Small Manufacturer Survey Overview

Distribution Transformers December 20

Low Voltage Dry Type

1 | Building Technologies Program 

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Small Business Analysis

• Definition: A distribution transformer manufacturer and its affiliat

employ no more than 750 employees to be considered a small bu

• DOE consulted several sources to identify manufacturers:

• Past rulemaking contacts• SBA d t b SBA database

• Asked manufacturers during interviews about small business• DOE’s certification and compliance database

• NEMA b li t NEMA member lists

• This search yielded 56 unique manufacturers:

• Of th 35 d t d LVDT t f b d Of these, 35 appeared to produce LVDT transformers based 

initial screening and contacts. Upon further investigation, DOof these to be either distributors or engineering firms only, lea

potential manufacturers.

2 | Building Technologies Program 

potential manufacturers.
Small Businesses in LDVT Market

14

11

29 Companies Identifed as LVDT Manufacturers

14 

Meet US Small Biz Definition Low‐volume, But Don't Meet Definition 

R hd eac

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d

8 R hd eac

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5

• Of the 29 potential LVDT manufacturers DOE ide

– 4 fi l i ith l k t h 4 firms are large companies with large mar

k

e

t s

hare

– 14 firms met the definition of a small business

• Of these, DOE successfully reached 8 (2 of which said DOE-cov

not meaningful to their business) not meaningful to their business).

– 11 firms could be considered low-volume players in the 

but do NOT* meet the definition of a U.S. small busines

• Of these DOE successfully reached 5

3 | Building Technologies Program 

Of these, DOE successfully reached

5.

* Six of these 11 had parent companies with more than 750 employees; the other five operated primarily ou
Survey Summary

• Of the 6 US Small businesses DOE reached:

– 4/6 produce in the U.S.; however, the majority of the vo

produced by these six is produced outside the country produced by these six is produced outside the country.

– 3/6 also compete in MVDT market also.– 3/6 have in-house mitering or wound core construction 

• Of all 11 low-volume businesses surveyed:

– 6/11 p ; , jy roduce in US; however, the majority of the volum

produced by these six is produced outside the country.

– 5/11 compete in MVDT market also.

– 7/11 have in 7/11 have in-house mitering or wound core construction house mitering or wound core construction

capability.

– 4 made nearly all cores in-house; 2 sourced all cores; 5 

mix

4 | Building Technologies Program 
Issue:

Answers to each question are scrambled in each ro

confidentiality. A given column does NOT repr

manufacturer’s complete set of answer

Revenue from 

DOE-covered 

LVDT

35% 25% 20% 5% 65

Sign

i 

Expected

Impact and 

Response to a 

standard set at 

NEMA

Unsure. But 

probably don’t 

have ability to 

t

No impact. 

Not a significant 

impact. 

Probably would 

source cores; 

d d

Would probably 

exit product line. 

Minimum of 

$750K 

i t ti

impa

would 

invest t

in ho

alth

a NEMA

Premium Level

meet. depends on 

steel prices. 

investment in 

new machinery. 

sou

greate

of co

Also in MVDT? Yes No Yes No. N

Produce in US? Yes No. No Yes Y

Share of cores 

sourced 100% 0%

Varies 

depending on 0% 20

currently. pricing. 

In-house 

mitering or 

wound core 

bilit ?*

Yes. Yes. No. Yes. N

5 | Building Technologies Program 

capability?*

Capital and 

one-time R&D 

investments

Unknown $1.6 M for NEMA Premium Not provided. Not a concern. $0 Unk
Issue:

Answers to each question are scrambled in each 

confidentiality. A given column does NOT rep

manufacturer’s complete set of answe

Share of Revenue

from DOE-covered 

LVDT

100% Up to 40% 100% 35% 

Expected Impact 

and Response to a 

standard set at a 

NEMA Premium

Unclear; significant 

investment in that

there would be 

investment would be 

No Impact. 

Already in high 

efficiency focus

No Impact. 

Already in high 

efficiency focus

No Impact

Already in h

efficiency foc

NEMA Premium 

Level R&D for new designs. efficiency focus. efficiency focus. efficiency foc

Also in MVDT

Mk? No No Yes No Market? No No Yes No 

Produce in US? No No Yes No 

Share of cores Share of cores

sourced currently 100% 0% Varies 0% 

In-house full 

mitering or wound

core capability?*

Yes Yes Yes No 

6 | Building Technologies Program 

core capability?*

Capital and onetime R&D 

investments

$0 $1.5M minimum Unknown but significant R&D $0 
Survey Conclusions

• The wide range of responses from small manufacturers 

clear summary statements difficult come by.

– Five manufacturers thought there would be no significant impa

NEMA Premium levels.

• Two of these companies expressed some ambivalence about CSL

NEMA Premium because of the trade-off between the potential for market share versus the prospect of the commoditization of their h

niche.

– Six manufacturers thought the impact would be significant or w

uncertain to comment on at this time. Of these 6 companies: uncertain to comment on at this time. Of these 6 companies:

• Three said they might exit the DOE-covered LVDT product line or 

cores after considering the costs of compliance.

7 | Building Technologies Program 

• One business indicated any change in standards would threaten t

altogether.