed Rules

1. Federal eRulemaking Portal:

http://www.regulations.gov. Follow the

instructions for submitting comments.

2. E-mail:

TransformerNOPRComment@ee. doe.

gov. Include the docket number EE-RM/

STD-00-550 and/or RIN 1904-AB08 in

the subject line of the message.

3. Mail: Ms. Brenda Edwards-Jones,

U.S. Department of Energy, Building

Technologies Program, Mailstop EE-2J,

1000 Independence Avenue, SW.,

Washington, DC 20585-0121. Please

submit one signed original paper copy.

4. Hand Delivery/Courier: Ms. Brenda

Edwards-Jones, U.S. Department of

Energy, Building Technologies Program,

Room 1J-018, 1000 Independence

Avenue, SW., Washington, DC 20585.

Telephone: (202) 586-2945. Please

submit one signed original paper copy.

For detailed instructions on

submitting comments and additional

information on the rulemaking process,

see section VI. of this document (Public

Participation).

Docket: For access to the docket to

read background documents or

comments received, visit the U.S.

Department of Energy, Forrestal

Building, Room 1J-018 (Resource Room

of the Building Technologies Program),

1000 Independence Avenue, SW.,

Washington, DC, (202) 586-2945,

between 9 a.m. and 4 p.m., Monday

through Friday, except Federal holidays.

Please call Ms. Brenda Edwards-Jones at

the above telephone number for

additional information regarding

visiting the Resource Room. Please note:

DOE's Freedom of Information Reading

Room (formerly Room 1E-190 at the

Forrestal Building) is no longer housing

rulemaking materials.

FOR FURTHER INFORMATION CONTACT:

Antonio Bouza, Project Manager, Energy

Conservation Standards for Distribution

Transformers, U.S. Department of

Energy, Building Technologies Program,

Mailstop EE-2J, 1000 Independence

Avenue, SW., Washington, DC 20585-

0121, (202) 586-4563, e-mail:

Antonio.Bouza@ee.doe.gov.

Francine Pinto, Esq. or Chris

Calamita, Esq., U.S. Department of

Energy, Office of General Counsel,

Mailstop GC-72, 1000 Independence

Avenue, SW., Washington, DC 20585,

(202) 586-7432, e-mail: Francine.

Pinto@hq.doe.gov, or Christopher.

Calamita@hq.doe.gov.

SUPPLEMENTARY INFORMATION:

1. Introduction

It. Transformer Size Issues

A. DOE's Treatment of Size Issues in the

NOPR Analysis

B. Summary of Comments on Size Issues

for Vault Transformers

C. Size Constraints in DOE's NOPR

Analysis

III. DOE's Proposed Revisions to Estimating

Size Burdens

A. Vault Transformer Subgroup Analysis

B. Addressing Size Constraints for Vault

Transformers

C. Potential Approaches for Estimating the

Cost Impacts of Satisfying Constraints

Without Vault Modifications

D. Potential Approaches for Estimating the

Cost Impacts of Satisfying Constraints

With Vault Modifications

IV. Summary of Size Issue

V. Consideration of Final Efficiency Levels

VI. Public Participation

A. Submission of Comments

B. Issues on Which DOE Seeks Comment

1. Introduction

Part C of Title III of EPCA authorizes

DOE to establish energy conservation

standards for distributions transformers

for which DOE determines that energy

conservation standards would be

technologically feasible and

6187

more energy efficient, they tend to

increase in size. For this reason,

stakeholders expressed concern that

DOE's mandatory standard may not

allow for practical replacement of

transformers in certain existing space

constrained installations.

In the analysis for the NOPR, DOE

considered potential weight-dependent

costs for installation, but DOE did not

factor potential space-constraint costs of

vault transformers in its analysis. DOE

acknowledges the concern with spaceconstrained installations, and in this

notice outlines for stakeholder comment

analytical approaches that take into

consideration potential costs related to

distribution transformers installed in

vaults.

This notice presents analytical

approaches DOE is considering for

addressing stakeholder concern on the

space-constrained vault transformer

issue. DOE invites stakeholders to

comment on these approaches, or to

propose alternatives to DOE.

II. Transformer Size Issues

economically justified, and would result A. DOE's Treatment of Size Issues in the

in significant energy savings. (42 U.S.C.

6317(a).) Pursuant to EPCA, DOE

published a NOPR for liquid-immersed

and medium-voltage, dry-type

distribution transformers on August 4,

2006. 71 FR 44356. Together with the

NOPR, DOE published a technical

support document (TSD) that details

each analysis DOE conducted for the

rulemaking, providing specific

information on its methodology and

results. These documents are available

at the following DOE Web site: http://

www. eere. en ergy.gov/buildings/

appliance standards1commerciall

distribution_transformers.html. DOE

subsequently held a public meeting on

September 27, 2006, and invited

comments from stakeholders until

October 18, 2006.

Some stakeholders commented that

DOE had not properly considered

potentially significant economic

impacts of the minimum efficiency

standard on space-constrained vault

transformer installations. Vault

transformers are distribution

transformers that are used in

underground distribution networks,

where the transformers are installed

below ground level. Often found in

urban areas, these transformers are

installed inside a concrete vault that is

open at the top, which can be very

expensive to replace or expand. As

transformers are manufactured to be

NOPR Analysis

In the life-cycle cost (LCC)

spreadsheets DOE published with the

NOPR, DOE provided external

dimensions and weight information for

each of the distribution transformer

designs it considered in its analysis. For

distribution transformers, size is very

closely correlated with weight, and DOE

developed weight-dependent

installation costs for transformers using

scaling relationships developed from RS

Means installation cost data (see TSD,

Chapter 7).

Although DOE's LCC spreadsheets

contained external dimensional

information for each transformer in the

design database, DOE's NOPR did not

report transformer size as a function of

trial standard level (TSL). For today's

notice, DOE calculated the volumes of

those transformers selected by the LCC

spreadsheets, as a function of TSL, for

the two design lines (DLs) for which

transformer vault constraints are most

likely to be an issue: DL4 and DL5.1

Tables 11.1 and 11.2 provide the average

volume distributions for DL4 and DL5,

respectively. For these tables, DOE

sorted the transformers from the

smallest to the largest volume for the

distribution of transformers purchased

at each standard level. DOE then

calculated the minimum volume, the

maximum volume, and the transformer

volume at the 10th, 25th, 50th, 75th,

1 DL4 includes 15-500 kilovolt-ampere (kVA) transformer. DL5 includes 750-2500 kVA liquid- represented in the LCC analysis by a 1500 kVA

liquid-immersed, three-phase transformers, and is immersed, three-phase transformers, and is transformer.

represented in the LCC analysis by a 150 kVA

 EE-RM/STD-00-550 COMMENT 159

Federal Register/Vol. 72, No. 27/Friday, February 9, 2007/Proposed Rules 6187 

1. Federal eRulemaking Portal: 

http://www.regulations.gov. Follow the 

instructions for submitting comments. 

2. E-mail: 

TransformerNOPRComment@ee.doe. 

gov. Include the docket number EE-RM/ 

STD-00-550 and/or RIN 1904-AB08 in 

the subject line of the message. 

3. Mail: Ms. Brenda Edwards-Jones, 

U.S. Department of Energy, Building 

Technologies Program, Mailstop EE-2J, 

1000 Independence Avenue, SW., 

Washington, DC 20585-0121. Please 

submit one signed original paper copy. 

4. Hand Delivery/Courier: Ms. Brenda 

Edwards-Jones, U.S. Department of 

Energy, Building Technologies Program, 

Room IJ-018, 1000 Independence 

Avenue, SW., Washington, DC 20585. 

Telephone: (202) 586-2945. Please 

submit one signed original paper copy. 

For detailed instructions on 

submitting comments and additional 

information on the rulemaking process, 

see section VI. of this document (Public 

Participation). 

Docket: For access to the docket to 

read background documents or 

comments received, visit the U.S. 

Department of Energy, Forrestal 

Building, Room IJ-018 (Resource Room 

of the Building Technologies Program), 

1000 Independence Avenue, SW., 

Washington, DC, (202) 586-2945, 

between 9 a.m. and 4 p.m., Monday 

through Friday, except Federal holidays. 

