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; tb allo@earthjustice.org; ScottB@lvmetals.com; john.caskey@nema.org; john.cymbalsky@ee .doe.gov; adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.g aytan@ge.com; rgreeson@federalpacific.com; bruce.r.hirsch@bge.com; mhyland@appanet.org; dave.millure@metglas.com; snadel@aceee.org; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.Polinski@atimetals.com; srosenstock@eei.org; rroy@nrdc.org; robert.sai nt@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@sta ndardsasap.org; greg.coulter405@gmail.com; bsmith@federalpacific.com; pkumar@publicpowe r.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.tendu lkar@onyxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider-electric.com; Marusine c, 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 request s for investigation by the DOE. Some of the questions listed belo w were presented before or during the first meeting,
but I have not received sufficient inform ation 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 rul es 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 suit able 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 cha nges 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 atto rney reviews the document. I also object to the 3 d. Deadline for Negot iations 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 beincluded to allow the transformer manufacturers to compare the same design created on their programs to the DOE created designs.

3. Would the DOE request transforme r design quotations from multiple
manufacturers for the transformer ef ficiency loss levels that the DOE considers buildable? This would pr ovide the DOE with actual designs which the manufacturers are capable ofbuilding. These designs could be compared to the designs whic h the DOE is currently using to generate the efficiency data projections.

4. Would the DOE request quotati ons from multiple manufacturers optimized for the lowest total owning costs at evaluated loss levels that they are considering. The evaluati on A and B factors would vary by a
4:1 ratio to reflect a m aximum 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 indicat es 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 efficiencylevels used by the DOE in their optimizations, which is Hitachi in Jap an and Metglas in the US (which is owned by Hitachi); is it legal fo r 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 thatadequate supplies of the materials produced within the United States exist to manufacture the required

transformers that will meet the tr ansformer efficiency requirements chosen for the proposed changes from the existing transformer efficiency requirements. If sour ces 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 wi thin the United States.

8. Regarding the assumptions that the DOE made to use an average distribution transformer life of 30 ye ars in their transformer efficiency payback calculations; the IEEE Tran sformer 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 a rrive 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 standa rd. In the Preliminary Technical Document (TSD):Energy Efficien cy Program for Commercial and Industrial Equiptment :D istribution 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 existin g efficiency standard, the DOE is requested to add the years of pa yback as listed in 19CFR Part 431 to the years listed on the March 2011 document.

10. The DOE used a 50% anticipate d loading factor for the 30 year anticipated average life calculations used in their transf ormer efficiency
evaluations. What is the source of th e 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 factor s 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 fact ors. 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 forc ing 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 a nd 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 th e 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 t ouch with Marketing and/or Business Development persons at the major au to manufacturers to learn what their projections are regarding the projected growth and market share
for electric vehicles. What market share do these companies project forelectric autos and how will that a dded load to the electrical systems affect the projected average load ing over the next 60 years?

14. For pole type distribution transfo rmers, the higher efficiency designs used by the DOE to evaluate the transformer efficiencies have a very significant increase in wei ght and also in transf ormer 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 desi gns using TOC A and B factors

written into law to control transfo rmer efficiencies. The advantage of using the TOC A and B factors to cont rol transformer efficiency is that it allows the transformer quotati ons to respond to the available materials. For example if copper conductors are required to meet a specified efficiency, transformer ma nufacturers would not be able to quote if a flood cut off the copper supply. Using the TOC A and B factors, each manufacturerwould be allowed to quote, if they used the
correct A and B factors. Another exam ple is if the customer prefers to raise the basic insulation level (b il) of the requested transformer design, the manufacturers will optimiz e to the specified bil using the
correct A and B factors. The end resu lt 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 , th erefore I am requesting that this subject be considered and responded to by the DOE before they proceed with the final ru le making. The total owni ng cost approach will

handle the variations that occur within the industry and also result in a similar improvement in efficiencyas would transformer efficiency targets. It will allow the transf ormer efficiencies to be increased as justified, using all the factors they are currently using to create target
transformer efficiencies. The DO E approach currently uses A and B
loss evaluation factors in their eval uations of what transformer efficiencies are justified. The A and B loss evaluation factors could be

written into the law ratherthan specifying the transformer efficiencies. The law could require that all ma nufacturers only q uote total owning cost optimized designs using these A and B factors for all quotations, just as they are now forced to quot e target efficiencies. The
transformer manufacturers would be re quired 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 becausethey have routinely used the TOC method of obtaining efficient transformer designs since about 1980.

Regards, Jerry Corkran Staff Engineer Cooper Power Systems