‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Cohen, Daniel [mailto:Daniel.Cohen@hq.doe.gov]  

Sent: Friday, January 06, 2012 10:17 AM

To: 'Richard Parker'; Jerry Hodge

Cc: Alex Hofmann; Andrew Delaski; Aris Marantan; Art Rosenfeld; Bob Saint; Bob

Smith; Edwards, Brenda; Brian Coffey; Caitlin Johnson; Carlos Gaytan; Caskey,

John; Charlie Drexler; Charlie Stevens; Chris Bolduc; Chris Brown; Clark Silcox;

Creevy, Jim; Daniel Young; David Flaten; Marchetti, Emily (CONTR); Eric Petersen;

Freeman, Jeremiah (CONTR); Gary Fernstrom; Greg Coulter; Greg Rosenquist; Hirsch,

Bruce R; James Lass; Tiedeman, Jennifer; Jerry Corkran; Jerry Schoen; Raba, Jim;

Joanna Mauer; Cymbalsky, John; John Rossetti; Katie Coughlin; Ken Winder; Mahesh

P. Sampat; Matthew Nardotti; Savitz, Maxine (EMAB); Meg Waltner; Meyers, Aaron;

Michael Hyland; Michael Rivest; Millure, Dave; Pamela Costello; Phil Harter; Phil

Hopkinson; Polinski, Raymond; Puesh Kumar; Rick Anderson; Rob Greeson; Robert

Berman; Van Buskirk, Robert (CONTR); Robin Roy; Ryan, Paul; Scott Beck; Simmons,

Chuck; Steve Nadel; Steve Rosenstock; Ted Johnstone; Thomas Petrosino; Tim Ballo;

Tom Eckman; Wes Patterson; Zhimei Luo; Vijay Tendulkar; Thomas Patzner; Chad

Kennedy; Eduardo Robles; Dhiru Patel

Subject: RE: DOE Issuing NOPR for Liquid Immersed Distribution Transformer

without any defined or trial Efficiency Levels by Feb. 01, 2012

Jerry et. al, Richard is correct.  The Department has an obligation pursuant to a

court order to issue by February 1, 2012, either a determination that the

existing standards do not need to be amended or a proposed rule to amend the

existing standards.  We have every intention of meeting that deadline.  If we

issue a proposed rule on February 1, that proposal would have a 60 public comment

period, including announcing a date and location for a public meeting during the

comment period.  We would then have an obligation under the court's order to

issue by October 1 a final rule responding to comments received.  Similar to the

2007 rulemaking, in which compliance with those standards was not required until

2010, if we issue a final rule establishing new standards on October 1, 2012,

there would be a implementation period before compliance was required.  Whatever

we do on February 1 benefits immensely from the hard work, information provided

and debate that occurred during the negotiated rulemaking process.  As such, we

are incredibly grateful to everyone on this e‐mail for their participation in and

dedication to an open and honest debate.    

Dan  

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

Sent: Thursday, January 05, 2012 6:25 PM

To: Jerry Hodge

Cc: Alex Hofmann; Andrew Delaski; Aris Marantan; Art Rosenfeld; Bob Saint; Bob

Smith; Edwards, Brenda; Brian Coffey; Caitlin Johnson; Carlos Gaytan; Caskey,

John; Charlie Drexler; Charlie Stevens; Chris Bolduc; Chris Brown; Clark Silcox;

Creevy, Jim; Cohen, Daniel; Daniel Young; David Flaten; Marchetti, Emily (CONTR);

Eric Petersen; Freeman, Jeremiah (CONTR); Gary Fernstrom; Greg Coulter; Greg

Rosenquist; Hirsch, Bruce R; James Lass; Tiedeman, Jennifer; Jerry Corkran; Jerry

Schoen; Raba, Jim; Joanna Mauer; Cymbalsky, John; John Rossetti; Katie Coughlin;

Ken Winder; Mahesh P. Sampat; Matthew Nardotti; Savitz, Maxine (EMAB); Meg

Waltner; Meyers, Aaron; Michael Hyland; Michael Rivest; Millure, Dave; Pamela

Costello; Phil Harter; Phil Hopkinson; Polinski, Raymond; Puesh Kumar; Rick

Anderson; Rob Greeson; Robert Berman; Van Buskirk, Robert (CONTR); Robin Roy;

Ryan, Paul; Scott Beck; Simmons, Chuck; Steve Nadel; Steve Rosenstock; Ted

Johnstone; Thomas Petrosino; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo;

Vijay Tendulkar; Thomas Patzner; Chad Kennedy; Eduardo Robles; Dhiru Patel

Subject: Re: DOE Issuing NOPR for Liquid Immersed Distribution Transformer

without any defined or trial Efficiency Levels by Feb. 01, 2012

Jerry,

John Cymbalsky or Dan Cohen will correct me if I mis‐speak, but it is my

understanding that the Department is moving forward with the NOPR on schedule,

with a decision and analysis  considerably enriched by the data and insights

yielded by our process, and that the Department plans (and is on track) to

finalize the rule on schedule as well.

