From: Phil Hopkinson [mailto:phopkinson@hvolt.com] 

Sent: Monday, November 14, 2011 10:13 AM 

To: Rosenstock, Steven; Steve Nadel; Robert Berman 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; 

mhyland@appanet.org; Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; 

bruce.r.hirsch@bge.com; tpetrosino@carolina.rr.com; dbrender@cda.copper.org; James.Lass@cleco.com; 

chris.brown@cogentpowerinc.com; frank.guilbault@cogentpowerinc.com; 

ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; Jack C Moore; Jerry L Corkran; 

tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily (CONTR) 

Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; DYoung@energy-solution.com; 

rick.anderson@faypwc.com; bsmith@federalpacific.com; rgreeson@federalpacific.com; 

carlos.gaytan@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; ned.efbrush@gmail.com; 

Richard Parker; Paul.Ryan@hitmet.com; jhodge@howard.com; Daniel Cohen; cabolduc@lbl.gov; 

gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; dave.millure@metglas.com; 

kwinder@mleainc.com; jrossetti@mlgw.org; Brian Coffey; Caitlin Johnson; Matthew Nardotti; Michael 

Rivest; Zhimei Luo; Jim.creevy@nema.org; john.caskey@nema.org; mwaltner@nrdc.org; rroy@nrdc.org; 

robert.saint@nreca.coop; Teckman@nwcouncil.org; vijay.tendulkar@onyxpower.com; gbf1@pge.com; 

chuck.simmons@pgnmail.com; ahofmann@publicpower.org; pkumar@publicpower.org; 

adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org 

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference 

Good response Steve and I would add that on an M3 base, the paybacks soar well beyond the 30 year

life expectancy even for EL1.  I see no cost justification for a change in most cases.

Phil

Philip J Hopkinson, PE 

President & CEO HVOLT Inc. 

3704 High Ridge Rd. 

Charlotte, NC 28270 

phopkinson@hvolt.com

Ph 704-846-3290 

Fx 704-845-2520 

Cell 704-236-3320 

www.hvolt.com

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

Sent: Monday, November 14, 2011 9:31 AM 

To: Steve Nadel; Robert Berman; Phil Hopkinson 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; 

mhyland@appanet.org; Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; 

bruce.r.hirsch@bge.com; tpetrosino@carolina.rr.com; dbrender@cda.copper.org; James.Lass@cleco.com; 

chris.brown@cogentpowerinc.com; frank.guilbault@cogentpowerinc.com; 

ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; Jack C Moore; Jerry L Corkran; 

tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily (CONTR) 

Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; DYoung@energy-solution.com; 

rick.anderson@faypwc.com; bsmith@federalpacific.com; rgreeson@federalpacific.com; 

carlos.gaytan@ge.com; artrosenfeld@gmail.com; greg.coulter405@gmail.com; ned.efbrush@gmail.com; 

Richard Parker; Paul.Ryan@hitmet.com; jhodge@howard.com; Daniel Cohen; cabolduc@lbl.gov; 

gjrosenquist@lbl.gov; kcoughlin@lbl.gov; ScottB@LVMetals.com; dave.millure@metglas.com; 
kwinder@mleainc.com; jrossetti@mlgw.org; brian.coffey@navigant.com; caitlin.johnson@navigant.com; 

matthew.nardotti@navigant.com; mrivest@navigant.com; zhimei.luo@navigant.com; 

Jim.creevy@nema.org; john.caskey@nema.org; mwaltner@nrdc.org; rroy@nrdc.org; 

robert.saint@nreca.coop; Teckman@nwcouncil.org; vijay.tendulkar@onyxpower.com; gbf1@pge.com; 

chuck.simmons@pgnmail.com; ahofmann@publicpower.org; pkumar@publicpower.org; 

adelaski@standardsASAP.org; jmauer@standardsasap.org; wes.patterson@us.abb.com; 

chad.kennedy@us.schneider-electric.com; thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference 

Mr. Nadel, 

In terms of the DOE analysis, some of us are still waiting for the other sensitivity 

analyses before concluding that DOE has justified higher standards . For example, I 

have not seen the analysis of transformer costs that rise higher than the rate of inflation 

(which DOE has shown has been the case since 2003). Also, many parties do not think 

that a 24 year payback is “cost effective”. 

