DOE/EA-1565


ENVIRONMENTAL ASSESSMENT 

FOR ADOPTED ENERGY CONSERVATION STANDARDS FOR 

DISTRIBUTION TRANSFORMERS 

July 2007 

U.S. Department of Energy

Assistant Secretary 

Office of Energy Efficiency & Renewable Energy 

Building Technologies Program 

Appliances and Commercial Equipment Standards 

Washington, DC 20585 
ENVIRONMENTAL ASSESSMENT FOR ADOPTED ENERGY CONSERVATION 

STANDARDS FOR DISTRIBUTION TRANSFORMERS 

TABLE OF CONTENTS 

1.0 INTRODUCTION ................................................. EA-1


2.0 PURPOSE ....................................................... EA-3


3.0 ALTERNATIVES, INCLUDING THE ACTION ......................... EA-5


3.1 No-Action Alternative ......................................... EA-6


3.2 Adopted Action .............................................. EA-6


3.3 Alternative Standards ......................................... EA-6


4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT .................. EA-14


4.1 Geography ................................................. EA-14


4.2 Air Resources .............................................. EA-14


4.2.1 Assumptions ......................................... EA-16


4.2.2 Methods ............................................ EA-16


4.3 Socioeconomics ............................................. EA-18


4.4 Environmental Justice ........................................ EA-18


4.5 Energy Consumption ......................................... EA-20


4.6 Noise and Aesthetics ......................................... EA-20


5.0 ENVIRONMENTAL IMPACTS ..................................... EA-20


5.1 Air Quality/Emissions Impacts .................................. EA-20


5.1.1 Power Sector Emissions ................................ EA-20


5.1.2 Discounted Emissions .................................. EA-25


5.1.3 Fuel-Cycle Emissions .................................. EA-26


5.2 Wetlands / Endangered and Threatened Species / Cultural Resources ..... EA-27


5.3 Socioeconomic Impacts ...................................... EA-27


5.4 Environmental Justice Impacts ................................. EA-27


5.5 Energy Consumption Impacts .................................. EA-28


5.6 Noise and Aesthetics ......................................... EA-29


5.7 Summary of Environmental Impacts ............................. EA-29


LIST OF TABLES 

Table EA.1 Adopted Standard Levels for Liquid-Immersed Distribution Transformers . EA-4


Table EA.2 Adopted Standard Levels for Medium-Voltage, Dry-Type Distribution


Transformers ............................................... EA-5


Table EA.3 Trial Standard Levels for PC 1 Liquid-Immersed, Medium-Voltage, Single-Phase 


Distribution Transformers ...................................... EA-7


Table EA.4 Trial Standard Levels for PC 2 Liquid-Immersed, Medium-Voltage, Three-Phase


Distribution Transformers ...................................... EA-8


Table EA.5 Trial Standard Levels for PC 5 Dry-Type, Medium-Voltage, Single-Phase


Distribution Transformers (20-45 kV BIL) ......................... EA-9


EA-i 
Table EA.6 Trial Standard Levels for PC 6 Dry-Type, Medium-Voltage, Three-Phase


Distribution Transformers (20-45 kV BIL) ........................ EA-10


Table EA.17 Cumulative Power Sector Emissions Impacts for Liquid-Immersed Transformers


Table EA.18 Cumulative Power Sector Emissions Impacts for Dry-Type Transformers


Table EA.22 Summary of the Analysis Results for Dry-Type, Medium-Voltage Transformers 


Table EA.7 Trial Standard Levels for PC 7 Dry-Type, Medium-Voltage, Single-Phase


Distribution Transformers (46-95 kV BIL) ........................ EA-11


Table EA.8 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers (46-95 kV


BIL) ..................................................... EA-12


Table EA.9 Dry-Type, Medium-Voltage, Single-Phase Distribution Transformers ($96 kV


BIL) ..................................................... EA-13


Table EA.10 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers ($96 kV


BIL) ..................................................... EA-14


Table EA.11 Liquid Immersed Power Sector Emissions ........................ EA-21


Table EA.12 Dry Type Power Sector Emissions .............................. EA-22


Table EA.13 Liquid Immersed Low Economic Growth Power Sector Emissions ...... EA-22


Table EA.14 Dry Type Low Economic Growth Power Sector Emissions ........... EA-23


Table EA.15 Liquid Immersed High Economic Growth Power Sector Emissions ...... EA-23


Table EA.16 Dry Type High Economic Growth Power Sector Emissions ........... EA-24


........................................................ EA-24


........................................................ EA-24


Table EA.19 Discounted CO2 Emissions Reductions of the Trial Standard Levels by Design


Line (in millions of metric tons) ................................ EA-25


Table EA.20 Estimated Upstream Emission Factors and Corresponding Percentages of Direct


Power Plant Combustion Emissions ............................. EA-26


Table EA.21 Summary of the Analysis Results for Liquid-Immersed Transformers .... EA-29


........................................................ EA-30


EA-ii 
ENVIRONMENTAL ASSESSMENT FOR DISTRIBUTION TRANSFORMERS 

1.0 INTRODUCTION 

The U.S. Department of Energy (DOE) prepared this distribution transformers 

environmental assessment (EA) pursuant to the National Environmental Policy Act of 1969 

(NEPA)(42 U.S.C. 4321 et seq.), the regulations of the Council on Environmental Quality (40 

CFR parts 1500–1508), and the DOE’s regulations for compliance with NEPA (10 CFR part 

1021). 

Title III of the Energy Policy and Conservation Act (EPCA) (42 U.S.C. 6291 et seq.) sets 

forth a variety of provisions designed to improve energy efficiency. Part C of title III (42 U.S.C. 

6311–6317) establishes an energy-conservation program for “Certain Industrial Equipment” and 

includes distribution transformers, the subject of this EA. EPCA states that the Secretary of 

Energy shall prescribe testing requirements for those distribution transformers for which the 

Secretary makes a determination that energy conservation standards would be technologically 

feasible and economically justified, and would result in significant energy savings. Furthermore, 

the Secretary shall prescribe, by rule, energy conservation standards for those distribution 

transformers for which the Secretary prescribed testing requirements under the first statement. 

(42 U.S.C. 6317) There are no current mandatory national standards for distribution transformers 

in the United States. 

On October 22, 1997, the Secretary of Energy issued a determination that “based on its 

analysis of the information now available, DOE has determined that energy conservation 

standards for transformers appear to be technologically feasible and economically justified, and 

are likely to result in significant savings.” 62 FR 54809. The Secretary’s determination was 

based, in part, on analyses conducted by the Department of Energy’s Oak Ridge National 

Laboratory (ORNL). In July 1996, ORNL published a report entitled Determination Analysis of 

Energy Conservation Standards for Distribution Transformers, ORNL-6847,1

 which assessed 

options for setting energy conservation standards. That report was based on information from 

annual sales data, average load data, and surveys of existing and potential transformer efficiencies 

obtained from several organizations. 

In September 1997, ORNL published a second report entitled Supplement to the 

“Determination Analysis” (ORNL-6847) and Analysis of the NEMA Efficiency Standard for 

Distribution Transformers, ORNL-6925.2

 This report assessed the suggested efficiency levels 

contained in the then-newly published National Electrical Manufacturers Association (NEMA) 

Standards Publication No. TP 1-1996, Guide for Determining Energy Efficiency for Distribution 

Transformers,

3

 along with the efficiency levels previously considered by DOE in the 

determination study. The latest downloadable version of TP 1 is available at the NEMA website: 

http://www.nema.org/stds/tp1.cfm#download. In its supplemental assessment, ORNL used a 

more accurate analytical model and better transformer market and loading data developed 

following the publication of ORNL-6847. Downloadable versions of both ORNL reports are 

EA-1 
available on the DOE website at: 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/dist_transformers.html 

On July 29, 2004, DOE published the advance notice of proposed rulemaking (ANOPR) 

and its associated technical support document (TSD).4

 At the ANOPR public meeting on 

September 28, 2004, as well as during the formal comment period, DOE invited stakeholders to 

comment on the following issues: definition and coverage, product classes (PCs), engineering 

analysis inputs, design option combinations, the 0.75 scaling rule, modeling of transformer load 

profiles, distribution chain markups, discount rate selection and use, baseline determination 

through purchase evaluation formulae, electricity prices, load growth over time, life-cycle cost 

(LCC) subgroups, and utility deregulation impacts. 

On August 5, 2005, DOE posted its draft NOPR analysis for the liquid-immersed and 

medium-voltage, dry-type distribution transformers on its website for early public review, along 

with spreadsheets for several of these analyses. This early publication of the draft NOPR analysis 

included the draft engineering analysis, LCC analysis, national impact analysis, and manufacturer 

impact analysis (MIA), and the draft TSD chapters associated with each of these analyses. The 

purpose of publishing these four draft analyses was to give stakeholders an opportunity to review 

the analyses and prepare recommendations for DOE as to the appropriate standard levels. 

On August 4, 2006, DOE published the distribution transformer energy conservation 

standards NOPR. 71 FR 44355. In conjunction with the NOPR, DOE also published on its 

website the complete TSD for the proposed rule, which incorporated the final analyses DOE 

conducted and technical documentation for each analysis. 

On February 9, 2007, DOE issued a notice of data availability and request for comments 

(NODA). 72 FR 6186. DOE published this notice in response to stakeholders who had 

commented in the NOPR that DOE's proposed standards might prevent or render impractical the 

replacement of distribution transformers in certain space-constrained (e.g., vault) installations. In 

the NODA, DOE sought comment on whether it should include in the LCC analysis potential 

costs related to size constraints of transformers installed in vaults. DOE also requested comment 

on an additional option of selecting final efficiency levels for liquid-immersed distribution 

transformers by design line. As discussed in the Engineering Analysis (see TSD Chapter 5), DOE 

created separate engineering design lines for small and large kVA liquid-immersed distribution 

transformers in both the single-phase and the three-phase product classes. In the NODA, DOE 

asked stakeholders whether it should select the final efficiency level for liquid-immersed 

distribution transformers by looking at its liquid-immersed analytical results in their most 

disaggregated form - by design line. Stakeholder comment from the NODA were considered in 

formulating the final rule for the energy conservation standard. 

