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; tb allo@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.pa tterson@us.abb.com; Eric.Petersen@aksteel.com;

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

chuck.simmons@pgnmail.com; mark.stoering@xcelener gy.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.coult er405@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.schneid er-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 reques ted 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 maximi ze d 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 lo cked 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 reques ted areas for the DOE to Investigate before

final rules are selected.



### Being a simple country lawyer, I’m not sure I quite understand the detail s 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 st andard based on calculations performed by

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

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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 reques ted 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 savi ngs and I'm for that. TOC is not "dead".

We recommend to all of our customers t hat we should optimiz e to meet the DOE

threshold efficiency and at the sa me time optimize to get t he lowest TOC that still meets

the DOE threshold. This may change the ra tio 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 th reshold 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 fa ctors 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 probabl y 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 other s. The point I want to make is that we

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

tendency to forget about using the TO C 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 LCc: 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 reques ted 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 bu ying th e 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 mi gh t 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 Ind u stry 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 a pproach tha t 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 reques ted areas for the DOE to Investigate before

final rules are selected.



### To Bruce and All;

Since 1992, when we first fell under the DO E 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 thes e products are well

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

the price of the product plus it's operati ng cost over the lif e 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 appr oach that had worked so well for many

years. Unfortunately, DOE di dn't agree with me. They w ant 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/medi a 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'; Rich ard 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 reques ted 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 197 0’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 th e 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 utili ty 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 wa nt to optimize effici ency 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) an d 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 ev aluation on eve ry transformer manufactured. This

approach would offer a customized approach that ensures true optimization, efficiency and affordabilityof 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. Th is is impractical and im possible 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 reques ted areas for the DOE to Investigate before

final rules are selected.



### Mr. Parker and others,

Below are other thoughts for the gr ound 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 ab le 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 efficien cy standards (e.g., effici ency standards for top

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

are different from side-by-si de refrigerator/freezers).

### -As part of these negotiations, any committee member can suggest sub-groups that can meet “off

line” to provide input to the fu ll 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 reques ted areas for the DOE to Investigate before

final rules are selected.



### Jerry (and larger group),

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

notice on the Ground Rules. The compressed tim e 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 requirement s and resource limitations allow). Most of the

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

discussion about the parts that are not. But gi ven 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 fo r comments on groundrules in your view, with

aim of taking online poll towa rds 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 dead line that results from

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

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

meeting the court deadline unless and until the plaint iffs 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 w ill 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 fo r 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 rule s 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 ad vance of the working group meetings. The

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

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

suitability for me to accept w/o reservatio ns. 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 object ing 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 obj ections 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 de sign information for the least-cost

transformer designs? Suffi cient design information should be included to allow

the transformer manufacturers to compa re 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 efficien cy 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 us ing 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 supp lier of amorphous core steel in the

world that meets the efficiency levels us ed 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 Tr ansformers 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 transfor mer 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 lo st and the dollar cost within the United

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

as compared to using materials a vailable 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 tran sformers 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 Techni cal Document (TSD):Energy Efficiency

Program for Commercial and Industr ial 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 tr ansformer 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 transforme rs evaluated? The DOE is requested

to consult the power companies to lear n 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 effi ciency 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 de signs 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, th e level of loading is based on many

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

recommended to avoid forcing transform er 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 touc h 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 tran sformer 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 effi ciency 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 th e 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 meet ing, 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 evalua tions 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 manufac turers 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 h ave 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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