Also, please refer to the attachment. Today’s standards that took effect on January 1, 

2010, are not “low”. In fact, they are significantly higher than the levels that several 

parties agreed to for 2009 or even 2013. The standard that took effect were at level 4.5 

for many transformer, well above the Level 2 efficiency that was agreed to. 

Also, several parties have indicated that they do not want to sign on to a standard that 

will likely result in domestic job losses and more “off-shoring” of jobs to meet the new 

standards. See the following for examples: 

http://www.washingtonpost.com/wpdyn/content/article/2010/09/07/AR2010090706933.html 

http://news.heartland.org/newspaper-article/2010/10/04/ge-closes-last-incandescentlight-bulb-plant-jobs-sent-china 

http://money.cnn.com/2011/10/28/news/companies/whirlpool_jobs/index.htm 

http://business380.com/2011/10/27/whirlpool-bringing-160-jobs-to-amana-closingarkansas-plant/ Key quotes: 

“Benton Harbor, Mich.-based Whirlpool announced Thursday that it plans to close its 

refrigerator plant in Fort Smith, Ark., in mid-2012, due to a decrease in demand for side-by-side 

refrigerators. The closing will put 884 hourly workers and 90 salaried employees employees out 

of work.” 

“The Fort Smith facility employed 4,600 people five years ago, but that number has declined in 

the poor economy and since Whirlpool opened a refrigerator factory in Mexico. The company 

said its plant at Ramos Arizpe, Mexico, will take on side-by-side refrigerator production, but will 

not need to hire new workers.” 
So, my question to you is, can’t you be a little flexible, since standards went up so high 

In 2010? Can’t you see that there are risks involved in going even higher? 

Steve Rosenstock 

Manager, Energy Solutions 

Edison Electric Institute 

srosenstock@eei.org

202-508-5465 

From: Steve Nadel [mailto:snadel@aceee.org] 

Sent: Friday, November 11, 2011 2:16 PM 

To: Robert Berman; Phil Hopkinson 

Cc: Eric.Petersen@aksteel.com; jerry.schoen@aksteel.com; Maxine (EMAB) Savitz; 

mhyland@appanet.org; Raymond.Polinski@ATImetals.com; maheshsampat@bellsouth.net; 

bruce.r.hirsch@bge.com; tpetrosino@carolina.rr.com; dbrender@cda.copper.org; James.Lass@cleco.com; 

chris.brown@cogentpowerinc.com; frank.guilbault@cogentpowerinc.com; 

ted.johnstone@cogentpowerinc.com; Aaron Meyers; Antonio Trujillo; Jack C Moore; Jerry L Corkran; 

tballo@earthjustice.org; carlosgsiqueiros@eaton.com; eduardorobles@eaton.com; Emily (CONTR) 

Marchetti; Jeremiah (CONTR) Freeman; Jim Raba; John Cymbalsky; Rosenstock, Steven; 

DYoung@energy-solution.com; rick.anderson@faypwc.com; bsmith@federalpacific.com; 

rgreeson@federalpacific.com; carlos.gaytan@ge.com; artrosenfeld@gmail.com; 

greg.coulter405@gmail.com; ned.efbrush@gmail.com; Richard Parker; Paul.Ryan@hitmet.com; 

jhodge@howard.com; Daniel Cohen; cabolduc@lbl.gov; gjrosenquist@lbl.gov; kcoughlin@lbl.gov; 

ScottB@LVMetals.com; dave.millure@metglas.com; kwinder@mleainc.com; jrossetti@mlgw.org; 

brian.coffey@navigant.com; caitlin.johnson@navigant.com; matthew.nardotti@navigant.com; 

mrivest@navigant.com; zhimei.luo@navigant.com; Jim.creevy@nema.org; john.caskey@nema.org; 

mwaltner@nrdc.org; rroy@nrdc.org; robert.saint@nreca.coop; Teckman@nwcouncil.org; 

vijay.tendulkar@onyxpower.com; gbf1@pge.com; chuck.simmons@pgnmail.com; 

ahofmann@publicpower.org; pkumar@publicpower.org; adelaski@standardsASAP.org; 

jmauer@standardsasap.org; wes.patterson@us.abb.com; chad.kennedy@us.schneider-electric.com; 

thomas.patzner@us.schneider-electric.com; charlied@uus.org

Subject: RE: Negotiated Rulemaking - Distribution Transformers Teleconference 

Phil, 

 

