The spreadsheet is attached this time. Sorry about that.Steve RosenstockManager, Energy SolutionsEdison Electric Institutesrosenstock@eei.org202-508-5465From:Rosenstock, StevenSent:Friday, September 30, 2011 9:56 AMTo:Richard Parker; Corkran, Jerry LCc:Caitlin Johnson;rick.anderson@faypwc.com;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;mhyland@appanet.org;dave.millure@metglas.com; Nadel, Steve;wes.patterson@us.abb.com;Eric.Petersen@aksteel.com;Raymond.Polinski@atimetals.com;rroy@nrdc.org;robert.saint@nreca.coop;chuck.simmons@pgnmail.com;mark.stoering@xcelenergy.com;cabolduc@lbl.gov;kcoughlin@lbl.gov; Brian Coffey;gjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge;jrossetti@mlgw.org;Jim.creevy@nema.org; Meyers, Aaron;Daniel.Cohen@hq.doe.gov;jmauer@standardsasap.org;greg.coulter405@gmail.com;bsmith@federalpacific.com;pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson;ahofmann@publicpower.org;BermanEconomics@gmail.com;Paul.Ryan@hitmet.com;jerry.schoen@aksteel.com;mwaltner@nrdc.org;kwinder@mleainc.com;chad.kennedy@us.schneider-electric.com;eduardorobles@eaton.com;vijay.tendulkar@onyxpower.com;carlosgsiqueiros@eaton.com;thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider,Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, Jack C; Smith, JenniferSubject:RE: Distribution Transformers Committee requested areas for the DOE to Investigate before final rules are selected.Will it be possible for the consultants to run a sensitivity analysis of future estimated prices of liquidfilled units (for the LCC and NIA impacts)based on the data from the consultant spreadsheets that EEI has reviewed and attached?The key parameters are shown below andare solelybased on the data that wasin the spreadsheets:Design Line 1:Average$2,527.96$3,220.56$1,963.16Median$2,524.19$3,223.98$1,962.82Standard Dev$320.47$460.20$247.03CPI Inflation 2006-2010:11.44%CPI Inflation 2007-2010:7.98%% Inc based on AveragePrices:28.77%% Inc based on MedianPrices:28.60%Design Line 1 - Single-phase, Liquid-immersed Units, Rectangular Tank from 10 to 167kVA.DesignCore LossCoil LossCoil LossMnf. SellingMnf. SellingMnf. SellingWeightEfficiency Design OptionName(watts)@50% (watts)@100% (watts)Price (2010)Price (hi -2008)Price (lo -2006)(lbs)@50% loadCombinationDesign Line 2:Average$1,555.10$2,076.32$1,234.18Median$1,517.21$2,007.41$1,195.70Standard Dev$289.30$317.12$172.52CPI Inflation 2006-2010:11.44%CPI Inflation 2007-2010:7.98%% Inc based on AveragePrices:26.00%% Inc based on MedianPrices:26.89%Design Line 2 - Single-phase, Liquid-immersedUnits, Round Tank from 10 to 167kVA.DesignCore LossCoil LossCoil LossMnf. SellingMnf. SellingMnf. SellingName(watts)@50% (watts)@100% (watts)Price (2010)Price (hi -2008)Price (lo -2006)Design Line 3:Average$11,713.95$15,266.63$8,753.19Median$11,229.97$14,456.36$8,325.90Standard Dev$2,761.19$3,779.81$2,062.16CPI Inflation 2006-2010:11.44%CPI Inflation 2007-2010:7.98%% Inc based on AveragePrices:33.83%% Inc based on MedianPrices:34.88%Design Line 3 - Single-phase, Liquid-immersed Units, from 250 to 833kVA.DesignCore LossCoil LossCoil LossMnf. SellingMnf. SellingMnf. SellingName(watts)@50% (watts)@100% (watts)Price (2010)Price (hi -2008)Price (lo -2006)Design Line 4:Average$7,040.12$9,084.95$5,333.47Median$6,685.38$8,550.78$5,048.23Standard Dev$1,229.00$1,656.06$902.86CPI Inflation 2006-2010:11.44%CPI Inflation 2007-2010:7.98%% Inc based on AveragePrices:32.00%% Inc based on MedianPrices:32.43%Design Line 4 - Three-phase, Liquid-immersed Units, from 15 to 500kVA.DesignCore LossCoil LossCoil LossMnf. SellingMnf. SellingMnf. SellingName(watts)@50% (watts)@100% (watts)Price (2010)Price (hi -2008)Price (lo -2006)Design Line 5:Average$32,904.33$42,291.34$24,487.23Median$31,180.18$40,691.92$23,708.52Standard Dev$5,713.25$6,885.12$3,920.24CPI Inflation 2006-2010:11.44%CPI Inflation 2007-2010:7.98%% Inc based on AveragePrices:34.37%% Inc based on MedianPrices:31.51%Design Line 5 - Three-phase, Liquid-immersed Units, from 750 to 2500kVA.DesignCore LossCoil LossCoil LossMnf. SellingMnf. SellingMnf. SellingName(watts)@50% (watts)@100% (watts)Price (2010)Price (hi -2008)Price (lo -2006)Steve RosenstockManager, Energy SolutionsEdison Electric Institutesrosenstock@eei.org202-508-5465From:Richard Parker [mailto:richardparkerdc@gmail.com]Sent:Wednesday, September 21, 2011 1:39 PMTo:Corkran, Jerry LCc:Caitlin