From: Hirsch, Bruce R [mailto:Bruce.R.Hirsch@bge.com] 

Sent: Wednesday, September 28, 2011 11:25 AM 

To: 'Cohen, Daniel'; 'Jerry Hodge'; Rosenstock, Steven; Richard Parker; Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; Cymbalsky, John; adelaski@standardsasap.org; Teckman@nwcouncil.org; 

gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; mhyland@appanet.org; 

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; 

Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop; 

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; 

Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, 

Aaron; jmauer@standardsasap.org; greg.coulter405@gmail.com; bsmith@federalpacific.com; 

pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; ahofmann@publicpower.org; 

BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org; 

kwinder@mleainc.com; chad.kennedy@us.schneider-electric.com; eduardorobles@eaton.com; 

vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneiderelectric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, 

Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected. 

Dan,

I understand your statement. But this is the underlying issue.

Does it make sense to:

 set goals based on a set of average numbers thus creating inefficiencies in the multitude of

utility transformer purchases or

 would it make better sense to design a system that would allow efficiency to me maximized for

each transformer purchased thus maximizing efficiency across the nation?  

I think what we are hearing is that there is a broad range for the variables among utilities. These

variables have a direct effect on the efficiency of the transformers being utilized. Can DOE choose

between these two options or are we locked into option 1?

I don’t know the answer!

                                                                                                                Bruce  

From: Cohen, Daniel [mailto:Daniel.Cohen@hq.doe.gov] 

Sent: Friday, September 23, 2011 12:16 PM 

To: 'Jerry Hodge'; Hirsch, Bruce R; Rosenstock, Steven; Richard Parker; Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; Cymbalsky, John; adelaski@standardsasap.org; Teckman@nwcouncil.org; 

gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; mhyland@appanet.org; 

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; 

Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop; 

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; 

Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, 

Aaron; jmauer@standardsasap.org; greg.coulter405@gmail.com; bsmith@federalpacific.com; 

pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; ahofmann@publicpower.org; 

BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org; 
kwinder@mleainc.com; chad.kennedy@us.schneider-electric.com; eduardorobles@eaton.com; 

vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneiderelectric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, 

Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected. 

Being a simple country lawyer, I’m not sure I quite understand the details of the analytical 

suggestions made in the below e-mails, however, I would point out that DOE’s authority is to 

establish energy conservation standards applicable to manufacturers of covered products. I’m 

not sure how we would set a manufacturer standard based on calculations performed by 

purchasers of a product to meet that purchaser’s individual requirements. 

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Please notify us immediately that you have received this message in error, and delete the message.

From: Jerry Hodge [mailto:jhodge@howard-ind.com] 

Sent: Thursday, September 22, 2011 5:03 PM 

To: Hirsch, Bruce R; Rosenstock, Steven; Richard Parker; Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; Cymbalsky, John; adelaski@standardsasap.org; Teckman@nwcouncil.org; 

gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; mhyland@appanet.org; 

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; 

Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop; 

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; 

Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, 

Aaron; Cohen, Daniel; jmauer@standardsasap.org; greg.coulter405@gmail.com; 

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; 

ahofmann@publicpower.org; BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; 

jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.kennedy@us.schneiderelectric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; 

thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, 

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected. 

To Bruce and All:

 

I must qualify what I wrote earlier. First of all, I don't want to sound negative about any 

of this. Higher efficiencies means energy savings and I'm for that. TOC is not "dead". 

We recommend to all of our customers that we should optimize to meet the DOE 

threshold efficiency and at the same time optimize to get the lowest TOC that still meets 

the DOE threshold. This may change the ratio of losses and make the price a little 

more expensive but it gives the best TOC.

 

There are a number scenarios with regard to optimizing:

 
1. Don't use any TOC formula. You just get the required DOE threshold efficiency at 

the lowest price.

 

2. Customer has a formula but doesn't want to use it, so you get the same result as no. 

1.

 

3. Customer has a formula but the A and B factors are too low to be effective, so you 

get the same result as no. 1.

 

4. Customer has a formula and the A and B factors are effective, so you get the best 

TOC design that probably changes the ratio of core loss to conductor loss and it may 

cost a little more, but it still meets the DOE Efficiency.