We're in the middle of negotiations and some of us have made clear that no or little change to the 

standard is not acceptable as the DOE analysis justifies higher standards (higher levels are technically 

feasible and cost-effective on a life-cycle cost basis). The efficiency groups would rather leave the 

decision to DOE than agree to subpar standards. If you and other participants want to veto any 

significant change in the standard, then we might as well save some time, break off negotiations and just 

make our respective arguments to DOE. Is that what you want to do? If the answer is no, then let's start 
talking about how to make higher standards acceptable rather than continue to make arguments about 

why low standards are needed. We're all busy and if we're going to make progress we need to break new 

ground and not rehash old ground. 

 

Steve 

>>> Phil Hopkinson <phopkinson@hvolt.com> 11/11/2011 1:16 PM >>> 

Hello Robert and all:

You must not have looked at Jerry Corkran’s message because he found the cost to be $17/watt, which

is pretty close to my number, where both Jerry and I have used M3 core steel to derive the cost curve.  

The fact is that the cost curve is very steep with M3 and quickly hits the brick wall.  

1. I have checked Carlos Gaytan’s cost curves as well and he is finding about the same

relationship with M3.  

2. I have checked Wes Patterson’s data as well and he is finding an M3 cost curve about the same

as mine.

3. I have checked the OPS data with M3 as well and it too is very close to $20/watt.

a. For example, for design line 1 they show an efficiency at 50% load of 99.08% which

translates to 232 watts of loss and sells for $1,960.73.

b. They show another M3 design with an efficiency of 99.26% which translates to 186

watts of loss and sells for $2962.11.

c. The change in selling price is $2,962.11‐$1,906.11 or +$1,001.38

d. The change in watts is 232‐186 or ‐46 watts.

e. The OPS $/watt is therefore, $1,001.38/46 watts or $21.77

f. Hence we see that all data sources are pointing to cost per watt of ~$20 /watt saved to

go from the current mandatory standard to EL1.  I get $30/watt to go to EL2 and

$53/watt to go to EL3

4. The fact is that M3 is about out of gas and the DOE did a good job in the last rule making.

5. The fact also is that a push to anything beyond present does not show economic value and I do

not support it.

6. The fact also is that a push to higher efficiencies will kill the new transformer market and open

up the rebuild market, destroying jobs at the new transformer manufacturers and resulting in

transformers of lower efficiency which will cost energy and not save it.

Best regards,

Phil

Philip J Hopkinson, PE 

President & CEO HVOLT Inc. 

3704 High Ridge Rd. 

Charlotte, NC 28270 

phopkinson@hvolt.com

Ph 704-846-3290 

Fx 704-845-2520 

Cell 704-236-3320 

www.hvolt.com
From: Robert Berman [mailto:bermaneconomics@gmail.com] 

Sent: Friday, November 11, 2011 11:16 AM 

To: Phil Hopkinson 

Cc: Corkran, Jerry L; Richard Parker; Freeman, Jeremiah (CONTR); 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; bruce.r.hirsch@bge.com; jhodge@howard.com; mhyland@appanet.org; 

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

Raymond.Polinski@ATImetals.com; artrosenfeld@gmail.com; srosenstock@eei.org; rroy@nrdc.org; 

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; kwinder@mleainc.com; mwaltner@nrdc.org; 

jerry.schoen@aksteel.com; Paul.Ryan@hitmet.com; ahofmann@publicpower.org; 

pkumar@publicpower.org; bsmith@federalpacific.com; greg.coulter405@gmail.com; 

jmauer@standardsasap.org; Cohen, Daniel; Meyers, Aaron; Jim.creevy@nema.org; jrossetti@mlgw.org; 

cabolduc@lbl.gov; kcoughlin@lbl.gov; brian.coffey@navigant.com; mrivest@navigant.com; 

gjrosenquist@lbl.gov; caitlin.johnson@navigant.com; zhimei.luo@navigant.com; Marchetti, Emily 

