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

Sent: Friday, September 09, 2011 12:24 PM

To: Corkran, Jerry L

Cc: Richard Parker; rick.anderson@faypwc.com; Robert Berman; tballo@earthjustice.org;

ScottB@LVMetals.com; john.caskey@ne ma.org; john.cymba lsky@ee.doe.gov;

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

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

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

Raymond.Polinski@ATImetals.com; srosenstock@eei.org; rroy@nrdc .org; robert.saint@nreca.coop;

chuck.simmons@pgnmail.com; mark.e.stoering@ xcelenergy.com; Daniel.Cohen@hq.doe.gov;

greg.coulter405@gmail.com; Jim.Creevy @nema.org; ahofmann@publicpower.org;

pkumar@publicpower.org; jmauer@standardsASAP.org; paul.ryan@hitmet.com;

bsmith@federalpacific.com; kwinder@mleainc.com; cabolduc@lbl.gov; Brian Coffey;

Jim.Raba@ee.doe.gov; Michael Rivest; GJRosenquist@lbl.gov

Subject: Re: DOE MV Transformer rulemaking - Analysis is now online



### Although Mr. Corkran and I may disagree about what the data might suggest if they were

provided (e.g., the extent to which more efficien t pole type distribution transformers might be

heavier and under what conditions is not at all clear), there is cl early no disagreement about the

need for more information.

The advisory to agencies is very clear re garding negotiated rulemakings. The process is

definitely more resource intensive. Data needs ar e substantially greater. Rather than provide only

the minimal information needed to support a ru le, based on the agency's approach, negotiated

rulemankings must address the information need s of the much more diverse group directly

involved. It is for this reason that agencies are cautioned to ensure that they have the resources

available before undertaking a negotiated rulemaking.

The DOE has asked this industry to devote significant resources to this process, in terms of

executive and senior staff time to attend meetings and prepare for meeti ngs. At a minimum, the

DOE must provide the information and analyses that participants require to properly participate;

rather than telling the participants that they ar e limited to what DOE believes to be relevant.



### Regards,

Robert A. Berman, Principal

Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703

‐ 281

‐ 0490

703

‐ 655

‐ 8398 (cell)

BermanEconomics@gmail.com

### On Sep 9, 2011, at 10:08 AM, Corkran, Jerry L wrote:

Mr. Berman raises some good points which I agree with. The following items listed below are

requested to help the subcommittee to determine if the projected designs shown by the DOE are

actually buildable by the transformer manufacturers.

 In addition to the request that Mr. Berman made, would the DOE provide the actual design

information for the least

‐ cost transformer designs? Sufficient design information should be included

to allow the transformer manufacturers to compare the same design created on their programs to the

DOE created designs.

 Would the DOE request transformer design quotations from multiple manufacturers for the

transformer efficiency loss levels that the DOE considers buildable? This would provide the DOE with

actual designs which the manufacturers are capable of building. These designs could be compared to

the designs which the DOE is currently using to generate th e effi ciency data projections.

 Would the DOE request quotations from multiple manufacturers optimized for the lowest total

owning costs at evaluated loss levels that they are considering. The evaluation A and B factors would

vary by a 4:1 ratio to reflect a maximum efficiency at a 50% load. Suggested A and B factors are 0/0,

$4/$1, $8/$2

, $12/$3, and $16/$4.

 Would the DOE share field performance data, if it is available showing that the projected

amorphous core transformers required to meet the higher efficiency levels will have a projected life

similar to the experience with silicon steel core transformers? The metal debris which comes off the

amorphous cores when they are subjected to mecha n ical movement is considered a factor which we

expect to result in a reduced transformer life as compared to the traditional silicon core distribution

transformers. The cores in Distribution Transformers will sustain mechanical movements during core

stacking and later while in service when short circuit thru faults occur.

Regarding the assumptions that the DOE made to use an average distribution transformer life of 32

years in their transformer efficiency payback calculations; the IEEE Transformer committee in the

various technical standards which apply to Distribution transformers specifies an average life of 20.5

years. We recommend that the 20.5 year average Distri bution Transf ormer life be used by the DOE

in their payback analysis.