EA-2 
2.0 PURPOSE 

Energy-efficiency standards for distribution transformers are expected to result in savings 

in electrical energy. The metric used to measure the efficiency of distribution transformers is 

percent efficiency, which is calculated by taking into account no-load losses (which are constant) 

and load losses (which vary by the square of the load) at a specified design load. An increase in 

the percent efficiency as measured above indicates that the distribution transformer is more 

energy-efficient. Details on the technical analysis of increased efficiency levels are provided in the 

TSD that accompanies DOE’s adopted energy conservation standard standard. 

To analyze improvements in the efficiency of distribution transformers, DOE created six 

trial standard levels (TSLs) during the NOPR using the following criteria for determining the 

efficiencies: 

TSL 1: The NEMA TP 1 standard level 

TSL 2: 1/3 of difference between TP 1 and minimum LCC 

TSL 3: 2/3 of difference between TP 1 and minimum LCC 

TSL 4: Minimum LCC 

TSL 5: Maximum energy savings with no change in LCC 

TSL 6: Maximum energy savings (or maximum technologically feasible level) 

In response to comments received in response to the NOPR and the NODA, DOE 

formulated four recombined standard levels that it evaluated for the final rule for liquid-immersed 

transformers. For liquid-immersed transformers, the efficiencies selected using the minimum LCC 

produced inconsistencies in the stringency of the single-phase and three-phase efficiency 

requirements. Appendix 8I of the TSD provides a detailed discussion of the three-phase to singephase inconsistencies in the NOPR standard levels and DOE’s response to thies issue. To resolve 

the issue of inconsistencies between single-phase and three-phase efficiency levels, DOE 

formulated four recombined efficiency levels to evaluate for the final rule. The recombined levels 

maintain exact consistency between the single-phase and three-phase efficiency levels for TSL A, 

B, and C and approximate single-phase and three-phase consistence for TSL D. 

TSL A: Combination of a DL1 TSL5, and a DL3 TSL4 

TSL B: Combination of a DL4 TSL2, and a DL5 TSL4 

TSL C: Combination of a DL4 TSL2, and a DL5 TSL3 

TSL D: Combination of a DL1 TSL4, a DL4 TSL2, a DL3 TSL2, and a DL5 TSL3 

Tables EA.3 through EA.10 provide the precise definitions of the efficiency levels for each 

product class. 

For medium-voltage dry-type transformers, DOE selected TSL 2 while for liquidimmersed transformers DOE selected TSL C. Tables EA.1 and EA.2 summarize the adopted 

standard levels for the liquid-immersed and medium-voltage, dry-type transformers. 

EA-3 
Table EA.1 Adopted Standard Levels for Liquid-Immersed Distribution Transformers 

Single-Phase Adopted Efficiency Level 

TSLC 

Three-Phase Adopted Efficiency Level 

TSLC 

kVA 

PC 1 

Efficiency 

(%) 

kVA 

PC 2 

Efficiency 

(%) 

10 98.62 15 98.36 

15 98.76 30 98.62 

25 98.91 45 98.76 

37.5 99.01 75 98.91 

50 99.08 112.5 99.01 

75 99.17 150 99.08 

100 99.23 225 99.17 

167 99.23 300 99.23 

250 99.31 500 99.27 

333 99.36 750 99.31 

500 99.42 1000 99.36 

667 99.46 1500 99.42 

833 99.49 2000 99.46 

2500 99.49 

Note: All efficiency values are at 50% of nameplate rated load, determined according to the DOE test procedure. 

EA-4 
Table EA.2 Adopted Standard Levels for Medium-Voltage, Dry-Type Distribution 

Transformers 

Single-Phase Adopted Efficiency Level Three-Phase Adopted Efficiency Level 

TSL2 TSL2 

PC5 PC7 PC9 PC6 PC8 PC10 

kVA 20-45kV 

BIL 

46-95kV 

BIL 

$96kV 

BIL kVA 20-45kV BIL 

46-95kV 

BIL 

$96kV 

BIL 

(%) (%) (%) (%) (%) (%) 

15 98.10 97.86 - 15 97.50 97.19 -

25 98.33 98.12 - 30 97.90 97.63 -

37.5 98.49 98.30 - 45 98.10 97.86 -

50 98.60 98.42 - 75 98.33 98.12 -

75 98.73 98.57 98.53 112.5 98.49 98.30 -

100 98.82 98.67 98.63 150 98.60 98.42 -

167 98.96 98.83 98.80 225 98.73 98.57 98.53 

250 99.07 98.95 98.91 300 98.82 98.67 98.63 

333 99.14 99.03 98.99 500 98.96 98.83 98.80 

500 99.22 99.12 99.09 750 99.07 98.95 98.91 

667 99.27 99.18 99.15 1000 99.14 99.03 98.99 

833 99.31 99.23 99.20 1500 99.22 99.12 99.09 

2000 99.27 99.18 99.15 

2500 99.31 99.23 99.20 

Note: All efficiency values are at 50% of nameplate rated load, determined according to the DOE test procedure. 

3.0 ALTERNATIVES, INCLUDING THE ACTION 

DOE analyzed 11 alternative standards levels for liquid-immersed transformers and seven 

for medium-voltage, dry-type transformers. For the liquid-immersed transformers the alternatives 

consisted of the six TSLs identified in the NOPR, four recombinations and a no-action alternative. 

As discussed above, DOE’s adopted action is to propose TSL 2 for medium-voltage, dry-type 

transformers and TSL C for liquid-immersed transformers. The following sections discuss the 11 

liquid-immersed alternatives and the seven medium-voltage dry-type transformers alternatives. 

3.1 No-Action Alternative 

Under a no-action alternative, DOE would not publish new minimum energy-efficiency 

standards for distribution transformers. DOE addresses the no-action alternative in the TSD, 

including the regulatory impact analysis (RIA), along with other non-regulatory policy cases and 

EA-5 
voluntary incentive programs. The RIA found that the no-action alternative would result in 

insufficient reductions in energy consumption as compared to other alternatives, including DOE’s 

adopted action. 

3.2 Adopted Action 

DOE’s action is to adopt TSL C for liquid-immersed transformers and TSL 2 for mediumvoltage, dry-type transformers (as identified in Tables EA.1 and EA.2), which would result in 

national energy savings, reduced average LCC for consumers, a net national benefit (i.e., 

monetary savings to the Nation exceed increased equipment costs to the Nation), and air-borne 

emissions reductions. The adopted action would also result in a reduction in industry net present 

value, but DOE believes the amount is not significant. In this final rule, DOE determined that the 

benefits of the adopted action outweighed its burdens and that the action is economically justified. 

DOE concluded that the adopted action would save a significant amount of energy and is 

technologically feasible. The adopted action goes into effect in the year 2010. Additional details 

on estimated impacts resulting from the adopted action and other TSLs are provided in the TSD. 

3.3 Alternative Standards 

This EA also presents the results of the environmental impacts from five other distribution 

transformer TSLs for medium-voltage, dry-type transformers and nine other TSLs for liquidimmersed transformers—besides those from DOE’s adopted action (TSL 2 and TSL C 

respectively). Each TSL is an alternative action, which DOE compared with the no-action 

alternative. (In the no-action alternative, also referred to as the base case, no new amended 

standards are adopted.) Each TSL has a unique combination of efficiency levels associated with 

it. Tables EA.3 through EA.10 show each TSL, including DOE’s adopted action, by product 

class. Each of the tables also indicate the specific engineering design lines (DL) associated with 

that particular product class at the transformer capacity associated with the particular design lines. 

DOE performed a detailed engineering and economic analysis for each design line and then 

extrapolated the results to the product class to estimate the economic and engineering impacts of 

alternative standards for the entire population of transformers. Chapter 5 of the TSD presents the 

engineering analysis for each of the transformers design lines, while Chapter 8 of the TSD 

presents the consumer economic impacts for each engineering design line. 

EA-6 
Table EA.3 Trial Standard Levels for PC 1 Liquid-Immersed, Medium-Voltage, 

Single-Phase Distribution Transformers 

Product Trial Standard Level 

Class 1 

0 1 2 3 4 5 6 A B C D 

Desig kVA Ave. Min. TP 1 Max 

n Ba se Ba se Tech. 

Line Case Eff. Ca se 

Eff. 

10 98.42 97.77 98.4 98.40 98.44 98.48 98.69 99.32 98.79 98.62 98.62 98.48 

15 98.57 97.99 98.6 98.56 98.59 98.63 98.82 99.39 98.91 98.76 98.76 98.63 

DL2 25 98.74 98.23 98.7 98.73 98.76 98.79 98.96 99.46 99.04 98.91 98.91 98.79 

37.5 98.86 98.40 98.8 98.85 98.88 98.91 99.06 99.51 99.13 99.01 99.01 98.91 

DL1 50 98.97 98.56 98.9 98.90 98.90 99.04 99.19 99.59 99.19 99.08 99.08 99.04 

75 99.04 98.66 99.0 99.04 99.06 99.08 99.21 99.59 99.27 99.17 99.17 99.08 

100 99.11 98.75 99.0 99.10 99.12 99.14 99.26 99.62 99.32 99.23 99.23 99.14 

167 99.22 98.90 99.1 99.21 99.23 99.25 99.35 99.66 99.40 99.32 99.32 99.25 

250 99.24 98.89 99.2 99.26 99.36 99.45 99.69 99.70 99.45 99.37 99.31 99.26 

333 99.29 98.97 99.2 99.31 99.40 99.49 99.71 99.72 99.49 99.41 99.36 99.31 

DL3 500 99.36 99.07 99.3 99.38 99.46 99.54 99.74 99.75 99.54 99.47 99.42 99.38 

667 99.40 99.13 99.4 99.42 99.50 99.57 99.76 99.77 99.57 99.51 99.46 99.42 

833 99.44 99.18 99.4 99.45 99.52 99.60 99.77 99.78 99.60 99.53 99.49 99.45 

EA-7 
Table EA.4 Trial Standard Levels for PC 2 Liquid-Immersed, Medium-Voltage, 

Three-Phase Distribution Transformers 

Product Trial Standard Level 

Class 2 

0 1 2 3 4 5 6 A B C D 

Design kVA Ave. Min. TP 1 Max 

Line Base Base Tech. 