 

5. Customer has a formula that has high A and B factors, so you get a design that has 

the best TOC and it has an efficiency greater than the DOE threshold value and it costs 

more.

 

These are the main scenarios, there may be others. The point I want to make is that we 

encourage customers to continue to use TOC and buy based on it. There is now a 

tendency to forget about using the TOC approach and just depend on meeting DOE 

requirements.

 

So,TOC is still alive and we encourage everyone to use it.

 

Jerry

 

 

Jerry Hodge 

Consulting Engineer, E.E., M.S., P.E. 

Retired V.P. & G.M. of Pole Type Transformer & Regulator Div. 

Howard Industries Inc. 

P.O.Box 1588 

Laurel, Ms, 39440 

601 422-1539 Bus. 

484 226-6190 Cell 

CONFIDENTIALITY NOTICE: The information in this e-mail message, including all replies or forwarded messages connected herewith, is 

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-----Original Message----- 

From: Hirsch, Bruce R [mailto:Bruce.R.Hirsch@bge.com] 

Sent: Thursday, September 22, 2011 2:54 PM 

To: Jerry Hodge; Rosenstock, Steven; Richard Parker; Corkran, Jerry L 
Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; john.cymbalsky@ee.doe.gov; adelaski@standardsasap.org; 

Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; 

mhyland@appanet.org; dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; 

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop; 

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; 

Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, 

Aaron; Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com; 

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; 

ahofmann@publicpower.org; BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; 

jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.kennedy@us.schneiderelectric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; 

thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, 

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected.

Jerry on other Team Members,

With a one size fits all philosophy, we know that the product is going to be too large in some cases and

too small in others. Unfortunately only a small percentage will fit correctly.  

In a transformer world, those of us using TOC evaluations have been buying the correct size for 40 years

and the Industry is well prepared to handle supplying the correct size to any and all comers. Seems that

we are moving from a very efficient micro‐management of the issue to a macro management that is

forcing inefficiencies upon us and driving up costs for our customers. I might be able to accept the

higher costs if I could see an improved product but in this case our customers (of the utilities that have

been buying via TOC evaluations) are being forced to pay for inefficiencies.

We need to convince those not in the Utility Industry that the majority of the Industry have been

maximizing transformer efficiency for many years. And I fully support forcing those who haven’t to

adopt procedures to maximize efficiency. The problem as I see it is that we gone away from a proven

theoretical approach to a shotgun approach that is missing most of the targets. I don’t understand why

everyone else doesn’t see that. Maybe I am missing something!

                                                                                                                                                Bruce

From: Jerry Hodge [mailto:jhodge@howard-ind.com] 

Sent: Thursday, September 22, 2011 3:34 PM 

To: Hirsch, Bruce R; Rosenstock, Steven; Richard Parker; Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; john.cymbalsky@ee.doe.gov; adelaski@standardsasap.org; 

Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; 

mhyland@appanet.org; dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; 

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop; 

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; 

Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, 

Aaron; Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com; 

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; 

ahofmann@publicpower.org; BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; 

jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.kennedy@us.schneider-
electric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; 

thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, 

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected. 

To Bruce and All;

 

Since 1992, when we first fell under the DOE Appliance efficiency rulemaking, I have 

pushed to keep the TOC approach to transformer efficiency. I am speaking now about 

only liquid-immersed distribution transformers. The users of these products are well 

educated utility personnel, who are trying to minimize their owning costs which includes 

the price of the product plus it's operating cost over the life of the transformer.

 

In all of my comments to DOE, leading up to the first Final Rule in October, 2007, I 

continued to recommend keeping the TOC approach that had worked so well for many 

years. Unfortunately, DOE didn't agree with me. They want one size to fit all. 

Therefore some utilities are forced to over buy what is economically best for them. 

Many of the Co-ops and some Municipals must buy a transformer that is optimized for a 

50% load when they only need one for a 10% load. The one size fits all ends up being 

a compromise. That's difficult to do well in a nation as big and diversified as the USA.

 

I don't know how we could change back to a TOC approach at this late date or if there is 

even any desire to do so.

 

Jerry 

Jerry Hodge 

Consulting Engineer, E.E., M.S., P.E. 

Retired V.P. & G.M. of Pole Type Transformer & Regulator Div. 

