1 9/26/11

Howard Industries Inc. Comments for Med. Voltage DOE Negotiating Committee

The following are my comments related to evaluating DOE Transformer Efficiency Levels for Liquid Immersed Distribution Transformers.

As a manufacturer of liquid i mmersed distribution transformers, I wish to submit the following comments.

At this time, we don’t see a need for any changes to the Negotiated Rulemaking Working Group “Ground Rules” document.

Howard Industries doesn’t have a problem related to the DOE Distribution Transformer Efficiencies remaining the same as they are defined now or increasing to some new higher values as long as there is an adequate supply of copper, aluminum, high grades of silicon core iron and a sizable capacity of amorphous core iron. The users must be able to handle the increases of weight, size and cost if these efficiencies are increased.

DOE needs to give special consideration to the following:

1. Network Transformers

-- Size and weight are very important elements when speci fying these types of units. We must use reason and common sense so that what we manufacture will fit into the constraints that exist. Some extra efficiency tolerance would be very helpful. We want to avoid the customer’s use of rebuilt

transformers.

2. Sub station Transformers -- Again, some of these units will be space constrained and we must have some leeway to satisfy the requirements.

3. Round/Rectangular Submersible Transformers

-- Most of these units are for

retro -fit purposes where the vault or enclo sure already exists. We need some way to satisfy our customer’s requirements without forcing him to use re- built

transformers.

4. On Series/Multiple Primary Voltage Transformers, the DOE transformer efficiency requirements should be based on the highest voltage, which is the voltage that is most used during the life of the transformer.

5. On the secondary voltage of the transformer, the DOE transformer efficiency

should be based on the series connection such as 240 v for a 120/240 v sec. and 480 v for a 240/480 v or 240 x 480 v sec. etc.. Over 90% of these types of secondary voltage ratings are used in this series configuration.

6. DOE’s Design Line 4 should at least be based on a 14,400 v primary voltage as are design lines 1, 2, 3 & 5. The use of 19,920 v primary voltage or possibly even 7200 x 19,920 v, series/multiple would be even more appropriate for design lines2 1 thru 5. Keep in mind, that as a manufacturer, we must design to meet these DOE Efficiencies on all ratings from 60 kv to 200 kv BIL.

7. DOE/Navigan t should consider all of our comments that we sent them from their Manufacturers Impact Analysis Interview at our plant in June, 2011.

8. We think that the “Symmetric Core Technology” should be eliminated from consideration for liquid immersed distribution tr ansformers since it was stated at the 9/15/11 committee meeting that there are no domestic manufacturers using this technology.

9. We think the use of 32 years as the average life of a transformer is too high. ANSI Stds. uses life spans of approx. 20 to 24 y ears which is much more realistic.

10. Using electricity to charge the batteries of automobiles will affect the loading factors of transformers in the years to come. Within the next 10 years, there will

be a substantial number of these PLUG- IN type of cars on the road and they will have to use our existing electric power distribution systems to recharge them. We need to keep in mind that this will affect the loading of transformers.

11. As Efficiency levels go up on new transformers, the re-built or re- manufacture market will also go up. There are no DOE efficiency requirements of these types of transformers and certain utilities will more seriously consider the use of them, especially where space or weight constraints are involved. This loophole will

need to be looked at by DOE.

12. Some utilities may take another look at their loading practices and possibly adjust them upward which could negate the possible energy savings that is projected by the efficiency rule.

In our committee meeting on 9/15/11, DOE/Navigant mentioned that they had some errors in their oil quantities related to the optimizing. It would help us if we knew the magnitude and impact of these errors. Did the errors affect weight, dimensions and cost/price? When was this type of error found and have all errors been corrected such that their present analysis of efficiencies is based on good optimizing runs? Were these errors corrected before our existing efficiency rules took effect? We just need a better understanding of this situation. We would like to know if DOE has a high degree of confidence in their optimizing results, such that they know that their final efficiencies are

accurate. Our calculations and analysis shows much higher incremental prices as the CSL levels

are increased. We ar e concerned that possibly the use of the “OPS” optimizing system by DOE may not be accounting for all costs involved. We are also unsure about the accuracy of their Life Cycle Costs and Payback Periods. We must be careful in negotiating new efficiency lev els based on information and data that may have a number of inaccuracies.

We agree that the new DOE Final Efficiency Rule should be such that the existing major core iron manufacturers can participate. The single sourcing of core iron would be detrimental to the entire distribution transformer industry in the United States.

Comparison analysis of core material must include weight and size of the product, material cost, & availability plus, for amorphous cores, look at any additional fabrication3 costs and the possibility of large capital outlays for manufacturing these amorphous cores that could possibly impact smaller transformer manufacturers.

Sincerely;

Gerald Hodge Consultant,

Howard Industries Inc.