From: Corkran, Jerry L [mailto:Jerry.Corkran@CooperIndustries.com] 

Sent: Tuesday, September 20, 2011 3:57 PM 

To: Richard Parker 

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; 

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

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

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

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

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

rules are selected. 

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