Please call Ms. Brenda Edwards-Jones at 

the above telephone number for 

additional information regarding 

visiting the Resource Room. Please note: 

DOE's Freedom of Information Reading 

Room (formerly Room lE-190 at the 

Forrestal Building) is no longer housing 

rulemaking materials. 

FOR FURTHER INFORMATION CONTACT: 

Antonio Bouza, Project Manager, Energy 

Conservation Standards for Distribution 

Transformers, U.S. Department of 

Energy, Building Technologies Program, 

Mailstop EE-2J, 1000 Independence 

Avenue, SW., Washington, DC 20585-

0121, (202) 586-4563, e-mail: 

Antonio.Bouza@ee.doe.gov. 

Francine Pinto, Esq. or Chris 

Calamita, Esq., U.S. Department of 

Energy, Office of General Counsel, 

Mailstop GC-72, 1000 Independence 

Avenue, SW., Washington, DC 20585, 

(202) 586-7432, e-mail: Francine. 

Pinto@hq.doe.gov. or Christopher. 

Caiamita@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

I. Introduction 

II. Transformer Size Issues 

1 DL4 includes 15-500 kilovolt-ampere (kVA) 

liquid-immersed, three-phase transformers, and is 

represented in the Lee analysis by a 150 kVA 

A. DOE's Treatment of Size Issues in the 

NOPR Analysis 

B. Summary of Comments on Size Issues 

for Vault Transformers 

C. Size Constraints in DOE's NOPR 

Analysis 

III. DOE's Proposed Revisions to Estimating 

Size Burdens 

A. Vault Transformer Subgroup Analysis 

B. Addressing Size Constraints for Vault 

Transformers 

C. Potential Approaches for Estimating the 

Cost Impacts of Satisfying Constraints 

Without Vault Modifications 

D. Potential Approaches for Estimating the 

Cost Impacts of Satisfying Constraints 

With Vault Modifications 

IV. Summary of Size Issue 

V. Consideration of Final Efficiency Levels 

VI. Public Participation 

A. Submission of Comments 

B. Issues on Which DOE Seeks Comment 

I. Introduction 

Part C of Title III of EPCA authorizes 

DOE to establish energy conservation 

standards for distributions transformers 

for which DOE determines that energy 

conservation standards would be 

technologically feasible and 

economically justified, and would result 

in significant energy savings. (42 U.S.C. 

6317(a).) Pursuant to EPCA, DOE 

published a NOPR for liquid-immersed 

and medium-voltage, dry-type 

distribution transformers on August 4, 

2006. 71 FR 44356. Together with the 

NOPR, DOE published a technical 

support document (TSD) that details 

each analysis DOE conducted for the 

rulemaking, providing specific 

information on its methodology and 

results. These documents are available 

at the following DOE Web site: http:// 

www.eere.energy.gov/buildings/ 

appliance_standards/commercial! 

distribution_transformers.html. DOE 

subsequently held a public meeting on 

September 27,2006, and invited 

comments from stakeholders until 

October 18, 2006. 

Some stakeholders commented that 

DOE had not properly considered 

potentially significant economic 

impacts of the minimum efficiency 

standard on space-constrained vault 

transformer installations. Vault 

transformers are distribution 

transformers that are used in 

underground distribution networks, 

where the transformers are installed 

below ground level. Often found in 

urban areas, these transformers are 

installed inside a concrete vault that is 

open at the top, which can be very 

expensive to replace or expand. As 

transformers are manufactured to be 

transformer. DL5 includes 750-2500 kVA liquidimmersed, three-phase transformers, and is 

more energy efficient, they tend to 

increase in size. For this reason, 

stakeholders expressed concern that 

DOE's mandatory standard may not 

allow for practical replacement of 

transformers in certain existing space 

constrained installations. 

In the analysis for the NOPR, DOE 

considered potential weight-dependent 

costs for installation, but DOE did not 

factor potential space-constraint costs of 

vault transformers in its analysis. DOE 

acknowledges the concern with spaceconstrained installations, and in this 

notice outlines for stakeholder comment 

analytical approaches that take into 

consideration potential costs related to 

distribution transformers installed in 

vaults. 

This notice presents analytical 

approaches DOE is considering for 

addressing stakeholder concern on the 

space-constrained vault transformer 

issue. DOE invites stakeholders to 

comment on these approaches, or to 

propose alternatives to DOE. 

II. Transformer Size Issues 

A. DOE's Treatment of Size Issues in the 

NOPR Analysis 

In the life-cycle cost (LCC) 

spreadsheets DOE published with the 

NOPR, DOE provided external 

dimensions and weight information for 

each of the distribution transformer 

designs it considered in its analysis. For 

distribution transformers, size is very 

closely correlated with weight, and DOE 

developed weight -dependent 

installation costs for transformers using 

scaling relationships developed from RS 

Means installation cost data (see TSD, 

Chapter 7). 

Although DOE's LCC spreadsheets 

contained external dimensional 

information for each transformer in the 

design database, DOE's NOPR did not 

report transformer size as a function of 

trial standard level (TSL). For today's 

notice, DOE calculated the volumes of 

those transformers selected by the LCC 

spreadsheets, as a function of TSL, for 

the two design lines (DLs) for which 

transformer vault constraints are most 

likely to be an issue: DL4 and DL5. 1 

Tables 11.1 and II.2 provide the average 

volume distributions for DL4 and DL5, 

respectively. For these tables, DOE 

sorted the transformers from the 

smallest to the largest volume for the 

distribution oftransformers purchased 

at each standard level. DOE then 

calculated the minimum volume, the 

maximum volume, and the transformer 

volume at the 10th, 25th, 50th, 75th, 

represented in the Lee analysis by a 1500 kVA 

transformer. 
6188 Federal Register /Vol. 72, No. 27 /Friday, February 9, 2007 /Proposed Rules

and 90th percentiles. These selected designs in the NOPR LCC

distributions illustrate the degree to analysis varied by TSL.

which average transformer volumes of

TABLE 11.1.-TRANSFORMER VOLUME IN CUBIC FEET, NOPR LCC RESULTS FOR DESIGN LINE 4 (150 KVA)

Design line 4 Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6

Minimum ................................................................. 61.11 63.89 66.55 66.41 66.41 80.24 87.50

10th percentile ....................................................... 62.50 66. 41 69.01 69. 01 69. 01 80 .24 87.50

25th percentile ....................................................... 64.93 67.71 69.36 70.54 70.54 80.24 87.50

50th percentile ....................................................... 69.01 71.61 75.14 75.87 75.87 81.60 87.50

75th percentile ....................................................... 75.87 76.16 78.88 81.60 81.60 86.11 88.89

90th percentile ....................................................... 81.94 81 . 94 81.94 85 . 68 85. 68 87.04 88.89

Maximum ................................................................ 90.28 90.28 91.67 91.67 91.67 91.67 90.74

TABLE 11.2.-TRANSFORMER VOLUME IN CUBIC FEET, NOPR LCC RESULTS FOR DESIGN LINE 5 (1500 KVA)

Design line 5 Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6

Minimum ................................................................. 202.22 223.81 222.96 229.93 233.41 247.35 247.35

10th percentile ....................................................... 215.91 227.99 233.41 233.41 236.90 250.83 250.83

25th percentile ....................................................... 226.45 233.41 236.90 233.41 236.90 257.80 257.80

50th percentile ....................................................... 236.90 236.90 240.38 240.38 240.38 257.80 257.80

75th percentile ....................................................... 240.38 240.38 241.03 243.87 247.35 257.80 257.80

90th percentile ....................................................... 250.83 250.83 250.83 250.83 250.83 257.80 257.80

Maximum ................................................................ 261.28 261 . 28 261.28 261 . 28 261 . 28 257. 80 257.80

Relative to the base case for DL4, the

increase in volume of the smallest

transformer (i.e., "minimum") is nine

percent or less for TSL4 and lower,

while the largest transformer (i.e.,

"maximum") has an increase in volume

relative to the base case of two percent

or less for TSL4 and lower.