(CONTR); charlied@uus.org; DYoung@energy-solution.com; James.Lass@cleco.com; 

maheshsampat@bellsouth.net; matthew.nardotti@navigant.com; Raba, Jim; Savitz, Maxine (EMAB); 

tpetrosino@carolina.rr.com; chris.brown@cogentpowerinc.com; ted.johnstone@cogentpowerinc.com; 

frank.guilbault@cogentpowerinc.com; ned.efbrush@gmail.com; dbrender@cda.copper.org; 

chad.kennedy@us.schneider-electric.com; eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; 

thomas.patzner@us.schneider-electric.com; carlosgsiqueiros@eaton.com; Robert Berman; Trujillo, 

Antonio; Moore, Jack C 

Subject: Re: Negotiated Rulemaking - Distribution Transformers Teleconference 

Even if it were that high (and Mr. Hopkinson is the only one I've seen who has put the number 

anywhere near that), the efficiency objective is saving Watt-hours (energy) not Watts (the 

capacity to save energy) . One Watt saved for 8,760 hours per year for 30 years is 262.8 kWh 

(not counting leap years). Even at Mr. Hutchinson's $20, that's just over 7¢ / kWh. If Mr. 

Hutchinson will examine his electric bill, as he has reported, he will see that even as high as 7¢ 

it's a good buy, and that assumes we put a ZERO value on any environmental benefits (which is 

why DOE agreed to reconsider its 2007 MEPS in the first place. 

Indeed, the cost of losses per Watt (roughly the A factors that OPS has been using) are no where 

near the $20 claimed here. Moreover, as ABB and others have pointed out, the proper approach 

would have been to minimize cost subject to efficiency, not A & B, which would have resulted 

in a lower, flatter curve to the asymptote. ABB's actual market data -- physical transformers 

produced and delivered -- shows a competitive market for M3 transformers even at EL4 

efficiency. You can make all the hypothetical claims you want to, gentlemen, the market is the 

real world. 

Regards,

Robert A. Berman, Principal

Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703-281-0490
703-655-8398 (cell)

BermanEconomics@gmail.com

On Nov 10, 2011, at 6:53 PM, Phil Hopkinson wrote: 

Well stated Jerry 

That is also what my analysis and report said. If you restrict to M3 then the cost of EL1 rises to 

about $20/watt. 

Phil 

Phil Hopkinson,P.E. 

HVolt Inc. 

704-846-3290 

F: 704-845-2520 

C: 704-236-3320 

phopkinson@hvolt.com

On Nov 10, 2011, at 18:04, "Corkran, Jerry L" <Jerry.Corkran@CooperIndustries.com> wrote: 

To Mr. Parker and the DOE working group,

The reason for the request for the incremental cost of the losses is that the current DOE efficiency levels

can be obtained if the design is optimized at about $4 per core watt and $1 per winding watt at full

load.  At the DOE 50% kVA rating, this is the same as evaluating the losses or optimizing the design at

about $4 per total watts loss.  

The present DOE efficiency loss level results in transformer designs about like many utilities were

purchasing their transformers before 2007.   The utilities were purchasing the efficiency levels that were

justified based on the cost of losses.  A few utilities  were purchasing higher efficiency that the 2007

efficiency rules because of the calculated cost of energy being higher than the $4/$1 loss evaluation.  

What came up in the discussion last week was even for loss level 1, the incremental cost of losses was

about $17 per watt for the design checked, between the present DOE losses an efficiency level of DEL1.  

The added cost of $17 per watt is so much higher than the typical cost of the energy for the utilities,

that  it is very questionable that the DOE payback estimates are accurate.  A 3% interest rate may be a

factor in the payback calculations.
Jerry Corkran

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

Sent: Thursday, November 10, 2011 3:23 PM 

To: Robert Berman 

Cc: Freeman, Jeremiah (CONTR); rick.anderson@faypwc.com; tballo@earthjustice.org; 

ScottB@LVMetals.com; john.caskey@nema.org; Corkran, Jerry L; Cymbalsky, John; 

adelaski@standardsASAP.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; 

rgreeson@federalpacific.com; bruce.r.hirsch@bge.com; jhodge@howard.com; mhyland@appanet.org; 

