The spreadsheet is attached this time. Sorry about that. 

Steve Rosenstock Manager, Energy Solutions Edison Electric Institute srosenstock@eei.org

202-508-5465 

From: Rosenstock, Steven Sent: Friday, September 30, 2011 9:56 AM To: Richard Parker; Corkran, Jerry L Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; john.caskey@nema.org; john.cymbals

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; bruce.r.

mhyland@appanet.org; dave.millure@metglas.com; Nadel, Steve; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.P

rroy@nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcoughlin@

gjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron; Daniel.Cohen@hq.doe.ggreg.coulter405@gmail.com; bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; ahofmann@publiBermanEconomics@gmail.com; Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.k

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider-electric.com; 

Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: 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 liquid filled units (fobased on the data from the consultant spreadsheets that EEI has reviewed and attached? The key parameters a

based on the data that was in the spreadsheets: Design Line 1:

Average 

 $ 

2,527.96 

 $ 

3,220.56 

 $ 

1,963.16 

Median 

 $ 

2,524.19 

 $ 

3,223.98 

 $ 

1,962.82 
Standard Dev 

 $ 

320.47 

 $ 

460.20 

 $ 

247.03 

CPI Inflation 2006-2010: 11.44% CPI Inflation 2007-2010: 7.98% 

% Inc based on Average 

Prices: 28.77% 

% Inc based on Median 

Prices: 28.60% 

Design Line 1 - Single-phase, Liquid-immersed Units, Rectangular Tank from 10 to 167kVA. 

Design Core Loss Coil Loss Coil Loss Mnf. Selling Mnf. Selling Mnf. Selling Weigh

Name (watts) @50% (watts) @100% (watts) Price (2010) 

 Price (hi - 

2008) 

 Price (lo - 

2006) (lbs) 

Design Line 2:

Average 

 $ 

 1,555.10 

 $ 

2,076.32 

 $ 

1,234.18 

Median 

 $ 

1,517.21 

 $ 

2,007.41 

 $ 

1,195.70 

Standard Dev 

 $ 

289.30 

 $ 

317.12 

 $ 

172.52 

CPI Inflation 2006-2010: 11.44% CPI Inflation 2007-2010: 7.98% 

% Inc based on Average 

Prices: 26.00% 

% Inc based on Median 

Prices: 26.89% 

Design Line 2 - Single-phase, Liquid-immersed Units, Round Tank from 10 to 167kVA. 

Design Core Loss Coil Loss Coil Loss Mnf. Selling Mnf. Selling Mnf. Selling 

Name (watts) @50% (watts) @100% (watts) Price (2010) 

 Price (hi - 

2008) 

 Price (lo - 

2006) 
Design Line 3:

Average 

 $ 

11,713.95 

 $ 

15,266.63 

 $ 

8,753.19 

Median 

 $ 

11,229.97 

 $ 

14,456.36 

 $ 

8,325.90 

Standard Dev 

 $ 

2,761.19 

 $ 

3,779.81 

 $ 

2,062.16 

CPI Inflation 2006-2010: 11.44% CPI Inflation 2007-2010: 7.98% 

% Inc based on Average 

Prices: 33.83% 

% Inc based on Median 

Prices: 34.88% 

Design Line 3 - Single-phase, Liquid-immersed Units, from 250 to 833kVA. 

Design Core Loss Coil Loss Coil Loss Mnf. Selling Mnf. Selling Mnf. Selling 

Name (watts) @50% (watts) @100% (watts) Price (2010) 

 Price (hi - 

2008) 

 Price (lo - 

2006) 

Design Line 4:

Average 

 $ 

7,040.12 

 $ 

9,084.95 

 $ 

5,333.47 

Median 

 $ 

6,685.38 

 $ 

8,550.78 

 $ 

5,048.23 

Standard Dev 

 $ 

1,229.00 

 $ 

1,656.06 

 $ 

902.86 

CPI Inflation 2006-2010: 11.44% CPI Inflation 2007-2010: 7.98% 

% Inc based on Average 

Prices: 32.00% 
% Inc based on Median 

Prices: 32.43% 

Design Line 4 - Three-phase, Liquid-immersed Units, from 15 to 500kVA. 

Design Core Loss Coil Loss Coil Loss Mnf. Selling Mnf. Selling Mnf. Selling 

Name (watts) @50% (watts) @100% (watts) Price (2010) 

 Price (hi - 

2008) 

 Price (lo - 

2006) 

Design Line 5:

Average 

 $ 

32,904.33 

 $ 

 42,291.34 

 $ 

24,487.23 

Median 

 $ 

31,180.18 

 $ 

40,691.92 

 $ 

23,708.52 

Standard Dev 

 $ 

5,713.25 

 $ 

6,885.12 

 $ 

3,920.24 

CPI Inflation 2006-2010: 11.44% CPI Inflation 2007-2010: 7.98% 

% Inc based on Average 

Prices: 34.37% 

% Inc based on Median 

Prices: 31.51% 

Design Line 5 - Three-phase, Liquid-immersed Units, from 750 to 2500kVA. 