Relative to the base case for DLS, the

increase in volume of the smallest

transformer is 16 percent or less for

TSL4 and lower, while the largest

transformer has no increase in volume.

B. Summary of Comments on Size

Issues for Vault Transformers

DOE received comments on both size

and weight issues from stakeholders

during both the advance notice of

proposed rulemaking (ANOPR) and

NOPR phases of the rulemaking. In the

NOPR, DOE requested comment on

"whether the Department should

include space occupancy costs in the

cost of transformers as a means of

accounting for space constraints." 71 FR

44407. In response to this request,

commenters provided feedback both

during the public meeting and in their

written comments.

HVOLT commented that it endorsed

the concept of using space occupancy

costs in the evaluation of the impacts of

space-constrained utility transformers.

(Public Meeting Transcript, No. 108.6 at

p. 129) The American Council for an

Energy Efficient Economy (ACEEE)

recommended that DOE calculate what

"the average cost of a vault modification

is times the percentage of applications

that will trigger." (Public Meeting

Transcript, No. 108.6 at p. 130) The

Edison Electric Institute (EEI)

commented that space occupancy costs

should be included but that such costs

may be difficult to estimate and may

range from 10 percent of the cost of a

transformer to 100 percent of the

transformer cost. (Public Meeting

Transcript, No. 108.6 at p. 129-130)

In written comments after the NOPR

public meeting, ACEEE commented that

vault transformer costs should be

treated using methods similar to the

methods DOE used for distribution

transformer pole costs in the NOPR

analysis. (ACEEE, No. 127 at p. 6) EEI,

in its written comments, emphasized

the importance of the potential costs for

vault transformers since this effect

could create serious service reliability

issues for some utilities. (EEI, No. 137

at p. 3)

In its comments and submissions in

response to the ANOPR, EEI provided

limited data on potential costs that

could be applicable to vault

transformers. (EEI, No. 63 at pp. 20-62)

In its submission, EEI provided a survey

in which it asked its members, as well

as members of the American Public

Power Association (APPA) and the

National Rural Electric Cooperative

Association (NRECA), the following

question: "For currently existing padmount units in urban areas that need to

be replaced, what kind of impact would

a 10%, 25%, or 50% size increase have

on the installed costs?" EEI received

nine responses from its members, eight

responses from APPA members, and one

response from an NRECA member. EEI

packaged all these responses and

provided them to the DOE as one

comment. Of these responses, a few

were directly relevant to vault

transformers, with most responses

noting some impact but not quantifying

the size of the impacts. EEI member #6

commented that "Should the

transformer pad or vault lid require

replacement in order to fit the larger

transformer, then additional costs

ranging from $500 to $1,500 will

apply." (EEI, No. 63 at p. 36) At the high

end of cost estimates, APPA member #5

commented that "size would be an issue

if we had to change out units to larger.

Cost per location can cost approx.

$15k." (EEI, No. 63 at p. 42) Other EEI,

APPA, or NRECA members did not

provide specific estimates for relocation,

vault replacement, or vault modification

costs for vault transformers.

C. Size Constraints in DOE's NOPR

Analysis

While DOE did include sizedependent installation costs for

distribution transformers in its analysis

(see NOPR TSD, Chapter 7), it did not

include the additional space-constraint

costs that may be borne by vault

transformers. Since stakeholders

presented this issue as a substantial

concern in their comments on the

NOPR, and since DOE agrees that it did

not include these costs in the NOPR

analysis, DOE intends to consider these

costs in its analysis for the final rule.

 EE-RM/STD-00-550 COMMENT 159

6188 Federal Register/Vol. 72, No. 27/Friday, February 9, 2007/Proposed Rules 

and 90th percentiles. These 

distributions illustrate the degree to 

which average transformer volumes of 

selected designs in the NOPR LCC 

analysis varied by TSL. 

TABLE 11.1.-TRANSFORMER VOLUME IN CUBIC FEET, NOPR LCC RESULTS FOR DESIGN LINE 4 (150 KVA) 

Design line 4 Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

Minimum ................................................................. 61.11 63.89 66.55 66.41 66.41 80.24 87.50 

10th percentile ....................................................... 62.50 66.41 69.01 69.01 69.01 80.24 87.50 

25th percentile ....................................................... 64.93 67.71 69.36 70.54 70.54 80.24 87.50 

50th percentile ....................................................... 69.01 71.61 75.14 75.87 75.87 81.60 87.50 

75th percentile ....................................................... 75.87 76.16 78.88 81.60 81.60 86.11 88.89 

90th percentile ....................................................... 81.94 81.94 81.94 85.68 85.68 87.04 88.89 

Maximum ................................................................ 90.28 90.28 91.67 91.67 91.67 91.67 90.74 

TABLE 11.2.-TRANSFORMER VOLUME IN CUBIC FEET, NOPR LCC RESULTS FOR DESIGN LINE 5 (1500 KVA) 

Design line 5 Base case TSL 1 TSL 2 

Minimum ................................................................. 202.22 223.81 222.96 

10th percentile ....................................................... 215.91 227.99 233.41 

25th percentile ....................................................... 226.45 233.41 236.90 

50th percentile ....................................................... 236.90 236.90 240.38 

75th percentile ....................................................... 240.38 240.38 241.03 

90th percentile ....................................................... 250.83 250.83 250.83 

Maximum ................................................................ 261.28 261.28 261.28 

Relative to the base case for DL4, the 

increase in volume of the smallest 

transformer (Le., "minimum") is nine 

percent or less for TSL4 and lower, 

while the largest transformer (Le., 

"maximum") has an increase in volume 

relative to the base case of two percent 

or less for TSL4 and lower. 

Relative to the base case for DL5, the 

increase in volume of the smallest 

transformer is 16 percent or less for 

TSL4 and lower, while the largest 

transformer has no increase in volume. 

B. Summary of Comments on Size 

Issues for Vault Transformers 

DOE received comments on both size 

and weight issues from stakeholders 

during both the advance notice of 

proposed rulemaking (ANOPR) and 

NOPR phases of the rulemaking. In the 

NOPR, DOE requested comment on 

"whether the Department should 

include space occupancy costs in the 

cost of transformers as a means of 

accounting for space constraints." 71 FR 

44407. In response to this request, 

commenters provided feedback both 

during the public meeting and in their 

written comments. 

HVOL T commented that it endorsed 

the concept of using space occupancy 

costs in the evaluation ofthe impacts of 

space-constrained utility transformers. 

(Public Meeting Transcript, No. 108.6 at 

p. 129) The American Council for an 

Energy Efficient Economy (ACEEE) 

recommended that DOE calculate what 

"the average cost of a vault modification 

is times the percentage of applications 

that will trigger." (Public Meeting 

Transcript, No. 108.6 at p. 130) The 

Edison Electric Institute (EEl) 

commented that space occupancy costs 

should be included but that such costs 

may be difficult to estimate and may 

range from 10 percent of the cost of a 

transformer to 100 percent of the 

transformer cost. (Public Meeting 

Transcript, No. 108.6 at p. 129-130) 

In written comments after the NOPR 

public meeting, ACEEE commented that 

vault transformer costs should be 

treated using methods similar to the 

methods DOE used for distribution 

transformer pole costs in the NOPR 

analysis. (ACEEE, No. 127 at p. 6) EEl, 

in its written comments, emphasized 

the importance of the potential costs for 

vault transformers since this effect 

could create serious service reliability 

issues for some utilities. (EEl, No. 137 

at p. 3) 

In its comments and submissions in 

response to the ANOPR, EEl provided 

limited data on potential costs that 

could be applicable to vault 

transformers. (EEl, No. 63 at pp. 20-62) 

In its submission, EEl provided a survey 

in which it asked its members, as well 

as members of the American Public 

Power Association (APPA) and the 

National Rural Electric Cooperative 

Association (NRECA), the following 

question: "For currently existing padmount units in urban areas that need to 

be replaced, what kind of impact would 

a 10%,25%, or 50% size increase have 

on the installed costs?" EEl received 

nine responses from its members, eight 

responses from APPA members, and one 

response from an NRECA member. EEl 

TSL 3 TSL 4 TSL 5 TSL 6 

229.93 233.41 247.35 247.35 

233.41 236.90 250.83 250.83 

233.41 236.90 257.80 257.80 

240.38 240.38 257.80 257.80 

243.87 247.35 257.80 257.80 

250.83 250.83 257.80 257.80 

261.28 261.28 257.80 257.80 

packaged all these responses and 

provided them to the DOE as one 

comment. Of these responses, a few 

were directly relevant to vault 

transformers, with most responses 

noting some impact but not quantifying 

the size of the impacts. EEl member #6 

commented that "Should the 

transformer pad or vault lid require 

replacement in order to fit the larger 

transformer, then additional costs 

ranging from $500 to $1,500 will 

apply." (EEl, No. 63 at p. 36) At the high 

end of cost estimates, APPA member #5 

commented that "size would be an issue 

if we had to change out units to larger. 