Howard Industries Inc. 

P.O.Box 1588 

Laurel, Ms, 39440 

601 422-1539 Bus. 

484 226-6190 Cell 

CONFIDENTIALITY NOTICE: The information in this e-mail message, including all replies or forwarded messages connected herewith, is 

confidential, may be legally privileged, and is intended only for the use of the intended recipient(s). If you, the reader of this message, are 

not an intended recipient hereof, you are hereby notified that you should not further disseminate, distribute, or forward this e-mail message. 

If you have received this e-mail message in error, please notify the sender as soon as possible by return e-mail message or by telephone at 

(601) 425-3151. In addition, please delete the erroneously received message and any reply from your system and any device/media where 

the message is stored. 

-----Original Message----- 

From: Hirsch, Bruce R [mailto:Bruce.R.Hirsch@bge.com] 

Sent: Thursday, September 22, 2011 1:45 PM 

To: 'Rosenstock, Steven'; Richard Parker; Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; john.cymbalsky@ee.doe.gov; adelaski@standardsasap.org; 
Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; 

mhyland@appanet.org; dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; 

Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; rroy@nrdc.org; robert.saint@nreca.coop; 

chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; 

Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge; jrossetti@mlgw.org; 

Jim.creevy@nema.org; Meyers, Aaron; Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; 

greg.coulter405@gmail.com; bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil 

Hopkinson; ahofmann@publicpower.org; BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; 

jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.kennedy@us.schneiderelectric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; 

thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, 

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected.

Richard,

I concur with Mr. Rosenstock’s concerns and would like to point out an underlying issue made in bullet

two of his email below. That being the concept that it is actually “less efficient” to try and force every

application of distribution transformers to fit a specific DOE efficiency level.  

Since the 1970’s a majority of utility organizations have purchased distribution transformers based on

Total Owning Costs (TOC). An IEEE developed equation provides the utility the opportunity to customize

the transformers they purchase to achieve the most efficient design for their system and their

application. The TOC evaluation takes into account the up‐front costs, transformer loading practices of

the utility, local energy costs and life expectancy of the transformers for the application under for

which they are being purchased. This is truly the most efficient and most economical application for the

utility’s customers.  

The Southeastern Electric Exchange is a group of electric utility companies that share information and

practices to improve performance. They represent a microcosm of the Utility Industry nationwide but

provide a good cross section of the Industry. I did a quick pole of the Exchange member Companies and

provide the following statistics.  

 With regards to transformer loading, the Companies report an average loading of 37.7% ‐ well

below the 50% designated in the DOE proposal.   

 80% of the Companies responding to the survey indicate they run a TOC calculation and utilize

that to assist in their transformer purchases. (Another 10% utilized the TOC methodology until

DOE instituted set efficiency standards in 2010 at which time they switched to buy transformers

per the DOE numbers.)  

If we truly want to optimize efficiency we need to find a way to take into account the different situations

that exist from Company to Company, application to application and geographical region to

geographical region. DOE should consider doing away with set efficiency numbers (which could never

truly optimize efficiency in all cases) and require all transformer purchases to be done via a TOC

optimization evaluation. DOE could dictate the equation to be used thus ensuring the essential variables

are included for each purchase. They could also have the transformer manufacturers continue to police

the requirements by requiring them to run a TOC evaluation on every transformer manufactured. This

approach would offer a customized approach that ensures true optimization, efficiency and affordability
of transformers purchased under all applications in the future. Since the majority of Utilities are familiar

with the TOC evaluation, adoption of the new rule could be accelerated yielding immediate benefits.  

We continue to struggle with setting efficiency levels. In fact we are trying to force every transformer

application to fit a specific model. This is impractical and impossible to accomplish. Allowing

transformers to be customized for each application via a mathematical design which optimizes cost

versus losses over some lifetime makes a lot more sense. We as a Team need to give this some serious

thought.