Johnson;rick.anderson@faypwc.com;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;mhyland@appanet.org;dave.millure@metglas.com; Nadel, Steve;wes.patterson@us.abb.com;Eric.Petersen@aksteel.com;Raymond.Polinski@atimetals.com; Rosenstock,Steven;rroy@nrdc.org;robert.saint@nreca.coop;chuck.simmons@pgnmail.com;mark.stoering@xcelenergy.com;cabolduc@lbl.gov;kcoughlin@lbl.gov; Brian Coffey;gjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge;jrossetti@mlgw.org;Jim.creevy@nema.org; Meyers, Aaron;Daniel.Cohen@hq.doe.gov;jmauer@standardsasap.org;greg.coulter405@gmail.com;bsmith@federalpacific.com;pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson;ahofmann@publicpower.org;BermanEconomics@gmail.com;Paul.Ryan@hitmet.com;jerry.schoen@aksteel.com;mwaltner@nrdc.org;kwinder@mleainc.com;chad.kennedy@us.schneider-electric.com;eduardorobles@eaton.com;vijay.tendulkar@onyxpower.com;carlosgsiqueiros@eaton.com;thomas.patzner@us.schneider-electric.com; Marusinec, Richard M; Schneider,Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, Jack C; Smith, JenniferSubject:Re: Distribution Transformers Committee requested areas for the DOE to Investigate before final rules are selected.Jerry (and larger group),Thanks, Jerry, for your comments, queries andsuggestions. My apologies to all for the late notice on the Ground Rules. The compressed time frame for thisrulemaking has us all scrambling, but we willdo our best to get key docs to group well inadvance of meetings in the future (to the extent that analyticalrequirements and resource limitations allow). Most of the groundrules document is boilerplatefor negotiated rulemakings. Wehad an extensive discussionabout the parts that are not. But given your concern I willre-open the groundrules for online discussion, as needed, and clearance. I will do that in a separateemail thread.Would c.o.b Monday be reasonable deadlinefor comments on groundrules in your view, with aim of taking online poll towards middle of next week?As for the deadlines for talks, the Dec22 term sheet deadline can be altered by unanimous consent of the group, but you shouldknow that it is really apractical deadline that results from working backwards from the Jan. 30 court deadline (assuming court approves revised settlement agreement). So regardlessof what is in our ground rules, that willbe the de facto deadline for meeting thecourt deadline unless and until the plaintiffs agree to further extend thatdeadline.Your substantive comments are appreciated.I will consult with DOE/Navigant/LBL staff and develop a joint preliminary responsewhich we will then postonline is some appropriate formatfor further review and comment.All best,Richard ParkerOn Tue, Sep 20, 2011 at 3:57 PM, Corkran, Jerry L <Jerry.Corkran@cooperindustries.com> wrote:I am submitting following items for requestsfor investigation by the DOE. Some of the questions listed below were presented before or during thefirst meeting, but I have not received sufficient information to answer the questions and requests listed below:1.A good portion of the recent meetings wereconcerned with the review and revisionsof the ground rules for the NegotiatedRulemaking Working Group. A copy of thisdocument was issued dated as “Final 9/15/11” during the second day of the meetings.I wasconcerned and puzzled about why a legal document of this type was not issued well in advance of the working group meetings. Thedocument has a legal tone and application that makes its review beyond mycapabilities to determineif it is suitable to governthe workinggroup and its suitability for me to accept w/o reservations. I have submitted it to a Cooper Power Systems attorney for reviewtodetermine if it requires changes before agreeing to its content.I am objecting to the Sept.23 deadline for comments and suggestions onthis item and request that we be able tosubmit input on suggested changes after outattorney has an opportunity to review thedocument.At this time I am objecting to the “4. Agreement” rule with details of the objection orwithdrawal of my objections to be madeafter ourattorney reviews the document. I also object to the 3 d. Deadline for Negotiations to terminate at Dec. 22, 2011. I suggest that this date bedetermined by the working group during thethird meeting in Nov. after the working group has a knowledge of the time needed tocomplete the process.2.Would the DOE provide the actual design information for the least-cost transformer designs? Sufficient design