I will not presume to speak for the department on whether the final efficiency

levels will be published informally before the October 1,

2012 deadline for publication of the final rule in the Federal Register.  That is

rare, in my experience, but I do not know the Department's plans or policy on

that.

Hope this is helpful.  I'm sure Dan or John will be happy to provide more

authoritative corroboration or correction in due course.

All best,

Richard

On Thu, Jan 5, 2012 at 5:52 PM, Jerry Hodge <jhodge@howard‐ind.com> wrote:

> Hi Richard and All:

>

> Are we now at a point in this Transformer Rule Review, where DOE will  

> issue an NOPR without any planned, expected or defined threshold  

> efficiency levels for Liquid‐Immersed Distribution Transformers?  Will  
> DOE meet this Feb. 01,

> 2012 date for issuing the NOPR?  Time is about to run out fast.  This  

> may not be a problem for DOE, but for the transformer manufacturers  

> and material suppliers, it leaves us totally in limbo.  No one will be  

> able to do any planning until the Final Rule is published.  No one  

> will even start budgeting the capital that may be required if levels  

> such as EL‐3 or 4 are chosen.  Meeting required implementation dates  

> may be difficult or impossible.

>

> Do you think the Final Rule will be published by Oct. 01, 2012?  Will  

> any of us stakeholders have any idea what efficiency levels will be  

> required between now and when the Final Rule is published?

>

> Any information you can give us on this situation would be appreciated.

>

> Thanks;

>

> Jerry

>

>

> Jerry Hodge

> Consulting Engineer, E.E., M.S., P.E.

> Retired V.P. & G.M. of Pole Type Transformer & Regulator Div.

> Howard Industries Inc.

> P.O.Box 1588

> Laurel, Ms, 39440

> 601 422‐1539 Bus.

> 484 226‐6190 Cell

>

> ‐‐‐‐‐Original Message‐‐‐‐‐ 

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

> Sent: Friday, December 23, 2011 12:51 PM

> To: Alex Hofmann; Andrew Delaski; Aris Marantan; Art Rosenfeld; Bob  

> Saint; Bob Smith; Brenda Edwards; Brian Coffey; Caitlin Johnson;  

> Carlos Gaytan; Caskey, John; Charlie Drexler; Charlie Stevens; Chris  

> Bolduc; Chris Brown; Clark Silcox; Creevy, Jim; Dan Cohen; Daniel  

> Young; David Flaten; Emily Marchetti; Eric Petersen; Freeman,  

> Jeremiah; Gary Fernstrom; Greg Coulter; Greg Rosenquist; Hirsch, Bruce  

> R; James Lass; Jennifer Tiedeman; Jerry Corkran; Jerry Hodge; Jerry  

> Schoen; Jim Raba; Joanna Mauer; John Cymbalsky; John Rossetti; Katie  

> Coughlin; Ken Winder; Mahesh P. Sampat; Matthew Nardotti; Maxine  

> Savitz; Meg Waltner; Meyers, Aaron; Michael Hyland; Michael Rivest;  

> Millure, Dave; Pamela Costello; Phil Harter; Phil Hopkinson; Polinski,  

> Raymond; Puesh Kumar; Richard W. Parker; Rick Anderson; Rob Greeson;  

> Robert Berman; Robert van Buskirk; Robin Roy; Ryan, Paul; Scott Beck;  

> Simmons, Chuck; Steve Nadel; Steve Rosenstock; Ted Johnstone; Thomas  

> Petrosino; Tim Ballo; Tom Eckman; Wes Patterson; Zhimei Luo; Vijay  

> Tendulkar; Thomas Patzner; Chad Kennedy; Eduardo Robles; Dhiru Patel

> Subject: Happy Holidays

>

> Dear Colleagues,

>
> Just a quick note to express my appreciation to each of you ‐‐ for the  

> knowledge, professionalism, hard work and, most of all civility, that  

> you all have brought to the negotiating table over the past several  

> months as we have wrestled with difficult issues in an effort to reach

consensus.

>  Although we did not achieve consensus on liquid immersed, your  

> courtesy and professionalism throughout the process was and is a model  

> for this town (hear that, Congress?).

>

> I am confident that your efforts have greatly strengthened the  

> Department's analysis and will improve the final rule for liquid  

> immersed.  I am hopeful that we can reach final consensus on MVDT and  

> possibly even on LV early next year.

>

> Meanwhile, I'd like to reiterate what a pleasure it has been working  

> with and getting to know you all.   Best wishes for a safe and happy  

> holiday season!

>

> Warm regards,

> Richard Parker