                                                                                                                                                Bruce Hirsch   

Rosenstock, Steven [mailto:SRosenstock@eei.org] 

Sent: Wednesday, September 21, 2011 6:04 PM 

To: Richard Parker; Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; john.cymbalsky@ee.doe.gov; adelaski@standardsasap.org; 

Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; Hirsch, 

Bruce R; mhyland@appanet.org; dave.millure@metglas.com; snadel@aceee.org; 

wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; 

rroy@nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; 

cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; gjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge; 

jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron; Daniel.Cohen@hq.doe.gov; 

jmauer@standardsasap.org; greg.coulter405@gmail.com; bsmith@federalpacific.com; 

pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; ahofmann@publicpower.org; 

BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org; 

kwinder@mleainc.com; chad.kennedy@us.schneider-electric.com; eduardorobles@eaton.com; 

vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneiderelectric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, 

Jack C; Smith, Jennifer 

Subject: RE: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected. 

Mr. Parker and others, 

Below are other thoughts for the ground rules / negotiations. I believe that they are critical for 

the success. 

-As part of these negotiations, any or all efficiency levels should be on the table, not just values 

chosen by DOE consultants. 

-As part of these negotiations, parties should be able to look at different efficiency levels for 

different applications and/or distinct designs. Such product groupings within a product class 

would be consistent with other federal efficiency standards (e.g., efficiency standards for top 

freezer type refrigerator/freezers are different from the standards for bottom freezer types, which 

are different from side-by-side refrigerator/freezers). 
-As part of these negotiations, any committee member can suggest sub-groups that can meet “off 

line” to provide input to the full committee for its consideration. 

Thank you for your consideration. 

Steve Rosenstock 

Manager, Energy Solutions 

Edison Electric Institute 

srosenstock@eei.org

202-508-5465 

From: Richard Parker [mailto:richardparkerdc@gmail.com] 

Sent: Wednesday, September 21, 2011 1:39 PM 

To: Corkran, Jerry L 

Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; 

john.caskey@nema.org; john.cymbalsky@ee.doe.gov; adelaski@standardsasap.org; 

Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; 

bruce.r.hirsch@bge.com; mhyland@appanet.org; dave.millure@metglas.com; Nadel, Steve; 

wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; Rosenstock, 

Steven; rroy@nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgnmail.com; 

mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@lbl.gov; Brian Coffey; 

gjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, 

Aaron; Daniel.Cohen@hq.doe.gov; jmauer@standardsasap.org; greg.coulter405@gmail.com; 

bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; 

ahofmann@publicpower.org; BermanEconomics@gmail.com; Paul.Ryan@hitmet.com; 

jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.kennedy@us.schneiderelectric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; 

thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider, Jeffrey A; Loomans, 

Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: Re: Distribution Transformers Committee requested areas for the DOE to Investigate before 

final rules are selected. 

Jerry (and larger group), 

Thanks, Jerry, for your comments, queries and suggestions. My apologies to all for the late 

notice on the Ground Rules. The compressed time frame for this rulemaking has us all 

scrambling, but we will do our best to get key docs to group well in advance of meetings in the 

future (to the extent that analytical requirements and resource limitations allow). Most of the 

ground rules document is boilerplate for negotiated rulemakings. We had an extensive 

discussion about the parts that are not. But given your concern I will re-open the groundrules for 

online discussion, as needed, and clearance. I will do that in a separate email thread. 

Would c.o.b Monday be reasonable deadline for comments on groundrules in your view, with 

aim of taking online poll towards middle of next week? 
As for the deadlines for talks, the Dec 22 term sheet deadline can be altered by unanimous 

consent of the group, but you should know that it is really a practical deadline that results from 

working backwards from the Jan. 30 court deadline (assuming court approves revised settlement 

agreement). So regardless of what is in our ground rules, that will be the de facto deadline for 

meeting the court deadline unless and until the plaintiffs agree to further extend that deadline. 

Your substantive comments are appreciated. I will consult with DOE/Navigant/LBL staff and 

develop a joint preliminary response which we will then post online is some appropriate format 

for further review and comment. 