Case Case 

Eff. Eff, 

15 98.06 97.19 98.1 98.36 98.68 98.68 99.25 99.31 98.56 98.36 98.36 98.36 

30 98.37 97.64 98.4 98.62 98.89 98.89 99.37 99.42 98.79 98.62 98.62 98.62 

45 98.53 97.87 98.6 98.76 99.00 99.00 99.43 99.47 98.91 98.76 98.76 98.76 

75 98.70 98.12 98.7 98.91 99.12 99.12 99.50 99.54 99.04 98.91 98.91 98.91 

112.5 98.83 98.30 98.8 99.01 99.20 99.20 99.55 99.58 99.13 99.01 99.01 99.01 

DL4 150 98.91 98.42 98.9 99.08 99.26 99.26 99.58 99.61 99.19 99.08 99.08 99.08 

225 99.02 98.57 99.0 99.17 99.33 99.33 99.62 99.65 99.27 99.17 99.17 99.17 

300 99.08 98.67 99.0 99.23 99.38 99.38 99.65 99.67 99.32 99.23 99.23 99.23 

500 99.19 98.83 99.1 99.32 99.45 99.45 99.69 99.71 99.40 99.32 99.32 99.32 

750 99.24 98.97 99.2 99.24 99.31 99.37 99.66 99.66 99.45 99.37 99.31 99.31 

1000 99.29 99.04 99.2 99.29 99.36 99.41 99.68 99.68 99.49 99.41 99.36 99.36 

DL5 1500 99.36 99.13 99.3 99.36 99.42 99.47 99.71 99.71 99.54 99.47 99.42 99.42 

2000 99.40 99.19 99.4 99.40 99.46 99.51 99.73 99.73 99.57 99.51 99.46 99.46 

2500 99.44 99.23 99.4 99.44 99.49 99.53 99.74 99.74 99.60 99.53 99.49 99.49 

EA-8 
Table EA.5 Trial Standard Levels for PC 5 Dry-Type, Medium-Voltage, Single-Phase 

Distribution Transformers (20-45 kV BIL) 

Product 

Class 5 

Trial Standard Level 

0 1 2 3 4 5 6 

Design 

Line 

kVA Ave. Base 

Case Eff. 

Min. Base 

Case Eff. 

TP 1 Max 

Tech. 

15 98.02 97.45 97.6 98.10 98.46 98.81 99.05 99.05 

25 98.26 97.75 97.9 98.33 98.64 98.95 99.17 99.17 

37.5 98.43 97.97 98.1 98.49 98.77 99.05 99.25 99.25 

50 98.54 98.11 98.2 98.60 98.86 99.12 99.30 99.30 

75 98.68 98.29 98.4 98.73 98.97 99.20 99.37 99.37 

DL9 100 98.77 98.41 98.5 98.82 99.04 99.26 99.41 99.41 

167 98.92 98.60 98.8 98.96 99.16 99.35 99.48 99.48 

250 99.01 98.56 98.9 99.05 99.17 99.27 99.42 99.42 

333 99.08 98.66 99.0 99.11 99.23 99.32 99.46 99.46 

DL10 500 99.17 98.79 99.1 99.20 99.30 99.39 99.51 99.51 

667 99.23 98.87 99.2 99.26 99.35 99.43 99.54 99.54 

833 99.27 98.93 99.2 99.30 99.38 99.46 99.57 99.57 

EA-9 
Table EA.6 Trial Standard Levels for PC 6 Dry-Type, Medium-Voltage, Three-Phase 

Distribution Transformers (20-45 kV BIL) 

Product 

Class 6 

Trial Standard Level 

0 1 2 3 4 5 6 

Design 

Line 

kVA Ave. Base 

Case Eff. 

Min. Base 

Case Eff. 

TP 1 Max Tech. 

15 97.40 96.64 96.8 97.50 97.97 98.44 98.75 98.75 

30 97.81 97.17 97.3 97.90 98.29 98.68 98.95 98.95 

45 98.02 97.45 97.6 98.10 98.46 98.81 99.05 99.05 

75 98.26 97.75 97.9 98.33 98.64 98.95 99.17 99.17 

112.5 98.43 97.97 98.1 98.49 98.77 99.05 99.25 99.25 

150 98.54 98.11 98.2 98.60 98.86 99.12 99.30 99.30 

225 98.68 98.29 98.4 98.73 98.97 99.20 99.37 99.37 

DL9 300 98.77 98.41 98.6 98.82 99.04 99.26 99.41 99.41 

500 98.92 98.60 98.8 98.96 99.16 99.35 99.48 99.48 

750 99.01 98.56 98.9 99.05 99.17 99.27 99.42 99.42 

1000 99.08 98.66 99.0 99.11 99.23 99.32 99.46 99.46 

DL10 1500 99.17 98.79 99.1 99.20 99.30 99.39 99.51 99.51 

2000 99.23 98.87 99.2 99.26 99.35 99.43 99.54 99.54 

2500 99.27 98.94 99.2 99.30 99.38 99.46 99.57 99.57 

EA-10 
Table EA.7 Trial Standard Levels for PC 7 Dry-Type, Medium-Voltage, Single-Phase 

Distribution Transformers (46-95 kV BIL) 

Product 

Class 7 

Trial Standard Level 

0 1 2 3 4 5 6 

Design 

Line 

kVA Ave. Base 

Case Eff. 

Min. Base 

Case Eff. 

TP 1 Max Tech. 

15 97.46 96.87 97.6 97.86 98.14 98.41 98.54 98.54 

25 97.77 97.24 97.9 98.12 98.36 98.60 98.71 98.71 

37.5 97.98 97.51 98.1 98.30 98.52 98.73 98.84 98.84 

50 98.12 97.68 98.2 98.42 98.62 98.82 98.92 98.92 

75 98.30 97.90 98.4 98.57 98.75 98.94 99.02 99.02 

DL11 100 98.42 98.05 98.5 98.67 98.84 99.01 99.09 99.09 

167 98.61 98.28 98.8 98.83 98.98 99.13 99.20 99.20 

250 99.02 98.58 98.9 98.95 99.08 99.23 99.42 99.42 

333 99.09 98.68 99.0 99.03 99.15 99.28 99.46 99.46 

DL12 500 99.18 98.81 99.1 99.12 99.23 99.35 99.51 99.51 

667 99.24 98.89 99.2 99.18 99.28 99.40 99.54 99.54 

833 99.28 98.95 99.2 99.23 99.32 99.43 99.57 99.57 

Note: Because the representative units for both of the underlying DLs for PC 7 (DL 11 and DL 12) were 95 kV 

BIL, for kVA ratings from 167 through 833, the value in the “TP 1” column is the NEMA TP 1 value for >60 kV 

BIL. 

EA-11 
Table EA.8 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers (46-95 

kV BIL) 

Product Trial Standard Level 

Class 8 

0 1 2 3 4 5 6 

Design kVA Ave. Min. TP 1 Max 

Line Base Base Tech. 

Case Eff. Case Eff. 

15 96.66 95.88 96.8 97.19 97.55 97.91 98.08 98.08 

30 97.19 96.53 97.3 97.63 97.94 98.24 98.38 98.38 

45 97.46 96.87 97.6 97.86 98.14 98.41 98.54 98.54 

75 97.77 97.24 97.9 98.12 98.36 98.60 98.71 98.71 

112.5 97.98 97.51 98.1 98.30 98.52 98.73 98.84 98.84 

150 98.12 97.68 98.2 98.42 98.62 98.82 98.92 98.92 

225 98.30 97.90 98.4 98.57 98.75 98.94 99.02 99.02 

DL11 300 98.42 98.05 98.5 98.67 98.84 99.01 99.09 99.09 

500 98.61 98.28 98.8 98.83 98.98 99.13 99.20 99.20 

750 99.02 98.58 98.9 98.95 99.08 99.23 99.42 99.42 

1000 99.09 98.68 99.0 99.03 99.15 99.28 99.46 99.46 

DL12 1500 99.18 98.81 99.0 99.12 99.23 99.35 99.51 99.51 

2000 99.24 98.89 99.2 99.18 99.28 99.40 99.54 99.54 

2500 99.28 98.95 99.2 99.23 99.32 99.43 99.57 99.57 

Note: Because the representative units for both of the underlying DLs for PC 8 (DL 11 and DL 12) were 95 kV 

BIL, for kVA ratings from 300 through 2500, the value in the “TP 1”column is the NEMA TP 1 value for >60 kV 

BIL. 

EA-12 
Table EA.9 Dry-Type, Medium-Voltage, Single-Phase Distribution Transformers ($96 

kV BIL) 

Product 

Class 9 

Trial Standard Level 

0 1 2 3 4 5 6 

Design 

Line 

kVA Ave. Base 

Case Eff. 

Min. Base 

Case Eff. 

TP 1 Max Tech. 

75 98.72 98.22 98.4 98.53 98.79 99.05 99.22 99.22 

100 98.81 98.34 98.5 98.63 98.88 99.12 99.28 99.28 

167 98.95 98.54 98.7 98.80 99.01 99.22 99.36 99.36 

250 99.05 98.68 98.8 98.91 99.11 99.30 99.42 99.42 

333 99.12 98.77 98.9 98.99 99.17 99.35 99.46 99.46 

500 99.20 98.89 99.0 99.09 99.25 99.41 99.52 99.52 

DL13 667 99.26 98.97 99.0 99.15 99.30 99.45 99.55 99.55 

833 99.30 99.03 99.1 99.20 99.34 99.48 99.57 99.57 

EA-13 
Table EA.10 Dry-Type, Medium-Voltage, Three-Phase Distribution Transformers ($96 

kV BIL) 

Product 

Class 10 

Trial Standard Level 

0 1 2 3 4 5 6 

Design 

Line 

kVA Ave. Base 

Case Eff. 

Min. Base 

Case Eff. 

TP 1 Max Tech. 

225 98.72 98.22 98.4 98.53 98.79 99.05 99.22 99.22 

300 98.81 98.34 98.5 98.63 98.88 99.12 99.28 99.28 

500 98.95 98.54 98.7 98.80 99.01 99.22 99.36 99.36 

750 99.05 98.68 98.8 98.91 99.11 99.30 99.42 99.42 

1000 99.12 98.78 98.9 98.99 99.17 99.35 99.46 99.46 

1500 99.20 98.89 99.0 99.09 99.25 99.41 99.52 99.52 

DL13 2000 99.26 98.97 99.0 99.15 99.30 99.45 99.55 99.55 

2500 99.30 99.03 99.1 99.20 99.34 99.48 99.57 99.57 

4.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT 

4.1 Geography 

The distribution transformer standard that DOE has adopted–TSL 2 for medium-voltage, 

dry-type and TSL C for liquid-immersed–would apply to all 50 States and United States 

territories. 