Cost per location can cost approx. 

$15k." (EEl, No. 63 at p. 42) Other EEl, 

APP A, or NRECA members did not 

provide specific estimates for relocation, 

vault replacement, or vault modification 

costs for vault transformers. 

C. Size Constraints in DOE's NOPR 

Analysis 

While DOE did include sizedependent installation costs for 

distribution transformers in its analysis 

(see NOPR TSD, Chapter 7), it did not 

include the additional space-constraint 

costs that may be borne by vault 

transformers. Since stakeholders 

presented this issue as a substantial 

concern in their comments on the 

NOPR, and since DOE agrees that it did 

not include these costs in the NOPR 

analysis, DOE intends to consider these 

costs in its analysis for the final rule. 
Federal Register /Vol. 72, No. 27 /Friday, February 9, 2007 /Proposed Rules

III. DOE's Proposed Revisions to

Estimating Size Burdens

A. Vault Transformer Subgroup

Analysis

In response to the stakeholder

comments summarized above, DOE

intends to conduct a subgroup

sensitivity analysis of vault transformers

to estimate space-constraint costs for the

final rule. This issue is primarily of

concern for liquid-immersed, threephase distribution transformers, as this

type of transformer is most often used

in vault applications. Therefore DOE

intends to conduct its sensitivity

analysis on its two design lines that

represent three-phase liquid-immersed

distribution transformers, DL4 and DL5.

Information provided by Howard

Industries suggests that less than 0.5

percent of transformers are used in

submersible or vault applications.

(Howard Industries, No. 143 at p.5)

Taking that estimate of 0.5 percent of all

liquid-immersed transformers are vault

transformers, and assuming they are all

large, three-phase units such as those in

DL5, the percentage of vault

transformers could account for a

sizeable portion of total DL5 salesperhaps as high as 25 percent. If the

estimate of 0.5 percent of all liquidimmersed shipments were instead

assumed to all be smaller three-phase

transformers (i.e., DL4), the fraction of

DL4 transformers affected by such space

constraints is likely to be less than a few

percent. Stakeholders are invited to

comment on the proportion of

distribution transformers sold that are

installed in underground vaults,

particularly with respect to the liquidimmersed, three-phase design lines, DL4

and DL5.

B. Addressing Size Constraints for Vault

Transformers

DOE recognizes that, where vault

dimensional constraints are an issue,

transformer customers have several

options available to them, including:

1. Rewinding or refurbishing the

existing transformer,

2.. Purchasing a lower-kVA

transformer and subjecting it to higher

loading (or re-routing part of the load

served),

3. Purchasing a transformerconstructed of higher-performing core

steel and/or other materials-that is

standards-compliant without being

significantly larger (with added cost),

4. Rebuilding or expanding the

existing vault, or

5. Petitioning DOE for waiver from

energy conservation standard

requirements.

DOE expects that the first two

options, if available, would be cheaper

than purchasing a new transformer.

DOE therefore proposes to focus its

analysis of the LCC impacts from

dimensionally constrained vault

transformers on the third and fourth

options as part of an LCC subgroup

analysis published with the final rule.

C. Potential Approaches for Estimating

the Cost Impacts of Satisfying

Constraints Without Vault Modifications

Considering option 3 from the above

list, DOE could estimate the cost of

purchasing a transformer of the same

size, but constructed of higherperforming materials, such as better

grades of core steel or copper conductor,

by performing a size-constrained LCC

calculation for both DL4 and DL5. In

this calculation, DOE could assume the

standards-compliant transformer in the

LCC calculation was constrained at

certain sizes, e.g., at the 25th and 50th

percentiles of the distribution

transformer volumes in the base case.

As a function of standard level, DOE

could then run the LCC spreadsheets

and calculate the LCC of the spaceconstrained transformers (at prescribed

dimensional percentiles), and compare

those values to the LCC from the

unconstrained transformer analysis. The

difference in LCC between the two cases

would quantify the impact of satisfying

the space constraint with better

materials as a function of efficiency

level for that subgroup of dimensionally

constrained vault transformers.

D. Potential Approaches for Estimating

the Cost Impacts of Satisfying

Constraints With Vault Modifications

Considering option 4 from the above

list, DOE could add an additional sizedependent installation cost to the

transformers included in the LCC

subgroup analysis for vault transformers

to account for a relatively high

underground vault-space cost. DOE

invites additional stakeholder input or

data on what would be reasonable fixed

and variable costs (e.g., per cubic foot)

for DL4 and DL5. For this option, DOE

would apply the vault replacement costs

(with both a fixed and variable cost)

when a transformer exceeds the median

volume of the transformers in the base

case. Given a review of cost estimation

data for utility vault reconstruction, the

Department currently estimates a fixed

cost for vault replacement of $1740 per

vault and a variable cost of $26 per

cubic foot of transformer. Vault

replacement may be required for the

higher TSLs (TSL5 and above for both

DL4 and DL5). In its standard LCC

calculation, DOE based transformer

6189

selection on the manufacturer selling

price. For this calculation, however,

DOE proposes to assume that the

customer choice of transformer design is

based on total installed cost because

customers are likely to be conscious of

space constraint costs.

IV. Summary of Size Issue

DOE intends to consider spaceconstrained vault transformers as part of

the LCC subgroup analysis for the final

rule. DOE seeks comment from

stakeholders on the proportion of

distribution transformers sold which are

installed in underground vaults,

particularly with respect to the liquidimmersed, three-phase design lines, DL4

and DL5.

In this notice, DOE outlines different

approaches as to how it might account

for those additional installation costs.

DOE requests that stakeholders review

these approaches and provide comment

on the methodology and inputs. DOE

intends to use the same LCC

spreadsheet tools for estimating LCC

impacts on vault transformers, with

minor modifications, as it used to

analyze the other LCC subgroups in the

NOPR (see NOPR TSD, Chapter 11).

V. Consideration of Final Efficiency

Levels

DOE notes that in the NOPR, the

proposed final standard for liquidimmersed distribution transformers was

based on the efficiency levels presented

in TSL 2. 71 FR 44407. While the

proposed standard was based on TSL 2,

DOE-evaluated efficiency levels

associated with a series of TSLs.

Analysis of the other TSLs indicated

that some of the efficiency levels set

forth in TSL 3 and TSL 4 may be

justifiable for specific liquid-immersed

distribution transformer designs and

capacities. (See Table IV.4 in 71 FR

44378 and Tables EA.3 through EA.10

in pages EA.6 through EA.13 of the

Environmental Assessment Report

published with the NOPR TSD)

Referencing this analysis, some

commenters suggested that DOE

establish a final standard that

incorporates higher efficiency levels

from other TSLs, which preliminarily

appeared to comply with the

requirements of EPCA.