All best, 

Richard Parker 

On Tue, Sep 20, 2011 at 3:57 PM, Corkran, Jerry L <Jerry.Corkran@cooperindustries.com> 

wrote: 

I am submitting following items for requests for investigation by the DOE. Some of the 

questions listed below were presented before or during the first meeting, but I have not 

received sufficient information to answer the questions and requests listed below:

1. A good portion of the recent meetings were concerned with the review and 

revisions of the ground rules for the Negotiated Rulemaking Working Group. A 

copy of this document was issued dated as “Final 9/15/11” during the second 

day of the meetings. I was concerned and puzzled about why a legal document 

of this type was not issued well in advance of the working group meetings. The 

document has a legal tone and application that makes its review beyond my 

capabilities to determine if it is suitable to govern the working group and its 

suitability for me to accept w/o reservations. I have submitted it to a Cooper 

Power Systems attorney for review to determine if it requires changes before 

agreeing to its content. I am objecting to the Sept. 23 deadline for comments 

and suggestions on this item and request that we be able to submit input on 

suggested changes after out attorney has an opportunity to review the 

document. At this time I am objecting to the “4. Agreement” rule with details of 

the objection or withdrawal of my objections to be made after our attorney 

reviews the document. I also object to the 3 d. Deadline for Negotiations to 

terminate at Dec. 22, 2011. I suggest that this date be determined by the 

working group during the third meeting in Nov. after the working group has a 

knowledge of the time needed to complete the process. 

2. Would the DOE provide the actual design information for the least-cost 

transformer designs? Sufficient design information should be included to allow 

the transformer manufacturers to compare the same design created on their 

programs to the DOE created designs.

3. Would the DOE request transformer design quotations from multiple 

manufacturers for the transformer efficiency loss levels that the DOE considers 
buildable? This would provide the DOE with actual designs which the 

manufacturers are capable of building. These designs could be compared to 

the designs which the DOE is currently using to generate the efficiency data 

projections.

4. Would the DOE request quotations from multiple manufacturers optimized 

for the lowest total owning costs at evaluated loss levels that they are 

considering. The evaluation A and B factors would vary by a 4:1 ratio to reflect 

a maximum efficiency at a 50% load. Suggested A and B factors are 0/0, $4/$1, 

$8/$2, $12/$3, and $16/$4.

5. The DOE transformer designs show a large scale movement to amorphous 

core steel due to it lower loss characteristics. Review of the DOE transformer 

designs indicates that there might be a 700% increase in usage of the 

amorphous core steel over present annual production of this material. The 

DOE is requested to create projections listing what price increases and material 

shortages are to be expected if the use of this material is forced by transformer 

efficiency rules that dictate its use.

6. Because there is only one major supplier of amorphous core steel in the 

world that meets the efficiency levels used by the DOE in their optimizations, 

which is Hitachi in Japan and Metglas in the US (which is owned by Hitachi); is 

it legal for a law to be created at the DOE’s suggestion, forcing the exclusive use 

of this material in Distribution Transformers to meet the efficiency 

requirements chosen by the DOE?

7. The DOE is requested to show that adequate supplies of the materials 

produced within the United States exist to manufacture the required 

transformers that will meet the transformer efficiency requirements chosen for 

the proposed changes from the existing transformer efficiency requirements. If 

sources of materials are required from outside the United States, the DOE is 

requested to estimate what jobs will be lost and the dollar cost within the United 

States over the 30 year average and 60 year maximum life of the transformers 

as compared to using materials available within the United States.

8. Regarding the assumptions that the DOE made to use an average 

distribution transformer life of 30 years in their transformer efficiency payback 

calculations; the IEEE Transformer committee in the various technical 

standards which apply to Distribution transformers specifies an average life of 

20.5 years. We recommend that the 20.5 year average Distribution 

Transformer life be used by the DOE in their payback analysis. How did the 

DOE arrive at the 30 year anticipated life?

9. Regarding the payback times used by the DOE, the document 10 CFR Part 

431 was issued on October 12, 2007 to list the required efficiency levels for 

distribution transformers. On page 58220 of this document, various payback 
intervals between 5.1 and 21.6 years are listed for the efficiencies chosen for this 

standard. In the Preliminary Technical Document (TSD):Energy Efficiency 

Program for Commercial and Industrial Equiptment :Distribution 

Transformers dated March 2011, pay back intervals are listed on page ES-16 

Table ES.2.7 for the various standard levels. The DOE is requested to explain if 

these pay back intervals are based on a change from the existing efficiency 

standard? If the change is from the existing efficiency standard, the DOE is 

requested to add the years of payback as listed in 19CFR Part 431 to the years 

listed on the March 2011 document. 