4.2 Air Resources 

The primary focus of the EA is the effect of adopted efficiency standards on air resources. 

For this analysis, the EA used a variant of the DOE Energy Information Administration (EIA)’s 

National Energy Modeling System (NEMS), called NEMS-BT (BT is DOE’s Building 

Technologies Program).a

 As described in section 4.2.1 below, the environmental analysis is 

similar to the utility impact analysis described in Chapter 13 of the TSD.5

 Outputs of the 

environmental analysis are in a format similar to the results of the EIA’s Annual Energy Outlook 

6 2006 (AEO2006). 

a

 The EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is run 

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it as NEMS-BT. 

NEMS-BT was previously called NEMS-BRS. 

EA-14 
For each of the energy-efficiency standard levels, DOE calculated total power-sector 

emissions based on output from NEMS-BT. The EA considers one emission, carbon dioxide 

(CO2). An air pollutant is any substance in the air that can cause harm to humans or the 

environment. Pollutants may be natural or man-made and may take the form of solid particles, 

liquid droplets, or gases. The Clean Air Act Amendments of 1990 list 188 toxic air pollutants that 

the U.S. Environmental Protection Agency (EPA) is required to control. The EPA has set 

national air-quality standards for six common pollutants (also referred to as “criteria” pollutants), 

two of which are SO2 and NOx. Also, the Clean Air Act Amendments of 1990 gave authority to 

EPA to control acidification and to require operators of electric power plants to reduce emissions 

of SO2 and NOx. In addressing SO2 emissions, the Clean Air Act Amendments of 1990 set an SO2 

emissions cap on all power generation, but permitted flexibility among generators through the use 

of emissions allowances and tradable permits. This SO2 trading implies that physical emissions 

effects of a standard is likely to be zero because emissions will always be at, or near, the allowed 

ceiling. Consequently, there is no direct SO2 environmental benefit from electricity conservation, 

as long as there is enforcement of the emissions ceiling. But to the extent reduced power 

generation demand decreases the demand for and price of emissions allowance permits, there is 

potentially an environmentally related economic benefit from standards reducing SO2 emissions 

allowance demand. 

In March 2005, EPA legislated the Clean Air Interstate Rule (CAIR). This rule was 

designed to further reduce atmospheric releases of ozone and particulate matter and therefore 

targets NOx and SO2 emissions. Applicable to 28 States and the District of Columbia, all fossilfueled boilers and turbines greater than 25 MW including CHP units greater than 25 MW are 

required to reduce their NOx and SO2 emissions in a two-phase program. Under CAIR, States are 

responsible for allocating emissions allowances, giving emitters the choice of participating in capand-trade programs or adopting control technologies to meet their requirements. 

Carbon dioxide is of interest because of its classification as a greenhouse gas and its 

impact on global climate change. Greenhouse gases — which trap the sun’s radiation inside the 

Earth’s atmosphere — either occur naturally in the atmosphere or result from human activities. 

Naturally occuring greenhouse gases include water vapor, CO2, methane (CH4), nitrous oxide, 

and ozone. Human activities, however, add to the levels of most of these naturally occurring 

gases. For example, CO2 is emitted to the atmosphere when solid waste, fossil fuels (oil, natural 

gas, and coal), wood, and wood products are burned. During the past 20 years, about 

three-quarters of anthropogenic (i.e., human-made) CO2 emissions resulted from burning fossil 

fuels. Concentrations of CO2 in the atmosphere are naturally regulated by numerous processes, 

collectively known as the “carbon cycle.” The movement of carbon between the atmosphere and 

the land and oceans is dominated by natural processes, such as plant photosynthesis. While these 

natural processes can absorb some of the anthropogenic CO2 emissions produced each year, 

billions of metric tons are added to the atmosphere annually. The Earth’s positive imbalance 

between emissions and absorption results in the continuing growth in greenhouse gases in the 

atmosphere, thereby causing surface air temperatures and sub-surface ocean temperatures to rise. 

The U.S. CO2 emissions from both energy consumption and industrial processes account for 84.6 

percent of total U.S. greenhouse gas emissions.7 

EA-15 
4.2.1 Assumptions 

In its forecasts of air resources impacts using NEMS-BT, DOE conducted the EA as a 

policy deviation from the typical meteorological year (TMY) System Load Reference Case, a 

modified AEO2006 Reference Case, using the same basic set of assumptions. The emissions 

b characteristics of all electricity-generating plants are exactly as those used in AEO2006. The 

TMY System Load Reference Case and alternative growth scenarios are as described in the utility 

impact analysis of the TSD (Chapter 13). DOE derived the environmental impacts of the adopted 

standard using the same higher decrement, double-decrement approach described in the utility 

impact analysis. 

As in the utility impact analysis, DOE substituted the default NEMS system load with a 

system load that represents weather conditions for a TMY—here referred to as the TMY system 

load. As a result, the reference case used to judge the impacts from a adopted distribution 

transformer standard is no longer an exact replication of the AEO2006 Reference Case and is 

therefore referred to as the TMY System Load Reference Case. 

The EA also includes a sensitivity analysis for the adopted standard level, using the High 

and Low Economic Growth scenarios of NEMS-BT. As described in Chapter 13 of the TSD, 

these scenarios cover a range of macro-economic growth assumptions. 

4.2.2 Methods 

CO2. The NEMS-BT tracks CO2 emissions using a detailed CO2 module that features 

broad coverage of all sectors and includes interactive effects. Past experience with NEMSgenerated CO2 emissions suggests estimates are somewhat lower than estimates based on simple 

average factors. One of the reasons for this divergence is that NEMS tends to predict that 

conservation displaces more-efficient generating capacity in the later years of its forecast. 

Power Sector NOx and Hg. The NEMS-BT reports the two airborne pollutant emissions 

that DOE has considered in past analyses, SO2 and NOx and now also reports Hg emissions. The 

NEMS-BT estimates NOx and Hg emissions from power generation by assuming that the power 

sector conforms to all pre-2005 legislation and regulations with respect to monitoring power 

facility development, retrofitting, and dispatch, including potential installations of emissionsb

 While the AEO2007 electricity price forecast data was available in time for preparation of this final rule, the full 

AEO2007 forecast was not available at the time DOE performed the utility and environmental impact analysis. 

DOE therefore used AEO2006 for the utility and environmental analysis. Following completion of the utility and 

environmental analysis and after the full AEO 2007 became available, DOE compared the AEO2006 and AEO2007 

and found the forecasts of electricity prices, the marginal generation mix and emissions factors in the AEO2007 

and AEO2006 forecasts were very similar. The two forecasts provide the same marginal fractions of coal and 

natural gas generation (within 3.5%), and have marginal CO2 emission factors that differ by less than 2%. DOE 

provides details of the AEO2006 and AEO2007 comparison in Chapter 13 of the TSD 

EA-16 
reducing equipment (i.e., scrubbers). Three recent regulatory actions adopted by the 

EPA—regarding (1) regulations and guidelines for best-available retrofit technology 

determinations, (2) the reduction of interstate transport of fine particulate matter and ozone—are 

tending toward further NOx reductions and has lead to an emissions cap on NOx for the Eastern 

United States. 69 FR 25184 (May 5, 2004), 69 FR 32684 (June 10, 2004), and 70 FR 25162 

(May 12, 2005), and (3) the recent promulgation of the mercury emissions rule has resulted in a 

cap on Hg emissions 70 FR 28606 (May 18, 2005). As with SO2 emissions, a cap on NOx and Hg 

emissions will likely result in no physical emissions effects from equipment efficiency standards. 

Because NOx and Hg have been regulated with emissions caps, and no emissions reductions are 

reported from the NEMS-BT forecast model, DOE does not report NOx and Hg results here. 

Power Sector SO2. As explained above, accurate simulation of SO2 trading tends to imply 

that physical emissions effects will be zero, as long as emissions are at the allowed ceiling. 

Because SO2 has been regulated with emissions caps for more than a decade, and no emissions 

reductions are reported from the NEMS-BT forecast model, DOE does not report SO2 results 

here. 

Fuel-Cycle Emissions. Fuel-cycle emissions refer to the emissions associated with the 

amount of energy used in the upstream production and downstream consumption of electricity, 

including energy used at the power plant. Upstream processes include the mining of coal or 

extraction of natural gas, physical preparatory and cleaning processes, and transportation to the 

power plant. he NEMS-BT does a thorough accounting of emissions at the power plant due to 

downstream energy consumption, but does not account for upstream emissions (i.e., emissions 

from energy losses during coal and natural gas production). Thus, this EA reports only power 

plant emissions. 

Interpolation. Because the energy savings from distribution transformer standards are too 

small to produce stable power sector results in NEMS-BT, DOE estimated results for the TSLs 

using interpolation. To run a simulation in NEMS-BT, the system electricity load and commercial 

demand use are reduced annually according to the energy savings estimated by the national energy 

savings (NES) Spreadsheet Model (see Chapter 10 of the TSD) for each TSL. These energy 

savings increase over time. The magnitude of the energy decrement that would be required for 

NEMS-BT to produce stable results out of the range of numerical noise is greater than the highest 

standard level under consideration. Therefore, to estimate results for the TSLs considered here, 

DOE carried out a series of NEMS-BT runs using higher values for the input energy savings. 

These runs established the relationship between the NEMS-BT outputs (e.g., installed capacity 

reductions, emissions reductions) and the energy savings inputs. DOE then obtained results for 

energy savings corresponding to the TSLs using linear interpolation. 

DOE then used the estimated reduction in total fuel generation at each TSL, as determined 

by interpolation, to determine emissions savings. First, it calculated annual marginal emissions 

rates for each of the simulations in each standard level, based on the actual output from NEMSBT. Marginal emissions rates incorporate both effects of the standards—the emissions saved by 

the reduction in total generation, and the slight change in the emissions characteristics of the 

EA-17 
whole power sector that result from the slight change in dispatch and capacity expansion plan. 