Design Core Loss Coil Loss Coil Loss Mnf. Selling Mnf. Selling Mnf. Selling 

Name (watts) @50% (watts) @100% (watts) Price (2010) 

 Price (hi - 

2008) 

 Price (lo - 

2006) 

Steve Rosenstock Manager, Energy Solutions Edison Electric Institute 
srosenstock@eei.org

202-508-5465 

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

Sent: Wednesday, September 21, 2011 1:39 PM To: Corkran, Jerry L Cc: Caitlin Johnson; rick.anderson@faypwc.com; tballo@earthjustice.org; ScottB@lvmetals.com; john.caskey@nema.org; john.cymbals

adelaski@standardsasap.org; Teckman@nwcouncil.org; gbf1@pge.com; carlos.gaytan@ge.com; rgreeson@federalpacific.com; bruce.r.

mhyland@appanet.org; dave.millure@metglas.com; Nadel, Steve; wes.patterson@us.abb.com; Eric.Petersen@aksteel.com; Raymond.P

Steven; rroy@nrdc.org; robert.saint@nreca.coop; chuck.simmons@pgnmail.com; mark.stoering@xcelenergy.com; cabolduc@lbl.gov; kcgjrosenquist@lbl.gov; Michael Rivest; Jerry Hodge; jrossetti@mlgw.org; Jim.creevy@nema.org; Meyers, Aaron; Daniel.Cohen@hq.doe.g

greg.coulter405@gmail.com; bsmith@federalpacific.com; pkumar@publicpower.org; Trujillo, Antonio; Phil Hopkinson; ahofmann@publiBermanEconomics@gmail.com; Paul.Ryan@hitmet.com; jerry.schoen@aksteel.com; mwaltner@nrdc.org; kwinder@mleainc.com; chad.k

eduardorobles@eaton.com; vijay.tendulkar@onyxpower.com; carlosgsiqueiros@eaton.com; thomas.patzner@us.schneider-electric.com; 

Jeffrey A; Loomans, Michael T; Poole, Raymond L; Moore, Jack C; Smith, Jennifer 

Subject: 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 and suggestions. My apologies to all for the late notice on the Ground Rules. The 

rulemaking has us all scrambling, but we will do our best to get key docs to group well in advance of meetings in the future (requirements and resource limitations allow). Most of the ground rules document is boilerplate for negotiated rulemakings. about the parts that are not. But given your concern I will re-open the groundrules for online discussion, as needed, and clearemail thread. Would c.o.b Monday be reasonable deadline for comments on groundrules in your view, with aim of taking online poll towa

As for the deadlines for talks, the Dec 22 term sheet deadline can be altered by unanimous consent of the group, but you shoupractical deadline that results from working backwards from the Jan. 30 court deadline (assuming court approves revised sett

of what is in our ground rules, that will be the de facto deadline for meeting the court deadline unless and until the plaintiffs 
deadline. 

Your substantive comments are appreciated. I will consult with DOE/Navigant/LBL staff and develop a joint preliminary re

online is some appropriate format for further review and comment. All best, Richard Parker On Tue, Sep 20, 2011 at 3:57 PM, Corkran, Jerry L <Jerry.Corkran@cooperindustries.com> wrote: 

I am submitting following items for requests for investigation by the DOE. Some of the questions listed below were pfirst meeting, but I have not received sufficient information to answer the questions and requests listed below:

1. A good portion of the recent meetings were concerned with the review and revisions of the ground rules 

Rulemaking Working Group. A copy of this document was issued dated as “Final 9/15/11” during the secoconcerned and puzzled about why a legal document of this type was not issued well in advance of the workdocument has a legal tone and application that makes its review beyond my capabilities to determine if it igroup and its suitability for me to accept w/o reservations. I have submitted it to a Cooper Power Systems 

determine if it requires changes before agreeing to its content. I am objecting to the Sept. 23 deadline for cthis item and request that we be able to submit input on suggested changes after out attorney has an oppor

 At this time I am objecting to the “4. Agreement” rule with details of the objection or withdrawal of my o

attorney reviews the document. I also object to the 3 d. Deadline for Negotiations to terminate at Dec. 22, 

determined by the working group during the third meeting in Nov. after the working group has a knowled

complete the process. 2. Would the DOE provide the actual design information for the least-cost transformer designs? Sufficie

included to allow the transformer manufacturers to compare the same design created on their programs to 3. Would the DOE request transformer design quotations from multiple manufacturers for the transformDOE considers buildable? This would provide the DOE with actual designs which the manufacturers are designs could be compared to the designs which the DOE is currently using to generate the efficiency data 
4. Would the DOE request quotations from multiple manufacturers optimized for the lowest total owning 

that they are considering. The evaluation A and B factors would vary by a 4:1 ratio to reflect a maximum 

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 to it lower losDOE transformer designs indicates that there might be a 700% increase in usage of the amorphous core stproduction of this material. The DOE is requested to create projections listing what price increases and mexpected if the use of this material is forced by transformer efficiency rules that dictate its use.

