### CONFIDENTIAL

Distribution Transformers – MIA Interview Guide Page 1 of 41 

# Manufacturer Impact Analysis Interview Guide for

Distribution Transformers

May 20 , 2011

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 2 of 41 Introduction
As part of the rulemaking process for amended energy conservation standards for distribution

transformers , the Department of Energy (DOE) conducts a manufacturer impact analysis (MIA). In this analysis, DOE uses publicly available information and information provided by manufacturers during
interviews to assess possible impacts on manufacturers due to amended energy conservation standards.

This questionnaire is a part of the MIA process and is intended to inform DOE about how changes in the energy conservation standard will affect distribution transformer manufacturers. All information provided in response to this questionnaire will be treated as confidential. In addition to questions about DOE’s test procedure, scope of coverage, market assessment, and engineering analysis, the MIA
questions range from requests about specific financial figures for use in i ndustry modeling to generic
questions intended to solicit qualitative comments. Topics covered will include:

A. Test Procedure

B. Scope of Coverage

C. Market and Technology Assessment

D. Engineering Analysis

E. Market Questionnaire



### F. Manufacturer Impact Analysis

1. Key Issues

2. Company Overview And Organizational Characteristics

3. Markups And Profitability

4. Distribution Channels

5. Shipment Projections and Market Shares

6. Financial Parameters

7. Conversion Costs

8. Cumulative Regulatory Burden

9. Direct Employment Impact Assessment

10. Capacity/Exports / Foreign Competition / Outsourcing

11. Consolidation

12. Impacts on S mall B usiness

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 3 of 41 

## A. TEST PROCEDURE

DOE published its test procedure for distribution transformers in 2006. Since then, manufacturers and
other stakeholders have raised issues on several points in the test procedure.

The test procedure states that the manufacturer must determine the basic model’s efficiency either at the
voltage at which the highest losses occur or at each voltage at which the transformer is rated to operate.

Thi s provision was implemented to address dual

- or multiple

- voltage transformers, which have different losses for each of their winding configurations (in series or in parallel). In the preliminary analysis, DOE proposed allowing compliance testing with the secondary winding in any configuration, but did not propose any changes for the requirements of primary windings. DOE understands that the different primary winding configurations oftentimes exhibit larger differences in efficiency than the efficiency

dif ferences between secondary windings configurations.

A.1 Dual/Multiple

- Voltage Winding Configurations

– Primary Voltages: How does the efficiency vary between series and parallel configurations for transformers with dual/multiple

- voltage
primaries? What proportion of distribution transformers are operated with the primary winding in parallel and for what portion of their lives?

A.2 Other Issues with the Test Procedure: Are there any other issues or concerns with the current test procedure that DOE shoul d be aware of?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 4 of 41 

## B. SCOPE OF COVERAGE

DOE received several comments about the scope of coverage for this rulemaking. The following
questions seek ad ditional information on a few scope related topics.

B.1 5 kVA Single

- Phase Liquid

- Immersed Transformers: Should DOE extend its scope of coverage
for single

- phase liquid

- immersed transformers down to 5 kVA? The current minimum is 10 kVA. Approximately how many annual shipments are there for these transformers? Is the
design for 5 kVA units similar to the design for 10 kVA units?

B.2 Step

- Up Transformers: Should step

- up transformers of comparable kVA sizes to DOE’s
currently covered products be included in the scope of this rulemaking? Do these step

- up transformers use similar design constructions as step

- down covered products? Can they meet

similar effi ciency levels? Would they require comparable cost increases to improve efficiency?
Can they be scaled from the analysis for step

- down transformers?

B.3 Transformers in Renewable Energy Applications: Are distribution transformers that are used in

renew able energy applications different in any way from distribution transformers used in other applications? Are these transformers typically loaded comparably to distribution transformers in
other applications?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 5 of 41 

## C. MARKET AND TECHNOLOGY ASSESSMENT

Symmetric Core Designs: DOE is aware of a design concept for three

- phase transformers that utilizes

120  ̊ symmetry and continuously wound cores. These symmetric core designs, such as the Hexaformer® design created by Hexaformer AB, have several benefits over a traditional transformer design, including: lower losses, lower inrush current, lower weight, and lower external magnetic field. Chalmers University
in Sweden has conducted a study on symmetric core designs and provided an overview of the design and

i nsights into modeling the technology. 1 DOE understands that symmetric core designs represent a
significant shift from current industry practice for manufacturing distribution transformers.

C.1 Symmetric Core Designs
- Applications: Please comment on any expe rience your company has
with symmetric core designs. Would any barriers exist to implementing this type of technology on a large scale? DOE understands that symmetric core designs cannot be used in a wye

- wye connection unless a tertiary winding is added. What applications would not be suitab le for symmetric core designs?

C.2 Symmetric Core Designs

– Performance and Costs: How do labor costs for symmetric core
designs compare to traditional designs? What intellectual property exists for this technol ogy, and what are the typical licensing costs of using patented symmetric core designs? Please provide any data you have available on the performance and cost of these designs compared to
conventional core designs, particularly for the representative unit s of DOE’s analysis.

1 Available online: http://www.hexaformer.com/ExternaDokument/chalmers_report1.pdf

.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 6 of 41 

## D. ENGINEERING ANALYSIS

The purpose of the engineering analysis is to estimate the relationship between the manufacturer’s selling price of a transformer and its corresponding efficiency rating. This relationship serves as the basis for the
subsequent cost

- benefit calculations for individual consumers, manufacturers, and the nation.

The engineering analysis considers design lines of distribution transformers that group together kVA ratings based on similar principles of design and construction. The design lines differentiate the distribution transformers by insulation type (liquid

- immersed or dry

- type), number of phases (single or
three), the primary voltage (low

- voltage or medium

- voltage for dry

- types) and primary insulation levels
(with three different BILs for medium

- voltage dry

- types).