The net effect on the entire system is very small and, typically, the overall effect on emissions can 

be fully attributed to the reduced generation capacity. DOE could then determine annual marginal 

emissions rates at the trial standard level from these rates (at multipliers of the TSL savings), by 

taking a simple average. 

Extrapolation. The current time horizon of NEMS-BT is 2030 (modeling a 20-year 

period, 2010–2030); however, other parts of the distribution transformer rulemaking analysis 

extend to 2038. It is not feasible to extend the forecast period of NEMS-BT for the purposes of 

this analysis nor does DOE/EIA have an approved method for extrapolation of many outputs 

beyond 2030. While it might seem reasonable in general to make simple linear extrapolations of 

results, in practice this is not advisable because outputs could be contradictory. For example, 

changes in the fuel mix implied by extrapolations of those outputs could be inconsistent with the 

extrapolation of marginal emissions factors. An analysis of various trends sufficiently detailed to 

guarantee consistency is beyond the scope of this work, and, in any case, would involve a great 

deal of uncertainty. Therefore, all extrapolations beyond 2030 are simple replications of year 

2030 results. While these may seem unreasonable in some instances, in this way results are 

guaranteed to be consistent. As with the AEO Reference Case in general, the implicit assumption 

is that the regulatory environment does not deviate from the current known situation during the 

extrapolation period. Only changes that have been announced with date-certain introduction are 

included in NEMS-BT. To emphasize the extrapolated results wherever they appear, they are 

shaded in grey to distinguish them from actual NEMS-BT results. 

4.3 Socioeconomics 

As part of the rulemaking process, DOE evaluated the socioeconomic effect on small 

businesses, especially small manufacturers, a subgroup that DOE identified as possibly being 

disproportionately affected by a national standard level. Converting from a company’s current 

basic product line involves designing, prototyping, testing, and manufacturing a new product. 

These tasks have associated capital investments and product conversion expenses. Small 

businesses, because of their limited access to capital and their need to spread product conversion 

expenses over smaller production volumes, may be affected more negatively than major 

manufacturers by an energy-conservation standard. For these reasons, DOE specifically evaluated 

the impacts on small businesses from an energy-conservation standard. Chapter 12 of the TSD 

provides more details on the manufacturer subgroup analysis. 

4.4 Environmental Justice 

According to Executive Order 12898 of February 11, 1994, "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations," 59 FR 7629 

(February 16, 1994), DOE is required to examine the effect of more stringent energy efficiency 

standards on (1) small businesses that either manufacture or use distribution transformers, (2) 

EA-18 
manufacturers of niche products related to distribution transformers, and (3) small businesses 

operated by disadvantaged or minority populations. 

Regarding users of distribution transformers, small businesses are included as part of the 

overall population examined by DOE in the LCC analysis. The results of that analysis estimated 

that between 26 and 61 percent of distribution transformer customers would experience positive 

economic impacts from the proposed standard. 

Small distribution transformer manufacturing enterprises, as defined by the Small Business 

Administration, are those with no more than 750 employees. DOE identified and interviewed six 

small manufacturers of distribution transformers, five of which produce medium-voltage, dry-type 

transformers and one of which produces liquid-immersed transformers. Because the 

liquid-immersed distribution transformer industry largely produces customized transformers, small 

businesses can compete because each unique design is produced in relatively small volumes for a 

given customer's order. Implementation of an energy conservation standard would have a 

relatively minor differential impact on small manufacturers of liquid-immersed distribution 

transformers. 

Because of the potential impacts of a standard on manufacturers of the medium-voltage, 

dry-type transformers, DOE determined that it cannot certify that the proposed rule (TSL2), if 

promulgated, would have no significant economic impact on a substantial number of small 

entities. Because DOE cannot certify this, due to the potential impacts on medium-voltage, 

dry-type manufacturers, it prepared an initial regulatory flexibility analysis (IRFA) for this 

rulemaking, which can be found in section VI.B of the NOPR. For additional information on this 

subject, see also section V.B.2.b of the NOPR and the manufacturer impact analysis (MIA) in 

Chapter 12 of the TSD. 

DOE did not conduct a separate analysis to assess the impacts of a new standard on niche 

product manufacturers because it found no niche products for which the adoption of a new 

standard would raise special considerations. 

DOE's LCC subgroup analysis (TSD Chapter 11) did not include small or disadvantaged 

businesses or populations as a subgroup. However, DOE believes that there are no 

disproportionately high and adverse human health or environmental effects on minority 

populations, and low-income populations resulting from more stringent energy efficiency 

standards. Positive impacts, such as decreased air emissions, would be equally shared among all 

populations. 

The MIA (TSD Chapter 12), and the regulatory impact analysis (published with the TSD) 

examined impacts on various business populations. However, DOE received no data concerning 

differential impacts on businesses owned by minority or disadvantaged populations. 

EA-19 
4.5 Energy Consumption 

DOE used a detailed shipments and NES Spreadsheet Model to determine national energy 

savings as a result of increases in the minimum efficiency standard. This spreadsheet model 

forecasts the national shipments and energy use of distribution transformers with and without new 

standards. The shipments and NES analyses are described in detail in TSD Chapters 9 and 10, 

respectively. 

4.6 Noise and Aesthetics 

DOE considered how new energy conservation standards for distribution transformers 

may affect the noise and aesthetics of the equipment. To improve the efficiency of distribution 

transformers, increased amounts of heavier materials (e.g., steel) may be used that can enlarge the 

size of the equipment. DOE reviewed these components to determined if noise and aesthetics 

were impacted. DOE determined that the adopted standard would result in less than 10% increase 

in the volume distribution transformers and that the higher efficiency transformers are likely to 

have the same noise characteristics as existing transformers. Therefore, DOE estimates that there 

will be no significant impact on noise and aesthetics from the adopted standard. 

5.0 ENVIRONMENTAL IMPACTS 

5.1 Air Quality/Emissions Impacts 

5.1.1 Power Sector Emissions 

The results for the environmental analysis are similar to a complete NEMS run as 

published in the AEO2006, and include power sector emissions for CO2 in five-year forecast 

increments, extrapolated to the year 2038. DOE reports the outcome of the analysis for each 

TSL as a deviation from the TMY System Load Reference Case. This is also referred to as the 

base case. 

As discussed in section 4.2, the Clean Air Act Amendments of 1990 set an SO2 emissions 

cap on all power generation, but permitted flexibility among generators through the use of 

emissions allowances and tradable permits. Similar rules provide power sector emissions caps on 

NOX and Hg. Moreover, emissions trading implies that physical emissions effects of a standard 

will be zero because emissions will always be at, or near, the ceiling. Consequently, there is 

virtually no physical emissions reduction benefit for these pollutants from electricity conservation 

as long as there is enforcement of the emissions ceiling. Even though there is no physical 

environmental benefit from adopted standards, there are potential environmental economic 

benefits. Given reduced demand for coal generation, there is reduced demand for emission 

allowances and this may lower the allowance price and traded allowance volume. For these 

reasons, DOE’s emissions reduction forecast from NEMS-BT indicated no significant emissions 

reductions from the adopted standard for SO2, NOX and Hg. Thus, DOE did not report these 

quantities. 

EA-20 
Tables EA.11 through EA.15 show annual total power sector CO2 emissions for the 

various distribution transformer TSLs for each superclass. The liquid-immersed class considers 

10 TSLs while the medium-volgate, dry-type class considers six TSLs. Annual CO2 emissions 

reductions are the highest for liquid-immersed TSL 6 and are the lowest for medium-voltage, drytype TSL 1. Tables EA.16 through EA.18 show the results for the cumulative emissions 

reductions through 2030 and 2038 for CO2. 

The results for the Low and High Economic Growth cases for the adopted standard of 

each product class are also shown in Tables EA.16 through EA.18. The differences between the 

reference and sensitivity cases are due to changes in the macroeconomic assumptions of NEMSBT. 

Reference Economic Growth 

Table EA.11 Liquid Immersed Power Sector Emissions 

NE MS-BT Resu lts 

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 2035 2038 

AEO 200 6 R efere nce C ase with TM Y Sys tem L oad 

CO2 (Mt/a)13 25 37 .0 26 72 .0 28 48 .0 30 38 .0 33 34 .0 Extrapolation 

Trial Standard Level 

1.0 CO2 (Mt/a) 25 37 .0 26 70 .3 28 45 .1 30 36 .2 33 25 .9 0 -1.7 -2.9 -1.8 -8.1 -8.1 -8.1 

2.0 CO2 (Mt/a) 25 37 .0 26 69 .6 28 43 .9 30 35 .5 33 22 .6 0 -2.4 -4.1 -2.5 -11 .4 -11 .4 -11 .4 

3.0 CO2 (Mt/a) 25 37 .0 26 68 .6 28 42 .2 30 34 .4 33 18 .0 0 -3.4 -5.8 -3.6 -16 .0 -16 .0 -16 .0 

4.0 CO2 (Mt/a) 25 37 .0 26 68 .3 28 41 .6 30 34 .1 33 16 .5 0 -3.7 -6.4 -3.9 -17 .5 -17 .5 -17 .5 

5.0 CO2 (Mt/a) 25 37 .0 26 65 .7 28 37 .1 30 31 .3 33 04 .1 0 -6.3 -10 .9 -6.7 -29 .9 -29 .9 -29 .9 

6.0 CO2 (Mt/a) 25 37 .0 26 62 .8 28 32 .2 30 28 .3 32 90 .6 0 -9.2 -15 .8 -9.7 -43 .4 -43 .3 -43 .3 

A CO2 (Mt/a) 25 37 .0 26 67 .0 28 39 .3 30 32 .7 33 10 .2 0 -5.0 -8.7 -5.3 -23 .8 -23 .8 -23 .8 

B CO2 (Mt/a) 25 37 .0 26 68 .6 28 42 .1 30 34 .4 33 17 .8 0 -3.4 -5.9 -3.6 -16 .2 -16 .2 -16 .2 

C CO2 (Mt/a) 25 37 .0 26 68 .8 28 42 .4 30 34 .6 33 18 .7 0 -3.2 -5.6 -3.4 -15 .3 -15 .3 -15 .3 

D CO2 (Mt/a) 25 37 .0 26 69 .3 28 43 .3 30 35 .1 33 21 .2 0 -2.7 -4.7 -2.9 -12 .8 -12 .8 -12 .8 