6. Because there is only one major supplier of amorphous core steel in the world that meets the efficiency 

optimizations, which is Hitachi in Japan and Metglas in the US (which is owned by Hitachi); is it legal for DOE’s suggestion, forcing the exclusive use of this material in Distribution Transformers to meet the efficithe DOE?7. The DOE is requested to show that adequate supplies of the materials produced within the United State

required transformers that will meet the transformer efficiency requirements chosen for the proposed chatransformer efficiency requirements. If sources of materials are required from outside the United States, testimate what jobs will be lost and the dollar cost within the United States over the 30 year average and 60 

transformers as compared to using materials available within the United States.

8. Regarding the assumptions that the DOE made to use an average distribution transformer life of 30 yea

efficiency payback calculations; the IEEE Transformer committee in the various technical standards whictransformers specifies an average life of 20.5 years. We recommend that the 20.5 year average Distributio

the 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 10 CFR Part 431 was issued on October 

efficiency levels for distribution transformers. On page 58220 of this document, various payback intervals 

listed for the efficiencies chosen for this standard. In the Preliminary Technical Document (TSD):Energy Commercial and Industrial Equiptment :Distribution Transformers dated March 2011, pay back intervals 

ES.2.7 for the various standard levels. The DOE is requested to explain if these pay back intervals are basexisting efficiency standard? If the change is from the existing efficiency standard, the DOE is requested tlisted 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 us

efficiency evaluations. What is the source of the 50% loading factor used over a 30 year average and 60 ye

the transformers evaluated? The DOE is requested to consult the power companies to learn what load factransformers in service for up to 60 years. This item is very important, because as the loading level increaamorphous core design will decrease when compared to a silicon core design if they are both optimized to 

amorphous core design may have a the higher efficiency at a 50% average loading but, this efficiency advaaverage load increases and the silicon core steel designs become more efficient than the amorphous core stoptimized to the same A and B factors. 11. Regarding the payback intervals to be used by the DOE to select the efficiency levels to be recommende

on many assumptions that may change, a payback interval of 5 to 10 years is recommended to avoid forcin

on 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 Pestimates that in 5 years, 15% of the global new vehicle market will be electric autos. The DOE is requesteload factor for charging electric vehicles over the 60 year span they have chosen to consider for transform13.The DOE is requested to get in touch with Marketing and/or Business Development persons at the majwhat their projections are regarding the projected growth and market share for electric vehicles. What mproject for electric autos and how will that added load to the electrical systems affect the projected averag

years?14.For pole type distribution transformers, the higher efficiency designs used by the DOE to evaluate the t

very significant increase in weight and also in transformer overall height. The DOE is requested to factor 

and related need to replace existing poles in some cases to allow the mounting of the heavier pole type tran

efficiency transformers will have a total weight of twice that of the existing transformer which is being rep

15.The DOE is requested to change percentage efficiency targets to a method of controlling the transform

total owning cost (TOC) optimized designs using TOC A and B factors written into law to control transfor

advantage of using the TOC A and B factors to control transformer efficiency is that it allows the transfor

the available materials. For example if copper conductors are required to meet a specified efficiency, trannot be able to quote if a flood cut off the copper supply. Using the TOC A and B factors, each manufacturthey used the correct A and B factors. Another example is if the customer prefers to raise the basic insulat
transformer design, the manufacturers will optimize to the specified bil using the correct A and B factors. 

higher bil would be just slightly less efficient than a lower bil because of the added insulation required to o

insulation level. I raised this question during the first meeting, but did not receive a response from the DOI am requesting that this subject be considered and responded to by the DOE before they proceed with the owning cost approach will handle the variations that occur within the industry and also result in a similar would transformer efficiency targets. It will allow the transformer efficiencies to be increased as justified

currently using to create target transformer efficiencies. The DOE approach currently uses A and B loss eevaluations of what transformer efficiencies are justified. The A and B loss evaluation factors could be wrspecifying the transformer efficiencies. The law could require that all manufacturers only quote total own

using these A and B factors for all quotations, just as they are now forced to quote target efficiencies. The 

would be required to maintain files showing they met the law by only quoting designs which were optimiz

according to the total owning cost method of reducing transformer losses. Utility companies have a familiCost approach to transformer purchases because they have routinely used the TOC method of obtaining esince about 1980. 

Regards,

 Jerry Corkran

Staff EngineerCooper Power Systems