Within each design line, DOE selects one representative unit for study in the enginee ring analysis. DOE then extrapolates the results from these representative units to the other kVA ratings in its engineering
design line. The design lines and representative units currently selected for this engineering analysis are similar to the ones p resented in the preliminary analysis with a few changes and additions.



### 1 L IQUID 

### -I MMERSED 

### E NGINEERING 

### A NALYSIS

Design Lines and Representative Units
The following table represents the five design lines and representative units DOE is considering for
liquid

- immersed distribution transformers, which have not changed from the preliminary analysis

. While DOE did not change the voltages for these representative units, it will conduct a sensitiv ity analysis to examine alternate primary voltage levels.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 7 of 41 Design Lines and Representative Units for Liquid -I mmersed Distribution TransformersDesign Line# of PhasesKVA RangePrimary BIL

Primary Taps, Full
Capacity Representative Unit for Design Lines

1 1 10 -1 67 30

- 150

kV Four 2.5% taps, two

above and two

below nominal 50kVA, 65  ̊C, single

- phase, 60Hz, 14400V primary, 240/120V secondary, 125 kV BIL, rectangular tank

2 1 10

- 167 30

- 150

kV Four 2.5% taps, two

above and two

below nominal 25kVA, 65  ̊C, single

- phase, 60Hz, 14400V primary, 120/240V secondary, 125 kV BIL,

round tank

3 1 250

- 833 30

- 150

kV Four 2.5% taps, two

above and two

below nominal 500kVA, 65  ̊C, single

- phase, 60Hz, 14400V primary, 277V secondary, 150 kV BIL

4 3 15

- 500 30

- 150

kV Four 2.5% taps, two

above and two

below nominal 150kVA, 65  ̊C, three

- phase, 60Hz, 12470Y/7200V primary, 208Y/120V
secondary, 95 kV BIL

5 3 750

- 2500 95

- 150

kV Four 2.5% taps, two

above and two

below nominal 1500kVA, 65  ̊C, three

- phase, 60Hz,

24940GrdY/14400V primary, 408Y/277V secondary, 125 kV BIL

D.1.1 Liquid

- Immersed Design Lines: Please comment on the appropriateness of the design lines and
representative units chosen for the liquid

- immersed distribution transformers. Should any other representative units be selected , and why ? Would these other representative units experience different incremental costs for increasing efficiency as compared to the current rep units?

D.1.2 Dimension and Weight Constraints: For each of the representative units, are there any weight constraints or dimensional constraints for customer applications that DOE should be aware of? If so, please specify the maximum weight and/or dimensions that are feasible.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 8 of 41 Design Option Comb inations For each representative unit, DOE is considering several design option combinations that characterize a
range of efficiency levels for distribution transformers. This range spans from the efficiency level requirements set forth in DOE’s 2007 final rule to the maximum technologically available level (“max tech”). Within this range, DOE considers several discrete candidate standard levels (CSLs) for setting the efficiency standard. The following tables present the CSL efficiency level and request feedback on the
design options available to reach that efficiency level, the manufacturer’s production cost (MPC) of the

lowest first

- cost design at that level, and the manufacturer’s selling price (MSP) for that design. The MPC

consists of all direct and indirect production costs, and the MSP includes the MPC plus non

- production costs (e.g., SG&A, R&D, profit factor, etc.).

Design Line 1

( 50kVA, 65  ̊ C, single

- phase, 60 Hz, 14400V primary, 240/120V secondary, 125 kV BIL, rectangular tank )

CSL Efficie ncy Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]
Example:

99.27 ≥ M3 (conventional core); ≥M5 (symmetric core); Al and Cu. 1,840 2,300

0 99.08

1 99.17

2 99.27

3 99.36

4 99.46

5 99.55

6 99.60

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 9 of 41 Design Line 2

(25kVA, 65  ̊ C, single

- phase, 60 Hz, 14400V primary, 120/240V secondary, 125 kV BIL, round tank)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 98.91

1 99.02

2 99.13

3 99.24

4 99.35

5 99.46

Design Line 3

( 500kVA, 65  ̊C, single

- phase, 60Hz, 14400V primary, 277V secondary, 150 kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 99.42

1 99.48

2 99.54

3 99.57

4 99.61

5 99.67

6 99.73

7 99.76

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 10 of 41 Design Line 4

(150kVA, 65  ̊ C, three

- phase, 60 Hz, 12470Y/7200V primary, 208Y/120V secondary, 95kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 99.08

1 99.17

2 99.27

3 99.36

4 99.46

5 99.55

6 99.60

Design Line 5

( 1500kVA, 65  ̊ C, three

- phase, 60 Hz, 24940GrdY/14400V primary, 480Y/277V secondary, 125 kV BIL )

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 99.42

1 99.48

2 99.54

3 99.57

4 99.61

5 99.67

6 99.73

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 11 of 41 D.1.3 Amorphous Cores in Large kVA Designs: DOE understands that amorphous cores in large distribution transformers (1500 kVA and greater) require additional labor and hardware costs
above and beyond the requirements for other core steels in these designs. The labor accounts for extra handling required for these large, fragile designs, and the hardware costs account for
additional bracing to prevent short circuit problems. Please comment on how these costs compare between amorphous designs and other designs using the table below.

Direct Labor and Bracing Costs f or Design Line 5

( 1500kVA, 65  ̊ C, three

- phase, 60 Hz, 24940GrdY/14400V primary, 408Y/277V secondary, 125 kV BIL )

Core Steel Direct Labor for
Typical Design

[ hours ] Bracing Costs for
Typical Design

[ $ ] Comments

M4

M3

M2

ZDMH
SA1 (Amorphous)

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 12 of 41 

### 2 L OW 

### -V OLTAGE 

### D RY 

### -T YPE 

### E NGINEERING 

### A NALYSIS

Design Lines and Representative Units
The following table represents the three design lines and representative units DOE is considering for low

voltage dry

- type distribution transformers , which have not changed from the preliminary analysis

.