1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

EA-21 
Table EA.12 Dry Type Power Sector Emissions 

NE M S-BT Re sults


Emission
 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 

AEO 200 6 R efere nce C ase with TM Y Sys tem L oad 

CO2 (Mt/a)13 25 37 .0 26 72 .0 28 48 .0 30 38 .0 33 34 .0 

Trial Standard Level 

1 CO2 (Mt/a) 25 37 .0 26 71 .9 28 47 .9 30 37 .9 33 33 .6 0.0 -0.1 -0.1 -0.1 -0.4 

2 CO2 (Mt/a) 25 37 .0 26 71 .8 28 47 .7 30 37 .8 33 33 .2 0.0 -0.2 -0.3 -0.2 -0.8 

3 CO2 (Mt/a) 25 37 .0 26 71 .8 28 47 .6 30 37 .8 33 32 .9 0.0 -0.2 -0.4 -0.2 -1.1 

4 CO2 (Mt/a) 25 37 .0 26 71 .6 28 47 .3 30 37 .6 33 32 .0 0.0 -0.3 -0.6 -0.4 -1.6 

5 CO2 (Mt/a) 25 37 .0 26 71 .5 28 47 .1 30 37 .5 33 31 .6 0.0 -0.5 -0.9 -0.5 -2.4 

6 CO2 (Mt/a) 25 37 .0 26 71 .5 28 47 .1 30 37 .5 33 31 .6 0.0 -0.5 -0.9 -0.5 -2.4 

2035 2038 

-0.4 -0.4 

-0.8 -0.8 

-1.1 -1.1 

-1.6 -1.6 

-2.4 -2.4 

-2.4 -2.4 

Extrapolation 

1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

Low Economic Growth Power Sector Emissions 

Table EA.13 Liquid Immersed Low Economic Growth Power Sector Emissions 

NE M S-BT Re sults 

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 

AEO 200 6 L ow Growth C ase with TM Y Sys tem L oad 

CO2 (Mt/a)1,3 24 91 .0 26 01 .0 27 11 .0 28 28 .0 29 89 .0 

Trial Standard Level 

1 CO2 (Mt/a) 24 91 .0 25 99 .9 27 09 .0 28 24 .8 29 84 .7 0.0 -1.1 -2.0 -3.2 -4.3


2
 CO2 (Mt/a) 24 91 .0 25 99 .4 27 08 .2 28 23 .5 29 83 .0 0.0 -1.6 -2.8 -4.5 -6.0


3
 CO2 (Mt/a) 24 91 .0 25 98 .8 27 07 .1 28 21 .7 29 80 .5 0.0 -2.2 -3.9 -6.3 -8.5 

4 CO2 (Mt/a) 24 91 .0 25 98 .6 27 06 .7 28 21 .1 29 79 .7 0.0 -2.4 -4.3 -6.9 -9.3 

5 CO2 (Mt/a) 24 91 .0 25 96 .9 27 03 .7 28 16 .3 29 73 .1 0.0 -4.1 -7.3 -11 .7 -15 .9


6
 CO2 (Mt/a) 24 91 .0 25 95 .0 27 00 .4 28 11 .0 29 65 .9 0.0 -6.0 -10 .6 -17 .0 -23 .1


A
 CO2 (Mt/a) 24 91 .0 25 97 .7 27 05 .2 28 18 .7 29 76 .4 0.0 -3.3 -5.8 -9.3 -12 .6


B
 CO2 (Mt/a) 24 91 .0 25 98 .8 27 07 .1 28 21 .7 29 80 .4 0.0 -2.2 -3.9 -6.3 -8.6 

C CO2 (Mt/a) 24 91 .0 25 98 .9 27 07 .3 28 22 .0 29 80 .9 0.0 -2.1 -3.7 -6.0 -8.1 

D CO2 (Mt/a) 24 91 .0 25 99 .2 27 07 .9 28 23 .0 29 82 .2 0.0 -1.8 -3.1 -5.0 -6.8 

2035 2038 

-4.3 -4.3 

-6.0 -6.0 

-8.5 -8.5 

-9.3 -9.3 

-8.6 -8.6 

-8.1 -8.1 

-6.8 -6.8 

Extrapolation 

-15 .9 -15 .9 

-23 .0 -23 .0 

-12 .6 -12 .6 

1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

EA-22 
Table EA.14 Dry Type Low Economic Growth Power Sector Emissions 

NE M S-BT Re sults 

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 

AEO 200 6 L ow Growth C ase with TM Y Sys tem L oad 

CO2 (Mt/a)1,3 24 91 .0 26 01 .0 27 11 .0 28 28 .0 29 89 .0 

Trial Standard Level 

1 CO2 (Mt/a) 24 91 .0 26 00 .9 27 10 .9 28 27 .9 29 88 .8 0.0 -0.1 -0.1 -0.1 -0.2 

2 CO2 (Mt/a) 24 91 .0 26 00 .9 27 10 .8 28 27 .7 29 88 .6 0.0 -0.1 -0.2 -0.3 -0.4 

3 CO2 (Mt/a) 24 91 .0 26 00 .8 27 10 .7 28 27 .6 29 88 .4 0.0 -0.2 -0.3 -0.4 -0.6 

4 CO2 (Mt/a) 24 91 .0 26 00 .7 27 10 .5 28 27 .2 29 88 .0 0.0 -0.2 -0.4 -0.6 -0.8 

5 CO2 (Mt/a) 24 91 .0 26 00 .7 27 10 .4 28 27 .1 29 87 .7 0.0 -0.3 -0.6 -0.9 -1.3 

6 CO2 (Mt/a) 24 91 .0 26 00 .7 27 10 .4 28 27 .1 29 87 .7 0.0 -0.3 -0.6 -0.9 -1.3 

2035 2038 

-0.2 -0.2 

-0.4 -0.4 

-0.6 -0.6 

-0.8 -0.8 

-1.3 -1.3 

-1.3 -1.3 

Extrapolation 

1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

High Economic Growth Power Sector Emissions 

Table EA.15 Liquid Immersed High Economic Growth Power Sector Emissions 

NE M S-BT Re sults


Emission
 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 

AEO 200 6 H igh Gr owth C ase with TM Y Sys tem L oad 

CO2 (Mt/a)1,3 25 86 .0 27 64 .0 30 41 .0 33 39 .0 36 97 .0 

Trial Standard Level 

1 CO2 (Mt/a) 25 86 .0 27 62 .1 30 35 .9 33 33 .2 36 88 .3 0.0 -1.9 -5.1 -5.8 -8.7 

2 CO2 (Mt/a) 25 86 .0 27 61 .4 30 33 .8 33 30 .8 36 84 .8 0.0 -2.6 -7.2 -8.2 -12.2 

3 CO2 (Mt/a) 25 86 .0 27 60 .3 30 30 .8 33 27 .5 36 79 .8 0.0 -3.7 -10.2 -11.5 -17.2 

4 CO2 (Mt/a) 25 86 .0 27 59 .9 30 29 .9 33 26 .4 36 78 .2 0.0 -4.1 -11.1 -12.6 -18.8 

5 CO2 (Mt/a) 25 86 .0 27 57 .1 30 22 .0 33 17 .5 36 64 .9 0.0 -6.9 -19.0 -21.5 -32.1 

6 CO2 (Mt/a) 25 86 .0 27 53 .9 30 13 .4 33 07 .8 36 50 .5 0.0 -10.1 -27.6 -31.2 -46.5 

A CO2 (Mt/a) 25 86 .0 27 58 .5 30 25 .9 33 21 .9 36 71 .5 0.0 -5.5 -15.1 -17.1 -25.5 

B CO2 (Mt/a) 25 86 .0 27 60 .3 30 30 .7 33 27 .4 36 79 .6 0.0 -3.7 -10.3 -11.6 -17.4 

C CO2 (Mt/a) 25 86 .0 27 60 .5 30 31 .3 33 28 .0 36 80 .6 0.0 -3.5 -9.7 -11.0 -16.4 

D CO2 (Mt/a) 25 86 .0 27 61 .0 30 32 .9 33 29 .8 36 83 .2 0.0 -3.0 -8.1 -9.2 -13.8 

2035 2038 

-8.7 -8.7 

Extrapolation 

-12.2 -12.2 

-17.2 -17.2 

-18.8 -18.8 

-32.0 -32.0 

-46.5 -46.5 

-25.5 -25.5 

-17.4 -17.4 

-16.4 -16.4 

-13.8 -13.8 1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

EA-23 
Table EA.16 Dry Type High Economic Growth Power Sector Emissions 

NE MS-BT Resu lts 

Emission 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 

AEO 200 6 H igh Gr owth C ase with TM Y Sys tem L oad 

CO2 (Mt/a)1,3 25 86 .0 27 64 .0 30 41 .0 33 39 .0 36 97 .0 

Trial Standard Level 

1 CO2 (Mt/a) 25 86 .0 27 63 .9 30 40 .8 33 38 .7 36 96 .6 0.0 -0.1 -0.2 -0.3 -0.4 

2 CO2 (Mt/a) 25 86 .0 27 63 .8 30 40 .5 33 38 .4 36 96 .2 0.0 -0.2 -0.5 -0.6 -0.8 

3 CO2 (Mt/a) 25 86 .0 27 63 .7 30 40 .3 33 38 .2 36 95 .8 0.0 -0.3 -0.7 -0.8 -1.2 

4 CO2 (Mt/a) 25 86 .0 27 63 .5 30 39 .7 33 37 .6 36 94 .9 0.0 -0.4 -1.0 -1.2 -1.7 

5 CO2 (Mt/a) 25 86 .0 27 63 .4 30 39 .5 33 37 .3 36 94 .4 0.0 -0.6 -1.5 -1.7 -2.6 

6 CO2 (Mt/a) 25 86 .0 27 63 .4 30 39 .5 33 37 .3 36 94 .4 0.0 -0.6 -1.5 -1.7 -2.6 

2035 2038 

-0.4 -0.4 

-0.8 -0.8 

-1.2 -1.2 

-1.7 -1.7 

-2.6 -2.6 

-2.6 -2.6 

Extrapolation 

1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

Cumulative Power Sector Emission Impacts 

Table EA.17 Cumulative Power Sector Emissions Impacts for Liquid-Immersed 

Transformers 

Trial 

Standard 

Reference Low Economic Growth High Economic Growth 

Level Emission 2000-2030 2000-2038 2000-2030 2000-2038 2000-2030 2000-2038 

1 CO2 (Mt/a) -60.9 -125.7 -47.1 -81.6 -88.2 -157.7 

2 CO2 (Mt/a) -85.5 -176.4 -66.2 -114.5 -123.8 -221.3 

3 CO2 (Mt/a) -120.4 -248.4 -93.2 -161.2 -174.3 -311.7 

4 CO2 (Mt/a) -131.8 -271.9 -102.0 -176.5 -190.8 -341.1 

5 CO2 (Mt/a) -225.1 -464.0 -174.2 -301.2 -325.8 -582.1 

6 CO2 (Mt/a) -326.8 -673.6 -252.9 -437.2 -473.0 -845.0 

A CO2 (Mt/a) -179.0 -369.2 -138.5 -239.6 -259.1 -463.2 

B CO2 (Mt/a) -121.7 -251.1 -94.2 -163.0 -176.2 -315.0 

C CO2 (Mt/a) -115.1 -237.6 -89.1 -154.2 -166.7 -298.0 

D CO2 (Mt/a) -96.6 -199.3 -74.7 -129.4 -139.8 -250.0 1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

