Analysis Requests And Clarifying Questions

1. For each design line or product, please recalculate (incremental delivered) cost and benefits 

(in kWh / year and in dollars per year) for each CSL relative to (1) the current standard and 

(2) relative to the next-lowest CSL (i.e., the incremental benefit and cost associated with each 

CSL). Rather than base the calculation on the full set of 10,000 designs, please use only the 

least-cost design in each CSL as discussed in the last meeting. This will normally be the “dot” 

on the plot in the lower left-hand corner (or most southwest) of each CSL, but may be located 

elsewhere as in CSL3 (the design the EEI representative referred to as the “sweet-spot”). For 6

CSLs and a base-period, for example, there should be 7 data-points / designs.

2. Please show benefits and costs for the designs in 1. above based on the 50% loading in the 

current standard as well as for 25%, 30%, 35%, 40%, and 45% RMS loadings and at a 

temperature of 75C. Consideration of alternative load factors and the higher temperature is 

purely for the purpose of calculating benefits and costs of the standard at 50% and 55C. I am 

not suggesting different test criteria for determining compliance.

3. For each design / data-point referenced in 1. above, please also provide full details on the 

design assumptions and output, including: A factor used in design, all material types, cooling 

design (e.g., radiators or fins), core and coil weights (required to analyze the “competitive” 

TSL determination for electrical steel manufacturers – this issue was raised at the last 

meeting), LL and NLL, total cost to build and estimated delivery price. Figure 1 is a sample 

presentation of the level of detail that would be ideal for our purposes.

4. For each of the designs in 1. and operating conditions in 2. above, please calculate the PBP as 

a comparison of specific deigns.

5. Whether or not consistent with DOE policy, unless there is a legal requirement that the 

committee may consider only those factors that are consistent with DOE policy, some 

members may believe that the cost of a kWh saved or the potential impact on consumer 

electric bills is a factor they would like to consider. Accordingly, I request that DOE also 

provide the cost per kWh saved over the life of the transformer (i.e., the incremental delivered 

cost divided by the discounted stream of kWh savings) each of the designs in 1. and operating 

conditions in 2. Above. I also ask that, each of the designs in 1. and operating conditions in 2. 

Above, DOE calculate compare the annual savings in generation to the annualized 

incremental delivered cost (i.e., levelized depreciation and return) using whatever rate of 

return and equity ratio it believes is appropriate and not inconsistent with its other 

programmatic analyses.

6. One would expect that a prudent OEM might prepare MEPS designs that were “somewhat” 

more efficient than the standard to ensure compliance. Does DOE/LBL/Navigant have any 

test or interview information that would address this question?

7. From the proprietary manufacturer sales data the has been provided to DOE/LBL/Navigant, 

please provide the percent of kva in each product class that exceeds the current MEPS or that 

exceeds the amount by more than what might be considered a prudent compliance margin 

addressed in 6. above.

8. Please provide the frequency distribution of A factors used in the PTSD, and the basis for that 

distribution.

9. What adjustments, if any, did DOE/LBL/Navigant make to delivered prices based on the 

comments filed in April, and the lower actual transactions data provided?