Design Lines and Representative Units for Low

- Voltage Dry

- Type Distribution T ransformersDesign Line# of PhasesKVA RangePrimary BIL Primary Taps, Full
Capacity Representative Unit for Design Lines

6 1 15

- 333 10 kV Universal* 25kVA, 150  ̊C, single

- phase, 60Hz, 480V primary, 120Y/240V secondary, 10kV BIL

7 3 15

- 150 10 kV Universal* 75kVA, 150  ̊C, three

- phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL

8 3 225

- 1000 10 kV Universal* 300kVA, 150  ̊C, three

- phase, 60Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL
* Universal Taps = 2 above and 4 below 2.5%

D.2.1 Low

- Voltage Dry

- Type Design Lines: Please comment on the appropriateness of the design lines
and representative units chosen for the low

- voltage dry

- type distribution transformers. Should any other representative units be selected, and why? Would these other representative units
experien ce different incremental costs for increasing efficiency as compared to the current rep

units?

D.2.2 Dimension and Weight Constraints: For each of the representative units, are there any weight
constraints or dimensional constraints for customer applications that DOE should be aware of? If so, please specify the maximum weight and/or dimensions that are feasible.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 13 of 41 Design Option Comb inations For each representative unit, DOE is considering several design option combinations that characterize a
range of efficiency levels for distribution transformers. This range spans from the efficiency level requirements set forth in the Energy Poli cy Act of 2005 to the maximum technologically available level
(“max tech”). Within this range, DOE considers several discrete candidate standard levels (CSLs) for setting the efficiency standard. The following tables present the CSL efficiency level and request feedback on the design options available to reach that efficiency level, the manufacturer’s production cost
(MPC) of the lowest first

- cost design at that level, and the manufacturer’s selling price (MSP) for that design. The MPC consists of all di rect and indirect production costs, and the MSP includes the MPC plus

non

- production costs (e.g., SG&A, R&D, profit factor, etc.).

Design Line 6

(25kVA, 150  ̊ C, single

- phase, 60 Hz, 480V primary, 120/240V secondary, 10 kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]
Example:

98.23 ≥M6 (conventional core); ≥M12
(symmetric core); butt

- lap or miter 1,600 2,000

0 98.00

1 98.23

2 98.47

3 98.60

4 98.70

5 98.93

6 99.17

7 99.40

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 14 of 41 Design Line 7

(75kVA, 150  ̊C, three

- phase, 60Hz, 480V primary, 208Y/120V secondary, 10kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 98.00

1 98.23

2 98.47

3 98.60

4 98.70

5 98.93

6 99.17

7 99.40

Design Line 8

( 300kVA, 150  ̊C, three

- phase, 60Hz, 480V Delta primary, 208Y/120V secondary, 10kV BIL )

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 98.60

1 98.80

2 99.02

3 99.19

4 99.41

5 99.59

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 15 of 41 

### 3 M EDIUM 

### -V OLTAGE 

### D RY 

### -T YPE 

### E NGINEERING 

### A NALYSIS

Design Lines and Representative Units
The following table represents the six design lines and representative units DOE is considering for

medium

- voltage dry

- type distribution transformers. DOE is considering an additional sixth design line for lower kVA ratings in the highest insulation class

. To do this, DOE split its existing design line 13 into
two design lines, 13A and 13B, where 13A considers kVA ratings between 15 and 500, and 13B considers kVA ratings between 750 and 2500. The representative unit from 13B is similar to the one examine d during the preliminary analysis, but DOE changed its primary voltage. The remaining design lines 9
through 12 have not changed.

Design Lines and Representative Units for Medium

- Voltage Dry

- Type Distribution T ransformersDesign Line# of PhasesKVA RangePrimary BIL

Primary Taps, Full
Capacity Representative Unit for Design Lines

9 3 15

- 500 20

- 45 kV Four 2.5% taps, two

above and two

below nominal 300kVA, 150  ̊C, three

- phase, 60Hz, 4160V Delta primary, 480Y/277V
secondary, 45kV BIL

10 3 750

- 2500 20

- 45 kV Four 2.5% taps, two

above and two

below nominal 1500kVA, 150  ̊C, three

- phase, 60Hz, 4160V primary, 480Y/277V secondary,

45kV BIL

11 3 15

- 500 46

- 95 kV Four 2.5% taps, two

above and two

below nominal 300kVA, 150  ̊C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary,

95kV BIL

12 3 750

- 2500 46

- 95 kV Four 2.5% taps, two

above and two

below nominal 1500kVA, 150  ̊C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary,

95kV BIL

13A 3 15

- 500 96

- 150

kV Four 2.5% taps, two

above and two

below nominal 3 00kVA, 150  ̊C, three

- phase, 60Hz,

24940 V primary, 480Y/277V secondary,

12 5kV BIL

13 B 3 750

- 2500 96

- 150

kV Four 2.5% taps, two

above and two

below nominal 2000kVA, 150  ̊C, three

- phase, 60Hz,

24940 V primary, 480Y/277V secondary,

125kV BIL

D.3.1 Medium

- Voltage Dry

- Type Design Lines: Please comment on the appropriateness of the design
lines and representative units chosen for the medium

- voltage dry

- type distribution transformers. Should any other representative units be selected, and why? Would these other representative units experience different incremental costs for increasing efficiency as compared to the current
rep units?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 16 of 41 D.3.2 Dimension and Weight Constraints: For each of the representative units, are there any weight

constraints or dimensional constr aints for customer applications that DOE should be aware of? If so, please specify the maximum weight and/or dimensions that are feasible.

Design Option Combinations
For each representative unit, DOE is considering several design option combinations that characterize a range of efficiency levels for distribution transformers. This range spans from the efficiency level
requirements set forth in DOE’s 2007 final rule to the maximum technologically available level (“max
tech”) . Within this range, DOE c onsiders several discrete candidate standard levels (CSLs) for setting the
efficiency standard. The following tables present the CSL efficiency level and request feedback on the design options available to reach that efficiency level, the manufacturer’s p roduction cost (MPC) of the

lowest first

- cost design at that level, and the manufacturer’s selling price (MSP) for that design. The MPC consists of all direct and indirect production costs, and the MSP includes the MPC plus non

- production costs (e.g., SG&A, R&D, profit factor, etc.).