Based on the comments received to

date, DOE is inclined to consider a final

standard that is based on efficiency

levels from TSL 2 and/or 3 for threephase, liquid-immersed, distribution

transformers and efficiency levels from

TSL 2, 3, and/or 4 for single-phase

liquid-immersed, distribution

transformers. Today's notice provides

 EE-RM/STD-00-550 COMMENT 159

Federal Register! Vol. 72, No. 27/ Friday, February 9, 2007/ Proposed Rules 6189 

III. DOE's Proposed Revisions to 

Estimating Size Burdens 

A. Vault Transformer Subgroup 

Analysis 

In response to the stakeholder 

comments summarized above, DOE 

intends to conduct a subgroup 

sensitivity analysis of vault transformers 

to estimate space-constraint costs for the 

final rule. This issue is primarily of 

concern for liquid-immersed, threephase distribution transformers, as this 

type of transformer is most often used 

in vault applications. Therefore DOE 

intends to conduct its sensitivity 

analysis on its two design lines that 

represent three-phase liquid-immersed 

distribution transformers, DL4 and DL5. 

Information provided by Howard 

Industries suggests that less than 0.5 

percent of transformers are used in 

submersible or vault applications. 

(Howard Industries, No. 143 at p.5) 

Taking that estimate of 0.5 percent of all 

liquid-immersed transformers are vault 

transformers, and assuming they are all 

large, three-phase units such as those in 

DL5, the percentage of vault 

transformers could account for a 

sizeable portion of total DL5 salesperhaps as high as 25 percent. If the 

estimate of 0.5 percent of all liquidimmersed shipments were instead 

assumed to all be smaller three-phase 

transformers (Le., DL4), the fraction of 

DL4 transformers affected by such space 

constraints is likely to be less than a few 

percent. Stakeholders are invited to 

comment on the proportion of 

distribution transformers sold that are 

installed in underground vaults, 

particularly with respect to the liquidimmersed, three-phase design lines, DL4 

and DL5. 

B. Addressing Size Constraints for Vault 

Transformers 

DOE recognizes that, where vault 

dimensional constraints are an issue, 

transformer customers have several 

options available to them, including: 

1. Rewinding or refurbishing the 

existing transformer, 

2. Purchasing a 10wer-kVA 

transformer and subjecting it to higher 

loading (or re-routing part of the load 

served), 

3. Purchasing a transformerconstructed of higher-performing core 

steel and/or other materials-that is 

standards-compliant without being 

significantly larger (with added cost), 

4. Rebuilding or expanding the 

existing vault, or 

5. Petitioning DOE for waiver from 

energy conservation standard 

requirements. 

DOE expects that the first two 

options, if available, would be cheaper 

than purchasing a new transformer. 

DOE therefore proposes to focus its 

analysis of the LCC impacts from 

dimensionally constrained vault 

transformers on the third and fourth 

options as part of an LCC subgroup 

analysis published with the final rule. 

C. Potential Approaches for Estimating 

the Cost Impacts of Satisfying 

Constraints Without Vault Modifications 

Considering option 3 from the above 

list, DOE could estimate the cost of 

purchasing a transformer of the same 

size, but constructed of higherperforming materials, such as better 

grades of core steel or copper conductor, 

by performing a size-constrained LCC 

calculation for both DL4 and DL5. In 

this calculation, DOE could assume the 

standards-compliant transformer in the 

LCC calculation was constrained at 

certain sizes, e.g., at the 25th and 50th 

percentiles of the distribution 

transformer volumes in the base case. As a function of standard level, DOE 

could then run the LCC spreadsheets 

and calculate the LCC of the spaceconstrained transformers (at prescribed 

dimensional percentiles), and compare 

those values to the LCC from the 

unconstrained transformer analysis. The 

difference in LCC between the two cases 

would quantify the impact of satisfying 

the space constraint with better 

materials as a function of efficiency 

level for that subgroup of dimensionally 

constrained vault transformers. 

D. Potential Approaches for Estimating 

the Cost Impacts of Satisfying 

Constraints With Vault Modifications 

Considering option 4 from the above 

list, DOE could add an additional sizedependent installation cost to the 

transformers included in the LCC 

subgroup analysis for vault transformers 

to account for a relatively high 

underground vault-space cost. DOE 

invites additional stakeholder input or 

data on what would be reasonable fixed 

and variable costs (e.g., per cubic foot) 

for DL4 and DL5. For this option, DOE 

would apply the vault replacement costs 

(with both a fixed and variable cost) 

when a transformer exceeds the median 

volume of the transformers in the base 

case. Given a review of cost estimation 

data for utility vault reconstruction, the 

Department currently estimates a fixed 

cost for vault replacement of $1740 per 

vault and a variable cost of $26 per 

cubic foot oftransformer. Vault 

replacement may be required for the 

higher TSLs (TSL5 and above for both 

DL4 and DL5). In its standard LCC 

calculation, DOE based transformer 

selection on the manufacturer selling 

price. For this calculation, however, 

DOE proposes to assume that the 

customer choice of transformer design is 

based on total installed cost because 

customers are likely to be conscious of 

space constraint costs. 

IV. Summary of Size Issue 

DOE intends to consider spaceconstrained vault transformers as part of 

the LCC subgroup analysis for the final 

rule. DOE seeks comment from 

stakeholders on the proportion of 

distribution transformers sold which are 

installed in underground vaults, 

particularly with respect to the liquidimmersed, three-phase design lines, DL4 

andDL5. 

In this notice, DOE outlines different 

approaches as to how it might account 

for those additional installation costs. 

DOE requests that stakeholders review 

these approaches and provide comment 

on the methodology and inputs. DOE 

intends to use the same LCC 

spreadsheet tools for estimating LCC 

impacts on vault transformers, with 

minor modifications, as it used to 

analyze the other LCC subgroups in the 

NOPR (see NOPR TSD, Chapter 11). 

V. Consideration of Final Efficiency 

Levels 

DOE notes that in the NOPR, the 

proposed final standard for liquidimmersed distribution transformers was 

based on the efficiency levels presented 

in TSL 2. 71 FR 44407. While the 

proposed standard was based on TSL 2, 

DOE-evaluated efficiency levels 

associated with a series of TSLs. 

Analysis of the other TSLs indicated 

that some of the efficiency levels set 

forth in TSL 3 and TSL 4 may be 

justifiable for specific liquid-immersed 

distribution transformer designs and 

capacities. (See Table IV.4 in 71 FR 

44378 and Tables EA.3 through EA.10 

in pages EA.6 through EA.13 of the 

Environmental Assessment Report 

published with the NOPR TSD) 

Referencing this analysis, some 

commenters suggested that DOE 

establish a final standard that 

incorporates higher efficiency levels 

from other TSLs, which preliminarily 

appeared to comply with the 

requirements of EPCA. 

Based on the comments received to 

date, DOE is inclined to consider a final 

standard that is based on efficiency 

levels from TSL 2 and/or 3 for threephase, liquid-immersed, distribution 

transformers and efficiency levels from 

TSL 2, 3, and/or 4 for single-phase 

liquid-immersed, distribution 

transformers. Today's notice provides 
6190 Federal Register /Vol. 72, No. 27 /Friday, February 9, 2007 / Proposed Rules

stakeholders an opportunity to comment

on this potential consideration.

VI. Public Participation

A. Submission of Comments

DOE will accept comments, data, and

information regarding this notice no

later than the date provided at the

beginning of this notice. Comments,

data, and information submitted to the

Department's e-mail address for this

rulemaking should be provided in

WordPerfect, Microsoft Word, PDF, or

text (ASCII) file format. Stakeholders

should avoid the use of special

characters or any form of encryption,

and wherever possible, comments

should include the electronic signature

of the author. Absent an electronic

signature, comments submitted

electronically must be followed and

authenticated by submitting a signed

original paper document to the address

provided at the beginning of this notice.

Comments, data, and information

submitted to the Department via mail or

hand delivery/courier should include

one signed original paper copy. No

telefacsimiles (faxes) will be accepted.

According to 10 CFR 1004.11, any

person submitting information that he

or she believes to be confidential and

exempt by law from public disclosure

should submit two copies: One copy of

the document including all the

information believed to be confidential,

and one copy of the document with the

information believed to be confidential

deleted. DOE will make its own

determination about the confidential

status of the information and treat it

according to its determination.

