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@nema.org; 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; mhyland@appanet.org; 

dave.millure@metglas.com; snadel@aceee.org; wes.patterson@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 efficient pole type distribution transformers might be 

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

need for more information. 

 

The advisory to agencies is very clear regarding negotiated rulemakings. The process is 

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

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

rulemankings must address the information needs 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 meetings. At a minimum, the 

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

rather than telling the participants that they are 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 the efficiency 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 mechanical 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 Distribution Transformer  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 type transformers.  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 meeting that LBNL was asked to calculate based on 

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

CSL 

 · cost savings on the basis of kWh saved over the 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 costs distributed, many of the designs included in a 

CSL appear to be redundant in the sense that they result in the same 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 calculated 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 transformer negotiating committee: 

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

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

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

http://www.eere.energy.gov/buildings/appliance_standards/commercial/distribution_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 reply to the entire group and we will work on getting you a timely 

clarification -- all with the goal of making our first meeting 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