Design Line 9

(300kVA, 150  ̊C, three

- phase, 60Hz, 4160V Delta primary, 480Y/277V secondary, 45kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]
Example:

99.12 ≥M3 (conventional core) miter only; ≥M5 (symmetric core); Al or Cu 6,560 8,200

0 98.82

1 98.97

2 99.12

3 99.28

4 99.43

5 99.58

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 17 of 41 Design Line 10

(1500kVA, 150  ̊C, three

- phase, 60Hz, 4160V primary, 480Y/277V secondary, 45kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 99.22

1 99.31

2 99.40

3 99.50

4 99.59

5 99.68

Design Line 11

(300kVA, 150  ̊C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 98.67

1 98.84

2 99.00

3 99.17

4 99.33

5 99.50

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 18 of 41 Design Line 12

(1500kVA, 150  ̊C, three

- phase, 60Hz, 12470V primary, 480Y/277V secondary, 95kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 99.12

1 99.21

2 99.30

3 99.39

4 99.48

5 99.57

6 99.66

Design Line 13 A

( 300 kVA, 150  ̊C, three

- phase, 60Hz, 24940 V primary, 480Y/277V secondary, 125kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 98. 63

1 98. 80

2 98. 96

3 99.13

4 99.29

5 99.45

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 19 of 41 Design Line 13 B
(2000kVA, 150  ̊C, three

- phase, 60Hz, 24940 V primary, 480Y/277V secondary, 125kV BIL)

CSL Efficiency

Level [ % ] Design Options Available MPC of lowest

first

- cost design [ $ ] MSP of lowest

first

- cost design [ $ ]

0 99.15

1 99.25

2 99.35

3 99.46

4 99.56

5 99.66

D.3.3 Amorphous Cores in Large kVA Designs: DOE understands that amorphous cores in large
distribution transformers (1500 kVA and greater) require additional labor and hardware costs above and beyond the requirements for other core steels in these designs. The labor accounts for
extra handling required for these large, fragile designs, and the hardware costs account for additional bracing to prevent short circuit problems. Please comment on how these costs compare between amorphous designs and other designs using the table below.

Direct Labor and Bracing Costs for Design Line 12

(1500kVa, 150  ̊ C, three

- phase, 60 Hz, 12470V primary, 480Y/277V secondary, 95kV BIL)

Core Steel Direct Labor for
Typical Design

[ hours ] Bracing Costs for
Typical Design

[ $ ] Comments

M6

M5

M4

M3

H- 0 DR
SA1 (Amorphous)

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 20 of 41 

### 4 M ATERIALS 

### P RICES


### , M ARKUPS


### , AND 

### L ABOR 

### R ATES

Materials Prices
DOE gathers materials price data for the five years between 2006 and 2010, and plans to use the 2010
materials prices for the reference case of its analysis.

D.4.1 Copper and Aluminum Indices: DOE is considering setting its copper and aluminum materials
prices based on the commodity’s index price plus a processing cost markup. DOE would consider the current (2011) index value and scale it back through 2006 using the producer price

inde x. DOE would then apply a processing cost to the commodity price that varies for each of DOE’s groupings (e.g., wire vs. strip, different gauges, etc.). Please comment on DOE’s proposed methodology for deriving copper and aluminum prices.

D.4.2 Copper and Aluminum Processing Costs: To account for the processing costs of converting
copper and aluminum into wire and strip, is it appropriate to apply a markup to the underlying commodity price, or a straight adder? In the table below, please indicate the appropriate markup or price adder for each of the types of copper and aluminum.

Processing Costs for Copper and Aluminum

Material Processing Cost
Markup [ % ]

or Adder [ $ ] Comments

Copper wire, formvar, round #10

- 20
Copper wire, enameled, round #7

- 10 flattened
Copper wire, enameled, rectangular sizes
Copper wire, rectangular 0.1 x 0.2, Nomex wrapped

Aluminum wire, formvar, round #9

- 17

Aluminum wire, formvar, round #7

- 10
Aluminum wire, rectangular 0.1 x 0.2, Nomex wrapped

Aluminum wire, rectangular #<7
Copper strip, thickness range 0.02

- 0.045
Copper strip, thickness range 0.030

- 0.060
Aluminum strip, thickness range 0.02

- 0.045
Aluminum strip, thickness range 0.045

- 0.080

D.4.3 Materials Prices: The following table contains DOE’s estimates for material prices for distribution
transformers in each of the past five years. The prices listed do not include any markups for scrap, handling, factory overhead, non

- production costs, or profit, but rather represent the price a manufacturer would pay for the material, including any bulk purchase discounts. All prices are listed in historic dollars (e.g., $2007 for year 2007). Does your company pay a similar price for
these materials? If not, what price d oes your company pay?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 21 of 41 Materials Prices for Distribution Transformers

Material Units 2010 2009 2008 2007 2006 Comments

M36 core steel (26 gauge) $/lb 0.6 6 0.6 6 0.6 6 0.8 0 0. 57
M19 core steel (26 gauge) $/lb 0.9 1 0.8 1 0.9 4 0.9 1 0.7 0

M12 core steel $/lb 1.0 3 1. 08 1. 25 1. 19 1. 05

M6 core steel $/lb 1. 46 1. 62 1. 72 1. 52 1. 18

M5 core steel $/lb 1.5 1 1. 65 1. 76 1. 55 1. 23

M4 core steel $/lb 1. 59 1.69 1.80 1.58 1.29

M3 core steel $/lb 1.88 1.95 2.05 1.64 1.32

M2 core steel $/lb 2.00 1.99 2.19 2.09 1.64

H- O DR core steel (laser scribed) $/lb 2.06 2.36 2.54 2.18 1.76
ZDMH (mechanically