information should beincluded to allow the transformer manufacturers to compare the same design created ontheir programs to the DOE created designs.3.Would the DOE request transformer design quotations from multiple manufacturers for the transformer efficiency loss levels thattheDOE considers buildable? This would provide the DOE with actualdesigns which the manufacturersare capable of building. Thesedesigns could be compared to the designs which the DOE is currently using to generate the efficiency data projections.4.Would the DOE request quotations from multiple manufacturers optimized for the lowesttotal owning costs at evaluated loss levelsthat they are considering. The evaluation A and B factors wouldvary by a 4:1 ratio to reflecta maximum efficiency at a 50% load.Suggested A and B factors are 0/0, $4/$1, $8/$2, $12/$3, and $16/$4.5.The DOE transformer designs show a large scale movement to amorphous core steel due toit lower loss characteristics. Review of theDOE transformer designs indicates that there might be a 700% increase in usage of the amorphous core steel over present annualproduction of this material. The DOE isrequested to create projections listing whatprice increases and material shortages are to beexpected if the use of this material is forced by transformer efficiency rules that dictate its use.6.Because there is only one major supplier ofamorphous core steel in the world that meets the efficiency levels used by the DOEin theiroptimizations, which is Hitachi in Japan andMetglas in the US (which is owned by Hitachi); is it legal for a law to be created at theDOE’s suggestion, forcing the exclusive use ofthis material in Distribution Transformers to meet the efficiency requirements chosen bythe DOE?7.The DOE is requested to show that adequate supplies of the materials produced within the UnitedStates exist to manufacture therequired transformers that will meet the transformer efficiencyrequirements chosen for the proposed changes from the existingtransformer efficiency requirements. If sources of materials are required from outside the United States, the DOE is requestedtoestimate what jobs will be lost and the dollar cost within the United States over the 30 year average and 60 year maximum lifeof thetransformers as compared to using materials available within the United States.8.Regarding the assumptions that the DOE made to use an averagedistribution transformer life of30 years in their transformerefficiency payback calculations; the IEEE Transformer committeein the various technical standards which apply to Distributiontransformers specifies an averagelife of 20.5 years. We recommend that the 20.5year average Distribution Transformer lifebe used bythe DOE in their payback analysis. How did the DOE arrive at the 30 year anticipated life?9.Regarding the payback times used by the DOE, the document 10CFR Part 431 was issued on October 12, 2007 to list the requiredefficiency levels for distribution transformers. On page 58220 of this document,various payback intervals between 5.1 and 21.6 years arelisted for the efficiencies chosen for this standard. In thePreliminary Technical Document (TSD):Energy Efficiency Program forCommercial and Industrial Equiptment :Distribution Transformersdated March 2011, pay back intervals are listed on page ES-16 TableES.2.7 for the various standard levels. The DOE is requested toexplain if these pay back intervals are based on a change fromtheexisting efficiency standard? If the change is from the existing efficiency standard, the DOE is requested to add the years ofpayback aslisted in 19CFR Part 431 to the years listed on the March 2011 document.10.The DOE used a 50% anticipated loading factor for the 30 year anticipated average life calculations used in their transformerefficiency evaluations. Whatis the source of the 50% loading factor used over a 30 year average and 60 year maximum expectedlife forthe transformers evaluated? The DOE is requested to consult the power companies to learn what load factors they expect fortransformers in service for up to 60 years.This item is very important, becauseas the loading level increases, the efficiency of anamorphous core design will decrease when compared to a silicon coredesign if they are both optimized to the same A and B factors. Theamorphous core design may have a the higherefficiency at a 50% averageloading but, this efficiency advantage will disappear