Factors of interest to DOE when

evaluating requests to treat submitted

information as confidential include: (1)

A description of the items; (2) whether

and why such items are customarily

treated as confidential within the

industry; (3) whether the information is

generally known or available from

public sources; (4) whether the

information has previously been made

available to others without obligation

concerning its confidentiality; (5) an

explanation of the competitive injury to

the submitting person which would

result from public disclosure; (6) a date

after which such information might no

longer be considered confidential; and

(7) why disclosure of the information

would be contrary to the public interest.

B. Issues on Which DOE Seeks Comment

DOE is particularly interested in

receiving comments and views of

interested parties concerning:

(1) The proportion of distribution

transformers sold that are installed in

underground vaults, particularly with

respect to the liquid-immersed, threephase design lines, DL4 and DL5,

(2) The assumption that typical spaceconstrained vault transformers will be

restricted to a volume that is

approximately the median size of

baseline transformers, and

(3) The approaches proposed in this

notice to account for LCC impacts on

space-constrained vault transformers,

including the methodology and inputs.

(4) The possibility of having a liquidimmersed standard level that is based

on efficiency levels from TSL 2 and/or

3 for three-phase and TSL 2, 3, and/or

4 for single-phase.

Issued in Washington, DC, on February 2,

2007.

Alexander A. Karsner

Assistant Secretary, Energy Efficiency and

Renewable Energy.

[FR Doc. E7-2168 Filed 2-8-07; 8:45 am]

BILLING CODE 6450-01-P

ADDRESSES : Send submissions to:

CC:PA:LPD:PR (REG-115403-05), room

5203, Internal Revenue Service, PO Box

7604, Ben Franklin Station, Washington,

DC 20044. Submissions may be hand

delivered Monday through Friday

between the hours of 8 a.m. and 4 p.m.

to: CC:PA:LPD:PR (REG-115403-05),

Courier's Desk, Internal Revenue

Service, 1111 Constitution Avenue,

NW., Washington, DC, or sent

electronically, via the IRS Internet site

at www.irs.gov/regs or via the Federal

eRulemaking Portal at http://

www.Regulations.gov/ (IRS REG115403-05).

FOR FURTHER INFORMATION CONTACT:

Concerning the regulations, Bernard P.

Harvey, (202) 622-3110; concerning

submissions and to request a hearing,

Kelly Banks, (202) 622-7180 (not tollfree numbers).

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

DEPARTMENT OF THE TREASURY

Internal Revenue Service

The collections of information

contained in this notice of proposed

rulemaking have been submitted to the

Office of Management and Budget for

review in accordance with the

26 CFR Part 1 Paperwork Reduction Act of 1995 (44

[REG-115403-05] U.S.C. 3507(d)). Comments on the

collections of information should be

RIN 1545-BF94 sent to the Office of Management and

Section 181-Deduction for Qualified

Film and Television Production Costs

AGENCY : Internal Revenue Service (IRS),

Treasury.

ACTION: Notice of proposed rulemaking

by cross reference to temporary

regulation.

SUMMARY : In the Rules and Regulations

section of this issue of the Federal

Register, the IRS is issuing temporary

regulations under section 181 of the

Internal Revenue Code relating to

deductions for costs of producing

qualified film and television

productions. These temporary

regulations reflect changes to the law

made by the American Jobs Creation Act

of 2004 and the Gulf Opportunity Zone

Act of 2005, and affect taxpayers that

produce films and television

productions within the United States.

This action is necessary to provide

guidance for the application of section

181. The text of the temporary

regulations also serves as the text of

these proposed regulations. This

document also provides notice of a

public hearing on these proposed

regulations.

DATES : Written comments and requests

for a public hearing must be received by

April 10, 2007.

Budget, Attn: Desk Officer for the

Department of the Treasury, Office of

Information and Regulatory Affairs,

Washington, DC 20503, with copies to

the Internal Revenue Service, Attn: IRS

Reports Clearance Officer,

SE:W:CAR:MP:T:T:SP, Washington, DC

20224. Comments on the collection of

information should be received by May

10, 2007. Comments are specifically

requested concerning:

Whether the proposed collection of

information is necessary for the proper

performance of the functions of the

Internal Revenue Service, including

whether the information will have

practical utility;

The accuracy of the estimated burden

associated with the proposed collection

of information;

How the quality, utility, and clarity of

the information to be collected may be

enhanced;

How the burden of complying with

the proposed collection of information

may be minimized, including through

the application of automated collection

techniques or other forms of information

technology; and

Estimates of capital or start-up costs

and costs of operation, maintenance,

and purchase of service to provide

information.

The collection of information in this

proposed regulation is in § 1.181-2T(c).

 EE-RM/STD-00-550 COMMENT 159

6190 Federal Register/Vol. 72, No. 27/Friday, February g, 2007/Proposed Rules 

stakeholders an opportunity to comment 

on this potential consideration. 

VI. Public Participation 

A. Submission of Comments 

DOE will accept comments, data, and 

information regarding this notice no 

later than the date provided at the 

beginning ofthis notice. Comments, 

data, and information submitted to the 

Department's e-mail address for this 

rulemaking should be provided in 

WordPerfect, Microsoft Word, PDF, or 

text (ASCII) file format. Stakeholders 

should avoid the use of special 

characters or any form of encryption, 

and wherever possible, comments 

should include the electronic signature 

ofthe author. Absent an electronic 

signature, comments submitted 

electronically must be followed and 

authenticated by submitting a signed 

original paper document to the address 

provided at the beginning of this notice. 

Comments, data, and information 

submitted to the Department via mail or 

hand delivery/courier should include 

one signed original paper copy. No 

telefacsimiles (faxes) will be accepted. 

According to 10 CFR 1004.11, any 

person submitting information that he 

or she believes to be confidential and 

exempt by law from public disclosure 

should submit two copies: One copy of 

the document including all the 

information believed to be confidential, 

and one copy ofthe document with the 

information believed to be confidential 

deleted. DOE will make its own 

determination about the confidential 

status of the information and treat it 

according to its determination. 

Factors of interest to DOE when 

evaluating requests to treat submitted 

information as confidential include: (1) 

A description of the items; (2) whether 

and why such items are customarily 

treated as confidential within the 

industry; (3) whether the information is 

generally known or available from 

public sources; (4) whether the 

information has previously been made 

available to others without obligation 

concerning its confidentiality; (5) an 

explanation ofthe competitive injury to 

the submitting person which would 

result from public disclosure; (6) a date 

after which such information might no 

longer be considered confidential; and 

(7) why disclosure of the information 

would be contrary to the public interest. 

B. Issues on Which DOE Seeks Comment 

DOE is particularly interested in 

receiving comments and views of 

interested parties concerning: 

(1) The proportion of distribution 

transformers sold that are installed in 

underground vaults, particularly with 

respect to the liquid-immersed, threephase design lines, DL4 and DL5, 

(2) The assumption that typical spaceconstrained vault transformers will be 

restricted to a volume that is 

approximately the median size of 

baseline transformers, and 

(3) The approaches proposed in this 

notice to account for LCC impacts on 

space-constrained vault transformers, 

including the methodology and inputs. 

(4) The possibility of having a liquidimmersed standard level that is based 

on efficiency levels from TSL 2 and/or 

3 for three-phase and TSL 2, 3, and/or 

4 for single-phase. 

Issued in Washington, DC, on February 2, 

2007. 

Alexander A. Karsner 

Assistant Secretary, Energy Efficiency and 

Renewable Energy. 

[FR Doc. E7-2168 Filed 2-8-07; 8:45 am] 

BILLING CODE 6450-01-P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Part 1 

[REG-115403-05] 

RIN 1545-BF94 

Section 181-Deduction for Qualified 

Film and Television Production Costs 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking 

by cross reference to temporary 

regulation. 

SUMMARY: In the Rules and Regulations 

section of this issue of the Federal 

Register, the IRS is issuing temporary 

regulations under section 181 of the 

Internal Revenue Code relating to 

deductions for costs of producing 

qualified film and television 

productions. These temporary 

regulations reflect changes to the law 

made by the American Jobs Creation Act 

of 2004 and the Gulf Opportunity Zone 

Act of 2005, and affect taxpayers that 

produce films and television 

productions within the United States. 