- scribed
core steel) $/lb 2.05 2.01 2.53 2.20 1.75

SA1 (amorphous) finished core, volume production $/lb 2.38 2.27 2.86

Copper wire, formvar, round

#10

- 20 $/lb 4.45 3.97 4.44 4.50 4.21

Copper wire, enameled, round

#7

- 10 flattened $/lb 4.85 4.37 4.84 4.90 4.61

Copper wire, enameled, rectangular sizes $/lb 4.81 4.33 4.80 4.86 4.57

Copper wire, rectangular 0.1 x
0.2, Nomex wrapped $/lb 4.95 4.47 4.94 5.00 4.71

Aluminum wire, formvar, round

#9

- 17 $/lb 2.47 2.40 2.53 2.48 2.47

Aluminum wire, formvar, round

#7

- 10 $/lb 2.17 2.10 2.23 2.18 2.17

Aluminum wire, rectangular 0.1 x 0.2, Nomex wrapped $/lb 1.68 1.61 1.74 1.69 1.68

Aluminum wire, rectangular #<7 $/lb 2.04 1.97 2.10 2.05 2.04
Copper strip, thickness range

0.02

- 0.045 $/lb 5.15 4.67 5.14 5.20 4.91

Copper strip, thickness range

0.030

- 0.060 $/lb 5.05 4.57 5.04 5.10 4.81

Aluminum strip, thickness range

0.02

- 0.045 $/lb 2.07 2.00 2.13 2.08 2.07

Aluminum strip, thickness range

0.045

- 0.080 $/lb 2.08 2.01 2.14 2.09 2.08

Kraft insulating paper with

diamond adhesive $/lb 1.52 1.53 1.52 1.50 1.46

Nomex insulation $/lb 24.50 24.50 22.80 19.89 17.07
Cequin insulation $/lb 5.53 5.07 4.78 4.93 4.78

Mineral oil $/gal 3.35 2.87 3.02 2.42 2.42
Impregnation $/gal 22.55 22.50 21.45 21.35 21.35
Winding combs $/lb 12.34 12.58 12.10 11.52 7.56

Tank/Enclosure Steel $/lb 0. 38 0.38 0.47 0.41 0.40

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 22 of 41 Markups
DOE applies markups to all costs to reflect a manufacturer’s internal markups. This interview guide does
not go into detail on all the markups, but further inf ormation can be found online. 2

DOE defines factory overhead as the indirect costs associated with production, indirect material s and energy use (e.g., annealing furnace), taxes, and insurance. In the preliminary analysis, DOE estimated this cost based on a markup applied to direct material production costs. However, DOE received

comments stating that factory overhead should be d erived from labor costs or based on a fixed amount per design option.

D.4.4 Factory Overhead: How can DOE best characterize factory overhead costs? If DOE should apply
a markup to labor costs, what markup is appropriate, and should it be applied to labor hours or labor cost? If DOE should account for a fixed overhead amount for each design option, what overhead amounts are appropriate for the design options considered by DOE for each of the representative units? Does factory overhead change with kVA size?

2 Preliminary Analysis: Chapter 5

– Engineering Analysis (pp. 39

- 41). Available here: http://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/transformer_preanalysis_ch5.pdf

.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 23 of 41 

### 5 S CALING 

### R ESULTS

DOE scales its analysis on the representative units to the other kVA ratings that are not directly analyzed. In the preliminary analysis, DOE relied on the 0.75 scaling rule to scale efficiency and cost. DOE received

comments that the 0.75 scaling rule may not provide accurate results beyond more than a few standard kVA ratings from the reference rating.

D.5.1 The 0.75 Scaling Rule: How accurate is the 0.75 scaling rule when scaling efficiency ? When
scaling cost? For DOE’s specific design lines and representative units, which kVA ratings would vary the most between the scaled cost/efficiency and the actual cost/efficiency?

D.5.2 Efficiency Adjustment Factor: If the 0.75 scaling rule is not accurate for wider kVA ranges,
would it be feasible for DOE to incrementally adjust efficiency standards for certain scaled kVA ratings within a design line? If so, please comment on which kVA ratings would require the
adjustment, what the adjustment should be, and any data used to support the adjustment.

DOE has heard that the 0.75 scaling rule is generally more accurate for scaling efficiency, but that it may understate the scaled cost of designs at lower kVA ratings due to certain fixed costs that do not scale

accord ing to the 0.75 rule. These costs could include tank/enclosure costs and other fixed hardware.

D.5.3 Scaling and Incremental Cost Impacts : Incremental efficiency improvements are typically
determined by the core and coil specifications, which scale accurately using the 0.75 scaling rule. Even if the total cost of the transformer does not scale accurately using the 0.75 scaling rule due to fixed costs, wouldn’t the incremental cost for improving efficiency still be accurately represented by the 0.75 scaling rul e? Why, or why not?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 24 of 41 

## E. MARKET QUESTIONNAIRE

E.1 Customer purchase evaluation rates: What is the percentage of customers that specify A and B
parameters when purchasing distribution transformers?

Customer Purchase Evaluation Rates for Distribution Transformers

Current DOE estimate of
purchasers who specify A and B

parameters % of purchasers who specify A
and B parameters

Liquid -I mmersed 75%

Low

- Voltage Dry -T ype 10%

Medium -C apacity Dry -T ype 50%
High -C apacity Dry -T ype 80%

E.2 Refurbished Transformers: Does your company refurbish distribution transformers? What
portion of the distribution transformer market are refurbished transformers? W hat factors would affect customer decisions to buy new vs. refurbish? How is this expected to change if efficiency

standards are increased?

E.3 Transformers with Forced Cooling: What percentage of distribution transformers use forced
cooling? Of the transformers with forced cooling, what percentage of the time are they operating using forced cooling rather than natural cooling?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 25 of 41 

## F. MANUFACTURER IMPACT ANALYSIS

The Manufacturer Impact Analysis (MIA) identifies and quantifies the likely impacts of amended energy

conservation standards on manufacturers. This section of the interview guide references the equipment
class groupings and design lines presented previously and repeated below

.