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

Raymond.Polinski@ATImetals.com; artrosenfeld@gmail.com; srosenstock@eei.org; rroy@nrdc.org; 

robert.saint@nreca.coop; chuck.simmons@pgnmail.com; kwinder@mleainc.com; mwaltner@nrdc.org; 

jerry.schoen@aksteel.com; Paul.Ryan@hitmet.com; ahofmann@publicpower.org; 

pkumar@publicpower.org; bsmith@federalpacific.com; greg.coulter405@gmail.com; 

jmauer@standardsasap.org; Cohen, Daniel; Meyers, Aaron; Jim.creevy@nema.org; jrossetti@mlgw.org; 

cabolduc@lbl.gov; kcoughlin@lbl.gov; brian.coffey@navigant.com; mrivest@navigant.com; 

gjrosenquist@lbl.gov; caitlin.johnson@navigant.com; zhimei.luo@navigant.com; Marchetti, Emily 

(CONTR); charlied@uus.org; DYoung@energy-solution.com; James.Lass@cleco.com; 

maheshsampat@bellsouth.net; phopkinson@hvolt.com; matthew.nardotti@navigant.com; Raba, Jim; 

Savitz, Maxine (EMAB); tpetrosino@carolina.rr.com; chris.brown@cogentpowerinc.com; 

ted.johnstone@cogentpowerinc.com; frank.guilbault@cogentpowerinc.com; ned.efbrush@gmail.com; 

dbrender@cda.copper.org; chad.kennedy@us.schneider-electric.com; eduardorobles@eaton.com; 

vijay.tendulkar@onyxpower.com; thomas.patzner@us.schneider-electric.com; 

carlosgsiqueiros@eaton.com

Subject: Re: Negotiated Rulemaking - Distribution Transformers Teleconference

 

Robert, 

I understand the DOE staff are working on the incremental Watts calculations and will get that 

out to group as soon as it's ready. 

best wishes, 

Richard 

On Thu, Nov 10, 2011 at 11:52 AM, Robert Berman <bermaneconomics@gmail.com> wrote: 

Thank you Richard. That clarification is helpful. 

 
In the liquid-filled meeting we were told that we would receive an analysis of incremental Watts 

saved by DL for all ELs, as well as the incremental cost. When will that analysis be available? 

For many of us, that analysis is the basis for additional, perhaps extensive analyses, so it should 

come with enough lead time before any additional meetings or teleconferences to that we can 

give it the required consideration. It would be most helpful if the incremental cost were provided 

separately for transformer and installation, with any pole component of the installation identified. 

 

For the MV Dry and LV Dry meetings, it would be most helpful if you would also circulate an 

agenda with objectives, hopefully this week, so that we are able to prepare for those meetings. 

Regards,

Robert A. Berman, Principal

Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703‐281‐0490

703‐655‐8398 (cell)

BermanEconomics@gmail.com

 

On Nov 10, 2011, at 11:14 AM, Richard Parker wrote: 

Dear Colleagues: 

The telcon on the 17th is currently planned for medium-voltage dry-type and the telcon on the 

21st is reserved for low-voltage. There will be revised analysis circulated in advance of both 

calls per our discussion yesterday. Each call has substantial chunks of time allocated, though I 

hope we won't need all that time. 

It may be prudent to schedule a liquid-filled call at some point as well, but I propose that we hold 

off on that for day or so, until we can clarify when revised analysis for liquid-filled will be 

ready. 

Thanks for your very constructive participation in the meetings over the last two days. 

Richard Parker 
On Thu, Nov 10, 2011 at 10:05 AM, Freeman, Jeremiah (CONTR) 

<Jeremiah.Freeman@ee.doe.gov> wrote: 

When: Thursday, November 17, 2011 1:00 PM‐5:00 PM (GMT‐05:00) Eastern Time (US & Canada).

Where: Webinar and Phone

Note: The GMT offset above does not reflect daylight saving time adjustments.

*~*~*~*~*~*~*~*~*~*

Dear Colleagues,

This event is to save the time slot on your calendar based on our discussion at yesterday's meeting.

Later today further information will be sent regarding the registration information for our November 17

and November 21 webinars. After registering you will get the link for the webinar and a toll free

number.

Please call with questions or concerns.

Very Respectfully,

Jeremiah Freeman

202‐431‐4243 (cell)

202‐586‐1867 (office)