This action is necessary to provide 

guidance for the application of section 

181, The text of the temporary 

regulations also serves as the text of 

these proposed regulations, This 

document also provides notice of a 

public hearing on these proposed 

regulations, 

DATES: Written comments and requests 

for a public hearing must be received by 

April 10, 2007. 

ADDRESSES: Send submissions to: 

CC:PA:LPD:PR (REG-115403-05), room 

5203, Internal Revenue Service, PO Box 

7604, Ben Franklin Station, Washington, 

DC 20044. Submissions may be hand 

delivered Monday through Friday 

between the hours of 8 a,m, and 4 p,m, 

to: CC:PA:LPD:PR (REG-115403-05), 

Courier's Desk, Internal Revenue 

Service, 1111 Constitution Avenue, 

NW" Washington, DC, or sent 

electronically, via the IRS Internet site 

at www.irs.gov/regs or via the Federal 

eRulemaking Portal at http:// 

www,Regulations,gov/ (IRS REG115403-05), 

FOR FURTHER INFORMATION CONTACT: 

Concerning the regulations, Bernard p, 

Harvey, (202) 622-3110; concerning 

submissions and to request a hearing, 

Kelly Banks, (202) 622-7180 (not tollfree numbers), 

SUPPLEMENTARY INFORMATION: 

Paperwork Reduction Act 

The collections of information 

contained in this notice of proposed 

rulemaking have been submitted to the 

Office of Management and Budget for 

review in accordance with the 

Paperwork Reduction Act of 1995 (44 

U,S,C. 3507(d)). Comments on the 

collections of information should be 

sent to the Office of Management and 

Budget, Attn: Desk Officer for the 

Department of the Treasury, Office of 

Information and Regulatory Affairs, 

Washington, DC 20503, with copies to 

the Internal Revenue Service, Attn: IRS 

Reports Clearance Officer, 

SE:W:CAR:MP:T:T:SP, Washington, DC 

20224, Comments on the collection of 

information should be received by May 

10,2007, Comments are specifically 

requested concerning: 

Whether the proposed collection of 

information is necessary for the proper 

performance of the functions of the 

Internal Revenue Service, including 

whether the information will have 

practical utility; 

The accuracy of the estimated burden 

associated with the proposed collection 

of information; 

How the quality, utility, and clarity of 

the information to be collected may be 

enhanced; 