Design Lines and Equipment Class Groupings for Distribution Transformers

Design Line Equipment Class
Grouping* Type of Distribution Transformer kVA Range

1

1 Liquid

- immersed, single

- phase, rectangular tank 10

– 167

2 Liquid

- immersed, single

- phase, round tank 10

– 167

3 Liquid

- immersed, single

- phase, round tank 250

– 833

4 2 Liquid

- immersed, three

- phase 15

– 500

5 Liquid

- immersed, three

- phase 750

– 2500

6 3 Dry

- type, low

- voltage, single

- phase 15

– 333

7 4 Dry

- type, low

- voltage, three

- phase 15

– 150

8 Dry

- type, low

- voltage, three

- phase 225

– 1000

9 6 Dry

- type, medium

- voltage, three

- phase, 20

- 45kV BIL 15

– 500

10 Dry

- type, medium

- voltage, three

- phase, 20

- 45kV BIL 750

– 2500

11 8 Dry

- type, medium

- voltage, three

- phase, 46

- 95kV BIL 15

– 500

12 Dry

- type, medium

- voltage, three

- phase, 46

- 95kV BIL 750

– 2500

13A 10 Dry

- type, medium

- voltage, three

- phase, 96

- 150kV BIL 15

- 500

13 B Dry

- type, medium

- voltage, three

- phase, 96

- 150kV BIL 750

– 2500

* DOE did not select any representative units from the single

- phase, m edium

- voltage equipment classes , but calculated the analytical results for them based on the results for their three

- phase counterparts.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 26 of 41 

### 1 K EY 

### I SSUES

DOE is interested in understanding the impact of amended energy conservation standards on
manufacturers. This section provides an opportunity for manufacturers to identify high priority issues that DOE should take into consideration when conducting the MI A

.

F.1.1 In general, what are the key concerns for your company regarding th is distribution transformer rulemaking?

F.1.2 How would amended energy conservation standards affect your ability to compete in the marketplace?

F.1.3 The limited availability of certain core steels may pose an issue at higher efficiency levels. For each type of core steel in the table below , ple ase indicate the names of suppliers that produce it, the
estimated total global supply of it, barriers in the marketplace for obtaining it , and any other comments that you would like to make.

### CONFIDENTIAL

Distribution Transformers – MIA Interview Guide Page 27 of 41 Core Steel Availability

Core Steel
Type Names of Suppliers Est. Total Global Supply Barriers to Availability Other Comments

M4

M3

M2

ZDMH

H- 0 DR

SA1 Amorphous

Other :

### CONFIDENTIAL

Distribution Transformers – MIA Interview Guide Page 28 of 41 

### 2 C OMPANY 

### O VERVIEW 

### A ND 

### O RGANIZATIONAL 

### C HARACTERISTICS

Understanding how the manufacture of distribution transformers fits within your larger organization will help DOE better estimate the probable impacts of an amended energy conservation standard.

F.2.1 Do you have a parent company and/or subsidiary? If so, please provide their names.

F.2.2 What is your company’s approximate market share of the distribution transformer market for: (1) liquid

- immersed, (2) low

- voltage dry

- type, and (3) medium

- voltage dry

- type ? Does this vary significantly for any particular design line that you manufacture?

F.2.3 What are your product line niches and relative strengths in the distribution transformer market ?

F.2.4 Do you manufacture any products other than distribution transformers? If so, what other products do you manufacture? Do you manufacture them in the same facilities as your
distribution transformers? What percentage of your overall revenue is from distribution

transformer sales?

### CONFIDENTIAL

Distribution Transformers – MIA Interview Guide Page 29 of 41 F.2.5 Where are your production facilities located, and what type of product is manufactured at each location? Please provide production figures for your company’s manufacturing at each location by design line or equipment class grouping

.

Manufacturing L ocations

Location Design Line (DL) or Equipment Class Grouping (ECG) Employees

(Production) Employees

(Non

- production) Units/Yr

Produced

Example : Jackson, TN ECG #1. Liquid

- immersed, medium

- voltage, single

- phase 75 25 68 0 ,000

F.2.6 Are higher efficiency product s built at different plants than lower efficie ncy products of the same design line ?

F.2.7 Would you expect your market share to change once amended energy conservation standards become effective?

### CONFIDENTIAL

Distribution Transformers – MIA Interview Guide Page 30 of 41 

### 3 M ARKUPS 

### A ND 

### P ROFITABILITY

In this section, DOE would like to understand the current markup structure of the industry and how
setting an amended energy conservation standard would impact your company’s markup structure and profitability.

T he manufacturer markup is a multiplier applied to manufacturer production cost to cover per unit research and development, selling, general, and administrative expense s , and profit. It is NOT a profit
margin. The manufacture r production cost multiplied by the manufacturer markup plus the shipping

costs cover s all costs involved in manufacturing and profit for the product

.

F.3.1 DOE calculated a markup of 1.25 for distribution transformers. How does this figure compare to
your company’s baseline markups? Do the markups vary by design line?

F.3.2 Within each design line , do the per

- unit mark

- ups vary by design options ? Alternatively, does efficiency affect the markup on a product?

F.3.3 What other factors affect mark

- ups in the same design line ?

F.3.4 Would you expect amended energy conservation standard s to affect your profitability ? If so,
please explain why

.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 31 of 41 

### 4 D ISTRIBUTION 

### C HANNELS

F.4.1 Delivery Channels for Liquid

- Immersed Transformers: What percentage of liquid

- immersed
distribution transformers is sold directly to utilities? What percentage of liquid

- immersed transformers is sold to a utility through an independent manufacturer distributor? For each of
these delivery channels what is the percentage increase in manufacturer sale price (markup factor) that will be realized in the final retail price?