For pole type distribution transformers, the higher efficiency designs have a very significant increase

in weight and also in transformer overall height. The DOE is requested to factor in the increased pole

loading and related need to replace existing poles in some cases to allow the mounting of the heavier

pole typ e transform ers. Some of the higher efficiency transformers will have a total weight of twice

that of the existing transformer which is being replaced.

Regards,

Jerry Corkran

Staff Engineer

Cooper Power Systems

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

Sent: Wednesday, September 07, 2011 6:01 AM

To: Richard Parker

Cc: rick.anderson@faypwc.com ; tballo@earthjustice.org ; ScottB@LVMetals.com ; john.caskey@nema.org ;Corkran, Jerry

L; john.cymbalsky@ee.doe.gov ; adelaski@standardsASAP.org ; Teckman@nwcouncil.org ; gbf1@pge.com ;

carlos.gaytan@ge.com ; rgreeson@federalpacific.com ; bruce.r.hirsch@bge.com ; jhodge@howard.com ; m

hyland@appanet.org ; dave.millure@metglas.com ; snadel@aceee.org ; wes.patterson@us.abb.com ; Eric.P

etersen@aksteel.com ; Raymond.Polinski@ATImetals.com ; srosenstock@eei.org ; rroy@nrdc.org ; robert.sa

int@nreca.coop ; chuck.simmons@pgnmail.com ; mark.e.stoering@xcelenergy.com ; BermanEconomics@g

mail.com ; Daniel.Cohen@hq.doe.gov ; greg.coulter405@gmail.com ; Jim.Creevy@nema.org ; ahofmann@p

ublicpower.org ; pkumar@publicpower.org ; jmauer@standardsASAP.org ; paul.ryan@hitmet.com ; bsmith@

federalpacific.com ; kwinder@mleainc.com ; cabolduc@lbl.gov ; brian.coffey@navigant.com ; Jim.Raba@ee.

doe.gov ; mrivest@navigant.com ; GJRosenquist@lbl.gov

Subject: Re: DOE MV Transformer rulemaking - Analysis is now online



### There were two matters discussed at the July m eeting that LBNL was asked to calculate based on

their existing information. Specifically, for the ne xt meeting, can we see for each design line and

CSL

· cost savings on the basis of kWh saved over th e life of the transformer using both the MEPS

load factor and the lower factor more likely to be experienced; and



### · reflect costs and savings through utility accounting and rate-making impacts.



### With respect to the engineering and life-cycle co sts distributed, many of th e designs included in a

CSL appear to be redundant in the sense that they result in the sa me efficiency albeit at a higher

cost (see, for example, the plots in the TSD).



##  to what extent are these higher cost designs reflected in the tables showing the

percent of transformers with net costs by CSL?



##  to what extent do these higher cost designs impact costs and PBP calculations?



##  would is be possible to see the analyses with redundant designs (as described above)

deleted from the database?



### With respect to the PBPs shown, are these calculat ed specifically as the PBP for the particular

least-cost design for a CSL or as in the TSD? If the latter, could we see the PBPs calculated for

the particular least cost design in the CSL.

Regards,

Robert A. Berman, Principal

Berman Economics

www.BermanEconomics.com

1915 Grand Court

Vienna, VA 22182

703-281-0490

703-655-8398 (cell)

BermanEconomics@gmail.com

### On Sep 1, 2011, at 2:01 PM, Richard Parker wrote:

Members of medium voltage tr ansformer negotiating committee:

Just a quick note to welcome you again to th e committee and let you know (in case any of you

haven't heard already) that the updated engine ering analysis and life-cycle cost and payback

period analysis is posted on the DOE website at the following link:

http://www.eere.energy.gov/buildin gs/appliance_standards/commerc ial/distributi on_transformer

s.html

We will reserve substantive discussion of the analysis for our first meeting on Sept. 15. If

anyone has clarifying questions to ask that would be helpful to table before the meeting -- or if

anyone sees any gaps that the Navigant/LBL team might be able to fill between now and Sept 15

-- please so indicate in a repl y to the entire group and we will work on getting you a timely

clarification -- all with the goal of making our first mee ting as efficient and productive as

possible. Again, no arguments pre-meeting please. Just clarifying questions and suggestions for

refinement or supplementation of analysis.

I've spoken with many of you already. If we haven't yet spoken, I will be reaching out to you

shortly. I look forward to working with you.

Best wishes,

Richard Parker

Facilitator