Table EA.18 Cumulative Power Sector Emissions Impacts for Dry-Type Transformers 

Trial 

Standard 

Level 

Emission 

Reference Low Economic Growth High Economic Growth 

2000-2030 2000-2038 2000-2030 2000-2038 2000-2030 2000-2038 

1 CO2 (Mt/a) -2.8 -5.8 -2.2 -3.8 -4.1 -7.4 

2 CO2 (Mt/a) -5.7 -11.8 -4.4 -7.6 -8.4 -15.0 

3 CO2 (Mt/a) -8.3 -17.1 -6.4 -11.0 -12.0 -21.6 

4 CO2 (Mt/a) -12.0 -24.8 -9.2 -16.0 -17.5 -31.4 

5 CO2 (Mt/a) -17.9 -36.9 -13.7 -23.8 -26.0 -46.7 

6 CO2 (Mt/a) -17.9 -36.9 -13.7 -23.8 -26.0 -46.7 1

Comparable to Table A1 7 of AEO 200 6: Electric Generators 

2

Comparable to Table A8 of AEO2 006 : Emissions 

3

All results in metric tons (t), equivalent to 1.1 short tons 

EA-24 
5.1.2 Discounted Emissions 

Table EA.19 provides DOE’s estimate of cumulative power sector CO2 for an uncapped 

emissions scenario for the TSLs considered in this rulemaking. Because of the Clean Air 

Interstate Rule (CAIR), which the EPA issued on March 10, 2005, will permanently cap 

emissions of NOX in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 

2005). As with sulfur dioxide emissions, for which a cap was previously in place, a cap on NOX 

emissions means that equipment efficiency standards may have no physical effect on these 

emissions. Similarly emissions of Hg for the power sector are also subject to emissions caps 

during the evaluation period, so that distribution transformer standards may similarly result in no 

physical effect on these emissions. DOE evaluated the emissions forecasts from AEO2006 and 

found that because of these new regulations capped most power sector NOX and Hg emissions, 

decreasing energy use from the adopted standard would not have any physical emissions reduction 

effects. The economic effects of emissions reductions are included in the forecasted projection of 

electricity prices and thus are included in DOE’s NPV analysis, but are not reported separately. 

DOE also calculated discounted values for future emissions, using the same seven-percent 

and three-percent real discount rates that it used in calculating the NPV. Table EA.19 also shows 

the discounted cumulative emissions impacts for both liquid-immersed and dry-type, mediumvoltage transformers. 

Table EA.19 Discounted CO2 Emissions Reductions of the Trial Standard Levels by 

Design Line (in millions of metric tons) 

Distribution 

Transformers 

Discount 

Rate % 

Trial Standard Level 

1 (TP 1) 2 3 4 5 6 A B C D 

0 125 176 248 272 464 674 369 251 238 199 

Liquid-Immersed 3 62 87 123 135 230 334 183 124 118 99 

7 27 38 53 59 100 145 80 54 51 43 

0 5.8 11.8 17.1 24.8 36.9 36.9 

Dry-Type 3 2.9 5.8 8.5 12.3 18.3 18.3 

7 1.2 2.5 3.7 5.3 8.0 8.0 

EA-25 
5.1.3 Fuel-Cycle Emissions 

As discussed earlier, fuel-cycle emissions refer to the emissions associated with the 

amount of fuel used in the upstream production of electricity and downstream consumption of 

electricity, including energy used at the power plant. The amount of energy used to perform the 

upstream processes, such as natural gas production, is not linked to the downstream consumption 

of electricity attributed to natural gas. For this reason, changes in upstream emissions due to 

adopted standards are not counted in NEMS-BT. Although DOE does not report actual 

estimates of the effects of standards on upstream emissions, the emissions factors described here 

provide the reader with a sense of the possible magnitude of the effects. 

Estimates of upstream emissions for CO2 and NOx are taken from a study in 1993 by Mark 

A. DeLuchi (sometimes spelled DeLucci), Ph. D., at Argonne National Laboratory. Dr. DeLuchi 

provides estimates of full fuel-cycle emissions factors for CO2, CH4, carbon monoxide (CO), nonmethane organic compounds (NMOC), and NOx from coal and natural gas production.10 The 

emission factor for SO2 is taken from the EPA Report AP-42, Compilation of Air Pollutant 

11 Emission Factors. The EPA AP-42 report notes that coal-cleaning is the primary source for 

upstream SO2 emissions from coal production, so the emission factor for SO2 reflects only the 

coal-cleaning process. Transportation of coal is not addressed in EPA’s study. 

Emission factor estimates and corresponding percentages of contributions of upstream 

emissions from coal and natural gas production, relative to power plant emissions, are shown in 

Table EA.20 for CO2, SO2, and NOx. The percentage relative to power plant emissions provides 

a means to estimate upstream emission savings based on the savings from the power plant. The 

values shown in Table EA.20 represent emissions from upstream processes as mass (g) per 

deliverable energy to end-use consumers, in gigajoules (GJ). 

Table EA.20	Estimated Upstream Emission Factors and Corresponding Percentages of 

Direct Power Plant Combustion Emissions 

Coal Natural Gas 

Emission % of Combustion Emission Factor % of Combustion 

Factor (g/GJ) Emissions (g/GJ) Emissions 

CO2 8,147 2.7 20,000 11.9 

SO2 29.2 0.9 0 0 

NOx 41.7 5.8 153 40 

Relative to the entire fuel cycle, Dr. DeLuchi estimates that approximately eight percent, 

by mass, of emissions from coal production are due to mining, preparation that includes cleaning 

the coal, and transportation from the mine to the power plant. Transportation emissions include 

emissions from the fuel used by the mode of transportation that moves the coal from the mine to 

the power plant. Also, Dr. DeLuchi estimates that approximately 14 percent of emissions from 

EA-26 
natural gas production result from upstream processes. In view of Table EA.20, this higher loss 

factor in natural gas production, compared to the emissions factor for coal, is likely due to the 

higher NOx contribution. In sum, emissions factors relative to power plant emissions are a 

relatively small proportion of the energy losses attributable to upstream processes. With the 

exception of NOx emissions from natural gas production, upstream emissions are less than 12 

percent of power plant emissions. 

5.2 Wetlands / Endangered and Threatened Species / Cultural Resources 

DOE’s adopted action is not site-specific, nor would it impact land disturbance or use due 

to distribution transformer placement. Therefore, this action is not expected to affect the quality 

of wetlands, or threatened or endangered species. Further, this action is not expected to impact 

cultural resources such as historical or archaeological sites. 

5.3 Socioeconomic Impacts 

DOE's analysis has shown that the increase in the first cost of purchasing a more efficient 

distribution transformer at the adopted and alternative standard levels is offset by a reduction in 

the LCC of owning a more efficient piece of equipment. Although the adopted and alternative 

standards increase the first cost, the standard levels result in a decrease in LCC (due to reduced 

energy costs) for many consumers. The precise change in LCC varies by standard level, size, class 

of transformer, and type of customer. At the adopted standard level, approximately 75 percent of 

the market is either not affected or realizes LCC savings. For a complete discussion of the LCC 

impacts on consumers, see Chapter 8 of the TSD 

5.4 Environmental Justice Impacts 

According to Executive Order 12898 of February 11, 1994, “Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations,” DOE is required to 

examine the effect of more stringent energy-efficiency standards on (1) small businesses that 

either manufacture or use distribution transformers, (2) manufacturers of niche products related to 

distribution transformers, and (3) small businesses operated by disadvantaged or minority 

populations. 

Regarding users of distribution transformers, small businesses are included as part of the 

overall population examined by DOE in the LCC analysis. The results of that analysis estimated 

that between 25 and 62 percent of distribution transformer customers would experience positive 

economic impacts from the adopted standard. 

EA-27 
Small distribution transformer manufacturing enterprises, as defined by the Small Business 

Administration, are those with no more than 750 employees.a

 DOE identified and interviewed six 

small manufacturers of distribution transformers, five of which produce medium-voltage, dry-type 

transformers and one of which produces liquid-immersed transformers. Because the liquidimmersed distribution transformer industry largely produces customized transformers, small 

businesses can compete because each unique design is produced in relatively small volumes for a 

given order. Implementation of an energy conservation standard would have a relatively minor 

differential impact on small manufacturers of liquid-immersed distribution transformers. 

Because of the potential impacts of a standard on manufacturers of the medium-voltage, 

dry-type superclass, DOE determined that it cannot certify that the adopted rule (TSL2), if 

promulgated, would have no significant economic impact on a substantial number of small 

entities. Because DOE cannot certify this, due to the potential impacts on medium-voltage, drytype manufacturers, it prepared an initial regulatory flexibility analysis (IRFA) for this rulemaking, 

which can be found in section VI.B of the NOPR. For additional information on this subject, see 

also section V.B.2.b of the NOPR (71 FR 44356-44408) and the manufacturer impact analysis 

(MIA) in Chapter 12 of the TSD. 

DOE did not conduct a separate analysis to assess the impacts of a new standard on niche 

product manufacturers because it found no niche products for which the adoption of a new 

standard would raise special considerations. 