10.The DOE used a 50% anticipated loading factor for the 30 year anticipated 

average life calculations used in their transformer efficiency evaluations. What 

is the source of the 50% loading factor used over a 30 year average and 60 year 

maximum expected life for the transformers evaluated? The DOE is requested 

to consult the power companies to learn what load factors they expect for 

transformers in service for up to 60 years. This item is very important, because 

as the loading level increases, the efficiency of an amorphous core design will 

decrease when compared to a silicon core design if they are both optimized to 

the same A and B factors. The amorphous core design may have a the higher 

efficiency at a 50% average loading but, this efficiency advantage will disappear 

as the average load increases and the silicon core steel designs become more 

efficient than the amorphous core steel designs when they are both optimized to 

the same A and B factors. 

11. Regarding the payback intervals to be used by the DOE to select the 

efficiency levels to be recommended, the level of loading is based on many 

assumptions that may change, a payback interval of 5 to 10 years is 

recommended to avoid forcing transformer purchases based on changeable 

assumptions that likely will result in the longer paybacks never happening. 

12.Electric autos are expected to take an increasing percentage of the auto 

market. The July 2011 IEEE Power and Energy magazine estimates that in 5 

years, 15% of the global new vehicle market will be electric autos. The DOE is 

requested to allow for the increased load factor for charging electric vehicles 

over the 60 year span they have chosen to consider for transformer loading. 

13.The DOE is requested to get in touch with Marketing and/or Business 

Development persons at the major auto manufacturers to learn what their 

projections are regarding the projected growth and market share for electric 

vehicles. What market share do these companies project for electric autos and 

how will that added load to the electrical systems affect the projected average 

loading over the next 60 years?

14.For pole type distribution transformers, the higher efficiency designs used 

by the DOE to evaluate the transformer efficiencies have a very significant 

increase in weight and also in transformer overall height. The DOE is 
requested to factor in the increased pole loading and related need to replace 

existing poles in some cases to allow the mounting of the heavier pole type 

transformers. Some of the higher efficiency transformers will have a total 

weight of twice that of the existing transformer which is being replaced.

15.The DOE is requested to change percentage efficiency targets to a method of 

controlling the transformer efficiency using the lowest total owning cost (TOC) 

optimized designs using TOC A and B factors written into law to control 

transformer efficiencies. The advantage of using the TOC A and B factors to 

control transformer efficiency is that it allows the transformer quotations to 

respond to the available materials. For example if copper conductors are 

required to meet a specified efficiency, transformer manufacturers would not be 

able to quote if a flood cut off the copper supply. Using the TOC A and B 

factors, each manufacturer would be allowed to quote, if they used the correct A 

and B factors. Another example is if the customer prefers to raise the basic 

insulation level (bil) of the requested transformer design, the manufacturers will 

optimize to the specified bil using the correct A and B factors. The end result is 

that the higher bil would be just slightly less efficient than a lower bil because of 

the added insulation required to obtain the higher basic insulation level. I 

raised this question during the first meeting, but did not receive a response from 

the DOE about this subject , therefore I am requesting that this subject be 

considered and responded to by the DOE before they proceed with the final rule 

making. The total owning cost approach will handle the variations that occur 

within the industry and also result in a similar improvement in efficiency as 

would transformer efficiency targets. It will allow the transformer efficiencies 

to be increased as justified, using all the factors they are currently using to 

create target transformer efficiencies. The DOE approach currently uses A and 

B loss evaluation factors in their evaluations of what transformer efficiencies 

are justified. The A and B loss evaluation factors could be written into the law 

rather than specifying the transformer efficiencies. The law could require that 

all manufacturers only quote total owning cost optimized designs using these A 

and B factors for all quotations, just as they are now forced to quote target 

efficiencies. The transformer manufacturers would be required to maintain 

files showing they met the law by only quoting designs which were optimized 

using the A and B factors according to the total owning cost method of reducing 

transformer losses. Utility companies have a familiarity with the Total Owning 

Cost approach to transformer purchases because they have routinely used the 

TOC method of obtaining efficient transformer designs since about 1980. 

Regards,

 Jerry Corkran

Staff Engineer
Cooper Power Systems

 

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