as theaverage load increases and the silicon core steel designs becomemore efficient than the amorphous core steel designs when theyare bothoptimized to the same A and B factors.11.Regarding the payback intervals to be used by the DOE to selectthe efficiency levels to be recommended, the level of loading is basedon many assumptions that may change, a payback interval of 5 to 10 years is recommended to avoid forcing transformer purchasesbasedon changeable assumptions that likely will result in the longer paybacks never happening.12.Electric autos are expected to take an increasing percentage of the auto market.The July 2011 IEEE Power and Energy magazineestimates that in 5 years, 15% of the global new vehicle market will be electric autos. The DOE is requested to allow for theincreasedload factor for charging electric vehicles over the 60 year span they have chosen to consider for transformer loading.13.The DOE is requested to get in touch withMarketing and/or Business Development persons at the major auto manufacturers to learnwhat their projections are regarding the projected growth and market share for electricvehicles. What market share do these companiesproject for electric autos and how will thatadded load to the electrical systems affect the projected average loading over thenext 60years?14.For pole type distribution transformers, the higher efficiency designs used by the DOE to evaluate the transformer efficiencieshave avery significant increase in weight and also in transformer overall height. The DOE is requested to factor in the increased pole loadingand related need to replace existing poles insome cases to allow the mounting of theheavier pole type transformers. Some ofthe higherefficiency transformers will have a total weight of twice that of the existing transformer which is being replaced.15.The DOE is requested to change percentage efficiency targets to a method of controlling the transformer efficiency using the lowesttotal owning cost (TOC) optimized designs using TOC A and B factors written into law to controltransformer efficiencies. Theadvantage of using the TOC A andB factors to control transformerefficiency is that it allowsthe transformer quotations to respond tothe available materials. For example if copper conductors are required to meeta specified efficiency,transformer manufacturers wouldnot be able to quote if a flood cut off the copper supply. Usingthe TOC A and B factors, each manufacturer would be allowed to quote, ifthey used the correct A and B factors. Another example is if the customer prefers toraise the basic insulation level (bil) ofthe requestedtransformer design, the manufacturers will optimize to the specified bil using the correct A and B factors. The end result isthat thehigher bil would be just slightly less efficient than a lower bil because of the added insulationrequired to obtain the higherbasicinsulation level. I raised this question during the first meeting, but did not receive a response from the DOE about this subject , thereforeI am requesting that this subject be considered and responded to by the DOE before they proceed with the final rule making. Thetotalowning cost approach will handle the variations that occur withinthe industry and also result in a similar improvement in efficiency aswould transformer efficiency targets. Itwill allow the transformer efficiencies tobe increased as justified, using all thefactors they arecurrently using to create target transformer efficiencies. The DOE approach currently uses A and Bloss evaluation factors intheirevaluations of what transformerefficiencies are justified. The A and B loss evaluation factors could be written into the lawrather thanspecifying the transformer efficiencies.The law could require that all manufacturersonly quote total owning cost optimizeddesignsusing these A and B factors for all quotations,just as they are now forced to quote target efficiencies. The transformer manufacturerswould be required to maintain files showing they met the law by only quoting designs which were optimized using the A and B factorsaccording to the total owning cost method of reducing transformer losses. Utility companies havea familiarity with the TotalOwningCost approach to transformer purchases because they have routinely used the TOC method of obtaining efficient transformer designssince about 1980.Regards,Jerry CorkranStaff EngineerCooper Power Systems