DOE's LCC subgroup analysis (TSD Chapter 11) did not include small or disadvantaged 

businesses or populations as a subgroup. However, DOE believes that there are no 

disproportionately high and adverse human health or environmental effects on small businesses, 

minority populations, and low-income populations resulting from more stringent energy-efficiency 

standards. Positive impacts, such as decreased air emissions, would be equally shared among all 

populations. 

The MIA (TSD Chapter 12), and the regulatory impact analysis (published with the TSD) 

examined impacts on various business populations. However, DOE received no data concerning 

differential impacts on businesses owned by minority or disadvantaged populations. DOE 

requests comment on this issue. 

5.5 Energy Consumption Impacts 

The adopted standard levels for distribution transformers (TSL C for liquid-immersed and 

TSL 2 for medium-voltage, dry-type) would result in the national energy savings shown in Table 

EA.21 and EA.22. Energy savings for the other TSLs are also provided. 

a

 Small Business Administration -http://www.sba.gov/gopher/Financial-Assistance/Defin/defi4.txt (06/24/05) 

EA-28 
5.6 Noise and Aesthetics 

The adopted action is not likely to affect the sound power levels or sound quality levels 

associated with distribution transformers. Transformers have no moving parts but do often emit a 

buzz associated with 60-Hz alternating current. DOE’s adopted standard is not expected to 

materially affect the noise of transformers. Higher-efficiency transformers tend to be larger; 

however, the efficiencies selected by DOE will not result in significant changes in transformer size 

nor in any other aesthetic feature. In sum, the noise and aesthetics of the more efficient 

distribution transformers covered under this EA would be virtually no different from equipment 

being installed today. 

5.7 Summary of Environmental Impacts 

Tables EA.22 to EA.24 provide a summary of the analysis results by superclass to aid the 

reader in the discussion of the benefits and burdens for the different TSLs as well as the no-action 

alternative. 

Table EA.21 Summary of the Analysis Results for Liquid-Immersed Transformers 

No Trial Standard Level 

Action 1 2 3 4 5 6 A B C D 

Cumulative Emission Reductions* 

CO2 Equivalent (Mt) 0.0 125 176 248 272 464 674 369 251 238 199 

Cumulative Primary Energy 0.0 1.38 1.94 2.76 3.00 5.07 7.37 4.07 2.75 2.61 2.18 Saved (quads)* 

Socioeconomic Impacts – All Consumers 

Transformers with non- 87.9 79.3 81.1 55.7 15.2 0.5 20.4 57.5 57.5 79.3 

negative LCC savings (%) NA to to to to to to to to to to 

based on underlying DLs 98.6 98.6 98.0 87.6 42.3 15.2 67.6 91.9 97.5 98.6 

19.3 21.6 10.6 Payback periods (years), based 2.3 to 2.4 to 2.4 to 7.8 to 8.9 to 4.3 to 3.6 to NA to to to on underlying DLs 7.8 10.4 11.4 11.4 15.7 15.7 10.4 23.4 52.1 24.7 

Environmental Justice Impacts None None None None None None None None None None None 

Wetlands/Endangered and 

Threatened Species/Cultural None None None None None None None None None None None 

Resources Impacts 

Fuel-Cycle (Upstream) Emissions None **   **  **   **  ** ** Impacts 

Noise and Aesthetics Impacts None None None None None None None None None None None 

* 	 Cumulative total is over a time period starting in 2010 and ending in 2038. 

**	 DOE does not report actual estimates of the effects of standards on upstream emissions, but section 5.1.2 

above provides a sense of the possible magnitude of effects. 

EA-29 
Table EA.22 Summary of the Analysis Results for Dry-Type, Medium-Voltage 

Transformers 

No 

Action 

Trial Standard Level 

1 

2 

(Adopted 

Action) 

3 4 5 6 

Cumulative Emission Reductions*

 CO2 Equivalent (Mt) 

Cumulative Primary Energy Saved 

(quads)* 

0.0 

0.0 

5.8 

0.06 

11.8 

0.13 

17.1 

0.19 

24.8 

0.27 

36.9 

0.40 

36.9 

0.40 

Socioeconomic Impacts – All 

Consumers 

Transformers with n on-negative 

LCC savings (%) based on 

underlying DLs 

NA 96.7 to 

99.7 

84.4 to 

98.7 

81.5 to 

92.6 

54.0 to 

75.8 

21.9 to 

63.5 

21.9 to 

63.5 

Payback periods (year s), based on 

underlying DLs NA 0.5 to 5.0 1.8 to 6.4 3.4 to 7.0 5.9 to 9.6 7.8 to 18.7 

7.8 to 

18.7 

Environmental Justice Impacts None None None None None None None 

Wetlands/Endangered and Threatened 

Species/Cultural Resources Impacts None None None None None None None 

Fuel-Cycle (Upstream) Emissions 

Impacts None **   **  ** ** 

Noise and Aesthetics Impacts None None None None None None None 

* Cumulative total is over a time period starting in 2010 and ending in 2038. 

** DOE does not report actual estimates of the effects of standards on upstream emissions, but section 5.1.2


above provides a sense of the possible magnitude of effects.


DOE has adopted energy-efficiency standards for distribution transformers at TSL C for 

liquid-immersed transformers and TSL 2 for medium-voltage, dry-type transformers. The 

adopted standards would apply to all covered products offered for sale in the United States and its 

Territories, with a compliance date of January 1, 2010. The justification for selecting the adopted 

action, adopting these standard levels over the other TSLs considered, is fully explained in the 

final rule. The final rule is available on the internet at: 

http://www.eere.energy.gov/buildings/appliance_standards/commercial/distribution_transformers. 

html under “Final Rule.” 

In addition to reducing the secondary energy lost in the distribution transformers 

themselves, the adopted standards would save even more energy at the electric power plant 

source, where less primary energy (e.g., oil, coal, or natural gas) directly attributable to the losses 

from distribution transformers would be burned. Burning less oil, coal, or natural gas reduces 

greenhouse gas emissions and pollutants, creating a cleaner environment. 

EA-30 
In the 28-year period after the new standards become effective, the Nation will save about 

2.74 quadrillion British thermal units (quads) of primary energy. Additionally, these energy 

savings would significantly reduce emissions of air pollutants and greenhouse gases associated 

with electricity production, by 250 Mt of CO2. This is equivalent to all the energy consumed by 

27 million American households in a single year. Furthermore, the adopted standards would 

eliminate the need for construction of roughly six new 400-megawatt (MW) power plants by 

2038. 

EA-31 
REFERENCES 

1.	 Barnes, P. R., J. W. Van Dyke, B. W. McConnell, and S. Das. Determination Analysis of 

Energy Conservation Standards for Distribution Transformers. 1996. Oak Ridge National 

Laboratory. Oak Ridge, TN. Report No. ORNL-6847. 

2.	 Barnes, P. R., S. Das, B. W. McConnell, and J. W. Van Dyke. Supplement to the 

"Determination Analysis" (ORNL-6847) and Analysis of the NEMA Efficiency Standards 

for Distribution Transformers. 1997. Oak Ridge National Laboratory. Oak Ridge, TN. 

Report No. ORNL-6925. 

3.	 National Electrical Manufacturers Association. NEMA Standards Publication TP 1-1996; 

Guide for Determining Energy Efficiency for Distribution Transformers. 1996. National 

Electrical Manufacturers Association. Rosslyn, VA. Report No. TP 1-1996. 

4.	 U.S. Department of Energy-Office of Building Technologies. Technical Support 

Document: Energy Conservation Program for Commercial and Industrial Equipment: 

Electrical Distribution Transformers - ANOPR Version. 2004. U.S. Department of 

Energy. Washington, DC. Report No. LBNL-53985. 

<http://www.eere.energy.gov/buildings/appliance_standards/commercial/dist_trans_tsd_0 

61404.html> 

5.	 U.S. Department of Energy-Office of Building Technologies. Technical Support 

Document: Energy Conservation Program for Commercial and Industrial Equipment: 

Electrical Distribution Transformers - NOPR Version. 2005. U.S. Department of Energy. 

Washington, DC. 

<http://www.eere.energy.gov/buildings/appliance_standards/commercial/distribution_trans 

formers.html> 

6.	 U.S. Department of Energy - Energy Information Administration. Annual Energy Outlook 

2005: With Projections Through 2025. January, 2005. Washington, DC. Report No. 

DOE/EIA-0383(2005). <http://www.eia.doe.gov/oiaf/aeo/index.html> 

7.	 U.S. Department of Energy-Energy Information Administration. Emissions of Greenhouse 

Gases in the United States 2003. December, 2004. Washington, DC. Report No. 

DOE/EIA-0573(2004). <http://www.eia.doe.gov/emeu/mer/prices.html> 

8.	 U.S. Office of Management and Budget. Circular A-4: Regulatory Analysis. 2003. (Last 

accessed March 25, 2005.) This material is available in Docket #86. Contact Ms. Brenda 

Edwards-Jones, U.S. Department of Energy, Building Technologies Program, Mailstop 

EE-2J, 1000 Independence Avenue, SW, Washington, DC, 20585-0121, telephone (202) 

586-2945 for more information. <http://www.whitehouse.gov/omb/circulars/a004/a4.pdf> 

EA-32 
9.	 Lind, R. C., K. J. Arrow, G. R. Corey, P. Dasgupta, A. K. Sen, T. Stauffer, J. E. Stiglitz, 

J. a. Stockfisch, and R. Wilson. Discounting for Time and Risk in Energy Policy. 1982. 

Resources for the Future: Washington, D.C. pp. 62-63. 

10.	 DeLuchi, M. A. Emissions of Greenhouse Gases from the Use of Transportation Fuels 

and Electricity, Volume 2: Appendixes A-S. November, 1993. Argonne National 

Laboratory. Argonne, IL. Report No. ANL/ESD/TM-22-Vol.2. 

11.	 U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, 

AP-42, Fifth Edition, Volume 1 - Chapter 3: Stationary Internal Combustion Engines. 

(Last accessed July 25, 2005.) This material is available in Docket #86. Contact Ms. 

Brenda Edwards-Jones, U.S. Department of Energy, Building Technologies Program, 

Mailstop EE-2J, 1000 Independence Avenue, SW, Washington, DC, 20585-0121, 

telephone (202) 586-2945 for more information. 

<http://www.epa.gov/ttn/chief/ap42/ch03/index.html> 

EA-33