Distribution Channels for Liquid

- Immersed Transformers

F.4.2 Delivery Channels for Dry

- Type Transformers: What percentage of dry

- type transformers is
sold directly to electrical contractors? What percentage of dry

- type transformers is sold directly

to multi

- site commercial/industrial customers (also known as “national accounts”)? For each of these delivery channels what is the percentage increase in manufacturer sale price (markup
factor) that will be realized in final retail price?

Distribution Channels Dry

- Type Transformers

Channel % of Units Sold Markup Factor
Sold directly to utilities
Sold through a distributer
Other, please describe:

Channel % of Units Sold Markup Factor
Sold directly to electrical contractors
Sold directly to “national accounts”

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 32 of 41 

### 5 S HIPMENT 

### P ROJECTIONS AND 

### M ARKET 

### S HARES

An amended energy conservation standard can change overall shipments by altering product attributes, marketing approaches, product availability, and price. DOE’s shipments model includes forecasts for the

base case shipments ( i.e., total industry shipments absent amended energy conser vation standards) and

the standards case shipments (i.e., total industry shipments with amended energy conservation
standards)

.

To determine efficiency distributions after the compliance date of the standard, DOE modeled a shift

scenario, in which products that exceed the new standard level in the base case shift to even higher

efficiencies in the standards case to maintain their relative efficiency premium

.

F.5.1 How do you think amended energy conservation standards will impact the sales of more effici ent products? For example, would customers continue to buy products that exceed the energy
conservation standard level? Would your response change for higher mandated efficiency levels?

F.5.2 How sensitive do you think shipments will be to price changes? Will it vary with equipment class
grouping or design line ?

F.5.3 Would you expect your market share to change when higher energy conservation standards take

effect?

F.5.4 What percent of your transformer shipments come from distribution transformers?

F.5.5 To your knowledge, are there any niche manufacturers or component manufacturers for which the adoption of amended energy conservation standard would have a particularly severe impact? If so, why?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 33 of 41 

### 6 F INANCIAL 

### P ARAMETERS

Navigant Consulting, Inc. (NCI) has developed a “strawman” model of financial performance called the Government Regulatory Impact Model (GRIM) using publicly available data. This section attempts to
understand how your company’s financial situation differs from our industry aggregate picture

.

Please compare your company’s distribution transformer financial parameters to the GRIM parameters

tabulated below.

Financial Parameters for Distribution Transformer Manufacturers

GRIM Input Definition Industry

Estimated

Value Your Actual

( I f S ignificantly

D ifferent from

DOE’s

E stimate )

Income Tax

Rate Corporate effective income tax paid (percentage of earnings before taxes, EBT) 23%

Discount Rate Weighted average cost of capital (inflation

adjusted weighted average of corporate cost

of debt and return on equity) 9%

Working
Capital Current assets less current liabilities
(percentage of revenues) 16%

SG&A Selling, general, and administrative expenses
(percentage of revenues) 16%

R&D Research and development expenses
(percentage of revenues) 3%

Depreciation Amortization of fixed assets (percentage of

revenues) 3%

Capital Expenditures Outlay of cash to acquire or improve capital
assets (percentage of revenues, not including acquisition or sale of business units) 3%

Cost of Goods

Sold Includes material, labor, overhead, and depreciation (percentage of revenues) 71%

F.6.1 Are the figure s in the table above representative of the distribution transformer industry as a whole? If not, why?

F.6.2 Do any of the financial parameters in the table above change for a particular subgroup of
manufacturers? Please describe any differences.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 34 of 41 

### 7 C ONVERSION 

### C OSTS

A n increase in energy conservation standards may cause the industry to incur capital and product

conversion costs to meet the amended ene rgy conservation standard. The MIA considers three types of conversion expenditures:

**•** Capital conversion costs

-- O ne

- time investments in plant, property, and equipment (PPE) necessitated by an amended energy conservation standard. These may be incremental changes to existing PPE or the replacement of existing PPE. Included are expenditures on buildings, equipment, and tooling.

**•** P roduct conversion costs

– One

- time investments in research, product development, testing, marketing and o ther costs for redesigning products necessitated by a n amended energy

conservation standard.

**•** Stranded assets

-- Assets replaced before the end of their useful lives as a direct result of the change in energy conservation standard

.

With a detailed unders tanding of the conversion costs necessi tated by different standard levels, DOE can
better model the impact on the distribution transformer industry resulting from amendments to the

conservation standard s

.

F.7.1 At your manufacturing facilities, would amended energy conservation standards be difficult to implement? If so, would your company modify existing facilities or develop new facilities?

F.7.2 Are there certain design options that would require relatively minor changes to existing products? Are there certain design options where the capital or product conversion costs significantly increase? Please describe these changes qualitatively.

F.7.3 Wh at conversion costs do you anticipate incurring with each design option ? In the sections
below, please indicate any significant capital and product conversion costs associated with the core steel options, core configuration options, and core type options listed. These design options
are presented separately for liquid immersed, low

- voltage dry

- type, and medium

- voltage dry

type distribution transformers.

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 35 of 41 Design Options Considered for Liquid Immersed Transformers (Design Lines 1

- 5)

Core Steel Options: Core Configuration Options: Core Type Options:

M5 Distributed Gap Wound Core Shell

M4 Symmetric Core Core

M3 3- Leg

M2 5- Leg

ZDMH

SA1 Amorphous

Capital Conversion Costs:

Product Conversion Costs:

Stranded Assets :

Design Options for Low

- Voltage Dry

- Type Transformers (Design Lines 6

- 8)

Core Steel Options: Core Configuration Options: Core Type Options:

M12 Stacked Butt -L ap Shell

M6 Stacked Full Miter Core

M5 Stacked Step

- Lap Miter 3- Leg

M4 Distributed Gap Wound Core 5- Leg

M3 Symmetric Core

M2 (wound cores)

ZDMH (wound cores)

H0

- DR

SA1 Amorphous

Capital Conversion Costs:

Product Conversion Costs:

Stranded Assets :

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 36 of 41 Design Options for Medium

- Voltage Dry

- Type Transformers (Design Lines 9

- 13 )

Core Steel Options: Core Configuration Options: Core Type Options:

M6 Stacked Full Miter Shell

M5 Stacked Step

- Lap Miter Core

M4 Mitered Cruciform 3- Leg

M3 Distributed Gap Wound Core 5- Leg

M2 (wound cores) Symmetric Core

ZDMH (wound cores)

H0

- DR

SA1 Amorphous

Capital Conversion Costs:

Product Conversion Costs:

Stranded Assets :

F.7.4 For any design options that would require new production equipment, please describe how
much downtime would be required. What impact would downtime have on your business?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 37 of 41 

### 8 C UMULATIVE 

### R EGULATORY 

### B URDEN

Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of new or revised DOE standards, and/or other regulatory actions affecting the same product or industry.