How the burden of complying with 

the proposed collection of information 

may be minimized, including through 

the application of automated collection 

techniques or other forms of information 

technology; and 

Estimates of capital or start-up costs 

and costs of operation, maintenance, 

and purchase of service to provide 

information, 

The collection of information in this 

proposed regulation is in § 1.181-2T(c). 
Distribution Transformer Rulemaking

NODA email fist for February 12, 2007

aadamantiades@icgdevelopment.com

rjstahara@centralmoloneyinc.com

Adelaskil@aol.com

akline1490@aol.com

alant@kuhlman.com

alexander@georgmfg.com

alharch@windstream.net

amarantan@navigantconsulting.com

atmckane@lbl.gov

awalls@federalpacific.com

awilks@ermco-eci.com

BDS@cpuc.ca.gov

bgibbs@navigantconsulting.com

bkillins@rncan.gc.ca

bobal@canelect.ca

bruce.r.purcell@us.abb.com

Bryan.Berringer@hq.doe.gov

bush-c@pemco.net

butcher@bnl.gov

CABolduc@lbl.gov

carlosgsiqueiros@eaton.com

cbieber@mlgw.org

Cbrown@acmepower.com

cem6@pge.com

cfixa@mag-tran.com

charlied@uus.org

Chris.tuttle@usda.gov

ChristopherDHess@Eaton.com

ClaudiaEEstrada@eaton.com

cpruess@hitrancorp.com

cwooddell@mlgw.org

Cyrus.Nasseri@EE.DOE.gov

daho@cooperpower.com

dan_greenberg@platts.com

dana.I.basel@us.abb.com

dave.millure@metglas.com

dbachrach@nrdc.org

dbrender@cda.copper.org

dennisc@kuhlman.com

dfoster@olsun.com

dgoldstein@nrdc.org

 EE-RM/STD-00-550 COMMENT 159

Distribution Transformer Rulemaking 

NODA email list for February 12, 2007 

aadamantiades@icgdevelopment.com 

rjstahara@centralmoloneyinc.com 

Adelaski l@aol.com 

akline1490@aol.com 

alant@kuhlman.com 

alexander@georgmfg.com 

alharch@windstream.net 

amarantan@navigantconsulting.com 

atmckane@lbl.gov 

awalls@federalpacific.com 

aWilks@ermco-eci.com 

BDS@cpuc.ca.gov 

bgibbs@navigantconsulting.com 

bkillins@rncan.gc.ca 

bobal@canelect.ca 

bruce.r.purcell@us.abb.com 

Bryan.Berringer@hq.doe.gov 

bush-c@pemco.net 

butcher@bnl.gov 

CABolduc@lbl.gov 

carlosgsiqueiros@eaton.com 

cbieber@mlgw.org 

Cbrown@acmepower.com 

cem6@pge.com 

cfixa@mag-tran.com 

charlied@uus.org 

Chris. tuttle@usda.gov 

ChristopherDHess@Eaton.com 

ClaudiaEEstrada@eaton.com 

cpruess@hitrancorp.com 

cwooddell@mlgw.org 

Cyrus. Nasseri@EE.DOE.gov 

daho@cooperpower.com 

dan_greenberg@platts.com 

dana.l.basel@us.abb.com 

dave.millure@metglas.com 

dbachrach@nrdc.org 

d brender@cda.copper.org 

dennisc@kuhlman.com 

dfoster@olsun.com 

dgoldstein@nrdc.org 
DHM3@PGE.COM

dmbrunda@southernco.com

don.duckett@hughessupply.com

doug.tyger@aksteel.com

drolling@cooperpower.com

dsaget@howard-ind.com

dwiegand@sympatico.ca

ebrush@Comcast.net

ed.case@aksteel.com

edw_gray@nema.org

ehwiebe@hydro.mb.ca

electric@uptegraff.com

elevy@navigantconsulting.com

empainc@aol.com

Eric.richman@pnI.gov

fbray@aeci.com

fouad.dagher@us.ngrid.com

Francine. Pinto@hq.doe.gov

gking@howard-ind.com

glen.campbelI@nrcan.gc.ca

greg.coulter@ge.com

gxd7@pge.com

hamblin@mirusinternational.com

hhayes@ameren.com

hhecker@cooperpower.com

hingea@aol.com

hoevenaars@mirusinternational.com

hsachs@aceee.org

info@jeffersonelectric.com

jashley@acmepower.com

jcorkran@cooperpower.com

jcurrall@acmepower.com

jdelk@howard-ind.com

Jeff.Sterba@pnmresources.com

jemcmahon@lbl.gov

ferry.keenum@powerpartners-usa.com

Jerry.Schoen@aksteel.com

jhodge@howard-ind.com

Jim.Bohlk@usda.gov

jim.mapp@doa.state.wi.us

Jim.Wiseman@us.schneider-electric.com

jlstoops@lbl.gov

jmoore@cooperpower.com

joel.jackman@pse.com

 EE-RM/STD-00-550 COMMENT 159

DHM3@PGE.COM 

dmbrunda@southernco.com 

don.duckett@hughessupply.com 

doug. tyger@aksteel.com 

drolling@cooperpower.com 

dsaget@howard-ind.com 

dwiegand@sympatico.ca 

ebrush@Comcast.net 

ed. case@aksteel.com 

edw_gray@nema.org 

ehwiebe@hydro.mb.ca 

electric@uptegraff.com 

elevy@navigantconsulting.com 

empainc@aol.com 

Eric.richman@pnl.gov 

fbray@aeci.com 

fouad.dagher@us.ngrid.com 

Fra ncine. Pinto@hq.doe.gov 

gking@howard-ind.com 

glen.campbell@nrcan.gc.ca 

greg.coulter@ge.com 

gxd7@pge.com 

hamblin@mirusinternational.com 

hhayes@ameren.com 

hhecker@cooperpower.com 

hingea@aol.com 

hoevenaars@mirusinternational.com 

hsachs@aceee.org 

info@jeffersonelectric.com 

jashley@acmepower.com 

jcorkran@cooperpower.com 

jcurrall@acmepower.com 

jdelk@howard-ind.com 

Jeff.Sterba@pnmresources.com 

jemcmahon@lbl.gov 

jerry. keenum@powerpartners-usa.com 

Jerry.Schoen@aksteel.com 

jhodge@howard-ind.com 

Jim. Bohlk@usda.gov 

jim.mapp@doa.state.wi.us 

Jim. Wiseman@us.schneider-electric.com 

jlstoops@lbl.gov 

jmoore@cooperpower.com 

joel.jackman@pse.com 
john.serfling@xcelenergy.com

john_hinkson@wr.com

johnson-j@pemco.net

johnz@kuhlman.com

]PHarris@Ibl.gov

jpiel@cooperpower.com

jrossetti@mlgw.org

jrossetti@mlgw.org

jstieler@cooperpower.com

jvandervort@navigantconsuIting.com

kdelves@nrcan.gc.ca

khall@eei.org

klgilmor@southernco.com

kmcclos@alleghenypower.com

kmcgill@duqlight.com

kur_riesenberg@nema.org

kwinder@mleainc.com

LanetteITynan@eaton.com

Lfrankli@energy.state.ca. us

LLVanWie@lbl.gov

maheshsampat@bellsouth.net

manopuri@worldnet.att.net

mark.friedrichs@hq.doe.gov

Mary.S.Dupre@xceIenergy.com

mbhanoo@layerzero.com

mbuckna@jeffersonelectric.com

McConnellBW@orni.gov

mculhane@cooperpower.com

MDFAULKE@southernco.com

mesteghamat@nmlp.com

Mgromlovits@acmepower.com

mhumen@cooperpower.com

mhyland@appanet.org

michael.mccabe@ee.doe.gov

misuriello@ase.org

MIyer@lbl.gov

mrivest@navigantconsulting.com

mscholand@navigantconsulting.com

mtucker@acmepower.com

narena@acmepower.com

nmitchell@APPAnet.org

opseast@msn.com

oskars.petersons@nist.gov

paul_boman@hsb.com

 EE-RM/STD-00-550 COMMENT 159

john.serfling@xcelenergy.com 

john_hinkson@wr.com 

johnson-j@pemco.net 

johnz@kuhlman.com 

JPHarris@lbl.gov 

jpiel@cooperpower.com 

jrossetti@mlgw.org 

jrossetti@mlgw.org 

jstieler@cooperpower.com 

jvandervort@navigantconsulting.com 

kdelves@nrcan.gc.ca 

khall@eei.org 

klgilmor@southernco.com 

kmcclos@alleghenypower.com 

kmcgill@duqlight.com 

kur _riesenberg@nema.org 

kwinder@mleainc.com 

LanetteITynan@eaton.com 

Lfrankli@energy.state.ca.us 

LLVanWie@lbl.gov 

maheshsampat@bellsouth.net 

manopuri@worldnet.att.net 

mark. friedrichs@hq.doe.gov 

Mary .5. Dupre@xcelenergy.com 

mbhanoo@layerzero.com 

mbuckna@jeffersonelectric.com 

McConneIIBW@ornl.gov 

mculhane@cooperpower.com 

MDFAULKE@southernco.com 

mesteghamat@nmlp.com 

Mgromlovits@acmepower.com 

mhumen@cooperpower.com 

mhyland@appanet.org 

michael. mccabe@ee.doe.gov 

misuriello@ase.org 

MIyer@lbl.gov 

mrivest@navigantconsulting.com 

mscholand@navigantconsulting.com 

mtucker@acmepower.com 

narena@acmepower.com 

nmitchell@APPAnet.org 

opseast@msn.com 

oskars.petersons@nist.gov 

paul_boman@hsb.com 
pdpdtechsupport@acmepower.com

Pet_Smeltzer@nema.org

Phopkinson@hvolt.com

pjr@nyserda.org

plim@mlgw.org

pnardi@jeffersonelectric.com

publicsolutions@earthlink.net

qhodge@howard-ind.com

Qonnie.Laughlin@ee.doe.gov

raleighd@squared.com

ray.nicholas@us.abb.com

rcarter@jeffersonelectric.com

rdvanbuskirk@lbl.gov

rgreeson@electro-mechanical.com

rg reeson @federa l pacific.com

rhollin@howard-ind.com

rich.adams@pse.com

Richard. Lyke@aksteel.com

rip.psyck@aksteel.com

rjpolinski@alleghenyludlum.com

rmarusinec@cooperpower.com

rmorgan@psc.dc.gov

robert.saint@nreca.org

Robert@actransformer.com

Ronald. Lewis@ee.doe.gov

rsecrest@kinetics-industries.com

rush.b.horton@us.abb.com

russell@federalpacific.com

ryan.steven@epa.gov

rzimmerman@jeffersonelectric.com

Sco_choinski@nema.org

sgebha rdt@state. pa. us

skennedy@niagaratransformer.com

slindsay@tranco.ca

snadel@aceee.org

spielvogel@comcast.net

spolonis@dongan.com

srosenstock@eei.org

staarlen@aol.com

stephen. rosenfield@aps.com

SteveBehl@eaton.com

Teckman@nwcouncil.org

tholif@howard-ind.com

Thomas.Callsen@ExelonCorp.com

 EE-RM/STD-00-550 COMMENT 159

pdpdtechsupport@acmepower.com 

Pet_Smeltzer@nema.org 

Phopkinson@hvolt.com 

pjr@nyserda.org 

plim@mlgw.org 

pnardi@jeffersonelectric.com 

publicsolutions@earthlink.net 

qhodge@howard-ind.com 

Qonnie.Laughlin@ee.doe.gov 

raleighd@squared.com 

ray.nicholas@us.abb.com 

rcarter@jeffersonelectric.com 

rdvanbuskirk@lbl.gov 

rgreeson@electro-mechanical.com 

rgreeson@federalpacific.com 

rhollin@howard-ind.com 

rich.adams@pse.com 

Richard. Lyke@aksteel.com 

rip.psyck@aksteel.com 

rjpolinski@alleghenyludlum.com 

rmarusinec@cooperpower.com 

rmorgan@psc.dc.gov 

robert.saint@nreca.org 

Robert@actransformer.com 

Ronald.Lewis@ee.doe.gov 

rsecrest@kinetics-industries.com 

rush.b.horton@us.abb.com 

russell@federalpacific.com 

ryan.steven@epa.gov 

rzimmerman@jeffersonelectric.com 

Sco_choinski@nema.org 

sgebhardt@state.pa.us 

sken nedy@niagaratransformer.com 

sl i ndsay@tranco.ca 

snadel@aceee.org 

spielvogel@comcast.net 

spolonis@dongan.com 

srosenstock@eei.org 

staarlen@aol.com 

stephen. rosenfield@aps.com 

SteveBehl@eaton.com 

Teckman@nwcouncil.org 

tholif@howard-ind.com 

Thomas.Callsen@ExelonCorp.com 
Thomas. Depriest@hq.doe.gov

tim_feldman@nema.org

tjones@ceel.org

tklink@jeffersonelectric.com

tlewis@acmepower.com

tolson@hydro.mb.ca

tom.Iopp@powerpartners-usa.com

Tom@EnlowCompanies.com

tomm@kuhiman.com

uscharfy@georgmfg.com

wbiack@cda.copper.org

wes.patterson@us.abb.com

WMB@cpuc.ca.gov

 EE-RM/STD-00-550 COMMENT 159

Thomas.Depriest@hq.doe.gov 

tim_feldman@nema.org 

tjones@ceel.org 

tklink@jeffersonelectric.com 

tlewis@acmepower.com 

tolson@hydro.mb.ca 

tom.lopp@powerpartners-usa.com 

Tom@EnlowCompanies.com 

tomm@kuhlman.com 

uscharfy@georgmfg.com 

wblack@cda.copper.org 

wes.patterson@us.abb.com 

WMB@cpuc.ca.gov