F.8.1 Are there other recent or impending standards that distribution transformer manufacturers face

from DOE , other U .S. federal agencies, State regulators, foreign government agencies, or other standard setting bodies ? If so, please identify the regulation and the corresponding possible

effect ive dates for those regulations

. Below is a preliminary list of regulations that could possibly

affect manufacturers of distribution transformers

. Please provide comments on the listed
regulations

.

Other Regulations Identified by DOE

Regulation Compliance Date (s) Expected Expenses / Comments
EPACT 2005 minimum efficiency

levels for low

- voltage dry

- type

distribution transformers January 1, 2007

DOE’s 2007 Energy Conservation
Standards Rulemaking for

Distribution Transformers January 1, 2010

F.8.2 Are there any additional regulatory burdens that DOE should take into consideration? If so, please identify the regulation, the corresponding effective dates, and your expected compliance

cost.

F.8.3 Under what circumstances would you be able to coordinate expenditures related to these other
regulations with an amended energy conservation standard, thereby lessening the cumulative

burden?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 38 of 41 

### 9 D IRECT 

### E MPLOYMENT 

### I MPACT 

### A SSESSMENT

The impact of amended energy conservation standards on employment is an important consideration in
the rulemaking process. This section of the interview guide seeks to explore current trends in transformer production employment and solicit manufacturer views on how domestic employment patterns might be affected by amended energy conservation standards.

F.9.1 Would your domestic emp loyment levels be expected to change significantly under amended energy conservation standards? If so, please identify particular standard levels which may trigger changes in employment.

F.9.2 Would the workforce skills necessary under amended energy conservation standards require
extensive retraining or replacement of employees at your manufacturing facilities?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 39 of 41 

### 10 C APACITY 

### /E XPORTS 

### / F OREIGN 

### C OMPETITION 

### / O UTSOURCING

Disparity between domestic and foreign energy conservation standards could impact exports or imports.

Labor con tent and material changes resulting from amended energy conservation standards may impact sourcing decisions.

F.10.1 How would amended energy conservation standards impact your company’s manufacturing
capacity

, in either the short term or the long term ?

F.10.2 Absent amended energy conservation standards, are production facilities being relocated to foreign countries?

F.10.3 Would amended energy conservation standards impact your domestic vs. foreign manufacturing

decision?

F.10.4 What percentage of your U.S. production of distribution transformers is exported?

F.10.5 What percentage of the U.S. market for distribution transfor mers is imported ? Would amended
energy conservation standards have an impact on foreign competition?

F.10.6 Are there any foreign companies with North American production facilities?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 40 of 41 

### 11 C ONSOLIDATION

Amended energy conservation standards can alter the competitive dynamics of the market. This can include prompting companies to enter or exit the market, or to merge. DOE and the Department of Justice
are both interested in any potential reduction in competition that would result from an amended energy

cons ervation standard.

F.11.1 Please comment on industry consolidation an d related trends over the last 10 years.

F.11.2 In the absence of amended energy conservation standards, do you expect any further industry

consolidation? Please describe your expectations.

F.11.3 How would industry competition change as a result of amended energy conservation standards?

F.11.4 To your knowledge, are there any niche manufacturers for which the adoption of amended energy conservation standards would have a particularly severe impact?

### CONFIDENTIAL

Distribution Transformers

– MIA Interview Guide Page 41 of 41 

### 12 I MPACTS 

### O N 

### S MALL 

### B USINESS

F.12.1 The Small Business Association (SBA) denotes a small business in the distribution transformer
industry as having less than 750 employees

. 3 By this definition, is your company considered a

small business?

F.12.2 Below is a list of small business distribution transformer manufacturers compiled by DOE. Are there any small manufacturers that should be added to this list? Are there specific manufacturers
on this list that may be more severely impacted by an amended energy conservation standard

than others?

CARTE International, Inc. Moloney Electric Inc. (Canadian)
Central Moloney, Inc. NEELTRAN

DYNAPOWER Niagara Transformer Corporation
Electric Service Company (ELSCO) Olsun Electrics Corporation

Federal Pacific ONYX Power Inc.
Hex Tec, LLC (subsidiary of MSE, Inc.) Pacific Crest Transformers

Jefferson Electric Pemco Corporation

JINPAN International USA, Limited Power Partners, Inc.
Kentucky Association of Electric Cooperatives, Inc. Power Quality International
Lindsey Manufacturing Company Powersmiths Int'l (Canadian)
Magnetic Technologies, Inc. Sola/Hevi

- Duty
Manufacturing Systems & Equipment, Inc. (MSE) VanTran Industries, Inc.
Marcus Transformer (Canadian) Virginia Transformer

MGM Transformer Company Warner Power
Mirus International (Canadian)

F.12.3 Are there any reasons that a small business might be at a disadvantage relative to a larger
business under amended energy conservation standards? Please consider such factors as

technical expertise, access to capital, bulk purchasing power for materials/components,
engineering resources, and any other relevant issues

.

3 DOE uses the SBA small business size standards effective November 5 , 20 10 to determine whether a company is a

small business. To be categorized as a small business, a power, distribution and specialty transformer manufacturer and its affiliates may em ploy a maximum of 750 employees. The 750 employee threshold in cludes all employees in a business’s parent company and any other subsidiaries.